| RIVERSIDE COUNTY INTEGRATED PROJECT |  |
| GENERAL PLAN FINAL PROGRAM ENVIRONMENTAL IMPACT REPORT VOLUME II | |
| RESPONSE TO COMMENTS ADDENDUM TO DRAFT EIR MITIGATION MONITORING PROGRAM | |
| RIVERSIDE COUNTY, CALIFORNIA | |
| Comprehensive General Plan Amendment No. 618 (GPA00618) Environmental Assessment (EA) No. 38614 Environmental Impact Report (EIR) No. 441 State Clearinghouse No. 2002051143 Prepared By: County of Riverside Transportation and Land Management Agency Planning Department 4080 Lemon Street, 9th Floor Riverside, California 92502 (909) 955-3200 With Technical Assistance From: LSA Associates, Inc. 1650 Spruce Street, Suite 500 Riverside, California 92507 (909) 781-9310 TransCore (Traffic) 300 South Harbor Boulevard, Suite 516 Anaheim, California 92805 (714) 758-0019 | |
| The County of Riverside has independently reviewed, analyzed, and exercised its judgement in the analysis contained in this Environmental Impact Report and supporting documentation pursuant to Section 21082 of the California Environmental Quality Act (CEQA) | |
TABLE OF CONTENTS
Section 1.0 - Summary of the Final Environmental Impact Report
1.3 Comments on the Draft EIR and Responses
1.4 List of Persons, Organizations, and Public Agencies Commenting on the Draft EIR
1.4.7 Citizens and Organizations
Section 2.0 - Responses to Comments
A United States Forest Service
B United States Marine Corps, Yuma
C United States Army Corps of Engineers
D United States Bureau of Land Management
E Office of Planning and Research
F Department of Parks and Recreation
G Caltrans Division of Aeronautics
I California Department of Fish and Game
J Regional Water Quality Control Board, Santa Ana Region
K Regional Water Quality Control Board, San Diego Region
L San Bernardino County Land Use Services Department
M Orange County Planning and Development Services
V Morongo Band of Mission Indians
W Agua Caliente Band of Cahuilla Indians
X Palo Verde Irrigation District
Y Rancho California Water District
Z Southern California Association of Governments
AA Old Rancher's Canning Company
DD Jack Stuckeman and Dorothy Stuckeman
MM Conservation Biology Institute
NN Property Owner's Association of Riverside County
OO Riverside County Farm Bureau
PP Sierra Club (San Gorgonio Chapter)
QQ Building Industry Association of Southern California
RR Jackson DeMarco Peckenpaugh (representing Domenigoni Family Trust)
SS Jackson DeMarco Peckenpaugh (representing David H. Murdock)
UU Metropolitan Water District of Southern California
Section 4.0 - Mitigation Monitoring Program
List of Tables
4.A Mitigation Monitoring Program for the Proposed Riverside County General Plan
SECTION 1.0 - SUMMARY OF THE FINAL ENVIRONMENTAL IMPACT REPORT
1.1 Introduction
The Final Environmental Impact Report (EIR) for the County of Riverside General Plan (State of California Clearinghouse No. 2002051143) has been prepared in accordance with the California Environmental Quality Act (CEQA) and the guidelines for the implementation of CEQA. The Final EIR consists of the following contents:
• A list of persons, organizations, and public agencies commenting on the Draft EIR (Section 1.4);
• The responses of the Lead Agency to significant environmental points raised in the public review and consultation process (Section 2.0);
• Revisions made to the Draft EIR (August 20, 2002), State of California Clearinghouse No. 2002051143, in the form of an addendum presented in Section 3.0; and
• The Mitigation Monitoring Plan (MMP) (Section 4.0).
1.2 Public Review Period
The public review period for the Draft EIR began on August 20, 2002, and ended on October 4, 2002, covering the CEQA-mandated 45-day public review period. A Notice of Completion of a Draft EIR was filed with the State Clearinghouse along with the required number of copies of the document for circulation to various State agencies. Copies of the Draft EIR were also mailed directly to local agencies, groups, and individuals for review (refer to Appendix A for the mailing list). In addition, a copy of the document was made available to the public at the following libraries and County offices:
| County Administrative Center (Riverside) 4080 Lemon Street Public Counter, 2nd Floor Planning Department, 9th Floor Riverside, California 92502 Hours of Operation: 8:00 a.m. to 5:00 p.m. Monday through Friday | County Administrative Center (Indio) 82-675 Highway 111, Room 209 Indio, California 92201 Hours of Operation: 8:00 a.m. to 5:00 p.m. Monday through Friday |
| Riverside County Permit Assistance Center (Murrieta) 39493 Los Alamos Road Murrieta, California 92563 Hours of Operation: 8:00 a.m. to 5:00 p.m. Monday through Friday |
| Libraries in Riverside County | |
|---|---|
| Anza Public Library Anza 57430 Mitchell Road Anza, California 92539 | Beaumont Library District Beaumont 125 East 8th Street Beaumont, California 92223 |
| Palo Verde Valley District Library Blythe 125 West Chanslorway Blythe, California 92225 | Corona Public Library Corona 650 South Main Street Corona, California 92882-3417 |
| Riverside County Public Library Desert Hot Springs 11691 West Drive Desert Hot Springs, California 92240 | Riverside County Public Library Glen Avon 9244 Galena Riverside, California 92509 |
| Riverside County Public Library Idyllwild 54185 Pinecrest Idyllwild, California 92549 | Riverside County Public Library Indio 200 Civic Center Mall Indio, California 92201 |
| Riverside County Public Library Lake Tamarisk 43880 Lake Tamarisk Desert Center, California 92239 | Riverside County Public Library Mecca 65-250 A Coahuilla Mecca, California 92254 |
| Riverside County Public Library Mission Trail 34303 Mission Trail Wildomar, California 92595 | Riverside County Public Library Moreno Valley 25480 Alessandro Moreno Valley, California 92553 |
| Riverside County Public Library Nuview 29990 Lakeview Nuevo, California 92567 | Riverside County Public Library Perris 163 East San Jacinto Perris, California 92570 |
| Riverside County Public Library Riverside Main Library 3581 Mission Inn Ave Riverside, California 92501 | Riverside County Public Library San Jacinto 500 Idyllwild Dr. San Jacinto, California 92583 |
| Riverside County Public Library Sun City 26982 Cherry Hills Boulevard Sun City, California 92586 | Riverside County Public Library Temecula 41000 County Center Temecula, California 92591 |
| Riverside County Public Library Thousand Palms 72-715 La Canada Way Thousand Palms, California 92276 | Riverside County Public Library Woodcrest 17024 Van Buren Boulevard Riverside, California 92504 |
1.3 Comments on the Draft EIR and Responses
Section 2.0 of the Final EIR contains the comments to the Draft EIR and responses to those comments. The primary objective and purpose of the EIR public review process is to obtain comments on the adequacy of the analysis of the environmental impacts, the mitigation measures presented, and other analyses contained in the report. CEQA requires the County to respond to all significant environmental comments in a level of detail commensurate to the comment (CEQA Guidelines, Section 15088). Comments that do not directly relate to the analysis in this document (i.e., are outside the scope of this document) are not given specific responses. However, all comments are included in this section so that the decision-makers know the opinions of the commentors.
1.4 List of Persons, Organizations, and Public Agencies Commenting on the Draft EIR
The persons, organizations, and public agencies that submitted comments on the Draft EIR through September 30, 2002, are listed below. A total of 67 written comment letters was received on the Draft EIR. Twenty-four of the comment letters were from public agencies, while 23 of the comment letters were from the public (including organizations and Indian Tribes). For reference, each letter was assigned a code (A - Z and AA - TT). These codes are included below, and represent the order of letters in Section 2.0.
