addendum to mitigated negative declaration

ADDENDUM TO MITIGATED NEGATIVE DECLARATION

City of Adelanto Applications:

Conditional Use Permit No. 21-03 (CUP 21-03) Location and Development Plan No. 21-02 (LDP 21-02)

Minor Variance No. 21-02 (MIN VAR 21-02)

Property located on APN 0459-421-25 and bounded by Bartlett Road to the north, Air Expressway to the south, Muskrat Avenue to the east, and Koala Road to the west;

City of Adelanto, CA

LEAD AGENCY: City of Adelanto

Development Services - Planning Division 11600 Air Expressway

Adelanto, California 92301 Case Planner: James Hirsch, Contract Planner

Phone: (760) 246-2300 Ext. 11190 [email protected]

PROJECT APPLICANT:

Industrial Integrity Solutions Contact: Daniel Pocius

2151 E. Convention Center Way, Ste 100 Ontario, CA 91764

April 15, 2021

Addendum to Mitigated Negative Declaration CUP 21-03, LDP 21-02, MIN VAR 21-02

TABLE OF CONTENTS

Section Name and Number Page

City of Adelanto Page i

1.0 Introduction ........................................................................................................................1-1

1.1 Prior California Environmental Quality Act (CEQA) Compliance ..................................... 1-1

1.2 Project Overview .............................................................................................................. 1-1

1.3 Findings for a MND Addendum Pursuant to the CEQA Guidelines ................................. 1-2

1.4 Format and Content of this MND Addendum ................................................................. 1-4

1.5 Addendum to Mitigated Negative Declaration Processing ............................................. 1-5

1.5.11 Lead Agency Contact Information ...................................................................... 1-5

2.0 Environmental Setting ..........................................................................................................2-1

2.1 Project Location ............................................................................................................... 2-1

2.2 Existing Site and Area Conditions .................................................................................... 2-1

2.3 Surrounding Land Uses and Development ...................................................................... 2-1

2.4 Existing General Plan Land Use and Zoning Districts ....................................................... 2-1

3.0 Project Description ..............................................................................................................3-1

3.1.1 Project Location .................................................................................................. 3-1

3.1.2 Project Description Details .................................................................................. 3-1

4.0 Environmental Checklist Form ..............................................................................................4-1

4.1 Environmental Factors Potentially Affected .................................................................... 4-1

4.2 Determination .................................................................................................................. 4-1

5.0 Environmental Analysis ........................................................................................................5-3

5.1 Aesthetics ......................................................................................................................... 5-3

5.2 Agriculture and Forestry Resources ................................................................................. 5-5

5.3 Air Quality ........................................................................................................................ 5-8

5.4 Biological Resources ...................................................................................................... 5-12

5.5 Cultural Resources ......................................................................................................... 5-16

5.6 Energy ............................................................................................................................ 5-18

5.7 Geology and Soils ........................................................................................................... 5-21

5.8 Greenhouse Gas Emissions ............................................................................................ 5-26

5.9 Hazards and Hazardous Materials ................................................................................. 5-28

5.10 Hydrology and Water Quality ........................................................................................ 5-32

5.11 Land Use and Planning ................................................................................................... 5-37

5.12 Mineral Resources ......................................................................................................... 5-39


TABLE OF CONTENTS

Section Name and Number Page

City of Adelanto Page ii

5.13 Noise .............................................................................................................................. 5-40

5.14 Population and Housing ................................................................................................. 5-42

5.15 Public Services................................................................................................................ 5-43

5.16 Recreation ...................................................................................................................... 5-46

5.17 Transportation ............................................................................................................... 5-47

5.18 Tribal Cultural Resources ............................................................................................... 5-52

5.19 Utilities and Service Systems ......................................................................................... 5-53

5.20 Wildfire .......................................................................................................................... 5-56

5.21 Mandatory Findings of Significance ............................................................................... 5-57

6.0 References ...........................................................................................................................5-1


LIST OF FIGURES

Figure Name and Number Page

City of Adelanto Page iii

Regional Map ................................................................................................................... 2-3 Vicinity Map ..................................................................................................................... 2-4 Aerial Photograph ............................................................................................................ 2-5 USGS Topographic Map ................................................................................................... 2-6 Location and Development Plan ...................................................................................... 3-3


LIST OF TABLES

Table Name and Number Page

City of Adelanto Page iv

Table 2-1 Surrounding Land Uses and Development ...................................................................... 2-1 Table 2-2 Surrounding General Plan Land Use and Zoning Districts ............................................... 2-2 Table 5-3 Maximum Daily Operational Air Emissions Reported in the Adopted MND ................. 5-10 Table 5-4 Proposed Project’s Maximum Daily Operational Air Quality Emissions ........................ 5-10 Table 5-5 Air Quality Emissions Comparison ................................................................................. 5-11 Table 5-6 2017 Approved Project Annual Energy Consumption ................................................... 5-19 Table 5-7 2021 Proposed Project Annual Energy Consumption .................................................... 5-19 Table 5-8 Energy Consumption Comparison ................................................................................. 5-20 Table 5-9 2017 Approved Project – GHG Emissions ...................................................................... 5-27 Table 5-10 Proposed Project – GHG Emissions................................................................................ 5-27 Table 5-11 GHG Emissions Comparison ........................................................................................... 5-28 Table 5-12 2017 Approved Project - Project Trip Generation Summary ......................................... 5-48 Table 5-13 Proposed Project – Trip Generation Summary .............................................................. 5-48 Table 5-14 Trip Generation Comparison ......................................................................................... 5-49


LIST OF TECHNICAL APPENDICES

Appendix Document Title

City of Adelanto Page v

A Initial Study/Mitigated Negative Declaration, City of Adelanto Application No. General

Plan Amendment No. 17-02 and Zone Change No. 17-02 B Air Quality, Greenhouse Gas, and Energy Assessment C Biological Resources Update Letter D Cultural Resources Update Letter E Geotechnical and Infiltration Evaluation F Phase 1 Environmental Site Assessment Update Letter G Preliminary Drainage Report H Trip Generation Assessment I Will Serve Letter


LIST OF ACRONYMS AND ABBREVIATED TERMS

Acronym Definition

City of Adelanto Page vi

APN Assessor Parcel Number APUA Adelanto Public Utility Authority CEQA California Environmental Quality Act CUP Conditional Use Permit DL-5 Desert Living (1 dwelling unit per 5 acres) (Zoning Code) DU dwelling unit EIR Environmental Impact Report GHG Greenhouse Gas GPA General Plan Amendment IS Initial Study LDP Location and Development Plan LM Light Manufacturing MDAQMD Mojave Desert Air Quality Management Zone MIN VAR Minor Variance MND Mitigated Negative Declaration MWA Mojave Water Agency NPDES National Pollutant Discharge Elimination System PRC Public Resources Code R-S1 Single Family Residential (Zoning Code) SB Senate Bill SCH State Clearinghouse SF Square Feet SWPPP Stormwater Pollution Prevention Plan WQMP Water Quality Management Plan ZC Zone Change ZCA Zone Code Amendment ZMA Zoning Map Amendment


City of Adelanto Page 1-1

1.0 Introduction

1.1 PRIOR CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) COMPLIANCE

CEQA is a statewide environmental law contained in Public Resources Code §§ 21000-21177 that applies to most public agency decisions to carry out, authorize, or approve actions that have the potential to adversely affect the environment. This document is an Addendum to a Mitigated Negative Declaration (MND) having State Clearinghouse (SCH) Number 2017031036 (SCH No. 2017031036) prepared in accordance with CEQA and adopted by the City of Adelanto City Council on June 14, 2017 pertaining to the following City-approved applications. On June 14, 2017 the Adelanto City Council approved Ordinance 563 (General Plan Amendment No. GPA 17-02, Zone Change No. ZC 17-02 and Zoning Map Amendment No. ZMA 17-01) - amending the General Plan Land Use and Zoning Map from Single Family Residential to Light Manufacturing and creating an Overlay zone to allow cannabis cultivation, manufacturing, distribution/transportation, and testing within the Light Manufacturing (LM) Zone on approximately 87.37 acres bounded by Bartlett Road to the north, Air Expressway to the south, Muskrat Avenue to the east, and Koala Road to the west; and, Ordinance 564 (Zone Code Amendment No. ZCA 17-01) amending Adelanto Municipal Code Sections 17.80.080, 17.80.090, 17.80.100, and 17.80.110 to restrict medical cannabis cultivation, manufacturing, distribution/transportation, and testing within the City to properties within the City’s Cannabis Overlay Zones-as that term is defined in Ordinance No. 563-to help protect the health and safety of City residents while permitting activities that can potentially have a beneficial medical effect on many individuals. (City of Adelanto, 2017b) Although an implementing development project was not concurrently proposed on the Project site, the MND (SCH No. 2017031036) assumed that the Project site would be developed in the future with uses authorized by GPA 17-02, ZC 17-02 and ZMA 17-01 (Ordinance 563) and ZCA 17-01 (Ordinance 564) which include cannabis cultivation, manufacturing, distribution/transportation, and testing. For analytical purposes the MND assumed a scenario of 87.37 acres of cannabis cultivation use and up to 100,00 square feet (SF) of manufacturing use, with full occupancy occurring by 2019. 1.2 PROJECT OVERVIEW

On March 15, 2021, the Project Applicant, Industrial Integrity Solutions, submitted the following applications to the City of Adelanto to implement development on the Project site:

• Conditional Use Permit No. 21-03 (CUP 21-03); • Location and Development Plan No. 21-02 (LDP 21-02) • Minor Variance No. 21-02 (MIN VAR 21-02)

The Project’s application materials are on file with the City of Adelanto Planning Department at 11600 Air Expressway, Adelanto, CA 92301 and are hereby incorporated by reference.



The Project’s intended cannabis cultivation and associated uses are consistent with previously-approved Ordinances 563 and 564 and are within the scope of uses assumed for the site in the previously-adopted MND (SCH No. 2017031036) (e.g., medical cannabis cultivation, manufacturing, distribution, transportation, and testing). Specifically, the proposed Project would involve the construction and operation of a cannabis cultivation business having six industrial concrete tilt-up buildings totaling 718,200 square feet (SF), 789,600 SF of greenhouse structures, and related site improvements such as parking areas and landscaping on the 87.37 gross-acre Project site. Each of the six tilt-up buildings would be 119,700 SF and would contain four 29,925 SF units. The Project site is located in the City of Adelanto Light Manufacturing (LM) Zone, which is a Zone that allows for cannabis-related uses (City of Adelanto, 2019). 1.3 FINDINGS FOR A MND ADDENDUM PURSUANT TO THE CEQA GUIDELINES

CEQA Guidelines Section 15164(b) permits a lead agency to prepare an addendum to an adopted MND when a subsequent approval is within the scope of the analysis of the earlier approved CEQA document. An addendum to the MND may be prepared if only minor technical changes or additions are necessary but none of the conditions described in CEQA Guidelines Section 15162 calling for the preparation of a subsequent MND have occurred. As described in detail herein, none of the circumstances that warrant the preparation of a subsequent MND are present. Furthermore, the previously-adopted MND (SCH No. 2017031036) (hereafter “Adopted MND”) remains relevant to the currently-proposed Project and retains informational value, as the Project site’s current environmental setting is similar to what is described in the Adopted MND, and the currently-proposed Project is consistent with the range of uses described and evaluated by the Adopted MND. The currently-proposed Project represents the implementation of a development Project that is substantially consistent with the development scenario studied in the Adopted MND. The Project would not generate new significant environmental effects that were not previously analyzed and disclosed in the Adopted MND. Therefore, the preparation of an Addendum to the Adopted MND pursuant to CEQA Guidelines Section 15164 is appropriate. CEQA Guidelines Section 15162 provides that when a MND has been adopted for a project, no subsequent MND shall be prepared unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more of the following. As indicated in the below findings, the City of Adelanto has determined that none of the conditions described in CEQA Guidelines Section 15162 have occurred pertaining to the proposed Project. For additional evidence to support the City’s conclusion, refer to Section 5.0 of this document.

1. Substantial changes are proposed in the project which will require major revisions of the previous MND due to the involvement of environmental effects or a substantial increase in the severity of previously identified significant effects:

a. Finding: The proposed Project does not involve substantial changes to the project

evaluated by the Adopted MND, and would not involve any new significant environmental effects or a substantial increase in the severity of previously-identified significant effects beyond what was evaluated and disclosed by the Adopted MND.



The Adopted MND evaluated the proposed 87.37-acre Project site for cannabis cultivation use in conjunction with up to 100,000 SF of manufacturing use. As documented by the Project’s Environmental Checklist Form (included herein in Section 5.0), there are no components of the currently-proposed Project that would result in new significant environmental effects or a substantial increase in the severity of previously-identified significant effects beyond the impacts that were evaluated, disclosed, and mitigated to below a level of significance as part of the Adopted MND. The currently-proposed Project would be subject to all applicable mitigation measures identified by the Adopted MND, which would be enforced through the City’s conditions of approval for the Project. Furthermore, the Adopted MND remains relevant to the currently-proposed Project and retains informational value, as the current environmental setting is the same or similar to the setting described by the Adopted MND and the currently-proposed Project is substantially consistent with the project described and evaluated by the Adopted MND.

