COUNTY OF RIVERSIDE

ENVIRONMENTAL ASSESSMENT FORM: INITIAL STUDY

Environmental Assessment (CEQ / EA) Number: CEQ_____
Project Case Type (s) and Number(s): Conditional Use Permit CUP230002
Lead Agency Name: County of Riverside Planning Department
Address: 4080 Lemon Street 12th Floor, Riverside, CA 92501
Contact Person: Krista Mason, Project Planner
Telephone Number: 951-955-1722
Applicant’s Name: Hamid Haque on behalf of Muslim Mortuary and Cemetery Committee
Applicant’s Address: 13121 Brookhurst Street, Suite C, Garden Grove, CA 92843

I. PROJECT INFORMATION

The Muslim Mortuary and Cemetery Committee (Applicant) proposes to construct the Crescent Garden
Cemetery (Project) consisting of an approximately 20,000-plot cemetery, with support facilities including
a ceremonial cleansing facility for washing the body prior to burial, a chapel, a caretaker's residence,
an equipment shed, and associated roads, utilities and landscaping in three phases over 15 years on
46.4 acres of 84.99 acres over 21 parcels at the end of Garfield Road in the community of
Meadowbrook. No crematorium is proposed as a part of this Project as burials will follow Muslim‘s
ceremonial traditions, and an estimated 10 to 15 burials may be performed per month. The Project Site
is composed of 21 assessor parcels, and no lot line or parcel merger is proposed. Refer to Figure 1 -
Regional Vicinity; Figure 2A – Project Site Parcels; and Figure 3 - Project Site USGS View, located
at the end of this section.

The Muslim Mortuary and Cemetery Committee (MMCC) is an independent non-profit organization,
licensed by the State of California Cemetery and Funeral Bureau, providing Islamic burial services to
over 5,000 families through established cemeteries in Anaheim, Westminster, LaVerne, and Colton
since 1991. The MMCC office is located in Garden Grove and staffed with a dedicated Funeral Director.
Its operations rely on highly trained staff and volunteers to provide funeral services in accordance with
the Islamic practices. Each of the existing cemeteries are smaller, with between 100 and 1,250 burial
plots. The existing cemeteries cannot be expanded, and a new cemetery, more centrally located in
Southern California that can provide a long-term solution for burial and funeral services, is needed. The
MMCC proposes this Project to provide a long-term solution for burial services for the Muslim
community of Southern California.

GENERAL PROJECT FEATURES

Phased Development: Site development is planned in three phases over 15 years (Figure 4A –
Phasing Plan), although the facility would be developed over time as finances allow.

Overall, the Project would develop 46.4 acres of the 84.99 acres over 21 parcels, leaving approximately
38.6 acres of undeveloped terrain. Figure 4B – Open and Developed Areas shows the concept plans
for the site and areas within the approximately 85-acre site that would be developed and undeveloped.
Within the undeveloped area is approximately 10.6 acres as the future right-of-way for Theda Street
that will not be developed by the Project but may or may not be developed by the County of Riverside.
The Project does not propose any grading or development in the future right-of-way for Theda Street.
Appendix J – Project Plans provides the full plan set.

On-Site Facilities. The Project proposes to ultimately develop 46.4 acres of on-site improvements in
phases including an approximately 5,559 square foot (SF) single story Ceremonial Cleansing Facility
(CCF) , a two-story approximately 11,079 SF chapel, an approximately 2,090 SF two-story caretakers
residence, an approximately 1,358 SF equipment shed, interior roads, 24.6 acres of level burial plots,

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landscaping and irrigation, an on-site septic system, four water quality/detention basins, and associated
utilities. Refer to Figure 5A and Figure 5B - Building Elevations and Profiles for details on the
buildings. However, improvements may be shifted between phases depending on funding availability
and overall site need. Figures 6A, 6B and 6C provide visual renderings of the proposed facilities.

Access and Private Interior Roads/Paths. The Project's main entry is at the eastern terminus of
Garfield Road near the western boundary of the Project Site and will serve as the single point of entry.
The main entry, which is within the Project’s private property boundary, has a queue for a minimum of
two vehicles if the entry gate is closed, and a cul-de-sac area in the public right-of-way of Garfield Road
to allow non-guests an opportunity to turn around. The entry gates are planned to be open from dawn
to dusk, and a guard house would be available at the entry gate. The Garfield Road entry leads directly
into the facility’s parking lot to easily accommodate guests in either the parking lot or the cemetery
interior private roadways, therefore, there would be no traffic backing up onto Garfield Road or parking
on the residential streets. The private interior roads of the cemetery are planned to be approximately
24 feet to 32 feet wide and designed to provide additional parking on the sides for use by mourner’s
families who visit to pay homage to their loved one. The interior private roads would be asphalt
pavement with stabilized decomposed granite along each side for additional parking and pathways. The
private roadways have also been designed in accordance with the requirements of the Riverside County
Fire Department’s, which approved the Project design on December 12, 2024.

Site Security, Fencing and Lighting. Site security consists of a wrought iron fence that would be
placed along the western property boundary of the site, as well as a wrought iron gate at the entry.
Chain link fencing will surround the north and south boundaries of the property. Chain link fencing along
the east perimeter will follow the limits of grading and landscape improvements to allow for the existing
regional trail network to cross onto the property, outside of the fence line, and continue off-site.
Temporary construction fencing would be placed around the construction areas during the various
phases of construction. Lighting is only planned for the parking lot and building areas and would
shielded and be of the type that would not cause lighting to spill off-site. No lighting is planned for the
cemetery grounds. Figure 7 – Photometric Analysis identifies that the light would not be intrusive or
spill off site. Cemetery operations would occur from dusk to dawn. Any minimal nighttime lighting would
be for the caretaker residence and would be what is minimally necessary for security lighting. The
nighttime security lighting will consist of low energy LED lamps at the entry gates, guard station, wall
scones on the CCF, Chapel buildings, and caretaker residence entrance and a LED light at the
equipment shed entry.

Landscaping Design. Overall, the landscape plan provides for approximately 1.8 acre of irrigated
landscaping to be installed consisting of shrubs, groundcover and trees that are moderate to very low
water usage. Refer to Figure 8A – Landscape Plan. Following the grading, the areas used for burial
would follow stormwater control measures or may be hydroseeded with native vegetation and temporary
on-grade irrigation may be placed after grading to control erosion. Burial plots would be developed as
needed. The finished burial plots would consist of white stones placed on top of each plot, with poured
concrete bands around each of the plots that are approximately 3.5-foot by 8-foot each, oriented
perpendicular to the direction of Mecca, Saudi Arabia. Figure 8B – Typical Burial Section provides a
schematic of a typical burial plot, along with a sample finished plot area currently in place at the
Westminster Memorial Park and Mortuary, which would be similar to the plots to be developed on the
Project Site. Trees planned for the entry include fruitless olive and date palm, while the interior roads
and pathways would be lined with accent trees such as Palo Verde and Marina Strawberry, and shade
trees such as Jacaranda, Australian willow, evergreen Chinese Elm and Coast Live Oak. The water
quality/detention basin slopes and portions of the bottoms will be planted with live groundcovers,
grasses and shrubs in accordance with the County of Riverside standards.

Water Quality/Detention Basins. Proposed water quality/detention improvements have been

designed in accordance with the County of Riverside’s design criteria. A Water Quality Management
Plan (WQMP) has been prepared and approved by the County on September 19, 2024 (refer to

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Appendix F-2). Drainage runoff from the improved site will be collected in a series of surface and
underground drainage facilities and conveyed to the four proposed water quality/detention basins or to
a modular wetland system before exiting to existing natural channels.

. The proposed drainage facilities are designed to convey the 100-year peak flow generated in the
watershed under post-project conditions, reduce the 10-year post-project runoff to less than pre-project
conditions, and to mitigate water quality and hydromodification impacts of the proposed development.
The Project includes rip-rap pads and/or energy dissipators to reduce flow velocities to less than 6 fps
at all points of discharge to natural streams.

Operations and Staffing. All operations of the cemetery site would comply with the California Cemetery
and Funeral Bureau regulations and requirements for licensing. The Crescent Garden Cemetery facility
anticipates approximately 10 to 15 funeral services per month. Assuming an average of 20 visitors per
funeral service, the expected total initial visitors are not anticipated to exceed approximately 300 people
per month. The Crescent Garden Cemetery would operate from dawn to dusk, seven days per week,
and be staffed by three full-time employees, consisting of a licensed Funeral Director, an operations
manager who will also serve as a clergy, and a groundskeeper for maintenance.

The cemetery employs a “natural burial” process which is used in various parts of the world and
minimizes the impact on the environment by allowing for a poignant return to the earth. The natural
burial process has been successfully used by the MMCC (Applicant) over the past 30 years at the other
four Southern California cemeteries (Westminster Memorial Park, Melrose Abbey-Anaheim, LaVerne
Memorial Park, and Montecito).

The natural burial process does not use embalming chemicals or formaldehyde, nor does it include
placing the deceased in a casket, both of which processes can leach harmful chemicals into the soil
over time. Instead, in summary, the deceased is washed with natural soap and water, wrapped in a
cotton shroud cloth, and placed directly on a bed of gravel in a subgrade vault. The burial generally
occurs within 24 hours of death to ensure that the deceased body is handled prior to decomposition.

The natural burial practice to be employed at the Crescent Gardens Cemetery would include the
following:

• Washing: This occurs in the Ceremonial Cleansing Facility. The deceased is ritually washed
with soap and water, a process known as ghusl or tajheez. This would be done as soon as
possible after death. No chemicals or embalming fluids are utilized. The water from the cleansing
is estimated to be approximately 20 gallons per body. The body washing would occur within a
designated room of the Ceremonial Cleansing Facility that has a floor drain that would be
connected to a below ground storage tank that is separate from the septic system. This separate
tank would be emptied by a licensed wastewater/septic hauler. The MMCC staff would work with
the family of the deceased to schedule and coordinate the required washing of the body. In
addition, traditionally the family members of the deceased usually participate in performing the
body wash.

• Shrouding: The deceased is wrapped in a white cloth, a process known as kafan or takfeen. The
number of pieces of cloth used depends on the deceased's gender, with men typically using
three and women using five.

• Other stages of the funeral include funeral prayers, known as salat al-janazah or janazah salah,
and a procession to carry the body to the gravesite. The prayers would most likely occur at the
gravesite until the chapel is constructed, when prayers may be held at either the graveside or
the chapel.

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 Burial: The deceased is buried as soon as possible, usually within 24 hours but no more than
three days, in a designated plot that has been developed for the individual. The deceased burial
plot is designed to face Mecca, Saudi Arabia, one of the holiest places of Islam. The burial plots
are designed to be deep enough to prevent odor from escaping and to keep animals from
compromising the grave. Plot development consists of excavating a rectangle shape in the earth
that would be approximately 5 feet deep 3 feet wide. A four-sided concrete vault with a gravel
bottom would be placed in the excavated space. The body would be placed in the concrete vault,
and a concrete lid would be placed on top of the vault. Approximately 18 inches of soil would be
placed on the top of the lid. White-colored stones are then placed over the plot, along with a
headstone.

Burial plots would be developed as needed. Once a row of plots are filled, the row is finished with
concrete bands that would surround each plot. A typical vault detail and photo of a sample of finished
plots is in Figure 8B. Excess soil from plot development would be stored in an area of a future phase.

Off-Site Improvements

The project proposes the following off-site improvements:

• Garfield Road would end as a proposed cul-de-sac west of the entry gates of Crescent Gardens
cemetery. The proposed cul-de-sac will be dedicated to the County as a public facility. Proposed
improvement would include paved road curb to curb, parkway and sidewalk that support fire
department vehicle turning radius requirements.

• The Project has been designed to avoid encroachment into Theda Street, a future north-south
roadway planned by the County with 100-feet wide right-of-way, which lies along the eastern
side of the cemetery and which would bisect a portion of the proposed Phase 1 and Phase 3
cemetery grounds. No improvements would be constructed by the Project in proposed Theda
Street right-of-way.

• Per Environmental Justice discussions a proposed Bus Shelter will be provided within the
Meadowbrook Community somewhere along Highway 74 or a similar location.

Utilities

• Water: Water will be supplied by the Elsinore Valley Municipal Water District, which provided a
letter agreeing to serve the Project provided that the Applicant provide a line extension
(Appendix I). As such, the Project would replace an existing 4-inch water line with an 8-inch
water line that will be extended approximately 1,600 linear feet from the Project Site at Garfield
Road, extending to Jarvis Street, then north along Jarvis Street, and to a point of connection at
an existing 8-inch domestic water line near Senola Avenue per Elsinore Valley Municipal Water
District.

• Sewer: Municipal sewer infrastructure does not exist in the Project vicinity. Therefore, the Project
would install a septic system where each building would have its own individual Onsite Waste
Treatment System (OWTS) systems. The OWTS design includes storage septic tanks, draining
into chamber leach lines. The OWTS system was reviewed and approved by the Riverside
County Department of Environmental Health Services on October 28, 2024.

CONSTRUCTION PHASING

Site development is planned to occur in three phases over 15 years (Figure 4A), as identified below,
although the grounds and facilities would be developed as finances allow and in accordance with

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grading and stormwater control plans. Cemetery grounds and facilities planned in Phase 1 are
anticipated to be completed first, in approximately 12 months, although the actual development
schedule would depend on available finances. Phase 1 grading provides soil balancing of cuts and fills
so no soil import is anticipated; Phases 2 and 3 will require import of fill material. Therefore, future
phases would be constructed in smaller sections periodically as fill soil becomes available. It is the
intent that as fill material becomes available, it would be either stockpiled on site for use in the next
phase, or it would be stockpiled and used to construct smaller areas in the future phases, based on the
amount of soil available.

PHASE 1: YEAR 1

Overall, Phase 1 would include the construction of all interior roads, the ceremonial cleansing facility
with parking, a care takers residence, equipment shed, three water quality/detention basins,
approximately 7.8 acres of cemetery grounds, and associated landscaping, lighting and utilities as
described herein.

Cemetery Grounds: Approximately 7.8 acres of cemetery land would be developed east and southeast
of the chapel site and offer a projected 6,230 plots. All the earthwork in Phase 1 consists of a cut and
fill designed to balance, therefore, there would be no import or export of material. The individual plots
would be developed on an as needed basis, therefore, only the main Phase 1 area would be graded.

Entry Area/Hardscape. Patrons to the cemetery will enter from Garfield Road, a public road, where a
cul-de-sac will be constructed. The entry is designed as a focal point for the cemetery, with the CCF,
caretaker’s residence, and a 145-space parking area to serve funeral services situated on the north
side, and the chapel situated along the south side. While the CCF and the 2,090 SF caretaker’s
residence with equipment shed and parking lot would be constructed as part of Phase 1, only a 6,974
SF footprint pad for the chapel would be established, and the chapel building would be constructed at
a later date. Graveside services would be held until the chapel is constructed.

Wrought iron entry gates and wrought iron fencing would be installed along the western property
boundary. Chain link fencing would surround the north and south boundaries of the property. Chain
link fencing along the east perimeter will follow the limits of grading and landscape improvements to
allow for the existing regional trail network to cross onto the property, outside of the fence line, and
continue off-site.

Also as part of Phase 1, the Applicant would improve two existing dirt driveways with decomposed
granite that are located along Garfield Road, on the western edge of the Property. One benefits the
residence to the north (APN 349-170-001) and one benefits the residence to the south (APN 349-180-
034). An access easement would be provided through the Project site’s southern boundary for the
existing dirt road which is used by the residence located at APN 349-180-026.

Stormwater Improvements: Proposed stormwater improvements include storm drain conduits, catch
basins, concrete ditches ang gutters, and four water quality/detention basins. Three of the four water
quality/detention basins would be constructed as part of Phase 1: One approximately 4,384 SF water
quality/detention basin located north and east of the parking lot, and one approximately 4,928 SF basin
on the southeast parking lot, and one approximately 17,513 SF basin near southeast corner of the
Project Site east of the Theda Street right-of-way.

Ceremonial Cleansing Facility (CCF). The approximately 5,559 SF CCF would be located near the
entrance at Garfield Road and is designed for burial preparations and small family-oriented gatherings
as needed. It also will provide temporary offices to support making funeral and burial arrangements,
including religious services ancillary to the CCF, with family attendance. A crematorium is not planned
for the CCF. Services would be held graveside until the chapel is constructed, and the interior roads
are designed to accommodate parking adjacent to the gravesite areas.

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The CCF would consist of a body washing and preparation area, an office, a conference room, a viewing
room, and a religious service area which is dedicated to CCF use only. The building is designed with
separate air circulation controls between the body preparation room(s) and the offices/service/viewing
area. The cleansing rooms have separate self-contained drainage systems that flow into an
underground tank, separate from the on-site sewerage treatment system, where the used wash water
would be pumped for disposal by a licensed hauler.

The CCF building would be one story structure in Mediterranean architectural style using a regional
take on modernism. The proposed building sits on a 2 feet high podium with entrances from the parking
lot. The building design utilizes large-format porcelain tiles, natural wood, and arch windows to contrast
with smooth white cement plaster. The colors & building materials utilize a neutral and natural color
palate. An emphasis on natural light is created through large arch window openings that wrap around
the entire building, producing well-lighted interior spaces. The building systems are designed with
sustainability in mind, including high-efficiency HVAC, low-flow plumbing fixtures, infrastructure for solar
panels, and LED lights resulting in a 53 percent lighting reduction below the energy code minimum.

Equipment Shed. The approximately 1,358 SF shed will house cemetery grounds supplies and
equipment such as a backhoe.

Landscape. Landscaping would be complete for all areas of Phase 1. The CCF and chapel area are
designed with fire resistant plants and grasses while the interior roads would be lined with various trees,
and sloped areas not used for gravesites would be low-water use groundcovers and shrubs. The
species of plants to be utilized, and their placement, are consistent with the requirements for a project
that is located in a Very High Fire Hazard Zone.

Interior Roads (Private). Three, private, interior roadways would be established to connect the CCF
and chapel area with the Phase 1 cemetery grounds. “A” Street, the primary entrance to the grounds
from the CCF, would be approximately 2,435 feet long, traversing east-west, and ending in a cul-de-
sac within the eastern portion of Phase 1. “B” Street would be approximately 788 feet long, traversing
generally north-south, ending with its intersection with “A” Street. “D” Street is designed to be
approximately 382 feet long, and traverse east-west along the southern portion of the Phase 1 grounds.

Utilities: The Project would install two septic systems on site to serve employees and visitors. The
septic tanks and leach fields would be installed in suitable locations designed to serve the chapel, CCF
and caretaker residence and connect to the leach fields. Additionally, the Project would establish its
water service by replacing an existing 4-inch water line with an 8-inch water line that will be extended
approximately 1,600 linear feet from the Project Site at Garfield Road, extending to Jarvis Street, then
north along Jarvis Street, and to a point of connection at an existing 8” domestic water line near Senola
Avenue per Elsinore Valley Municipal Water District.

Off-Site Road Improvements. Improvements to Garfield Road including developing the cul-de-sac
with curb and gutter and streetlights.

PHASE 2: YEAR 2 THROUGH YEAR 10

Cemetery Grounds: Approximately 9.9 acres of cemetery land would be developed northeast of the
chapel area and offer approximately 6,500 plots. Site work requires a cut of approximately 18,500 cubic
yards, and fill of approximately 49,000 cubic yards, for a total fill import of approximately 30,500 cubic
yards. Because of the fill soil requirement, it is anticipated that the 9.9 acres would be developed in
subphases, with development dictated by the amount of soil available. As the imported soil becomes
available from regional sources, it would be stockpiled in the southern portion of the site. Smaller
sections of the Phase 2 area would be developed in consultation with a licensed civil engineer and
County grading permits.

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Chapel. The two-story approximately 11,079 SF, chapel would be located south of the entrance at
Garfield Road, south of the CCF, and is designed for family-oriented gatherings to celebrate the life of
the deceased. It will provide permanent offices to support making funeral and burial arrangements,
including religious services ancillary to the CCF, with family attendance. The chapel building would be
one-story and similar in architecture to the CCF in that it would utilize large-format porcelain tiles, natural
wood, and arch windows to contrast with smooth white cement plaster. The colors & building materials
utilize a neutral and natural color palate. An emphasis on natural light is also created through large arch
window openings that wrap around the entire building, producing well-lighted interior spaces. The
building systems are designed with sustainability in mind, including high-efficiency HVAC, low-flow
plumbing fixtures, infrastructure for solar panels, and LED lights resulting in a 53 percent lighting
reduction below the energy code minimum.

Caretaker Residence: The approximately 2,090 two-story caretaker’s residence with a 400 SF garage
would be standard single-family residential construction, also with a Mediterranean style. The residence
would be located just east of the CCF.

Landscape. The interior roads would be lined with various trees, and sloped areas not used for
gravesites would be low-water use groundcovers and shrubs.

Stormwater Improvements: Proposed stormwater improvements include storm drain conduits, catch
basins, concrete ditches and gutters and one approximately 1,625 SF water quality/detention basin
located in the northeast portion of the cemetery.

Interior Roads (Private). Two private interior roadways would be established to connect the CCF and
chapel to the northern portion of the cemetery grounds. “B” Street would be approximately 1,781 feet
long, connecting with the intersection of “A” and “B” streets from Phase 1, continuing north along the
western side of the Phase 2 grounds. At the northernmost boundary, it will connect with “C” Street and
traverse approximately 1,434 feet south along the east side of the Phase 2 grounds, to the connection
with “A” Street in the Phase 1 area. “E” Street, approximately 391 feet long would traverse east-west,
in the center of the grounds, connecting “B” Street on the west and “C” Street on the east.

PHASE 3: YEAR 11 THROUGH YEAR 15

Cemetery Grounds: Approximately 7.2 acres of cemetery land would be developed east of the
CCF/chapel area and offer approximately 5,900 plots. Site work requires a cut of approximately 17,000
cubic yards, and fill of approximately 91,000 cubic yards, for a total fill import of approximately 74,000
cubic yards. Because of the fill soil requirement, it is anticipated that the 9.9 acres would be developed
in sub-phases, with development dictated by the amount of soil available. As the imported soil becomes
available from regional sources, it would be stockpiled in the southern portion of the site. Smaller
sections of the Phase 3 area would be developed in consultation with a licensed civil engineer and
County grading permits.

Landscape. The interior roads would be lined with various trees, and sloped areas not used for
gravesites would be low-water use groundcovers and shrubs.

Interior Roads (Private). There will be no roads constructed in Phase 3. Roads will have been
constructed in Phases 1 and Phase 2.

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 A. Type of Project: Site Specific ; Countywide ; Community ; Policy .

B. Total Project Area:

Residential Acres: Lots: Units: 0 Projected No. of Residents:

Commercial Acres: Lots: Sq. Ft. of Bldg. Area: Est. No. of Employees:
Industrial Acres: Lots: Sq. Ft. of Bldg. Area: Est. No. of Employees:
Other: Cemetery Lots: 21 Sq. Ft. of Bldg. Area: 20,086 Est. No. of Employees: 3

C. Assessor’s Parcel No(s): Refer to Table 1: Project APN Listing for the complete list of parcels
and their proposed uses. The parcel locations are graphically represented on Figure 2A, and
their respective zoning is represented on Figure 2B – Zoning and Land Use.

Page 8 of 146 CEQA – Crescent Gardens

 Table 1: Project APN Listing

Parcel
APN Proposed Project Use General Plan Land Use Zoning
Acreage
349-170-003 6.36 Cemetery Grounds VLDR RR
349-170-004 5.23 Cemetery Grounds VLDR RR
349-170-005 5.28 Cemetery Grounds VLDR (western portion) RR
and RM (eastern portion)
349-170-006 5.28 Cemetery Grounds (1) VLDR (western portion) RR
and RM (eastern portion)
349-170-007 3.82 Chapel, CCF, Parking, VLDR RR
Landscaping, Caretakers
residence, equipment shed
349-170-008 4.46 Open Space VLDR RR
349-170-009 4.46 Chapel, CCF, Parking, VLDR RR
Landscaping, Caretakers
residence, equipment shed
349-170-010 4 Chapel, CCF, Parking, VLDR RR
Landscaping, Caretakers
residence, equipment shed
349-170-011 4 Open Space / Caretaker VLDR RR
Residence
349-170-012 3.82 Chapel, CCF, Parking, VLDR RR
Landscaping, Caretakers
residence, equipment shed
349-170-013 5.23 Cemetery Grounds (1) VLDR (western portion) RR
and RM (eastern portion)
349-180-002 5.01 Chapel, CCF, Parking, VLDR RR
Landscaping, Caretakers
residence, equipment shed
349-180-004 5.03 Cemetery Grounds (1) RM RR
349-180-005 5.01 Chapel, CCF, Parking, VLDR RR
Landscaping, Caretakers
residence, equipment shed
349-180-006 3.99 Chapel, CCF, Parking, VLDR RR
Landscaping, Caretakers
residence, equipment shed
349-180-007 4.53 Chapel, CCF, Parking, VLDR RR
Landscaping, Caretakers
residence, equipment shed
349-180-008 0.45 Chapel, CCF, Parking, VLDR RR
Landscaping, Caretakers
residence, equipment shed
349-180-016 4.37 Chapel, CCF, Parking, VLDR RR
Landscaping, Caretakers
residence, equipment shed
349-180-017 0.45 Chapel, CCF, Parking, VLDR RR
Landscaping, Caretakers
residence, equipment shed
349-180-020 2.21 Cemetery Grounds (1) RM RR
349-180-035 1.99 Roads and Landscaping (public road) N/A

Notes:
(1) Slopes greater than 25 percent will not be developed.

Page 9 of 146 CEQA – Crescent Gardens

Street References: Garfield Road

D. Section, Township & Range Description or reference/attach a Legal Description: Section

22 Southeast, Township 5 South, Range 4 West, San Bernardino Base and Meridian, Lake
Elsinore USGS Quad.

E. Brief description of the existing environmental setting of the project site and its
surroundings: The Project Site has a gentle topographic relief with elevations that range from
approximately 1,584 to 1,650 feet above mean sea level, sloping in a northeasterly gradient. A
more mountainous terrain exists on the east and northeast sides of the Project Site.

North: The Project Site primarily abuts vacant property on the north side, zoned R-R (Rural
Residential). One single-family residence is situated near the northern property boundary of
Project parcel 0349-170-009, which is designed for the CCF, future caretaker residence,
equipment shed, and parking. The Project would provide a dedicated crushed decomposed
granite driveway from the Project’s main entrance on Garfield Road to the residence, which is
situated on APN 349-170-001. Additionally, two residences are situated in the northeast corner,
adjacent to Project APN 349-170-004, which is designed as cemetery grounds for the Phase 2
area.

South: The Project Site primarily abuts vacant property on the south side, zoned R-R (Rural
Residential). Two residences are situated on APNs 340-180-034 and APN 340-180-026, outside
the Project’s southwestern boundary, adjacent to Project APN 349-180-035, which is designed
for the chapel, parking and landscaped water quality/detention basin. The Project also provides
a dedicated decomposed granite driveway to these residences from Garfield Road.

West: The Project main entrance is from Garfield Road, located along the western boundary.
Garfield Road is developed with single family residential. Two residences are adjacent to the
Project entrance (APN 349-150-065 and APN 349-150-074). Along the northwest portion, the
Project Site primarily abuts vacant property, zoned R-R (Rural Residential). The southwestern
portion of the Project is planned for Phase 3 cemetery grounds; one residence (APN 349-180-
034) is situated outside the southwestern portion of the Project’s southwestern boundary.

East: The Project Site abuts vacant property along the east side zoned R-R (Rural Residential).
A Southern California Edison transmission utility line exists along the east and northeast
boundary of the site.

II. APPLICABLE GENERAL PLAN AND ZONING REGULATIONS

A. General Plan Elements/Policies:

• Land Use: The Project Site lies within the Elsinore Area Plan (ELAP). The Land Use of the
parcels range from Rural Mountainous (RM) with a General Plan Foundation Component of
Rural and a Land Use of Very Low Density Residential (VLDR) with a General Plan
Foundation Component of Community Development. The Project Site is located within the
unincorporated community of Meadowbrook, which is characterized by very low-density
residential development and vacant properties set amid rolling hills.

The Project does not lie within any of the policy or Land Use Overlay areas of the ELAP.

• Circulation: The site is within the ELAP. Applicable circulation policies contained in the Plan
include the following:

Page 10 of 146 CEQA – Crescent Gardens

o ELAP 8.1 Design and develop the vehicular roadway system per Figure 7, Circulation,
and in accordance with the functional classifications and standards specified in the
Planned Circulation Systems section of the General Plan Circulation Element.

o ELAP 8.2 Maintain Riverside County’s roadway Level of Service standards as

described in the Level of Service section of the General Plan Circulation Element.

The Project includes street improvements to Garfield Road, an east-west local paved
roadway that leads to the Project Site, which is an unpaved north-south local roadway.
Garfield Road will end easterly as a cul-de-sac west of the entry gates of Crescent Gardens
cemetery and dedicated to the County. This will include paved road curb to curb, parkway
and sidewalk that support fire department vehicle turning radius requirements.

The Project has been designed to avoid encroachment into the potential right-of-way for a
future secondary arterial to be developed by the County, known as Theda Street. A portion
of the Phase 1 area will cross the Theda Street right-of-way, and a portion of the Phase 1
and Phase 3 areas would abut Theda Street. However, the Applicant has worked with the
County Transportation Department to ensure that the cemetery grounds and cemetery road
crossing would not interfere with the development of Theda Street.

Access to the Project Site includes the following potential routes from State Route 74 (SR-
74), which is approximately 0.75 mile west of the site.

• From SR-74: Greenwald Avenue south, to Wallace Street; east to Jarvis Street; south
to Garfield Road, east into the Crescent Gardens Cemetery.

• From SR-74: River Road west, to Maze Avenue; south to Jarvis Road, east to
Garfield Road, east into the Crescent Gardens Cemetery.

• (Future Potential) From SR-74: Mauricio Avenue, east to proposed Theda Street
(possible future secondary arterial to be developed by the County) to Crescent
Gardens Cemetery, at “A” Street, which would be modified as necessary at the time.

The General Plan Element identifies that Level of Service (LOS) “C” applies to all
development proposals within the ELAP. The Proposed Project is anticipated to generate a
total of 89.5 daily roundtrips, based on Trip Generation analysis (Appendix H). According to
the County’s traffic study guidelines, the Project generates less than 100 vehicle trips during
the peak hours and is exempt from preparing a Traffic Impact Analysis. Therefore, it is
assumed that the Project would maintain a LOS C consistent with the General Plan.

Trails: An extensive system of proposed trails and bikeways exists within the ELAP planning
area connecting the various neighborhoods with the recreational resources of the Cleveland
National Forest and the regional trail system. The Elsinore Area Plan trail system is mapped
in the ELAP, Figure 8, Trails and Bikeway System. A Regional Trail: Urban/Suburban is
mapped on ELAP Figure 8 to traverse south and east of the Project Site’s Phase 2 and
Phase 3 areas. Trail spurs from the Regional Trail have been informally developed by trail
users and local residents to traverse the Project Site’s eastern boundary. These informal
trail spurs would be abandoned (Refer to Project Figure 4A). Therefore, circulation policies
relative to trails are not applicable as the Project would not impact the Regional Trail as
mapped on ELAP Figure 8.

Page 11 of 146 CEQA – Crescent Gardens

 Scenic Highways: SR-74, located approximately 0.75-mile west of the Project Site, has been
designated as an Eligible State Scenic Highway. The western segment of SR-74 is a
secondary County entrance road and will serve as a link to Orange County’s system of
scenic routes. The scenic highways designated within the ELAP are depicted on ELAP
Figure 9, Scenic Highways. The applicable policy is the following:

o ELAP 10.1 Protect Interstate 15 and State Route 74 from change that would diminish
the aesthetic value of adjacent properties through adherence to the Scenic Corridors
sections of the General Plan Land Use and Circulation Elements.

Due to the terrain of the area, and that the cemetery would resemble the existing condition,
the Project would not be visible or distinguishable from SR-74. Therefore, the Project is
consistent with the circulation policies relative to scenic highways.

CETAP Corridors: A Community Environmental Transportation Acceptability Process

(CETAP) Corridors are transportation corridors include a range of transportation options
such as highways or transit and are developed with careful consideration for potential
impacts to habitat requirements, land use plans, and public infrastructure. The East-West
CETAP Corridor may pass through the Elsinore Area Plan along State Route 74, or to the
north of it. The Project Site does not lie within any area identified being within a CETAP
Corridor.

• Multipurpose Open Space: The Proposed Project is not located in an Open Space area or
adjacent to an Open Space area. No natural open space land is required to be preserved
within the boundaries of this Project.

Watersheds, Floodplains, and Watercourse Policies. The ELAP contains a major portion of
the Santa Margarita River watershed, which includes Murrieta Creek. However, the Project
Site does not lie within these watershed areas, according to ELAP Figure 10, therefore,
policies related to Watersheds, Floodplains, and Watercourses are not applicable to the
Project.

Mineral Extraction. The Proposed Project Site is not located in an area that contains
regionally important aggregate and clay resources, as well as non-regionally important
mineral resources. Therefore policies regarding Mineral Extraction are not applicable to the
Project.

Oak Tree Preservation. The Project Site does not contain oak woodlands that should be
protected to preserve habitat and the character of the area. Therefore policies regarding Oak
Tree Preservation are not applicable to the Project.

