HomeMy WebLinkAboutSierra Distribution Facility FEIRSierra Distribution Facility Project
Final Environmental Impact Report
SCH No. 2023030788
Prepared for:
City of Fontana
8353 Sierra Avenue
Fontana, CA 92335
Prepared by:
Kimley-Horn and Associates, Inc.
3801 University Avenue, Suite 300
Riverside, CA 92501
May 2025
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Table of Contents
Section 1: Introduction
1.1 Introduction .........................................................................................................................1.0-1
1.2 Organization of EIR ..............................................................................................................1.0-2
1.3 CEQA Process Summary .......................................................................................................1.0-2
1.4 Changes to the Draft EIR ......................................................................................................1.0-3
Section 2: Comments and Responses to Draft EIR
2.1 Introduction to Comments and Responses ...........................................................................2.0-1
Comment Letter A - West Valley Water District ....................................................................2.0-3
Responses to Comment Letter A .....................................................................................2.0-5
Comment Letter B - Blum, Collins & Ho LLP ..........................................................................2.0-7
Response to Comment Letter B ......................................................................................2.0-57
Comment Letter C - Golden State Environmental Justice Alliance .........................................2.0-69
Response to Comment Letter C ......................................................................................2.0-71
Section 3.0: Errata to the Draft EIR
3.1 Introduction to the Errata ....................................................................................................3.0-1
3.2 Changes to the Draft EIR ......................................................................................................3.0-1
List of Tables
Table 2.0-1: Comments from Public Agencies, Organizations and Individuals .................................2.0-1
List of Figures
Figure 3-5: Overall Site Plan
Figure 3-6: Building Design and Elevations
Figure 3-7: Conceptual Landscape Plan and Fuel Modification Zone Plan
Figure 3-8: Conceptual Grading Plan
Figure 4.17-1: Passenger Vehicle Dwy at Sierra Avenue Emergency Vehicle Turning Movement
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Figure 4.17-2: Truck Dwy and Passenger Vehicle Dwy at Mango Avenue Emergency Vehicle Turning
Movement
Figure 4.17-3: Truck Dwy and Passenger Vehicle Dwy at Mango Avenue Emergency Vehicle Turning
Movement
Figure 4.17-4: Truck Dwy at Mango Avenue CAL Legal Turning Movement
Figure 4.17-5: Passenger Vehicle Driveway – Westbound Right Turn
Figure 4.17-6: Truck Driveway – Eastbound Left/Right Turn and Passenger Vehicle Driveway – Eastbound
Left/Right Turn
List of Appendices
Appendix L: Fire Protection Plan
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Section 1.0 Introduction
1.1 INTRODUCTION
The Final Environmental Impact Report (Final EIR) for the Sierra Distribution Facility Project has been
prepared in accordance with the California Environmental Quality Act (CEQA), and CEQA Guidelines. CEQA
Guidelines Section 15132 indicates that the contents of a Final EIR shall consist of:
(a) Environmental Impact Reports shall contain the information outlined in this article, but the format
of the document may be varied. Each element must be covered, and when these elements are
not separated into distinct sections, the document shall state where in the document each
element is discussed.
(b) The EIR may be prepared as a separate document, as part of a general plan, or as part of a project
report. If prepared as a part of the project report, it must still contain one separate and
distinguishable section providing either analysis of all the subjects required in an EIR or, as a
minimum, a table showing where each of the subjects is discussed. When the Lead Agency is a
state agency, the EIR shall be included as part of the regular project report if such a report is used
in the agency’s existing review and budgetary process.
(c) Draft EIRs shall contain the information required by Sections 15122 through 15131. Final EIRs shall
contain the same information and the subjects described in Section 15132.
(d) No document prepared pursuant to this article that is available for public examination shall
include a “trade secret” as defined in Section 6254.7 of the Government Code, information about
the location of archaeological sites and sacred lands, or any other information that is subject to
the disclosure restrictions of Section 6254 of the Government Code.
The Final EIR includes all of these required components.
In accordance with Section 15088 of the State CEQA Guidelines, the City of Fontana, as the lead agency
for the proposed Project, evaluated comments received on the Draft EIR (State Clearinghouse No.
2023030788) and has prepared responses to the comments received. The preceding Table of Contents
and Section 1.0 provides of a list of all persons, organizations, and public agencies commenting on the
Draft EIR. Section 2.0 includes the Responses to Comments received by the City of Fontana on the
Draft EIR. It should be noted that responses to comments also result in various editorial clarifications and
corrections to the original Draft EIR text. Added or modified text is shown in Section 3.0, Errata, by
underlining (example) while deleted text is shown by striking (example). The additional information,
corrections, and clarifications are not considered to substantively affect the conclusions within the EIR.
This Response to Comments document is part of the Final EIR, which includes the EIR pursuant to
Section 15132 of the State CEQA Guidelines.
Responses to comments will be sent to commenting agencies and individuals. This satisfies the
requirement of Section 21092.5 of CEQA to send responses to the public agency comments received on
the Draft EIR at least 10 days prior to Project approval. This document includes responses to all written
comments received on the Draft EIR.
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1.2 ORGANIZATION OF EIR
This Final EIR provides the requisite information required under CEQA and is organized as follows:
Section 1.0 Introduction. This section provides an introduction to the Final EIR, including the
requirements under CEQA, the organization of the document, as well as brief summary of the
CEQA process activities to date.
Section 2.0 Comments and Responses. This section provides a list of public agencies,
organizations, and individuals commenting on the Draft EIR, provides a copy of each written
comment received, and any response required under CEQA.
Section 3.0 Errata to the Draft EIR. This section details changes to the Draft EIR.
1.3 CEQA PROCESS SUMMARY
The Draft Environmental Impact Report (Draft EIR) is an informational document intended to inform the
public and decision-makers about the environmental consequences of the proposed Sierra Distribution
Facility Project (Project). The Project involves the development of an approximately 398,514-square foot
warehouse building within an approximately 18.3-acre site, with associated facilities and improvements
including approximately 10,000 square feet of office space, vehicle parking, loading dock doors, trail er
parking, on-site landscaping, and related on-site and off-site improvements. The single building for the
Project would maintain a typical height of 48 feet. The maximum building height allowed is 75 feet. The
Project’s proposed building will have a maximum Floor Area Ratio (FAR) of approximately 0.5 and can
have a maximum FAR of 0.6.
The Project site will provide landscaping on approximately 21.4 percent (85,181-square-feet) of Project
site. Project construction is anticipated to occur in one phase. Should the Project be approved,
construction is anticipated to occur over a duration of approximately 15 months, commencing in summer
of 2025; the facility would be operational in fall of 202 6.
Pursuant to CEQA Guidelines Section 15082, the City circulated a Notice of Preparation (NOP) advising
public agencies, special districts, and members of the public who had requested such notice that an EIR
for the proposed Project was being prepared. The NOP was distributed on April 3, 2023, with a 30-day
public review period ending on May 3, 2023. The NOP and comment letters received are provided in
Appendix A: Notice of Preparation and Scoping Meeting Notice of the Draft EIR.
After receiving public comments on the NOP, the Project was analyzed for its potential to result in
environmental impacts. Impacts were evaluated in accordance with the significance criteria developed by
the City that are based on criteria presented in Appendix G, “Environmental Checklist Form,” of the CEQA
Guidelines. The criteria in the Environmental Checklist (checklist), was used to determine if the proposed
Project would result in, “no impact,” “less than significant impact,” “less than significant imp act with
mitigation measures,” or potentially significant impact” to a particular environmental resource.