1.4.1 Federal Agencies
A United States Forest Service
B United States Marine Corps, Yuma
C United States Army Corps of Engineers
D United States Bureau of Land Management
1.4.2 State Agencies
E Office of Planning and Research
F Department of Parks and Recreation
G Caltrans Division of Aeronautics
H Caltrans District 11
I California Department of Fish and Game
J Regional Water Quality Control Board, Santa Ana Region
K Regional Water Quality Control Board, San Diego Region
1.4.3 Local Agencies
L San Bernardino County Land Use Services Department
M Orange County Planning and Development Services
N City of Anaheim
O City of Ontario
P City of Chino Hills
Q City of Riverside
R City of Palm Desert
S City of Temecula
T City of Moreno Valley
U City of Corona
1.4.4 Indian Tribes
V Morongo Band of Mission Indians
W Agua Caliente Band of Cahuilla Indians
1.4.5 Districts
X Palo Verde Irrigation District
Y Rancho California Water District
1.4.6 Regional Agencies
Z Southern California Association of Governments
1.4.7 Citizens and Organizations
AA Old Rancher's Canning Company
BB JBJ Ranch (Frank Johnson)
CC Wintec
DD Jack Stuckeman and Dorothy Stuckeman
EE Michael McKibben
FF Reed McManus
GG Bill Graber
HH Patricia Hewitt
II Tina Tyler
JJ Lloyd Cliff
KK Sierra Club (San Gorgonio Chapter), San Bernardino Valley Audubon Society, and Friends of the Northern San Jacinto Valley
1.4.8 Late Comments Received
UU Metropolitan Water District of Southern California
LL Endangered Habitats League
MM Conservation Biology Institute
NN Property Owner's Association of Riverside County
OO Riverside County Farm Bureau
PP Sierra Club (San Gorgonio Chapter)
QQ Building Industry Association of Southern California
RR Jackson DeMarco Peckenpaugh (representing Domenigoni Family Trust)
SS Jackson DeMarco Peckenpaugh (representing David H. Murdock)
TT Albert A. Web Associates
SECTION 2.0 - RESPONSES TO COMMENTS
The comments on the County of Riverside General Plan Draft Program EIR (State Clearinghouse No. 2002051143) and individual responses to each comment are a part of this Final Environmental Impact Report. The primary objective and purpose of the EIR public review process is to obtain comments on the adequacy of the analysis of environmental impacts, the mitigation measures presented, and other analyses contained in the report. The California Environmental Quality Act (CEQA) requires that the County of Riverside respond to all significant environmental comments in a level of detail commensurate to the comment (CEQA Guidelines Section 15088). Comments that do not directly relate to the analysis in this document (i.e., are outside of the scope of this document) are not given specific responses. However, all comments are included in this section so that the decision-makers may know the opinions of the commentors.
The County of Riverside, as the Lead Agency, is obligated to respond to comments on the Draft EIR. According to CEQA Guidelines Section 15088 (a), the Lead Agency shall evaluate comments on environmental issues received from persons who reviewed the Draft EIR and shall prepare a written response. The response to comments may take the form of changes directly to the Draft EIR or a separate section in the Final EIR. If the response results in important changes to the information contained in the Draft EIR, the Lead Agency should:
• Revise the text directly in the EIR, or
• Include margin notes indicating that the revised information is contained in the response to comments.
This section, which discusses the text changes that have been made to the Draft EIR and responses to comments that have been received on the Draft EIR, is included as a part of the Final EIR. The Draft EIR has not been substantially revised in response to any written comments received. However, minor additions and clarifications have been made at several locations in the text. The information contained in these minor text additions and clarifications was determined by the County of Riverside not to be "significant new information," as it does not substantially change the project description, the impact analyses, or the proposed mitigation measures. Added text is shown as double underline (double underline) and the deleted text is shown as strikeout (strikeout).
Aside from issues not related to the environmental effect of the project - the courtesy statements, introductions, and closings - the text of each comment document has been divided into individual comments. Brackets and identification numbers in the right margin of each comment letter delineate each comment. A number that corresponds to the comment identified on the original comment document precedes each response.
Response to Letter A: U.S. Department of Agriculture, Cleveland National Forest
A-1 This comment does not raise any substantive issues regarding the adequacy of the Draft EIR, and recognizes Riverside County's efforts to incorporate habitat conservation planning as part of its General Plan update process. Identification of the "More Intense Community Centers Alternative" as the "environmentally superior alternative" in the Draft EIR represents a conclusion regarding relative levels of environmental impacts among the alternatives evaluated in the Draft EIR, and is not a conclusion as to which alternative may be "best" in terms of the other considerations. These include, but are not limited to, economic development potential, fiscal implications for the County, market acceptance, or overall feasibility. Under CEQA, identification of an "environmentally superior alternative" is intended to assist the Lead Agency in making a decision regarding the proposed project, but does not commit the Lead Agency to adopt the "environmentally superior alternative" in lieu of the proposed project or other alternatives.
A-2 Tenaja Trail is designated as a Mountain Arterial in the current County General Plan. Accordingly, it has been included as part of the circulation system in the proposed General Plan. At both ends of the roadway, it is currently traversable. The Mountain Arterial designation of the roadway will be deleted from the General Plan.
A-3 The Forest Service will be contacted and asked to become involved in the planning process for a bi-county transportation corridor, between Riverside and Orange Counties, that would bisect the National Forest. Discussions between the Forest Service and the County have been ongoing, and it is anticipated that the new Forest Plan will include the corridor. The County recognizes the need for continued discussion and collaboration with the Forest Service.
A-4 It is understood that any specific proposal to create a transportation corridor crossing the Cleveland National Forest will require full analysis under the National Environmental Policy Act (NEPA).
A-5 The County will consider the management objectives of the Forest Service Plan in its future discussions regarding transportation corridors between Riverside and Orange Counties.
A-6 This Commentor provides names of contact persons for the National Forest and does not raise any substantive issues regarding the adequacy of the Draft EIR. See response A-3. Further response is unnecessary.
Response to Letter B: U.S. Marine Corps
B-1 The Commentor is stating that lands adjacent to the Chocolate Mountain Aerial Gunnery Range should remain rural, agricultural, or open space in use. As shown in Figure LU-1 in the General Plan the area in Riverside County adjacent to the gunnery range has been designated open space/conservation. This comment in regard to land use designations is related to the Draft Riverside County General Plan and not to the Draft EIR. The comment will be forwarded to the County decision-makers in their consideration of the General Plan. Further response is unnecessary.
B-2 This comment is referring to land use designations within the Coachella Valley. This comment is related to the Draft General Plan and not the Draft EIR. The comment will be forwarded to the County decision-makers in their consideration of the General Plan. Further response is unnecessary.
Response to Letter C: U.S. Army Corps of Engineers
C-1 The comment letter identifies the County's "intent" in undertaking the Riverside County Integrated Project (RCIP) as being the simultaneous adoption of the General Plan update, Western Riverside County Multi-Species Habitat Conservation Plan (MSHCP), and the Community Environmental and Transportation Acceptability Program (CETAP). This is an incorrect characterization of the RCIP effort. From its inception, the three components of RCIP were designed to use a common data base, and to have coordinated policy direction; however, there was never an intent to adopt the General Plan, MSHCP, and CETAP simultaneously. As noted in the Draft EIR, adoption of the General Plan is the sole responsibility of the County of Riverside, while adoption of the MSHCP also requires approval of 14 cities within the western portion of the County, the California Department of Fish and Game, and US Fish and Wildlife Service. Adoption of CETAP is the responsibility of the Riverside County Transportation Commission (RCTC) and the Federal Highway Administration.
While they are coordinated, the update of the County's General Plan, Western Riverside County MSHCP, and CETAP have independent utility, and could be adopted regardless of actions taken in relation to the other projects.
C-2 Any development application considered by the County that would affect "waters" under the jurisdiction of the Corps would be subject to permitting by the Corps under its rules and regulations. The changed pattern of allowable land use in the update of the County's General Plan is intended in part to reduce the impact of growth on natural resources, including "waters of the U.S." No further response is necessary. Refer to the following proposed General Plan policies, which reduce growth impacts to "waters" : OS 5.1, OS 5.2, OS 5.3, OS 5.5, OS 5.6, OS 5.7, S 4.4, S 4.5, S 4.7.
C-3 The Commentor commends the County's proposed Safety Policies. No response is required.
C-4 The threshold in Section 4.9.2 on page 4.9-10 in the Draft EIR has been changed as shown in Section 3 of the Final EIR to read:
• Considerably alters existing drainage patterns such that substantial changes to streamflow velocities, erosion patterns, or siltation would occur.
It should be noted that, for a Program EIR, qualitative thresholds of significance may be appropriate (see, for example, CEQA Guidelines, Appendix G, VII (D)).