2. Substantial changes occur with respect to the circumstances under which the project is

undertaken, which will require major revisions of the previous Mitigated Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or,

a. Finding: Substantial changes have not occurred with respect to the circumstances

under which the Project will be undertaken. Similar to the conditions that existed when the Adopted MND was prepared, the Project site consists of vacant undeveloped land. The Adopted MND anticipated future development of the 87.37 gross-acre Project site with a range of cannabis cultivation, manufacturing, distribution/transportation, and testing uses and analytically studied a scenario of cannabis cultivation and manufacturing use that would result in the same, or in some circumstances, greater, environmental effects than would the proposed Project. The environmental conditions of the Project site and in the surrounding area are substantially the same as disclosed in the Adopted MND. Therefore, no changes have occurred that require revisions to Adopted MND due to the involvement of new significant environmental effects or a substantial increase in the severity of previously-identified significant effects.

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 Mitigated Negative Declaration was adopted, shows any of the following: (A)The project will have one or more significant effects not discussed in the previous Mitigated Negative Declaration; (B) Significant effects previously examined will be substantially more severe than shown in the previous Mitigated 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, and (D) Mitigation measures or alternatives which are considerably



different from those analyzed in the previous Mitigated Negative Declaration, would substantially reduce one or more significant effects on the environment.

a. Finding: No 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 environmental determination was adopted, has become available. The currently-proposed Project will not result in new significant environmental effects, or increase the severity of previously identified significant effects as demonstrated in Section 5.0 of this document.

The City of Adelanto, serving as the CEQA Lead Agency for the proposed Project (See CEQA Guidelines §§ 15050–15051), determined in its independent judgment that the Project as proposed does not meet any of the circumstances from CEQA Guidelines Section 15162 and that an Addendum to the previously-adopted MND (SCH 2017031036) GPA 17-02 and ZC 17-02 is the appropriate CEQA compliance document for the Project. The City’s finding is based on the following facts:

a. As demonstrated in Section 5.0, Environmental Analysis, of this document, major revisions to the Adopted MND are not required. Implementation of the Project would not result in any significant impacts to the physical environment that were not already disclosed in the Adopted MND and would not result in substantial increases in the severity of the environmental impacts previously disclosed in the Adopted MND.

b. Subsequent to the City’s adoption of the Adopted MND, no substantial changes in the

circumstances under which the Project would be undertaken have occurred that would require major revisions to the Adopted MND due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

c. There is no evidence in the public record that new information of substantial

importance has become available that is applicable to the Project and/or Project site, and that was not known and could not have been known with the exercise of reasonable diligence at the time the City Council adopted the Adopted MND, and that would alter the conclusions of the Adopted MND.

1.4 FORMAT AND CONTENT OF THIS MND ADDENDUM

The following components comprise this MND Addendum in its totality:

a. This Introduction (Section 1.0), the Environmental Setting (Section 2.0) and the Project Description (Section 3.0).

b. The Environmental Checklist Form (Section 4.0) and Environmental Analysis (Section 5.0), which

conclude that implementation of the Project would not result in any new, significant environmental impacts that were not previously disclosed in the Adopted MND or substantially



increase the severity of the significant environmental impacts beyond the levels disclosed in the Adopted MND.

c. The Adopted MND (SCH No. 2017031036) and the technical reports and other documentation and reference sources cited therein. The Adopted MND is attached as Appendix A to this MND Addendum.

d. Technical reports and reference sources cited in this MND Addendum that evaluate the proposed Project and Project site and which are attached as Appendices B - I. Appendix A: Initial Study/Mitigated Negative Declaration, City of Adelanto Application No.

General Plan Amendment No. 17-02 and Zone Change No. 17-02

Appendix B Air Quality, Greenhouse Gas, and Energy Assessment

Appendix C Biological Resources Update Letter

Appendix D Cultural Resources Update Letter

Appendix E Geotechnical and Infiltration Evaluation

Appendix F Phase 1 Environmental Site Assessment Update Letter

Appendix G Preliminary Drainage Report

Appendix H Trip Generation Assessment

Appendix I Will Serve Letter

1.5 ADDENDUM TO MITIGATED NEGATIVE DECLARATION PROCESSING

This MND Addendum was compiled by the City of Adelanto, serving as the Lead Agency for the proposed Project pursuant to CEQA Section 21067 and CEQA Guidelines Article 4 and Section 15367. “Lead Agency” refers to the public agency that has the principal responsibility for carrying out or approving a project. The City of Adelanto Planning Division directed and supervised the preparation of this MND Addendum. Although prepared with the assistance of the consulting firm T&B Planning, Inc., all of the content, analyses, determinations, and conclusions contained within this MND Addendum reflect the sole independent judgment of the City of Adelanto, acting as Lead Agency under CEQA. 1.5.11 Lead Agency Contact Information

James Hirsch, Contract Planner City of Adelanto Planning Division City of Adelanto City Hall 11600 Air Expressway Adelanto, CA 92301 Email: [email protected] Phone: (760) 246-2300 ext. 11190



2.0 Environmental Setting

2.1 PROJECT LOCATION

As shown on Figure 2-1, Regional Map, and Figure 2-2, Vicinity Map, the Project site is partially bounded by Air Expressway on the south, Bartlett Avenue on the north, Muskrat Avenue on the east, and Koala Road on the west. The Project site includes Assessor Parcel Number (APN) 0459-421-25; Township 6 N, Range 5W, Section 30. 2.2 EXISTING SITE AND AREA CONDITIONS

As depicted on Figure 2-3, Aerial Photograph, the Project site is approximately 87.37 gross acres of vacant undeveloped land. Under existing conditions, vegetation consists of desert scrub. As shown on Figure 2-4, USGS Topographic Map, the Project site is relatively flat with no significant topographic features. The northern boundary of the site is Bartlett Avenue which is a dirt roadway. The southern boundary of the site consists of a portion of Air Expressway (approximately 480 feet in length as measured from the right-of way of Muskrat Avenue). The remaining southern boundary of the site is adjacent to power lines that bisect the southwest corner of the site. The eastern boundary of the site is the unimproved right-of-way of Muskrat Avenue. The western boundary of the site is Koala Road which is a paved two-lane roadway. 2.3 SURROUNDING LAND USES AND DEVELOPMENT

As identified on Table 2-1, Surrounding Land Uses and Development, the land use at the Project site is consistent with the surrounding land uses. The site is bound on all sides by roadways and vacant land.

Table 2-1 Surrounding Land Uses and Development

Location Existing Use Project site Vacant undeveloped land North Unimproved Bartlett Avenue, north of which is vacant undeveloped land South Air Expressway (approximately 480 feet in length as measured from the right-of-way of

Muskrat Avenue). The remaining portion of the southern boundary is bound by power lines that bisect the southwest corner of the site.

East Muskrat Avenue, east of which is vacant undeveloped land West Koala Road, a paved two-lane roadway, west of which is vacant undeveloped land

2.4 EXISTING GENERAL PLAN LAND USE AND ZONING DISTRICTS

In the City of Adelanto, the General Plan Map and Zoning Map are combined; therefore, general plan amendments and zone changes occur simultaneously (City of Adelanto, 2020a). As identified on Table 2-2, Surrounding General Plan Land Use and Zoning , the Project site is designated and zoned Light Manufacturing and is located in a zone for cannabis uses (City of Adelanto, 2019).



Table 2-2 Surrounding General Plan Land Use and Zoning Districts

Location Land Use Designation and Zoning Project site Light Manufacturing (LM) with Cannabis Overlay North Single-Family Residential (R-S1) South Light Manufacturing (LM) East Single-Family Residential (R-S1) West Desert Living (DL-5) (1 du/5 ac)

(City of Adelanto, 2019)



Regional Map



Vicinity Map



Aerial Photograph



USGS Topographic Map



3.0 Project Description

3.1.1 Project Location

The Project site is partially bounded by Air Expressway on the south, Bartlett Road on the north, Muskrat Avenue on the east, and Koala Road on the west. The site is identified as County of San Bernardino Assessor’s Parcel Number 0459-421-25. 3.1.2 Project Description Details

As shown on Figure 3-1, Location and Development Plan, the proposed Project entails the construction and operation of six industrial concrete tilt-up buildings totaling 718,200 square feet (SF), 789,600 SF of greenhouse structures, and related site improvements. The Project’s intended use is for medical cannabis cultivation, manufacturing, distribution, transportation, and testing. The six tilt-up buildings would be positioned on the eastern portion of the property and would be used for cannabis cultivation operations and ancillary uses. The greenhouse structures are proposed as 39 greenhouses on the western portion of the property arranged in a single column with six clusters of six greenhouses, and a cluster of three greenhouse at the southern limits. The facility is designed to contain two gated entrances and would be secured 24 hours a day. To entitle the Project, the Project applicant is seeking a CUP, LDP, and a Minor Variation to reduce the front setback for a proposed guard shack from 25 feet to 15 feet. The application numbers are as follows:

• Conditional Use Permit No. 21-03 (CUP 21-03) • Location and Development Plan No. 21-02 (LDP 21-02) • Minor Variance No. 21-02 (MIN VAR 21-02)

A. Project Phasing

The Project would be constructed in two phases. Phase 1 would include the six industrial tilt-up buildings having 718,200 SF, as well as 394,800 SF of greenhouses. Phase 2, to be constructed at a later date, would consist of an additional 394,800 SF of greenhouse structures. The CUP for the industrial tilt-up buildings would reflect the approval of a total square footage of 1,436,400 SF (twice the space as currently proposed) to address any future tenant improvements related to a second level of greenhouses. B. Project Site Access

Street improvements and access to the Project site would be from Bartlett Avenue and Muskrat Avenue. Bartlett Avenue along the Project site frontage is designed to be half-width + 8 feet from the western most entrance to Muskrat Avenue. Offsite improvements on Bartlett Avenue are designed to be 26-foot-wide asphalt with 2-foot graded shoulders from Muskrat Avenue to Aster Road. Muskrat Avenue along the Project site frontage is designed to be half-width + 8 feet from Bartlett Avenue to Air Expressway. Offsite improvements on Muskrat Avenue are designed to be 26-foot-wide asphalt with 2-foot graded shoulders from Air Expressway to Joshua Avenue.



C. Utilities

Water Service Water service would be provided to the Project via an existing water line located beneath Racoon Avenue approximately 660 feet north of Bartlett Avenue, and via an existing water line located beneath the intersection of Racoon Avenue and Air Expressway. The Project would connect to both existing water lines to create a looped system throughout the Project site in order to supply water to the Project. Sewer Service Sewer service would be provided to the Project via existing sewer lines located beneath Racoon Avenue, approximately 660 feet north of Bartlett Avenue, and via the existing sewer line beneath the intersection of Bartlett Avenue and Stevens Street. Drainage Improvements The Project’s stormwater drainage design would route all Project site runoff to two proposed onsite retention and water quality basins located in the northern portion of the property. Storm drain inlets are planned to be installed in appropriate locations on the site with subsurface storm drain pipes conveying water to the basins. The basins are designed to allow infiltration of all 100 year, 24-hour storm events. As such, no offsite stormwater conveyance facilities are required. D. Construction Characteristics

Construction characteristics would not substantially differ from those assumed and described in the Adopted MND other than the Project being constructed and brought into operation three years later than the Adopted MND assumed. The Adopted MND assumed a 2019 opening year and the proposed Project’s opening year is projected as 2022. Later construction and operational start dates is not substantial new information nor would a later start date result in additional or more severe impacts to the environment as compared to the impacts presented in the Adopted MND. In fact, the later start date is likely to result in lesser environmental impacts due to the increased stringency of environmental regulatory requirements in California to which the Project must comply, and the phasing in of less polluting construction equipment in most standard construction equipment fleets. E. Project Operational Characteristics

Operational characteristics would not substantially differ from those assumed and described in the Adopted MND. The proposed Project entails the proposed operation of cannabis cultivation and accessory uses in six industrial tilt-up building in the western portion of the Project site and greenhouses in the eastern portion of the Project site.



Location and Development Plan



4.0 Environmental Checklist Form

4.1 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED

Pursuant to Public Resources Code Section 21157.1 (b) and CEQA Guidelines 15177(b)(2), the purpose of this Initial Study is to analyze whether the proposed Project described as Conditional Use Permit No. 21-03 (CUP21-03), Location and Development Plan No. 21-02 (LDP21-02), and Minimum Variance No 21-02 (MIN VAR 21-02) may cause any additional significant effects on the environment, which were not previously disclosed in the MND (SCH No. 2017031036) which was adopted by the City of Adelanto in 2017 (hereafter “Adopted MND”). The environmental factors checked below (none) would be potentially affected by the proposed Project involving at least one new impact that is a "Potentially Significant Impact" as indicated by the checklist on the following pages.

☐ Aesthetics ☐ Agriculture and Forestry Resources ☐ Air Quality

☐ Biological Resources ☐ Cultural Resources ☐ Energy

☐ Geology /Soils ☐ Greenhouse Gas Emissions ☐ Hazards & Hazardous Materials

☐ Hydrology / Water Quality ☐ Land Use / Planning ☐ Mineral Resources ☐ Noise ☐ Population /Housing ☐ Public Services ☐ Recreation ☐ Transportation ☐ Tribal Cultural Resources

☐ Utilities /Service Systems ☐ Wildfire ☐ Mandatory Findings of Significance

4.2 DETERMINATION

On the basis of this initial evaluation:

☐ 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 have been made by 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 (EIR) is required.

☐ 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.

☐ 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 the 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.

Signature Date Printed Name



5.0 Environmental Analysis

In accordance with the California Environmental Quality Act (CEQA) (Public Resources Code §§ 21000-21178.1), this Initial Study (IS) has been prepared to analyze the proposed Project to determine if any potential significant impacts upon the environment would occur beyond those disclosed in the Adopted MND. 5.1 AESTHETICS

New Significant

Impact

More Severe Impacts

New Ability to

Substantially Reduce

Significant Impact

No Substantial

Change from

Previous Analysis

Except as provided in Public Resources Cod Section 21099, would the project:

a. Have a substantial effect upon a scenic vista? ☒ ☐ ☐ ☒

b. Substantially damage scenic resources, including, but not limited to trees, rock outcroppings and historic buildings within a state scenic highway?