The Draft EIR describes the existing environmental resources on the Project site and in the vicinity of the
Project site, analyzes potential impacts on those resources that would or could occur upon initiation of
the proposed Project, and identifies mitigation measures that could avoid or reduce the magnitude of
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those impacts determined to be significant. The environmental impacts evaluated in the Draft EIR concern
several subject areas, including aesthetics, agriculture and forestry, air quality, biological resources,
cultural resources, energy, geology and soils, greenhouse gas emissions, hazards and hazardous materials,
hydrology and water quality, land use and planning, mineral resources, noise, population and housing,
public services, recreation, transportation, tribal cultural resources, utilities and service systems, and
wildfire. As noted in the preceding paragraph, public comments were received during the NOP process
and included written letters provided to the City during public meetings. A copy of the letters with the
NOP is provided in Appendix A to the Draft EIR. The comments were used, as intended, to help inform the
discussion of the Draft EIR and help determine the scope and framework of certain topical discussions.
When the Draft EIR was completed, it was circulated for public review pursuant to CEQA Guidelines
Section 15087. The 45-day public review for the Draft Environmental Impact Report began on
September 11, 2024, and ended on October 25, 2024. All comment letters received during the 45-day
public review period previously mentioned are included in this Final EIR.
As set forth in more detail in the Responses to Comments and Errata, none of the clarifications or
amplifications set forth herein change the significance conclusions presented in the Draft EIR or
substantially alters the analysis presented for public review. Furthermore, the Draft EIR circulated for
public review was fully adequate under CEQA such that meaningful public review was not precluded.
Thus, the clarifications provided in the Responses to Comments and Errata do not constitute significant
new information that might trigger recirculation.
1.4 CHANGES TO THE DRAFT EIR
Section 3.0, Errata to the Draft EIR details the changes to the Draft EIR. Most of the changes to the
Draft EIR represent clarifications to the existing content. Added or modified text is shown in Section 3.0,
Errata, by underlining (example) while deleted text is shown by striking (example).
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Section 2 .0 Comments and Responses to Draft EIR
2.1 INTRODUCTION TO COMMENTS AND RESPONSES
Table 2.0-1 below provides a list of those parties that provided written comments on the Draft EIR during
the public review period. Each comment document has been assigned a letter as indicated in the table.
A copy of the written comments is provided in this section and have been annotated with the assigned
letter along with a number for each comment. Each comment document is followed by a written response
which corresponds to the comments provided.
Table 2.0-1: Comments from Public Agencies, Organizations and Individuals
Letter Date Received Organization/Name
Agencies
A October 09, 2024 West Valley Water District
Daniel Guerrera
Organizations
B October 23, 2024 Blum, Collins & Ho LLP
Matt Hagemann, P.G, C. Hg. and Paul E. Rosenfeld, Ph.D.
C October 24, 2024 Golden State Environmental Justice Alliance
Adam Salcido
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Comment Letter A - West Valley Water District - Daniel Guerrera
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Responses to Comment Letter A - West Valley Water District, Daniel Guerrera
A1 Comment noted. This comment does not identify a specific concern with the adequacy of the
Draft EIR or note a specific issue or comment related to the Draft EIR’s environmental analysis.
However, the comment will be taken into consideration by decision-makers.
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Comment Letter B - Blum, Collins & Ho LLP - Matt Hagemann, P.G, C. Hg. and
Paul E. Rosenfeld, Ph.D.
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Response to Comment Letter B - Blum, Collins & Ho LLP - Matt Hagemann, P.G, C. Hg. and
Paul E. Rosenfeld, Ph.D.
B1 Comment noted. This comment does not identify a specific concern with the adequacy of the
Draft EIR or note a specific issue or comment related to the Draft EIR’s environmental analysis.
However, the comment will be taken into consideration by decision-makers.
B2 The comment does not provide substantial evidence of a significant impact. California Public
Resources Code Section 21065 defines a ‘Project’ as an activity that could result in a direct or
indirect physical change in the environment and which involves the issuance to a person of an
entitlement by one or more public agencies. Piecemealing occurs when a Project is segmented in
a way that environmental evaluation of some of the activities associated with the Project is
deferred. The projects referenced by the commenter and the subject Project are separate
projects, undertaken at different times, and each has its own independent utility. None of these
projects are reliant on the approval or development of the other projects. Therefore,
piecemealing has not occurred. The projects are also geographically distinct. Notably, MCN22-
000105 and MCN22-000079 are located in the Southwest Industrial Park Specific Plan. The Project
is not part of a specific plan. The projects referenced by the commenter are separate projects and
the adequacy of the CEQA review prepared for these projects are not relevant. These are not
“phased” projects, and separate environmental review of each is contemplated by the authority
cited by the commenter. A Project level EIR is the appropriate CEQA document for the Project and
includes a thorough discussion of the Project’s potential impacts, including cumulative impacts.
B3 See Response B2 above. See Section 2.2, Compliance with CEQA, page 2-1 through 2-2 of the Draft
EIR. The comment does not provide substantial evidence of a significant impact. According to the
CEQA Guidelines (14 CCR Section 15064(f)(1)), preparation of an EIR is required whenever a
project may result in a significant effect on the environment. An EIR is an informational document
used to inform public agency decision-makers and the general public of the significant
environmental effects of a project, identify possible ways to minimize the significant effects, and
describe reasonable alternatives to the project that could feasibly attain most of the basic
objectives of the project while substantially lessening or avoiding any of the significant
environmental impacts. Public agencies are required to consider the information presented in the
EIR when determining whether to approve a project. CEQA requires that state and local
government agencies consider the environmental effects of projects over which they have
discretionary authority before taking action on those projects. This Draft EIR analyzes the
environmental effects of the Project to the degree of specificity appropriate to the current
proposed actions, as required by Section 15146 of the CEQA Guidelines. The analysis considers
the activities associated with the Project, to determine the short-term and long-term effects
associated with their implementation. This EIR discusses both direct and indirect impacts of the
Project, as well as cumulative impacts associated with other past, present, and reasonably
foreseeable future projects.
B4 The comment does not provide substantial evidence of a significant impact. This comment
incorrectly asserts that the Draft EIR does not include a complete Project Description due to not
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including a detailed site plan, floor plan, conceptual grading plan, written narrative, and detailed
elevations, while summarizing CEQA requirements related to a project description. The Project
Description included in Section 3.0 of the Draft EIR includes a detailed description of the Project,
including the conceptual site plan and description of grading activities and elevations that are
further described and analyzed in the Draft EIR. Project information specific to earthwork, parking
requirements, site coverage and floor area ratio is described in Section 3.0, Project Description of
the Draft EIR. The Draft EIR provides the required level of detail in Section 3.0 to evaluate impacts
of the Project, as required under Section 15124 of the CEQA Guidelines. Impacts associated with
short-term construction activities (e.g., air and greenhouse gas emissions, truck trips), including
onsite grading are addressed in Section 4.3: Air Quality, Section 4.8: Greenhouse Gas Emissions,
and Section 4.17: Transportation.
However, to satisfy the commenter, Figure 3-5: Overall Site Plan has been updated to include an
aerial map, tabulation information, and a legend; Figure 3-6: Building Design and Elevations has
been updated to include building heights; and the Conceptual Grading Plan has been added as
Figure 3-8. This additional information concerning the description of the Project does not change
the analysis or the conclusions of the Draft EIR. Further, these revisions added to the Final EIR do
not warrant recirculation of the Draft EIR.
B5 The comment does not provide substantial evidence of a significant impact. Only auto traffic and
emergency response vehicles are permitted to access the Project site via Sierra Avenue. See
Appendix K page 1; truck traffic would be restricted from using Summit Avenue and discouraged
from using Sierra Avenue. Furthermore, see Section 3.0, Project Description page 3-7 of the
Draft EIR. The Project prohibits truck access to the Project via Sierra Avenue. Trucks are instead
able to enter and exit the site via Mango Avenue in a left-in and right-out truck traffic pattern.
Finally, Wildflower Avenue is a private driveway, not a street, but nevertheless was included in
traffic counts in Attachment B of Appendix K of the Draft EIR. See Final EIR Section 3.0: Errata, for
revisions to Section 4.17: Transportation of the Draft EIR, removing any confusion regarding trucks
accessing the Project site via Sierra Avenue. The revisions added to the Final EIR Section 3.0:
Errata do not warrant recirculation of the Draft EIR.