C-5 The Corps does not recommend hardscape measures such as piping or concrete channelization. The General Plan policies concur with this recommendation and contain measures to preserve natural watercourses within Riverside County. The policies are as follows:
Safety Policy 4.4 Prohibit alteration of floodways and channelization unless alternative methods of flood control are not technically feasible. The intent is to balance the need for protection, with prudent land use solutions, recreation needs, and habitat requirements, and as applicable, to provide incentives for natural watercourse preservation, including density transfer programs that may be adopted.
a. Prohibit the construction, location, or substantial improvement of structures in areas designated as floodways, except upon approval of a plan that provides that the proposed development will not result in any increase in flood levels during the occurrence of a 100-year flood discharge.
b. Prohibit the filling or grading of land for nonagricultural purposes and for unauthorized flood control purposes in areas designated as floodways, except upon approval of a plan that provides that the proposed development will not result in any increase in flood levels during the occurrence of a 100-year flood discharge.
Safety Policy 4.5 Prohibit substantial modification to water courses, unless modification does not increase erosion or adjacent sedimentation, or increase water velocities, so as to be detrimental to adjacent property, or adversely affect adjacent wetlands or riparian habitat.
The mitigation measure is as follows:
4.9.1B Riverside County shall prohibit alteration of floodways and channelization unless alternative methods of flood control are not technically, economically, and practicably feasible.
C-6 The Safety Policies contained within the Draft EIR are taken directly from the General Plan, and are reiterated within the EIR to detail the policies contained within the General Plan that lessen any impacts of implementation of the General Plan, prior to any mitigation measures. This comment does not raise any substantive environmental issues regarding the adequacy of the Draft EIR. This comment will be taken into consideration by the decision-making body in its deliberations on the General Plan.
C-7 Refer to response C-6.
C-8 Refer to response C-6.
C-9 The text in Section 4.9 on page 4.9-12 in the Draft EIR has been changed as shown in Section 3 of the Final EIR as requested by the Commentor to read as follows:
4.9.1C Riverside County shall not necessarily require all land uses to withstand flooding. These may include land uses such as agricultural, golf courses, and trails. For these land uses, flows shall not be obstructed, and upstream and downstream properties shall not be adversely affected by increased velocities, erosion backwater effects, or concentration of flows, and adverse impacts to water quality from point and nonpoint sources of pollution.
C-10 Riverside County concurs on the implementation of Safety Policies 4.22 and 4.23, prior to allowing development within the 100-year floodplain.
C-11 The following mitigation measure in Section 4.9 on page 4.9-14 in the Draft EIR has been revised, as shown in Section 3 of the Final EIR.
4.9.2D Provided the applicant does hydrological studies, engineers structures to be safe from flooding, and provides evidence that the structures will not adversely impact the flood plain, Riverside County shall may allow development into the floodway fringe if the proposed structures can be adequately flood-proofed.
C-12 The flood hazard issues raised within this comment letter do not raise substantive issues that would alter the conclusion of the EIR, which is that the level of impact to flood hazards would be less than significant. However, based on issues raised within this comment letter some text has been amended as indicated in responses C-4, C-9, C-11, and C-14.
C-13 The text of the Draft EIR from Section 4.17, "Water Quality," page 4.17-11, has been revised as shown in Section 3.0 of the Final EIR.
The effects of the proposed General Plan on existing or planned water quality are considered to be significant if:
• It results in the deterioration of the quality of drinking water or a drinking water source;
• There is substantial degradation in The quality of a ground or surface water resource is degraded below the standard established by local/regional water purveyors and/or regulatory agencies; and/or
• It will cause substantial degradation of water quality in any surface body of water; and/or
• It would result in a substantial a degradation in water quality (as determined by local/regional water purveyors and/or regulatory agencies) such that an existing use or planned use could no longer be supported.
C-14 The policies referenced by this Commentor are part of the General Plan and are only restated in the EIR. This comment will be taken into consideration by the decision-making body in its deliberations on the General Plan. Additionally, Mitigation Measure 4.17.3A from Section 4.17, page 4.17-21 of the Draft EIR has been revised in Section 3.0 of the Final EIR to incorporate the requested revision as follows:
4.17.3A New development that includes more than one acre of impervious surface area (including roofs, parking areas, streets, sidewalk, etc.), shall incorporate features to facilitate the on-site infiltration of precipitation and/or runoff into groundwater basins. Such features shall include such as (but not be limited to): natural drainage systems (where economically feasible), detention basins incorporated into project landscaping; and the installation of porous areas within parking areas. Where natural drainage systems are utilized for groundwater recharge, they shall be managed using natural approaches (as modified to safeguard public health and safety).
Groundwater recharge features shall be included on development plans and shall be reviewed by the Riverside County Building and Safety Department and/or Riverside County Flood Control and Water Conservation District prior to the issuance of grading permits.
C-15 The policy referenced by this comment is part of the General Plan, and is only restated in the EIR. This comment will be taken into consideration by the decision-making body in its deliberations on the General Plan. Additionally, Mitigation Measure 4.17.4A from Section 4.17, page 4.17-23 of the Draft EIR has been revised as shown in Section 3.0 of the Final EIR to incorporate the requested revision as follows:
4.17.4A Where development may interfere with, disrupt, or otherwise affect surface or subsurface hydrologic baseline conditions (as determined by the Riverside County Flood Control and Water Conservation District, the United States Army Corps of Engineers, the California Department of Fish and Game, and/or the Regional Water Quality Control Board), preparation of a project specific hydrologic study shall be required. The hydrologic study shall include (but shall not be limited to): an inventory of existing surface and subsurface hydrologic conditions existing at the time of the study; an analysis of how the proposed development would affect these hydrologic baseline conditions; and specific measures to limit or eliminate the interference or disruption of the on-site hydrologic process. The hydrologic study shall evaluate the feasibility of incorporating bioengineering measures into any project that may alter the hydrologic process. Where required by the County, the hydrologic study shall include analysis of, at an equal level of detail, potential impacts to tributary or downstream areas. The hydrologic study shall be submitted to the County or responsible entity for review and shall be approved prior to the issuance of any entitlement that would result in the physical modification of the project site.
The following mitigation measure has been added to the Final EIR as shown in Section 3.0.
4.17.4C Where determined feasible by the County or responsible entity, bioengineering measures shall be incorporated into any project that may alter the hydrologic process.
C-16 The hydrologic study will identify baseline conditions existing at the time of preparation of the study and recommendations for mitigation. Mitigation Measure 4.17.4A (as modified above) incorporates the requested revision. While Measure 4.17.4A requires the identification of potential impacts to the hydrologic process, Measure 4.17.4B requires the evidence that development projects implement measures to reduce or eliminate these impacts to the hydrologic process.
C-17 While the Corps correctly states that existing regulations require avoidance of hydrologic impacts prior to minimization, the Corps or other responsible entity does not have jurisdiction over every hydrologic feature or process. The County's jurisdiction over natural resources is much broader than the Corps', and may cover resources that are also regulated by the Corps. In the event that the Corps has no jurisdiction, the County simply has to mitigate impacts according to the General Plan policies. When combined with existing regulations mandated by the Corps or other responsible entity, Mitigation Measure 4.17.4B will ensure that the potential impacts to both jurisdictional and non-jurisdictional hydrologic features are mitigated to the greatest extent possible.
C-18 The policy referenced by this comment is part of the proposed General Plan, and is only restated in the EIR. Mitigation Measure 4.17.5C requires the identification of specific measures, including applicable Corps requirements governing the use of created wetlands to attenuate pollutants, to reduce or eliminate potential water quality impacts.
C-19 The EIR states that water supply impacts "... must be considered significant and unavoidable." In the absence of project-specific data, even with the incorporation of relevant Corp comments, this assessment remains valid. Because the EIR requires development to identify project-specific measures to reduce or eliminate impacts to hydrologic processes or water quality, impacts related to these water issues are not significant.
Response to Letter D: Bureau of Land Management, Yuma Field Office
D-1 Thank you for your review of the Draft EIR.
D-2 The following discussion has been included on page 4.6-50 of the Draft EIR (following third full paragraph, after "local and regional scales"):
The construction and maintenance of new and existing roadways, structures, or facilities provide opportunities for the movement of invasive species. Invasive species can travel on vehicles and in the loads they carry. Invasive plants can be moved from site to site during spraying and mowing operations. Weed seed can be inadvertently introduced into the construction site on equipment during construction and through the use of mulch, imported soil or gravel, and sod. Some invasive plant species might be deliberately planted in erosion control, landscape, or wildflower projects. Highway rights-of-way provide ample opportunity for weeds in adjacent land to spread along corridors that, on a national scale, span millions of miles of highway. The introduction of invasive species may contribute to affect the habitat value of conservation lands.