☐ ☐ ☐ ☒

c. In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point.) If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?

☐ ☐ ☐ ☒

d. Create a new source of substantial light or glare which would adversely affect say or nighttime views in the area?

☐ ☐ ☐ ☒

Would the Project have a substantial effect upon a scenic vista?

Determination: No substantial change from previous analysis. Less than significant impact. Impact Analysis:

The Adopted MND analyzed development of the Project site for cannabis uses and concluded that implementing development projects that comply with Adelanto Municipal Code Section 17.15.101 and Table 30-1 (which regulates building height and lot coverage in the Light Manufacturing Zone), would result in less than significant impacts to scenic vistas. Municipal Code Section 17.15.101 establishes review procedures to ensure high aesthetic standards and the City has complied with the Code provision



by subjecting the Project to a review process by the City’s Design Review Committee. The Project also complies with all other Municipal Code standards, including but not limited to height and lot coverage standards, with exception of the Code’s front setback requirement of 25 feet, for which the Project Applicant is seeking a Minor Variance (MIN VAR 21-02) to allow a guard shack with a 15-foot setback. The proposed guard shack is a small structure and has no reasonable potential to impact a scenic vista due to being located closer to the front property line (15 feet) than would be permitted by Code (25 feet) without a variance. As such, the Project is consistent with the conclusion of the Adopted MND and the Project’s potential to have a substantial effect upon a scenic vista would be less than significant and no mitigation measures are required. There are no components of the proposed Project that would result in increased adverse effects upon scenic vistas. As such, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project substantially damage scenic resources, including, but not limited to trees, rock outcroppings and historic buildings within a state scenic highway?

Determination: No substantial change from previous analysis. No impact. Impact Analysis:

The Adopted MND states that according to the California Department of Transportation there are no State Scenic Highways in the City of Adelanto and thus no potential for development on the Project site to substantially damage scenic resources within a State scenic highway. Since adoption of the MND, no Scenic Highways have been designated in Adelanto. As such, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

In non-urbanized areas, would the project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage points.) If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?


The Adopted MND analyzed development of the Project site for cannabis uses and concluded that if implementing projects are designed to meet the Industrial Design Standards contained in Adelanto Municipal Code Section 17.15.070, a less than significant impact would occur in respect to degrading the visual character or quality of the site and its surroundings. The proposed Project has been reviewed by the City’s Design Review Committee, which found the Project compliant with the City’s Industrial Design Standards. As such, the Project is consistent with the conclusion of the Adopted MND and the Project’s potential to degrade public views of the site and its surroundings would be less than significant and no



mitigation measures are required. There are no components of the proposed Project that would result in increased adverse effects upon visual character. As such, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project create a new source of substantial light or glare which would adversely affect say or nighttime views in the area?


The Adopted MND analyzed development of the Project site for cannabis uses and concluded that if implementing projects comply with the City’s Performance Standards for lighting as described in Section 17.90.040 of the Zoning Ordinance, impacts would be less than significant. The Project’s lighting design will be required as a condition of the Project’s approval to comply with the City’s Performance Standards for lighting. As such, light and glare impacts would be less than significant as concluded by the Adopted MND and no mitigation is required. There are no components of the proposed Project that would result in increased adverse effects or create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. Therefore, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.2 AGRICULTURE AND FORESTRY RESOURCES

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:

a. Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the

☐ ☐ ☐ ☒



New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

California Resources Agency, to non-agricultural use?

b. Conflict with existing zoning for agricultural use, or a Williamson Act contract? ☐ ☐ ☐ ☒

c. Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?

☐ ☐ ☐ ☒

d. Result in the loss of forest land or conversion of forest land to non-forest use?

☐ ☐ ☐ ☒

e. Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?

☐ ☐ ☐ ☒

Would the Project 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?


The Adopted MND states that the California Department of Conservation does not designate lands within the Project site as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. As such, the Adopted MND concluded that no impact would occur. Since adoption of the Adopted MND, the Project site has not been designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) and there are no components of the proposed Project that would result in impacts to Farmland. As such, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.



Would the Project Conflict with existing zoning for agricultural use, or a Williamson Act contract?


The Adopted MND states that the Project site is not zoned for agricultural use and is not under a Williamson Act contract. Since adoption of the adopted MND, the Project site remains designated for non-agricultural uses and no Williamson Act contracts pertaining to the Project site have been put in place. There are no components of the proposed Project that would result in a conflict with existing zoning for agricultural use or a Williamson Act contract. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?


Consistent with the conditions that existed with the Adopted MND, the Project site does not contain any forest lands, timberland, or timberland zoned as Timberland Production, nor are any forest lands or timberlands located on or nearby the Project site. No impact would occur. Therefore, consistent with the findings of the Adopted MND, the Project would not conflict with zoning for forests or Timberland Production. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project result in the loss of forest land or conversion of forest land to non-forest use?


Consistent with the conditions that existed with the Adopted MND, the Project site does not contain any forest lands. No impact would occur. Therefore, consistent with the findings of the Adopted MND, the Project would not result in the loss of forest land or conversion of forest land to non-forest use. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.



Would the Project involve other changes in the existing environment which, due to their location

or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?


Consistent with the conditions that existed with the Adopted MND, based on the analysis under Thresholds 3.2(a) through 3.2(d) above, no impacts would occur with respect to changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use and no mitigation measures are required. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.3 AIR QUALITY

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Where available, the significance criteria established by the applicable air quality management zone or air pollution control zone may be relied upon to make the following determinations. Would the project:

a. Conflict with or obstruct implementation of the applicable air quality plan?

☐ ☐ ☐ ☒

b. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?

☐ ☐ ☐ ☒

c. Expose sensitive receptors to substantial pollutant concentrations? ☐ ☐ ☐ ☒

d. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?

☐ ☐ ☐ ☒

Would the Project conflict with or obstruct implementation of the applicable air quality plan?

Determination: No substantial change from previous analysis. Less than significant impact with mitigation incorporated.



Impact Analysis:

The Project site is located within the Mojave Air Basin, with air quality overseen by the Mojave Desert Air Quality Management District (MDAQMD). The Adopted MND analyzed the Project site for the development of cannabis uses and concluded that up to 87.37 acres of cannabis cultivation use in conjunction with up to 100,000 SF of manufacturing use on the property would not conflict with the MDAQMD’s federal attainment plans for ozone and particulate matter (PM10). The Adopted MND determined that the analyzed cannabis uses on the property would not cause or contribute to any new violation of any air quality standard; increase the frequency or severity of any existing violation of any air quality standard; or delay timely attainment of any air quality standard or any required interim emission reductions or other milestones of any federal attainment plan, with acknowledgement that mitigation for volatile organic compound (VOC) emissions during the architectural coating phase of the construction process would be needed to reduce daily VOC emissions during the construction process to less than significant levels (Mitigation Measures AQ-1). As discussed in more detail under the analysis of Threshold 5.3 (b), the proposed Project would result in a decrease in air quality emissions compared to the air emissions calculated and disclosed in the Adopted MND. Therefore, because the proposed Project would not increase air pollutant emissions as compared to the emissions previously disclosed in the Adopted MND, the proposed Project would not result in new or substantively increased air quality impacts beyond those disclosed in Adopted MND. The proposed Project also would be subject to all applicable regulatory requirements addressing air pollution, as well as Mitigation Measure AQ-1included in Adopted MND to reduce air pollutant emissions. There are no components of the proposed Project that would result in a conflict with or that would obstruct implementation of the MDAQMD attainment plans; therefore, impacts would be less than significant with implementation of Mitigation Measures AQ-1 from the Adopted MND. The Project would not result in any new impacts not already analyzed in Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed Adopted MND.

Would the Project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?

Determination: No substantial change from previous analysis. Less than significant impact with mitigation incorporated. Impact Analysis:

The Adopted MND analyzed development of the Project site with up to 87.37 acres of cannabis cultivation use and up to 100,000 SF of manufacturing use, and reported daily air pollutant emissions expected during the construction and operational phases of the assumed development scenario. The Adopted MND concluded that construction-related air quality impacts would be less than significant with the exception of VOC emissions that would occur during the architectural coating phase of construction. Mitigation Measure AQ-1 was applied to reduce this impact to less than significant. During construction, the proposed Project would result in the same daily air pollutant emissions levels as reported in the Adopted



MND. The same use type would be constructed and the construction equipment fleet is expected to be substantially similar to the fleet assumed in the Adopted MND, although likely less polluting due to the replacement of older equipment with newer, less polluting equipment in most standard fleets over time. Therefore, the Project would not result in any increased impacts due to construction-related air quality emissions as compared to what was evaluated and disclosed by the Adopted MND (Urban Crossroads. Inc., 2021a, p. 2). Mitigation Measure AQ-1 would continue to apply to the proposed Project. With respect to operational emissions, Urban Crossroads, Inc. conducted an analytical assessment to compare the operational air pollutant emissions reported in the Adopted MND against the emissions that would be generated by the currently-proposed Project. Refer to Technical Appendix B for the analysis results. Refer to Table 5-3, Maximum Daily Operational Air Emissions, and Table 5-4, Proposed Project’s Maximum Daily Operational Air Quality Emissions.

Table 5-3 Maximum Daily Operational Air Emissions Reported in the Adopted MND

(Urban Crossroads. Inc., 2021a, Table 1)

Table 5-4 Proposed Project’s Maximum Daily Operational Air Quality Emissions

(Urban Crossroads. Inc., 2021a, Table 3) As shown in below in Table 5-5, Air Quality Emissions Comparison, the proposed Project would result in a decrease in air pollutant emissions compared to the daily emission levels reported in the Adopted MND (Urban Crossroads. Inc., 2021a, p. 3).



Table 5-5 Air Quality Emissions Comparison

(Urban Crossroads. Inc., 2021a, Table 8) Consistent with the findings of the Adopted MND), the Project would not 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, and impacts would be less than significant. The proposed Project also would be subject to all applicable regulatory requirements addressing air pollution reduction. Therefore, the Project would not result in any new impacts not already analyzed in Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed Adopted MND.

Would the Project expose sensitive receptors to substantial pollutant concentrations?


The Adopted MND identified the closest sensitive receptors to the Project site being residential homes located along Raccoon Avenue approximately 1,320 feet east of the Project site. This receptor location is still the closest sensitive receptor to the Project site. The Adopted MND analyzed development of the Project site for cannabis uses and concluded that with development of the property with up to 87.37 acres of cannabis cultivation use and up to 100,000 SF of manufacturing use, impacts to sensitive receptors would be less than significant. The Project’s intended cannabis cultivation and associated uses fall within the intensity and range of uses assumed by the Adopted MND. As such, and consistent with the findings of the Adopted MND, the Project would not exceed any of the MDAQMD’s significance thresholds with implementation of Mitigation Measure AQ-1 during construction, would not create a carbon monoxide (CO) hot spot, and would not expose sensitive receptors to substantial air pollutant concentrations. The Project would not result in any new or increased impacts associated with the exposure of sensitive receptors to substantial pollutant concentrations beyond what was evaluated and disclosed as a less-than-significant impact by the Adopted MND. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?




The Adopted MND analyzed development of the Project site for cannabis uses and concluded that implementing development projects that comply with Adelanto Municipal Code Section 17.90.110 would result in less than significant odor impacts. Municipal Code Section 17.90.110 regulates odors by stating that it is unlawful to emit odorous gasses or matter that is dangerous, noxious, or otherwise objectionable. The proposed Project is required to comply with the City’s Municipal Code, including Section 17.90.110. Therefore, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.4 BIOLOGICAL RESOURCES

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project:

a. Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

☐ ☐ ☐ ☒

b. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or US Fish and Wildlife Service?

☐ ☐ ☐ ☒

c. Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?

☐ ☐ ☐ ☒

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?

☐ ☐ ☐ ☒



Would the Project have a substantial adverse effect, either directly or through habitat

modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?


The Adopted MND analyzed development of the Project site for cannabis uses and concluded that implementing development projects that comply with Adelanto Municipal Code Section 17.57 would result in less than significant impacts to candidate, sensitive, or special status species. Since adoption of the Adopted MND, the Project applicant has demonstrated compliance with the provisions of Code Section 17.57. A General Biological Resources Assessment of the Project site and adjoining lands was conducted by RCA Associates, Inc. in 2016, which included general plant and animal surveys, a desert tortoise habitat assessment and survey, a burrowing owl habitat assessment and focused survey, and a habitat assessment for Mohave ground squirrel. RCA concluded that no federal or State listed species were observed on the site including the Mohave ground squirrel, burrowing owl, desert tortoise, or Swainson’s hawk. In addition, RCA reported there were no documented observations of these species in the immediate area. (RCA, 2016) In June 2020, the City issued a grading permit for the property. As reported in a biological update letter prepared by RCA in February 2021, RCA confirmed that there are no significant biological resources currently on the property (RCA Associates, Inc., 2021a). See Technical Appendix C attached to this Addendum, for RCA’s letter to the Project Applicant documenting the existing biological resource conditions of the site. Joshua trees were reported on the property by RCA in 2016 but at that time the Adopted MND was prepared, the Joshua tree was not an identified candidate, sensitive, or special status species. Joshua trees are now protected by the State of California as a candidate for listing as an endangered species. In June 2020, the City issued a grading permit for the property, and as part of the that permitting process, the Joshua trees that were suitable for relocation were removed from the site and relocated to an off-site parcel approved by the City; the Joshua trees that were not suitable for transplanting were removed during the grading process (RCA Associates, Inc., 2021a). No trees are currently present on the site.

e. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

☐ ☐ ☐ ☒

f. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?