B6 The comment does not provide substantial evidence of a significant impact. Contrary to the
commenter’s assertions, the Project applicant did not collect traffic data early on to exaggerate
the existing traffic counts. According to the City of Fontana’s Traffic Impact Analysis (TIA)
guidelines, dated October 21, 2020, the following is stated:
“The screening criteria trip limit is based on net trip generation after considering pass-by, internal
capture, affordable housing, and/or existing land use trips.”
“Existing land use trip credits can be taken for land uses on a project site that are currently or
have been operational within 6 months from the time the application is filed.”
Traffic data was collected early in the process to establish a baseline for the current number of
trips generated by the site before any onsite operations terminated. These counts were essential
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for determining the scope of the Project’s transportation analysis, which is based on the net trips
generated by the proposed development. The Project applicant confirmed that the operations at
the site remained essentially the same between the time when counts were collected and when
the NOP was released.
B7 The comment does not provide substantial evidence of a significant impact. The EIR does not
overstate the existing operations of the Project site. All four business were operating at the time
the City published the NOP. Whether a business has a business license or not does not affect the
Draft EIR’s environmental baseline. Banning Ranch Conservancy v City of Newport Beach (2012)
211 Cal.App. 4th 1209, 1233.
B8 Comment noted. This comment does not identify a specific concern with the adequacy of the
Draft EIR or note a specific issue or comment related to the Draft EIR’s environmental analysis.
The comment does not provide substantial evidence of a significant impact. However, the
comment will be taken into consideration by decision-makers.
B9 The comment does not provide substantial evidence of a significant impact. See Section 3.0,
Project Description page 3-1 through 3-2 of the Draft EIR. A summary of the permitted uses in the
City of Fontana’s M-1 zone has little to no relevance concerning the Project’s environmental
impacts. Nonetheless, the Project is consistent with the City’s General Plan land use designation
and the zoning. The Project site’s industrial land use designation is I -L: Light Industrial and the
zoning is M-1: Light Industrial. I-L: Light Industrial (0.1 to 0.6 FAR) allows for employee-intensive
uses, including business parks, research and development, technology centers, corporate and
support office uses, clean industry, supporting retail uses, truck and equipment sales and related
services. General uses permitted (either by right, minor use permit, or conditional use permit)
under the industrial zoning districts (Light Industrial [M-1]) includes manufacturing, food
processing, service and repair, storage and open yards, warehousing uses, retail sales, restaurants
and bars, administrative and professional offices, educational, and miscellaneous uses. The
Project is not categorized as a “heavy traffic manufacturing” use. For a detailed list of permitted
uses, see Table No. 30-530: Permitted Uses in Industrial Zoning Districts of the City’s Zoning and
Development Code here:
https://library.municode.com/ca/fontana/codes/zoning_and_development_code?nodeId=CH30
ZODECO_ARTVIIINZODI.
B10 The comment does not provide substantial evidence of a significant impact. Please see Response
B9. Also, see Section 4.17, Transportation pages 4.17-10 through 4.17-11 of the Draft EIR. Use of
ITE rates accurately estimates the trips to be generated by the Project, providing a more accurate
estimate of trips than would be derived based upon the myriad of permitted uses laid out in the
City’s M-1 zoning regulations. Based on ITE Warehouse rates selected, the Project is estimated to
generate 681 daily trips, with 68 trips during the AM peak hour and 72 trips during the PM peak
hour (see Table 2 of Appendix K). Following the City’s TIA guidelines for estimating trip generation,
the trips were converted to a Passenger Car Equivalent (PCE) based on ITE truck trip rates. The
truck mixes by number of axles were based on the City of Fontana Truck Trip Generation Study
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for the Light Warehouse land use category. The truck trips were then converted to PCE trips using
the factors from the City’s guidelines. The Project is estimated to generate a total of 1,076 PCE
trips daily, with 85 PCE trips (63 inbound / 22 outbound) during the AM peak hour, and 84 PCE
trips (26 inbound / 58 outbound) during the PM peak hour. Draft EIR Table 4.17-2: Trip Generation
Comparison provides a comparison of the trips currently being generated by the existing site and
the trips estimated to be generated by the Project. The Project is estimated to generate an
additional 106 PCE trips daily, with nine additional PCE trips during the AM peak hour and 38
additional PCE trips during the PM peak hour. Additionally, the Project will be consistent with
applicable local agency operational LOS standards. Overall, the Project would not conflict with a
program, plan, ordinance, or policy, addressing the circulation system, including transit, roadway,
bicycle, and pedestrian facilities. The Project includes roadway improvements that would be
designed in accordance with applicable federal, state, and local provisions, design requirements,
and policies. Furthermore, roadway improvements may include a combination of fee payments
to established programs, construction of specific improvements, and payment of a fair-share
contribution toward future improvements (see Appendix K for more details). Therefore, impacts
would be less than significant.
B11 The comment does not provide substantial evidence of a significant impact. The first sentence of
the comment states that the EIR does not include analysis of relevant environmental justice issues
in reviewing potential impacts, including cumulative impacts from the Project. The comment also
references SB 535. This is incorrect. The Draft EIR fully analyzed and disclosed the Project’s
cumulative impacts in Section 4.1, Aesthetics through Section 4.18, Wildfire. More specifically,
the Draft EIR fully analyzed and disclosed the Project’s impacts concerning air quality,
transportation, and hazards and hazardous materials in Section 4.2, Air Quality, Section 4.8,
Hazards and Hazardous Materials, and Section 4.15, Transportation.
B12 Comment noted. This comment does not identify a specific concern with the adequacy of the
Draft EIR or note a specific issue or comment related to the Draft EIR’s environmental analysis.
The comment does not provide substantial evidence of a significant impact. However, the
comment will be taken into consideration by decision-makers.
B13 Comment noted. This comment does not identify a specific concern with the adequacy of the
Draft EIR or note a specific issue or comment related to the Draft EIR’s environmental analysis.
The comment does not provide substantial evidence of a significant impact. However, the
comment will be taken into consideration by decision-makers.
B14 Comment noted. This comment does not identify a specific concern with the adequacy of the
Draft EIR or note a specific issue or comment related to the Draft EIR’s environmental analysis.
The comment does not provide substantial evidence of a significant impact. However, the
comment will be taken into consideration by decision-makers.
B15 Comment noted. This comment does not identify a specific concern with the adequacy of the
Draft EIR or note a specific issue or comment related to the Draft EIR’s environmental analysis.
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The comment does not provide substantial evidence of a significant impact. However, the
comment will be taken into consideration by decision-makers.
B16 The comment does not provide substantial evidence of a significant impact. The comment states
that the Project is adjacent to census tracts that are designated as SB 535 Disadvantaged
Communities. It should be noted that SB 535 does not include project-specific requirements or
prohibit developments in proximity to the designated communities. SB 535 directs 25 percent of
the proceeds from the state’s Greenhouse Gas Reduction Fund (i.e., funds from the AB 32 cap-
and-trade program) to go to projects that provide a benefit to disadvantaged communities (as
identified by the OEHHA mapping). As noted throughout this Final EIR, an HRA was prepared for
the Project and quantified risk levels at nearby sensitive receptors and determined that impacts
would be less than significant.
B17 The comment does not provide substantial evidence of a significant impact. The comment
provides no substantial evidence regarding why the use of CalEEMod, which is universally used by
lead agencies in CEQA documents, is inaccurate or flawed. CalEEMod comprehensively and
cohesively provides building energy consumption estimates, as well as establishes the basis for
estimation of construction activity/construction equipment energy consumption, and mobile -
source (vehicular) energy consumption. This latter category (vehicular energy consumption)
comprises the majority of the Project energy demand. In addition, the sources for the
methodologies include studies commissioned by the California Energy Commission (CEC) and also
utilize energy conservation standards subject to Title 24. CalEEMod User Guide Appendix D
(Technical Source Documentation for Emissions Calculations) states the energy intensity
estimates are based on a survey completed in 2019 with structures ranging from 1935 to 2015.