The following mitigation measure has been added to Page 4.6-54 of the Draft EIR:
4.6.7E The following measures will be implemented to mitigate the potential spread of invasive plant species from construction areas:
• Soil exposed during construction and maintenance activities shall be landscaped utilizing seeds, cuttings, and/or plant material from locally adapted species to preclude the invasion of noxious weeds. The use of site specific materials, which are adapted to local conditions, increases the likelihood that revegetation will be successful and maintains the genetic integrity of the local ecosystem. Arrangements will be made well in advance of planting (nine months, if possible) to ensure that plant materials are located and available for the scheduled planting time. Sufficient time should be allocated for a qualified specialist to visit the project site during the appropriate season and collect the native plant material. If local propagules are not available or cannot be collected in sufficient quantities, materials collected or grown from other sources within Southern California shall be substituted. For widespread native herbaceous species that are more likely to be genetically homogeneous, site specificity is a less important consideration, and seed from commercial sources may be used.
• Seed purity shall be certified by planting seeds labeled under the California Food and Agricultural Code, or that have been tested within a year by a seed laboratory certified by the Association of Official Seed Analysts or by a seed technologist certified by the Society of Commercial Seed Technologists.
• Construction equipment will be cleaned of mud or other debris that may contain invasive plants and/or seeds and inspected to reduce the potential of spreading noxious weeds (before mobilizing to arrive at the site and before leaving the site).
• Vehicles with loads carrying vegetation shall be covered and vegetative materials removed from the site shall be disposed of in accordance with all applicable laws and regulations.
Response to Letter E: State Clearinghouse
E-1 No response is necessary. The letter includes a list of the State agencies that have been provided a copy of the Draft EIR and details the review period of the Draft EIR assigned by the State Clearinghouse.
Response to Letter F: Department of Parks and Recreation
F-1 The Commentor expresses support for the concept of buffer areas around State Park units. Areas adjacent to State Parks located within the County are generally designated for open space or rural uses. For example, land adjacent to Anza-Borego Desert State Park is designated Open Space-Rural, areas bordering Salton Sea State Recreation Area are designated Rural Desert and/or Open Space-Rural, while Mount San Jacinto State Park is bounded by lands designated as Open Space-Conservation. The California Citrus State Park is located entirely within the City of Riverside; therefore, land use designations for areas adjacent to this park are not subject to County land use decisions. This comment, along with all other comments, will be taken into consideration by the decision-making body in its deliberations on the General Plan.
F-2 The Commentor requests trail development coordination for County trails that may abut State Park areas. This comment, along with all other comments, will be taken into consideration by the decision-making body in its deliberations on the General Plan.
F-3 The Commentor expresses concern about potentially significant impacts to State Parks, particularly Park Rangers. State Parks are a recreational destination for all of California, as well as national and international visitors. Thus, any growth anywhere within the State has the potential to affect all State Parks. However, as State Parks are funded by the State and by user fees, growth in population in California and increased State Park use will contribute additional funding to offset impacts to State Parks.
F-4 The Commentor expresses concern about potential significant impacts to State Parks, particularly the Park Resource Ecologist. Please see response to F-3 above. It is not the responsibility of the County to fund State programs or State employees.
F-5 The Commentor expresses concern about potential significant impacts to State Parks, particularly Park Maintenance Workers. Please see response to F-3 above.
F-6 The Commentor requests policies to mitigate for potential impacts to State Parks. Funding for State Parks will increase as usage increases as a result of the payment of user fees. Any establishment of State funding is outside the scope of a County General Plan; therefore, no feasible mitigation measures are available. Refer to response to F-3.
Response to Letter G: Department of Transportation, Division of Aeronautics
G-1 Where airports are located in unincorporated areas, the proposed General Plan has established Airport Influenced Policy Areas. These Policy Areas are delineated within the various Area Plans that accompany the General Plan. As stated by Policy 1.1 of the Harvest Valley-Winchester Area Plan, the County will:
Enforce the Hemet Ryan Airport Land Use Plan and the policies in the Airport section of the General Plan Land Use Element for the purposes of protecting life and property in the vicinity of the Hemet Ryan Airport.
Similar policies are present in each of the Area Plans in which airports are located. As Area Plan policies require the County to "enforce" existing airport land use plans, the General Plan is consistent with said plans.
G-2 The revised General Plan Update Draft EIR will add a statement indicating the following:
Any new development within the General Plan area proposed within two miles of an airport will utilize the Division of Aeronautics' Airport Land Use Planning Handbook as a resource in the preparation of environmental documents.
G-3 The Commentor states that areas surrounding airports are influenced by the airport operation. See responses to G-1 and G-2. Furthermore, the zones mentioned by the Commentor are incorporated as part of the Land Use Maps for Area Plans that contain airports.
G-4 The Draft EIR will be revised to replace the second paragraph on Page 4.13-97 with the following paragraph:
Single family and multifamily residential uses, schools, libraries, and churches have a normally acceptable community noise exposure range of 60 dBA CNEL to 70 dBA CNEL. Most communities use 60 dBA CNEL or 65 dBA CNEL as their exterior residential noise standard. Office buildings are normally acceptable up to 70 dBA CNEL. Industrial and manufacturing land uses, being less sensitive to noise, are normally acceptable where the exterior noise levels are 75 dBA CNEL or less.
Low-density single-family, duplex, and mobile homes are normally acceptable from below 55 dBA to 60 dBA CNEL. Multifamily homes are normally acceptable from below 55 dBA to 65 dBA CNEL. Schools, libraries, churches, hospitals, and nursing homes are normally acceptable from below 55 dBA to 65 dBA.
Figure 4.13.39 on page 4.13-95 has been modified to reflect the normally acceptable noise levels. The new figure is shown in Section 3.2 of the Final EIR.
For the General Plan, airport noise contours maps for each airport were shown independently from the vehicular traffic noise contours along roadway links in the airport vicinity. It is impractical for the General Plan to show traffic noise contours along each roadway link on a map covering the entire County. Vehicular traffic noise contours are shown in Figures 4.13.3 through 4.13.21. However, for each individual development proposed within the airport affected areas, the County Planning Department requires that potential noise impacts from both aircraft and vehicles be combined to evaluate the potential noise impacts on this proposed development.
In addition, the County is adding the following mitigation measure:
4.13.2D Ensure that all new schools, particularly in subdivisions and specific plans, are sited more than 2 miles away from any airport.
4.13.2D Ensure that all new schools, particularly in subdivisions and specific plans, are sited more than 2 miles away from any airport.
The 60 and 65 dBA CNEL contour labels for Bermuda Dunes Airport (Figure 4.13.83 on page 4.13-34) have been corrected as shown in Section 3.2 of the Final EIR.
G-5 Staff will recommend the inclusion of such a policy in the Final General Plan. This comment will be taken into consideration by the decision-making body in its deliberations on the General Plan.
G-6 The siting of schools is the responsibility of individual school districts in accordance with applicable guidelines and standards of Caltrans and the State Department of Education.
G-7 The Commentor does not identify specific locations where this might occur so very hard to respond. Individual development proposals within airport influence areas would be reviewed for such effects.
G-8 The County concurs with the comment that land compatibility issues around airports are very important. Refer to the following proposed General Plan policies, which concern compatible land uses surrounding airports: LU 14.1, LU 14.2, and C 14.3. No further response is necessary.
Response to Letter H: Caltrans District 11
H-1 The comment provides the views of Caltrans District 11 regarding the types of communities at which the General Plan should be aiming. The proposed General Plan provides for achieving a balance between jobs and housing within the County, and aims at creating distinct community centers that facilitate the use of pedestrian, bicycle, and public transportation modes. The following proposed General Plan policies support these objectives: LU 2.1, LU 3.1, LU 7.10, LU 7.12, LU 10.4, LU 12.1, LU 12.2, LU 12.3, LU 22.2, LU 22.5, LU 23.2, LU 23.4, LU 24.4, LU 26.1, and LU 26.5. This comment will be taken into consideration by the decision-making body in its deliberations on the General Plan.
H-2 Riverside County concurs on the need for inter-agency coordination to facilitate expansion of regional transportation facilities connecting Riverside County with surrounding counties. The following policies from the proposed General Plan support this coordination: C 1.6, C 7.3, C 7.4, C 7.5, C 13.1, and C 13.2. This comment will be taken into consideration by the decision-making body in its deliberations on the General Plan.