☐ ☐ ☐ ☒



Consistent with the conclusion reached in the Adopted MND, because the Project applicant has demonstrated compliance with City Municipal Code Section 17.57, because all Joshua trees have been removed from the site, and because RCA reports that there are no significant biological resources currently on the property (RCA Associates, Inc., 2021a), implementation of the proposed Project would not have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service. The proposed Project would not result in any new impacts not already analyzed in the Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or US Fish and Wildlife Service?


The Adopted MND analyzed development of the Project site for cannabis uses and concluded that implementing development projects that comply with Adelanto Municipal Code Section 17.57 would result in less than significant impacts to riparian habitats and other regulated natural communities. Since adoption of the Adopted MND, the Project applicant has demonstrated compliance with the provisions of Code Section 17.57. A General Biological Resources Assessment of the Project site and adjoining lands was conducted by RCA Associates, Inc. in 2016, which demonstrates that there is no riparian habitat or other regulated sensitive natural communities on the Project site (RCA, 2016). As reported in a biological update letter prepared by RCA in February 2021, RCA confirmed that there are no significant biological resources currently on the property (RCA Associates, Inc., 2021a). As such, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project 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?


The Adopted MND analyzed development of the Project site for cannabis uses and concluded that implementing development projects that comply with Adelanto Municipal Code Section 17.57 would result in less than significant impacts to wetlands. Since adoption of the Adopted MND, the Project applicant has demonstrated compliance with the provisions of Code Section 17.57. A General Biological Resources Assessment of the Project site and adjoining lands was conducted by RCA Associates, Inc. in



2016, which demonstrates that there are no wetlands on the Project site (RCA, 2016). As reported in a biological update letter prepared by RCA in February 2021, RCA confirmed that there are no significant biological resources currently on the property (RCA Associates, Inc., 2021a). As such, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project 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?


The Adopted MND analyzed development of the Project site for cannabis uses and concluded that implementing development projects that comply with Adelanto Municipal Code Section 17.57 would result in less than significant impacts to wildlife movement. The Project site is not used as a native wildlife nursery. Since adoption of the Adopted MND, the Project applicant has demonstrated compliance with the provisions of Code Section 17.57. A General Biological Resources Assessment of the Project site and adjoining lands was conducted by RCA Associates, Inc. in 2016, which concluded that were no federal or State listed species observed on the site nor was there documented observations of these species in the immediate area. (RCA, 2016) As reported in a biological update letter prepared by RCA in February 2021, RCA confirmed that there are no significant biological resources currently on the property (RCA Associates, Inc., 2021a). As such, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?


The Adopted MND states that City Municipal Code Section 17.57.040, Plant Protection and Management, requires future development projects to comply with the requirements of the County of San Bernardino for the relocation of Joshua trees. The Project applicant has demonstrated compliance with Code Section 17.57.040. In June 2020, the City issued a grading permit for the property, and as part of the that permitting process, all on-site Joshua trees that were suitable for relocation were removed from the site and relocated to an off-site parcel approved by the City; the Joshua trees that were not suitable for transplanting were removed during the grading process (RCA Associates, Inc., 2021a). No trees are currently present on the site. As such, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.



Would the Project conflict with the provisions of an adopted Habitat Conservation Plan, Natural

Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?

Determination: No substantial change from previous analysis. Impact Analysis:

The Adopted MND states that the Project site is not subject to an adopted habitat conservation plan (HCP). Since adoption of the adopted MND, no HCPs have been adopted that apply to the Project site. There are no components of the proposed Project that would result in a conflict with an adopted HCP. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.5 CULTURAL RESOURCES

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project:

a. Cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?

☐ ☐ ☐ ☒

b. Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5?

☐ ☐ ☐ ☒

c. Physically disturb any human remains, including those interred outside of formal cemeteries? ☐ ☐ ☐ ☒

Would the Project cause a substantial adverse change in the significance of a historical resource

pursuant to §15064.5?

Determination: No substantial change from previous analysis. Less than significant impact. Impact Analysis

The Adopted MND analyzed development of the Project site for cannabis uses and concluded that according to General Plan policies, implementing development projects would need to be assessed for impacts to cultural resources during the City’s land development review process, and with proper



assessment and treatment of any identified resources, impacts would be less than significant. The Project applicant has demonstrated compliance with the related General Plan policies. According to RCA Associates, they had previously conducted a comprehensive cultural study of the Project site and summarized the results in a report. As stated by RCA Associates, no cultural resources were identified on the site and they did not recommend mitigation or additional surveys. To support this EIR Addendum, RCA conducted reconnaissance level analysis of the Project site on February 22, 2021 to evaluate the current conditions. According to RCA’s letter to the Project Applicant, no cultural resources were identified during the February 22, 2021 field investigation and no additional analysis is deemed necessary by RCA. See Technical Appendix C attached to this Addendum, for RCA’s letter to the Project Applicant documenting the existing cultural resource conditions of the site on February 23, 2021. (RCA Associates, Inc., 2021a) As such, no impacts to historic resources would occur and the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?


The Adopted MND analyzed development of the Project site for cannabis uses and concluded that according to General Plan policies, implementing development projects would need to be assessed for impacts to cultural resources during the City’s land development review process, and with proper assessment and treatment of any identified resources, impacts would be less than significant. The Project applicant has demonstrated compliance with the related General Plan policies. According to RCA Associates, they had previously conducted a comprehensive cultural study of the Project site and summarized the results in a report. As stated by RCA Associates, no cultural resources were identified on the site and they did not recommend mitigation or additional surveys. To support this EIR Addendum, RCA conducted reconnaissance level analysis of the Project site on February 22, 2021 to evaluate the current conditions. According to RCA’s letter to the Project Applicant, no cultural resources were identified during the February 22, 2021 field investigation and no additional analysis is deemed necessary by RCA. See Technical Appendix C attached to this Addendum, for RCA’s letter to the Project Applicant documenting the existing cultural resource conditions of the site on February 23, 2021. (RCA Associates, Inc., 2021a) As such, no impacts to known archaeological resources would occur and the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. As required by the Adopted MND and as discussed under Thresholds 5.18(a) and (b) below under the topic of Tribal Cultural Resources, the Project applicant is required to comply with Mitigation Measure CR-1 in the event that a resource is discovered during ground-disturbing construction activities.

Physically disturb any human remains, including those interred outside of formal cemeteries?

Determination: No substantial change from previous analysis. Less than significant impact.



Impact Analysis:

Consistent with the findings of the Adopted MND, in the event that human remains are discovered during Project-related grading or other ground disturbing activities, compliance with the applicable provisions of California Health and Safety Code §7050.5 as well as Public Resources Code §5097 et. seq. are required. These regulations specify requirements that must be followed in the event that human remains are discovered and the process to undertake should the Coroner identify the remains as Native American. The proposed Project has not greater potential to uncover human remains than was assumed in the Adopted MND. As such, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.6 ENERGY

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project:

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? ☐ ☐ ☐ ☒

The CEQA Energy thresholds listed in this Addendum were not required by CEQA at the time MND (SCH No. 2017031036) was adopted.

Would the Project result in potentially significant environmental impacts due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?


The previously Adopted MND analyzed cannabis use of the property and the development of up to 87.37 acres of cannabis cultivation use and up to 100,000 SF of manufacturing use. In accordance with the



analytical assumptions used in the Adopted MND, Urban Crossroads, Inc. prepared an energy assessment for the proposed Project. The technical study is attached to this Addendum as Technical Appendix B. Title 24 of the California Code of Regulations establishes energy conservation standards for new construction. These standards relate to insulation requirements, glazing, lighting, shading, and water and space heating systems. The City of Adelanto Municipal Code incorporates these State requirements. Construction-related energy consumption would consist largely of temporary power consumption related to the use of power tools, more specialized equipment (welding equipment, elevators, cranes, etc.), and lighting. A second major source of energy consumption would be related to temporary lighting used for both work and security. Security lighting would likely be required for the site during the course of the construction period. The construction-related electrical consumption rate will be minimal in comparison to the operational consumption once the cannabis facility is occupied. In addition, construction-related activities do not require the use of natural gas. (Urban Crossroads. Inc., 2021a, pp. 3-4) Table 5-6, 2017 Approved Project Annual Energy Consumption, provides a summary of electrical and natural gas consumption based on the Project analyzed in the Adopted MND.

Table 5-6 2017 Approved Project Annual Energy Consumption


Table 5-7, 2021 Proposed Project Annual Energy Consumption, provides an estimate of electrical and natural gas consumption associated with the proposed Project.

Table 5-7 2021 Proposed Project Annual Energy Consumption


The proposed Project would include energy efficient fixtures such as energy efficient lighting, appliances, windows, roofing materials, air conditioning, and insulation and comply with the applicable provisions of the 2019 California Green Building Code requirements. Title 24, Part 6 contains energy requirements for newly constructed buildings, additions to existing buildings, and alterations to existing buildings. As a result, the proposed Project would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during Project construction or operations nor would the Project conflict with or obstruct a state plan for renewable energy or energy



efficiency and a less than significant impacts will occur. The City of Adelanto does not have a local energy plan. (Urban Crossroads. Inc., 2021a, pp. 4-5) Table 5-8, Energy Consumption Comparison, provides a comparison of electrical and natural gas consumption for the buildout scenario analyzed in the Adopted MND as compared to the proposed Project. As shown in Table 5-8, the proposed Project would result in a net decrease in energy demand from the uses that were analyzed in the Adopted MND. As such, the Proposed Project would not result in new or substantively different or substantively increased energy impacts. Therefore, the Project would not result in any new impacts not already analyzed in Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed Adopted MND. (Urban Crossroads. Inc., 2021a, p. 5)

Table 5-8 Energy Consumption Comparison


Would the Project conflict with or obstruct a State or local plan for renewable energy or energy

efficiency?


There are no adopted State plans for renewable energy or energy efficiency that pertain to the Project site. The City of Adelanto does not have a local energy plan (Urban Crossroads. Inc., 2021a, p. 5). Because the proposed Project would have no potential to conflict with such plans, no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.



5.7 GEOLOGY AND SOILS

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project:

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

i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

☐ ☐ ☐ ☒

ii. Strong seismic ground shaking? ☐ ☐ ☐ ☒

iii. Seismic-related ground failure, including liquefaction? ☐ ☐ ☐ ☒

iv. Landslides? ☐ ☐ ☐ ☒

b. Result in substantial soil erosion or the loss of topsoil? ☐ ☐ ☐ ☒

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

☐ ☐ ☐ ☒

d. Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?

☐ ☐ ☐ ☒

e. Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?

☐ ☐ ☐ ☒

f. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?

☐ ☐ ☐ ☒



A Geotechnical and Infiltration Evaluation was completed by GeoTek for the subject property in March 2018 that summarizes GeoTek’s evaluation and preliminary geotechnical recommendations for earthwork, foundation design, and construction on the Project site. Although Geotek’s evaluation was completed for a formerly contemplated multi-family residential development, GeoTek’s evaluation is referenced herein in regard to the existing ground conditions and suitability for development. The Geotechnical and Infiltration Evaluation is attached to this Addendum as Technical Appendix E.

Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:

i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Geology of Mines and Geology Publication 42.


Consistent with the conditions evaluated in the Adopted MND, no Alquist-Priolo Earthquake Fault Zone is presently known to exist in Adelanto. The site is in a seismically active region as is most of Southern California; however, no active or potentially active faults are presently known to exist at the Project site nor is the Project site situated within an Alquist-Priolo Earthquake Fault Zone. (GeoTek, 2018) The nearest zoned fault is the San Andreas fault located approximately 20 miles to the southwest of the City. Because there are no Alquist-Priolo Earthquake Fault Zones within the City, there is no potential for future development of the Project site to expose people or structures to adverse effects related to rupture of a known earthquake fault. Therefore, the Project would not result in any new impacts not already analyzed in the MND (SCH 2017031036), and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

ii) Strong seismic ground shaking? Determination: No substantial change from previous analysis. Less than significant impact. Impact Analysis:

As disclosed in the Adopted MND, the City of Adelanto is located in a seismically active area of Southern California and is expected to experience moderate to severe ground shaking during a seismic event. This risk is not considered substantially different than that of other jurisdictions in the Southern California area. The Adopted MND concluded that with mandatory compliance with the California Building Standards Code also known as the California Code of Regulations Title 24, implementing development projects would withstand seismic ground shaking and not directly or indirectly cause substantial adverse environmental effects. The Project’s construction is required to comply with the California Building Standards Code. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND,



and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

iii) Seismic-related ground failure, including liquefaction? Determination: No substantial change from previous analysis. Less than significant impact. Impact Analysis:

As disclosed in the Adopted MND, the City of Adelanto is located in a seismically active area of Southern California. The Adopted MND concluded that with mandatory compliance with the California Building Standards Code also known as the California Code of Regulations Title 24, implementing development projects would withstand liquefaction and not directly or indirectly cause substantial adverse environmental effects. The Project’s construction is required to comply with the California Building Standards Code. Further, based on the California Geologic Survey, the Project site is not mapped within a zone of potentially liquifiable soils, free groundwater was not encountered in any of the test borings by GeoTek, and GeoTek estimated that groundwater on the site is at a depth of greater than 50 feet below grade. Also, the Project site is not included within the San Bernardino County Geologic Hazards Map as being within an area subject to liquefaction hazard. Therefore, due to the depth to groundwater (greater than 50 feet) and the current geologic hazard mapping, GeoTek determined that liquefaction is not considered to be a hazard at the subject property. (GeoTek, 2018, p. 6) Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

iv) Landslides? Determination: No substantial change from previous analysis. No impact. Impact Analysis:

As disclosed in the Adopted MND, all of the land within the Project site is relatively flat and according to the County of San Bernardino Hazard Maps, is not located in areas prone to landslides. Per the California Geological Survey, the site is not located within a zone of generalized landslide susceptibility and evidence of slope instabilities was not observed during GeoTek’s investigation. (GeoTek, 2018, p. 6) Accordingly, and consistent with the findings of the Adopted MND, the proposed Project would not directly or indirectly cause potential substantial adverse environmental effects associated with landslide, and no impact would occur. The Project would not result in any new impacts not already analyzed in the MND (SCH 2017031036), and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project result in substantial soil erosion or the loss of topsoil?