The Appendix notes “default energy consumption estimates provided in CalEEMod based on the
RASS are very conservative, overestimating expected energy use compared to what would be
expected for new buildings subject to the latest Energy Code with more stringent energy
efficiency measures.” Therefore, the energy estimates in Section 4.6 Energy of the Draft EIR
Appendix E, Energy Analysis are conservative.
The analysis specifically responds to the guidance for energy analysis in the State CEQA Guidelines
Appendix F, which requires a determination regarding whether a project would increase the need
for new energy supplies. The analysis is used to disclose the amount of energy that the Project
would require and is not utilized to demonstrate compliance for performance. Additionally, the
Draft EIR discloses the Project’s electricity consumption, natural gas consumption, and
transportation fuel consumption and determined that the Project’s energy consumption would
not be inefficient or wasteful as the Project will be required by the CALGreen Code to comply with
the Title 24 Building Energy Efficiency Standards (Nonresidential) published by the CEC, which
contain stringent mandatory standards for mechanical systems, lighting (indoor and outdoor), and
appliances to minimize energy use. Revisions to the Draft EIR are not required.
B18 The comment states that the City is not listed as a jurisdiction with local energy standards
approved by the California Energy Commission. However, only local jurisdictions that adopt their
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own energy standards are required to be approved by the California Energy Commission. All local
jurisdictions are required to comply with the State’s Title 24 energy code unless they have
standards approved by the California Energy Commission that exceed the Title 24 energy code .
The energy analysis presented in the Draft EIR is for purposes of estimating Project demand and
responds to the requirements in State CEQA Guidelines Appendix F. All California jurisdictions are
required to comply with the State Building Code, including the Energy Code (Title 24, Part 6) and
the Green Building Standards Code (Title 24, Part 11). Therefore, the discussion in the Draft EIR
correctly explains that the project would implement required green building strategies. As noted
above, only local jurisdictions that adopt their own energy standards are required to be approved
by the California Energy Commission. As the City of Fontana has not adopted their own energy
standards, they are required to comply with the Title 24 energy standards. Compliance with
Title 24 standards is enforced through the City’s plan check and building inspection process. The
comment has not provided any evidence that the project would not comply with the California
Energy Commission standards or AB 32/SB 32 and the Draft EIR does not need to be recirculated.
B19 The comment does not provide substantial evidence of a significant impact. Refer to Response B7.
The comment states that it is inappropriate for the Project’s GHG emissions modeling to take
credit for the existing uses at full capacity when only one of the four existing businesses located
on site has a business license. The comment states that the Draft EIR should be revised to remove
any credit given to existing uses in order to accurately and adequately analyze the Project’s
environmental impacts.
Section 152049(c) of the CEQA Guidelines advises that comments should be accompanied by
factual support, stating “[r]eviewers should explain the basis for their comments and should
submit data or references offering facts, reasonable assumptions based on facts, or expert
opinion supported by facts in support of the comments. Pursuant to Section 15064, an effect shall
not be considered significant in the absence of substantial evidence.” Where comments provide
no factors or other substantial evidence to support an assertion, or where comments do not
explain why the evidence supporting a conclusion in the Draft EIR is not substantial evidence, the
Final EIR is not required to alter a significance determination of the Draft EIR. While CEQA permits
disagreements of opinion with respect to environmental issues addressed in the EIR (see Section
15151 of the CEQA Guidelines [“disagreement among experts does not make an EIR inadequate…
the courts have looked not for perfection but for adequacy, completeness, and a good faith effort
at full disclosure”].) The Draft EIR for the Project provides an adequate, complete, and good faith
effort at full disclosure of the physical environmental impacts of the Project and the conclusions
are based upon substantial evidence in light of the whole record.
CEQA Guidelines Section 15125 provides that “the lead agency should describe physical
environmental conditions as they exist at the time the notice of preparation is published. As
demonstrated in Chapter 3.0, Project Description, of the Draft EIR, the Project was occupied by
four active businesses at the time the City published the NOP for the Draft EIR. In addition, as
described in the Trip Generation Assessment and Traffic Scoping (Appendix K of the Draft EIR),
existing trip generation was determined by trip counts taken over the course of 72 hours. Existing
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trips, as collected by field data, was accounted for in the GHG analysis. Additionally, as addressed
in Response B7, all four business were operating at the time the City published the NOP. Whether
a business has a business license or not does not affect the Draft EIR’s environmental baseline.
The underlying site approvals would still remain in effect. Thus, because the existing businesses
were active at the time the NOP was circulated, and the existing GHG emissions were based on
field data collected, it is appropriate to take into account the GHG emissions stemming from the
existing uses and the Draft EIR properly takes credit for the existing emissions associated with the
use of and the trips associated with onsite existing uses.
B20 The comment does not provide substantial evidence of a significant impact. The comment claims
that Draft EIR Table 4.8-4: Regional Transportation Plan/Sustainable Communities Strategy
Consistency provides does not adequately address consistency analysis with SCAG’s 2020-2045
Connect SoCal RTP/SCS. The comment also mentions that there are errors in modeling and states
that the Project is inconsistent with Goal 5, Goal 6, and Goal 7 of Table 4.8-4. The comment states
that the EIR must be revised to include findings of significance due to inconsistency with the 2020-
2045 RTP/SCS Connect SoCal document.
Section 152049(c) of the CEQA Guidelines advises that comments should be accompanied by
factual support, stating “[r]eviewers should explain the basis for their comments and should
submit data or references offering facts, reasonable assumptions based on facts, or expert
opinion supported by facts in support of the comments. Pursuant to Section 15064, an effect shall
not be considered significant in the absence of substantial evidence.” Where comments provide
no facts or other substantial evidence to support an assertion, or where comments do not explain
why the evidence supporting a conclusion in the Draft EIR is not substantial evidence, the Final
EIR is not required to alter a significance determination of the Draft EIR. While CEQA permits
disagreements of opinion with respect to environmental issues addressed in the EIR (see Section
15151 of the CEQA Guidelines [“disagreement among experts does not make an EIR inadequate…
the courts have looked not for perfection but for adequacy, completeness, and a good faith effort
at full disclosure”].) The Draft EIR for the Project provides an adequate, complete, and good faith
effort at full disclosure of the physical environmental impacts of the Project and the conclusions
are based upon substantial evidence in light of the whole record.
As discussed in Response B19, GHG emissions modeling adequately accounts for existing uses.
Substantial evidence supporting the SCAG RTP/SCS consistency analysis is provided in Draft EIR
Section 4.3: Air Quality and Section 4.8: Greenhouse Gas Emissions. Additionally, as addressed in
Response B19, all four business were operating at the time the City published the NOP. Whether
a business has a business license or not does not affect the Draft EIR’s environmental baseline.
The Project consistency discussion within Table 4.8-4 provides justification for consistency with
each goal. Thus, the Draft EIR does not need to be revised due to an inconsistency with the 2020-
2045 RTP/SCS Connect SoCal document.
B21 The comment does not provide substantial evidence of a significant impact. See Responses B9
and B10 above.
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B22 The comment does not provide substantial evidence of a significant impact. CEQA Guidelines
require that projects show consistency with applicable and use plans, such as the City’s General
Plan. See Section 4.11: Land Use and Planning of the Draft EIR. Table 4.11-4 summarizes the
Project’s consistency with applicable policies from the City’s General Plan. The policies listed by
the commenter either do not apply to light industrial projects, are meant to be City ac tions, or do
not specify the policy they are referencing. No further analysis is required.
B23 The comment does not provide substantial evidence of a significant impact. LOS analysis is being
provided for disclosure purposes, but this analysis is not being provided to determine whether or
not the Project has a significant transportation impact.
B24 The comment does not provide substantial evidence of a significant impact. Refer to
Response B20.