Response to Letter I: Department of Fish and Game
I-1 A set of mitigation measures have been incorporated into the Draft EIR to address fully impacts to biological resources; however, these mitigation measures may not reduce impacts to below a level of significance.
Pursuant to State CEQA Guidelines Section 15126.4 (a)(1), an EIR shall describe feasible measures that could minimize significant adverse impacts. Section 15126.4 (a)(4)(B) states that the mitigation measures must be roughly proportional to the impacts of the project. The mitigation measures proposed are feasible and are roughly proportional to the impacts of implementing the General Plan. As described in the Draft EIR (Section 4.6.4 Biological Resources Level of Significance after Mitigation), implementation of policies and mitigation measures will reduce impacts to biological resources, however, not below a level of significance (with the exception of oak tree impacts, which will be reduced to below a level of significance).
Pursuant to State CEQA Guidelines (Section 15093):
CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against the unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered "acceptable."
With respect to item 2 of the comment, as described in the Draft EIR in Section 4.6.3 Biological Resources Impacts and Mitigation and in compliance with County policy, all future projects must comply with Riverside County Planning Department Biological Report Guidelines to include all necessary surveys and an analysis of potential project effects. Additionally, Section 4.6.3 of the Draft EIR states the following:
During subsequent project-level environmental analysis and review of individual development projects, compliance with applicable regulations may require coordination with resource agencies (e.g., USFWS, CDFG, or Corps) to determine specific mitigation for impacts to waters of the U.S. (including wetlands), riparian habitats, and state and federally listed species. Resource agency permits for project-level approvals may require mitigation measures in addition to those outlined herein for the proposed General Plan.
The policies and mitigation measures do, in fact, require a full analysis of biological impacts of future development projects.
I-2 Refer to response I-1.
I-3 The County disagrees with the Commentor's statement that the current document does not satisfy the statutory requirements relating to mitigation for impacts to biological resources. The Draft EIR provides an analysis of environmental impacts and mitigation measures to offset those impacts (Section 4.6 of the Draft EIR). As described in Section 2.1 of the Draft EIR, this EIR is a "Program EIR," which evaluates the broad-scale impacts of the proposed General Plan. Although the legally required contents of a Program EIR are the same as those of a Project EIR, in practice there are considerable differences in level of detail. Program EIRs are typically more conceptual and abstract. They contain a more general discussion of impacts, alternatives, and mitigation measures. As is stated in response to Comment I-1, in accordance with the CEQA Guidelines, the mitigation measures proposed are feasible and are roughly proportional to the impacts of implementing the General Plan.
The County received a number of comments requesting that the County provide additional details regarding the impacts of the proposed project. In a similar vein, some comments requested additional specificity with respect to mitigation measures or policies addressing potential impacts caused by the plan.
In many instances, the County has responded to these comments by providing the additional information requested by the Commentor. In other instances, however, the County has not provided this additional information.
The reason for this approach is that the project consists of a General Plan for the entire County, not a specific development proposal. Similarly, the Draft EIR is a Program EIR addressing the impacts of the General Plan as a whole, rather than a project-specific EIR. Additional environmental review will be performed in connection with specific development proposals as they come forward. The General Plan does not address specific development proposals. Rather, the General Plan establishes an overall policy framework the County will use as a means of evaluating such proposals.
"The Program EIR prepared for a general plan examines broad policy alternatives, considers the cumulative effects and alternatives to later individual activities, where known, and contains plan level mitigation measures. Later activities which have been adequately described under the program EIR will not require additional environmental documents. When necessary, new environmental documents such as a subsequent or supplemental EIR or negative declaration will focus on the project-specific impacts of later activities, filling in the information and analysis missing from the program EIR." (Governor's Office of Planning and Research, General Plan Guidelines (1998), p. 108.)
CEQA provides that the programmatic environmental analysis for such large-scale planning efforts differs from the sort of environmental analysis performed about a specific development project. According to the CEQA Guidelines, "[a] program EIR is an EIR which may be prepared on a series of actions that can be characterized as one large project and are related either: (1) Geographically, (2) A logical parts in the chain of contemplated actions, (3) In connection with issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program, or (4) As individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental effects which can be mitigated in similar ways." (CEQA Guidelines, § 15168, subd. (a).)
"The Program EIR can be used effectively with a decision to carry out a new governmental program or to adopt a new body of regulations in a regulatory program. The program EIR enables the agency to examine the overall effects of the proposed course of action and to take steps to avoid unnecessary adverse environmental effects. Use of the program EIR also enables the Lead Agency to characterize the overall program as the project being approved at that time. Following this approach when individual activities within the program are proposed, the agency would be required to examine the individual activities to determine whether their effects were fully analyzed in the program EIR...." (Discussion following CEQA Guidelines, § 15168.)
In Al Larson Boat Shop, Inc. v. Board of Harbor Commissioners (1993) 18 Cal.App.4th 729, 741-746, the Court of Appeal stated that, in preparing a "first tier EIR" for a plan-level decision, an agency may permissibly defer until later project-specific EIRs analysis that might otherwise be required in a stand-alone project EIR. In upholding the alternatives analysis in the program EIR, the Court stated:
"No ironclad rules can be imposed regarding the level of detail required in the consideration of alternatives. EIR requirements must be ‘sufficiently flexible to encompass vastly different projects with varying levels of specificity.' (Rio Vista Farm Bureau Center v. County of Solano (1992) 5 Cal.App.4th 351, 374.) The degree of specificity required in an EIR ‘will correspond to the degree specificity involved in the underlying activity which is described in the EIR.' (Guidelines, § 15146.) Thus, ‘an EIR on the adoption of a general plan ... must focus on secondary effects of adoption, but need not be as precise as an EIR on the specific projects which might follow. [Citations.]' (Rio Vista, supra, 5 Cal.App.4th at p. 374.) The consideration of alternatives in this FEIR was adequate for its purposes."
(18 Cal.App.4th at pp. 741-742, 745-746.)
The Larson court also addressed the extent to which an agency, in preparing a first tier EIR, can defer the identification of environmental impacts and the formulation of specific mitigation measures until later "project EIRs":
"While a Final EIR cannot defer all consideration of cumulative impacts to a later time, it may legitimately indicate that more detailed information may be considered in future project EIR's. [sic] * * *
"A Final EIR need only conform with the general rule if reason in analyzing the impact of future projects, and may reasonably leave many specifics of future EIR's. ‘CEQA recognizes that environmental studies in connection with amendments to a general plan will be, on balance, general' (Schaeffer Land Trust v. San Jose City Council (1989) 215 Cal.App.3d 612, 625.)
"Deferral of more detailed analysis to a project EIR is legitimate. It has been held that ‘where practical considerations prohibit devising such measures early in the planning process (e.g., at the general plan amendment or rezone stage), the agency can commit itself to eventually devising measures that will satisfy specific performance criteria articulated at the time of project approval....[Citation.]' (Sacramento Old City Association v. City Council of Sacramento (1991) 229 Cal.App.3d 1011, 1029.)"
(18 Cal.App.4th at pp. 746-747.)
A similar approach was upheld by the Court in Rio Vista Farm Bureau Center v. County of Solano (1992) 5 Cal.App.4th 351. In that case, the County prepared a hazardous waste management plan representing an initial assessment of the County's hazardous waste management needs. The Plan contained criteria for siting future facilities and designated generally acceptable locations; site specific analysis, however, was deferred to subsequent "project EIRs." The petitioners argued that the County "piecemealed" its environmental review. The Court disagreed, stating:
"The omission of any description of specific potential future facilities ... does not, in our view, render the FEIR deficient....The Plan does not propose a single project divided into parts; it merely serves as a hazardous waste management assessment and overview, with any separate future projects ... to be accompanied by additional EIRs. Repeated commitments are made in both the Plan and the FEIR for preparation of future CEQA documents prior to approval, upon a finding of consistency with the Plan, of any hazardous waste management facilities."
(5 Cal.App.4th at 371-371.)
As these cases make clear, the EIR for a plan-level, first tier program EIR focuses on the broad policy implications of implementing the plan as a whole. It is neither feasible nor necessary for an EIR of this sort to specify with precision exactly how a particular policy or mitigation measure will be applied to a particular development project. What is necessary, however, its to devise policies and mitigation measures representing a genuine commitment to a performance standard, such that the impact of the plan will be avoided or lessened, to the extent it is feasible to do so. (See Citizens for Quality Growth v. City of Mount Shasta (1988) 198 Cal.App.3d 433, 442 ("[w]hile detailed mitigation measures may not be possible before a specific development plan is proposed, general mitigation measures may be adopted"); Rio Vista Farm Bureau Center v. County of Solano, supra, 5 Cal.App.4th at p. 377 (where "devising more specific mitigation measures early in the planning process is impractical, the agency can commit itself to eventually devising measures that will satisfy specific performance standards articulated at the time of project approval" (internal quotations omitted).)