Impact Analysis:

The Adopted MND analyzed development of the Project site for cannabis uses and concluded that implementing development projects that comply with the National Pollutant Discharge Elimination System (NPDES) permit applicable to the project area and prepare a Storm Water Pollution Prevention Plan (SWPPP), impacts associated with soil erosion would be less than significant. Pursuant to the requirements of the State Water Resources Control Board, the Project Applicant is required to obtain coverage under a NPDES permit for construction activities. The NPDES permit is required for all projects that include construction activities, such as clearing, grading, and/or excavation that physically disturb at least one acre of total land area. Mandatory compliance with the Project’s NPDES permit and other applicable regulatory requirements would ensure that water and wind erosion impacts would be less than significant during construction. Following construction, wind and water erosion on the Project site would be minimized, as the areas physically disturbed during construction would be landscaped or covered with impervious surfaces. Only nominal areas of exposed soil, if any, would occur in the site’s landscaped areas. In addition, the Project Applicant is required to prepare and submit to the City for approval of a Project-specific Storm Water Pollution Prevention Plan (SWPPP) and Water Quality Management Plan (WQMP). The SWPPP and WQMP must identify and implement an effective combination of erosion control and sediment control measures (i.e., Best Management Practices) to reduce or eliminate discharge to surface water from storm water and non-storm water discharges. Adherence to the requirements noted in the Project’s required WQMP and site-specific SWPPP would further ensure that potential erosion and sedimentation effects would be less than significant. As such, consistent with the project characteristics analyzed in the Adopted MND, impacts due to substantial soil erosion or the loss of topsoil would be less than significant. Based on the foregoing analysis, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?


The Adopted MND concluded that with mandatory compliance with the California Building Standards Code also known as the California Code of Regulations Title 24, implementing development projects would be stable and not directly or indirectly cause substantial adverse environmental effects. The Project’s construction is required to comply with the California Building Standards Code. As such, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.



Would the Project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?


The Adopted MND concluded that with mandatory compliance with the California Building Standards Code also known as the California Code of Regulations Title 24, implementing development projects would not create an environmental risk due to expansive soil. The Project’s construction is required to comply with the California Building Standards Code. Alluvium was encountered in all of the hollow-stem auger borings excavated on the site by GeoTek in 2018. In general, the alluvial materials encountered typically consist of medium dense silty sand, clayey sand and sand and very stiff to hard silt. According to the laboratory tests performed, the near-surface alluvial soils exhibited a “very low” expansion potential when tested. (GeoTek, 2018, p. 5) As such, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?


As noted in the Adopted MND, sewer service is provided by the Adelanto Public Utility Authority (APUA) through a network of gravity and force main sewer pipelines. This, no impacts associated with septic tanks would occur. The Project would tie into the domestic sewer system. The “Will-serve" letter from the City of Adelanto confirms that APUA has sewer available approximately 700-feet north of the Raccoon Avenue / Bartlett Avenue intersection. APUA notes that a 2-inch meter is the minimum size for all industrial operations and cultivation operations must maximize recycle and reuse of irrigation water and no discharge is allowed into the City’s sewer system. The Project’s Will-Serve letter is attached to this Addendum as Technical Appendix I. (City of Adelanto, 2021) Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?




Impact Analysis:

The Adopted MND analyzed development of the Project site for cannabis uses and concluded that according to General Plan policies, implementing development projects would need to be assessed for impacts to cultural resources during the City’s land development review process, and with proper assessment and treatment of any identified resources, impacts would be less than significant. Paleontological resources, however, are not cultural resources. Regardless, to implement the proposed Project the depth of grading would be shallow and there is no reasonable potential to encounter a significant paleontological resource. Therefore, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.8 GREENHOUSE GAS EMISSIONS

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project:

a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?

☐ ☐ ☐ ☒

b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing emissions of greenhouse gases?

☐ ☐ ☐ ☒

Would the Project generate greenhouse gas emissions, either directly or indirectly, that may

have a significant impact on the environment?


The Adopted MND analyzed development of the Project site with up to 87.37 acres of cannabis cultivation use and up to 100,000 SF of manufacturing use, and reported expected annual greenhouse gas (GHG) emissions concluding that impacts would be less than significant. Using the same methodology used for analytical analysis in the Adopted MND, Urban Crossroads, Inc. prepared GHG emission calculations for the proposed Project. The technical study is attached to this Addendum as Technical Appendix B. Construction activities associated with the proposed Project would be similar to the construction activities anticipated for the Project site by the Adopted MND; therefore, the Project would not result in any increased impacts due to construction-related GHG emissions as



compared to what was evaluated and disclosed by the Adopted MND. Therefore, construction activities associated with the proposed Project would not result in any new or substantively increased greenhouse gas impacts or cumulatively considerable net increase of greenhouse gasses. (Urban Crossroads. Inc., 2021a, p. 2). With respect to operational emissions, Urban Crossroads conducted an assessment to compare the GHG emissions that would have been generated by the project analyzed in the Adopted MND against the emissions that would be generated by the currently proposed Project. Table 5-9, 2017 Approved Project – GHG Emissions, summarizes the GHG emissions evaluated in 2017 for the Adopted MND and Table 5-10, Proposed Project – GHG Emissions summarizes the operational air quality emissions resulting from the proposed Project.

Table 5-9 2017 Approved Project – GHG Emissions


Table 5-10 Proposed Project – GHG Emissions


As shown in Table 5-11, GHG Emissions Comparison, the proposed Project would result in a decrease in GHG emissions from the GHG emissions previously disclosed in the Adopted MND (Urban Crossroads. Inc., 2021a, p. 3). Therefore, because the proposed Project would not generate an increase in GHG emissions above the amount of emissions analyzed previously by the Adopted MND, the proposed Project would not result in new or substantively increased GHG impacts beyond those disclosed in the Adopted MND. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.



Table 5-11 GHG Emissions Comparison


Would the Project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?


As discussed in the Adopted MND, the San Bernardino Associated Governments (SANBAG) adopted the San Bernardino Regional Greenhouse Reduction Plan, March 2014, which identifies state measures applicable to every partnership city and local measures selected by each local city that could reduce future GHG emissions within the jurisdictional boundary of the city. The City of Adelanto selected a goal to reduce its community GHG emissions to a level that is 30% below its projected GHG emission levels in 2020. As analyzed in Threshold 5.8 (a) above, GHG emissions generated by the proposed Project would be less, in comparison to what was evaluated for the project in the Adopted MND. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the proposed Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.9 HAZARDS AND HAZARDOUS MATERIALS

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project:

a. Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?

☐ ☐ ☐ ☒

b. Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?

☐ ☐ ☐ ☒



New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

c. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?

☐ ☐ ☐ ☒

d. Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

☐ ☐ ☐ ☒

e. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?

☐ ☐ ☐ ☒

f. Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?

☐ ☐ ☐ ☒

g. Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?

☐ ☐ ☐ ☒

Would the Project create a significant hazard to the public or the environment through the

routine transport, use, or disposal of hazardous materials?

Determination: No substantial change from previous analysis. Less than significant. Impact Analysis:

The construction and operational activities evaluated in the previous Phase I Environmental Site Assessment (ESA) prepared by RCA for the Adopted MND covered the same physical disturbance area as the current site. In February 2021 RCA Associates conducted an evaluation of the current conditions on the Project site to determine if there were any signs of contamination or if any hazardous materials had been deposited on the site since their 2016 assessment. RCA’s February 22, 2021 field investigation determined that there were no signs of any soil contamination or the presence of any hazardous materials throughout the site and determined that no additional site investigations or analysis were deemed necessary.



As evaluated in the Adopted MND, the proposed Project would be required to comply with the requirements set forth involving new construction of buildings or structures, in the Adelanto Municipal Code, Chapter 8.10, Hazardous Materials, and Sections 17.80.080(d)(1)(J) and 17.80.090(d)(1)(l). With mandatory compliance with the Municipal Code, consistent with the findings of the Adopted MND, the Project’s potential to create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials, would be less than significant. Thus, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. RCA’s 2021 Phase I ESA update letter is attached to this Addendum as Technical Appendix F. (RCA Associates, Inc., 2021c)

Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?

Determination: No substantial change from previous analysis. Less than significant. Impact Analysis:

The Adopted MND referred to Threshold (a) above. There are no components of the proposed Project that would result in increased hazard impacts compared to the cannabis uses anticipated by the Adopted MND. Compliance with applicable requirements of the Adelanto Municipal Code, Chapter 8.10, Hazardous Materials, and Sections 17.80.080(d)(1)(J) and 17.80.090(d)(1)(l) would ensure that impacts would remain less than significant.

Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?


No schools are located within one-quarter miles of the Project site. As evaluated in the Adopted MND, pursuant to Section 17.80.080(d)(1)C and Section 17.80.090(d)(1)C of the City Municipal Code, no cannabis cultivation or manufacturing shall be established, developed, or operated within 2,500 feet of a school. This requirement would effectively prevent the Project from emitting hazardous or acutely hazardous materials, substances, or waste within one-quarter mile (1,320 feet) of an existing or proposed school. Therefore, consistent with the Adopted MND, the Project has no potential to emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.



Would the Project 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?


As determined by the Adopted MND, the Project site is not on the “Cortese List.” A check of the hazardous material sites completed in April 2021, shows that the Project site is still not listed on a Cortese List as a hazardous waste and substances site. In addition, as evaluated in Thresholds 5.8 (a) and (b) above, RCA’s February 22, 2021 field investigation determined that there were no signs of any soil contamination or the presence of any hazardous materials throughout the site and determined that no additional site investigations or analysis are deemed necessary. Therefore, consistent with the findings of the Adopted MND, no impact would occur. Thus, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?


As determined by the Adopted MND, the Project site is not located within an airport land use plan or within 2.0 miles of a public airport or public use airport. The nearest private airstrip is the Adelanto Airport located more than 2.0 miles southwest of the Project site. Therefore, consistent with the findings of the Adopted MND, no impact would occur. Thus, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?


As evaluated in the Adopted MND, development on the Project site would be required to comply with City Municipal Code Section 13.20.010 to ensure that it would not substantially alter the design or capacity of any public road that would impair or interfere with the implementation of evacuation procedures. The Project complies with Code Section 13.20.010 and the Project’s potential to impair implementation of or



physically interfere with an adopted emergency response plan or emergency evacuation plan would be less than significant. Street improvements and access to the Project site would improve emergency circulation. As such, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?


The Adopted MND analyzed development of the Project site for cannabis uses and concluded that if implementing projects are designed to comply with Adelanto Municipal Code Chapter 14.20, which adopts the most current edition of the California Fire Code, a less than significant impact would occur in respect to wildfire hazards. The proposed Project has been reviewed by the City to confirm compliance with Code Section 14.20. As such, the Project is consistent with the conclusion of the Adopted MND and the Project’s potential to expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires, would be less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.10 HYDROLOGY AND WATER QUALITY

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project:

a. Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?

☐ ☐ ☐ ☒

b. Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?

☐ ☐ ☐ ☒

c. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the

☐ ☐ ☐ ☒



New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

addition of impervious surfaces, in a manner which would:

i. result in substantial erosion or siltation on – or off-site; ☐ ☐ ☐ ☒

iI. Substantially increase the rate of runoff in a manner which would result in flooding on – or offsite;

☐ ☐ ☐ ☒

iii. create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff, or

☐ ☐ ☐ ☒

iv. impede or redirect flood flows? ☐ ☐ ☐ ☒

d. In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?

☐ ☐ ☐ ☒

e. Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?

☐ ☐ ☐ ☒

Would the Project violate any water quality standards or waste discharge requirements or

otherwise substantially degrade surface or ground water quality?