B25 The comment does not provide substantial evidence of a significant impact. See Section 4.14,
Population and Housing of the Draft EIR. Development forecasts for the City were based on
California Department of Finance (DOF) and Southern California Association of Governments
(SCAG) forecasts. The General Plan EIR for the City’s General Plan was developed using SCAG data.
As such, the Draft EIR includes data which is consistent with those used for the City’s General Plan
projections.
B26 The comment does not provide substantial evidence of a significant impact. The Draft EIR is
written as an analysis of effects to the both the lead agency jurisdiction as well as the larger region.
Employment is reasonably assumed to directly affect the lead agency jurisdiction and the local
region. Additionally, the region refers to the County areas nearby the Project and is clarified by
the inclusion of County demographics in Section 4.14.2, Environmental Setting of Section 4.14,
Population and Housing of the Draft EIR. The Draft EIR adequately incorporates multiple areas of
effect of Project implementation and no further analysis is required.
B27 The comment does not provide substantial evidence of a significant impact. See Response B26.
CEQA does not require an analysis of employee interest in employment, only the effects on the
affected workforce. As such, an analysis of market interest is not a required component of the
Draft EIR. The Draft EIR adequately incorporates multiple areas of effect of Project
implementation and no further analysis is required.
B28 The comment does not provide substantial evidence of a significant impact. The office use
associated with the Project includes administrative activities which will be used solely in
connection with the Project’s warehouse operations. As such, the office use is considered as a
component of the Project’s warehouse uses. Note that the ITE Trip Generation manual accounts
for some interior office space as part of the Warehouse land use, stating that “A warehouse is
primarily devoted to the storage of materials, but it may also include office and maintenance
areas. “Refer to Final EIR Section 3.0: Errata which incorporates the correct employment average.
The revisions added to Final EIR Section 3.0: Errata do not warrant recirculation of the Draft EIR.
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B29 The comment does not provide substantial evidence of a significant impact. See Responses
B26-28. As discussed in Draft EIR Section 4.0: Environmental Impact Analysis “There are two
commonly used approaches, or methodologies, for establishing the cumulative impact setting or
scenario. One approach is to use a “list of past, present, and probable future projects producing
related or cumulative impacts including, if necessary, those projects outside the control of the
agency…” (14 CCR Section 15130(b)(1)(A)). The other is to use a “summary of projections
contained in an adopted local, regional or Statewide plan, or related planning document, that
describes or evaluates conditions contribution to the cumulative effect” (14 CCR Section
15130(b)(1)(B)).” The Project took the latter approach, not the list approach. See Final EIR
Section 3.0: Errata, for revisions to Draft EIR Section 4.0.4. The revisions added to Final EIR
Section 3.0: Errata do not warrant recirculation of the Draft EIR.
B30 The comment does not provide substantial evidence of a significant impact. Refer to Responses
B6 and B7.
B31 The comment does not provide substantial evidence of a significant impact. Refer to Response
B23. With regard to Circulation Element Goal 5 and the associated policy to maintain levels of
service for passenger vehicles, transit vehicles, trucks, bicyclists, and pedestrians that are
appropriate for the context of the area, this goal and policy are not project specific but applicable
to the City of Fontana as a whole.
B32 The comment does not provide substantial evidence of a significant impact. See Final EIR Section
3.0: Errata, for revisions to Section 4.17: Transportation of the Draft EIR, including a summary of
the Project’s potential to increase roadway hazards or result in inadequate emergency and truck
access. Exhibits provided to evaluate the updated site plan. The revisions added to Final EIR
Section 3.0: Errata do not warrant recirculation of the Draft EIR.
B33 The comment does not provide substantial evidence of a significant impact. Refer to Response
B32. Final EIR Section 3.0: Errata, for revisions to Section 4.17: Transportation of the Draft EIR,
including a summary of the Project’s potential to increase roadway hazards or result in inadequate
emergency and truck access. Exhibits provided to evaluate the updated site plan. The revisions
added to Final EIR Section 3.0: Errata do not warrant recirculation of the Draft EIR.
B34 The comment does not provide substantial evidence of a significant impact. Refer to Responses
B32 and B33. An evaluation of the truck movement in the cul-de-sac was not provided since trucks
would access the site, making a northbound left-turn movement from Mango Avenue. Trucks are
not anticipated to travel north of the truck driveway or circulate the cul -de-sac. The Project’s
frontage improvement will widen Mango Avenue, providing more area in the cul-de-sac for
turning around.
B35 The comment does not provide substantial evidence of a significant impact. Refer to Responses
B32-B34. The site plan was updated to remove truck driveway along Sierra Avenue. See Final EIR
Section 3.0: Errata, for revisions to Section 4.17: Transportation of the Draft EIR, including a
summary of the Project’s potential to increase roadway hazards or result in inadequate
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emergency and truck access. Exhibits provided to evaluate the updated site plan. The revisions
added to Final EIR Section 3.0: Errata do not warrant recirculation of the Draft EIR.
B36 The comment does not provide substantial evidence of a significant impact. Refer to Responses
B32-B35. See Final EIR Section 3.0: Errata, for revisions to Section 4.17: Transportation of the
Draft EIR, including a summary of the site circulation for emergency vehicles and trucks. The
revisions added to Final EIR Section 3.0: Errata do not warrant recirculation of the Draft EIR.
B37 The comment does not provide substantial evidence of a significant impact. Refer to Responses
B32-B36. See Final EIR Section 3.0: Errata, for revisions to Section 4.17: Transportation of the
Draft EIR, including a summary of the sight distance evaluation. The revisions added to Final EIR
Section 3.0: Errata do not warrant recirculation of the Draft EIR.
B38 The comment does not provide substantial evidence of a significant impact. Refer to Responses
B32-B37. See Final EIR Section 3.0, Errata for added discussion regarding Site Access, Emergency
Vehicle Access and Circulation, Truck Access and Circulation, and Roadway Hazards. The revisions
added to Final EIR Section 3.0: Errata do not warrant recirculation of the Draft EIR.
B39 The comment does not provide substantial evidence of a significant impact. See Response B29.
Each environmental analysis section of the Draft EIR discusses relevant cumulative impacts which
may occur as a result of Project implementation. The analysis of the Project’s potential to cause
growth-inducing impacts is assessed using the projection method.
B40 The comment does not provide substantial evidence of a significant impact. See Responses B25,
B26, B27, B29 and B39.
B41 The comment does not provide substantial evidence of a significant impact. See Response B29
and B39.
B42 The commenter’s request for the Draft EIR’s revision and recirculation is noted for the record.
However, the commenter has raised no substantial or substantiated criticisms of the Draft EIR ,
which would necessitate recirculation. The commenter’s request for subsequent public noticing
and hearing information is noted for the record.
B43 Introductory comments and general description of the Project are noted for the record. The
request for a revised EIR is also noted for the record.
B44 The commenter’s reference of the South Coast Air Quality Management District's adoption of the
Warehouse Indirect Source Rule is noted for the record.
B45 Comment noted. See Response B11. This comment does not identify a specific concern with the
adequacy of the Draft EIR or note a specific issue or comment related to the Draft EIR’s
environmental analysis. The comment does not provide substantial evidence of a significant
impact. However, the comment will be taken into consideration by decision-makers.
B46 Comment noted. See Response B11. This comment does not identify a specific concern with the
adequacy of the Draft EIR or note a specific issue or comment related to the Draft EIR’s
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environmental analysis. The comment does not provide substantial evidence of a significant
impact. However, the comment will be taken into consideration by decision-makers.
B47 Comment noted. See Response B11. This comment does not identify a specific concern with the
adequacy of the Draft EIR or note a specific issue or comment related to the Draft EIR’s
environmental analysis. The comment does not provide substantial evidence of a significant
impact. However, the comment will be taken into consideration by decision-makers.
B48 Comment noted. See Response B11. This comment does not identify a specific concern with the
adequacy of the Draft EIR or note a specific issue or comment related to the Draft EIR’s
environmental analysis. The comment does not provide substantial evidence of a significant
impact. However, the comment will be taken into consideration by decision-makers.