That is the approach taken by Riverside County in this case. In each chapter analyzing the impacts of the project on a particular resource, the EIR identifies those General Plan policies that, when applied to a particular development proposal, will ensure that the project's impacts on that resource are addressed. Where those policies do not assure a proposed project will avoid impacts to that resource, the Draft EIR identifies additional mitigation measures to address further the impact.
Many other cities and counties have employed a similar approach in order to comply with CEQA in connection with the update of their General Plans.
I-4 No response required, as the comment cites State CEQA Guidelines.
I-5 The County respectfully disagrees with the Commentor in the statement that compliance with existing HCPs does not constitute mitigation. Existing HCPs have been established to provide and fund permanent reserves for certain species. For instance, a current project may affect habitat occupied by the Stephens' kangaroo rat (a State-threatened and federally-endangered species); pursuant to CEQA, such impacts may be considered significant. If the project were within the fee area of the existing Stephens' kangaroo rat HCP, then the project must comply with the requirements of the HCP (i.e., payment of fees that fund the permanent reserves). It is standard professional practice to consider potential project impacts to the Stephens' kangaroo rat to be fully mitigated by project participation in the HCP. HCPs for individual projects are applicable as mitigation only for those individual projects that are covered by the HCP.
The Riverside County General Plan is a regional planning effort intended to meet regulatory and other obligations including the following:
• Provide housing to all economic segments of the population;
• Remain fiscally solvent; and
• Provide necessary public services.
The General Plan seeks to balance these obligations with other objectives, including open space conservation. The mitigation measures proposed by the CDFG would result in the conservation of substantial areas of open space while minimizing the extent of land available for developed uses. The comment identifies eight habitat types as worthy of mitigation (wetland, riparian, meadow and coniferous forest, sage scrub, oak woodland, grassland, desert scrub, and agricultural lands which support foraging habitat for raptors). Based on the Existing Setting document and data provided in Table 4.6.C of the Draft EIR, the eight habitats account for 3,170,253 acres (75 percent) of the 4,203,761 acres of unincorporated area in Riverside County. Such an approach is not compatible with the regulatory and other obligations that the General Plan must meet.
Existing CEQA regulations require the analysis of impacts to biological resources, including conducting surveys as appropriate. Furthermore, sensitive, endangered, or threatened species, as well as wetland and riparian habitat (and sensitive vegetation communities as indicated by the State or USFWS) are subject to CDFG, USFWS, and/or US Army Corps of Engineers regulations and permits. Impacts to sage scrub and desert scrub, as well as other habitats, may be regulated depending on the suitability of the habitat for sensitive species. Impacts to nesting raptors are regulated through existing CDFG regulations. Impacts to raptor foraging habitat must be disclosed under CEQA. The addition of a policy to the proposed General Plan requiring mitigation under all circumstances for any impacts, regardless of significance, to the listed biological resources does not take into account the differing degrees of sensitivity and the different levels of impacts to these resources.
As stated in response I-1, in accordance with the State CEQA Guidelines, the mitigation measures proposed are feasible and are roughly proportional to the impacts of implementing the General Plan.
I-6 All future projects in the County are required to comply with CEQA. The Commentor is apparently recommending alternative language for Section 15065 of the State CEQA Guidelines to be used in determining when an EIR should be prepared. The recommended alternative language is superfluous in light of the Guidelines. The Commentor is also recommending that language be adopted to ensure that all impacts to biological resources be reduced to below a level of significance. CEQA does not require mitigation of all impacts to below a level of significance. The County will comply with applicable CEQA Guidelines.
I-7 The Commentor proposes mitigation measures for impacts to contiguous habitat blocks larger than 40 acres, impacts to habitat blocks less than 40 acres, impacts to narrow endemic species, and impacts to wetland, riparian, meadow and coniferous forest, sage scrub, oak woodland, grassland, desert scrub, and agricultural lands which support foraging habitat for raptors. The measure further provides suggested ratios for mitigation for the eight habitats. Refer to response I-5 for a discussion of the habitats indicated above. Current practice by CDFG, USFWS, and US Army Corps of Engineers typically results in the suggested mitigation ratios for wetland, riparian, and some types of sage scrub habitat. Existing regulations require the consideration of connectivity, habitat fragmentation, and wildlife movement when identifying impacts to biological resources under CEQA. Significant impacts must be disclosed and mitigation implemented to the maximum extent feasible. The County notes the Commentor's suggested measures for mitigation to impacts, and these will be taken into consideration by the decision-making body during its deliberations on the General Plan. However, the decision to impose mitigation standards, in this instance, a policy decision by the County. The County does not at this time wish to set forth concrete mitigation ratios and measures (which could limit its ability to impose greater mitigation requirements if appropriate), but will continue to assess impacts to biological resources on a project-by-project basis in accordance with CEQA and all appropriate regulations. The County will continue to require project compliance with CDFG, USFWS, and US Army Corps of Engineers permit regulations and any mitigation imposed by these agencies.
I-8 The Commentor recommends including language to address additional mitigation measures that may be required on a project-specific basis. This language has already appeared in the Biological Resources section of the Draft EIR (Section 4.6.3).
For the sake of clarification, the following will be added before Impact 4.6.1:
During subsequent project-level environmental analysis and review of individual development projects, compliance with applicable regulations may require coordination with resource agencies (e.g., USFWS, CDFG, or Corps) to determine specific mitigation for impacts to waters of the U.S. (Including wetlands), riparian habitats, and State and federally listed species. Resource agency permits for project-level approvals may require mitigation measures in addition to those outlined in the existing General Plan.
I-9 "Urban and disturbed" are included as a "natural community" because certain species that are listed or proposed for listing as threatened or endangered (e.g., mountain plover and peninsular bighorn sheep) are known to use certain "urban and disturbed" habitats. The intent of this habitat categorization was to summarize the habitat use and associated distribution of listed or proposed species. However, Tables 4.6.C and 4.6.D do not include "urban and disturbed,"as such areas are not considered relevant in the County assessment of proposed General Plan impacts to habitat types. The change recommended by the Commentor is not appropriate given the context in which the categorization is used.
I-10 The categories of management status are described in the Existing Setting document and are intended to provide a general framework of how conservation areas are currently managed on various lands within the County. A description of current management approaches is relevant in describing the existing setting of biological resources in the County.
I-11 Open Space Policy 5.3 addresses setbacks to be implemented in the vicinity of a floodway whereas Policy 6.2 addresses buffer zones around wetlands. The proposed General Plan (Appendix A) defines floodway as:
The channel of a river or other watercourse and the adjacent land areas that must be reserved in order discharge the "base flood [a 100-year flood]" without cumulatively increasing the water surface elevation more than one foot. No development is allowed in floodways.
Wetlands are those areas that meet State and/or federal definitions based on soils, vegetation, and hydrology. Wetlands and floodways may occur together or separately; the different policies address two different resources that may, in some situations, overlap one another.
I-12 Although the term "superior" is used in Open Space Policy 9.3, it is intended to convey a level of value and quality associated with certain examples of native trees and habitat. The Commentor's recommended language of "remaining intact" is equally subjective and lacks any differentiation with respect to value or quality. The Commentor appears to be suggesting that virtually any area of native trees or habitat should be maintained and conserved. Such an approach is not consistent with the specified thresholds of significance (Section 4.6.2) nor would it be consistent with the objectives of the regional planning effort contemplated with the proposed General Plan. Refer to response I-5.
The Commentor is incorrect in stating that Open Space Policy 9.3 and Mitigation Measure 4.6.4B are the only measures pertaining to upland habitat. Various impacts and associated mitigation measures refer to "habitat" and do not distinguish between riparian/wetland and upland habitats. Section 4.6.3 identifies various upland habitats as "sensitive." Mitigation Measure 4.6.1B pertains to upland habitat that is occupied by listed, proposed, or candidate species. Mitigation Measure 4.6.1C pertains to upland habitat that is conserved through efforts of the Stephens' Kangaroo Rat HCP and the Coachella Valley Fringe-toed Lizard HCP. Mitigation Measures 4.6.4B and 4.6.5B address impacts to connectivity of sensitive habitats. Mitigation Measure 4.6.6B requires compliance with existing Oak Tree Management Guidelines, as many oaks are found in upland habitats of the County. Mitigation Measures 4.6.7B and 4.6.7C pertain to direct or indirect impacts to upland habitats that are occupied by one or more listed, proposed, or candidate species.