Multiple Species Habitat Conservation Plan. The property is located in the Western Riverside
County Multiple Species Habitat Conservation Plan (MSHCP) Conservation Area but is not
located within any Criteria Cell or Public/Quasi-Public (PQP) Land. The Project is located
south and adjacent to 3491-700-02, which designated as a PQP parcel. No grading activities
or portions of the Project would be developed immediately adjacent to the PQP Parcel. A
Multiple Species Habitat Conservation Plan Consistency Analysis was prepared for the
Project (Appendix B-1) and approved in December 2024.

• Safety: The Proposed Project’s Safety policies are as follows:

Page 12 of 146 CEQA – Crescent Gardens

 Flooding and Dam Inundation. The Project Site is not located within a Flood and Dam
Inundation Zone as identified on ELAP Figure 10 – Special Flood Hazard Areas. Therefore,
policies regarding Flooding and Dam Inundation are not applicable.

Wildland Fire Hazard. The Project Site lies within a Very High/High/Moderate Fire Hazard
Severity Zone (FHSZ) as identified in EALP Figure 11 – Wildfire Susceptibility. The
applicable policy for Wildfire Hazard is as follows:

o ELAP 18.1 Protect life and property from wildfire hazards through adherence to the Fire
Hazards section of the General Plan Safety Element.

Of the 85-acre Project Site, 24.6 acres are to be utilized as cemetery grounds, which would
be gravel and cement. Approximately 1.8 acres would be iIrrigated landscaping along the
interior roads, pathways slopes and entrance that contains the buildings. The landscaping
is designed as drought tolerant and fire-resistant species. The Project is requried to comply
with the Fire Hazards section of the General Plan Safety Element. Therefore, the Project is
consistent with the applicable policies.

Seismic. The Project Site is not situated in or near a fault zone as identified in ELAP Figure
12 – Seismic Hazards. Therefore, policies regarding seismic hazards are not applicable.

Slope. The Project Site is not situated in or near a steep slope area as identified in ELAP
Figure 13 – Steep Slope, nor within an area identified on ELAP Figure 14 – Slope Instability.
The Project Site is located adjacent and to the west of Steep Slopes as mapped on ELAP
Figure 14. The applicable policy for Slope is as follows:

o ELAP 20.1 Identify and preserve the ridgelines that provide a significant visual resource
for Elsinore through adherence to the Hillside Development and Slope section of the
General Plan Land Use Element and the Scenic Resources section of the Multipurpose
Open Space Element.

The Project Site’s eastern boundary exists at the base of rolling hillsides. Some of the Project
Site’s topography has been mapped by the Applicant as having slopes of 25 percent or
greater (refer to Project Figure 9: On-Site Slope Topography, located at the end of this
section). The Project would grade these slopes to 2:1 or gentler, depending on design for
use as a road or gravesites. Therefore, the Project is consistent with ELAP Slope policy.

Airport. The Project site is not located within 2 miles of any airport, therefore, there are no
airport land use compatibility policies that apply to the Project Site.

• Noise: Noise associated with thie Proposed Project will be during the initial grading and
building construction, which is temporary. Operational noise will meet all applicable Noise
policies.

• Housing: The Proposed Project includes one single-family residence that would be
occupied by the caretaker.

• Air Quality: The Proposed Project would control any fugitive dust during grading and
construction activities pursuant to South Coast Air Quality Management District
(SCAQMD)requirements. The Proposed Project meets all applicable Air Quality Element
policies.

Page 13 of 146 CEQA – Crescent Gardens

 • Healthy Communities: Not applicable. The Proposed Project is a cemetery within a
residential area. The Project would not result in any air quality, hazardous materials,noise
or other impacts that would affect Healthy Communities.

• Environmental Justice: The Project would develop and operate a cemetery. The Project
is located in the Good Hope/Meadowbrook Environmental Justice Area. Figure 10 –
Environmental Justice Communities, located at the end of this section, provides the
Project Site location in relation to sensitive communities. In compliance with General Plan
Policy HC 15.1, outreach events have been conducted during the planning process for the
Project. Additionally, the Applicant has provided a completed an Environmental Justice Form
showing that the Proposed Project complies with all applicable Environmental Justice
Policies as the applicant will be providing a bus shelter off of SR-74 or similar route
connection in the Meadowbrook community.

B. General Plan Area Plan(s): Elsinore Area Plan (ELAP).

C. Foundation Component(s): Rural (eastern portion of the site), Community Development

(remainder of site).

D. Land Use Designation(s): Rural Mountainous (RM) (eastern portion of the site) and Very Low
Density Residential (VLDR) (remainder of the site).

E. Overlay(s), if any: N/A

F. Policy Area(s), if any: N/A

G. Adjacent and Surrounding:

1. General Plan Area Plan(s): Elsinore

2. Foundation Component(s): Rural (adjacent to the eastern portion of the Project Site),
Community Development (north, south, west of the Project Site).

3. Land Use Designation(s): Rural Mountainous (RM) (adjacent to the eastern portion of the
Project Site), Very Low Density Residential (VLDR) (adjacent to the north, west, and south
of the Project Site).

4. Overlay(s), if any: N/A.

5. Policy Area(s), if any: N/A

H. Adopted Specific Plan Information

1. Name and Number of Specific Plan, if any: Not Applicable.

2. Specific Plan Planning Area, and Policies, if any: Not Applicable.

I. Existing Zoning: Rural Residential (R-R). Pursuant to County Municipal Code Section
17.16.010, cemetery use is permitted provided a Conditional Use Permit has been issued.
Churches, temples and other places of worship are permitted with a Plot Plan approval. Single-
family residences are permitted. Because the CCF, chapel and single-family residence is
associated with the cemetery operations, a Conditional Use Permit is required to approve the
Project.

Page 14 of 146 CEQA – Crescent Gardens

 J. Proposed Zoning, if any: No change.

K. Adjacent and Surrounding Zoning: Rural Residential (R-R)

The environmental factors checked below ( x ) would be potentially affected by this project, involving at
least one impact that is a “Potentially Significant Impact” or “Less than Significant with Mitigation
Incorporated” as indicated by the checklist on the following pages.

Aesthetics Hazards & Hazardous Materials Recreation

Agriculture & Forest Resources Hydrology / Water Quality Transportation
Air Quality Land Use / Planning Tribal Cultural Resources
Biological Resources Mineral Resources Utilities / Service Systems
Cultural Resources Noise Wildfire
Energy Paleontological Resources Mandatory Findings of
Geology / Soils Population / Housing Significance
Greenhouse Gas Emissions Public Services

III. DETERMINATION

On the basis of this initial evaluation:

A PREVIOUS ENVIRONMENTAL IMPACT REPORT/NEGATIVE DECLARATION WAS NOT

PREPARED
I find that the proposed project COULD NOT have a significant effect on the environment, and a
NEGATIVE DECLARATION will be prepared.
I find that although the proposed project could have a significant effect on the environment, there
will not be a significant effect in this case because revisions in the project, described in this document,
have been made or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION
will be prepared.
I find that the proposed project MAY have a significant effect on the environment, and an
ENVIRONMENTAL IMPACT REPORT is required.

A PREVIOUS ENVIRONMENTAL IMPACT REPORT/NEGATIVE DECLARATION WAS PREPARED

I find that although the proposed project could have a significant effect on the environment, NO
NEW ENVIRONMENTAL DOCUMENTATION IS REQUIRED because (a) all potentially significant
effects of the proposed project have been adequately analyzed in an earlier EIR or Negative Declaration
pursuant to applicable legal standards, (b) all potentially significant effects of the proposed project have
been avoided or mitigated pursuant to that earlier EIR or Negative Declaration, (c) the proposed project
will not result in any new significant environmental effects not identified in the earlier EIR or Negative
Declaration, (d) the proposed project will not substantially increase the severity of the environmental
effects identified in the earlier EIR or Negative Declaration, (e) no considerably different mitigation
measures have been identified and (f) no mitigation measures found infeasible have become feasible.
I find that although all potentially significant effects have been adequately analyzed in an earlier EIR
or Negative Declaration pursuant to applicable legal standards, some changes or additions are
necessary but none of the conditions described in California Code of Regulations, Section 15162 exist.
An ADDENDUM to a previously-certified EIR or Negative Declaration has been prepared and will be
considered by the approving body or bodies.

Page 15 of 146 CEQA – Crescent Gardens

 I find that at least one of the conditions described in California Code of Regulations, Section 15162
exist, but I further find that only minor additions or changes are necessary to make the previous EIR
adequately apply to the project in the changed situation; therefore a SUPPLEMENT TO THE
ENVIRONMENTAL IMPACT REPORT is required that need only contain the information necessary to
make the previous EIR adequate for the project as revised.
I find that at least one of the following conditions described in California Code of Regulations, Section
15162, exist and a SUBSEQUENT ENVIRONMENTAL IMPACT REPORT is required: (1) Substantial
changes are proposed in the project which will require major revisions of the previous EIR or negative
declaration due to the involvement of new significant environmental effects or a substantial increase in
the severity of previously identified significant effects; (2) Substantial changes have occurred with
respect to the circumstances under which the project is undertaken which will require major revisions of
the previous EIR or negative declaration due to the involvement of new significant environmental effects
or a substantial increase in the severity of previously identified significant effects; or (3) New information
of substantial importance, which was not known and could not have been known with the exercise of
reasonable diligence at the time the previous EIR was certified as complete or the negative declaration
was adopted, shows any the following:(A) The project will have one or more significant effects not
discussed in the previous EIR or negative declaration;(B) Significant effects previously examined will
be substantially more severe than shown in the previous EIR or negative declaration;(C) Mitigation
measures or alternatives previously found not to be feasible would in fact be feasible, and would
substantially reduce one or more significant effects of the project, but the project proponents decline to
adopt the mitigation measures or alternatives; or,(D) Mitigation measures or alternatives which are
considerably different from those analyzed in the previous EIR or negative declaration would
substantially reduce one or more significant effects of the project on the environment, but the project
proponents decline to adopt the mitigation measures or alternatives.

July 31, 2025

Signature Date

For John Hildebrand

Planning Director
Krista Mason, Project Planner

Printed Name

Page 16 of 146 CEQA – Crescent Gardens

 River Road

Garfield St
Greenwald Ave

Project Site

Jarvis St

Mauricio Ave Robert St

Figure 1: Regional and Project Vicinity Map

Not to Scale Source: Google Earth
 349-170-004

349-170-005

349-170-003

349-170-006
349-170-009 349-170-008 349-170-007

349-170-013
349-170-011 349-170-012
349-170-010

349-180-035
Not A Part
349-180-006 349-180-002

349-180-007 349-180-004
349-180-005

349-180-008

Not A
349-180-016 349-180-020
Part
349-180-017

Figure 2A: Project Site Parcels

Not to Scale Source: Riverside County GIS
 Figure 2B: Project Zoning and Land Use
Not to Scale Source: Riverside County GIS
 Figure 3: Project Site: USGS View
Not to Scale Source: ESRI
 Figure 4A: Phasing Plan
Not to Scale Source: Applicant Submittal
 Figure 4B: Open and Developed Areas
Not to Scale Source: Applicant Submittal
 Figure 5A: Building Elevations and Profiles
Not to Scale Source: Applicant Submittal
 Figure 5B: Building Elevations and Profiles
Not to Scale Source: Applicant Submittal
 Figure 6A: Architectural Rendering - Site
Not to Scale Source: Applicant Submittal
 Figure 6B: Architectural Rendering – Ceremonial Cleansing Facility and Entry
Not to Scale Source: Applicant Submittal
 Figure 6C: Architectural Rendering – Chapel
Not to Scale Source: Applicant Submittal
 Figure 7: Photometric Analysis
Not to Scale Source: Applicant Submittal
 Figure 8A: Landscape Plan
Not to Scale Source: Applicant Submittal
 Figure 8B: Typical Burial Section
Not to Scale Source: Applicant Submittal
 Figure 9: On-Site Slope Topography
Not to Scale Source: Applicant Submittal
 Figure 10: Environmental Justice Communities
Not to Scale Source: Riverside County GIS
ENVIRONMENTAL ISSUES ASSESSMENT

In accordance with the California Environmental Quality Act (CEQA) (Public Resources Code Section
21000-21178.1), this Initial Study has been prepared to analyze the proposed project to determine any
potential significant impacts upon the environment that would result from construction and
implementation of the project. In accordance with California Code of Regulations, Section 15063, this
Initial Study is a preliminary analysis prepared by the Lead Agency, the County of Riverside, in
consultation with other jurisdictional agencies, to determine whether a Negative Declaration, Mitigated
Negative Declaration, or an Environmental Impact Report is required for the proposed project. The
purpose of this Initial Study is to inform the decision-makers, affected agencies, and the public of
potential environmental impacts associated with the implementation of the proposed project.

Potentially Less than Less No

Significant Significant Than Impact
Impact with Significant
Mitigation Impact
Incorporated
AESTHETICS Would the project:
1. Scenic Resources
a) Have a substantial effect upon a scenic highway
corridor within which it is located?
b) Substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings and unique or
landmark features; obstruct any prominent scenic vista or
view open to the public; or result in the creation of an
aesthetically offensive site open to public view?
c) In non-urbanized areas, substantially degrade the
existing visual character or quality of public views of the site
and its surroundings? (Public views are those that are
experienced from publicly accessible vantage points.) If the
project is in an urbanized area, would the project conflict with
applicable zoning and other regulations governing scenic
quality?

Source(s): Riverside County General Plan Figure C-8 “Scenic Highways;” ELAP, Figure 9 “Scenic
Highways”; Project Engineering and Renderings.

Findings of Fact:

a) The Project Site is not located within a scenic highway or scenic highway corridor as
designated by the County or State or found eligible by the County or State. There is one
State Eligible Scenic Highway in Elsinore Valley: State Route 74 as it connects with
Interstate 215 in the southern portion of the Elsinore Valley. State Route 74 is of regional
significance because it provides a link between Orange and Riverside Counties through the
Santa Ana Mountains and eventually through the San Jacinto Mountains as the famous
Palms to Pines Scenic Highway. The Project Site is approximately 0.75 mile to the east of
State Route 74 and cannot be viewed from State Route 74; the Project Site is not located
in any scenic corridor or scenic highway. Therefore, there would be no impacts.

b) The Project would develop approximately 46.4 acres of the total approximately 85 acres
that is currently undeveloped land that has native shrubs, grasses, rock outcroppings,
rolling hills and some trees. The Project would develop the 46.39 acres with a cemetery
Page 33 of 146 CEQA – Crescent Gardens
 that is designed to primarily follow the existing topography, while grading some slopes to
support the interior roadways and slopes. While the Project would change the visual
character of the vicinity with private interior roadways and some irrigated trees along the
roads and pathways, it would not substantially degrade the existing visual character or
create an aesthetically offensive site open to public view of the area and its surroundings
because the cemetery plots would follow existing elevation of the relatively flat grades.
Some of the facilities may be visible, however they are designed in a manner that exceeds
setbacks and are surrounded by trees that would allow the facilities to blend into the overall
landscape. Architectural renderings of the Project are provided in Figures 6A, 6B and 6C.
Impacts would be less than significant, and no mitigation measures are required.

c) The Project Site is within a rural area and is designed to be consistent with the rural
residential nature of the area. Sensitive receptors would include the pocket of existing rural
residential that exists to the west of the Project Site.

The building would be set back from adjacent streets and would not encroach into public
long-distance views. Parking and landscaping areas would be located in the setback space
between roadways and buildings, which would minimize the visual scale of the structures.
The areas most visible to the public would be landscaped with 115 new trees.

Areas adjacent to the buildings would be landscaped with trees and a variety of shrubs and
ground covers. The layering of landscaping between the proposed building and the
surrounding roadways would provide visual depth and distance between the roadways and
proposed structures, while functioning as a screen to trailer parking and truck yard.

Therefore, potential impacts associated with scenic quality would be less than significant,
and no mitigation would be required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

2. Mt. Palomar Observatory

a) Interfere with the nighttime use of the Mt. Palomar
Observatory, as protected through Riverside County
Ordinance No. 655?

Source(s): GIS database, Ord. No. 655 (Regulating Light Pollution)

Findings of Fact:

a) According to GIS database, the Project Site is located approximately 45 miles northwest of the
Mt. Palomar Observatory and is located in Zone B of the Mt. Palomar Nighttime Lighting Policy
Area. Projects within Zone B must adhere to the lighting requirements specified in Riverside
County Ordinance No. 655 for standards that are intended to limit light leakage and spillage
that may interfere with the operations of the Mount Palomar Observatory. The Project is
designed consistent with County Ordinance No. 655 with pole lights of varying height for
parking lot lighting and exterior building downlighting. Therefore, due to distance and lighting
design, the Project would not interfere with the nighttime use of the Mt. Palomar Observatory,
as protected through Riverside County Ordinance No. 655. Impacts will be less than significant.

Page 34 of 146 CEQA – Crescent Gardens

 Potentially Less than Less No
Significant Significant Than Impact
Impact with Significant
Mitigation Impact
Incorporated

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

3. Other Lighting Issues

a) Create a new source of substantial light or glare
which would adversely affect day or nighttime views in the
area?
b) Expose residential property to unacceptable light
levels?

Source(s): On-site Inspection, Project Application Description

Findings of Fact:

a) The Project will create a new source of light from low-level exterior security lighting of the
buildings, parking lot lighting, and ground-level landscape lighting around the buildings and
parking lot only. The roadways and pathways within the cemetery grounds would contain low
level landscape lighting, such as a low-to-the-ground solar light fixture that would light up the
edge of the roads. All lighting is designed with downward pointing lighting of a soft color and
intensity to ensure safety but not to spill over to adjacent properties. Fixtures with light shields
are specified at certain locations per the lighting plan. No lighting will be on during daytime
hours. The lower color intensity of the building security lighting and the ground level landscape
lighting will not impact localized nighttime views around the building and will not migrate to the
night sky because all lights are pointed downward. The Project would therefore create a new
source of light but because of shielding and use of low-intensity fixtures, the light would not be
so substantial that it would adversely affect day or nighttime views in the area. Impacts will be
less than significant.

b) Residences exist along the west side of the Project Site, along Garfield Road, which is the
main entrance to the site. All entrance and parking lot lighting will be pointed downward and
be of a color intensity that will not be bright or obtrusive to the residences. Parking lot lighting
would be designed with light emitting diode (LED) lighting, pointed downward toward the
parking lot and/or buildings. A photometric analysis (Figure 7) has been completed that shows
that light spill-over from the parking lot lighting would not occur and will be in conformance with
County ordinances. Low-level landscape lighting is planned for the interior roadways or
pathways to provide safety, although as the facility would not be generally accessible at night.
Therefore, the Project would not expose residential property to unacceptable light levels.
Impacts will be less than significant.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

Page 35 of 146 CEQA – Crescent Gardens

 Potentially Less than Less No
Significant Significant Than Impact
Impact with Significant
Mitigation Impact
Incorporated

AGRICULTURE & FOREST RESOURCES Would the project:

4. Agriculture
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 agricultural zoning,
agricultural use or with land subject to a Williamson Act
contract or land within a Riverside County Agricultural
Preserve?
c) Cause development of non-agricultural uses within
300 feet of agriculturally zoned property (Ordinance No. 625
“Right-to-Farm”)?
d) Involve other changes in the existing environment
which, due to their location or nature, could result in
conversion of Farmland, to non-agricultural use?

Source(s): Riverside County General Plan Figure OS-2 “Agricultural Resources,” GIS database,
Project Application Materials

Findings of Fact:

a) The Project Site is designated by the California Resources Agency Farmland Mapping and
Monitoring Program as “Other Land” which is not prime, unique or other important farmland.
Due to the designation of Other Land, there will be no conversion of 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. There would be no impacts and no mitigation
measures are required.

b) The Project Site is vacant, zoned for rural residential uses and not subject to a Williamson
Act contract. Pursuant to California Government Code section 51242, no jurisdiction may
contract with respect to the Williamson Act unless the land is devoted to agricultural use
and is located within an area designated by a city or county as an agricultural preserve. The
Project Site is not within a Riverside County designated Agricultural Preserve as the Project
Site is zoned for Rural Residential. Therefore, no impacts associated with existing zoning
for agricultural use, or a Williamson Act contract would occur, and no mitigation would be
required.

c) Properties within 300 feet of the Proposed Project are either vacant, do not contain active
agricultural operations, or are developed with rural single family residential uses. The
Project Site is zoned Rural Residential. Ordinance No. 625 “Right-to-Farm” is designed to
reduce the County’s loss of its agricultural resources by limiting the circumstances under
which agricultural operations may be deemed to constitute a nuisance. Ordinance No. 625
provides that “no agricultural activity, operation, or facility, or appurtenances thereof,
conducted or maintained for commercial purposes in the unincorporated area of the County,
and in a manner consistent with proper and accepted customs and standards, as
established and followed by similar agricultural operations in the same locality, shall be or

Page 36 of 146 CEQA – Crescent Gardens

 Potentially Less than Less No
Significant Significant Than Impact
Impact with Significant
Mitigation Impact
Incorporated

become a nuisance, private or public, due to any changed condition in or about the locality,
after the same has been in operation for more than three (3) years, if it was not a nuisance
at the time it began.” There are no active agricultural operations within 300 feet of the
Project Site, therefore, Ordinance 625 is not applicable. The Proposed Project would not
preclude or deter surrounding properties from conducting agricultural operations as allowed
by the zoning. Therefore, impacts will be less than significant and no mitigation would be
required.

d) The Project Site is vacant and is not undergoing farming or agricultural activities. The
Project Site is zoned for Rural Residential uses. The Proposed Project would construct
religious facilities and a cemetery, which is allowed with the current zoning for the site.
Therefore, while the Project will involve other changes in the existing environment which,
due to their location or nature, could result in conversion of Farmland, to non-agricultural
use, the Project Site is consistent with the zoning and land uses permitted for the Project
Site by Riverside County. Therefore, impacts will be less than significant, and no mitigation
would be required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

5. Forest
a) 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 Govt. Code section 51104(g))?
b) Result in the loss of forest land or conversion of
forest land to non-forest use?
c) Involve other changes in the existing environment
which, due to their location or nature, could result in con-
version of forest land to non-forest use?

Source(s): Riverside County General Plan Figure OS-3a “Forestry Resources Western Riverside
County Parks, Forests, and Recreation Areas,” Figure OS-3b “Forestry Resources Eastern Riverside
County Parks, Forests, and Recreation Areas,” Project Application Materials

Findings of Fact:

a) The Project would 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
Govt. Code section 51104[g]) because the General Plan identifies that the site is not zoned
or used for timber production. The site is not located within forest land. There would be no
impacts.

b) The Project would not result in the loss of forest land or conversion of forest land to non-
forest use because there is no forest land on the property. There would be no impacts.

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c) The Project will not involve other changes in the existing environment that could result in
conversion of forest land to non-forest use because there is no forest or forest lands on the
property. There would be no impacts.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

AIR QUALITY Would the project:

6. Air Quality Impacts
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, which are located within
one (1) mile of the project site, to substantial pollutant
concentrations?
d) Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of people?

Source(s): Riverside County General Plan; Riverside County Climate Action Plan (“CAP”); Air Quality
Management Plan (AQMP); California Emissions Estimator Model (CalEEMod) version 2022.1.1.29
outputs (Appendix A).

Findings of Fact:

a) Less than Significant Impact. The Project Site is located in the South Coast Air Basin
(SCAB). The South Coast Air Quality Management District (SCAQMD) has jurisdiction over air
quality issues and regulations within the SCAB. The Air Quality Management Plan (AQMP) for
the basin establishes a program of rules and regulations administered by SCAQMD to obtain
attainment of the state and federal air quality standards. The SCAB is classified as an
“extreme” nonattainment area for the 2015 Ozone National Ambient Air Quality Standards
(NAAQS). The most recent AQMP (AQMP 2022) was developed to address the requirements
for meeting this standard and was adopted by the SCAQMD on December 2, 2022. The 2022
AQMP incorporates the latest scientific and technological information and planning
assumptions, including transportation control measures developed by the Southern California
Association of Governments (SCAG) from the 2020 Regional Transportation Plan/Sustainable
Communities Strategy, and updated emission inventory methodologies for various source
categories. Consistency with the AQMP 2022 for general development projects is determined
by demonstrating compliance with local land use plans and/or employment projections.

A project is inconsistent with the AQMP if: (1) it does not conform with the local general plan;
or (2) it uses a disproportionately large portion of the forecast growth increment. The AQMP
contains air pollutant reduction strategies based on SCAG’s latest growth forecasts, and
SCAG’s growth forecasts were defined in consultation with local governments and with

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reference to local general plans. The Project Site lies within the Elsinore Area Plan (ELAP).
The Land Use of the parcels range from Rural Mountainous (RM) with a General Plan
Foundation Component of Rural and a Land Use of Very Low Density Residential (VLDR) with
a General Plan Foundation Component of Community Development. The Project Site is
located within the unincorporated community of Meadowbrook, which is characterized by very
low-density residential development. The Proposed Project is not growth inducing and
therefore, approval of the Proposed Project would not conflict with the AQMP. No significant
adverse impacts are identified or are anticipated, and no mitigation measures are required.

b) Less than Significant Impact. The Proposed Project’s construction and operational
emissions were screened using California Emissions Estimator Model (CalEEMod) version
2022.1.1.29 prepared by the SCAQMD (available at County office for review). CalEEMod was
used to estimate the on-site and off-site construction emissions. The emissions incorporate
Rule 402 and 403 by default as required during construction. The criteria pollutants screened
for include reactive organic gases (ROG), nitrous oxides (NOx), carbon monoxide (CO), sulfur
dioxide (SO2), and particulates (PM10 and PM2.5). Two of the analyzed pollutants, ROG and
NOx, are ozone precursors. Both summer and winter season emission levels were estimated.

Construction Source Emissions

Construction activities associated with the Proposed Project would have the potential to
generate air emissions and odor impacts. Construction emissions are considered short-term,
temporary emissions and were modeled with the following construction parameters: site
grading (mass and fine grading), building construction, paving, and architectural coating. The
grading phase of the Proposed Project is anticipated to include 104,500 net cubic yards being
graded over three phases (30,500 cubic yards Phase 2 and 74,000 cubic yards Phase 3) of
imported material. Material import was phased in within the model. During earthwork activities
the applicant will be required to water active sites at least three times daily to reduce impacts
to sensitive receptors. Refer to Table 2: Construction Emissions (Pounds per Day) for
construction emissions generated per phase with watering activities three times per day.

Table 2: Construction Emissions

(Pounds per Day)

Phase I
Source/Phase ROG NOX CO SO2 PM10 PM2.5
Demolition 2.6 23.7 22.0 <0.0 1.1 0.9
Site Preparation 3.5 32.7 32.2 <0.0 6.6 3.9
Hauling 0.0 0.0 0.0 0.0 0.0 0.0
Grading 1.9 17.4 19.9 <0.0 2.7 1.6
Building Construction 2.7 24.4 31.1 <0.0 1.2 1.0
Paving 1.2 7.6 11.4 <0.0 0.5 0.3
Architectural Coating 10.7 0.9 1.3 <0.0 <0.0 <0.0
Highest Value 10.7 32.7 32.2 0.0 6.6 3.9
SCAQMD Threshold 75 100 550 150 150 55
Significant No No No No No No

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Phase II
Source/Phase ROG NOX CO SO2 PM10 PM2.5
Demolition 2.5 22.1 21.0 <0.0 1.0 0.9
Site Preparation 3.3 30.2 30.7 <0.0 6.7 3.9
Hauling 0.2 14.2 3.9 0.2 3.7 1.2
Grading 1.8 16.8 19.5 <0.0 3.0 1.7
Building Construction 2.5 22.9 30.2 <0.0 0.9 0.8
Paving 1.2 7.4 11.4 <0.0 0.5 0.3
Architectural Coating 0.1 0.9 1.2 <0.0 <0.0 <0.0
Highest Value 3.3 30.2 30.7 0.2 6.7 3.9
SCAQMD Threshold 75 100 550 150 150 55
Significant No No No No No No
Phase III
Source/Phase ROG NOX CO SO2 PM10 PM2.5
Demolition 2.4 21.2 20.5 <0.0 1.0 0.8
Site Preparation 3.2 28.9 30.1 <0.0 6.6 3.8
Hauling 0.5 33.4 8.3 0.2 8.9 2.9
Grading 1.8 15.2 19.1 <0.0 2.8 1.6
Building Construction 2.5 21.4 30.0 <0.0 0.8 0.7
Paving 1.1 7.1 11.2 <0.0 0.4 0.3
Architectural Coating 0.1 0.8 1.2 <0.0 <0.0 <0.0
Highest Value 3.2 33.4 30.1 0.2 8.9 3.8
SCAQMD Threshold 75 100 550 150 150 55
Significant No No No No No No

As shown in Table 2, none of the Proposed Project’s construction emissions would exceed
regional thresholds. Impacts would be less than significant, and no mitigation measures would
be required.

Compliance with SCAQMD Rules and Regulations

During construction and operation, the Proposed Project must comply with applicable rules
and regulations even if the Project does not exceed thresholds. The following are rules the
Project may be required to comply with, either directly, or indirectly would include but not be
limited to the following, and the Project would follow the most recent versions of these rules:

SCAQMD Rule 402

Prohibits a person from discharging from any source whatsoever such quantities of air
contaminants or other material which cause injury, detriment, nuisance, or annoyance to
any considerable number of persons or to the public, or which endanger the comfort,
repose, health or safety of any such persons or the public, or which cause, or have a
natural tendency to cause, injury or damage to business or property.

SCAQMD Rule 403

Governs emissions of fugitive dust during construction and operation activities.
Compliance with this rule is achieved through application of standard Best Management
Practices, such as application of water or chemical stabilizers to disturbed soils, covering
haul vehicles, restricting vehicle speeds on unpaved roads to 15 miles per hour, sweeping

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loose dirt from paved site access roadways, cessation of construction activity when winds
exceed 25 mph, and establishing a permanent ground cover on finished sites.

Rule 403 requires that fugitive dust be controlled with best available control measures so
that the presence of such dust does not remain visible in the atmosphere beyond the
property line of the emission source. In addition, SCAQMD Rule 403 requires
implementation of dust suppression techniques to prevent fugitive dust from creating a
nuisance off-site. Applicable dust suppression techniques from Rule 403 are summarized
below. Implementation of these dust suppression techniques can reduce the fugitive dust
generation (and thus the PM10 component). Compliance with these rules would reduce
impacts on nearby sensitive receptors. Rule 403 measures may include but are not limited
to the following:

• Apply nontoxic chemical soil stabilizers according to manufacturers’ specifications

to all inactive construction areas (previously graded areas inactive for 10 days or
more).
• Water active sites at least three times daily. (Locations where grading is to occur will
be thoroughly watered prior to earthmoving.)
• Cover all trucks hauling dirt, sand, soil, or other loose materials, or maintain at least
0.6 meters (2 feet) of freeboard (vertical space between the top of the load and top
of the trailer) in accordance with the requirements of California Vehicle Code section
23114.
• Reduce traffic speeds on all unpaved roads to 15 miles per hour (mph) or less.
• Suspension of all grading activities when wind speeds (including instantaneous wind
gusts) exceed 25 mph.
• Bumper strips or similar best management practices shall be provided where
vehicles enter and exit the construction site onto paved roads or wash off trucks and
any equipment leaving the site each trip.
• Replanting disturbed areas as soon as practical.
• During all construction activities, construction contractors shall sweep on-site and
off-site streets if silt is carried to adjacent public thoroughfares, to reduce the amount
of particulate matter on public streets. All sweepers shall be compliant with
SCAQMD Rule 1186.1, Less Polluting Sweepers.

SCAQMD Rule 481

Applies to all spray painting and spray coating operations and equipment. The rule states that
a person shall not use or operate any spray painting or spray coating equipment unless one of
the following conditions is met:

1. The spray coating equipment is operated inside a control enclosure, which is approved
by the Executive Officer. Any control enclosure for which an application for permit for
new construction, alteration, or change of ownership or location is submitted after the
date of adoption of this rule shall be exhausted only through filters at a design face
velocity not less than 100 feet per minute nor greater than 300 feet per minute, or through
a water wash system designed to be equally effective for the purpose of air pollution
control.
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2. Coatings are applied with high-volume low-pressure, electrostatic and/or airless spray
equipment.
3. An alternative method of coating application or control is used which has effectiveness
equal to or greater than the equipment specified in the rule.

SCAQMD Rule 1108

Governs the sale, use, and manufacturing of asphalt and limits the volatile organic compound
(VOC) content in asphalt used in the South Coast Air Basin. This rule would regulate the VOC
content of asphalt used during construction. Therefore, all asphalt used during construction of
the project must comply with SCAQMD Rule 1108.

SCAQMD Rule 1113

Governs the sale, use, and manufacturing of architectural coating and limits the VOC content
in paints and paint solvents. This rule regulates the VOC content of paints available during
construction. Therefore, all paints and solvents used during construction and operation of the
project must comply with SCAQMD Rule 1113.

SCAQMD Rule 1143

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

SCAQMD Rule 1186

Limits the presence of fugitive dust on paved and unpaved roads and sets certification
protocols and requirements for street sweepers that are under contract to provide sweeping
services to any federal, state, county, agency or special district such as water, air, sanitation,
transit, or school district.

SCAQMD Rule 1303

Governs the permitting of re-located or new major emission sources, requiring Best Available
Control Measures and setting significance limits for PM10 among other pollutants.