B49 Comment noted. This comment does not identify a specific concern with the adequacy of the
Draft EIR or note a specific issue or comment related to the Draft EIR’s environmental analysis.
However, the comment will be taken into consideration by decision-makers.
B50 Comment noted. This comment does not identify a specific concern with the adequacy of the
Draft EIR or note a specific issue or comment related to the Draft EIR’s environmental analysis.
However, the comment will be taken into consideration by decision-makers.
B51 Comment noted. This comment does not identify a specific concern with the adequacy of the
Draft EIR or note a specific issue or comment related to the Draft EIR’s environmental analysis.
However, the comment will be taken into consideration by decision-makers.
B52 The commenter’s admission of receiving limited information regarding the Project is noted for
the record. The commenter’s conclusory statements and admission of potential information gaps
and inconsistencies is noted for the record. The comment does not provide substantial evidence
of a significant impact.
B53 The resume of Matthew F. Hageman is noted for the record.
B54 The resume of Paul Rosenfeld is noted for the record.
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Comment Letter C - Golden State Environmental Justice Alliance - Adam Salcido
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Response to Comment Letter C - Golden State Environmental Justice Alliance - Adam Salcido
C1 The commenter’s request for the inclusion of interested parties to the mailing list is noted for the
record. No further response required.
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Section 3 .0 Errata to the Draft EIR
3.1 INTRODUCTION TO THE ERRATA
The Draft EIR for the Sierra Distribution Facility Project dated September 2024, is hereby incorporated by
reference as part of the Final EIR. Changes to the Draft EIR are further detailed below.
The changes to the Draft EIR do not affect the overall conclusions of the environmental document and
instead represent changes to the Draft EIR that provide clarification, amplification and/or insignificant
modifications, as needed as a result of public comments on the Draft EIR, or due to additional information
received during the public review period. These clarifications and corrections do not warrant Draft EIR
recirculation pursuant to CEQA Guidelines Section 15088.5.
None of the changes or information provided in the comments reflect a new significant environmental
impact, a substantial increase in the severity of an environmental impact for which mitigation is not
proposed, or a new feasible alternative or mitigation measure that would clearly lessen significant
environmental impacts but is not adopted. In addition, the changes do not reflect a fundamentally flawed
or conclusory Draft EIR.
Changes to the Draft EIR are listed by Section, page, paragraph, etc. to best guide the reader to the
revision. Changes are identified as follows:
• Deletions are indicated by strikeout text.
• Additions are indicated by underline text.
3.2 CHANGES TO THE DRAFT EIR
Section 3.0: Project Description
Figures
Figure 3-5: Overall Site Plan, updated.
Figure 3-6: Building Design and Elevations, updated.
Figure 3-8: Conceptual Grading Plan, added.
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Section 4.0: Environmental Impact Analysis
Page 4-5, Section 4.0.4, Project Approach
The City of Fontana General Plan and SCAG’s RTP/SCS other planning documents (such as recent City of
Fontana CEQA documents) were used as additional reference points in establishing the cumulative
scenario for the analysis. The previous CEQA documents provide further context as to cumulative impacts
considered for prior projects. The intent of the cumulative impact discussions is to provide sufficient
information to inform decision makers and the public, rather than “tiering” off of prior CEQA documents
for cumulative impacts. Note that Project impacts were found to be no impact, less than significant, or
less than significant with mitigation incorporated; therefore, through avoiding any significant and
unavoidable impacts, the Project’s contribution to cumulative impacts would not be considerable.
Section 4.14: Population and Housing
Page 4.14-10, Impact 4.14-1
Table 4.14-9: Project Employment Generation
Land Use Generation Rate Project SF Employment Generation
Land Use (Warehouse)
Warehousing1 1 employee/2,111 1,195 sf 398,514 189 333 employees
Source: SCAG. 2001. Employment Density Report. Page 4. Los Angeles, CA: SCAG.
1. Standard rate applied to the Project’s 398,514 sf of warehousing.
The Project’s planned development strategy of warehousing uses would generate a total of 189 333 new
employees. This would comprise approximately 0.193 percent of the City’s 2021 workforce. These jobs
could be filled by unemployed City residents, given the City’s existing unemployment rate of 5.9 percent.
Specifically, the warehousing portion would comprise approximately 2.12 percent of the City’s
warehousing workforce (see Table 4.14-8 above). In the event that all the new jobs created would be filled
by new workers moving to the City, the 189333-person workforce would generate a 0.0816 percent
increase in the City’s 2022 population. This growth rate would be well within the projections of the SCAG
2020-2045 RTP/SCS and could be accommodated by existing housing within the City. Therefore, it is
unlikely the Project would directly or indirectly induce substantial, unplanned population growth in the
County. Thus, the impact is less than significant, and no mitigation is required.
Section 4.17: Transportation
Page 4.17-8, Table 4.17-1: Consistency Analysis
Policy 3.1: Maximize the accessibility,
safety, convenience, and appeal of transit
service and transit stops.
Consistent: The Project is located within an area of the City
designated for light industrial use, consistent with Project
development. Regional Project access would be from SR-210 via the
officially designated local truck route, Sierra Avenue, approximately
0.6 mile south of the Project site. The Project would comply with the
requirements for emergency lane width, vertical clearance, and
distance would ensure that adequate emergency access is available
for all new development and redevelopment projects. Additionally,
the necessary development fees will be paid prior to construction,
as indicated in the Fontana MC Section 11.2.
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Page 4.17-9, Table 4.17-1 Consistency Analysis
Policy 2.3: Locate high-quality industrial
uses where there is appropriate access to
regional transportation routes.
Consistent: The Project is located within an area of the City
designated for light industrial use, consistent with Project
development. Regional Project access would be from SR-210 via
the officially designated local truck route, Sierra Avenue,
approximately 0.6 mile south of the Project site.
Page 4.17-13, Impact 4.17-4
The Project is not anticipated to result in any significant emergency access impacts during construction.
Roadway improvements could result in temporary disruption or slowing of traffic flows, but all roadways
would remain open to emergency vehicle traffic at all times. Local access would be provided via Sierra
Avenue and Mango Avenue. Project site ingress and egress would be via three driveways: one 50-foot
driveway on Sierra Avenue and one approximately 54-foot (southerly) driveway and one 35-foot
(northerly) driveway on Mango Avenue. Trucks would enter and exit the site from via northbound Sierra
Mango Avenue and exit the site via southbound Mango Avenue. Mango Avenue intersects with Sierra
Lakes Parkway which reconnects with Sierra Avenue. Trucks would access southbound Sierra Avenue from
this point to reach SR-210 and regional destinations beyond. This would ensure that aAll emergency
vehicles would be able to pass access the Project site using either Sierra Avenue or Mango Avenue should
the need arise. A 30-foot-wide fire lane would also circumvent the Project site.
Site Access
The City of Fontana Municipal Code Section 30-692 requires a minimum driveway width of 40-feet for
two-way truck access at industrial sites and 26-feet for two-way passenger vehicle access. The site exceeds
these requirements with a 35-foot passenger vehicle driveway on Mango Avenue, a 50-foot passenger
vehicle driveway on Sierra Avenue, and a 54-foot truck driveway on Mango Avenue.
Emergency Vehicle Access and Circulation
The Project’s site was designed to ensure emergency vehicle access to all driveways and allow for
circulation around the building’s perimeter, with a 30-foot-wide fire lane around the building, consistent
with San Bernardino County Fire Protection District’s Standard Number A-1. The Project also provides two
points of access for fire apparatus, also consistent with Standard Number A-1. Per Standard Number A-1
“Buildings which exceed 100,000 square feet shall have fire access roadways provided on all sides”.1 The
Project is consistent.