The California Porter-Cologne Water Quality Control Act (§ 13000 [“Water Quality”] et seq., of the California Water Code), and the Federal Water Pollution Control Act Amendment of 1972 (also referred to as the Clean Water Act [CWA]) require that comprehensive water quality control plans be developed for all waters within the State of California. The Project site is located within the jurisdiction of the Lahontan Regional Water Quality Control Board. A specific provision of the CWA applicable to the proposed Project is CWA Section 402, which authorizes the National Pollutant Discharge Elimination System (NPDES) permit program that covers point sources of pollution discharging to a water body. The NPDES program also requires operators of construction sites one acre or larger to prepare a Stormwater Pollution Prevention Plan (SWPPP) and obtain authorization to discharge stormwater under an NPDES



construction stormwater permit. These requirements have not substantially changed since the Adopted MND was adopted. The Adopted MND analyzed development of the Project site for cannabis uses and concluded that implementing development projects that comply with the NPDES permit applicable to the Lahontan Regional Water Quality Control Board (LRWQCB) requirements and prepare a SWPPP, would result in less than significant impacts pertaining to compliance with water quality and waste discharge standards. Construction activities would occur on the same site and in the same or similar manner as assumed by the Adopted MND. As with the project evaluated by the Adopted MND, construction of the proposed Project would involve grading, paving, utility installation, building construction, and landscaping activities, which would generate potential water quality pollutants such as silt, debris, chemicals, paints, and other solvents with the potential to adversely affect water quality. As such, short-term water quality impacts have the potential to occur during construction of the Project in the absence of any protective or avoidance measures. However, pursuant to the requirements of the LRWQCB and the City of Adelanto, and consistent with the requirements that were in effect when the Adopted MND was adopted, the Project Applicant would be required to obtain a NPDES Municipal Stormwater Permit for construction activities. The NPDES permit is required for all projects that include construction activities, such as clearing, grading, and/or excavation that physically disturb at least one acre of total land area. Compliance with the NPDES permit involves the preparation and implementation of a SWPPP for construction-related activities, and these requirements also would have applied to new development at the time the Adopted MND was adopted. The SWPPP is required to specify the best management practices (BMPs) that the Project is required to implement during construction activities to ensure that all potential pollutants of concern are prevented, minimized, and/or otherwise appropriately treated prior to being discharged from the subject property. As with the project evaluated in the Adopted MND, mandatory compliance with the SWPPP would ensure that the proposed Project does not violate any water quality standards or waste discharge requirements during construction activities. Therefore, with mandatory adherence to the required SWPPP, water quality impacts associated with construction activities would be less than significant and no mitigation measures would be required. For long-term operating conditions, the Project Applicant would be required to implement a site-specific Water Quality Management Plan (WQMP), pursuant to the requirements of the applicable NPDES permit. The WQMP is a post-construction management program that ensures the on-going protection of the watershed basin by requiring structural and programmatic controls. According to the Project’s Preliminary Drainage Report prepared by United Engineering Group, dated March 11, 2021, and attached to this MND Addendum as Technical Appendix G, the Project’s stormwater drainage design would route all Project site runoff to two proposed onsite retention and water quality basins located in the northern portion of the property. Storm drain inlets are planned to be installed in appropriate locations on the site with subsurface storm drain pipes conveying water to the basins. The basins are designed to perform water quality functions and allow infiltration of all 100 year, 24-hour storm events. As such, no offsite stormwater conveyance facilities are required. (UEG, 2021) The City requires preparation of a WQMP to demonstrate that the Project’s water quality features do not violate any water quality standards or waste discharge requirements during long-term operation.



Based on the foregoing analysis, and consistent with the conclusion reached by the Adopted MND, the Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality, and impacts would be less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?


As noted in the Adopted MND, the Project would be served with potable water by the Adelanto Public Utility Authority (APUA) and the Project site is not part of the groundwater storage program managed by the Mojave Water Agency (MWA). Therefore, consistent with the findings of the Adopted MND, the Project’s demand for domestic water service would has no reasonable potential to substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level. Therefore, consistent with the findings of the Adopted MND, the Project’s impacts would be less than significant. The Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:

i) result in substantial erosion or siltation on -or off-site; ii) substantially increase the rate of runoff in a manner which would result in flooding on-

or offsite; iii) create or contribute runoff water which would exceed the capacity of existing or

planned stormwater drainage systems or provide substantial additional sources or polluted runoff; or

iv) impede or redirect flows? Determination: No substantial change from previous analysis. Less than significant impact. Impact Analysis:

The Adopted MND analyzed development of the Project site for cannabis uses and concluded that with adherence to General Plan policies pertaining to drainage and runoff, and compliance with City Municipal Code Section 17.93.050 that requires the implementation of erosion and sediment control measures for



development projects, environmental impacts associated with erosion, runoff, flooding, and drainage flows would be less than significant. The Project applicant has demonstrated compliance with applicable General Plan policies. As documented in the Project’s Preliminary Drainage Report attached to this Addendum as Technical Appendix G, the Project is in conformance with the City of Adelanto Master Plan of Drainage. According to the Project’s Preliminary Drainage Report prepared by United Engineering Group, dated March 11, 2021, and attached to this MND Addendum as Technical Appendix G, the Project’s stormwater drainage design would route all Project site runoff to two proposed onsite retention and water quality basins located in the northern portion of the property. Storm drain inlets are planned to be installed in appropriate locations on the site with subsurface storm drain pipes conveying water to the basins. The basins are designed to perform water quality functions and allow infiltration of all 100 year, 24-hour storm events. As such, no offsite stormwater conveyance facilities are required (UEG, 2021). As such and consistent with the findings of the Adopted MND, development of the Project site as proposed would not change any drainage patterns, impact any of the surrounding properties, cause flooding, or change any of the regional master plan facilities. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project result in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?


As stated in the Adopted MND, there is no land within the Project site that is located within a 100-year flood hazard area. The City is not located within a designated dam inundation area. The Pacific Ocean is located more than 70 miles from the Project site; consequently, there is no potential for tsunamis to impact the Project site. In addition, no steep hillsides subject to mudflow are located on or near the Project site and there is no large body of surface water in the vicinity of the Project site that could produce a seiche. Therefore, consistent with the findings of the Adopted MND, the Project would not be subject to inundation by flood hazard, seiches, mudflow, or tsunami. No impact would occur. Based on the foregoing analysis, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?




As noted in the Adopted MND, the Project site is not part of the groundwater storage program managed by the Mojave Water Agency (MWA). Therefore, consistent with the findings of the Adopted MND, the Project and its demand for domestic water service would has no reasonable potential to conflict with a groundwater management plan. In regards to water quality, Project compliance with the applicable standards and requirements of the Lahontan Regional Water Quality Control Board are discussed above under Threshold 5.10(a). Consistent with the findings of the Adopted MND, the Project’s impacts would be less than significant. The Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.11 LAND USE AND PLANNING

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project:

a. Physically divide an established community? ☐ ☐ ☐ ☒

b. Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?

☐ ☐ ☐ ☒

Would the Project physically divide an established community?


The Adopted MND concluded that the development of cannabis uses on the Project site would not divide an established community. The Project site is on the same site with the same land use (cannabis cultivation) as evaluated by the Adopted MND. The Project site is currently vacant and is surrounded by vacant land on all four sides. Therefore, consistent with the findings of the Adopted MND, development of the proposed Project would not physically divide an established community and no impact would occur. Based on the foregoing analysis, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.



Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?

Determination: No substantial change from previous analysis. Less than Significant Impact with Mitigation Incorporated. Impact Analysis:

The project evaluated by the previously Adopted MND proposed a General Plan Map/Zoning Map to change the then-existing land use designation from Single Family Residential (R-S1) (.41 - 1 du/acre) to Light Manufacturing (LM), with Cannabis Overlay and amending the Zoning Ordinance to allow cannabis cultivation, manufacturing, distribution/transportation, and testing within the proposed Light Manufacturing (LM) Zone. Although the project evaluated by the Adopted MND was inconsistent at the time with the existing General Plan Land Use and Zoning designation for the Project site, such inconsistencies are only deemed significant under CEQA if they result in significant, adverse physical effects to the environment. Therefore, because the approved Project was processing a General Plan Amendment and Change of Zone to modify the site’s underlying land use regulations to be consistent with those proposed by the Project and because implementation of the Project was found not to result in significant impacts to the environment, the Project’s inconsistency with the site’s existing underlying General Plan land use designations and Zoning classifications represented a less-than-significant impact for which no mitigation was required. The Project analyzed in the Adopted MND, otherwise was found not to conflict with any applicable goals, objectives, and policies of the City of Adelanto General Plan or the City of Adelanto Municipal Code. Additionally, with Mitigation Measure AQ-1 use of the property as a cannabis cultivation use was determined not to conflict with the Mojave Desert Air Quality Management District’s Air Quality Management Plan or the San Bernardino Regional Greenhouse Reduction Plan. Under existing conditions, the Project site is now zoned Light Manufacturing and is located in a zone that conditionally allows cannabis uses; the Project’s applications include a Conditional Use Permit for that purpose; therefore, the proposed Project is consistent with General Plan Land Use Plan. (City of Adelanto, 2019) Consistent with the Adopted MND, the proposed Project would be subject to all applicable regulatory requirements addressing air pollution, as well as Mitigation Measure AQ-1 included in the Adopted MND to reduce VOC air pollutant emissions. There are no components of the proposed Project that would result in a conflict with or that would obstruct implementation of the Mojave Desert Air Quality Management Zone (MDAQMD) attainment plans; therefore, impacts would be less than significant with implementation of Mitigation Measure AQ-1 from the Adopted MND. Based on the foregoing analysis, the Project would not result in any new impacts not already analyzed in the MND (SCH 2017031036), and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.



5.12 MINERAL RESOURCES

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project:

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?

☐ ☐ ☐ ☒

Would the Project 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?

Determination: No substantial change from previous analysis. No Impact. Impact Analysis:

As evaluated in the Adopted MND, according to the California Geological Survey mapping, the Project site is located in the MRZ-3 Mineral Resource Zone (MRZ), which is defined as “Areas containing mineral deposits the significance of which cannot be evaluated from available data.” No mineral extraction activities are currently taking place within the Project site and mineral resource extraction is not a permitted use in the Light Manufacturing (LM) zone. Consistent with the determination in the Adopted MND, the proposed Project would not 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. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project 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?


As evaluated in the Adopted MND, The City of Adelanto General Plan does not identify any locally important mineral resource recovery sites within the Project site. In addition, mineral resource extraction is not a permitted use in the Light Manufacturing (LM) zone. Consistent with the Adopted MND, the



Project would not 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. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.13 NOISE

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project result in:

a. Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan, noise ordinance, or applicable standards of other agencies?

☐ ☐ ☐ ☒

b. Generation of excessive groundborne vibration or groundborne noise levels?

☐ ☐ ☐ ☒

c. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?

☐ ☐ ☐ ☒

Would the Project result I the 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?


The Adopted MND analyzed development of the Project site for cannabis uses and concluded that implementing development projects that comply with General Plan Table VIII-2 “Land Use Compatibility Guidelines Related to Noise Exposure” and Adelanto Municipal Code Sections 17.90.020 (b) and (d) would result in less than significant impacts associated with noise generation. The proposed Project entails the same use type (cannabis cultivation and ancillary uses) with the same expected construction and



operational characteristics as the project described and evaluated in the Adopted MND. Although activities associated with development on the Project site could result in a temporary or periodic increase in ambient noise levels in the vicinity, the Project would be required to comply with the City’s General Plan policies and Municipal Code in regard to noise. Construction activities are required to comply with Municipal Code Sections 17.90.020 (d) which requires construction projects to list general noise reduction practices as “General Notes” on construction drawings. The Adopted MND specified that the notes should allow construction activity only between 7:00 a.m. and dusk on weekdays and prohibit construction (and its associated noise) on weekends and holidays unless otherwise approved by the City Building Official. Also, stationary construction equipment that generates noise over 65 dBA at the Project site boundaries is required to be shielded. The Project’s construction activities will be required to comply with these notes, yielding a less than significant construction-related noise impact. In regards to Project operation, the operation of a cannabis cultivation business is not a noise intensive use. As discussed in Threshold 5.17 under the topic of Transportation, the proposed Project is calculated to generate 1,055 fewer two-way trips per day with 57 fewer AM peak hour trips and 58 fewer PM peak hours trips compared to the analysis scenario presented in the Adopted MND for cannabis cultivating and associated manufacturing uses on the Project site. Therefore, consistent with the findings of the Adopted MND, with compliance with the City’s General Plan and the City’s Municipal Code, the proposed Project would not result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies, and impacts would be less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project generate excessive ground-borne vibration or ground-borne noise levels?


The Adopted MND analyzed development of the Project site for cannabis uses and concluded that implementing development projects that comply with Adelanto Municipal Code Sections17.90.020(a) would result in less than significant impacts associated with ground-borne vibration and noise. The proposed Project entails the same use type (cannabis cultivation and ancillary uses) with the same expected construction and operational characteristics as the project described and evaluated in the Adopted MND. Aside from potential minor vibration associated with the use of construction equipment during construction of the Project, the development and operation of a cannabis cultivation business is not expected to produce any noticeable ground-borne vibration or noise. Construction and operational activities are required to comply with Municipal Code Section 17.90.020(a) which prohibits activities that generate measurable vibration beyond property lines. Therefore, based on the foregoing analysis, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.



For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?


As determined by the Adopted MND, the Project site is not located in the vicinity of a private airstrip or within 65 dB CNEL noise contour for the Southern California Logistics Airport Comprehensive Airport Land Use Plan. Therefore, consistent with findings of the Adopted MND, the proposed Project would not be exposed to excessive noise from the Southern California Logistics Airport. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.14 POPULATION AND HOUSING

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the Project induce substantial unplanned population growth in an area, either directly

(for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure?


Would the project:

a. Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure?

☐ ☐ ☐ ☒

b. Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?

☐ ☐ ☐ ☒



The Project would be implemented in a manner consistent with the site’s existing General Plan and use designation and zoning classification. As such, the Project would not represent or facilitate an intensification of uses beyond that which is already planned by the City. Furthermore, the proposed Project does not propose any residential units and therefore would not either directly or indirectly induce substantial population growth in the area. Consistent with the Adopted MND, the Project proposes buildings intended to be used for medical cannabis cultivation and associated uses. This type of use is not labor intensive and would not create an additional need for housing thus increasing the overall population of the City. In addition, and consistent with the information presented in the Adopted MND, the Project site is located in close proximity to developed areas of the City and water and sewer service are available to serve land uses within the Project area, inclusive of the Project site, and roadways exist in the vicinity of the Project area. Therefore, the expansion or new construction of public facilities and utilities will be localized and not extend into distant undeveloped areas of the City. In addition, consistent with the Adopted MND and as evaluated in Threshold 5.15, Public Services, demonstrate that the impacts on public services would be less than significant thus the public service provider’s ability to provide services will not be reduced. Based on the foregoing analysis, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?