SCAQMD Rule 1401

New Source Review of Toxic Air Contaminants specifies limits for maximum individual cancer
risk, cancer burden, and non-cancer acute and chronic hazard index from new permit units,
relocations, or modifications to existing permit units, which emit toxic air contaminants.

SCAQMD Rule 1403

Asbestos Emissions from Demolition/Renovation Activities, specifies work practice
requirements to limit asbestos emissions from building demolition and renovation activities,
including the removal and associated disturbance of asbestos-containing materials (ACM).

SCAQMD Rule 2202

On-Road Motor Vehicle Mitigation Options, is to provide employers with a menu of options to
reduce mobile source emissions generated from employee commutes, to comply with federal
and state Clean Air Act requirements, Health & Safety Code Section 40458, and Section
182(d)(1)(B) of the federal Clean Air Act. It applies to any employer who employs 250 or more

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employees on a full or part-time basis at a worksite for a consecutive six-month period

calculated as a monthly average.

Compliance with these regulations would minimize air quality operational impacts.

Operational Emissions

The operation of the Proposed Project would result in a long-term increase in air quality
emissions. This increase would be due to emissions from the Project-generated vehicle trips
and operational emissions from the on-going use of the Proposed Project. Operational
emissions are categorized as energy (generation and distribution of energy to the end use),
area (operational use of the project), and mobile (vehicle trips). Operational emissions were
estimated using the CalEEMod version 2022.1 defaults values for Place of Worship
(Cemetery), City Park (open spaces), and Single-Family Residence (caretaker residence). The
Project is assumed to generate up to 46 trips per day (applicant anticipated 39 daily trips at
year 30 buildout). The use of a backhoe and miscellaneous pieces of construction handling
equipment was also added to operational use. Cemetery uses include approximately 18,667
square feet of chapel, CCF, caretaker, and equipment shed. Proposed Project emissions are
listed in Table 3: Operational Emissions Summary (Pounds Per Day), which represent
summer and winter operational emissions.

Table 3: Operational Emissions Summary

(Pounds Per Day)
Summer
Source ROG NOX CO SO2 PM10 PM2.5
Summer Max 0.8 0.4 2.5 <0.0 0.4 0.1
Construction Equipment 0.7 3.8 4.9 <0.0 0.1 0.1
Totals 1.5 4.2 7.4 <0.0 0.5 0.2
SCAQMD Threshold 55 55 550 150 150 55
Significant No No No No No No
Winter
Winter Max 0.7 0.4 1.5 <0.0 0.3 0.1
Construction Equipment 0.7 3.8 4.9 <0.0 0.1 0.1
Totals 1.4 4.2 6.4 <0.0 0.4 0.2
SCAQMD Threshold 55 55 550 150 150 55
Significant No No No No No No
Source: CalEEMod 2022; SCAQMD Emission Factors for construction equipment 2025.

As shown, both summer and winter season operational emissions are below SCAQMD
thresholds. Therefore, no significant adverse impacts are identified or anticipated, and no
mitigation measures are required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

c) Less than Significant Impact. SCAQMD has developed a methodology to assess the
localized impacts of emissions from a Proposed Project as outlined within the Final Localized
Significance Threshold (LST) Methodology report; completed in June 2003 and revised in July

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2008. The use of LSTs is voluntary, to be implemented at the discretion of local public agencies
acting as a lead agency pursuant to CEQA. LSTs apply to projects that must undergo CEQA
or the National Environmental Policy Act (NEPA) and are five acres or less. LST methodology
is incorporated to represent worst-case scenario emissions thresholds. CalEEMod was used
to estimate the on-site and off-site construction emissions. The LSTs were developed to
analyze the significance of potential air quality impacts of a project to sensitive receptors (i.e.
schools, single family residences, etc.) and provide screening tables for small projects (one,
two, or five acres). Projects are evaluated based on geographic location and distance from the
sensitive receptor (25, 50, 100, 200, or 500 meters from the site).

For the purposes of a CEQA analysis, the SCAQMD considers a sensitive receptor to be a
receptor such as a residence, hospital, convalescent facility or anywhere that it is possible for
an individual to remain for 24 hours. Additionally, schools, playgrounds, childcare centers, and
athletic facilities can also be considered as sensitive receptors. Commercial and industrial
facilities are not included in the definition of sensitive receptor because employees do not
typically remain on-site for a full 24 hours, but are usually present for shorter periods of time,
such as eight hours.

The Project Site is approximately 30 acres and therefore the “5-acre” LSTs were utilized for
the analysis to represent a worst-case scenario as the larger the site, the higher the screening
threshold. The closest sensitive receptor are residences immediately adjacent to the south of
the Site; therefore, LSTs are based on a 25-meter distance. The Proposed Project’s
construction and operational emissions with the appropriate LST are presented in Table 4 –
Localized Significance Thresholds (pounds per day).

Table 4: Localized Significance Thresholds (pounds per day)

Phase I
Source NOx CO PM10 PM2.5
Construction Emissions
32.7 32.2 6.6 3.9
(Max. from Table 1)
Operational Emissions
4.2 7.4 0.5 0.2
(Max. Total from Table 2)
Highest Value (lbs/day) 32.7 32.2 6.6 0.5 3.9 0.2
LST Threshold 371 1,965 13* 8 †
4* 2†
Greater Than Threshold No No No No No No
Phase II
Source NOx CO PM10 PM2.5
Construction Emissions
30.2 30.7 6.7 3.9
(Max. from Table 1)
Operational Emissions
4.2 7.4 0.5 0.2
(Max. Total from Table 2)
Highest Value (lbs/day) 30.2 30.7 6.7 0.5 3.9 0.2
LST Threshold 371 1,965 13* 8† 4* 2†
Greater Than Threshold No No No No No No

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Phase III
Source NOx CO PM10 PM2.5
Construction Emissions
33.4 30.1 8.9 3.8
(Max. from Table 1)
Operational Emissions
4.2 7.4 0.5 0.2
(Max. Total from Table 2)
Highest Value (lbs/day) 33.4 30.1 8.9 0.5 3.8 0.2
LST Threshold 371 1,965 13* 8† 4* 2†
Greater Than Threshold No No No No No No
Sources: CalEEMod.2022 Summer and Winter Emissions; SCAQMD Final Localized Significance Threshold Methodology; SCAQMD
Mass Rate Look-up Tables for a 5-acre site in SRA No. 25 Lake Elsinore, distance of 25 meters.
Note: PM10 and PM2.5 emissions are separated into construction and operational thresholds in accordance with the SCAQMD Mass
Rate LST Look-up Tables.
*
Construction emissions LST
†
Operational emissions LST

During earthwork activities the applicant will be required to water active sites at least three
times daily, which is a common compliance measure for dust control under SCAQMD
regulations. As shown in Table 4, the Proposed Project’s localized emissions are not
anticipated to exceed Localized Significance Thresholds. Therefore, no significant adverse
impacts are identified or anticipated, and no mitigation measures are required.

d) 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 short-term in nature, and the
odor emissions are expected to cease upon the drying or hardening of the odor-producing
materials. 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.

Once developed, the operational use of the Cemetery is not expected to create odors.
Therefore, less than significant impact from operational odors would occur and no mitigation
measures are required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

BIOLOGICAL RESOURCES Would the project:

7. Wildlife & Vegetation
a) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Conservation Community Plan,
or other approved local, regional, or state conservation plan?
b) Have a substantial adverse effect, either directly or
through habitat modifications, on any endangered, or
threatened species, as listed in Title 14 of the California

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Code of Regulations (Sections 670.2 or 670.5) or in Title 50,

Code of Federal Regulations (Sections 17.11 or 17.12)?
c) 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 Wildlife or U. S. Wildlife Service?
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) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community identified in local
or regional plans, policies, and regulations or by the
California Department of Fish and Game or U. S. Fish and
Wildlife Service?
f) 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?
g) Conflict with any local policies or ordinances
protecting biological resources, such as a tree preservation
policy or ordinance?

Source(s): GIS database, WRCMSHCP and/or CVMSHCP, On-site Inspection; Report by ELMT
Consulting titled Crescent Cemetery, Conditional Use Permit CUP 230002, Habitat Assessment and
Western Riverside County Multiple Species Habitat Conservation Plan Consistency Analysis, March
2024 (Appendix B-1); Report by ELMT Consulting titled Crescent Cemetery, Conditional Use Permit
CUP 230002, Delineation of State and Federal Jurisdictional Waters, March 2024 (Appendix B-2);
Report by ELMT Consulting titled Determination of Biologically Equivalent or Superior Preservation
Report, Crescent Garden Cemetery, July 2024, updated October 2024 (Appendix B-3); Report by
Huffman Environmental titled 2024 Proposed Crescent Gardens Cemetery Project Crotch’s Bumble
Bee Summary Report, Riverside County, California, August 2024 (Appendix B-4); Report by ELMT
Consulting titled Crotch’s Bumblebee (Bombus crotchii) Suitability Assessment for the Proposed
Crescent Cemetery Project Located in Unincorporated Riverside County, California, April 7, 2025
(Appendix B-5).

Findings of Fact:

a) The property is located in the Western Riverside County Multiple Species Habitat Conservation
Plan (MSHCP) Elsinore Area Plan. The Project was evaluated for consistency with MSHCP as
follows:

Criteria Cell Location. The Project Site does not occur within one of the Criteria Cells of the
MSHCP, which were established for the acquisition of habitat and sensitive plant and wildlife
species and therefore is not subject to MSHCP's Habitat Evaluation and Acquisition
Negotiation Strategy (HANS) process or the Joint Project Review (JPR) process.

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Section 6.1.2 - Riverine/Riparian Resources. The biological report included in Appendix B-1
identified that one unnamed drainage feature (Drainage 1) was observed within the boundaries
of the Project Site at the time of the investigation that will qualify as riparian/riverine habitat
under the MSHCP. The limits of disturbance for the proposed project were purposefully
designed to avoid impacts to the greatest extent possible; however, a small portion of Drainage
1 will be impacted from Project implementation. As required by the MSHCP, a Determination
of Biologically Equivalent or Superior Preservation Analysis (DBESP) analysis must be
conducted to address any impacts to riparian/riverine habitat. The objective of the DBESP is
to demonstrate that proposed mitigation would provide an equivalent or superior preservation
of habitat function and value of riparian/riverine resources. The factors to be considered in
analyzing the function and value include hydrologic regime, flood storage and flood flow
modification, nutrient retention and transformation, sediment trapping and transport, toxicant
trapping, public use, wildlife habitat, and aquatic habitat.

The DBESP (Appendix B-3), which was reviewed by the Riverside Conservation Authority
(RCA) on September 17, 2024. The RCA identified that mitigation was required to mitigate the
potential impacts to riverine/riparian resources. The DBESP in Appendix B-3 was revised in
October 2024 to reflect the required mitigation. The mitigation identified in the DBESP is
reflected in Mitigation Measure BIO-1 and is designed to off-set impacts to 0.036 acre of
riparian/riverine habitat to install a drainage culvert to support an interior roadway. Refer to
“Mitigation” at the end of this section for the full mitigation measure language. Refer to Figure
11: DBESP and Crotch Bumble Mitigation Area, located at the end of this section, for the
location of the DBESP mitigation area.

Section 6.1.4 – Urban/Wildland Interface. The Urban/Wildlife Interface Guidelines are intended
to ensure that indirect project-related impacts to the MSHCP Conservation Area, including
drainage, toxics, lighting, noise, invasive plant species, barriers, and grading/land
development, are avoided or minimized. The project site is not located within any Criteria Cells
or designated conservation areas. However, the northern portion of the site does occur
adjacent to mapped MSHCP Conserved Public/Quasi-Public Land (PQP) within APN 3491-
700-02 (refer to Exhibit 9 in Appendix B-1); however, this parcel does not occur within any
Criteria Cells and is not documented as contributing to nearby Linkages. The Riverside County
Building and Safety will require review of the lighting plans to ensure that the proposed on-site
lighting sources would meet County lighting standards. Construction and operational noise
were assessed in Appendix G. Operational noise was determined to be below the County’s
standard for daytime noise standards throughout the life of the Project. Construction would
occur during the permitted hours outlined in County of Riverside Municipal Code Section
9.52.020, and therefore would be in compliance with the County’s noise ordinance during
construction. The Project would be conditioned to meet all applicable County noise policies.
Overall, the analyses provided found the Project consistent with MSHCP Section 6.1.4.

Section 6.3.2 – Additional Surveys. The Project Site is not located within plan-defined areas
requiring surveys for narrow endemic plant species or criteria area plant species. However,
the Project is located within a designated area, requiring surveys for burrowing owl (BUOW).
A habitat assessment was prepared in November 2023 which determined the potential suitable
foraging habitat for burrowing owl, but less favorable conditions for colonization opportunities.
Four focused burrowing owl surveys were conducted in 2024, on May 10 and 31 and June 14
and June 28, in accordance with the MSHCP Burrowing Owl Survey Instructions (2006)(refer
to Appendix B-3). The result was that no burrowing owls were found. However, because

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suitable habitat exists on site and construction would occur over time, Mitigation Measure
BIO-2 to conduct a pre-construction survey for burrowing owl during each phase of
construction to avoid impacts to the burrowing owl. The mitigation measure also identifies that
relocation may occur under certain conditions to avoid impacts during construction. Refer to
“Mitigation” at the end of this section for details.

Impacts would be less than significant with the incorporated mitigation.

b) A literature review and field assessment were performed to document baseline conditions and
assess the potential for special status plants and wildlife species to occur within the Project
Site. Special attention was given to the suitability of on-site habitat to support special status
species as identified by the California Department of Fish and Wildlife (CDFW) and other
electronic databases utilized for the assessment (Appendix B-1).

According to the CNDDB, seventy-five (75) special-status wildlife species have been reported
in the Lake Elsinore and Romoland quadrangles (refer to Appendix B-1). Three special-status
wildlife species were observed on-site during the field investigation: orange-throat whiptail
(CDFW Watch List), loggerhead shrike (CDFW Species of Special Concern), and coastal
California gnatcatcher (Federally Threatened, CDFW Species of Special Concern). These
species are covered under the MSHCP.

Crotch’s Bumble Bee

The Crotch’s bumblebee (Bombus crotchii, CBB), is a candidate species for State listing and
is not covered under the MSHCP. CBB surveys were conducted on the Project site and
included a habitat assessment to identify optimal nectar sources, as well as focused species
surveys to determine the presence or absence, with the survey methodology following the
2023 CDFW guidance document for the CBB. (Appendix B-4).

The habitat assessment identified that of the approximately 85-acre Project Site, approximately
34 acres contained potentially suitable habitat. Of the 34 acres, approximately 15.07 would be
developed as follows: Phase 1: 1.67 acres; Phase 2: 10.61 acres; Phase 3: 2.79 acres.

Three presence/absence surveys rounds were conducted on June 6, June 26, and July 6,
2024 during CBB’s peak Colony Active Period in areas determined as optimal nectar sources.
Efforts were made to survey during the most active flight and peak blooming periods of
potential nectar and pollen sources. Out of three survey rounds, a total of one CBB was
observed within the delineated survey area during the first survey (June 6, 2024). The species
was observed in the area east of the CCF, within an area that would not be developed and
where most of the habitat would not be disturbed by the Project (Refer to Figure 11 located at
the end of this section). The CBB was not identified in the remaining two surveys. Mitigation
Measure BIO-3 would be implemented and is designed to avoid and minimize potential
impacts to CBB.

Subsequent to the presence/absence surveys, a desktop habitat assessment was conducted

to determine the Project Site’s habitat quality for nectar, overwintering and nesting (Appendix
B-5). The study identified that, overall, while the entire 85.3 acre site provides some level of
nectar, overwintering and burrowing habitat, the total of 57 acres (including roads) impacted

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by the Project allows for nearly half of the Project Site to remain undisturbed for the CBB (refer
to Tables 2 and 3 in Appendix B-5).

Burrowing Owl

On October 10, 2024, the California Fish and Game Commission (CFGC) approved a petition
to proceed with candidacy to list the western burrowing owl (Athene cunicularia) as a candidate
protected species under the California Endangered Species Act (CESA). The BUOW is one
of 146 species that are also afforded protection under the MSHCP. Mitigation Measure BIO-2
would be implemented and is designed to avoid and minimize potential impacts to burrowing
owl.

Overall, the Project would not have a substantial adverse effect, either directly or through
habitat modifications, on any endangered, or threatened species, as listed in Title 14 of the
California Code of Regulations (Sections 670.2 or 670.5) or in Title 50, Code of Federal
Regulations (Sections 17.11 or 17.12) with the incorporated mitigation.

c) The Project Site contains suitable habitat for BUOW, identified by the CDFW as a candidate
protected species under California ESA and identified in the MSHCP. Mitigation Measure BIO-
2 would be implemented and is designed to avoid and minimize potential impacts to burrowing
owl. The Project Site also contains suitable habitat and one occurrence of CBB, which is also
a candidate protected species under the California ESA. Mitigation Measure BIO-3 would be
implemented and is designed to avoid and minimize potential impacts to CBB.

The Project Site and immediate surrounding areas also contain habitat suitable for nesting
birds in general, including the shrubs on site, and nesting birds are protected under the
Migratory Bird Treaty Act (MBTA) of 1918. The MBTA provides protection for nesting birds that
are both residents and migrants whether or not they are considered sensitive by resource
agencies. The MBTA makes it unlawful to take, possess, buy, sell, purchase, or barter any
migratory bird listed under 50 CFR 10, including feathers or other parts, nests, eggs, or
products, except as allowed by implementing regulations (50 CFR 21). The direct injury or
death of a migratory bird, due to construction activities or other construction-related
disturbance that causes nest abandonment, nestling abandonment, or forced fledging would
be considered take under federal law. The U.S. Fish and Wildlife Service (USFWS), in
coordination with the CDFW administers the MBTA. CDFW’s authoritative nexus to MBTA is
provided in FGC Sections 3503.5 which protects all birds of prey and their nests and FGC
Section 3800 which protects all non-game birds that occur naturally in the State.

To ensure potential impacts to nesting birds are avoided or minimized during construction of
the remaining Project Site, Mitigation Measure BIO-4 to conduct a pre-construction survey
for nesting birds and establishment of no-work buffers during construction is required to ensure
birds and their nests are not disturbed during construction. Refer to “Mitigation” at the end of
this section for details.

Impacts would be less than significant with the incorporated mitigation.

d) There are no native resident or migratory fish or wildlife species, established native resident or
migratory wildlife corridors, or native wildlife nursery sites on the Project Site according to
surveys conducted (Appendix B-1). The Project Site was not identified as occurring in a wildlife

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corridor or linkage or wildlife nursery site(s). The Proposed Project will be confined to existing
areas that have been heavily disturbed or developed, are isolated from regional wildlife
corridors and linkages, and there are no riparian corridors, creeks, or useful patches of
stepping stone habitat (natural areas) within or connecting the improvement areas to a
recognized wildlife corridor or linkage.

Impacts would be less than significant.

e) Refer to item a) above. Impacts would be less than significant with the incorporation of
Mitigation Measure BIO-1.

f) The biological survey identified that there are no State or federally protected wetlands
(including, but not limited to, vernal pools, marsh, coastal, etc.) on the Project Site. However,
the Project Site was determined to contain 33 road rut/small depressional areas that pond
seasonally. Vernal pools are seasonally inundated, ponded areas that only form in regions
where specialized soil and climatic conditions exist. During fall and winter rains typical of
Mediterranean climates, water collects in shallow depressions where downward percolation of
water is prevented by the presence of a hard pan or clay pan layer (duripan) below the soil
surface. Although 33 road rut/small depressional areas exhibit hydrology, the features are
compacted and lack hydric soils, and the features do not support any vegetation. As a result,
these features are not MSHCP vernal pools because they lack two of the parameters needed
to be considered as a depressional wetland.

There are three species of fairy shrimp with the potential to occur on-site: vernal pool fairy
shrimp (Branchinecta lynchi), Riverside fairy shrimp (Streptocephalus woottoni), and versatile
fairy shrimp (Branchinecta lindahli) (Appendix B-3). Vernal pool fairy shrimp are federally listed
as threatened, and Riverside fairy shrimp are federally listed as endangered, whereas the
versatile fairy shrimp is relatively common and is not listed or considered sensitive. Vernal pool
fairy shrimp have the widest geographic range of the federally listed vernal pool crustaceans
and occur from southern Oregon to northern and central California, generally west of the Sierra
Nevada, to southern California. The species’ range extends south to Orange and Los Angeles
counties and east to western Riverside County but is generally absent from San Diego County.
Vernal pool fairy shrimp are found in vernal pools and other vernal pool-like habitats such as
ephemeral ponds or features that can be formed from anthropogenic events such as tire ruts.
Riverside fairy shrimp can be found in Riverside, Orange, and San Diego counties and occur
in vernal pools and other ephemeral features with long inundation times. The versatile fairy
shrimp is common in pools throughout California .and can co-occur with both vernal pool and
Riverside fairy shrimp.

The road rut/small depressional features were surveyed for fairy shrimp according to the
USFWS protocol in the dry season of 2023 and the wet season of 2023/2024 (refer to Appendix
B-3), with follow-up surveys conducted in the dry season of 2024 for pools discovered during
the wet season of 2023/2024. The results indicated that no listed or sensitive fairy shrimp
occurred within any of the depressional features.

Impacts would be less than significant.

g) Aside from the MSHCP, the only other local policies/ordinances protecting biological resources
within the Project area are the Riverside County Oak Tree Management Guidelines and the

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Stephens' Kangaroo Rat (SKR) Impact Fee Area. There are no oak trees on the Project Site
that would be removed as a result of the Project, therefore, this guideline is not applicable.

The Project Site is located within the Mitigation Fee Area of the SKR Habitat Conservation
Plan. Therefore, the Applicant will be required to pay the SKR HCP Mitigation Fee prior to
development of the Project Site.

Impacts would be less than significant.

Mitigation: The following mitigation measures are required:

BIO – 1 Riverine/Riparian Habitat: Mitigation for the loss of 0.036-acre of riparian/riverine

habitat within Drainage 1 would occur as a conservation easement to be placed over
the 0.894 acre remainder of Drainage 1 as identified in the DBESP. A Habitat
Mitigation Monitoring and Reporting Program (HMMP) must be submitted to Riverside
County Planning for review. The HMMP would identify how the applicant would
maintain and manage the 0.894 acre area. Activities may include but not be limited to
removal of extensive invasive species, such as Tree of Heaven throughout the 0.894
acre area. Work can be performed by a third-party or by trained maintenance staff
with the oversight of a biologist.

BIO – 2 BUOW Avoidance and Minimization: A preconstruction survey shall be conducted

within 30 days prior to ground disturbance to avoid direct take of burrowing owls. If
burrowing owls are found to be present or nesting on-site during the preconstruction
survey, then the following recommendations must be adhered to: Exclusion and
relocation activities may not occur during the breeding season, which is defined as
March 1 through August 31, with the following exception: From March 1 through
March 15 and from August 1 through August 31 exclusion and relocation activities
may take place if it is proven to the County and appropriate regulatory agencies (if
any) that egg laying or chick rearing is not taking place. Any relocation activities
cannot occur without first consulting with the CDFW, and any relocation would be
conducted in accordance with the conditions set forth by the CDFW. The pre-
construction survey must be conducted by a qualified biologist; any relocation
activities would be undertaken by a qualified biologist as approved by the CDFW.

BIO-3 Crotch’s Bumble Bee: The Project will occur in phases, and this measure will apply
to each phase. If the Crotch’s bumble bee is no longer a candidate or listed species
under the California ESA at the time ground-disturbing activities, then no additional
protection measures are proposed for this species.

The Project Proponent shall not undertake Project activities within suitable habitat
until appropriate authorization (i.e., California Endangered Species Act (CESA)
Incidental Take Permit (ITP) under Fish and Game Code §2081) is obtained. The ITP
for Phase 1 will include but not be limited to mitigation for 1.67 acres of habitat loss
which may include but not be limited to 0.45 acre of suitable habitat that is located
within the 0.89 acre area conserved under BIO-1. Additional acreage may be required
in accordance with the ITP.

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This measure does not apply to work occurring in habitat that is not suitable for the
species in any phase.

BIO-4 Migratory Bird Avoidance and Minimization. Bird nesting season generally extends
from February 1 through September 15 in southern California and specifically, April
15 through August 31 for migratory passerine birds. To avoid impacts to nesting birds
(common and special status) during the nesting season, a qualified Avian Biologist
shall conduct pre‐construction Nesting Bird Surveys (NBS) at least three (3) days prior
to project‐related disturbance to nestable vegetation to identify any active nests. If no
active nests are found, no further action is required. If an active nest is found, the
qualified Avian Biologist shall set appropriate no‐work buffers around the nest which
will be based upon the nesting species, based on the individual species type, its
sensitivity to disturbance, nesting stage and expected types of nest, and the intensity
and duration of disturbance. The nests and buffer zones shall be field checked weekly
by a qualified biological monitor. The approved no‐work buffer zone shall be clearly
marked in the field, within which no disturbance activity shall commence until the
qualified biologist has determined the young birds have successfully fledged and the
nest is inactive.

Monitoring: Qualified biologists will conduct the pre-construction surveys as identified in the mitigation
measures.

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 Nectar Patches – 34.59 Acres Total

Nectar Patches to be developed – 15.07 acres total

B Crotchii location

Total DBESP Deed Restricted Area – 0.89 acres

Total B. Crotchii Nectar Overlap for Mitigation in

DBESP Restricted Area: 0.45 acres

Figure 11: DBESP and Crotch Bumble Mitigation Area

Not to Scale Source: Hunsaker & Associates
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CULTURAL RESOURCES Would the project:

8. Historic Resources
a) Alter or destroy a historic site?
b) Cause a substantial adverse change in the
significance of a historical resource, pursuant to California
Code of Regulations, Section 15064.5?

Source(s): On-site Inspection, Project Application Materials; Report by CRM Tech, titled
Historical/Archaeological Resources Survey Report, Crescent Garden Mortuary and Cemetery Project,
, December 14, 2023, revised June 23, 2024; (Appendix C-1, on file with the County); Report by Helix
Environmental Planning, titled Crescent Gardens Cemetery, Cultural Resources Phase II Testing
Report, PDA8402/CUP230002, July 2024 (Appendix C-2, on file with the County).

Findings of Fact:

a) The Historical/Archaeological Resources report prepared for the Project identified that within
the Project footprint existed five historic prospecting pits (sites 3719-03H and 3719-13H to -
16H), two sets of historic-era structural remains (3719-01H and -02H), and a historic-era refuse
scatter (3719-12H). Four of the prospecting pits (3719-03H and 3719-14H to -16H) were
recommended as not significant based on the results of the Phase I study. A Phase II study
was performed at the two sets of historic-era structural remains (3719-01H and -02H), the
historic-era refuse scatter (3719-12H) and prospecting pit 3719-13H to further identify the
significance of these sites. As a result of this testing program, which consisted of an intensive
resurvey of each of the four resources and the collection of surficial historic-era artifacts, as
well as expanded archival research, the Phase II report concluded that each resource was not
eligible for listing on the National Register of Historic Places (NHRP) or the California Register
of Historical Resources (CRHR). Based on this, the project will not have significant effects to
these historic period resources. However, given the potential to encounter subsurface
historical features Mitigation Measure 60-Planning-CUL-2 and 70-Planning CUL-2 that
requires inadvertent discovery of historical artifacts be evaluated by a project archaeologist
and identifies the disposition of potential artifacts. With the implementation of the mitigation
measure, impacts would be less than significant.

b) Public Resources Code Section 15064.5(a) defines historical resources, which includes: A
resource listed in, or determined to be eligible by the State Historical Resources Commission,
for listing in the California Register of Historical Resources (Pub. Res. Code §5024.1, Title 14
CCR, Section 14 CCR, Section 4850 et seq.). Based on the Phase 1 and Phase II cultural
resources reports, there are no historical resources that are considered eligible to the California
Register of Historical Resources. Implementation of Conditions of Approval would ensure that
potential impacts to unanticipated resources that may be found to be eligible would be avoided
or minimized.

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Mitigation: The following mitigation measures are required:

60. Prior to Grading Permit Issuance

60-Planning-CUL. 2 Inadvertent Discoveries: Historic Period Cultural Resources. If

previously unknown historic-period cultural resources are discovered on the project
site, work shall be temporarily halted within 60 feet of the discovery, and the resources
shall be evaluated by the Project Archaeologist and the Consulting Tribes in
consultation with County staff. If historic archaeological material associated with the
previously identified historic-period archaeological sites is encountered, cultural
features will be documented, and diagnostic artifacts will be collected before ground-
disturbing activities resume within 60 feet of the discoveries. This language shall be
included in the Cultural Resources Monitoring Plan.

70. Prior To Grading Final Inspection

70-Planning-CUL. 2 Artifact Disposition: Historic Resources: Prior to Grading Permit Final

Inspection, the landowner(s) shall relinquish ownership of all cultural resources that
are unearthed on the Project property during any ground-disturbing activities,
including previous investigations and/or Phase III data recovery.

Historic Resources- all historic archaeological materials recovered during the

archaeological investigations (this includes collections made during an earlier project,
such as testing of archaeological sites that took place years ago), shall be curated at
the Western Science Center, a Riverside County curation facility that meets State
Resources Department 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 County.

Monitoring: Monitoring required as identified in the mitigation measures above.

9. Archaeological Resources
a) Alter or destroy an archaeological site?
b) Cause a substantial adverse change in the
significance of an archaeological resource, pursuant to
California Code of Regulations, Section 15064.5?
c) Disturb any human remains, including those
interred outside of formal cemeteries?

Source(s): On-Site Inspection, Project Application Materials; Report by Report by CRM Tech, titled
Historical/Archaeological Resources Survey Report, Crescent Garden Mortuary and Cemetery Project,
December 14, 2023, revised June 23, 2024 (Appendix C, on file with the County); Report by Helix

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Environmental Planning, titled Crescent Gardens Cemetery, Cultural Resources Phase II Testing
Report, PDA8402/CUP230002, July 2024 (Appendix C, on file with the County),

a) The Phase 1 and Phase II cultural resources reports identified that a large Luiseño “village”
with bedrock mortars and metates, a “vast” midden deposit, cupule rocks and pictographs
encompasses much of the northern portion of the Project area, and extends outside the
Project to the north. This site has been recorded as P-33-000710 (CA-RIV-710). Given the
significance of this resource, the Project is designed to minimize and avoid the cultural
resource site through preservation of portions of the site in open space and use engineered
fill in other areas, so that the Project grave sites would be placed in the fill, and not below
ground where these resources exist. Implementation of the Mitigation Measures, as
identified below, which require monitoring and reporting by a qualified archaeologist and
tribal representatives would minimize potential impacts are required to reduce impacts to
this resource.

b) Refer to the above. The Phase II report also identified that while P-33-000710 (CA-RIV-
710) has not been formally evaluated for the NRHP or the CRHR, it is known to contain
cultural features and deposits of both cultural and tribal importance and scientific/
archaeological importance. Therefore, this resource is treated as potentially eligible for the
purpose of this Project. Implementation of the Mitigation Measures as identified above
would reduce impacts to less than significant.

c) Refer to the above.

Mitigation: The following mitigation measures are required:

60. Prior to Grading Permit Issuance

60-Planning-CUL. 1 ECS Sheet Resource Reburial Area. Prior to issuance of grading permits:
the developer/ applicant shall provide evidence to the Riverside County Planning
Department that an Environmental Constraints Sheet has been included in the
Grading Plans. This sheet shall indicate an area that will be used for reburial of any
artifacts that have been identified during grading and cannot be avoided. This area
will be protected and not disturbed in the future. This is confidential information, and
the exact nature of this area will not be called out on the grading plans.

60-Planning-CUL. 3 Inadvertent Finds. Avoidance and preservation in place is the preferred

method for all Tribal Cultural Resources inadvertently discovered during the course
of ground disturbing activities. If avoidance and preservation is not feasible, a
feasibility study shall be required for final determination regarding the need for
avoidance. If the County determines that the study has adequately demonstrated that
preservation is not feasible, a Data Recovery/Treatment Plan for the resource shall
be drafted in consultation with the Pechanga Band, and subject to review and
approval by the County of Riverside prior to implementation and recommencement of
ground disturbing activities.

If Tribal cultural resources are discovered during ground disturbance activities that
were not assessed by the archaeological report(s) and/or environmental assessment

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conducted prior to Project approval, the following procedures shall be followed.

Treatment of tribal cultural resources inadvertently discovered during the project’s
ground-disturbing activities shall be subject to the consultation process required by
state law and AB 52.

i. All ground disturbance activities within 100 feet of the discovered cultural resources
shall be halted until a meeting is convened between the Project Applicant, the Project
Archaeologist, the Tribal Representative(s), and the County to discuss the
significance of the find.

ii. At the meeting, the significance of the discoveries shall be discussed and after
consultation with the Tribal Representative(s) and the Project Archaeologist, a
decision shall be made, with the concurrence of the County, as to the appropriate
mitigation (documentation, recovery, avoidance, etc.) for the cultural resources.

iii. Further ground disturbance, including but not limited to grading, trenching etc., shall
not resume within the area of the discovery until an agreement has been reached by
all parties as to the appropriate mitigation. Work shall be allowed to continue outside
of the buffer area and will be monitored by additional Tribal Monitors if needed.

iv. Treatment and avoidance of the newly discovered resources shall be consistent
with the Cultural Resources Management Plan and Monitoring Agreements entered
into with the appropriate tribes. This may include avoidance of the cultural resources
through project design to the extent feasible, 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 Condition/Mitigation Measures.

v. 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 Tribe, and shall be submitted to the County for
their review and approval prior to implementation of the said plan.

vi. 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 Tribe(s) cannot agree on the significance or the mitigation for the
archaeological or cultural resources, these issues will be presented to the County of
Riverside for decision. The County 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 consider the
cultural and religious principles and practices of the Tribe. Notwithstanding any other
rights available under the law, the decision of the County shall be appealable to the
County Planning Commission and Historical Commission.

vii. Evidence of compliance with this mitigation measure, if a significant archaeological

resource is found, shall be provided to County of Riverside upon the completion of a
treatment plan and final report detailing the significance and treatment finding.