Figure 4.17-1 presents an evaluation of the turning movements for emergency vehicles at the passenger
vehicle driveway along Sierra Avenue. The analysis includes the northbound right-turn and westbound
right-turn movements only due to the presence of raised median along Sierra Avenue. Both turns were
assessed simultaneously to demonstrate that emergency vehicles can perform these maneuvers without
conflict with other vehicles. Additionally, the evaluation confirms that emergency vehicles are able to
maneuver around both sides of the building.
1 SBCFPD. 2023. Standard Number A-1. https://sbcfire.org/wp-content/uploads/sites/46/2023/09/SBCOFPD-STANDARD-A-1-FIRE-APPARATUS-
ACCESS-ROAD-DESIGN-CONSTRUCTION-AND-MAINTENANCE-7.1.23.pdf?x36804.
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Figure 4.17-2 presents an evaluation of the turning movements for emergency vehicles at the passenger
vehicle driveway along Mango Avenue. The analysis includes the northbound left-turn and eastbound
right-turn movements to reflect movements emergency services would make traveling to and from the
Project. Both turns were assessed simultaneously to demonstrate that emergency vehicles can perform
these maneuvers without conflict with other vehicles. Additionally, the evaluation confirms that
emergency vehicles are able to maneuver around both sides of the building.
Figure 4.17-3 presents an evaluation of the turning movements for emergency vehicles at the truck
driveway along Mango Avenue. The analysis includes the northbound left-turn and eastbound right-turn
movements to reflect movements emergency services would make traveling to and from the Project. Both
turns were assessed simultaneously to demonstrate that emergency vehicles can perform these
maneuvers without conflict with other vehicles. Additionally, the evaluation confirms that emergency
vehicles are able to maneuver around both sides of the building.
The Project would not result in inadequate emergency access or circulation.
Truck Access and Circulation
The Project’s truck access driveway was designed to provide access to heavy vehicles, which would be
entering the site via a northbound left-turn movement and exit the site making an eastbound right-turn
movement.
Figure 4.17-4 presents an evaluation of the turning movements for heavy vehicles at the truck driveway
along Mango Avenue. The analysis includes the northbound left-turn and eastbound right-turn
movements to reflect movements trucks would make traveling to and from the Project. Both turns were
assessed simultaneously to demonstrate that trucks can perform these maneuvers without conflict with
other trucks. Additionally, the evaluation confirms that trucks are able to maneuver into and out of the
building’s loading docks.
The Project would not result in inadequate truck access or circulation.
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Roadway Hazards
The site is located along straight and generally level roadways, with no sharp curves or dangerous
intersection designs nearby. The proposed driveway along Sierra Avenue exceeds the City’s required
spacing from the signalized intersection of Clubhouse Drive.
A sight distance analysis for each Project driveway was conducted to determine if vehicles and trucks
exiting each of the Project driveways would have adequate sight distance to observe conflicting traffic
along the intersecting roadways. Intersection sight distance for the Project driveways were evaluated
following methodology from the American Association of State Highway and Transportation Officials
(AAHSTO), A Policy on Geometric Design of Highway and Street, 7th Edition2. Sight distance for each Project
driveway was determined based the proposed Project site plan and the following AASHTO intersection
sight distance criteria formula:
Intersection Sight Distance = 1.47 x Vmajor x tg
Where Vmajor is the design speed of the major road and tg is the time gap for the vehicle to exit the Project
driveway and enter the major road. For passenger vehicles, the time gap is 6.5 seconds for right turns and
7.5 seconds for left turns. For trucks, the time gap is 10.5 seconds for right turns and 11.5 seconds for left
turns. No spot speed study was conducted. Therefore, the posted speed limit plus 5 MPH was assumed.
Figure 4.17-5 provides an evaluation of the sight distance at the passenger vehicle driveway along Sierra
Avenue. Due to the presence of a raised median and restriction of left-turn movements, only the visibility
of the south leg was assessed. With Sierra Avenue having a posted speed limit of 55 mph, the evaluation
was conducted for 60 mph. For passenger vehicles turning rig ht, the minimum required sight distance is
575 feet. The sightline analysis for passenger vehicles shows no obstructions that would limit visibility of
approaching vehicles.
Figure 4.17-6 provides an evaluation of the sight distance at the passenger vehicle and truck driveways
along Mango Avenue. With Mango Avenue having a posted speed limit of 35 mph, the evaluation was
conducted for 40 mph. For the passenger vehicle driveway, the minimum sight distance for vehicles
turning right is 385-feet, and 445-feet for vehicles turning left. For the truck driveway, the minimum sight
distance for vehicles turning right is 665-feet, and 725-feet for vehicles turning left. The lines of sight for
both Project driveways demonstrates that there are no obstructions that would limit visibility of
approaching vehicles.
The Project would not increase roadway hazards or degrade safety conditions.
2 A Policy on Geometric Design of Highway and Street, 7 th Edition, American Association of State Highway and Transportation Officials
(AAHSTO), 2018.
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Section 4.20: Wildfire
Page 4.20-1, Introduction
This section evaluates potential wildfire hazard impacts that may result from the implementation of the
proposed Sierra Distribution Facility (Project). This section identifies existing wildfire hazard conditions of
the Project and surrounding areas; considers applicable federal, state, and local goals and policies;
identifies and analyzes environmental impacts; and recommends measures to minimize or avoid potential
adverse impacts as a result of Project implementation.
Information presented in this wildfire hazards impact analysis is derived largely from the following:
• City of Fontana. 2018. Fontana Forward General Plan Update 2015-2035.
• City of Fontana. 2017. City of Fontana Local Hazard Mitigation Plan (LHMP).
• City of Fontana Municipal Code (MC).
• FireWise2000 LLC. 2024. Fire Protection Plan, Sierra Distribution Facility Project, Fontana, CA
(Appendix L).
Pages 4.20-12 through 4.20-14, Section 4.20.5, Impacts and Mitigation Measures
Impact 4.20-2 If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the Project, due to slope, prevailing winds, and other factors,
exacerbate wildlife risks, and thereby expose Project occupants to pollutant
concentrations from a wildfire or the uncontrolled spread of a wildfire?
Level of Significance: Less Than Significant
Construction and Operations
According to CAL FIRE’s Very High Fire Hazard Severity Zones (VHFHSZ) exhibit, the Project resides in a
Non-VHFHSZ and is not identified as a State Responsibility Area (SRA). However, according to the Fire
Prevention Plan (Appendix L) (FPP) prepared for the Project, the Project site is located within a Local
Responsibility Area (LRA) and the area just northwest of the Project site is classified as a Very High FHSZ.
according to the City’s Local Hazard Mitigation Plan, the Project site is identified within a High FHSZ within
an LRA. The City identifies factors contributing to the high, widespread wildfire risk in the City; these
include narrow and often one-lane and/or dead-end roads complicating evacuation and emergency
response, nature and frequency of ignitions and increasing population density leading to more ignitions;
slope of the foothills; and residential development along the foothills. As discussed in Section 2 of the FPP
(Appendix L), topography influences fire risk by affecting fire spread rates. Typically, steep terrain results
in faster fire spread upslope and slower fire spread down-slope in the absence of wind. Flat terrain tends
to have little effect on fire spread, resulting in fires that are driven by wind. Conversely, flat terrain tends
to have little effect on fire spread, resulting in fires that are driven by vegetation and/or wind.
The Project site generally slopes downward to the south at a gradient of three percent. The elevation at
the Project site ranges from 1,630 feet amsl in the northern region of the site to 1,612 feet amsl in the
southern region. Annual mean precipitation ranges from 13 to 29 inches across the surface of the subbasin
and averages about 17 inches and the depth to groundwater is reported approximately 150-250 feet bgs
with a flow direction towards south.
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The climate within the Project site would be characterized as Mediterranean. There are generally mild
and wet (14 to 16 inches of precipitation per year) winters, the bulk of the annual precipitation falling
between January and March. Long, hot, and very dry summer seasons frequently occur with occasional
multi-year droughts. Fires can be a significant issue during summer and fall, before the rainy period,
especially during dry Santa Ana wind events. The seasonal Santa Ana winds can be particularly strong i n
the Project area as warm and dry air is channeled through the north from the dry desert land and can
occur anytime of the year; however, they generally occur in the late fall (September through November).