I-13 The section (on page 4.6-30) cited by the Commentor goes on to state that, in conjunction with the proposed General Plan policies, mitigation measures will be implemented. The mitigation measures are intended to supplement the General Plan policies by providing additional feasible measures to offset impacts of implementation of the General Plan. Refer to response I-1 regarding the adequacy of mitigation measures and to response I-5 regarding the incompatibility of the Commentor's recommended mitigation measures.
I-14 Refer to response I-5.
I-15 The County concurs with the comment.
I-16 The County concurs with the CDFG that the purpose of an MSHCP is to obtain incidental take for threatened and endangered species and eliminate the need for project-specific review by the CDFG and permitting pursuant to the Federal Endangered Species Act. However, there are areas under the County's land use jurisdiction that are outside (mainly eastern Riverside County) the boundaries area covered by both the Western Riverside County MSHCP and Coachella Valley MSHCP. Those areas not covered by the MSHCPs will be required to obtain permits from resource agencies for endangered and threatened species. Therefore, the assumptions in the alternatives discussion is correct.
I-17 It is not the intent of the Program EIR to "waive environmental documentation for future projects." As is clearly stated in Section 2.1.2 of the Draft EIR:
A General Plan EIR, addressing the impacts of countywide and local policy decisions, can be thought of as a "first tier" document. It evaluates the large-scale impacts on the environment that can be expected to result from the adoption of the General Plan, but does not necessarily address the site-specific impacts of each of the thousands of individual development projects that will follow and implement the General Plan. CEQA requires each of those subsequent development projects be evaluated for their particular site-specific impacts. These site-specific analyses are typically encompassed in second-tier documents, such as Project EIRs, Focused EIRs, or Negative Declarations on individual development projects subject to the General Plan, which typically evaluate the impacts of a single activity undertaken to implement the overall plan.
Response to Letter J: California Regional Water Quality Control Board, Santa AnaRegion
J-1 Mitigation Measure 4.17.5C permits the RWQCB to request the preparation of water quality analysis for any development that may contribute to a worsening of local or regional water quality. The RWQCB is routinely noticed subsequent to the receipt of development applications, and would, therefore, be in the position to require the preparation of such an analysis. The water quality analysis requires the identification of "... specific measures to limit or eliminate potential water quality impacts" that would result from a specific development project. To ensure project-specific measures conform to RWQCB requirements, Mitigation Measures 4.17.5C and 4.17.5D have been revised and are shown in Section 3.0 of the Final EIR:
4.17.5C Where development may contribute to a worsening of local or regional ground or surface water quality (as determined by the Riverside County Department of Environmental Health and/or RWQCB), a water quality analysis shall be prepared. The water quality analysis shall include (but shall not be limited to): an analysis of existing surface and subsurface water quality; an assessment of how the proposed development would affect such conditions existing water quality; an assessment of how the proposed development would affect beneficial uses of the water; and specific measures to limit or eliminate potential water quality impacts and/or impacts to beneficial uses of ground/surface water. Where determined necessary by the County or other responsible entity, the water quality analysis shall include, at an equal level of detail, potential impacts to tributary or downstream areas. The water quality analysis shall be submitted to the County and the RWCQB or responsible entity for review and shall be approved prior to the issuance of any entitlement that would result in the physical modification of the project site.
4.17.5D The project applicant shall submit to the County and the RWQCB, for review and approval, evidence that the specific measures to limit or eliminate potential water quality impacts resulting from the entire development process, and will be implemented as set forth in the water quality analysis. Said evidence shall be submitted and approved prior to the issuance of any entitlement that would result in the physical modification of the project site.
In response to the Commentor's request, the following mitigation measure has been added to Section 4.17 of the EIR:
4.17.5E For each new development project, the following principles and policies shall be considered and implemented:
(1) Avoid or limit disturbance to natural water bodies and drainage systems (including ephemeral drainage systems) when feasible. Provide adequate buffers of native vegetation along drainage systems to lessen erosion and protect water quality.
(2) Appropriate best management practices (BMPs) must be implemented to lessen impacts to waters of the United States and/or waters of the State of California resulting from development. Drainages should be left in a natural condition or modified in a way that preserves all existing water quality standards where feasible. Any discharges of sediment or other wastes, including wastewater, to waters of the United States or waters of the State must be avoided to the maximum extent practicable. All such discharges will require an NPDES permit issued by the Regional Water Quality Control Board (RWQCB).
(3) Small drainages shall be preserved and incorporated into new development, along with adequate buffer zones of native vegetation, to the maximum extent practicable.
(4) Any impacts to waters of the United States require a Section 401 Water Quality Standards Certification from the RWQCB. Impacts to these waters shall be avoided to the maximum extent practicable. Where avoidance is not practicable, impacts to these waters shall be minimized to the maximum extent practicable. Mitigation of unavoidable impacts must, at a minimum, replace the full function and value of the affected water body. Impacts to waters of the United States also require a Clean Water Act Section 404 Permit from the United States Army Corps of Engineers and a Streambed Alteration Agreement from the California Department of Fish and Game.
(5) The County shall encourage the use of pervious materials in development to retain absorption and allow more percolation of stormwater into the ground. The use of pervious materials, such as grass, permeable/porous pavement, etc., for runoff channels and parking areas shall also be encouraged. Lining runoff channels with impermeable surfaces, such as concrete or grouted rip-rap, will be discouraged.
(6) The County shall encourage construction of detention basins or holding ponds and/or constructed wetlands within a project site to capture and treat dry weather urban runoff and the first flush of rainfall runoff. These basins should be designed to detain runoff for a minimum time, such as 24 hours, to allow particles and associated pollutants to settle and to provide for natural treatment.
(7) The County shall encourage development to retain areas of open space as natural or landscaped to aid in the recharge and retention of runoff. Native plant materials shall be used in replanting and hydroseeding operations, where feasible.
(8) The County shall require that environmental documents for proposed projects in areas tributary to Canyon Lake Reservoir, Lake Elsinore, sections of the Santa Ana River, Fulmar Lake, and Mill Creek (as a result of the proposed 2002 303 (d) listing of these water bodies) include discharge prohibitions, revisions to discharge permits, or management plans to address water quality impacts in accordance with the controls that may be applied pursuant to State and Federal regulation. Environmental documents shall acknowledge that additional requirements may be imposed in the future for projects in areas tributary to the water bodies listed above.
(9) The County shall ensure that in new development, post-development stormwater runoff flow rates do not differ from the pre-development storm-water runoff flow rates.
(10) All construction projects should be designed and implemented to protect, and if at all possible, to improve the quality of the underlying groundwater.
(11) The County shall encourage the enhancement of groundwater recharge wherever possible. Measures such as keeping stream/river channels and floodplains in natural conditions or with pervious surfaces, as well as keeping areas of high recharge as open space will be considered.
(12) The County shall prohibit the discharge of waste material resulting from any type of construction into any drainage areas, channels, streambeds, streams, lakes, wetlands, or rivers. Spoil sites shall be prohibited within any streams or areas where spoil material could be washed into a water body.
(13) The County shall require that appropriate BMPs be developed and implemented during construction efforts to control the discharge of pollutants, prevent sewage spills, and to avoid discharge of sediments into the streets, stormwater conveyance channels, or waterways.
Response to Letter K: California Regional Water Quality Control Board, San DiegoRegion
K-1 The Draft Environmental Impact Report allows for the possibility that the Western Riverside County MSHCP will not be adopted.
Furthermore, Section 4.17, page 4.17-23 of the Draft EIR has been revised as follows:
Impact 4.17.5 Implementation of the proposed General Plan will result in reliance on a higher percentage of lower quality water sources either from the Colorado River or from marginal groundwater sources, and/or may increase the level of pollutants that occur in local/regional ground water reserves and/or local/regional surface water. Either of these conditions would result in the deterioration of the quality of the drinking water in Riverside County and would be a significant impact.