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60-Planning-CUL. 4 Native American Monitor. Prior to the issuance of grading permits, the
developer/permit applicant shall enter into an agreement with Pechanga for a Native
American Monitor. The Native American Monitor shall be on-site during all ground-
disturbing activities for development of the project, including clearing, grubbing, tree
removals, grading and trenching, removal of existing structural remains and
infrastructure, and over-excavation for Phases 1, 2, and 3 of project development. In
conjunction with the Archaeological Monitor, the Native American Monitor shall have
the authority to temporarily divert, redirect, or halt the ground disturbance activities to
allow identification, evaluation, and potential recovery of cultural resources.

The developer/permit applicant shall submit a fully executed copy of the agreement
to the County Archaeologist to ensure compliance with this condition of approval.
Upon verification, the Archaeologist shall clear this condition. This agreement shall
not modify any condition of approval or mitigation measure.

No monitor will be required post phased development and during the Cemetery
operations due to the reasons listed below.

a) The project has been designed to avoid impacts on known significant

archaeological/cultural resource (i.e., historical resource per CEQA), P-33-
000710 (CA-RIV-710), to the extent feasible.

b) The design features include avoiding bedrock milling features and cupule rocks,
and leaving large areas of the archaeological site in undeveloped open space.

c) The project design includes as-needed over-excavation to ensure that all

gravesites in the cemetery will have engineered fill or backfill extending to a
minimum depth of five (5) feet below finished grade. The planned graves will be
dug five (5) feet deep for the burial, per the established Muslim burial customs.
Therefore, by having a minimum of five (5) feet of engineered fill, all earthwork
during burials will remain within the engineered fill zone, and no natural ground
will be disturbed.

60-Planning-CUL. 5 Pre-grade Surface Collection. Prior to the start of any ground-disturbing

activity in any phase of the project, the Native American Monitor shall conduct a
surface collection of artifacts within that phase that would be subject to impacts from
ground disturbance. The artifacts/cultural material will be kept in a secure location on
site or temporarily kept by the Monitoring Tribe until such time as they are reburied in
a location agreed upon by the Consulting Tribes and the project applicant/developer.

60-Planning-CUL. 6. Project Archaeologist Archaeological Monitor. Prior to issuance of

grading permits, the developer/permit applicant shall provide evidence to the County
of Riverside Planning Department that a County-certified professional archaeologist
(Project Archaeologist) has been contracted to implement a Cultural Resource
Monitoring Program for Phases 1, 2, and 3 of project development. The Project
Archaeologist, in consultation with the Consulting Tribe(s) shall develop a Cultural
Resources Management Plan (CRMP) that addresses the details of all activities and
provides procedures that must be followed in order to reduce the impacts to cultural
and historic resources to a level that is less than significant, as well as address

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potential impacts to undiscovered buried archaeological resources associated with

this project. The CRMP shall include a Controlled Grading Plan that will identify
specific areas of the project site requiring controlled grading and detail the methods
for such grading. Controlled grading entails small lifts of soil (3-5 inches), allowing the
Native American Monitor and Archaeological Monitor adequate opportunity to
examine the ground surface in a more controlled manner than general mass grading.
This allows for recording cultural features and artifacts that may be destroyed or
overlooked in standard mass grading. Controlled grading will be utilized for soil
removals within and adjacent to the mapped boundaries of P-33-000710, in the areas
of the historic archaeological sites, and at other areas identified by the Project
Archaeologist or the Consulting Tribe(s) as requiring controlled grading. A fully
executed copy of the contract and a wet-signed copy of the CRMP shall be provided
to the County Archaeologist to ensure compliance with this condition of approval.

Working directly under the Project Archaeologist, an adequate number of qualified

Archaeological Monitors shall be present to ensure that all earth-moving activities for
project development are observed and shall be on-site during all ground-disturbing
activities for the project in areas with the potential to yield archaeological resources
(not in formational material), including clearing, grubbing, tree removals, grading and
trenching, removal of existing structural remains and infrastructure, and over-
excavation for Phases 1, 2, and 3 of project development. In conjunction with the
Native American Monitor, the Archaeological Monitor shall have the authority to
temporarily divert, redirect, or halt the ground disturbance activities to allow
identification, evaluation, and potential recovery of cultural resources.

60-Planning -CUL-7 Temporary Construction Fencing. Prior to the start of any ground-
disturbing activity, the applicant/developer shall ensure that temporary construction
fencing is placed at the edges of the extent of grading and around bedrock milling
features and cupule rocks within the development footprint to prevent inadvertent
movement of personnel and equipment into the areas of P-33-000710 that will remain
in undeveloped open space and to ensure that no removals of bedrock milling
features, cupule rocks, and cultural soils or cultural material occur in these areas. A
Native American Monitor and an Archaeological Monitor shall observe the placement
of fencing, which will be based on a fencing plan to be approved by the County
Archaeologist and the Consulting Tribes. No staging of material or equipment shall
occur within the fenced areas.

70. Prior To Grading Final Inspection

70-Planning-CUL. 1. Artifact Disposition: Prehistoric Resources. Prior to Grading Permit

Final Inspection, the landowner(s) shall relinquish ownership of all cultural resources
that are unearthed on the Project property during any ground-disturbing activities,
including previous investigations and/or Phase III data recovery.

Prehistoric Resources- The following treatment shall be applied.

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Reburial of the resources on the Project property. The measures for reburial shall
include, at least, the following: Measures to protect the reburial area from any
future impacts. Reburial shall not occur until all required cataloguing, analysis,
and studies have been completed on the cultural resources, with an exception
that sacred items, burial goods and Native American human remains are
excluded. Any reburial processes 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 County under a confidential
cover and not subject to a Public Records Request.

70-Planning-CUL. 3. Phase IV Monitoring Report. Prior to Grading Permit Final Inspection, 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 TLMA website. The report
shall include results of any feature relocation or residue analysis required, as well as
evidence of the required cultural sensitivity training for the construction staff held
during the required pre-grade meeting and evidence that any artifacts have been
treated in accordance with procedures stipulated in the Cultural Resources
Management Plan.

Monitoring: Prior to the issuance of grading permits, the Applicant

ENERGY Would the project:

10) Energy Impacts
a) Result in potentially significant environmental
impacts 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?

Source(s): Riverside County Climate Action Plan (CAP); California Emissions Estimator Model
(CalEEMod) version 2022.1.1.21 (Appendix A).

Findings of Fact:

a) Less than Significant Impact.

Electricity

The Proposed Project is the development of a Cemetery. Southern California Edison (SCE)
currently provides electrical service to the Project area. The demand for electricity associated
with the Proposed Project would be for operation of the Cemetery structures (CCF, Chapel,

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Residence, and Equipment Shed). In 2021, the Commercial sector of the Southern California
Edison planning area consumed 5965.998733 GWh of electricity. Based on the CalEEMod
2022.1.1.21 emission output tables for the Proposed Project, the estimated electricity demand
is 0.165554 GWH (refer to Appendix A - CalEEMod Data Outputs). The Proposed Project’s
estimated annual electricity consumption compared to the 2020 annual electricity consumption
of the overall Industry Sector in the SCE Planning Area would account for approximately
0.0004590 percent of total electricity consumption. Total electricity demand in SCE’s service
area is estimated to increase by approximately 12,000 GWh between the years 2015 and 2026.
The increase in electricity demand from the Proposed Project is insignificant compared to the
projected electricity demand within SCE’s service area.

The Proposed Project has been designed to comply with the 2022 Building Energy Efficiency
Standards. The County would review and verify that the Proposed Project plans would be in
compliance with the most current version of the Building and Energy Efficiency Standards. The
Proposed Project would also be required to adhere to CALGreen, which establishes planning
and design standards for sustainable developments, and energy efficiency. Adherence to these
requirements would result in the Proposed Project being efficient in terms of energy
consumption. The development of the Proposed Project is not anticipated to affect achievement
of the 60 percent Renewable Portfolio Standard established in in the current SB 100. SCE and
other electricity retailer’s SB 100 goals include that end-user electricity use such as residential
and commercial developments use would decrease from current emission estimates. The
Proposed Project would not result in a significant impact due to wasteful, inefficient, or
unnecessary consumption of energy resources, during project construction or operation and no
mitigation measures are recommended.

Natural Gas

Southern California Gas Company currently provides natural gas service to the project area. In
2021, the Commercial sector of the Southern California Gas Company planning area consumed
98.293612 million therms of natural gas. Based on the CalEEMod emission output tables for the
Proposed Project, the estimated natural gas demand is 7,430.84 therms of natural gas per year.
The Proposed Project’s estimated annual natural gas consumption compared to the 2020
annual natural gas consumption of the overall Industry Sector in the Southern California Gas
Company Planning Area would account for approximately 0.0008308 percent of total natural
gas consumption. No significant adverse impacts are identified or are anticipated, and no
mitigation measures are required.

In summary, the construction and operation of the Proposed Project would not result in the
inefficient, wasteful, or unnecessary use of energy. Impacts associated with energy use would
be less than significant and no mitigation is required.

Fuel

During operations of the Proposed Project, the use of fuel would be generated by maintenance
staff and product delivery/pick-up trips. The Proposed Project is not expected to result in a
substantial demand for energy that would require expanded supplies or the construction of other
infrastructure or expansion of existing facilities. The fuel use related with vehicle trips produced
by the Proposed Project would not be considered inefficient, wasteful, or unnecessary. The

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Proposed Project would not result in wasteful, inefficient, or unnecessary consumption of energy
resources. Impacts are less than significant, and no mitigation is recommended.

b) Less than Significant Impact. Construction of the Proposed Project would be temporary.
Limitations on idling of vehicles and equipment, and requirements that equipment be properly
maintained would save fuel. Fossil fuels used for construction vehicles and other energy-
consuming equipment would be used during site clearing, grading, paving, and building
construction. The County’s permissible hours for construction is 7:00 a.m. to 6:00 p.m. on non-
holiday weekdays, including Saturdays. As on-site construction activities would be restricted
between these hours, it is anticipated that the use of construction lighting would be minimal.

The State’s Title 24 energy efficiency standards are widely regarded as the most advanced
energy efficiency standards. These standards help reduce the amount of energy required for
lighting, water heating, and heating and air conditioning in buildings and promote energy
conservation. Policy OS 16.1 of the County General Plan reinforces the implementation and
enforcement of the California Code of Regulations (the “California Building Standards Code”)
particularly Part 6 (the California Energy Code) and Part 11 (the California Green Building
Standards Code), as amended and adopted pursuant to County ordinance. The Proposed
Project would be required by State law to comply with the Title 24 energy efficiency standards
and shall abide by the CAP.

Therefore, no significant adverse impacts are identified or anticipated, and no mitigation

measures are required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

GEOLOGY AND SOILS Would the project directly or indirectly:

10. Alquist-Priolo Earthquake Fault Zone or County
Fault Hazard Zones
a) Be subject to 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?

Source(s): Riverside County General Plan Safety Element (adopted September 28, 2021) Figure 1
“Fault Lines,” GIS database, California Department of Conservation; Report by Leighton, Inc titled,
Geotechnical Exploration and Infiltration Testing, Proposed Crescent Gardens Cemetery, East of the
Intersection of Garfield Street and Roberts Street, March 11, 2024 (Appendix D-1).

Findings of Fact:

a) The Project Site is located in Southern California, a seismically active area and susceptible to
the effects of seismic activity include rupture of earthquake faults. The Project Site is not
located on or near an Alquist-Priolo Earthquake fault, according to the geotechnical report in
Appendix D-1. The Project Site is located approximately 4.8 miles to the northeast of the
Elsinore fault zone and approximately 15.5 miles to the southwest of the San Jacinto fault zone
(Appendix D-1). Due to the distance of the Project Site from the closest fault zone, there is a

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less than significant potential for the Project to be subject to rupture of a known earthquake
fault. Impacts would be less than significant, and no mitigation measures are required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

11. Liquefaction Potential Zone

a) Be subject to seismic-related ground failure,
including liquefaction?

Source(s): Riverside County General Plan Safety Element (adopted September 28, 2021) Figure 2
“Liquefaction Zones,” Report by Leighton, Inc titled, Geotechnical Exploration and Infiltration Testing,
Proposed Crescent Gardens Cemetery, East of the Intersection of Garfield Street and Roberts Street,
March 11, 2024 (Appendix D-1).

Findings of Fact:

Liquefaction occurs when shallow, fine to medium-grained sediments saturated with water are
subjected to strong seismic ground shaking. It generally occurs when the underlying water table is 50
feet or less below the surface. The Project Site is identified by the Riverside County General Plan as
being in a mapped area with no potential for liquefaction except for the eastern portions of parcels 340-
180-016, 340-180-005, and 340-180-002, which are in an area designated as “low potential” for
liquefaction. The planned buildings are located on parcels identified by the General Plan as having no
potential for liquefaction. The parcels identified by the General Plan has having a “low potential” for
liquefaction are identified for cemetery plot use and interior cemetery roadways. Field work conducted
did not encounter groundwater during the subsurface investigation (Appendix D-1).

The Riverside County Department of Building and Safety reviews structural plans and geotechnical data
prior to issuance of a grading permit and conducts inspections during construction, which would ensure
that all required CBC (California Building standards Commission) measures are incorporated.
Compliance with the CBC as included as a condition of approval and verified by the County’s review
process would ensure that impacts related to liquefaction are less than significant.

Impacts would be less than significant, and not mitigation measures are required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

12. Ground-shaking Zone

a) Be subject to strong seismic ground shaking?

Source(s): Riverside County General Plan Safety Element (adopted September 28, 2021) Figure 1
“Fault Lines,” GIS database, California Department of Conservation; California Department of
Conservation; Report by Leighton, Inc titled, Geotechnical Exploration and Infiltration Testing, Proposed

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Crescent Gardens Cemetery, East of the Intersection of Garfield Street and Roberts Street, March 11,
2024 (Appendix D-1).

Findings of Fact:

a) The Project Site is located in Southern California, a seismically active area and susceptible
to the effects of seismic activity include rupture of earthquake faults. The Project Site is
located approximately 4.8 miles to the northeast of the Elsinore fault zone and
approximately 15.5 miles to the southwest of the San Jacinto fault zone (Appendix D-1).
The Proposed Project would be designed in accordance with the most current California
building codes that are designed to reduce structural impacts from earthquakes. The
Riverside County Department of Building and Safety reviews structural plans and
geotechnical data prior to issuance of a grading permit and conducts inspections during
construction, which would ensure that all required CBC (California Building standards
Commission) measures are incorporated. Compliance with the CBC as included as a
condition of approval and verified by the County’s review process would ensure that impacts
related to strong seismic ground shaking are less than significant.

Impacts would be less than significant, and no mitigation measures are required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

13. Landslide Risk

a) 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,
collapse, or rockfall hazards?

Source(s): On-site Inspection, Riverside County General Plan Safety Element (adopted September
28, 2021) Figure 3 “Landslide Risk,” Report by Leighton, Inc titled, Geotechnical Exploration and
Infiltration Testing, Proposed Crescent Gardens Cemetery, East of the Intersection of Garfield Street
and Roberts Street, March 11, 2024 (Appendix D-1).

Findings of Fact:

a) Landslides, Rockfall Hazards. Landslides are the downhill movement of masses of earth
and rock and are often associated with earthquakes; but other factors, such as the slope,
moisture content of the soil, composition of the subsurface geology, heavy rains, and
improper grading can influence the occurrence of landslides. The Project Site and adjacent
parcels range from gentle slopes to relatively flat with rocky outcroppings. Site elevations
range from approximately 1,540 to 1,660 feet above mean sea level (amsl). The ELAP
Figure 13 Steep Slopes identifies that steep slopes are located east of Project area. The
site has not been evaluated for seismically induced landslide potential by the State of
California. No mapped limits of historic landslides have been mapped by the California
Geological Survey on their Landslide Inventory Interactive website. Natural rolling hillsides
towards the southeast portion of the development have gradients that are generally 2:1

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(horizontal:vertical) or flatter and are composed of very dense shallow bedrock. These
slopes are not expected to pose seismically induced landslides hazards (Appendix D-1).
Therefore, Because the Project Site and vicinity are relatively flat with rolling hills, impacts
related to landslides or rock falls would not occur from implementation of the Proposed
Project. The impact would be less than significant.

Lateral Spreading. Lateral spreading is a type of liquefaction hazard associated with ground
failure and/or lateral displacement of surficial blocks of sediment resulting from liquefaction
in a subsurface layer. Once liquefaction transforms the subsurface layer into a fluid mass,
gravity plus the earthquake inertial forces may cause the mass to move downslope towards
a free face (such as a river channel or an embankment). The geotechnical investigation in
Appendix D-1 found that the potential for liquefaction at the Project Site to be very low due
to the shallow bedrock present at the site and the absence of liquefaction hazards.
Therefore, the Geotechnical Investigation determined that the Project Site is not susceptible
to lateral spreading.

Excavation and recompaction would be performed in compliance with the CBC as required
through the County’s permitting process would ensure that settlement-related impacts
would be less than significant, and no mitigation measures are required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

14. Ground Subsidence

a) 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 ground subsidence?

Source(s): On-site Inspection, Riverside County General Plan Safety Element (adopted August 6,
2019) Figure S-7 “ Documented Subsidence Areas,” GIS Database, Report by Leighton, Inc titled,
Geotechnical Exploration and Infiltration Testing, Proposed Crescent Gardens Cemetery, East of the
Intersection of Garfield Street and Roberts Street, March 11, 2024 (Appendix D-1).

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Findings of Fact:

a) In general, the Project Site has been mapped outside of any areas of subsidence due to
groundwater pumping, peat loss, or oil extraction as delineated by the United States Geological
Survey (USGS). The Project Site is identified by the Riverside County General Plan as being
in a mapped area with no potential for subsidence except for the eastern portions of parcels
340-180-002, 340-180-005, and 340-180-016, and the western portion of parcel 349-180-004,
which are designated as “susceptible” to subsidence. The planned buildings are located on
parcels identified by the General Plan as having no potential for subsidence. The parcels
identified by the General Plan as being “susceptible” to subsidence are identified for cemetery
plot use and interior cemetery roadways, but is underlain by shallow bedrock according to the
geotechnical investigation in Appendix D-1. Because the area is outside of groundwater
pumping and is underlain by shallow bedrock, impacts would be less than significant, and no
mitigation measures are required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

15. Other Geologic Hazards

a) Be subject to geologic hazards, such as seiche,
mudflow, or volcanic hazard?

Source(s): Project Application Materials; Report by Leighton, Inc titled, Geotechnical Exploration and
Infiltration Testing, Proposed Crescent Gardens Cemetery, East of the Intersection of Garfield Street
and Roberts Street, March 11, 2024 (Appendix D-1).

Findings of Fact:

a) The Project Site is not located near steep hillsides subject to mudflow or volcanoes
(Riverside County General Plan, Safety Element). With respect to seiches, the nearest body
of water to the Project Site is Canyon Lake, located approximately 1 mile to the east (Google
Earth Pro, 2022). A seiche is the sloshing of a closed body of water from earthquake
shaking. Seiches are of concern relative to water storage facilities because inundation from
a seiche can occur if the wave overflows a containment wall, such as the wall of a reservoir,
water storage tank, dam, or other artificial body of water. Due to the distance of the closest
water body an impact related to seiche would not occur. Therefore, there is no potential for
the Proposed Project to be subject to hazards associated with seiches, mudflows, and/or
volcanic hazards. No impacts would occur.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

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16. Slopes
a) Change topography or ground surface relief
features?
b) Create cut or fill slopes greater than 2:1 or higher
than 10 feet?
c) Result in grading that affects or negates
subsurface sewage disposal systems?

Source(s): Riv. Co. 800-Scale Slope Maps, Project Application Materials, Report by Leighton, Inc
titled, Geotechnical Exploration and Infiltration Testing, Proposed Crescent Gardens Cemetery, East of
the Intersection of Garfield Street and Roberts Street, March 11, 2024 (Appendix D-1), Report by
Lakeshore Engineering Inc titled, Percolation Feasibility Study Report, Conditional Use Permit 23002
Proposed Garden Cemetery, October 15, 2024 (Appendix D-2).

Findings of Fact:

a) As described previously, the Project Site and adjacent parcels range from gentle slopes to
relatively flat with rocky outcroppings. Site elevations range from approximately 1,540 to
1,660 feet above mean sea level (amsl), and there are no steep slopes on the Project Site.
The Project Site is not situated in or near a steep slope area as identified in ELAP Figure
13 – Steep Slope, nor within an area identified on ELAP Figure 14 – Slope Instability. The
Project Site is located adjacent and to the west of Steep Slopes as mapped on ELAP Figure
14. The Project would grade slopes and place fill as necessary for a more streamlined and
stable terrain, and elevations would remain generally similar to existing conditions. Thus,
while the Project would change topography or ground surface relief features, the impacts
would be less than significant, and no mitigation measures are required.

b) No cut or fill slopes greater than 2:1 are proposed as part of the Proposed Project grading.
There would be no impacts.

c) The Proposed Project would install a subsurface sewage disposal system. Percolation tests
were performed on the Project Site to design a septic system (Appendix D-2). The study
identified that the ground surface on the Project Site is undulating, from gentle to steep
sloping ground, distinct high ridgelines, valleys, drainage flowlines and watercourses.
Terrian contours in general appears are smooth and uniform, with annual grass and scrub
cover. Where buildings are proposed, land is relatively flat with only minor grading needed
for building pads construction. The result was that the ground showed no anomaly that
could impede system installation. The report further stated that existing ground in the area
of proposed leach field are relatively flat with minor earthwork grading required for pad
preparation, with less than 3 feet of cuts and/or fill placement needed for building pads
construction. No adverse conditions, such as rock outcrops or obstructions were
encountered in the field that could impede systems installation. Surface water runoff post
systems installation will remain as sheetflow across the subsurface leach field. The
installation and grading of the Project Site would be completed pursuant to the County’s
required specifications for sewer system installation for positive gravity flow. Therefore,
there would be no grading that affects or negates subsurface sewage disposal systems.
Impacts would be less than significant, and no mitigation measures are required.

Mitigation: No mitigation is required.

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Monitoring: No monitoring is required.

17. Soils
a) Result in substantial soil erosion or the loss of
topsoil?
b) Be located on expansive soil, as defined in Section
1803.5.3 of the California Building Code (2022), creating
substantial direct or indirect risks to life or property?
c) Have soils incapable of adequately supporting use
of septic tanks or alternative waste water disposal systems
where sewers are not available for the disposal of waste
water?

Source(s): U.S.D.A. Soil Conservation Service Soil Surveys, Project Application Materials, Report by
Leighton, Inc titled, Geotechnical Exploration and Infiltration Testing, Proposed Crescent Gardens
Cemetery, East of the Intersection of Garfield Street and Roberts Street, March 11, 2024 (Appendix D-
1); Report by Lakeshore Engineering Inc titled, Percolation Feasibility Study Report, Conditional Use
Permit 23002, Proposed Garden Cemetery, October 15, 2024 (Appendix D-2)

Findings of Fact:

a) Construction activities associated with the Proposed Project’s construction over the
approximately 46.4 net acres would involve earth movement and the exposure of soil which
has the potential to contribute to soil erosion and the loss of topsoil.

According to the geotechnical report in Appendix D-1, the Project Site is generally underlain
by a thin mantle of topsoil consisting of loose to medium dense sands with clays and silts,
silty sands, and clayey sands. Granitic bedrock was encountered underlying the topsoil in
the northwestern portion of the site and generally consisted of white to gray, with zones of
orange to orangish brown, reddish brown and brown, intensely weathered to decomposed
tonalite (Kgt). Phyllite (Trmp) bedrock encountered underlying the topsoil in the
southeastern portion of the site and generally consisted of gray, with fracture surfaces of
orange to orangish brown, moderately to intensely weathered. Granitic and metamorphic
bedrock in the geotechnical test pits were considered to be slightly weathered where
excavation refusal by a backhoe at depths ranging from 1½ to 7½ feet below ground surface
(bgs) in the test pits, with shallower bedrock generally being encountered towards the
eastern end of the site within the rolling hillsides and deeper bedrock being encountered
toward the west.

During construction, the Project would also be required to adhere to standard regulatory
requirements designed to reduce erosional impacts, including, but not limited to,
requirements imposed by the State Water Resources Control Board Construction General
Permit Order 2009-0009-DWQ which requires projects that disturb one (1) or more acres
of soil or whose projects disturb less than one acre but are part of a larger common plan of
development that in total disturbs one or more acres, obtain coverage under the General
Permit for Discharges of Storm Water Associated with Construction Activity Construction
General Permit Order 2009-0009-DWQ. Construction activity subject to this permit includes

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clearing, grading and disturbances to the ground such as stockpiling or excavation. The
Construction General Permit requires the development of a Storm Water Pollution
Prevention Plan (SWPPP) by a certified Qualified SWPPP Developer (QSD). The Proposed
Project is anticipated to disturb more than one acre, and therefore, would be subject to
preparation of a SWPPP. The SWPPP would include BMPs to be implemented during and
after Project construction to minimize erosion and sedimentation of downstream
watercourses. Impacts would be less than significant, and no mitigation measures are
required.

For operations, the Proposed Project includes installation of landscape and hardscape
features adjacent to the proposed buildings, throughout the proposed parking areas, and
interior roads and pathways, which would reduce erosion for these developed areas.

Operations of the cemetery burial grounds area include placing concrete liners with
concrete lids in the excavated plots that would be covered with soil that was excavated from
the burial plot. It is estimated that each vault would be installed approximately 5 feet below
ground surface, and approximately 18 inches of topsoil would be placed on top of each liner
with the lid. Gravel would be placed on top of the burial plot. The gravel would secure the
topsoil from eroding the top of each of the grave sites. Additionally, as a row of grave sites
are completed, concrete bands would be placed around each grave site. This would also
prevent the erosion of topsoil.

In addition, as described in Section 23, Hydrology and Water Quality, four water
quality/detention basins are designed to slow, filter, and retain stormwater within the
landscaped cemetery grounds, which would also reduce the potential for stormwater to
erode topsoil. Furthermore, implementation of the Project requires County approval of a
Water Quality Management Plan (WQMP), which would ensure that RWQCB requirements
and appropriate operational BMPs would be implemented to minimize or eliminate the
potential for soil erosion or loss of topsoil to occur. As a result, with implementation of
existing requirements, impacts related to substantial soil erosion or loss of topsoil would be
less than significant.

b) The geotechnical report prepared for the Project (Appendix D-1) identified that the near-
surface materials are low expansive with in expansion potential, as defined in Section
1803.5.3 of the California Building Code (2022). The Riverside County Department of
Building and Safety reviews structural plans and geotechnical data prior to issuance of a
grading permit and conducts inspections during construction, which would ensure that all
required CBC (California Building standards Commission) measures are incorporated.
Compliance with the CBC as included as a condition of approval and verified by the
County’s review process would ensure that impacts related to expansive soils are less than
significant.

c) The Project would install an on-site wastewater treatment system (OWTS) that includes a
septic tank and leachfields. The geotechnical analysis provided in Appendix D-2 identified
that shallow percolation tests were performed, and infiltration rates were good to moderate
in the area proposed for the system, which is the northeastern portion of the site, near the
proposed buildings. Based on the system layout, each of the three buildings would have its
own individual OWTS system. The installation and grading of the Project Site and
installation of the OWTS would be completed pursuant to the County’s required

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specifications for sewer system installation for positive gravity flow. The impacts would be
less than significant, and no mitigation measures are required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

18. Wind Erosion and Blowsand from project either on

or off site.
a) Be impacted by or result in an increase in wind
erosion and blowsand, either on or off site?

Source(s): Riverside County General Plan Safety Element (adopted August 6, 2019) Figure S-8 “Wind
Erosion Susceptibility Areas,” Riverside County General Plan Safety Element (Adopted Sept. 28,
2021),” GIS database, Ord. No. 460, Article XV & Ord. No. 484.

Findings of Fact:

a) Figure S-8 of the Riverside County General Plan Safety Element adopted August 6, 2019
identified that the Project Site is located within an area of Moderate Wind Erodibility rating.
The General Plan Safety Element adopted September 28, 2021 did not evaluate wind
erosion and blow sand as an independent risk category, but did evaluate the potential
effects of “severe weather” due to climate change. “Severe weather” was defined as
localized storms that bring heavy rain, hail, lightning, and strong winds. Severe weather is
usually caused by intense storm systems, although types of strong winds can occur without
a storm. The Safety Element includes a Vulnerability Assessment that identified “industrial
buildings” to have a “moderate vulnerability” to severe weather. The Riverside County
Department of Building and Safety reviews structural plans and geotechnical data prior to
issuance of a grading permit and conducts inspections during construction, which would
ensure that all required CBC (California Building standards Commission) measures,
including wind loading, are incorporated. Compliance with the CBC included as a condition
of approval and verified by the County’s review process would ensure that impacts related
to severe weather including wind erosion and blowsand are less than significant.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

GREENHOUSE GAS EMISSIONS Would the project:

20) Greenhouse Gas Emissions
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?

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Source(s): Riverside County General Plan; Riverside County Climate Action Plan (“CAP”); California
Emissions Estimator Model (CalEEMod) version 2022 outputs (Appendix A)

Findings of Fact:

a) Less than Significant Impact. The County of Riverside’s Climate Action Plan Update (CAP)
was completed in November 2019. The CAP Update describes Riverside County’s GHG
emissions for the year 2017, projects how these emissions will increase into 2020, 2030, and
2050, and includes strategies to reduce emissions to a level consistent with the State of
California’s emissions reduction targets. The CAP Update sets a target to reduce community-
wide GHG emission emissions by 15 percent from 2008 levels by 2020, 49 percent by 2030,
and 83 percent by 2050.

Appendix D of the Riverside County CAP Update also states that projects 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. Projects that
exceed emissions of 3,000 MTCO2e per year are also required to use Screening Tables.
Projects that garner at least 100 points will be consistent with the reduction quantities anticipated
in the County’s CAP Update. Consistent with CEQA Guidelines, such projects would be
determined to have a less than significant individual and cumulative impact for GHG emissions.
Those projects that do not garner 100 points using the Screening Tables will need to provide
additional analysis to determine the significance of GHG emissions.

Emissions associated with the construction and operation of the Proposed Project were
estimated using CalEEMod version 2022.1. The operational emissions analyzed a Cemetery
generating up to 39 daily trips. However, default values were used (46 trips per day). As such,
greenhouse gas emissions estimated for the Proposed Project are considered conservative.
Table 5 - Greenhouse Gas Construction Emissions shows that the total for the Proposed
Project’s construction emissions amortized over 30 years would be approximately 49.6
MTCO2e. Table 6 - Greenhouse Gas Operational Emissions identifies that the Proposed
Project operations would generate approximately 376.1 MTCO2e annually.

Table 5: Greenhouse Gas Construction Emissions (Metric Tons per Year)

Phase I
Source/Phase CO2 CH4 N20 R
Year 2025 200 <0.0 <0.0 <0.0
Year 2026 168 <0.0 <0.0 <0.0
Total MTCO2e 368
Construction Amortized (30 Years) 12.3
Phase II
Source/Phase CO2 CH4 N20 R
Year 2026 311 <0.0 <0.0 0.1
Year 2027 158 <0.0 <0.0 <0.0
Total MTCO2e 476
Construction Amortized (30 Years) 15.8
Phase III
Source/Phase CO2 CH4 N20 R
Year 2027 473 <0.0 <0.0 0.2
Year 2028 157 <0.0 <0.0 <0.0

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Total MTCO2e 645

Construction Amortized (30 Years) 21.5
Total of all Phases 49.6
Table 6: Greenhouse Gas Operational Emissions (Metric Tons per Year)

Source/Phase CO2 CH4 N20 R

Mobile 62.4 <0.0 <0.0 0.1
Area 0.4 <0.0 <0.0 ---
Energy 68.8 <0.0 <0.0 ---
Water 3.6 <0.0 <0.0 ---
Waste 8.9 <0.0 <0.0 ---
Refrigeration --- --- --- <0.0
Construction Equipment 158.2 0.2 0.1 ---
Construction Amortized (30 Years) 49.6
Total MTCO2e 376.1
County of Riverside screening threshold 3,000
Significant No
Source: CalEEMod.2022 Annual Emissions.
SCAQMD Emission Factors for construction equipment 2025.

According to the thresholds of significance, a cumulative global climate change impact would
not occur. GHG emissions created from the proposed construction and operations of the
Proposed Project would not exceed the Riverside County screening thresholds. Therefore, the
construction and operation of the Proposed Project would not create a significant cumulative
impact to global climate change.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

b) Less than Significant Impact. As referenced above, the County of Riverside CAP Update
(updated in December 2019) contains guidance on Riverside County’s GHG Inventory reduction
goals, thresholds, policies, guidelines, and implementation programs. In particular, the CAP
elaborates on the General Plan goals and policies relative to the GHG emissions and provides
a specific implementation tool to guide future decisions of the County of Riverside.