This is also when non-irrigated vegetation is at its lowest moisture content. Santa Ana winds may gust up
to 70 miles per hour (mph). This phenomenon markedly increases the wildfire danger and intensity in the
Project area by drying out and preheating vegetation as well as accelerating oxygen supply, and thereby,
making possible the burning of fuels that otherwise might not burn under cooler, moister conditions. The
undeveloped land in proximity to the Project site can contribute to a damaging wildland fire event. Any
wind or topography driven wildfire burning under a northeastern (Santa Ana) wind pattern through areas
to the north would create a wildland fire hazard to the Project. However, wildland fires starting west of
the Project site, on a typical fire day with a southwest wind will likely burn up to the fuel treatment areas
and be controlled.3 The Project site is not located in areas with steep slopes that can accelerate the spread
of wildfire and it is listed as a non-VHFHSZ site, so wildfire risk is minimal. The site and surrounding areas
contain little to no vegetation and do not contain tall or even a substantial number of tall trees that would
experience a crown fire. Due to the existing urbanized setting of the Project, wildfire risk is minimal due
to lack of fuel.
The Fuel Modification Zone (FMZ) on the Project site will consist of irrigated and maintained landscapes.
This maintenance results in reduced fire ignition, spread rates, and intensity. Wildland fire behavior
calculations have been projected for the hazardous vegetative fuels on the undeveloped areas in
proximity to the site. These projections are based on fire scenarios that are considered ‘worst case.’ Local
environmental assumptions in the vicinity of the Project area were used in the model process. The FMZ
treated areas on the Project site experienced significant reduction in flame length and fireline intensity.
In summary, wildfires may occur in wildland areas that surround the Project site, but would not be
meaningfully increased in frequency, duration, or size with the construction of the Project. The Project’s
on-site fire potential would be reduced due to conversion of wildland fuels to buildings, parking areas,
managed landscapes, FMZ, improved accessibility for fire personnel, and structures built to the latest
ignition and ember-resistant fire codes. Additionally, the Project would comply with applicable Ci ty
policies mitigating or minimizing wildfire hazard risks. Therefore, due to the presence of surrounding
development, presence of area roadways, lack of steep slopes, and concrete construction of the Project,
it is not likely to be affected by a wildfire during construction or operations. Lastly, the warehouse
structure would be predominantly concrete which is not typically susceptible to fire. As a result, impacts
would be less than significant.
Mitigation Measures
No mitigation is necessary.
3 Firewise2000 LLC. 2024. Fire Protection Plan. Page 13. (Appendix L).
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Impact 4.20-3 If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the Project 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?
Level of Significance: Less Than Significant with Mitigation Incorporated
Construction and Operations
According to CAL FIRE’s Very High Fire Hazard Severity Zones exhibit, the Project resides in a Non-VHFHSZ
Zone and is not identified as an SRA. However, according to the City’s Local Hazard Mitigation Plan, the
Project site is identified within a High FHSZ within an LRA. The Project includes construction of an
approximately 398,514-square foot warehouse facility, located at the northeast corner of Sierra Avenue
and Clubhouse Drive within the City, and is bounded to the north and south by existing commercial /
industrial buildings, to the west by Sierra Avenue, and to the east by Mango Avenue. The Project does not
include any interior roadways, fuel breaks, emergency water sources, or above ground power or utility
lines that would exacerbate a fire hazard with their installation or in their operations. The improvements
of Mango Avenue similarly would not exacerbate fire hazard as the roadway improvement would increase
accessibility to the Project site. Vegetation management requirements shall be implemented at Project
commencement and throughout the construction phase. Vegetation management shall be performed
pursuant to the FPP prior to the start of work and prior to any import of combustible construction
materials. Landscape plantings will not utilize prohibited plants that have been found to be highly
flammable. Overall, the combination of adherence to relevant fire/building codes and implementation of
MM FIRE-1 would result in a less than significant impact with mitigation incorporated.
Mitigation Measures
MM FIRE-1 Fire Safety Requirements. The Project shall be required to comply with all Fire Safety
Requirements as identified in Section 5 of the Fire Protection Plan prepared for the
Project (Appendix L). Conformance with these requirements shall be verified by the San
Bernardino County Fire Department during design review prior to the issuance of building
and grading permits.
No mitigation is necessary.
Impact 4.20-4 If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the Project expose people or structures to significant risks,
including downslope or downstream flooding or landslides, as a result of runof f, post-
fire slope instability, or drainage changes?
Level of Significance: Less Than Significant with Mitigation Incorporated
Construction and Operations
According to CAL FIRE’s Very High Fire Hazard Severity Zones exhibit, the Project resides in a Non-VHFHSZ
Zone and is not identified as an SRA. However, according to the City’s Local Hazard Mitigation Plan, the
Project site is identified within a High FHSZ within an LRA. As discussed above, the Project does not contain
steep slopes and is flat. Slopes can be an important factor relative to wildfire because steeper slopes can
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facilitate more rapid-fire spread. No flooding risk would occur should a wildfire occur in the Project
vicinity. No evidence of on-site landslides or debris flow was observed during field investigations or
documented on the California Geologic Survey Landslide inventory. There is no risk of land sliding and
rockfall for the Project site and surrounding locations, as these areas do not have steep slopes or contain
loose rock or debris. According to the City of Fontana Flood Insurance Rate Map, published by FEMA,
Community Panel Number 06071C7920H, dated August 27, 2008, the Project site is located in Zone X, an
area of minimal flood hazard. The potential for flooding on the Project site, therefore, is considered low.
As noted above, the Fontana MC has a fire hazard overlay district provision for areas designated on the
Fontana GP land use map. Projects within the overlay district must prepare a fuel modification zone plan
for each new tentative tract map, parcel map, or design review application. Therefore, in conformance
with the Fontana MC, a fuel modification zone plan has been prepared for the Project. The fuel
modification zone plan for the Project establishes fuel zones in conformance with Section 30-658 of the
Fontana MC that includes permanent fuel modification zones, access requirements and protection
measures. The Project’s fuel modification zone plan protects the site from wildfire exposure and reduces
exposure to the City of Fontana residents, people, and structures from wildfires. Refer to Figure 3-7:
Conceptual Landscape Plan and Fuel Modification Zone Plan . The final fuel modification zone plan would
be reviewed and approved by the Fire Marshal in advance of going to the Planning Commission. A Fire
Protection Plan (FPP) would also be prepared in advance of going to the Planning Commission, consistent
with Chapter 49 or the California Fire Code. The FPP must be approved by the Fire Marshal in advance of
going to the Planning Commission. The Project would adhere to the requirements of the FPP.
Additionally, the Project would include the installation of an integrated, on-site system consisting of
measures designed to capture and control stormwater. These measures may include, but would not
necessarily be limited to, underground storm drainpipes, catch basins, underground infiltration basins,
and other structural best management practices to capture on-site stormwater runoff, and temporarily
capture and hold stormwater before conveying the runoff offsite. In addition, the Project includes BMPs
and low impact development to minimize run-off and maximize infiltration. These structures are designed
to accommodate both existing drainage flows and potential drainage flow increases that would result
from Project implementation. The Project also would not introduce new slopes that would exacerbate
existing hazards of wildfire.
Lastly, the Project would implement MM FIRE -1 which would require the Project to comply with all Fire
Safety Requirements as identified in Section 5 of the FPP prepared for the Project. Therefore, due to the
existing topography and low slopes both on the Project site and surrounding areas as well as proposed
drainage improvements, impervious areas and landscaping incorporated into Project design, the Project
would not substantially exacerbate risks with slope instability due to landslides or flooding if a wildfire
should occur in these areas.
Mitigation Measures
See MM FIRE-1 above. No mitigation is necessary.
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