Consistent with the conditions that existed when the Adopted MND was prepared, the Project site consists of vacant, undeveloped land that does not contain residential housing. Therefore, consistent with the findings of the Adopted MND, the Project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. The Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.15 PUBLIC SERVICES

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities or the need for new or physically altered governmental facilities, the



New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

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?

Fire protection? ☐ ☐ ☐ ☒

Police Protection? ☐ ☐ ☐ ☒

Schools? ☐ ☐ ☐ ☒

Parks? ☐ ☐ ☐ ☒

Other public facilities? ☐ ☐ ☐ ☒

Would the Project result in substantial adverse physical impacts associated with the provision

of new or physically altered governmental 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 public services?


The previously Adopted MND analyzed development of the site with cannabis uses and evaluated a scenario of 87.37 acres of cannabis cultivation use in conjunction with up to 100,000 SF of manufacturing use. The proposed Project is consistent in use type with the Project evaluated in the Adopted MND, resulting in the same or similar demand for public services as assumed by the Adopted MND. Fire Protection: Fire protection services to the proposed Project would be provided by the San Bernardino County Fire Department, primarily Adelanto Station #322. Consistent with the Adopted MND, the proposed Project would be conditioned by the City to provide a minimum of fire safety and support fire suppression activities, including compliance with State and local fire codes, fire sprinklers, a fire hydrant system, paved access, and secondary access routes. As stated in the Adopted MND, the Project applicant would be required to pay a Fire Facilities Impact Fee. Consistent with the finding of the Adopted MND, impacts would be less than significant. The Project would not trigger the need to provide new or physically altered fire stations or other fire protection facilities. Therefore, the Project would not result in any new



impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. Police Protection: The San Bernardino County Sheriff’s Department provides community policing to the Project area via the Victor Valley Sheriff Station. Consistent with the Adopted MND, the Project applicant is required to implement a security plan in conjunction with the City and Sheriff’s Department. Consistent with the finding of the Adopted MND, impacts would be less than significant. The Project would not trigger the need to provide new or physically altered sheriff’s stations or other law enforcement facilities. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. Schools: Consistent with the Adopted MND, the proposed Project does not involve the construction of any residential dwelling units, and as such only would have an indirect potential to increase the demand for school services in the area. The Project is located within the Adelanto School District and as evaluated by the Adopted MND the Project applicant would be required to pay school impact fees to the Adelanto School District to offset the potential impacts of increased student enrollment. Pursuant to Senate Bill 50, payment of school impact fees constitutes complete mitigation for project-related impacts to school services. As such, the Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities. Consistent with the finding of the Adopted MND, impacts would be less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. Parks: Consistent with the Adopted MND, the proposed Project does not involve the construction of any park facilities or housing that would generate a demand for park facilities. Consistent with the finding of the Adopted MND, impacts would be less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. Other Public Facilities: Consistent with the Adopted MND, the Project involves development of cannabis cultivation and associated uses, which are not labor intensive and would not create a need for additional housing in the area or place an unplanned demand on other public facilities such as public health services and library services. Consistent with the finding of the Adopted MND, impacts would be less than significant. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.



5.16 RECREATION

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project:

a. 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?

☐ ☐ ☐ ☒

b. Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?

☐ ☐ ☐ ☒

Would the Project 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?

Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?


Refer to Threshold 5.15 above. Consistent with the finding of the Adopted MND, the Project would not create a demand for additional park facilities or require the construction of additional park or recreational facilities because it does not propose any new housing and is not a labor intensify use that would generate the need for new housing. Consistent with the Adopted MND, the Project would 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 and the Project would not include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical adverse physical effect on the environment. Impacts would be less than significant. Based on the foregoing analysis, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.



5.17 TRANSPORTATION

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the Project conflict with a program, plan, ordinance, or policy addressing the circulation

system, including transit, roadway, bicycle, and pedestrian facilities?


The previously Adopted MND analyzed development of the Project site with up to 87.37 acres of cannabis cultivation use in conjunction with up to 100,000 SF of manufacturing use. A Traffic Impact Analysis was prepared by Urban Crossroads to support the Adopted MND, for which traffic modeling was performed for the analytical assumptions of the Adopted MND (up to 87.37 acres of cannabis cultivation use in conjunction with up to 100,000 SF of manufacturing use.). To support this MND Addendum, Urban Crossroads conducted a Trip Generation Assessment to compare the number of vehicle trips previously calculated and reported in the Adopted MND against the vehicle trips that would be generated by the currently proposed Project. The Trip Generation Assessment is attached to this Addendum as Technical Appendix H. Table 5-12, 2017 Approved Project - Project Trip Generation Summary, summarizes the trip generation as evaluated in the 2017 Traffic Impact Study. As shown in Table 5-12, the Project evaluated by the Adopted MND, would have generated 2,061 two-way passenger car equivalent (PCE) trips per day, with 103 PCE

Would the project:

a. Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?

☐ ☐ ☐ ☒

b. Conflict with or be inconsistent with CEQA Guidelines §15064.3, subdivision (b)? ☐ ☐ ☐ ☒

c. Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g. farm equipment)?

☐ ☐ ☐ ☒

d. Result in inadequate emergency access? ☐ ☐ ☐ ☒



trips during the AM peak hour and 129 PCE trips during the PM peak hour. Trip generation for the approved land uses were based on information collected by the Institute of Transportation Engineers (ITE) as provided in their Trip Generation Manual (6th Edition, 2012), the ITE Trip Generation Manual that was current at the time of analysis by the Adopted MND. Excerpts from the 2017 Traffic Impact Analysis that show detailed trip generation are provided in Attachment A of the 2021 Trip Generation Assessment (Technical Appendix H). (Urban Crossroads, Inc., 2021b, p. 1)

Table 5-12 2017 Approved Project - Project Trip Generation Summary

(Urban Crossroads, Inc., 2021b, Table 1) The Project would be constructed in two phases. Phase 1 would include the six industrial tilt-up buildings having 718,200 SF, as well as 394,800 SF of greenhouses. Phase 2, to be constructed at a later date, would consist of an additional 394,800 SF of greenhouse structures. The greenhouse portion of the Project is not expected to generate any measurable traffic. For purposes of the Project’s Trip Generation Assessment, the 718,000 SF of industrial tilt up buildings was determined to have operational characteristics that fit within the scope of the ITE Trip Generation Manual’s description of High-Cube Transload and Short-Term Storage Warehouse use (ITE Code 154). The ITE Trip Generation Manual (10th Edition, 2017) is the most current ITE Trip Generation Manual at this time. (Urban Crossroads, Inc., 2021b, p. 2). The Project is calculated to generate 1,006 daily rips, with 59 trips occurring in the AM peak hour and 72 trips occurring in the PM peak hour.

Table 5-13 Proposed Project – Trip Generation Summary

(Urban Crossroads, Inc., 2021b, Table 3) As shown in Table 5-14, Trip Generation Comparison, the proposed Project is anticipated to generate a total of 1,055 fewer two-way trips per day with 57 fewer AM peak hour trips and 58 fewer PM peak hours trips compared to the number of trips assumed by the Adopted MND. The San Bernardino County’s traffic



guidelines identify that if a project demonstrates a trip generation of fewer than 100 vehicle trips during the AM and PM hours (based on the latest ITE Trip Generation Manual, then a project may be exempt from conducting a level of service (LOS)-based traffic analysis. Therefore, a LOS-based traffic analysis is not required for the proposed Project. (Urban Crossroads, Inc., 2021b, p. 3)

Table 5-14 Trip Generation Comparison

(Urban Crossroads, Inc., 2021b, Table 4)

Because the proposed Project would generate fewer trips as compared to the trips that would have been generated by the Project proposed in the Adopted MND, the proposed Project would result in reduced impacts to study area transportation facilities as compared to the Project evaluated by the Adopted MND. Consistent with the findings of the Adopted MND, the proposed Project would be subject to General Plan policies, the City’s Municipal Code, and Mitigation Measure TR-1 included in the Adopted MND, which requires the Project Applicant to pay City Development Impact Fees (DIF) and/or fair share fees for the funding of road improvements. As concluded by the Adopted MND, the Project does not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities. No transit, bicycle, or pedestrian facilities are located adjacent to the Project site. Based on the foregoing analysis, the Project would not result in any new impacts not already analyzed in the Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project conflict with or be inconsistent with CEQA Guidelines §15064.3, subdivision (b)?

Determination: No substantial change from previous analysis. Not applicable. Impact Analysis:

CEQA Guidelines Section 15064.3(b) includes specific considerations for evaluating a project’s transportation impacts using a Vehicle Miles Travelled (VMT) measure, instead of evaluating impacts based on Level of Service (LOS) criteria, as required by California Senate Bill (SB) 743. LOS has been used as the basis for determining the significance of traffic impacts as standard practice in CEQA documents for decades, including at the time the Adopted MND was adopted in June 2017. In 2013, SB 743 was passed, which is intended to balance the need for LOS for traffic planning with the need to build infill housing and mixed-use commercial developments within walking distance of mass transit facilities, downtowns, and town centers, and to provide greater flexibility to local governments to balance these sometimes-competing needs. In January 2019, the Natural Resources Agency finalized updates to the CEQA Guidelines including the incorporation of the SB 743 modifications. The Guidelines changes were



approved by the Office of Administrative Law and are now in effect. As such, as of July 1, 2020, LOS can no longer be the basis for determining an environmental effect under CEQA, and the analysis of impacts to transportation is now based on VMT. CEQA Guidelines Section 15064.3(c) is clear that “[t]he provisions of [§ 15064.3] shall apply prospectively as described in [CEQA Guidelines] section 15007.” CEQA Guidelines Section 15007(c) specifically states: “[i]f a document meets the content requirements in effect when the document is sent out for public review, the document shall not need to be revised to conform to any new content requirements in Guideline amendments taking effect before the document is finally approved.” As noted above, the Guidelines changes with respect to VMT took effect on July 1, 2020, while the Adopted MND was adopted in June 2017. As such, and in accordance with CEQA Guidelines Sections 15064.3(c) and 15007(c), revisions to the Adopted MND are not required under CEQA in order to conform to the new requirements established by CEQA Guidelines Section 15064.3. Once a project is approved, CEQA does not require that it be analyzed anew every time another discretionary action is required to implement the project. Quite the opposite, where an EIR or MND has previously been prepared for a project, CEQA expressly prohibits agencies from requiring a subsequent or supplemental EIR or MND, except in specified circumstances. (Pub. Res. Code § 21166.) Under CEQA, “Section 21166 comes into play precisely because in-depth review has already occurred, the time for challenging the sufficiency of the original EIR has long since expired, and the question is whether circumstances have changed enough to justify repeating a substantial portion of the process.” (Citizens Against Airport Pollution v. City of San Jose (“CAAP”) (2014), 227 Cal.App.4th at 796.) Also, because at the time the Adopted MND was adopted, there was no CEQA requirement to analyze VMT and thus there is no need to analyze VMT impacts in connection with this Addendum. Furthermore, the new VMT requirements set forth by CEQA Guidelines § 15064.3 do not relate to a different type of impact, but merely a different way of analyzing transportation impacts. VMT associated with buildout of the proposed Project do not comprise “new information” that was not known or could not have been known at the time the Adopted MND was adopted. Because VMT impacts were known or should have been known, the adoption of the requirement to analyze VMT therefore does not constitute significant new information requiring preparation of a subsequent or supplemental EIR. Concerned Dublin Citizens v. City of Dublin (2013) 214 Cal.App.4th 1301, 1320. In the case of the proposed Project, there are no changed circumstances that would warrant additional analysis under Public Resources Code § 21166. Even if an analysis were conducted utilizing the assumptions and methodologies for VMT, the results of such an analysis would show that the Project-related total VMTs are less than was assumed by the Adopted MND, based on the reduction in traffic associated with the proposed Project as compared to what was evaluated for the Project site the Adopted MND. As discussed above, according to the CEQA Guidelines, revisions to the Adopted MND are not required under CEQA in order to conform to the new requirements established by CEQA Guidelines § 15064.3. As indicated in Table 5-14, the proposed Project is anticipated to generate a total of 1,055 fewer two-way



trips per day with 57 fewer AM peak hour trips and 58 fewer PM peak hours trips compared to the amount of traffic assumed in the Adopted MND. Therefore, there is substantial evidence that the Project as proposed would result in reduced VMT as compared to the development scenario evaluated by the Adopted MND. Therefore, and based on the foregoing analysis, the Project would not result in any new impacts not already analyzed in the Adopted MND and the Project would not increase the severity of a significant impact as previously identified and analyzed in the G the Adopted MND.

Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?


Consistent with the Project evaluated in the Adopted MND, the Project would not result in or require major improvements to circulation facilities within the City, and the geometrics of the Project’s proposed access driveways are consistent with applicable City requirements. Additionally, the Project occurs in an area that is planned for long-term development with industrial uses, and the uses proposed as part of the Project would not represent an incompatible use. Consistent with the Adopted MND, compliance with Section 13.20.010 of the Municipal Code will ensure future development will not substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses. Accordingly, the Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment), and no impact would occur. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project result in inadequate emergency access?


Consistent with the Adopted MND, required compliance with City Municipal Code Section 13.20.020 would ensure that development of the proposed Project would not result in inadequate emergency access. The Project complies with Code Section 13.20.020 by including roadway improvements that assure emergency access to and from the site. Based on the foregoing analysis, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.