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.

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:

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 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 shown above, the proposed project is anticipated to generate 376.1 MTCO2e per year and
would not exceed the County’s screening threshold. In addition, prior to issuance of a building
permit the applicant will be required to demonstrate consistency with Title 24 energy efficiency
building requirements, California Green Building Code, and County water conservation
measures. Therefore, the Proposed Project is in compliance with County’s screening thresholds.
No significant impacts are identified or anticipated, and no mitigation measures are required.

CARB 2022 Scoping Plan

The California Air Resources Board 2022 Scoping Plan assesses progress toward the statutory
target of reducing GHG emissions to 40 percent below 1990 levels by 2030, while laying out a
path to achieving carbon neutrality no later than 2045. The 2022 Scoping Plan focuses on
outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy
deployment, natural and working lands, and others, and is designed to meet the State’s long-
term climate objectives and support a range of economic, environmental, energy security,
environmental justice, and public health priorities. All of the post-2020 reductions in GHG
emissions are addressed via regulatory requirements at the State level, and the Proposed
Project would be required to comply with these regulations as they come into effect.

The Proposed Project would comply with the CALGreen Code, regarding energy conservation
and green building standards. Therefore, the Proposed Project would comply with applicable
energy also comply with the CALGreen Code, which includes a variety of different measures,
including the reduction of wastewater and water use. In addition, the proposed Project would be
required to comply with the California Model Water Efficient Landscape Ordinance. Therefore,
the proposed Project would not conflict with any of the water conservation and efficiency
measures. Vehicles traveling to the Project site would comply with the Pavley II (LEV III)
Advanced Clean Cars Program. Therefore, the proposed Project would not conflict with the
identified transportation and motor vehicle measures. Implementation of the proposed Project
would not conflict with existing plans, policies, and regulations adopted for the purpose of
reducing the emissions of greenhouse gas with the 2022 Scoping Plan.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

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HAZARDS AND HAZARDOUS MATERIALS Would the project:

19. 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?
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?
c) Impair implementation of or physically interfere
with an adopted emergency response plan or an emergency
evacuation plan?
d) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste within
one-quarter (1/4) mile of an existing or proposed school?
e) 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?

Source(s): Report by Environmental Managers & Auditors, Inc.. titled Phase 1 Environmental Site
Assessment of Proposed Crescent Gardens Cemetery, Meadowbrook Community, December 2020,
(Appendix E).

Findings of Fact:

a) A hazardous material is a substance that is toxic, flammable/ignitable, reactive, or

corrosive. Extremely hazardous materials are substances that show high or chronic toxicity,
carcinogenic, bioaccumulative properties, persistence in the environment, or that are water
reactive. Improper use, storage, transport, and disposal of hazardous materials and waste
may result in harm to humans, surface and groundwater degradation, air pollution, fire, and
explosion.

Construction

Construction of the Proposed Project would involve the use and routine transport of small
quantities of construction-related chemicals including but not limited to hydraulic fluids,
motor oil, grease, runoff, and other related fluids and lubricants. The construction activities
would involve the disposal and recycling of materials, trash, and debris. The County’s
General Plan Safety Element addresses potential hazards in the County and identifies
goals and policies to reduce risks and damages associated with hazards, including disposal
of hazardous materials due to human activities. Compliance with all local, State and federal
regulations related to hazardous materials use and transport during construction would
reduce potential hazards to the public or the environment through the routine transport, use,
or disposal of hazardous materials.

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Operations

The Proposed Project would operate a cemetery. Body preparation in the CCF only includes
water and standard, natural body soap and does not include the use of hazardous materials
or embalming fluids.

Maintenance of the facilities may involve the use of typical limited hazardous materials,
such as: cleaning agents, paints, pesticides, batteries, and aerosol cans. Normal routine
use of these types of products would not result in a significant hazard to residents or
workers in the vicinity of the Proposed Project as these materials would be handled and
stored in compliance with all with applicable federal, state, and local requirements.

The Project would include the use of a backhoe to excavate grave sites. This activity may
include but would not be limited to hydraulic fluids, motor oil, grease, runoff, and other
related fluids and lubricants. The County’s General Plan Safety Element addresses
potential hazards in the County and identifies goals and policies to reduce risks and
damages associated with hazards, including disposal of hazardous materials due to human
activities. The Project operation may include the routine transport of small quantities of fuel,
oil and hydraulic fluid to maintain the grave site digging equipment. However, the operator
is required to comply with all local, State and federal regulations related to hazardous
materials use and transport during operation which would reduce potential hazards to the
public or the environment through the routine transport, use, or disposal of hazardous
materials.

Therefore, operation of the Proposed Project would result in a less than significant impact
related to the routine transport, use, or disposal of hazardous materials and no mitigation
measures are required.

b) A Phase 1 Environmental Site Assessment (ESA) was prepared for the Project Site
(Appendix E). The Phase 1 ESA identified that there were no potentially hazardous
conditions that existed on the Project Site. The Phase 1 ESA identified that the property
has generally been historically vacant with some residential structures that have been
removed.

Construction

Construction activities would require the temporary use of hazardous substances, such as
fuel, lubricants, and other petroleum-based products for the operation of construction
equipment as well as oil, solvents, or paints. As a result, the Proposed Project could result
in the exposure of persons and/or the environment to an adverse environmental impact due
to the accidental release of a hazardous material. However, the transportation, use, and
handling of hazardous materials would be temporary and would coincide with the short-
term Project construction activities. Further, the construction contractor is required to
ensure that these materials would be handled and stored in compliance with all with
applicable federal, state, and local requirements. Any handling of hazardous materials
would be limited to the quantities and concentrations set forth by the manufacturer and/or
applicable regulations, and all hazardous materials would be securely stored in a
construction staging area or similar designated location within the Project Site. In addition,
the handling, transport, use, and disposal of hazardous materials must comply with all

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applicable federal, state, and local agencies and regulations, including the Department of
Toxic Substances Control; Occupational Health and Safety Administration (OSHA);
Caltrans; and the County Health Department - Hazardous Materials Management Services.

Operations

As discussed, the Proposed Project would operate a cemetery. Body preparation in the
CCF only includes water and standard, natural body soap and does not include the use of
hazardous materials or embalming fluids. The business operation would generally use
typical limited hazardous materials, such as: cleaning agents, paints, pesticides, batteries,
and aerosol cans. Normal routine use of these types of products would not result in a
significant hazard to residents or workers in the vicinity of the Proposed Project as these
materials would be handled and stored in compliance with all applicable federal, state, and
local requirements. Impacts would be less than significant, and no mitigation measures are
required.

c) The Proposed Project would not impair implementation of or physically interfere with an
adopted emergency response plan or an emergency evacuation plan. Project construction
would occur on a vacant parcel. Short-term construction of off-site improvements will occur
along local roadways, but the construction will be conducted consistent with all applicable
rules for traffic control which outlines procedures for emergency situations. The Project
design allows for adequate emergency access off the site onto local roads. Evacuation
routes are determined by the local emergency services; none are identified adjacent to the
Project Site. The Proposed Project would be reviewed by the local emergency services
agencies for compliance with all applicable codes. Impacts would be less than significant,
and no mitigation measures are required.

d) The Quail Valley Elementary School is located approximately 2 miles east of the Project.
Small quantities of fuel and lubricants will be transported to the Project Site during
construction. As previously discussed, the limited quantities of hazardous materials would
be transported, handled, and disposed of in accordance with all regulations. Additionally,
the potential emissions that would be generated from construction and operation of the
Proposed Project were evaluated in the air quality analyses presented in this document
which identified that the emissions generated from the Proposed Project would not cause
or contribute to an exceedance of the federal or state air quality standards. Thus, the
Proposed Project would not emit hazardous or handle acutely hazardous materials,
substances, or waste within 0.25 mile of school. No impacts would occur.

e) The Phase 1 ESA prepared for the Project (Appendix E) included a historical literature
review of the Project Site and surrounding area. The results indicated that 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. Therefore, construction and operation of
the Proposed Project would not create a significant hazard to the public or the environment.
No impacts would occur.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

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20. Airports
a) Result in an inconsistency with an Airport Master
Plan?
b) Require review by the Airport Land Use
Commission?
c) For a project located within an airport land use plan
or, where such a plan has not been adopted, within two (2)
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?
d) For a project within the vicinity of a private airstrip,
or heliport, would the project result in a safety hazard for
people residing or working in the project area?

Source(s): Riverside County General Plan Figure S-20 “Airport Locations,” GIS database.

Findings of Fact:

a) The Project Site is not located within an Airport Master Plan; therefore, the Project would
not result in an inconsistency with an Airport Master Plan. There would be no impacts.

b) The Project Site is not located near any airport, therefore, land use approvals do not apply.
The closet airport is the March Air Reserve Base in Perris, located approximately 10 miles
to the northeast and the Perris Valley Airport, located approximately 5 miles to the
east/northeast. The Project Site is outside of any airport compatibility zone, based on a
review of the March Air Reserve Base/Inland Port Airport Land Use Compatibility Plan
(November 2014) and the Riverside County Airport Land Use Plan Policy Document for the
Perris Valley Airport (July 2010). There would be no impacts.

c) Refer to Item 20.b above. There would be no impacts.

d) The Project Site is not located within two miles of any private airstrip, or heliport; therefore,
the Project would not create a safety hazard for people residing or working in the Project
area. There would be no impacts.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

HYDROLOGY AND WATER QUALITY Would the project:

21. Water Quality Impacts
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?

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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?
d) Result in substantial erosion or siltation on-site or
off-site?
e) Substantially increase the rate or amount of
surface runoff in a manner which would result in flooding on-
site or off-site?
f) 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?
g) Impede or redirect flood flows?
h) In flood hazard, tsunami, or seiche zones, risk the
release of pollutants due to project inundation?
i) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater management
plan?

Source(s): Riverside County General Plan Figure S-9 “Special Flood Hazard Areas,” Figure S-10
“Dam Failure Inundation Zone,” GIS database; Report by Hunsaker & Associates Irvine Inc, titled
Preliminary Hydrology Report for Crescent Gardens Cemetery, January 2025 (Appendix F-1); Report
by Hunsaker & Associates Irvine Inc, titled Preliminary Water Quality Management Plan, Crescent
Gardens Cemetery, March 13, 2024 (Appendix F-2).

The Project Site is situated approximately 5 miles northeast of Lake Elsinore and approximately 1 mile
west of Canyon Lake, which is a source of drinking water that is provided by the Elsinore Valley
Municipal Water District (EVMWD). The EVMWD obtains its potable water supplies from imported water
from the Metropolitan Water District, local surface water from Canyon Lake, and local groundwater from
the Elsinore Basin. Additionally, the groundwater obtained from its groundwater wells is disinfected with
chlorine and chloramines at the wellhead and represents 40-50 percent of drinking water supplies.

Findings of Fact:

a) Groundwater and surface water at the Project Site is regulated by the Regional Water
Quality Control Board-Santa Ana Region (SARWQCB). The Water Quality Control Plan for
the Santa Ana River Basin (Basin Plan) contains the Region Board's policies for managing
the Region's water quality. The Basin Plan includes the water quality standards (water
quality objectives, beneficial uses, and anti-degradation policy) for the Region, regionally
important water quality management and improvement initiatives, policies and practices for
implementing water quality standards, and implementation plans. The Project Site is within
the San Jacinto River Basin.

According to the Preliminary Water Quality Management Plan (PWQMP, Appendix F-2),
receiving waters include Canyon Lake and Lake Elsinore. Table 7: Beneficial Uses of
Receiving Waters identifies the Basin Plan’s beneficial uses for these water bodies and
Table 8: Water Quality Objectives for Receiving Waters identifies the water quality
standards as identified in the Basin Plan.

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Table 7: Beneficial Uses of Receiving Waters

Canyon
Lake
(Railroad Lake Elsinore
Canyon
Beneficial Use
Reservoir)
(excepted from
Municipal and Domestic Supply (MUN) X
MUN)
Agricultural Supply (AGR) X
Industrial Service Supply (IND)
Industrial Process Supply (PROC)
Groundwater Recharge (GWR) X
Navigation (NAV)
Hydropower Generation (POW)
Water Contact Recreation (REC1: Primary Contact Recreation) X X
Non-contact Water Recreation (REC2: Secondary Contact Recreation) X X
Commercial and Sportfishing (COMM) X X
Warm Freshwater Habitat (WARM) X X
Limited Warm Freshwater Habitat (LWRM)
Cold Freshwater Habitat (COLD)
Preservation of Biological Habitats of Special Significance (BIOL)
Wildlife Habitat (WILD) X X
Rare, Threatened or Endangered Species (RARE) X
Spawning, Reproduction and Development (SPWN)
Marine Habitat (MAR)
Source: Basin Plan, Chapter 3, Table 3-1

Table 8: Water Quality Objectives for Receiving Waters

Canyon Lake
(Railroad
Constituent Canyon Elsinore,
Reservoir)(1) Lake(2)
Total Dissolved Solids 700 2,000
Hardness 325 ---
Sodium 100 ---
Chloride 90 ---
Total Inorganic Nitrogen 8 1.5
Sulfate 290 ---
Chemical Oxygen Demand --- ---
Source: Basin Plan, Chapter 3, Table 3-1
Notes:
(1) The quality objectives for Canyon Lake is not intended to preclude transport of water supplies or delivery to
the Lake
(2) Lake volume and quality highly variable

In 1998, Canyon Lake was added to the SARWQCB list of “impaired” waters based on
periodic algal blooms and fish kills. In 2004, a mechanism was adopted by the SARWQCB

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to regulate the amount of nutrients released into the area tributary to Canyon Lake (i.e.,
Total Maximum Daily Load or TMDL). Because Canyon Lake is an “impaired” waterbody,
all properties that drain to it must provide stormwater treatment that targets the pollutants
for which the lake is listed during construction and long-term operation. The SARWQCB
enforces the regulations that target pollutants discharged from construction activities as
well as long-term operational activities, including National Pollutant Discharge Elimination
System (NPDES) permits. The Project site is not located within a groundwater
management zone (GMZ) designated by the SARWQCB Basin Plan (SARWQCB-A) and
the Project is not located within a groundwater basin identified by the California Department
of Water Resources (DWR) Bulletin 118. However, Canyon Lake is a tributary to the
Elsinore GMZ and the Elsinore Valley Groundwater Basin.

Construction

Construction activities and post-construction operations may have the potential to

discharge pollutants to downstream waterbodies during storm events and incidental (non-
rainfall) runoff, which could violate water quality standards/waste discharge requirements.
The SARWQCB requires that dischargers whose construction projects disturb one (1) or
more acres of soil or whose projects disturb less than one acre but are part of a larger
common plan of development that in total disturbs 1 or more acres, obtain coverage under
the General Permit for Discharges of Storm Water Associated with Construction Activity
Construction General Permit Order 2009-0009-DWQ. Construction activity subject to this
permit includes clearing, grading and disturbances to the ground such as stockpiling, or
excavation. The Construction General Permit requires the development of a Storm Water
Pollution Prevention Plan (SWPPP) by a certified Qualified SWPPP Developer (QSD).

The Proposed Project would disturb approximately 46.4 of the 89 acres in three phases
over 15-20 years. It is anticipated that individual SWPPPs would be prepared for each
phase. Phase 1, as described in the Project Description of this document, would be
completed as one phase. However, because development of Phase 2 and Phase 3 requires
significant soil import, it is anticipated that Phase 2 and Phase 3 would be developed in
subareas, based on soil availability. It is anticipated that soil would be stockpiled until it is
used for construction.

The Project SWPPP which would be developed for each phase of construction, modified if
necessary to include the subphases. The SWPPP would include construction BMPs to
minimize the potential for construction related sources of pollution, per County conditions
of approval. Construction BMPs may include but not be limited to:

• Silt fencing, fiber rolls, or gravel bags

• Street sweeping and vacuuming
• Storm drain inlet protection
• Stabilized construction entrance/exit
• Vehicle and equipment maintenance, cleaning, and fueling
• Hydroseeding
• Material delivery and storage
• Stockpile management
• Spill prevention and control
• Solid waste management

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• Concrete waste management

Adherence to the existing requirements and implementation of the appropriate BMPs per
the permitting process would ensure that activities associated with construction would not
violate water quality standards. As a result, impacts related to the degradation of water
quality during construction of the Proposed Project would be less than significant.

Post-Construction and Operations – Surface Water

Riverside County and 23 other cities and agencies obtained a joint permit NPDES permit
from the SARWQCB (Order No. R8-2010-0033, NPDES Permit No. CAS618033) to control
pollutants in runoff. The NPDES requires the preparation of a Water Quality Management
Plan (WQMP). The WQMP outlines what method(s) are to be employed to effectively treat
in perpetuity the required amount of post-construction stormwater and incidental runoff for
the expected pollutants. Methods include infiltration systems, bioretention or biotreatment
basins, sand filters and harvest/reuse cisterns. The Project will be required to comply with
the MS4 requirements to minimize the release of pollutants into downstream surface and
ground waters from redevelopment projects.

The Proposed Project has prepared a Project Specific Preliminary Water Quality
Management Plan (PWQMP), which is provided in Appendix F-2. The PWQMP identifies
stormwater controls for the post-construction condition and includes Low Impact
Development (LID) site design, source control, and treatment control BMPs. The County
would review and approve the PWQMP as part of the design for the Proposed Project.

The PWQMP Drainage from the proposed surface drainage and storm drain facilities will
either be conveyed to one of the four water quality/detention basins or be conveyed off-site
to existing natural channels depending on the location and drainage patterns. requirements.
The proposed drainage basins are designed to convey the 100-year peak flow generated
on the Project Site and are designed to mitigate any water quality and hydromodification
impacts of the proposed development. The first flush of all storm runoff will be treated in the
water quality/detention basins prior to leaving the Project Site, as detailed in the WQMP.
The proposed grading of the Project Site slightly alters the original drainage boundaries and
drainage areas of the existing Project Site but does not significantly alter the original
drainage patterns or runoff discharge locations.

The PWQMP in Appendix F-2 identifies the Drainage Management Areas (DMA) of the site,
where flows would be directed based on grading, and how the flows would be treated as
follows:

• DMA A (1.8 acres) – Consists of a chapel and parking lot. Majority of runoff from
this DMA will be conveyed to a Bioretention Basin/Detention Basin located at the
northeast corner of the DMA A.
• DMA B (2.2 acres) – Consists of a chapel, caretaker’s residence and parking lot.
Majority of runoff from this DMA will be conveyed to Bioretention Basin/Detention
basin located in the eastern corner of the DMA B.

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• DMA C (0.3 acres) – Consists of the western portion of “A” Street. The low point of
DMA C is located adjacent to the 100-year flood plain limit, therefore a BMP is not
suitable for this location. DMA H has been oversized to mitigate flows for DMA C.
• DMA D (0.4 acres) – Consists of the eastern portion of “A” Street. The low point of
DMA D is located adjacent to the 100-year flood plain limit, therefore a BMP is not
suitable for this location. DMA H has been oversized to mitigate flows for DMA D.
• DMA E (1.6 acres) – Consists of a grave site and will be considered “Self-Treating”
and will convey flows off site to natural area and will not comingle flows.
• DMA F (1.8 acres) - Consists of a grave site and will be considered “Self-Treating”
and will convey flows off site to natural area and will not comingle flows.
• DMA G (33.6 acres) – Consists of grave sites, “B” Street, “D” Street and a portion
of “A” Street and will convey flows to a proposed Bioretention Basin.
• DMA H (7.8 acres) – Consists of grave sites, portion of “B” Street and “E” Street and
will convey flows to a proposed Proprietary Biofiltration System (8’x20’ Modular
Wetland System). DMA H has been oversized to mitigate flows from DMA C and
DMA D that are adjacent to the flood plain limits and the street area within the flood
plain limits.
• DMA I (6.3 acres) – Consists of grave sites and “C” Street and will convey flows to
a proposed Bioretention Basin/Detention Basin.

Additionally, there is no publicly operated wastewater system that serves the area. The
Project proposes to construct an onsite septic system for its employees and visitors. The
system would be designed in accordance with County standards and approved by the
County.

Additionally, the EVMWD collects water samples weekly, monthly, quarterly, annually and
tri-annually to ensure the safety and quality of the water served. Sample frequency depends
on State regulations and health risk factors. Therefore, any potential increase in
constituents that may enter the groundwater or surface waters that may be attributed to the
cemetery would be identified early through routine sampling.

Post-Construction and Operations – Groundwater

The Project’s geotechnical report (Appendix D-1) identifies that groundwater at the Project
Site occurs at a depth of approximately 147 feet below ground surface. It acknowledged
that perched groundwater may occur at between 13 and 15 feet in some areas, depending
soil type and precipitation.

The Project proposes a burial process that reduces risk to groundwater quality as only the
natural body would decay in a grave that would be approximately 5 feet below ground
surface. The process does not utilize makeup or cosmetics, formaldehyde or other
embalming fluids that could enter the groundwater during the body’s decomposition
process. The burial also does not include the use of a casket where paints and plastics and
metal can also decay over time and potentially cause an impact to groundwater quality.

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Preparing the body for the grave consists of washing the body is washed with traditional
soap and water in the CCF, where the waste rinse water would be directed into a separate
tank that would be pumped and disposed of by a licensed vendor, and would not be directed
to the septic system. This method would ensure that any biological pathogens would not
enter into the groundwater. Plot development consists of excavating a rectangle shape in
the earth that would be approximately 5 feet deep 3 feet wide with a soil bottom (refer to
Figure 8B). A bottomless concrete liner with a lid would be placed in the excavated space.
The body would be placed in the concrete vault, and a concrete lid would be placed on top
of the concrete liner. Approximately 18 inches of soil would be placed on the top of the lid.

A 2015 article in the Journal of Water and Health 1 studied the impact on groundwater
contamination by bacteria and viruses caused by cemeteries. It identified that while corps
can release bacteria, many pathogens gradually die after the death of the host body as they
are not capable of surviving for a long time outside of the host body, especially when
environmental conditions are inappropriate. While the study was conducted in various areas
of the world and not directly in the United States, the study concluded that in a moderate
climate condition, a relatively low impact of cemeteries on groundwater pollution by bacteria
and viruses was observed. Additionally, it identified that the bottom of the grave should be
at least 5 feet above the groundwater level.

According to the geotechnical report (Appendix D-1), groundwater primarily exists at 147
feet below ground surface, although perched groundwater may occur at between 13 and
15 feet in some areas, depending soil type and precipitation. Plot development consists of
excavating a rectangle shape in the earth that would be approximately 5 feet deep 3 feet
wide with a soil bottom (refer to Figure 8B). Therefore, there would be approximately a
minimum of a 6-foot earthen buffer between the bottom of the grave and any perched
groundwater pocket that may occur, which also reduces potential for bacteria to directly
enter the groundwater during natural body decay.

Therefore, with implementation of the SWPPP during construction and implementation of

the WQMP during operations, as well as the operational burial practices, the Project would
not violate water quality standards or waste discharge requirements or otherwise
substantially degrade surface or ground water quality. Impacts would be less than
significant, and no mitigation measures are required.

b) The Project site is not located within a groundwater management zone (GMZ) designated
by the SARWQCB Basin Plan and the Project is not located within a groundwater basin
identified by the California Department of Water Resources (DWR) Bulletin 118. However,
Canyon Lake is tributary to the Elsinore GMZ and the Elsinore Valley Groundwater Basin
area and may contribute to recharge of that basin.

There are two wells on site; however, they are non-operable, and no permits for them could
be located. These wells are believed to be associated with previous agricultural activities.
The Project will not refurbish these wells nor construct new wells. All water supplied to the
site will be from the Elsinore Valley Municipal Water District. The Project site may provide
groundwater recharge benefits because of the approximately 85-acre site, approximately

1
Journal of Water and Health, Volume 13, Issue 2, as accessed 11/10/24 at:
https://iwaponline.com/jwh/article/13/2/285/28303/Impact-of-cemeteries-on-groundwater-contamination

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51 acres (approximately 57 percent) will either remain undeveloped or consist of

landscaping, basins and graded slopes. The Project design includes four earthen water
quality/detention basins that would collect stormwater from the impervious surfaces and
allow it to percolate in the ground. The approximately 31 acres of impervious surfaces
(approximately 36 percent) includes 9.12 acres of parking, roads and paved areas, and
24.6 acres of grave plots that would consist of a concrete vault, topped with soil and gravel.
Hence, the Project may continue to be a source of potential groundwater recharge in the
future.

Therefore, the Proposed Project would not substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such that the Proposed Project may
impede sustainable groundwater management of the groundwater basin. Impacts would be
less than significant, and no mitigation is required.

c) One unnamed drainage feature (Drainage 1) was observed within the boundaries of the
Project Site at the time of the investigation (Appendix B-2). Drainage 1 extends from south
to north within the northwest region of the project site. Drainage 1 conveys flows primarily
outside of the proposed limits of disturbance before terminating near the northwest corner
of the site. Drainage 1 receives flows direct precipitation upstream and from the discharge
waters of a well in the middle of the drainage, outside the proposed limits of disturbance,
which was installed to provide water to onsite agricultural activities. The upstream portion
of Drainage 1 appears to only support surface water immediately following storm events.
An interior roadway is planned to cross this drainage. As such, a road culvert will be placed
within the drainage to facilitate the road. Project approvals include a PWQMP developed to
satisfy the requirements of the adopted NPDES program, which would be verified by the
County’s Building and Safety Division through the County’s permitting process and through
conditions of approval. Therefore, the Proposed Project would result in less than significant
impacts related to alteration of the drainage pattern of the site or area, and no mitigation
measures are required.

d) As discussed in 21.a, the phase-specific SWPPPs that would be prepared for each phase
of construction by the project contractor would include BMPs to be implemented during and
after project construction to minimize erosion or siltation on-site and/or off-site.
Implementation of a WQMP would provide operational BMPs to ensure that operation of
cemetery use would not result in erosion or siltation. Impacts would be less than significant,
and no mitigation measures are required.

e) Project construction includes the preparation of phase-specific SWPPPs that would include
BMPs to be implemented during Project construction to minimize the rate and/or amount of
surface runoff during construction. The Project’s drainage features would make the site
drainage consistent with the existing drainage pattern for the area (refer to Appendix F-1).
Therefore, the Proposed Project would not substantially increase the rate or amount of
surface runoff in a manner which would result in flooding on-site or off-site. Impacts would
be less than significant, and no mitigation measures are required.

f) The Proposed Project’s stormwater would not exceed the capacity of the existing or planned
stormwater drainage system in the area because the Project proposes to retain all
stormwater on site. Therefore, the Project would not create or contribute runoff water which
would exceed the capacity of existing or planned stormwater drainage systems or provide

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substantial additional sources of polluted runoff. Impacts would be less than significant, and
no mitigation measures are required.

g) As indicated in General Plan Figure S-9 and S-10, the Project Site is not located in an area
with the potential for flood hazards where the Proposed Project would impede or redirect
flood flows. According to FEMA FIRM Panel No. 06065C2034G (8//28/2008) and Panel No.
6065C2032G (3/28/2008), the Project is within “Zone X” which is defined as “Area of
Minimal Flood Hazard” and outside of a 0.2 percent (500-year) annual chance floodplain.
This designation is not a special flood hazard zone and would not require flood insurance.
Because the Project is not located within a flood hazard zone and outside of the 0.2 percent
500-year flood plain, the Proposed Project will not impede or redirect flood flows. There
would be no impacts.

h) As indicated in General Plan Figure S-9 and S-10, the Project Site is not located in an area
of a flood hazard, tsunami, or seiche zone. Therefore, there is no risk related to the release
of pollutants due to Project Site inundation. There would be no impacts.

i) The Project receives potable water service from EVMWD which serves both groundwater
and imported water. EVMWD pumps water from the Elsinore Valley Basin located to the
west of Canyon Lake and the Bedford-Coldwater Basin located northwest of Lake
Elsinore. EVMWD has been actively managing these groundwater basins and currently
serves as the Groundwater Sustainability Agency (GSA) for the Elsinore Valley basin,
referred to as “EVGSA,” and as a partner in the Bedford-Coldwater Groundwater
Sustainability Authority (BCGSA), which serves as the GSA for the Bedford-Coldwater
basin. Both GSAs are in the process of developing groundwater sustainability plans
(GSPs), which call for the basins to be sustainably managed. The Project Site is located
in the Elsinore Valley GSA, according to the Department of Water Resources Sustainable
Groundwater Management Area GIS mapping portal
(https://sgma.water.ca.gov/webgis/index.jsp?jsonfile=https%3a%2f%2fsgma.water.ca.gov
%2fportal%2fresources%2fjs%2fmapconfigs%2fGsaMaster.js, accessed 1/24/25).

Because the Project, by design, allows for future recharge or other groundwater
management activities to sustainably manage surrounding basins, the proposed Project will
not substantially decrease groundwater supplies or interfere substantially with groundwater
recharge such that the project may impede sustainable groundwater management of the
basin.

As described previously, the Proposed Project would be required to have approved

SWPPPs for each phase of construction, which would include construction BMPs to
minimize the potential for construction related sources of pollution. For operations, the
Proposed Project would be required to implement source control BMPs to minimize the
introduction of pollutants; and treatment control BMPs to treat runoff in accordance with its
approved WQMP. With implementation of the operational source and treatment control
BMPs that would be required by the County during the Project permitting and approval
process, potential pollutants would be reduced to the maximum extent feasible, and
implementation of the Proposed Project would not obstruct implementation of a water
quality control plan or sustainable groundwater management plan. Therefore, impacts are
less than significant.

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Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

LAND USE/PLANNING Would the project:

22. Land Use
a) 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?
b) Disrupt or divide the physical arrangement of an
established community (including a low-income or minority
community)?

Source(s): Riverside County General Plan, GIS database, Project Application Materials.

Findings of Fact:

The Project Site lies within the Elsinore Area Plan (ELAP). The Land Use of the parcels
range from Rural Mountainous (RM) with a General Plan Foundation Component of Rural
and a Land Use of Very Low Density Residential (VLDR) with a General Plan Foundation
Component of Community Development. The Project Site is located within the
unincorporated community of Meadowbrook, which is characterized by very low density
residential development and vacant properties set amid rolling hills.

The Project does not lie within any of the policy or Land Use Overlay areas of the ELAP.
Impacts would be less than significant, and no mitigation measures are required.

a) The Proposed Project would occur over approximately 46.4 acres of approximately 85
acres of vacant lands located at the eastern edge of where rural residential has developed
in the area, where rolling hills and vacant land exist. The Proposed Project will not disrupt
or divide the physical arrangement of the community because the Proposed Project is
allowed within the zoning with a conditional use permit. There would be no impact.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

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MINERAL RESOURCES Would the project:

23. Mineral Resources
a) Result in the loss of availability of a known mineral
resource that would be of value to the region or 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?
c) Potentially expose people or property to hazards
from proposed, existing, or abandoned quarries or mines?

Source(s): Riverside County General Plan Figure OS-6 “Mineral Resources Area.”

Findings of Fact:

a) The State Mining and Geology Board (SMGB) has also established Mineral Classification
Zones (MRZs) to designate lands that contain mineral deposits. The Riverside County
General Plan identifies the Project area as “MRZ-3 (areas where the available geologic
information indicates that mineral deposits are likely to exist, however, the significance of
the deposit is undetermined). No mining activities are proposed. An area with undetermined
mineral significance would not be valuable to the region or residents of the state until its
mineral significance is confirmed. Additionally, the Project Site is surrounded by residential.
The current uses of the Project Site and surrounding areas are not compatible with mineral
resource extraction. Therefore, no significant impacts are identified or anticipated, and no
mitigation measures are required. There would be no impacts.

b) The Project is zoned MRZ-3 which contains undetermined mineral deposits. However, the
Project Site is not located within a planning area designated for mining. There would be no
impacts.

c) There are no existing or abandoned mines or quarries on site. There would be no impacts.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

NOISE Would the project result in:

24. Airport Noise
a) For a project located within an airport land use plan
or, where such a plan has not been adopted, within two (2)
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?
b) For a project located within the vicinity of a private
airstrip, would the project expose people residing or working
in the project area to excessive noise levels?

Source(s): Riverside County General Plan Figure S-20 “Airport Locations,” County of Riverside Airport
Facilities Map.

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Findings of Fact:

a) The Project Site is not located near any airport; therefore, project would not expose people
residing or working in the project area to excessive noise levels. The closet airport is the
March Air Reserve Base in Perris, located approximately 10 miles to the northeast and the
Perris Valley Airport, located approximately 5 miles to the east/northeast. There would be
no impact.

b) There are no private airstrips in the vicinity of the Project. There would be no impact.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

25. Noise Effects by the Project
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, noise ordinance, or applicable standards of
other agencies?
b) Generation of excessive ground-borne vibration or
ground-borne noise levels?

Source(s): Riverside County General Plan, Table N-1 (“Land Use Compatibility for Community Noise
Exposure”), Report by Report by MD Acoustics titled, Crescent Gardens Cemetery, Noise Impact
Analysis, May 16, 2024 (Appendix G).

Findings of Fact:

a) Environmental noise is commonly measured in A-weighted decibels (dBA). A decibel (dB)

is a unit of sound energy intensity. Sound waves, traveling outward from a source, exert a
sound pressure level (commonly called a “sound level”) measured in dB. An A-weighted
decibel (dBA) is a decibel corrected for the variation in frequency response that duplicates
the sensitivity of human ears. Decibels are measured on a logarithmic scale. Generally, a
3 dBA increase in ambient noise levels represents the threshold at which most people can
detect a change in the noise environment; an increase of 10 dBA is perceived as a doubling
of loudness.

To determine potential noise impact standards, the Noise Impact Analysis in Appendix G
utilized the criteria standards provided in Table 9: Riverside County Allowable Exterior
Noise Level.

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Table 9: Riverside County Allowable Exterior Noise Level

Maximum Decibel Level
General Plan Land Use Designation
7 a.m. - 10 p.m. 10 p.m. - 7 a.m.
Low Density Residential 55 45
Medium Density Residential 55 45
Medium High Density Residential 55 45
Commercial Retail 65 55
Light Industrial 75 55

The Noise Impact Study also analyzed the existing noise levels at four noise-sensitive
receptor locations closest to the Project Site on March 22, 2024, along property lines of
residential uses to the west and to the south based on the site layout and operational
aspects of the site.

Construction

The County of Riverside outlines its noise standards within its General Plan and Riverside
County Ordinance 847. Ordinance 847 also identifies a list of exemptions and exceptions
to the noise standards which includes construction and demolition. Riverside Ordinance
847 identifies that private construction within one-quarter of a mile from an inhabited
dwelling cannot occur between the hours of 6:00 p.m. and 6:00 a.m. during the months of
June through September; and between the hours of 6:00 p.m. and 7:00 a.m. during the
months of October through May.

Construction noise would be limited primarily to the use of the heavy equipment for site
grading and excavating activities at the site which will be short-term in nature.

Phase 1 consists of 7.8 acres of cemetery land that would be developed east and southeast
of the CCF/chapel area and offer a projected 6,237 plots, as well as several buildings and
entry features at Garfield Road. All cemetery land site work consists of a cut and fill
designed to balance, therefore, there would be no import or export of material. Phase 1 is
anticipated to occur over 12 months. The remaining phases would occur occasionally over
the next 15 to 20 years as import soil and finances become available.

Construction overall will occur during the permissible hours as described in the County of
Riverside Noise Ordinance 847.

Construction noise associated with the project was calculated at nearby sensitive receptors
utilizing methodology presented in the Federal Highway Administration (FHWA)
Construction Noise Model together with several key construction parameters including
distance to each sensitive receiver, equipment usage, percent usage factor, and baseline
parameters for the project site.

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 distance to the closest receiver from the center of the site represents an average of
equipment moving around the site per the FTA Noise and Vibration Manual. Additionally,

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the FTA Noise and Vibration Manual gives a daytime noise criterium of 80 dBA Leq of
residential land uses. Table 10: Construction Noise Level Compliance. The Noise
Impact Study also analyzed the construction noise levels at the closest sensitive receptor,
identified to be the residence located to the west of the main entrance.

Table 10: Construction Noise Level Compliance

Leq Noise Levels at Nearest Criteria

Phase 1 Activity Sensitive Receptor (dBA) Criteria Exceeded?
Demolition 66 80 No
Site Prep 63 80 No
Grading 68 80 No
Building Construction 66 80 No
Paving 62 80 No
Arch coat 53 80 No
Phase 2 (Future) 40 80 No
Phase 3 (Future) 52 80 No
Note:
Construction Modeling Worksheets are provided in Appendix G.

Construction noise would range from 53 to 68 dBA Leq at the residential use located to the
west of the Project Site. If construction does not occur outside the permitted hours outlined
in section 9.52.020, the Project would be exempt from the provisions of the County of
Riverside Municipal Code. Thus, the Project would adhere to the local noise guidelines for
construction activities and the impact is less than significant. Additionally, the construction
noise is below the FTA Noise and Vibration Manual criterium for daytime residential
construction noise. Therefore, the noise impacts due to Project construction noise are
considered less than significant at all receiver locations.

Operations

Operations consist of a cemetery where operational noise would generally consist of traffic
traveling to the site to attend the funeral, the HVAC units in the buildings, and a single piece
of equipment such as a small backhoe to dig and fill the grave sites as required. There
would be no singing or outdoor music.

Sensitive receptors that may be affected by project operational noise include existing
residences to the west and south. Operational noise, evaluated in Appendix G, was
determined to fall below the County of Riverside’s residential daytime noise standard as
identified in Table 11: Operational Noise Level Compliance.

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Table 11: Operational Noise Level Compliance

Existing Ambient Project Daytime (7 a.m. - 10 p.m.) Total Combined

Receptor1 Noise Level Noise Level Non Transp. Noise Limit Noise Level
(dBA, Leq)2 (dBA, Lmax)3 (dBA, Lmax) (dBA, Lmax)
1 48 50 55 52
2 45 51 55 52
3 42 48 55 49
4 42 46 55 47
Notes:
1.
Receptors 1 and 2 represent residential uses to the west. Receptors 3 and 4 represent the southern property line.
2.
See Appendix G for the ambient noise measurement.
3.
See Exhibit F in Appendix G for the operational noise level projections at said receptors.

The Project will be conditioned to operate within the County of Riverside guidelines for type
of use and hours of operation.

Traffic

A worst-case Project generated traffic noise level was modeled utilizing the FHWA Traffic
Noise Prediction Model - FHWA-RD-77-108. Traffic noise levels were calculated 50 feet
from the centerline of the analyzed roadways in the noise analysis in Appendix G. The noise
analysis identified that the change in traffic noise along Greenwald Avenue, north of Suzan
Street, which is the main roadway anticipated to be utilized to access the site would be 0.1
dbA, which would not be perceptible.

Impacts would be less than significant, and no mitigation measures are required.

b) The Caltrans Transportation and Construction Vibration Guidance Manual (Guidance

Manual) is used to evaluate potential construction vibration impacts related to both potential
building damage and human annoyance (Appendix G). Based on the Caltrans criteria
shown in Table 19 of the Guidance Manual, construction vibration impacts would be
significant if vibration levels exceed 1.0 inches per second (in/sec) PPV (transient sources)
and 0.5 in./sec. PPV (continuous/frequent intermittent sources) for new residential
structures.

Certain types of construction equipment can generate high levels of ground borne vibration.
Construction of the Proposed Project would potentially utilize bulldozers, loaded trucks, and
jackhammers during construction phases. Vibration impacts are assessed based on the
distance from the location of vibration-intensive construction activities, conservatively
assumed to be at edge of a project site, to the edge of nearby off-site structures.

Table 12: Vibration Source Levels for Construction Equipment presents the combined
noise levels for the loudest construction equipment, assuming they operate at the same
time. As shown on Table 9, the construction noise levels are expected to range from 50.4
to 58.9 dBA Leq at the nearby receiver locations (Appendix G).

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Table 12: Vibration Source Levels for Construction Equipment

Peak Particle Velocity Approximate Vibration Level

Equipment (inches/second) at 25 feet LV (dVB) at 25 feet
1.518 (upper range) 112
Pile driver (impact)
0.644 (typical) 104
0.734 upper range 105
Pile driver (sonic)
0.170 typical 93
Clam shovel drop (slurry wall) 0.202 94
Hydromill 0.008 in soil 66
(slurry wall) 0.017 in rock 75
Vibratory Roller 0.21 94
Hoe Ram 0.089 87
Large bulldozer 0.089 87
Caisson drill 0.089 87
Loaded trucks 0.076 86
Jackhammer 0.035 79
Small bulldozer 0.003 58
1
Source: Transit Noise and Vibration Impact Assessment, Federal Transit Administration, May 2006.

At a distance of 40 feet (distance from the site to the nearest residences), a vibratory roller
would yield a worst-case 0.125 PPV (in/sec) which may be perceptible but below any risk
of damage (0.5 in/sec PPV is the threshold of old residential structures). The impact is less
than significant, and no mitigation is required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

PALEONTOLOGICAL RESOURCES:
26. Paleontological Resources
a) Directly or indirectly destroy a unique paleontological
resource, site, or unique geologic feature?

Source(s): Riverside County General Plan Figure OS-8, Report by Leighton, Inc titled, Geotechnical
Exploration and Infiltration Testing, Proposed Crescent Gardens Cemetery, East of the Intersection of
Garfield Street and Roberts Street, March 11, 2024 (Appendix D-1); Report by CRM Tech titled,
Paleontological Resources Assessment Report, Crescent Gardens Cemetery Project, August 28, 2023
(Appendix D-3).

Findings of Fact:

a) The site is located within a prominent geomorphic feature known as the Perris Block
(Appendix D-1). The Perris Block is comprised of various granitic rocks underlain by pre-
batholithic low grade crystalline rocks characterized as metamorphic rock of Mesozoic age
which manifest mostly at the ground surface near the margins of the Perris block.

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The valley areas of the region are characterized by accumulated alluvial sediment
consisting of stratified sequences of sand, silt and clay that is moderately consolidated. The
alluvial sediment is underlain at depth by the granitic rock of the Perris block. Isolated
outcrops of these granitic rocks are noted on-site confined to the north and northwest
portions of the property. The rocks consist mainly of granodiorite, gabbro, and tonalite.
These resistant rock outcrops are surrounded by thin accumulations of older alluvial soil
that has accumulated over time, likely dating back to the late Pleistocene. Pleistocene units
are considered to be highly paleontologically sensitive.

In order to identify any paleontological resource localities that may exist in or near the
Project area and to assess the probability for such resources to be encountered during the
Project, a paleontological records search, literature review, and a field inspection of the
Project area were conducted (Appendix D-3).

The results of the paleontological analysis in D-3 identified that the majority of the site is
situated on top of tonalite sediments that date to the Cretaceous period and Mesozoic-age
phyllite sediments with a north-south trending, late- to middle-Pleistocene band of alluvial-
channel deposits in the mid-south-southeastern part of the project area. The tonalite and
phyllite deposits are considered to be of low paleontological sensitivity. The old alluvial
channel deposits, however, have a higher paleontological sensitivity. The paleontological
records search indicated that no paleontological localities have been reported within the
project area or within 1 mile of its borders. However, numerous fossil localities have been
reported throughout Riverside County in old alluvial channel deposits similar to those
present in the mid-south-southeastern portion of the project area, making these types of
sediments to be considered highly sensitive for paleontological resources.

The Riverside County General Plan identifies that most of the Project Site is of a low
paleontological sensitivity while the eastern portion has a “undetermined” sensitivity for
paleontological resources.

As a result, Mitigation Measure PAL-1 is included to require that any substantial excavations
below 4 feet in the old alluvial-channel deposits in the mid-south-southeastern corner of the
project area be monitored to identify and recover any significant fossil remains. With
implementation of Mitigation Measure PAL-1, impacts to paleontological resources would
be less than significant.

Impacts would be less than significant with mitigation incorporated.

Mitigation: The following mitigation measure is required:

PAL – 1 Paleontological Monitoring. Prior to the issuance of grading permits, the Applicant
shall provide a letter to the County of Riverside Planning Department, or designee,
from a professional paleontologist, stating that a qualified paleontologist has been
retained to provide services for the Project. The paleontologist will monitor all site
preparation activities that involve excavations that extend down into older
Pleistocene-aged deposits. In the event paleontological resources are encountered,
ground disturbing activity within 50 feet of the area shall cease. The paleontologist
shall examine the materials encountered, assess the nature and extent of the find,

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and recommend a course of action to further investigate and protect or recover and
salvage those resources that have been encountered.

Monitoring: Monitoring is required pursuant to Mitigation Measure PAL-1, above.

POPULATION AND HOUSING Would the project:

27. Housing
a) Displace substantial numbers of existing people or
housing, necessitating the construction of replacement
housing elsewhere?
b) Create a demand for additional housing,
particularly housing affordable to households earning 80% or
less of the County’s median income?
c) 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)?

Source(s): Project Application Materials, GIS database, Riverside County General Plan Housing
Element.

Findings of Fact:

a) The Project Site is vacant and unoccupied, therefore, construction and operations of the
Project will not displace substantial numbers of existing people or housing, necessitating
the construction of replacement housing elsewhere. There would be no impact.

b) The Proposed Project would develop a cemetery with gathering facilities and grounds. For
purposes of analysis, the Project is estimated to require approximately 1 to 3 employees.
The employees that would fill these roles are anticipated to reside within commuting
distance and would not generate needs for any housing. The California Employment
Development Department Labor Market Information Division published an average 3.9%
unemployment rate in March 2023 for the four communities near the Project Site (Moreno
Valley, Nuevo, Perris, and Riverside).

In addition, should the Project require employees to relocate to the area for work, there is
sufficient vacant housing available within the region, including the Mead Valley area, City
of Perris, City of Hemet, City of Moreno Valley and City of Menifee. Riverside County, and
the cities within proximity to Mead Valley, have adopted General Plan Housing Elements
which describe their jurisdiction’s strategies for accommodating affordable housing. Thus,
the Proposed Project would not create a demand for substantial additional housing,
including housing affordable to households earning 80 percent or less of the County’s
median income. Impacts would be less than significant, and no mitigation measures are
required.

c) As discussed, workers are anticipated to come from within the region. The Project is
consistent with the ELAP and the County General Plan with a primary Land Use designation
of Very Low Density Residential. Additionally, the Project would provide a caretaker’s

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residence as part of the Project facilities. Therefore, the Project will not 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). Impacts would be less than significant, and no mitigation measures are
required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

PUBLIC SERVICES Would the project result in substantial adverse physical impacts associated with
the provision of new or physically altered government facilities or the 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
following public services:
28. Fire Services

Source(s): Riverside County General Plan, Google Earth imagery, GIS Database, General Plan Final
Program Environmental Impact Report (State Clearinghouse No. 2002051143)

Findings of Fact:

The Project Site receives fire protection services from the Riverside County Fire Department
(RCFD). Development of the Project Site with a cemetery that would hold religious services has
the potential to increase the frequency of fire protection calls to the site.

Riverside County Fire Station 97, 41725 Rosetta Canyon Dr, Lake Elsinore, CA is located
approximately 3 miles from the Project Site that can service the Project within acceptable service
ratios, response times or other performance objectives.

To ensure adequate fire protection for all residents of Riverside County, the Riverside County
Department of Building and Safety and the RCFD enforce fire standards as they review building
plans, conduct building inspection and review structures for compliance with the California Code,
including Public Resources Code Sections 4290-4299 and California Government Code Section
51178 that address fire safety and Riverside County Ordinance No. 787 (Fire Code Standards).
Although the Proposed Project’s increased demand on fire services could impact the RCFD’s
response times, the impact under CEQA is determined to be less than significant because the
Proposed Project would be served from existing RCFD fire stations and would not require the
construction of a new fire station or physical alteration of an existing fire station. The Project
Applicant would be required to comply with Riverside County Ordinance No. 659 (the County
Development Impact Fee [DIF]), which requires a fee payment by developers for the funding of
public facilities, including fire protection facilities.

Therefore, the Project will not result in substantial adverse physical impacts associated with the
provision of new or physically altered fire services or facilities. Impacts would be less than
significant, and no mitigation measures are required.

Mitigation: No mitigation is required.

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Monitoring: No monitoring is required.

29. Sheriff Services

Source(s): Riverside County General Plan, General Plan Final Program Environmental Impact Report
(State Clearinghouse No. 2002051143)

Findings of Fact:

The Project Site is located within an existing service area of the Riverside County Sherriff
Department and specifically serviced by the Perris Station, located at 137 N. Perris Blvd, Suite
A, Perris, CA 92570, approximately 6 miles northeast of the Project Site. In addition to the main
assigned substation, the Sheriff’s Department maintains routine patrols in various areas of the
County to maintain acceptable service ratios and response times. The Proposed Project would
result in additional on-site employees and visitors that could create the need for sheriff services.
Operation of the cemetery may generate a typical range of sheriff service calls, such as
burglaries, thefts, and visitor disturbances. Unincorporated Riverside County has set a minimum
standard of 1.0 deputy per 1,000 residents. As discussed throughout this document, the
Proposed Project would not result in an increase in residents. As such, the Project would not
result in a demand for additional Sheriff’s Department employees, facilities, or service levels.
The Project Applicant will be required to comply with Riverside County Ordinance No. 659 (the
County DIF), which requires a fee payment by developers for the funding of public facilities,
including sheriff protection facilities. Therefore, the Proposed Project will not result in substantial
adverse physical impacts associated with the provision of new or physically altered sheriff
services or facilities. Impacts would be less than significant, and no mitigation measures are
required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

30. Schools

Source(s): GIS database, General Plan Final Program Environmental Impact Report (State
Clearinghouse No. 2002051143)

Findings of Fact:

The Project Site is located in the Val Verde Unified School District. The Proposed Project
consists of a cemetery that would not directly generate students. As described previously, the
Proposed Project is not anticipated to generate a new population, as the employees needed to
operate the Project are anticipated to come from within the Project region. Pursuant to
Government Code Section 65995 applicants shall pay developer fees to the appropriate school
districts at the time building permits are issued, and payment of the adopted fees provides full
and complete mitigation of school impacts. Therefore, the Project will not result in substantial
adverse physical impacts associated with the provision of new or physically altered school

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services or facilities. Impacts would be less than significant, and no mitigation measures are
required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

31. Libraries

Source(s): Riverside County General Plan, General Plan Final Program Environmental Impact Report
(State Clearinghouse No. 2002051143)

Findings of Fact:

The Project consists of the development of a cemetery where employees are anticipated to
come from within the local region. As such, there would be no increase in population where the
existing area and regional libraries would need to expand personnel or physical building space
to accommodate additional patrons. The Project Applicant will be required to comply with
Riverside County Ordinance No. 659 (the County DIF), which requires a fee payment by
developers for the funding of public facilities, including library facilities. Therefore, the Proposed
Project will not result in substantial adverse physical impacts associated with the provision of
new or physically altered library services or facilities. Impacts would be less than significant, and
no mitigation measures are required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

32. Health Services

Source(s): Riverside County General Plan.

Findings of Fact:

The General Plan indicates the location of several hospitals and medical facilities all located
within 5 to 10 miles of the Project Site, including medical offices and urgent care centers located
approximately 7 miles north in the vicinity of the SR-74 and I-215 junction. The Project can be
served by existing health services within acceptable service ratios. Therefore, the Project will
not result in substantial adverse physical impacts associated with the provision of new or
physically altered health services or facilities. Impacts would be less than significant, and no
mitigation measures are required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

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RECREATION Would the project:

33. Parks and Recreation
a) Include recreational facilities or require the
construction or expansion of recreational facilities which
might have an adverse physical effect on the environment?
b) Increase the use of existing neighborhood or
regional parks or other recreational facilities such that
substantial physical deterioration of the facility would occur
or be accelerated?
c) Be located within a Community Service Area (CSA)
or recreation and park district with a Community Parks and
Recreation Plan (Quimby fees)?

Source(s): GIS database, Ord. No. 460, Section 10.35 (Regulating the Division of Land – Park and
Recreation Fees and Dedications), Ord. No. 659 (Establishing Development Impact Fees), Parks &
Open Space Department Review.

Findings of Fact:

a) The Proposed Project consists of the development of a cemetery where employees are
anticipated to come from within the region and therefore would not require new park or
recreational facilities. Therefore, the Proposed Project does not propose to build a park and
would not create the need for new recreational facilities or require the construction or
expansion of recreational facilities which might have an adverse physical effect on the
environment. Impacts would be less than significant, and no mitigation measures are
required.

b) The Proposed Project consists of the development of a cemetery where employees are
anticipated to come from within the region and therefore would not require new park or
recreational facilities or use facilities in a manner that would cause deterioration of existing
parks. The Project Applicant will be required to comply with Riverside County Ordinance
No. 659 (the County DIF), which requires a fee payment by developers for the funding of
public facilities, including park facilities. The Project does not increase population and will
not increase the use of existing neighborhood or regional parks or other recreational
facilities such that substantial physical deterioration of the facility would occur or be
accelerated. Impacts would be less than significant, and no mitigation measures are
required.

c) According to the County of Riverside Economic Development publicly available mapping,

the Proposed Project is not located in a Community Service Area (CSA) or recreation and
park district with a Community Parks and Recreation Plan (Quimby fees). There would be
no impact.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

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34. Recreational Trails

a) Include the construction or expansion of a trail
system?

Source(s): Riverside County General Plan Figure C-6 Trails and Bikeway System, Elsinore Area Plan.

Findings of Fact:

a) An extensive system of proposed trails and bikeways exists within the ELAP planning area
connecting the various neighborhoods with the recreational resources of the Cleveland
National Forest and the regional trail system. The Elsinore Area Plan trail system is mapped
in the ELAP, Figure 8, Trails and Bikeway System. A Regional Trail: Urban/Suburban is
mapped on ELAP Figure 8 to traverse south and east of the Project Site’s Phase 2 and
Phase 3 areas. Trail spurs from the Regional Trail have been informally developed by trail
users and local residents to traverse the Project Site’s eastern boundary. These informal
trail spurs would be abandoned (Refer to Project Figure 4B). There would be no impacts to
the regional trail system because the informal spurs that would be eliminated are not part
of the mapped trail system. Impacts would be less than significant, and no mitigation is
required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

TRANSPORTATION Would the project:

35. Transportation
a) Conflict with a program, plan, ordinance, or policy
addressing the circulation system, including transit, roadway,
bicycle, and pedestrian facilities?
b) 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) Cause an effect upon, or a need for new or altered
maintenance of roads?
e) Cause an effect upon circulation during the
project’s construction?
f) Result in inadequate emergency access or access
to nearby uses?

Source(s): Riverside County General Plan; Report by Integrated Engineering Group titled Scoping
Agreement for Traffic Impact Study, December 11, 2023 (Appendix H).

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Findings of Fact:

a) The ELAP programs and policies are supplemental to, and coordinated with, the policies of
the Riverside County General Plan Circulation Element. As such, the circulation system of
ELAP is tied to the countywide system and its long-range direction.

The Project Site is located at the end of Garfield Street, which is not designated as an
arterial, major roadway, or secondary roadway.

The ELAP identifies applicable circulation policies to include following:

o ELAP 8.1 - Design and develop the vehicular roadway system per Figure 7, Circulation,
and in accordance with the Functional Classifications and Standards section in the
General Plan Circulation Element.

o ELAP 8.2 - Maintain the County’s roadway Level of Service standards as described in
the Level of Service section of the General Plan Circulation Element.

The Proposed Project was reviewed and approved for conformance with Riverside County
Ordinance No. 461, “Road Improved Standards and Specifications” by the Riverside County
Transportation Department. The Project would improve the existing terminus of Garfield
Road, which is the main entry to the Project Site. The Project proposes that Garfield Road
would end easterly as a cul-de-sac, west of the entry gates of Crescent Gardens cemetery,
and dedicated to the County. This would include paved road curb to curb, parkway and
sidewalk that support fire department vehicle turning radius requirements.

The General Plan Element identifies that Level of Service (LOS) “C” applies to all
development proposals within the ELAP.

Trip generation is a measure or forecast of the number of trips that begin or end at the
Project Site. The traffic generated is a function of the extent and type of development
proposed for the site. These trips will result in some traffic increases on the streets where
they occur. The Proposed Project is anticipated to generate a total of 90 two-way trips per
day with 4 AM peak hour trips and 11 PM peak hour trips (in actual vehicles). Therefore, it
is assumed that the Project would maintain a LOS C consistent with the General Plan
consistent with the County’s level of service standards. Impacts would be less than
significant, and no mitigation is required.

The County of Riverside contains bicycle, pedestrian, and multi-purpose trails that traverse
urban, rural, and natural areas. These multi-use trails serve both as a means of connecting
the unique communities and activity centers throughout the County of Riverside and as an
effective alternate mode of transportation. The ELAP does not identify any bicycle,
pedestrian, and multi-purpose trails in the Project footprint. As identified in Criteria 34
Recreational Trails above, a regional trail exists east of the Project Site, with informal trail
spurs to allow access to the Project Site. These spurs would be removed, although users
would still be able to access and use the existing regional trail. Therefore, the Project is
consistent with the ELAP’s vision for bikeways and pedestrian facilities. Impacts would be
less than significant, and no mitigation is required.

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b) Senate Bill 743, adopted in 2013, added section 21099 to the Public Resources Code,
which states that automobile delay, as described by level of service (LOS) or similar
measures of vehicular capacity or traffic congestion, shall not be considered a significant
impact on the environment. Essentially a project’s environmental impacts can no longer
focus on vehicle delay at street intersections or on roadway segments but must use the
miles a vehicle must travel between a dwelling and commerce, recreation and/or work. The
intent of this shift in methodology is to encourage different land use and transportation
decisions to reduce greenhouse gas emission, support in-fill development and improve
public health through active transportation. Section 15064.3, subdivision (b)(1) of the CEQA
Guidelines requires a determination as to whether the project will result in a substantial
increase in vehicle miles traveled (VMT). Riverside County adopted the Transportation
Analysis Guidelines for Level of Service, Vehicle Miles Traveled (December 2020) to be
compliant with CEQA Guidelines section 15064.3, subdivision (b) and provide screening
criteria and methodology for vehicle miles traveled (VMT) analysis.

The Vehicle Miles Traveled Screening Evaluation prepared for the Project (Appendix H)
identified that the Project falls within the VMT screening criteria for “Small Project.” The
County VMT guidelines do not specifically address the cemetery land use. Based on the
County VMT guidelines, the Project would meet the definition of a “Small Project” as it is
defined as “Unless specified above, project trip generation is less than 110 trips per day
per the ITE Manual or other acceptable source determined by Riverside County.” Based on
the project trip generation assessment, the Proposed Project is expected to generate less
than 110 trips which is presumed to cause a less-than-significant impact. Therefore, the
project is exempt from performing a VMT analysis because it is considered a “Small
Project.” Therefore, this Project will screen out from a VMT analysis, and is therefore
consistent with CEQA Guidelines Section 15064.3, subdivision (b). Impacts would be less
than significant, and no mitigation is required.

c) The Proposed Project’s road improvements include modifying the terminus of Garfield Road
to include a cul-de-sac and transition from a public right of way to a private road within the
cemetery. From the terminus of Garfield Road, the cemetery would contain a series of
internal roads for the use of the cemetery patrons only. This improvement does not increase
hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections)
or incompatible uses (e.g. farm equipment) because the improvements are designed to
County standards. Therefore, while the Project would make various street improvements,
there are no geometric changes to the roadways that would create a geometric hazard or
sharp curve or dangerous intersection. There would be less than significant impacts, and
no mitigation is required.

d) The Proposed Project roadway modifications along Garfield do not cause an effect upon,
or a need for new or altered maintenance of roads as these are existing roadways and the
modifications will improve the roadway conditions by installing a cul-de-sac with a curb and
gutter and pavement rehabilitation.

The Project is located in the Good Hope/Meadowbrook Environmental Justice Area. In

compliance with General Plan Policy HC 15.1, outreach events have been conducted
during the planning process for the Project. Additionally, the Applicant has provided a
completed an Environmental Justice Form showing that the Proposed Project complies with

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all applicable Environmental Justice Policies as the applicant will be providing a bus shelter
off of SR-74 or similar route connection in the Meadowbrook community.

Impacts would be less than significant, and no mitigation is required.

e) The Proposed Project would not cause an effect upon circulation during the Project's
construction because all equipment and materials needed for construction would be staged
within the Project Site. Construction vehicles accessing the site would be transported to the
site under all State, federal and local transport regulations along the area’s roadways.
Impacts would be less than significant, and no mitigation is required.

f) Primary and secondary access for the Proposed Project consists of one driveway off of
Garfield Road. The interior private roads of the Project Site have been designed to allow
for emergency service access. And while some parking would occur along the edges of the
interior roadways for graveside services, the roads are designed in a manner that would
allow for emergency access. Prior to construction, the Project would be subject to review
by the County's Fire and Sheriff Departments, as well as grading plan review, to assure that
adequate emergency access is provided to and from the Project Site and for surrounding
residents. Impacts would be less than significant, and no mitigation is required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

36. Bike Trails

a) Include the construction or expansion of a bike
system or bike lanes?

Source(s): Riverside County General Plan.

Findings of Fact:

a) According to the County General Plan, the Project Site is not located adjacent to or nearby
any designated bike trails. The Proposed Project does not propose a bicycle trail system or
bike lanes, nor is there a requirement to construct or expand any of the existing bike
trail/lane systems within the Project vicinity. There would be no impacts.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

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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, or 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:
37. 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)?
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.)

Source(s): County Archaeologist, AB52 Tribal Consultation, Report by Tierra Environmental Services,
titled Cultural Resources Assessment for 23682 Water Street, Riverside County, April 24, 2023
(Appendix C), Advisory Notification Document, PPT220047, County of Riverside Transportation and
Land Development Agency, April 26, 2023 (on file with the County).

Findings of Fact:

a) Cultural Resources are those resources with inherent tribal values that are difficult to identify
through the same means as archaeological resources. These resources can be identified and
understood 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.

Changes in the California Environmental Quality Act, effective July 2015, require that the
County address a new category of cultural resources – tribal cultural resources – not previously
included within the law’s purview. Tribal Cultural Resources (TCRs) are those resources with
inherent tribal values that are difficult to identify through the same means as archaeological
resources. These resources can be identified and understood 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.

In compliance with Assembly Bill 52 (AB52), notices regarding this project were mailed to all
requesting tribes on February 8, 2023.

No response was received from the Colorado River Indian Tribes, Cahuilla Band of Indians,
Ramona Band of Cahuilla Indians, Pala Band of Luiseño Indians or the Santa Rosa Band of
Cahuilla Indians.

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The following is a summary of the AB52 consultation:

Quechan Indian Tribe

The Quechan Indian Tribe Historic Preservation Officer responded in an email dated February
08, 2023 and stated that the tribe does not wish to comment on the project and deferred to
more local tribes.

Agua Caliente Band of Cahuilla Indians

The Agua Caliente Band of Cahuilla Indians responded in an email dated February 09, 2023,
stating that the project is not located within the Tribe’s Traditional Use Area. Agua Caliente
deferred to other tribes in the area.

Soboba Band of Luiseño Indians

The Soboba Band of Luiseño Indians responded in an emailed letter dated February 23, 2023,
requesting consultation. The letter further stated that the tribe has identified multiple areas of
potential impact. Based on the sensitive nature of the substantial information that will be
disclosed by the tribe, specifics will be discussed in a confidential setting, during consultation.
This project was discussed during a meeting held on January 24, 2024. Soboba told Planning
that the area is very sensitive and requested a site visit. The site visit was held June 12, 2024.
Soboba deferred to Pechanga and consultation was concluded verbally during the site visit.

Rincon Band of Luiseño Indians

The Rincon Band of Luiseño Indians responded in an emailed letter dated March 9, 2023
requesting consultation. Further, the letter stated that the City of Lake Elsinore is considered
a Traditional Cultural Place (TCP) and Landscape (TCL) by the Rincon Band, as it is
associated with the Luiseño Creation and contains numerous recorded cultural places and
other TCRs. Rincon has no knowledge of cultural resources within the project area. However,
that does not mean that none exist. The tribe requested archaeological records and shape
files, archaeological record search results, and the grading plans. These were provided to the
tribe and consultation was concluded and deferred to Pechanga on March 14, 2024.

Pechanga Band of Indians

The Pechanga Band of Indians responded in an email dated March 3, 2023. In the letter the
Pechanga Tribe told Planning that “the Project area is part of 'Atáaxum (Luiseño), and therefore
the Tribe's, aboriginal territory as evidenced by the existence of cultural features associated
with religious practice and an extensive artifact record in the vicinity of the Project. This
culturally sensitive area is affiliated with the Pechanga Band of Indians because of the Tribe's
cultural ties to this area, as well as our extensive history with the Meadowbrook-region and
other projects within the area.”

Further, the email stated that Project is within a Traditional Cultural Property, directly adjacent
to Pechanga Tribe’s Reservation land, and contains a multitude of TCRs. The Tribe requests
that all efforts to preserve sensitive TCRs be made as early in the development process as
possible.

This project was discussed in Government-to-Government consultation with the Tribe in a

meeting held January 29, 2024, February 21, 2024 and also during two site visits. The
Pechanga Tribe worked very closely with the applicant throughout the CEQA process and
made recommendations regarding all aspects of the development process.

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Pechanga representatives have indicated on numerous occasions the extreme cultural

significance of this area. Pechanga trust land is located immediately adjacent to the project
area to the north and site CA-RIV-710 (P-33-000710) is located partially within the Project
area, extending north beyond it. As described in the Cultural Resources section of this Initial
Study and in the cultural resources technical reports prepared for the project and on file with
the County, this resource is known to include cremations, ceremonial items, grave goods, and
cupule-petroglyph boulders. Additionally, there are extensive midden deposits, bedrock milling
features, and dense artifact concentrations. Although CA-RIV-710 has not been formally
evaluated for inclusion in the National Register of Historic Places or the California Register of
Historical Resources, it has been noted in reports and site records as a significant resource
both archaeologically and culturally. Pechanga has identified it as a TCP/TCR.

Summary of Results:

In consultation with the Pechanga Band of Indians, the County learned of a well-documented
TCR on the property, identified as the Meadowbrook Traditional Cultural Place (N-RIV-108),
which was filed with the Native American Heritage Commission (NAHC) as a Sacred Lands
File in 2017 by Pechanga Band of Indians. The entire project site sits within this TCR. Although
site CA-RIV-710 has not been formally evaluated for inclusion in the National Register of
Historic Places (NRHP) nor the California Register of Historic Places (CRHR); the County
formally recognized the Tribal cultural significance of this resource, as well as its significance
as an archaeological site in the early 1990s by working closely with the BLM to manage,
protect, and maintain the site. The cultural importance is documented in archaeological reports
that were prepared for the County and the BLM in the early 1990s and in more recent
discussions with both Pechanga and Soboba. Based on this, for the purposes of this Project,
the resource is treated as a TCR, eligible for the NRHP and CRHR. CA-RIV-710’s
archaeological boundary was updated in 2023 as part of the Phase I archaeological report that
was completed for this project; however the Tribe incorporates a much larger region for the
TCP boundary which includes the entire project site which is included within this TCR.