5.18 TRIBAL CULTURAL RESOURCES

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is:

a. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? or

☐ ☐ ☐ ☐

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).

☐ ☐ ☐ ☐

Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is:

Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or

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).




Thresholds 5.18 (a) and (b) above, were added to Appendix G of the CEQA Guidelines in 2018 after the Adopted MND was adopted in 2017. Although tribal consultation requirements did not apply (and also do not apply to MND Addendums), the Adopted MND discussed tribal cultural resources under the topic of Cultural Resources. The Adopted MND analyzed development of the Project site for cannabis uses and concluded that according to General Plan policies, implementing development projects would need to be assessed for impacts to cultural (including tribal cultural) resources during the City’s land development review process, and with proper assessment and treatment of any identified resources, impacts would be less than significant. The Project applicant has demonstrated compliance with the related General Plan policies. According to RCA Associates, they had previously conducted a comprehensive cultural study of the Project site and summarized the results in a report. As stated by RCA Associates, no cultural resources were identified on the site and they did not recommend mitigation or additional surveys. To support this EIR Addendum, RCA conducted reconnaissance level analysis of the Project site on February 22, 2021 to evaluate the current conditions. According to RCA’s letter to the Project Applicant, no cultural resources were identified during the February 22, 2021 field investigation and no additional analysis is deemed necessary by RCA. See Technical Appendix C attached to this Addendum, for RCA’s letter to the Project Applicant documenting the existing cultural resource conditions of the site on February 23, 2021. (RCA Associates, Inc., 2021a) As such, no impacts to known resources would occur and the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. As required by the Adopted MND, the Project applicant is required to comply with Mitigation Measure CR-1 in the event that a resource is discovered during ground-disturbing construction activities. The mitigation measure requires that San Manuel Bank of Mission Indians and other consulting tribes participate in the development of treatment and data recovery plan development in the unlikely event that an archaeological or tribal cultural resource is unearthed during the Project’s construction process. 5.19 UTILITIES AND SERVICE SYSTEMS

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project:

a. Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?

☐ ☐ ☐ ☒



New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

b. Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?

☐ ☐ ☐ ☒

c. Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

☐ ☐ ☐ ☒

d. Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?

☐ ☐ ☐ ☒

e. Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?

☐ ☐ ☐ ☒

Would the Project require or result in the relocation or construction of new or expanded water,

wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?


The proposed Project is consistent with the project described in the Adopted MND in terms of utility provision and demand. Specifically, there would be no major changes in the Project’s proposed utility connections beyond what was expected by the development scenario evaluated in the Adopted MND, and therefore, would not create a new, additional, or increased demand for the provision of utilities beyond what was determined by the Adopted MND. Therefore, the proposed Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?




The Adopted MND disclosed that cannabis development on the Project would be served with potable water by the Adelanto Public Utility Authority. At the time the Adopted MND was prepared, development of cannabis uses on the site was evaluated in context with the City of Adelanto’s 2015 Urban Water Management Plan. As stated in the Plan, the City’s water supply comes from groundwater production drawn by 15 potable wells in three pressure zones. The Adopted MND stated that during the Location and Development Plan and Conditional Use Permit process for implementing projects, the City will require all cultivators to use the most efficient form of watering plants (hydroponics) with a recirculating system that filters and reuses the filtered water. Refer to the Project’s application materials herein incorporated by reference. A “Will-serve” letter dated February 22, 2021 from the City of Adelanto indicated that domestic water service would be available to serve the Project. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?


The Adopted MND disclosed that Wastewater from Adelanto’s water service area is collected and treated at the City-owned 4.0 MGD activated sludge wastewater treatment facility through an operations and maintenance contract with the PERC Water Corporation. The Adopted MND concluded that based on the 4.0 MGD capacity of the wastewater treatment plant, it is anticipated that capacity will be available to serve future projects including development of the Project site with cannabis uses. The proposed Project is consistent with the cannabis use type evaluated in the Adopted MND. A “Will-serve” letter dated February 22, 2021 from the City of Adelanto indicated that sewer service would be available to serve the Project Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?




The Adopted MND disclosed that cannabis development on the Project site would be served by the County of San Bernardino Victorville Landfill which has a permitted disposal capacity of 3,000 tons per day. The Victorville Landfill is estimated to reach capacity, at the earliest time, in 2047. The Adopted MND concluded that the landfill capacity will exist to serve future development. The proposed Project is consistent with the cannabis use type evaluated in the Adopted MND including its solid waste disposal generation characteristics. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.

Would the Project Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?


The Adopted MND informed that the Project applicant would be required to coordinate with the waste hauler to ensure the collection of recyclable materials as required by applicable regulatory requirements. With mandatory compliance, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.20 WILDFIRE

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

If located in or near a state responsibility area or lands classified as very high fire hazard severity zone, would the project:

a. Substantially impair an adopted emergency response plan or emergency evacuation plan? ☐ ☐ ☐ ☒

b. Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?

☐ ☐ ☐ ☒

c. Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may

☐ ☐ ☐ ☒



New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

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?

☐ ☐ ☐ ☒

If located in or near a state responsibility area or lands classified as very high fire hazard severity zone, would the project [see a., b.; c.; and d in above checklist). Determination: No substantial change from previous analysis. Less than significant impact. Impact Analysis:

As determined by the Adopted MND, the project site is located within a “moderate” wildfire hazard area; therefore, additional analysis associated with this Threshold 5.20 is not required. Consistent with the findings of the Adopted MND, the proposed Project’s applications for permits involving medical cannabis cultivation or manufacturing facilities are required to comply with City Municipal Code Chapter 14.20 which adopts the most current edition of the California Fire Code making all provisions of it applicable in the City of Adelanto. Applicable provisions of the Fire Code implemented into the Project’s design will reduce the risk of loss, injury, or death involving wildland fires to a level less than significant. Therefore, no significant adverse impacts are identified or anticipated and no mitigation measures are required. Based on the foregoing analysis, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. 5.21 MANDATORY FINDINGS OF SIGNIFICANCE

New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

Would the project:

a. Does the project have the potential to substantially degrade the quality of the environment, ☐ ☐ ☐ ☒



New Significant

Impact

More Severe Impacts

New Ability to


Significant Impact

No Substantial

Change from

Previous Analysis

substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?

b. Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?

☐ ☐ ☐ ☒

c. Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?

☐ ☐ ☐ ☒

a) Does the project have the potential to substantially degrade the quality of the environment,

substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?

Determination: No substantial change from previous analysis. Less than significant with mitigation incorporated. Impact Analysis:

As evaluated in Threshold 5.4 and Threshold 5.5, above, the Project site has been graded and no sensitive biological resources or known cultural resources existing. Mitigation Measure CUL-1 is included to address the unlikely but potential discovery of cultural resources that may be unearthed during the Project’s construction process. No circumstances would result in different impacts or greater impacts than disclosed by the Adopted MND. The Project would not result in less new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND



b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?

Determination: No substantial change from previous analysis. Less than significant impact with mitigation incorporated. Impact Analysis

As evaluated throughout this Section 5.0, Environmental Analysis, consistent with the development scenario evaluated in the Adopted MND, with implementation of Mitigation Measures AQ-1, CR-1, and TR-1, all potentially significant impacts would be reduced to less than significant levels and the Project would not contribute to environmental effects that are individually limited, but cumulatively considerable. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND. c) Does the project have environmental effects which will cause substantial adverse effects on

human beings, either directly or indirectly? Determination: No substantial change from previous analysis. Less than significant impact with mitigation incorporated. Impact Analysis:

As evaluated throughout this Section 5.0, Environmental Analysis, consistent with the development scenario evaluated in the Adopted MND with implementation of Mitigation Measures, AQ-1, CR-1, and TR-1 impacts would be reduced to less than significant levels and the Project would result in environmental effects that will cause substantial adverse effects on human beings, either directly or indirectly. Therefore, the Project would not result in any new impacts not already analyzed in the Adopted MND, and the Project would not increase the severity of a significant impact as previously identified and analyzed in the Adopted MND.


Page 5-1

6.0 References

Documents Appended to this MND Addendum The following reports, studies, and supporting documentation were used in preparing this MND and are bound separately as Technical Appendices. A copy of the Technical Appendices is available for review at the City of Adelanto Planning Division, City of Adelanto City Hall 11600 Air Expressway, Adelanto, CA 92301. Cited As: Source:

(City of Adelanto, 2017a)

City of Adelanto, 2017. Initial Study/Mitigated Negative Declaration, City of Adelanto Application No. General Plan Amendment No. 17-02 and Zone Change No. 17-02. March 6, 2017. Attached to this Addendum as Technical Appendix A.

(Urban Crossroads. Inc., 2021a)

Urban Crossroads, Inc., 2021a. Air Quality, Greenhouse Gas, and Energy Assessment. March 9, 2021. Attached to this Addendum as Technical Appendix B.

(RCA Associates, Inc., 2021a)

RCA Associates, Inc., 2021a. 80-acre Parcel; APN 0459-421-25; Adelanto, California RCA#2016-99 Biological Resources and Joshua Trees. February 23, 2021. Attached to this Addendum as Technical Appendix C.

(RCA Associates, Inc., 2021b)

RCA Associates, Inc., 2021b. 80-acre Parcel; APN 0459-421-25; Adelanto, California RCA#2016-99 Cultural Analysis. February 23, 2021. Attached to this Addendum as Technical Appendix D.

(GeoTek, 2018) GeoTek, 2018. Geotechnical and Infiltration Evaluation. March 13, 2018.

Attached to this Addendum as Technical Appendix E. (RCA, 2016) RCA Associates, Inc. 2016., General Biological Resource Assessment;

Adelanto, CA; APN 0459-421-25; Adelanto, California. December 28, 2016.

(RCA Associates, Inc., 2021c)

RCA Associates, Inc. 2021c., 80-acre parcel; Phase 1 Environmental Site Assessment; APN 0459-421-25; Adelanto, California RCA#2016-99 Phase 1 Study. February 23, 2021. Attached to this Addendum as Technical Appendix F.

(UEG, 2021) United Engineering Group, 2021a. Preliminary Drainage Report for

Frontier 80-acre Industrial LDP #TBD Adelanto, CA. March 11, 2021. Attached to this Addendum as Technical Appendix F.


Page 5-2

Documents Appended to this MND Addendum The following reports, studies, and supporting documentation were used in preparing this MND and are bound separately as Technical Appendices. A copy of the Technical Appendices is available for review at the City of Adelanto Planning Division, City of Adelanto City Hall 11600 Air Expressway, Adelanto, CA 92301. Cited As: Source:

(Urban Crossroads, Inc., 2021b)

Urban Crossroads, Inc., 2021b. Adelanto 80 Acres Trip Generation Assessment. February 23, 2021. Attached to this Addendum as Technical Appendix H.


City of Adelanto, 2021. “Will-Serve Letter for Sewage and Potable Water Service-Frontier Communities 80 Acres” APN 0459-421-25. February 22, 2021. Attached to this Addendum as Technical Appendix I.

Documents Incorporated by Reference in this MND Addendum

Cited As: Source:


City of Adelanto, 2017a. Initial Study Checklist/Mitigated Negative Declaration. City of Adelanto Application No. General Plan Amendment No. 17-02 and Zone Change No. 17-02. March 6, 2017. Also attached to this Addendum as Technical Appendix A.

(City of Adelanto, 2017b)

City of Adelanto, 2017b. Agenda. Regular Meeting of the Adelanto City Council. June 14, 2017.


City of Adelanto, 1995. Final Environmental Impact Report. City of Adelanto General Plan Update (SCH 94082081). May 1995.

Documents and Websites Consulted in Preparation of this MND Cited As: Source:


City of Adelanto, 2014. Adelanto North 2035 Comprehensive Sustainable Plan. August 27, 2014. Available online: https://www.ci.adelanto.ca.us/DocumentCenter/View/623/Adelanto-North-2035-Sustainable-Plan


City of Adelanto, 2019. Zoning Matrix. Available online: https://www.ci.adelanto.ca.us/DocumentCenter/View/794/Zoning-Matrix-2018

https://www.ci.adelanto.ca.us/DocumentCenter/View/623/Adelanto-North-2035-Sustainable-Plan

https://www.ci.adelanto.ca.us/DocumentCenter/View/623/Adelanto-North-2035-Sustainable-Plan

https://www.ci.adelanto.ca.us/DocumentCenter/View/794/Zoning-Matrix-2018


Page 5-3


City of Adelanto, 2019a. California Environmental Quality Act (CEQA) Process Policy Memorandum 2019-01. Effective November 15, 2019. Accessed: August 14, 2020. Available online: https://www.ci.adelanto.ca.us/DocumentCenter/View/1155/CEQA-Process-Policy-2019-01


City of Adelanto, 2020a. General Plan Amendments/Zone Changes. Accessed: September 24. 2020. Available online: https://www.ci.adelanto.ca.us/DocumentCenter/View/550/General-Plan-Amendments-Zone-Chang

(City of Adelanto, 2020b)

City of Adelanto, 2020b. Municipal Code. Available online: https://codelibrary.amlegal.com/codes/adelanto/latest/adelanto_ca/0-0-0-20747

https://www.ci.adelanto.ca.us/DocumentCenter/View/1155/CEQA-Process-Policy-2019-01

https://www.ci.adelanto.ca.us/DocumentCenter/View/1155/CEQA-Process-Policy-2019-01

https://www.ci.adelanto.ca.us/DocumentCenter/View/550/General-Plan-Amendments-Zone-Chang

https://www.ci.adelanto.ca.us/DocumentCenter/View/550/General-Plan-Amendments-Zone-Chang

https://codelibrary.amlegal.com/codes/adelanto/latest/adelanto_ca/0-0-0-20747