The applicant has worked diligently with Pechanga to design the Project to avoid impacts to
cultural resources to the greatest extent feasible. The areas of the project site identified as the
most sensitive, based on knowledge of Pechanga tribal members and elders as well as
previous archaeological studies will be left in open space. Other areas of the project site will
be covered with engineered-fill, such that excavation for new gravesites will be in these
engineered-fill soils; not in native soils with higher potential for disturbing sensitive cultural
resources. Fencing will be used to prevent access to open space areas and off-site areas of
the TCR.

Although the project has been designed to avoid or minimize impacts to the TCRs as much as
possible, not all impacts can be fully avoided. There is also a potential for encountering cultural
material during ground-disturbing activities necessary to implement the project during the
development phases. Thus, the project could have effects to previously unidentified
subsurface TCRs.

The following mitigation measures have been recommended for the project to mitigate impacts
to the archaeological resource and TCR that cannot be avoided through project design and to

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ensure that any previously unidentified artifacts or features that are identified during the
grading process will be handled in a professional and culturally appropriate manner.

b) Refer to Item 39.a above. All mitigation measures and COAs previously identified would also
apply to this criterion to reduce potential impacts to less than significant for the reasons
previously identified.

Mitigation: Public agencies must, when feasible, avoid damaging effects to any tribal cultural resource.
Pub. Res. Code § 21084.3 (a). Appropriate mitigation for a tribal cultural resource is different than
mitigation for archeological resources. During the course of AB 52 consultation between the County of
Riverside the Pechanga Band of Indians (Pechanga Band) identified that the CUP 230002, TPM 38623,
as known as Crescent Gardens Muslim Cemetery is a part of recorded Meadowbrook Tribal Cultural
Property (TCP) N-RIV-108 and therefore a Tribal Cultural Resource (TCR) has been identified. The
proposed project is also located directly adjacent to Pechanga Tribe’s Reservation land. Both
aforementioned TCPs and TCR have been previously deemed eligible for listing on the NRHP, as well
as the CRHR. The Tribes consider the Meadowbrook TCP/TCR to consist of a large village complex
that spans 4.5 miles in length and 1.3 miles width in the community of Meadowbrook with at least three
separate ceremonial/religious areas within the TCR, two of which have recorded burial/cremation
locations that are associated, along with multiple domestic activity areas containing bedrock mortars
and slicks, rock art in the form of pictographs and cupules, ceremonial areas, and other features that
represent everyday activities of ‘Atáaxum (The People) culture. The TCR fully encompasses the 84.99
gross acres proposed CUP 230002, TPM 38623 Crescent Gardens Muslim Cemetery Project, and as
such all tangible and intangible natural and cultural sites, geologic features, water resource features,
and native plants traditionally used by the Pechanga Band of Indians are contributing elements of the
TCR.

TCR - 1 The Pechanga Band requests avoidance to the greatest extent possible, of the most
significant places within the TCR, namely CA-RIV-710 as they are elements of the larger
TCRs identified by the tribes during consultation. The currently designed project avoids
all known significant areas; however, additional areas of interest may be exposed during
the grading operations of each phase of the project. Therefore, if significant
archaeological sites, geologic features, or water resource features are identified during
grading operations, these shall be avoided to the extent feasible through re-design in
consultation with the Pechanga Band of Indians.

TCR-2 Preparation of a Tribal Cultural Resource Management Plan (TCRMP). The TCRMP
shall be prepared by the developer in close consultation with the Pechanga Band, to
manage the impacts to the tangible cultural and natural resources identified in the project
area and will outline in detail how the Tribal mitigation shall be implemented in a manner
that respects Tribal cultural values. The TCRMP will be developed prior to grading permit
issuance and approved by the County of Riverside after the Pechanga Band of Indians
have fully reviewed and provided all edits. The TCRMP will function like a cultural
resources management plan (CRMP), but will consider the TCRs as defined by
California Public Resources Code Section 21074(a) and will be used as a guide to
identify, protect, and manage the tangible and intangible TCRs already present on site
and those inadvertently identified within the project area, and ensure that impacts to
these resources are minimized or avoided during project implementation.

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The TCRMP will include protection protocols to safeguard the known TCRs during
construction and throughout the life of the project. This will include but is not limited to:
• Incorporating an exhibit that details and identifies the tangible
components of the TCR that encompasses the project area (i.e., features,
natural resources, sites, preservation areas).
• The development of buffer zones and exclusion areas around sensitive
sites, as determined in consultation with the Pechanga Band, to ensure
that the avoided resources are not disturbed by construction activities.
The proposed development plan incorporates buffer zones around known
significant areas, developed in consultation with the Pechanga Band over
a period of several years. Buffer zones for newly identified resources may
be mutually addressed based on inadvertent discoveries. (TCR-1, TCR-
6, TCR-8)
• Temporary protection measures during construction for Tribal Ceremonial
Areas, such as restricted access to areas of spiritual or ceremonial
importance by equipment and personnel and respecting seasonal and
cultural significance of the land use. The areas of temporary protections
may change depending on weather conditions and the areas of work.
(TCR-4, TCR-6)

In addition, the TCRMP will specify the process for the following:
• Preconstruction meeting requirements and monthly check in meetings
• Cultural resources monitoring during construction and other ground-
disturbing activities.
• Phasing Plan and Map
• Grading Schedule and Timeline based on Phasing Map
• Avoidance Plan
• Relocation Plan
• Fencing Plan
• Control Grading Plan
• Inadvertent Finds
• Inadvertent Findings of Human Remains
• Photo Recordation of Inadvertent Features
• Final Disposition of Inadvertently found Tribal Resources
• The development process of a long-term management plan to ensure
the protection of TCRs beyond the ground disturbing and construction
phase of the project
• Roles and Responsibilities and contact information for all parties
• Mitigation Measures for Tribal Cultural Resources will be listed within
the TCRMP for reference

The Pechanga Band will co-manage the TCRMP with the landowner, Management
Company , environmental agency such as RCA or other Conservation Easement Holder
or Grantee.. CRMPs traditionally only address tangible archaeological and historical
resources that are eligible for listing in the CRHR. A TCRMP is required for this Project
because the identified TCR can only be defined by the Pechanga Band, which includes
places, sites, features, sacred places, and objects that have cultural significance, as well
as archaeological resources.

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TCR – 3 Tribal Monitoring Agreements. The developer/Land Owner is required to enter into
Agreements with the Pechanga Band of Indians for Tribal monitoring of the project. The
agreements shall be in place prior to issuance of a grading permit. To accomplish this,
the applicant should contact the Tribes no less than 30 days and no more than 60 days
prior to issuance of a grading permit. This Agreement will address the treatment and
disposition of Tribal cultural resources, the designation, responsibilities, and participation
of 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 discovered onsite. The Tribal Monitor(s) shall have the authority to temporarily
divert, redirect, or halt the ground-disturbance activities to allow recovery of cultural
resources, in coordination with the Project Archaeologist. Tribal Monitors shall be
allowed to monitor all grading, excavation, and groundbreaking activities associated with
the project development and shall not monitor the excavation of individual graves in
engineered fill soils associated with cemetery operations.

TCR – 4 Environmentally Sensitive Areas (ESA). Prior to the start of ground-disturbing

activities, all Tribal features shall be fenced off with construction fencing and identified
as ESAs to ensure Project personnel do not disturb the features. The installation of the
ESA fencing shall be monitored by the project archeologist and Tribal Monitors. Specific
requirements pertaining to the avoidance buffer, style, materials, access, maintenance,
and other requirements shall be provided within the TCRMP.

TCR – 5 Pre-grade Surface Collection. Prior to the start of any ground-disturbing activity in any
phase of the project, the Native American and archaeological Monitors shall conduct a
surface collection of artifacts within that phase that would be subject to impacts from
ground disturbance. The archaeological monitor will record all surface collected
resources using GPS to record resource location and all relevant documentation for DPR
site record updates. The artifacts/cultural material will be temporarily kept on site in a
secure location until such time as they are reburied in a location agreed upon by the
Pechanga Band of Indians, and the project applicant/developer.

TCR – 6 Avoidance Plan. Prior to issuance of a grading permit, an avoidance plan shall be
prepared by the developer in consultation with the Pechanga Band of Indians. The
avoidance plan is to formalize the avoidance areas with their buffer zones and how work
shall proceed around them, inspections of protective fencing, protection measures
should individual features need them, and how temporary avoidance area protocols shall
be carried out. This plan shall indicate the areas/locations of the features that will be
avoided by this project and the protection measures to be implemented during
construction. In addition, the locations will be designated, in consultation with the
Pechanga Band of Indians, on a confidential map. The developer/applicant shall provide
evidence to the Riverside County Planning Department that the map has been included
in the Grading Plans, and shall indicate the presence of environmentally constrained
area(s) and the requirements for avoidance of portions of CA-RIV-710.

TCR – 7 Relocation of Cultural Features. Prior to the start of ground-disturbing activities, all
impacted features recommended for relocation shall be temporarily fenced off with
construction fencing and identified as ESAs to ensure project personnel does not disturb

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the features. The installation of the ESA fencing shall be monitored by the project
archaeologist and Tribal monitors. Once the final location of the features has been
determined and the area prepped, the features are to be moved to their final resting
location. The features are only to be moved once. If the feature(s) do not survive the
relocation efforts in one piece, all feasible fragments will be relocated to the final location.
The relocation area shall be preserved in perpetuity and protected from all future ground-
disturbing activity via an enforceable legal instrument such as a conservation easement
or other restrictive binding upon successive owners of the relocation area.

TCR – 8 Environmentally Sensitive Open Space Areas- Avoidance Mitigation for CA-RIV-
710. Portions of site CA-RIV-710 will be avoided by the Project design. For purposes of
preserving this site in perpetuity, the Project Applicant will record a restrictive covenant,
or similar legal restriction, over the preservation portion of site CA-RIV-710 prior to the
issuance of any grading permits for the Project.
The Project Applicant, in consultation with the Project Archaeologist, County of
Riverside, grading contractor, and the Pechanga Band of Indians, will create an exhibit
for the placement of a temporary construction fence, around the preservation portion of
site CA-RIV-710. Permanent fencing around the preservation portion of site CA-RIV-710
will be installed in accordance with and in conformance to the Project’s fencing plan.
Future maintenance and upkeep of the fencing will be the responsibility of the Crescent
Gardens Mortuary.

TCR – 9 Controlled Grading and Grubbing. All grading shall be controlled in areas around
identified Tribal Cultural Resources, such as cultural features or cultural areas of
concern, including but not limited to all impacted areas within CA-RIV- 710 and as
determined by the Pechanga Band of Indians. The identified areas shall be inspected by
the Principal Investigator/Archaeologist and Pechanga Tribal monitor(s) prior to initiating
grading for each area. Grading shall be controlled within the Environmentally Sensitive
Buffer Area using a slope board or similar equipment to allow soil to be removed in
increments of only a few inches at a time. Other areas that may require controlled grading
shall be determined by the Principal Investigator/Archaeologist and the Pechanga Tribal
monitor(s) based on the results and soil types identified during grading. Should any
changes be needed, an updated exhibit will be produced and approved by all parties
prior to any ground disturbance in the newly identified area.

TCR-10 Inadvertent Finds. Avoidance and preservation in place is the preferred method for all
Tribal Cultural Resources inadvertently discovered during the course of ground
disturbing activities. If avoidance and preservation is not feasible, a feasibility study shall
be required for final determination regarding the need for avoidance. If the County
determines that the study has adequately demonstrated that preservation is not feasible,
a Data Recovery/Treatment Plan for the resource shall be drafted in consultation with
the Pechanga Band, and subject to review and approval by the County of Riverside prior
to implementation and recommencement of ground disturbing activities.

If Tribal cultural resources are discovered during ground disturbance activities that were
not assessed by the archaeological report(s) and/or environmental assessment
conducted prior to Project approval, the following procedures shall be followed.
Treatment of tribal cultural resources inadvertently discovered during the project’s

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ground-disturbing activities shall be subject to the consultation process required by state

law and AB 52.

i. All ground disturbance activities within 100 feet of the discovered cultural
resources shall be halted until a meeting is convened between the Project
Applicant, the Project Archaeologist, the Tribal Representative(s), and the
County to discuss the significance of the find.

ii. At the meeting, the significance of the discoveries shall be discussed and after
consultation with the Tribal Representative(s) and the Project Archaeologist, a
decision shall be made, with the concurrence of the County, as to the appropriate
mitigation (documentation, recovery, avoidance, etc.) for the cultural resources.

iii. Further ground disturbance, including but not limited to grading, trenching etc.,
shall not resume within the area of the discovery until an agreement has been
reached by all parties as to the appropriate mitigation. Work shall be allowed to
continue outside of the buffer area and will be monitored by additional Tribal
Monitors if needed.

iv. Treatment and avoidance of the newly discovered resources shall be

consistent with the Cultural Resources Management Plan and Monitoring
Agreements entered into with the appropriate tribes. This may include avoidance
of the cultural resources through project design to the extent feasible, 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 Condition/Mitigation Measures.

v. 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 Tribe, and shall be submitted to the County
for their review and approval prior to implementation of the said plan.

vi. 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 Tribe(s) cannot agree on the significance or the
mitigation for the archaeological or cultural resources, these issues will be
presented to the County of Riverside for decision. The County 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 consider the cultural and religious principles and practices
of the Tribe. Notwithstanding any other rights available under the law, the
decision of the County shall be appealable to the County Planning Commission
and Historical Commission.

vii. Evidence of compliance with this mitigation measure, if a significant

archaeological resource is found, shall be provided to County of Riverside upon
the completion of a treatment plan and final report detailing the significance and
treatment finding.

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TCR – 11 Human Remains. If human remains are discovered, no further disturbance shall occur
in the affected area until the County Coroner has made necessary findings as to origin.
If the County Coroner determines that the remains are potentially Native American, the
California Native American Heritage Commission shall be notified within 24 hours of the
published finding to be given a reasonable opportunity to identify the “most likely
descendant”. The “most likely descendant” shall then make recommendations, and
engage in consultations concerning the treatment of the remains (California Public
Resources Code 5097.98). (GP Objective 23.3, CEQA).

TCR - 12 Final Disposition. Tangible cultural resources within the TCR inadvertently discovered
during ground disturbing activities, as well as previously identified features that are not
of ceremonial nature, which cannot remain in their existing location, shall be relocated
to multiple mutually agreed upon areas within the 84.99-acre Project Area. These areas
will be identified and described within the TCRMP and the CRMP as open space
preservation areas, that will be preserved in perpetuity so that no future disturbances will
occur.

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: a) 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
County of Riverside:

i. 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.

ii. Reburial of the resources on the Project property. The measures for reburial
shall include, at least, the following: Measures and provisions to protect the future
reburial area from any future impacts in perpetuity. Reburial 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 County under a confidential
cover and not subject to Public Records Request.

TCR–13 Preservation and Maintenance Plan. Prior to Occupancy Permit Issuance, the
landowner and the Pechanga Tribe shall develop a Preservation and Maintenance Plan
for the long-term care and management of CA-RIV- 710 and any additional areas that
may be included as mitigation for inadvertently found cultural sites. The plan shall
indicate at a minimum, the specific areas to be included in and excluded for long-term
maintenance, prohibited activities, methods of preservation to be employed, measures
for stabilization of the relocated resources, security and long-term preservation, the party
responsible for the long-term maintenance, appropriate protocols and necessary
emergency protocols. The plan shall also identify areas of Tribal access for Cultural and
educational purposes. The plan shall be developed in consultation with the Pechanga
Band, and subject to review and approval by the County of Riverside. The project

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applicant/landowner shall submit a fully executed copy of the preservation and

maintenance plan to the County of Riverside and the Pechanga Band of Indians.

TCR – 14 Reburial area. Prior to issuance of grading permits: the developer/ applicant, in
consultation with the Pechanga Band of Indians, shall provide evidence to the Riverside
County Planning Department that a Reburial Area(s) have been identified and an
Environmental Constraints Sheet has been included in the Grading Plans. This sheet
shall indicate an area that will be used for reburial of any artifacts that have been
identified during grading and cannot be avoided. This area will be protected and not
disturbed in the future. This is confidential information, and the exact nature of this area
will not be called out on the grading plans.

TCR-15 Non-Disclosure. It is understood by all parties that unless otherwise required by law,
the site of any reburial of Native American human remains or associated grave goods
shall not be disclosed and shall not be governed by public disclosure requirements of
the California Public Records Act. The Coroner, pursuant to the specific exemption set
forth in California Government Code 7927.000, parties, and Lead Agencies, will be asked
to withhold public disclosure information related to such reburial, pursuant to the specific
exemption set forth in California Government Code 7927.000.

TCR- 16 Tribal Notification for Annual Fuel Modification Maintenance. The Pechanga Band
of Indians understands that the Project will be required to have fuel modification
maintenance on an annual or biannual basis by the County of Riverside Fire Marshall.

The Project applicant shall notify the Pechanga Band of Indians for all such required
work by the County Fire Marshall in all open space areas within the Project.

TCR-17 Phase IV Report. Prior to final inspection, the Project Archaeologist is to submit two (2)
copies of the Phase IV Monitoring Report that addresses Cultural and Tribal Cultural
Resources and complies with the Planning Department's requirements for such reports.
The Phase IV report shall include evidence of the required cultural/historical sensitivity
training for the construction staff held during the pre-grade meeting. The Planning
Department shall review the reports to determine adequate mitigation compliance.
Provided the reports are adequate, the Planning Department shall clear this
condition. Once the report(s) are determined to be adequate, two (2) copies shall be
submitted to the South Coastal Information Center (SCIC) at San Diego State University
(SDSU) and one (1) copy shall be submitted to the Pechanga Cultural Resources
Department.

In addition to the mitigation measures detailed in this section, see also the mitigation measures detailed
in the Cultural Resources section of this Initial Study.

Monitoring: Monitoring will be conducted by qualified archaeologists and tribal representatives as

identified in the Mitigation Measures and COAs.

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UTILITIES AND SERVICE SYSTEMS Would the project:

38. Water
a) Require or result in the relocation or construction
of new or expanded water, wastewater treatment, or storm
water drainage systems, whereby the construction or
relocation would 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?

Source(s): Project Application Materials; letter by Elsinore Valley Municipal Water District, Mortuary
& Cemetery (WO# 22-125), dated January 16, 2023 (Appendix I).

a) Domestic water service for the Project area is provided by the EVMWD. The EVMWD
issued a “will serve” letter to the Project Applicant dated January 16, 2023 indicating that
the EVMWD has capacity to provide water service to the Proposed Project within EVMWD’s
existing facility abilities. However, to receive water service the Project would replace
approximately 1,600 linear feet of existing 4-inch water line with an 8-inch water line to that
will be extended from the Project Site at Garfield Road, extending to Jarvis Street, then
north along Jarvis Street, and to a point of connection near Senola Avenue per EVMWD.
The replacement water line would occur in the same location as the existing waterline,
which is in road right-of-way.

Because the Proposed Project’s connection to EVMWD’s existing water facilities would
occur within existing roadways and rights of way and stormwater will be contained on site,
the Project does not require or result in the relocation or construction of new or expanded
water, wastewater treatment, or storm water drainage systems, whereby the construction
or relocation would cause significant environmental effects.

The Project is outside of EVMWD’s sewer service area. As such, the Project would
construct an on-site septic system that would not require EVMWD to construct new, or
upgrade existing facilities. Impacts would be less than significant. Impacts would be less
than significant.

b) The EVMWD reviewed the Proposed Project’s water needs in light of project water
demands in its Urban Water Management Plan and issued a “will serve” letter to the Project
Applicant for domestic water service on January 16, 2023. Therefore, there are sufficient
water supplies available to serve the Proposed Project and reasonably foreseeable future
development during normal, dry, and multiple dry years. Impacts would be less than
significant.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

39. Sewer

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a) Require or result in the construction of new

wastewater treatment facilities, including septic systems, or
expansion of existing facilities, whereby the construction or
relocation would cause significant environmental effects?
b) Result in a determination by the wastewater
treatment provider that serves or may service the project that
it has adequate capacity to serve the project’s projected
demand in addition to the provider’s existing commitments?

Source(s): Department of Environmental Health Review; letter by Elsinore Valley Municipal Water
District, Mortuary & Cemetery (WO# 22-125), dated January 16, 2023 (Appendix I).

a) Municipal sewer infrastructure does not exist in the Project vicinity, according to the
EVMWD and the County maps. Therefore, the Project would install a septic system on site
to serve employees and visitors and is designed such that each building would have its own
individual septic system. The Project’s soils have been identified as suitable for
construction of the septic system, and the system would be sized in accordance with County
regulations. Therefore, while the Proposed Project would require or result in the
construction of a new wastewater treatment facilities, which is a septic system, the
construction or relocation would not cause significant environmental effects because it
would be constructed to County standards. Impacts would be less than significant, and no
mitigation is required.

b) Municipal sewer infrastructure does not exist in the Project vicinity, according to the
EVMWD and the County maps. The Proposed Project would install its own on-site sewer
treatment system. Therefore, the Proposed Project will not result in a determination by the
wastewater treatment provider that serves the project that it has adequate capacity to serve
the projected demand in addition to the provider’s existing commitments. There would be
no impact.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

40. Solid Waste

a) 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?
b) Comply with federal, state, and local management
and reduction statutes and regulations related to solid
wastes including the CIWMP (County Integrated Waste
Management Plan)?

Source(s): Riverside County General Plan.

a) Solid waste generated within the planning area is primarily transferred to the El Sobrante
Landfill, located approximately 12 miles north of the Project Site and is permitted to accept

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16,054 tons per day and has a remaining capacity of 143,977,170 tons, through 2051.
However, the County’s waste hauler can also use other County landfills in the area such as
the Lamb Canyon Landfill. All Riverside County landfills are Class III disposal sites
permitted to receive non-hazardous municipal solid waste. Waste Management of Inland
Empire currently provides waste pickup in Project area. The intention of the goals, policies,
and land use map of the County’s General Plan is that the Project Site and surrounding
parcels be used for residential and other permitted purposes. The Proposed Project is
consistent with the designated land use, and waste generated has therefore been
accounted for in the County’s long-range plans for waste management and landfill capacity.
As such, the County’s solid waste handling infrastructure has sufficient capacity to serve
solid waste generated by the Proposed Project.

The Proposed Project would generate construction waste during building construction, and
general solid waste during operations. As noted above, the Proposed Project’s waste
generation would be handled by the local waste hauler and sufficient capacity would exist
at the local County landfills. Therefore, the Project will not 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. Impacts would be less than significant,
and no mitigation is required.

b) The Countywide Integrated Waste Management Plan (CIWMP) was prepared in

accordance with the California Integrated Waste Management Act of 1989, Chapter 1095
(AB 939). AB 939 requires each of the cities and unincorporated portions of counties
throughout the state to divert a minimum of 25% by 1995 and 50% of the solid waste
landfilled by the year 2000. Riverside County reports to the State indicate that the County
is in compliance with the AB 939 goals. The County’s private waste hauler provides
contractors separate bins where construction waste can be separated for disposal from
regular trash, which is typically required by waste haulers for construction projects to ensure
proper recycling and disposal of construction debris. During operations, the Proposed
Project would be required to comply with the County’s recycling regulations where separate
bins for recyclable materials will be placed and handled separately by the waste hauler.
Therefore, the Proposed Project will comply with federal, state, and local management and
reduction statutes and regulations related to solid waste including the CIWMP. Impacts
would be less than significant.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

41. Utilities
Would the project impact the following facilities requiring or resulting in the construction of new facilities
or the expansion of existing facilities, whereby the construction or relocation would cause significant
environmental effects?
a) Electricity?
b) Natural gas?
c) Communications systems?
d) Street lighting?
e) Maintenance of public facilities, including roads?

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f) Other governmental services?

Source(s): Project Application Materials, Utility Companies, Appendix I.

a) Electricity: Development of the Proposed Project would cause a permanent increase in

demand for electricity when compared to existing conditions. Information from the
CalEEMod 2022 emission output tables for the Proposed Project (Appendix A) was utilized
to generate estimates of the Project’s electricity, natural gas, and fuel consumption for
construction and operational aspects of the Project. Electricity used for the Project during
construction and operations would be provided by Southern California Edison (SCE), which
serves more than 15 million customers. The increased demand is expected to be sufficiently
served by existing SCE electrical facilities. There are currently overhead power lines and
related easements on Garfield Street. All of these lines will remain overhead, and no new
power lines are required to serve the Project. Impacts would be less than significant, and
no mitigation is required.

b) Natural Gas: The Project is designed to solely rely on electricity for all services, and no
natural gas would be used. There would be no impact on natural gas services and no
mitigation is required.

c) Communications Systems: Existing overhead telephone and cable TV cables would remain
in their current location on overhead poles along Garfield Street to serve the Project, and
no new poles or facilities are required to be constructed, except at the terminus of Garfield
Street where facilities would be brought to the site buildings for service. Impacts would be
less than significant, and no mitigation is required.

d) Street Lighting: The County may require street lighting on Garfield near the Project driveway
as a standard condition of approval. The streetlights would be consistent with the County
of Riverside standards. Impacts would be less than significant and no mitigation is required.

e) Public Facilities: Garfield Street would be modified to include a cul-de-sac and would
include new curb and gutter and sidewalk. The improvements would be dedicated to the
County to facilitate these improvements to public facilities. These features would be
maintained by the County, but they will be designed and constructed to County standards
which facilitates proper maintenance. Impacts would be less than significant, and no
mitigation is required.

f) Government Services: There will be no government services that need to be constructed

as part of, or to serve the Proposed Project. There would be no impact.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required.

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WILDFIRE If located in or near a State Responsibility Area (“SRA”), lands classified as very high fire
hazard severity zone, or other hazardous fire areas that may be designated by the Fire Chief, would
the project:
42. Wildfire Impacts
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?
e) Expose people or structures either directly or
indirectly, to a significant risk of loss, injury, or death
involving wildland fires?

Source(s): 2019 Riverside County General Plan Figure S-11 “Wildfire Susceptibility”, GIS database,
Project Application Materials.

a) The California Fire Hazard Severity Zone Mapping, the County of Riverside GIS database,
and the County General Plan Figures show that the Project Site is within a Very
High/High/Moderate Fire Hazard Severity Zone (FHSZ). The County of Riverside utilizes a
Multi-Jurisdictional Local Hazard Mitigation Plan that identifies risks by natural and human-
made disasters and ways to minimize the damage from those disasters.

During construction, all activities will occur on the Project Site. Road improvements to
Garfield may temporarily block full access to the Project Site, but such closures would be
in accordance with all local and State guidelines to allow for emergency access. For
Proposed Project operations, the Riverside County Department of Building and Safety and
the RCFD enforce fire standards as they review building plans and conduct building
inspections. This includes a review for compliance with Riverside County Ordinance No.
787, which requires, among other measures, the County to review all future building plans
to ensure that every building is positioned in a way that allows adequate access for
emergency. Therefore, impacts would be less than significant, and no mitigation is required.

b) The Project area is composed of flat to rolling hills, with slope angles between less than 15
percent and 15 to 25 percent with rock outcroppings, according to Figure 13 of the ELAP.
The 2019 Riverside County General Plan Figure S-11 classifies the wildfire susceptibility
rating for the site as “High” to “Moderate.”

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Construction

While the Project Site is identified as being within a high fire risk area and consists of native
vegetation and rocks and boulders. The National Weather Service issues Red Flag
Warnings & Fire Weather Watches to alert fire departments of the onset, or possible onset,
of critical weather and dry conditions that could lead to rapid or dramatic increases in wildfire
activity.

A Red Flag Warning is issued for weather events which may result in extreme fire behavior
that will occur within 24 hours. A Fire Weather Watch is issued when weather conditions
could exist in the next 12-72 hours. A Red Flag Warning is the highest alert. During these
times extreme caution is urged by all residents, because a simple spark can cause a major
wildfire. A Fire Weather Watch is one level below a warning, but fire danger is still high.

The contractor must submit a fire safety practices and procedures document for welding
and the use of various equipment, consistent with OSHA General Industry Standards. The
procedures must include procedures for routinely checking weather reports, requiring fire
suppression equipment to be functional and maintained on site at all times, emergency
procedures, and the protocol for suspension of welding operations, outside of a partially or
fully constructed building, when a Red Flag warning has been issued by the National
Weather Service.

Operations

The Project is subject to compliance with the 2023 California Building Code (or the most
current version) and the 2022 edition of the California Fire Code (Part 9 of Title 24 of the
California Code of Regulations, or most current version). Compliance with these regulations
would reduce impacts of wildlife risks to Project occupants including, pollutant
concentrations from a wildfire or the uncontrolled spread of a wildfire. The Project would
develop a cemetery that would contain irrigated lands, which would reduce the potential for
wildfire spread. Additionally, the Project landscaping has been designed in accordance with
Riverside County fuel modification zone requirements (refer to Appendix J – Project Plans,
Sheets FM-1 and FM-2 located at the end of the plan set). Impacts would be less than
significant, and no mitigation is required.

c) Implementation of the Proposed Project would not 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. Impacts would be less than significant, and no
mitigation is required.

d) The Project Site is within a High Fire Hazard Severity Zone and there is no indication of
landslides, slumps, rock fall hazard, debris flow or slope instability surrounding the Project
Site. As the Project Site would develop a cemetery with interior roads and irrigated
vegetation, wildfire hazards are not anticipated to occur. The Project would not expose
people or structures to downslope flooding or landslides, as a result of runoff, post-fire slope
instability, or drainage changes. Therefore, there would be no impacts.

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e) The Project Site is within a High Fire Hazard Severity Zone. The Project would be
constructed to comply with the 2023 California Building Code (or the most current version)
and the 2020 edition of the California Fire Code (Part 9 of Title 24 of the California Code of
Regulations). Additionally, a Fuel Modification Plan has been developed as part of the
landscape plan that identifies fire-resistant plants and irrigation near the buildings.
Therefore, the Project would not expose people or structures either directly or indirectly, to
a significant risk of loss, injury, or death involving wildland fires. Impacts would be less than
significant, and no mitigation would be required.

Mitigation: No mitigation is required.

Monitoring: No monitoring is required. None.

MANDATORY FINDINGS OF SIGNIFICANCE Does the Project:

43. 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?

Source(s): Staff Review, Project Application Materials

Findings of Fact:

The Project Site is vacant, contains one drainage, and complies with the Western Riverside Multiple
Species Habitat Conservation Plan. Portions of the Project Site were identified to contain suitable
habitat and one individual of the Crotch’s Bumble Bee, a candidate species for protection under CESA.
Implementation of Mitigation Measure BIO-3 would reduce impacts through surveys and coordination
with CDFW. The Project Site also contains suitable habitat for burrowing owl and nesting birds, although
none were identified on site. However, implementation of Mitigation Measure BIO-2 and BIO-4 would
reduce potential impacts to burrowing owl and nesting birds during construction by conducting a pre-
construction survey and implementing the appropriate mitigation measures, if found. Implementation of
Mitigation Measure BIO-1 would also reduce potential impacts to riverine/riparian resources on site.
Therefore, with the implementation of mitigation measures, the Project would not 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.

The portion of Project Site slated for development does contain examples of the major periods of
California history or prehistory. Implementation of the Mitigation Measures as identified in Item 8
and 9 of this document will manage discoveries through implementation of extensive monitoring,
reporting and inspection required procedures to reduce impacts to potential cultural resources and will
reduce impacts to less than significant levels.

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Thus, the Proposed Project will not 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, reduce the number or restrict the range of a
rare or an endangered plant or animal or eliminate important examples of the major periods of California
history or prehistory. Therefore, impacts are less than significant with mitigation incorporated.

44. Have impacts which 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, other current projects and probable future
projects)?

Source(s): Staff Review, Project Application Materials

Findings of Fact: The environmental analysis conducted in this Initial Study determined that the
Proposed Project is consistent with the County's General Plan land use and zoning projections. The
land use has been considered with overall County growth. The analysis demonstrated that the Project
is in compliance with federal, State, and County applicable regulations. There are no other projects
planned for the Project vicinity that would be considered cumulatively considerable. Therefore, the
Project would not create impacts, that considered with the effects of other past, present, and probable
future projects, would be cumulatively considerable because Project impacts were either determined to
have no impact or to be less than significant.

45. Have environmental effects that will cause

substantial adverse effects on human beings, either directly
or indirectly?

Source(s): Staff Review, Project Application Materials

Findings of Fact: The Project is required to comply with a number of Project-specific mitigation
measures that are identified throughout this document to ensure that the Project’s environmental effects
will have a less than significant effects on human beings, either directly or indirectly. These mitigation
measures are summarized as follows:

Therefore, with mitigation incorporated, the Proposed Project would not directly or indirectly cause
substantial adverse effects on human beings.

IV. EARLIER ANALYSES

Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an
effect has been adequately analyzed in an earlier EIR or negative declaration as per California Code of
Regulations, Section 15063 (c) (3) (D). There was no earlier analyses, therefore, this is not applicable.

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LIST OF APPENDICES

Appendix A California Emissions Estimator Model (CalEEMod) version 2022.1 outputs, dated
12/20/24
Appendix B-1 Crescent Cemetery, Conditional Use Permit CUP 230002, Habitat Assessment and
Western Riverside County Multiple Species Habitat Conservation Plan Consistency
Analysis, July 2024, prepared by ELMT Consulting
Appendix B-2 Crescent Cemetery, Conditional Use Permit CUP 230002, Delineation of State and
Federal Jurisdictional Waters, March 2024, prepared by ELMT Consulting
Appendix B-3 Determination of Biologically Equivalent or Superior Preservation Report, Crescent
Garden Cemetery, July 2024, updated October 2024, prepared by ELMT Consulting
Appendix B-4 2024 Proposed Crescent Gardens Cemetery Project Crotch’s Bumble Bee
Summary Report, Riverside County, California, August 22, 2024, prepared by
Huffman Environmental, LLC
Appendix C-1 Historical/Archaeological Resources Survey Report, Crescent Garden Mortuary and
Cemetery Project, December 14, 2023, revised June 23, 2024, prepared by CRM
Tech (confidential, on file with the County of Riverside).
Appendix C-2 Crescent Gardens Cemetery, Cultural Resources Phase II Testing Report,
PDA8402/CUP230002, July 2024 prepared by Helix Environmental Planning
(confidential, on file with the County of Riverside).
Appendix D-1 Geotechnical Exploration and Infiltration Testing, Proposed Crescent Gardens
Cemetery, East of the Intersection of Garfield Street and Roberts Street, March 11,
2024, prepared by Leighton, Inc
Appendix D-2 Percolation Feasibility Study Report, Conditional Use Permit 23002 Proposed
Garden Cemetery, prepared by Lakeshore Engineering, October 15, 2024
Appendix D-3 Paleontological Resources Assessment Report, Crescent Gardens Cemetery
Project, August 28, 2023, prepared by CRM Tech
Appendix E Phase 1 Environmental Site Assessment of Proposed Crescent Gardens Cemetery,
Meadowbrook Community, January 2021, prepared by Environmental Managers &
Auditors, Inc
Appendix F-1 Preliminary Hydrology Report for Crescent Gardens Cemetery, January 2025,
prepared by Hunsaker & Associates Irvine Inc
Appendix F-2 Preliminary Water Quality Management Plan, Crescent Gardens Cemetery, March
13, 2024, prepared by Hunsaker & Associates
Appendix G Crescent Gardens Cemetery, Noise Impact Analysis, May 16, 2024, prepared by
MD Acoustics
Appendix H Scoping Agreement for Traffic Impact Study, December 11, 2023, prepared by
Integrated Engineering Group
Appendix I Will Serve Letters from Utilities
Appendix J Project Plans

LIST OF EXHIBITS

Figure 1: Regional and Project Vicinity Map

Figure 2A: Project Site Parcels
Figure 2B: Project Zoning and Land Use
Figure 3: Project Site - USGS View
Figure 4A: Phasing Plan

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Figure 4B: Open and Developed Areas

Figure 5A: Building Elevations and Profiles – Sheet 1
Figure 5B: Building Elevations and Profiles-Sheet 2
Figure 6A: Architectural Rendering - Site
Figure 6B: Architectural Rendering – CCF and Entry
Figure 6C: Architectural Rendering - Chapel
Figure 7: Photometric Analysis
Figure 8A: Landscape Plan
Figure 8B: Typical Burial Section
Figure 9: On-Site Slope Topography
Figure 10: Environmental Justice Communities
Figure 11: DBESP and Crotch Bumble Mitigation Area

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SUMMARY OF MITIGATION MEASURES (DRAFT-TO BE FINALIZED WITH COUNTY

COMMENTS ON DRAFT INITIAL STUDY)

Mitigation Measure Monitoring Method

BIO-1: Riverine/Riparian Habitat: Mitigation for A qualified biologist will conduct the pre-
the loss of 0.036-acre of riparian/riverine habitat construction surveys as identified in the
within Drainage 1 would occur as a conservation mitigation measure.
easement to be placed over the 0.894 acre
remainder of Drainage 1 as identified in the
DBESP. A Habitat Mitigation Monitoring and
Reporting Program (HMMP) must be submitted
to Riverside County Planning for review. The
HMMP would identify how the applicant would
maintain and manage the 0.894 acre area.
Activities may include but not be limited to
removal of extensive invasive species, such as
Tree of Heaven throughout the 0.894 acre area.
Work can be performed by a third-party or by
trained maintenance staff with the oversight of a
biologist.
BIO-2: BUOW Avoidance and Minimization: A A qualified biologist will conduct the pre-
preconstruction survey shall be conducted within construction surveys as identified in the
30 days prior to ground disturbance to avoid mitigation measure.
direct take of burrowing owls. If burrowing owls
are found to be present or nesting on-site during
the preconstruction survey, then the following
recommendations must be adhered to:
Exclusion and relocation activities may not occur
during the breeding season, which is defined as
March 1 through August 31, with the following
exception: From March 1 through March 15 and
from August 1 through August 31 exclusion and
relocation activities may take place if it is proven
to the County and appropriate regulatory
agencies (if any) that egg laying or chick rearing
is not taking place. Any relocation activities
cannot occur without first consulting with the
CDFW, and any relocation would be conducted
in accordance with the conditions set forth by
the CDFW. The pre-construction survey must be
conducted by a qualified biologist; any relocation
activities would be undertaken by a qualified
biologist as approved by the CDFW.

BIO-3 Crotch’s Bumble Bee: The Project will

occur in phases, and this measure will apply to
each phase. If the Crotch’s bumble bee is no

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longer a candidate or listed species under the
California ESA at the time ground-disturbing
activities, then no additional protection
measures are proposed for this species.

The Project Proponent shall not undertake

Project activities within suitable habitat until
appropriate authorization (i.e., California
Endangered Species Act (CESA) Incidental
Take Permit (ITP) under Fish and Game
Code §2081) is obtained. The ITP for Phase
1 will include but not be limited to mitigation
for 1.67 acres of habitat loss which may
include but not be limited to 0.45 acre of
suitable habitat that is located within the
0.89 acre area conserved under BIO-1.
Additional acreage may be required in
accordance with the ITP.

This measure does not apply to work occurring

in habitat that is not suitable for the species in
any phase.

BIO-4: Migratory Bird Avoidance and

Minimization. Bird nesting season generally
extends from February 1 through September 15
in southern California and specifically, April 15
through August 31 for migratory passerine birds.
To avoid impacts to nesting birds (common and
special status) during the nesting season, a
qualified Avian Biologist shall conduct pre‐
construction Nesting Bird Surveys (NBS) at least
three (3) days prior to project‐related
disturbance to nestable vegetation to identify
any active nests. If no active nests are found, no
further action is required. If an active nest is
found, the qualified Avian Biologist shall set
appropriate no‐work buffers around the nest
which will be based upon the nesting species,
based on the individual species type, its
sensitivity to disturbance, nesting stage and
expected types of nest, and the intensity and
duration of disturbance. The nests and buffer
zones shall be field checked weekly by a
qualified biological monitor. The approved no‐
work buffer zone shall be clearly marked in the
field, within which no disturbance activity shall

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commence until the qualified biologist has
determined the young birds have successfully
fledged and the nest is inactive.
60-Planning-CUL. 2 Inadvertent Discoveries:
Historic Period Cultural Resources. If previously
unknown historic-period cultural resources are
discovered on the project site, work shall be
temporarily halted within 60 feet of the
discovery, and the resources shall be evaluated
by the Project Archaeologist and the Consulting
Tribes in consultation with County staff. If
historic archaeological material associated with
the previously identified historic-period
archaeological sites is encountered, cultural
features will be documented, and diagnostic
artifacts will be collected before ground-
disturbing activities resume within 60 feet of the
discoveries. This language shall be included in
the Cultural Resources Monitoring Plan.
70-Planning-CUL. 2 Artifact Disposition:
Historic Resources: Prior to Grading Permit
Final Inspection, the landowner(s) shall
relinquish ownership of all cultural resources
that are unearthed on the Project property
during any ground-disturbing activities, including
previous investigations and/or Phase III data
recovery.

Historic Resources- all historic archaeological

materials recovered during the archaeological
investigations (this includes collections made
during an earlier project, such as testing of
archaeological sites that took place years ago),
shall be curated at the Western Science Center,
a Riverside County curation facility that meets
State Resources Department 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

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paid, shall be provided by the landowner to the
County.
60-Planning-CUL. 1 ECS Sheet Resource
Reburial Area. Prior to issuance of grading
permits: the developer/ applicant shall provide
evidence to the Riverside County Planning
Department that an Environmental Constraints
Sheet has been included in the Grading Plans.
This sheet shall indicate an area that will be
used for reburial of any artifacts that have been
identified during grading and cannot be avoided.
This area will be protected and not disturbed in
the future. This is confidential information, and
the exact nature of this area will not be called
out on the grading plans.
60-Planning-CUL. 3 Inadvertent Finds.
Avoidance and preservation in place is the
preferred method for all Tribal Cultural
Resources inadvertently discovered during the
course of ground disturbing activities. If
avoidance and preservation is not feasible, a
feasibility study shall be required for final
determination regarding the need for avoidance.
If the County determines that the study has
adequately demonstrated that preservation is
not feasible, a Data Recovery/Treatment Plan
for the resource shall be drafted in consultation
with the Pechanga Band, and subject to review
and approval by the County of Riverside prior to
implementation and recommencement of ground
disturbing activities.

If Tribal cultural resources are discovered during

ground disturbance activities that were not
assessed by the archaeological report(s) and/or
environmental assessment conducted prior to
Project approval, the following procedures shall
be followed. Treatment of tribal cultural
resources inadvertently discovered during the
project’s ground-disturbing activities shall be
subject to the consultation process required by
state law and AB 52.

i. All ground disturbance activities within 100

feet of the discovered cultural resources
shall be halted until a meeting is convened
between the Project Applicant, the Project
Archaeologist, the Tribal Representative(s),

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and the County to discuss the significance of
the find.

ii. At the meeting, the significance of the

discoveries shall be discussed and after
consultation with the Tribal Representative(s)
and the Project Archaeologist, a decision
shall be made, with the concurrence of the
County, as to the appropriate mitigation
(documentation, recovery, avoidance, etc.)
for the cultural resources.

iii. Further ground disturbance, including but

not limited to grading, trenching etc., shall
not resume within the area of the discovery
until an agreement has been reached by all
parties as to the appropriate mitigation. Work
shall be allowed to continue outside of the
buffer area and will be monitored by
additional Tribal Monitors if needed.

iv. Treatment and avoidance of the newly

discovered resources shall be consistent
with the Cultural Resources Management
Plan and Monitoring Agreements entered
into with the appropriate tribes. This may
include avoidance of the cultural resources
through project design to the extent feasible,
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
Condition/Mitigation Measures.

v. 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 Tribe,
and shall be submitted to the County for their
review and approval prior to implementation
of the said plan.

vi. Pursuant to Calif. Pub. Res. Code §

21083.2(b) avoidance is the preferred
method of preservation for archaeological
resources and cultural resources. If the

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Project Applicant and the Tribe(s) cannot
agree on the significance or the mitigation for
the archaeological or cultural resources,
these issues will be presented to the County
of Riverside for decision. The County 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 consider the cultural
and religious principles and practices of the
Tribe. Notwithstanding any other rights
available under the law, the decision of the
County shall be appealable to the County
Planning Commission and Historical
Commission.

vii. Evidence of compliance with this

mitigation measure, if a significant
archaeological resource is found, shall be
provided to County of Riverside upon the
completion of a treatment plan and final
report detailing the significance and
treatment finding.
60-Planning-CUL. 4 Native American
Monitor. Prior to the issuance of grading
permits, the developer/permit applicant shall
enter into an agreement with Pechanga for a
Native American Monitor. The Native American
Monitor shall be on-site during all ground-
disturbing activities for development of the
project, including clearing, grubbing, tree
removals, grading and trenching, removal of
existing structural remains and infrastructure,
and over-excavation for Phases 1, 2, and 3 of
project development. In conjunction with the
Archaeological Monitor, the Native American
Monitor shall have the authority to temporarily
divert, redirect, or halt the ground disturbance
activities to allow identification, evaluation, and
potential recovery of cultural resources.

The developer/permit applicant shall submit a

fully executed copy of the agreement to the
County Archaeologist to ensure compliance
with this condition of approval. Upon
verification, the Archaeologist shall clear this

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condition. This agreement shall not modify any
condition of approval or mitigation measure.

No monitor will be required post phased

development and during the Cemetery
operations due to the reasons listed below.

a) The project has been designed to avoid

impacts on known significant
archaeological/cultural resource (i.e.,
historical resource per CEQA), P-33-
000710 (CA-RIV-710), to the extent
feasible.

b) The design features include avoiding

bedrock milling features and cupule rocks,
and leaving large areas of the
archaeological site in undeveloped open
space.

c) The project design includes as-needed

over-excavation to ensure that all
gravesites in the cemetery will have
engineered fill or backfill extending to a
minimum depth of five (5) feet below
finished grade. The planned graves will be
dug five (5) feet deep for the burial, per the
established Muslim burial customs.
Therefore, by having a minimum of five (5)
feet of engineered fill, all earthwork during
burials will remain within the engineered fill
zone, and no natural ground will be
disturbed.

60-Planning-CUL. 5 Pre-grade Surface

Collection. Prior to the start of any ground-
disturbing activity in any phase of the project,
the Native American Monitor shall conduct a
surface collection of artifacts within that phase
that would be subject to impacts from ground
disturbance. The artifacts/cultural material will
be kept in a secure location on site or
temporarily kept by the Monitoring Tribe until
such time as they are reburied in a location
agreed upon by the Consulting Tribes and the
project applicant/developer.
60-Planning-CUL. 6. Project Archaeologist
Archaeological Monitor. Prior to issuance of

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grading permits, the developer/permit applicant
shall provide evidence to the County of
Riverside Planning Department that a County-
certified professional archaeologist (Project
Archaeologist) has been contracted to
implement a Cultural Resource Monitoring
Program for Phases 1, 2, and 3 of project
development. The Project Archaeologist, in
consultation with the Consulting Tribe(s) shall
develop a Cultural Resources Management Plan
(CRMP) that addresses the details of all
activities and provides procedures that must be
followed in order to reduce the impacts to
cultural and historic resources to a level that is
less than significant, as well as address potential
impacts to undiscovered buried archaeological
resources associated with this project. The
CRMP shall include a Controlled Grading Plan
that will identify specific areas of the project site
requiring controlled grading and detail the
methods for such grading. Controlled grading
entails small lifts of soil (3-5 inches), allowing the
Native American Monitor and Archaeological
Monitor adequate opportunity to examine the
ground surface in a more controlled manner
than general mass grading. This allows for
recording cultural features and artifacts that may
be destroyed or overlooked in standard mass
grading. Controlled grading will be utilized for
soil removals within and adjacent to the mapped
boundaries of P-33-000710, in the areas of the
historic archaeological sites, and at other areas
identified by the Project Archaeologist or the
Consulting Tribe(s) as requiring controlled
grading. A fully executed copy of the contract
and a wet-signed copy of the CRMP shall be
provided to the County Archaeologist to ensure
compliance with this condition of approval.

Working directly under the Project

Archaeologist, an adequate number of qualified
Archaeological Monitors shall be present to
ensure that all earth-moving activities for project
development are observed and shall be on-site
during all ground-disturbing activities for the
project in areas with the potential to yield
archaeological resources (not in formational
material), including clearing, grubbing, tree

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removals, grading and trenching, removal of
existing structural remains and infrastructure,
and over-excavation for Phases 1, 2, and 3 of
project development. In conjunction with the
Native American Monitor, the Archaeological
Monitor shall have the authority to temporarily
divert, redirect, or halt the ground disturbance
activities to allow identification, evaluation, and
potential recovery of cultural resources.
60-Planning -CUL-7 Temporary Construction
Fencing. Prior to the start of any ground-
disturbing activity, the applicant/developer shall
ensure that temporary construction fencing is
placed at the edges of the extent of grading and
around bedrock milling features and cupule
rocks within the development footprint to prevent
inadvertent movement of personnel and
equipment into the areas of P-33-000710 that
will remain in undeveloped open space and to
ensure that no removals of bedrock milling
features, cupule rocks, and cultural soils or
cultural material occur in these areas. A Native
American Monitor and an Archaeological
Monitor shall observe the placement of fencing,
which will be based on a fencing plan to be
approved by the County Archaeologist and the
Consulting Tribes. No staging of material or
equipment shall occur within the fenced areas.
70-Planning-CUL. 1. Artifact Disposition:
Prehistoric Resources. Prior to Grading
Permit Final Inspection, the landowner(s) shall
relinquish ownership of all cultural resources
that are unearthed on the Project property
during any ground-disturbing activities,
including previous investigations and/or Phase
III data recovery.

Prehistoric Resources- The following treatment

shall be applied.

Reburial of the resources on the Project

property. The measures for reburial shall
include, at least, the following: Measures to
protect the reburial area from any future
impacts. Reburial shall not occur until all
required cataloguing, analysis, and studies
have been completed on the cultural
resources, with an exception that sacred

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items, burial goods and Native American
human remains are excluded. Any reburial
processes 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 County under a confidential
cover and not subject to a Public Records
Request.
70-Planning-CUL. 3. Phase IV Monitoring
Report. Prior to Grading Permit Final
Inspection, 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 TLMA website. The report shall include
results of any feature relocation or residue
analysis required, as well as evidence of the
required cultural sensitivity training for the
construction staff held during the required pre-
grade meeting and evidence that any artifacts
have been treated in accordance with
procedures stipulated in the Cultural Resources
Management Plan.

TCR - 1 The Pechanga Band requests

avoidance to the greatest extent
possible, of the most significant places
within the TCR, namely CA-RIV-710 as
they are elements of the larger TCRs
identified by the tribes during
consultation. The currently designed
project avoids all known significant
areas; however, additional areas of
interest may be exposed during the
grading operations of each phase of the
project. Therefore, if significant
archaeological sites, geologic features,
or water resource features are identified
during grading operations, these shall
be avoided to the extent feasible
through re-design in consultation with
the Pechanga Band of Indians.

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TCR-2 Preparation of a Tribal Cultural

Resource Management Plan
(TCRMP). The TCRMP shall be
prepared by the developer in close
consultation with the Pechanga Band,
to manage the impacts to the tangible
cultural and natural resources identified
in the project area and will outline in
detail how the Tribal mitigation shall be
implemented in a manner that respects
Tribal cultural values. The TCRMP will
be developed prior to grading permit
issuance and approved by the County
of Riverside after the Pechanga Band
of Indians have fully reviewed and
provided all edits. The TCRMP will
function like a cultural resources
management plan (CRMP), but will
consider the TCRs as defined by
California Public Resources Code
Section 21074(a) and will be used as a
guide to identify, protect, and manage
the tangible and intangible TCRs
already present on site and those
inadvertently identified within the
project area, and ensure that impacts to
these resources are minimized or
avoided during project implementation.

The TCRMP will include protection

protocols to safeguard the known
TCRs during construction and
throughout the life of the project. This
will include but is not limited to:
• Incorporating an exhibit that details
and identifies the tangible
components of the TCR that
encompasses the project area
(i.e., features, natural resources,
sites, preservation areas).
• The development of buffer zones
and exclusion areas around
sensitive sites, as determined in
consultation with the Pechanga
Band, to ensure that the avoided
resources are not disturbed by
construction activities. The

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proposed development plan
incorporates buffer zones around
known significant areas, developed
in consultation with the Pechanga
Band over a period of several
years. Buffer zones for newly
identified resources may be
mutually addressed based on
inadvertent discoveries. (TCR-1,
TCR-6, TCR-8)
• Temporary protection measures
during construction for Tribal
Ceremonial Areas, such as
restricted access to areas of
spiritual or ceremonial importance
by equipment and personnel and
respecting seasonal and cultural
significance of the land use. The
areas of temporary protections
may change depending on
weather conditions and the areas
of work. (TCR-4, TCR-6)

In addition, the TCRMP will specify the

process for the following:
• Preconstruction meeting
requirements and monthly
check in meetings
• Cultural resources monitoring
during construction and other
ground-disturbing activities.
• Phasing Plan and Map

• Grading Schedule and

Timeline based on Phasing
Map
• Avoidance Plan
• Relocation Plan
• Fencing Plan
• Control Grading Plan
• Inadvertent Finds
• Inadvertent Findings of Human
Remains
• Photo Recordation of
Inadvertent Features
• Final Disposition of
Inadvertently found Tribal
Resources

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• The development process of a
long-term management plan to
ensure the protection of TCRs
beyond the ground disturbing
and construction phase of the
project
• Roles and Responsibilities and
contact information for all
parties
• Mitigation Measures for Tribal
Cultural Resources will be
listed within the TCRMP for
reference

The Pechanga Band will co-manage

the TCRMP with the landowner,
Management Company ,
environmental agency such as RCA or
other Conservation Easement Holder
or Grantee.. CRMPs traditionally only
address tangible archaeological and
historical resources that are eligible for
listing in the CRHR. A TCRMP is
required for this Project because the
identified TCR can only be defined by
the Pechanga Band, which includes
places, sites, features, sacred places,
and objects that have cultural
significance, as well as archaeological
resources.
TCR – 3 Tribal Monitoring Agreements.
The developer/Land Owner is required
to enter into Agreements with the
Pechanga Band of Indians for Tribal
monitoring of the project. The
agreements shall be in place prior to
issuance of a grading permit. To
accomplish this, the applicant should
contact the Tribes no less than 30 days
and no more than 60 days prior to
issuance of a grading permit. This
Agreement will address the treatment
and disposition of Tribal cultural
resources, the designation,
responsibilities, and participation of
Tribal monitors during grading,
excavation and ground disturbing
activities; project grading and

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development scheduling; terms of
compensation for the monitors; and
treatment and final disposition of any
cultural resources, sacred sites, and
human remains discovered onsite. The
Tribal Monitor(s) shall have the
authority to temporarily divert, redirect,
or halt the ground-disturbance activities
to allow recovery of cultural resources,
in coordination with the Project
Archaeologist. Tribal Monitors shall be
allowed to monitor all grading,
excavation, and groundbreaking
activities associated with the project
development and shall not monitor the
excavation of individual graves in
engineered fill soils associated with
cemetery operations.

TCR – 4 Environmentally Sensitive

Areas (ESA). Prior to the start of
ground-disturbing activities, all Tribal
features shall be fenced off with
construction fencing and identified as
ESAs to ensure Project personnel do
not disturb the features. The installation
of the ESA fencing shall be monitored
by the project archeologist and Tribal
Monitors. Specific requirements
pertaining to the avoidance buffer,
style, materials, access, maintenance,
and other requirements shall be
provided within the TCRMP.

TCR – 5 Pre-grade Surface Collection.

Prior to the start of any ground-
disturbing activity in any phase of the
project, the Native American and
archaeological Monitors shall conduct a
surface collection of artifacts within that
phase that would be subject to impacts
from ground disturbance. The
archaeological monitor will record all
surface collected resources using GPS
to record resource location and all
relevant documentation for DPR site
record updates. The artifacts/cultural
material will be temporarily kept on site

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in a secure location until such time as
they are reburied in a location agreed
upon by the Pechanga Band of Indians,
and the project applicant/developer.

TCR – 6 Avoidance Plan. Prior to

issuance of a grading permit, an
avoidance plan shall be prepared by
the developer in consultation with the
Pechanga Band of Indians. The
avoidance plan is to formalize the
avoidance areas with their buffer zones
and how work shall proceed around
them, inspections of protective fencing,
protection measures should individual
features need them, and how
temporary avoidance area protocols
shall be carried out. This plan shall
indicate the areas/locations of the
features that will be avoided by this
project and the protection measures to
be implemented during construction. In
addition, the locations will be
designated, in consultation with the
Pechanga Band of Indians, on a
confidential map. The
developer/applicant shall provide
evidence to the Riverside County
Planning Department that the map has
been included in the Grading Plans,
and shall indicate the presence of
environmentally constrained area(s)
and the requirements for avoidance of
portions of CA-RIV-710.

TCR – 7 Relocation of Cultural

Features. Prior to the start of ground-
disturbing activities, all impacted
features recommended for relocation
shall be temporarily fenced off with
construction fencing and identified as
ESAs to ensure project personnel does
not disturb the features. The installation
of the ESA fencing shall be monitored
by the project archaeologist and Tribal
monitors. Once the final location of the
features has been determined and the
area prepped, the features are to be

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moved to their final resting location.
The features are only to be moved
once. If the feature(s) do not survive
the relocation efforts in one piece, all
feasible fragments will be relocated to
the final location. The relocation area
shall be preserved in perpetuity and
protected from all future ground-
disturbing activity via an enforceable
legal instrument such as a conservation
easement or other restrictive binding
upon successive owners of the
relocation area.

TCR – 8 Environmentally Sensitive

Open Space Areas- Avoidance
Mitigation for CA-RIV-710. Portions of
site CA-RIV-710 will be avoided by the
Project design. For purposes of
preserving this site in perpetuity, the
Project Applicant will record a
restrictive covenant, or similar legal
restriction, over the preservation portion
of site CA-RIV-710 prior to the issuance
of any grading permits for the Project.

The Project Applicant, in consultation

with the Project Archaeologist, County
of Riverside, grading contractor, and
the Pechanga Band of Indians, will
create an exhibit for the placement of a
temporary construction fence, around
the preservation portion of site CA-RIV-
710. Permanent fencing around the
preservation portion of site CA-RIV-710
will be installed in accordance with and
in conformance to the Project’s fencing
plan. Future maintenance and upkeep
of the fencing will be the responsibility
of the Crescent Gardens Mortuary.
TCR – 9 Controlled Grading and
Grubbing. All grading shall be
controlled in areas around identified
Tribal Cultural Resources, such as
cultural features or cultural areas of
concern, including but not limited to all
impacted areas within CA-RIV- 710 and
as determined by the Pechanga Band

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of Indians. The identified areas shall be
inspected by the Principal
Investigator/Archaeologist and
Pechanga Tribal monitor(s) prior to
initiating grading for each area. Grading
shall be controlled within the
Environmentally Sensitive Buffer Area
using a slope board or similar
equipment to allow soil to be removed
in increments of only a few inches at a
time. Other areas that may require
controlled grading shall be determined
by the Principal
Investigator/Archaeologist and the
Pechanga Tribal monitor(s) based on
the results and soil types identified
during grading. Should any changes be
needed, an updated exhibit will be
produced and approved by all parties
prior to any ground disturbance in the
newly identified area.

TCR-10 Inadvertent Finds. Avoidance and

preservation in place is the preferred
method for all Tribal Cultural
Resources inadvertently discovered
during the course of ground
disturbing activities. If avoidance and
preservation is not feasible, a
feasibility study shall be required for
final determination regarding the
need for avoidance. If the County
determines that the study has
adequately demonstrated that
preservation is not feasible, a Data
Recovery/Treatment Plan for the
resource shall be drafted in
consultation with the Pechanga Band,
and subject to review and approval by
the County of Riverside prior to
implementation and
recommencement of ground
disturbing activities.

If Tribal cultural resources are

discovered during ground disturbance
activities that were not assessed by
the archaeological report(s) and/or

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environmental assessment conducted
prior to Project approval, the following
procedures shall be followed.
Treatment of tribal cultural resources
inadvertently discovered during the
project’s ground-disturbing activities
shall be subject to the consultation
process required by state law and AB
52.

i. All ground disturbance activities

within 100 feet of the discovered
cultural resources shall be halted until
a meeting is convened between the
Project Applicant, the Project
Archaeologist, the Tribal
Representative(s), and the County to
discuss the significance of the find.

ii. At the meeting, the significance of

the discoveries shall be discussed
and after consultation with the Tribal
Representative(s) and the Project
Archaeologist, a decision shall be
made, with the concurrence of the
County, as to the appropriate
mitigation (documentation, recovery,
avoidance, etc.) for the cultural
resources.

iii. Further ground disturbance,

including but not limited to grading,
trenching etc., shall not resume
within the area of the discovery until
an agreement has been reached by
all parties as to the appropriate
mitigation. Work shall be allowed to
continue outside of the buffer area
and will be monitored by additional
Tribal Monitors if needed.

iv. Treatment and avoidance of the

newly discovered resources shall be
consistent with the Cultural
Resources Management Plan and
Monitoring Agreements entered into
with the appropriate tribes. This may
include avoidance of the cultural

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resources through project design to
the extent feasible, 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
Condition/Mitigation Measures.

v. 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 Tribe, and shall
be submitted to the County for their
review and approval prior to
implementation of the said plan.

vi. 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 Tribe(s) cannot
agree on the significance or the
mitigation for the archaeological or
cultural resources, these issues will
be presented to the County of
Riverside for decision. The County
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 consider the
cultural and religious principles and
practices of the Tribe.
Notwithstanding any other rights
available under the law, the decision
of the County shall be appealable to
the County Planning Commission
and Historical Commission.

vii. Evidence of compliance with this

mitigation measure, if a significant
archaeological resource is found,

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shall be provided to County of
Riverside upon the completion of a
treatment plan and final report
detailing the significance and
treatment finding.
TCR – 11 Human Remains. If human
remains are discovered, no further
disturbance shall occur in the affected
area until the County Coroner has
made necessary findings as to origin.
If the County Coroner determines that
the remains are potentially Native
American, the California Native
American Heritage Commission shall
be notified within 24 hours of the
published finding to be given a
reasonable opportunity to identify the
“most likely descendant”. The “most
likely descendant” shall then make
recommendations, and engage in
consultations concerning the
treatment of the remains (California
Public Resources Code 5097.98).
(GP Objective 23.3, CEQA).

TCR - 12 Final Disposition. Tangible cultural

resources within the TCR
inadvertently discovered during
ground disturbing activities, as well as
previously identified features that are
not of ceremonial nature, which
cannot remain in their existing
location, shall be relocated to multiple
mutually agreed upon areas within
the 84.99-acre Project Area. These
areas will be identified and described
within the TCRMP and the CRMP as
open space preservation areas, that
will be preserved in perpetuity so that
no future disturbances will occur.

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

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discoveries: a) 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 County of Riverside:

i. 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.

ii. Reburial of the resources on the

Project property. The measures for
reburial shall include, at least, the
following: Measures and provisions
to protect the future reburial area
from any future impacts in
perpetuity. Reburial 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 County
under a confidential cover and not
subject to Public Records Request.

TCR–13 Preservation and Maintenance

Plan. Prior to Occupancy Permit
Issuance, the landowner and the
Pechanga Tribe shall develop a
Preservation and Maintenance Plan
for the long-term care and
management of CA-RIV- 710 and any
additional areas that may be included
as mitigation for inadvertently found
cultural sites. The plan shall indicate
at a minimum, the specific areas to
be included in and excluded for long-
term maintenance, prohibited

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activities, methods of preservation to
be employed, measures for
stabilization of the relocated
resources, security and long-term
preservation, the party responsible for
the long-term maintenance,
appropriate protocols and necessary
emergency protocols. The plan shall
also identify areas of Tribal access for
Cultural and educational purposes.
The plan shall be developed in
consultation with the Pechanga Band,
and subject to review and approval by
the County of Riverside. The project
applicant/landowner shall submit a
fully executed copy of the
preservation and maintenance plan to
the County of Riverside and the
Pechanga Band of Indians.

TCR – 14 Reburial area. Prior to issuance of

grading permits: the developer/
applicant, in consultation with the
Pechanga Band of Indians, shall
provide evidence to the Riverside
County Planning Department that a
Reburial Area(s) have been identified
and an Environmental Constraints
Sheet has been included in the
Grading Plans. This sheet shall
indicate an area that will be used for
reburial of any artifacts that have
been identified during grading and
cannot be avoided. This area will be
protected and not disturbed in the
future. This is confidential
information, and the exact nature of
this area will not be called out on the
grading plans.

TCR-15 Non-Disclosure. It is understood by

all parties that unless otherwise
required by law, the site of any
reburial of Native American human
remains or associated grave goods
shall not be disclosed and shall not
be governed by public disclosure
requirements of the California Public

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Records Act. The Coroner, pursuant
to the specific exemption set forth in
California Government Code
7927.000, parties, and Lead
Agencies, will be asked to withhold
public disclosure information related
to such reburial, pursuant to the
specific exemption set forth in
California Government Code
7927.000.

TCR- 16 Tribal Notification for Annual Fuel

Modification Maintenance. The
Pechanga Band of Indians
understands that the Project will be
required to have fuel modification
maintenance on an annual or
biannual basis by the County of
Riverside Fire Marshall.

The Project applicant shall notify the

Pechanga Band of Indians for all
such required work by the County
Fire Marshall in all open space areas
within the Project.
TCR-17 Phase IV Report. Prior to final
inspection, the Project Archaeologist
is to submit two (2) copies of the
Phase IV Monitoring Report that
addresses Cultural and Tribal Cultural
Resources and complies with the
Planning Department's requirements
for such reports. The Phase IV report
shall include evidence of the required
cultural/historical sensitivity training
for the construction staff held during
the pre-grade meeting. The Planning
Department shall review the reports
to determine adequate mitigation
compliance. Provided the reports are
adequate, the Planning Department
shall clear this condition. Once the
report(s) are determined to be
adequate, two (2) copies shall be
submitted to the South Coastal
Information Center (SCIC) at San
Diego State University (SDSU) and
one (1) copy shall be submitted to the

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Pechanga Cultural Resources
Department.

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