Page 4.17-24 of the Draft EIR has been revised as follows (add following second full paragraph):
Non-consumptive beneficial water uses, such as contact and non-contact recreation, warm and cold water habitat, or habitat for sensitive plant/animal species, may be affected by any degradation of water quality resulting from the development envisioned in the proposed General Plan.
Mitigation Measures 4.17.5C and 4.17.5D (page 4.17-25 of the Draft EIR) have been revised as follows:
4.17.5C Where development may contribute to a worsening of local or regional ground or surface water quality (as determined by the Riverside County Department of Environmental Health and/or RWQCB), a water quality analysis shall be prepared. The water quality analysis shall include (but shall not be limited to): an analysis of existing surface and subsurface water quality; an assessment of how the proposed development would affect such conditions existing water quality; an assessment of how the proposed development would affect beneficial uses of the water; and specific measures to limit or eliminate potential water quality impacts and/or impacts to beneficial uses of ground/surface water. Where determined necessary by the County or other responsible entity, the water quality analysis shall include, at an equal level of detail, potential impacts to tributary or downstream areas. The water quality analysis shall be submitted to the County and the RWCQB or responsible entity for review and shall be approved prior to the issuance of any entitlement that would result in the physical modification of the project site.
4.17.5D The project applicant shall submit to the County and the RWQCB, for review and approval, evidence that the specific measures to limit or eliminate potential water quality impacts resulting from the entire development process, and will be implemented as set forth in the water quality analysis. Said evidence shall be submitted and approved prior to the issuance of any entitlement that would result in the physical modification of the project site.
K-2 The EIR allows for the possibility that the MSHCP will not be adopted.
The policy referenced by this comment is part of the General Plan, and is only restated in the EIR. This comment will be taken into consideration by the decision-making body in its deliberations on the General Plan.
Mitigation Measure 4.17.5C has been modified in response J-1 to require the incorporation of natural drainage systems (where feasible) into specific developments. Such features would be managed using natural management approaches (modified to safeguard public health and safety). There may be circumstances wherein site-specific conditions make the use of natural drainage systems infeasible or unsafe. Refer to response K-1.
Additionally, staff shall recommend the addition of the following policy to the General Plan:
"Incorporate natural drainage systems into developments unless proven to be infeasible. Where avoidance of impacts to natural drainage systems is infeasible, impacts shall be minimized and adequately mitigated."
K-3 To ensure consistency with the anticipated municipal storm water permit for the Santa Margarita Watershed, Mitigation Measure 4.17.3A on page 4.17-21 has been revised as follows:
4.17.3A New development that includes more than one acre of impervious surface area (including roofs, parking areas, streets, sidewalk, etc.), shall incorporate features to facilitate the on-site infiltration of precipitation and/or runoff into groundwater basins. Such features shall include such as (but not be limited to): natural drainage systems (where feasible), detention basins incorporated into project landscaping; and the installation of porous areas within parking areas. Where natural drainage systems are utilized for groundwater recharge, they shall be managed using natural approaches (as modified to safeguard public health and safety). Groundwater recharge features shall be included on development plans and shall be reviewed by the Riverside County Building and Safety Department and/or Riverside County Flood Control and Water Conservation District prior to the issuance of grading permits.
K-4 Mitigation Measure 4.17.5C permits the RWQCB to request the preparation of a water quality analysis for any development that may contribute to a worsening of local or regional water quality. The RWQCB is routinely noticed subsequent to the receipt of development applications, and would therefore, be in the position to require the preparation of such an analysis. The water quality analysis requires the identification of "... specific measures to limit or eliminate potential water quality impacts."
Mitigation Measures 4.17.5C and 4.17.5D (see Section 3.0 of the Final EIR) have been revised in response J-1 to require RWQCB review and approval of the water quality analysis and the project-specific measures identified to reduce or eliminate water quality impacts. As appropriate, the RWQCB can require adherence to additional RWQCB requirements during this review and approval process. Mitigation Measures 4.17.5C and 4.17.5D are shown in response K-1.
K-5 As with the preceding response, the RWQCB will review and approve the water quality analysis and project-specific water quality protection measures. During the review and approval process, the RWQCB can require the incorporation of additional watershed protection and water quality control measures that will reduce or eliminate potential impacts related to these issues.
Staff will recommend the following policies as additions to the General Plan:
Minimize the number of impervious surfaces and directly connected impervious surfaces in areas of new development and redevelopment, and, where feasible, slow runoff and maximize on-site infiltration of runoff.
Implement pollution prevention methods supplemented by pollutant source controls and treatment. Use small collection strategies located at, or as close as possible to, the source (i.e., the point where water initially meets the ground) to minimize the transport of urban runoff and pollutants off-site. Preserve, and where possible, create or restore areas that provide important water quality benefits, such as riparian corridors, wetlands, and buffer zones. Encourage land acquisition of such areas.
Limit disturbances of natural water bodies and natural drainage systems caused by development, including roads, highways, and bridges.
Prior to making land use decisions, utilize methods available to estimate increases in pollutant loads and flows resulting from projected future development. Require incorporation of structural and non-structural BMPs to mitigate the projected increases in pollutant loads and flows.
Avoid development of areas that are particularly susceptible to erosion and sediment loss; or establish development guidance that identifies these areas and protects them from erosion and sediment loss.
Reduce pollutants associated with vehicles and increasing traffic resulting from development.
Post-development runoff from a site shall not contain pollutant loads that cause or contribute to an exceedance of receiving water quality objectives or that have not been reduced to the maximum extent practicable.
K-6 Refer to response K-5.
Response to Letter L: County of San Bernardino, Land Use Services Department
L-1 Thank you for reviewing the Draft EIR. The Commentor requests a copy of the Final EIR when it becomes available, which will be transmitted to the County as requested. No further comment is necessary.
Response to Letter M: County of Orange, Planning & Development Services Department
M-1 The existing Riverside County General Plan provides for more growth and development than the proposed General Plan. This was verified by comparing the proposed Area Plan Land Use Plans for the appropriate portions of the County to the existing General Plan land uses for the same areas. The Land Use Plans for the Eastvale, Jurupa, Highgrove, Reche Canyon/Badlands, Lake Mathews/Woodcrest, Temescal Canyon, and Mead Valley Area Plans are found in the proposed Riverside County General Plan Area Plans Volume 1 and Volume 2. The existing General Plan land uses for the entire County and cities were inventoried as part of the technical tasks associated with defining baseline conditions for the RCIP effort. The existing General Plan land uses were mapped as part within the GIS system, with a final print of the map dated July 2000. Accordingly, there would be more "built-up" condition runoff generated from the existing General Plan versus the proposed General Plan. Because the Phase II General Design Memorandum (GDM) for the Santa Ana River Mainstem Project was prepared in 1988 based on the existing General Plan, the impacts of this project would be less than what was anticipated in the GDM. Therefore, no further analysis is necessary.
M-2 The Commentor requests that the EIR note that trails are addressed in Transportation Section. The text in the first paragraph of page 4.14-1 has been amended as follows:
This section assesses the potential impacts on parks and recreation that could occur with the development projected under the proposed General Plan. Please note that trails are discussed in Section 4.16, Transportation and Circulation.
M-3 The Commentor requests that the trails text be modified to include discussion of the Santa Ana River Trail, as well as additional information on the Santa Ana River Bikeway. The text of the last paragraph of page 4.16-8 has been amended as follows:
Non-Motorized Transportation
Bicycling occurs throughout the County, but is more concentrated in the cities and urbanized portions of unincorporated areas, and is more recreational than commute-oriented. Although the County's current bicycle plan provides for connections between major urban and recreational facilities within the County, implementation of the plan has occurred only to a limited extent. Two major facilities, the Santa Ana River Bikeway and the Santa Ana River Trail, are proposed to extend along the Santa Ana River from the foothills of the San Bernardino mountains to the Pacific Ocean. One of the major regional bikeway paths is located along the Santa Ana River, which has been completed from the Orange/Riverside County boundary to downtown Riverside. The Santa Ana River Bikeway is paved. The Santa Ana River Trail is surfaced with decomposed granite, and is used by equestrians, mountain bicyclists, hikers, and joggers. Some segments of both trails are in existence in the Riverside and Orange Counties; however, a major coordination project for Orange and Riverside County planners (in concert with the Wildlands Conservancy) is the closure of the gap between the existing bikeway segment in the City of Riverside and the boundary with Orange County.
M-4 The comment is noted and appreciated.
Response to Letter N: City of Anaheim Planning Department
N-1 Thank you for reviewing the Draft EIR. The Commentor requests copies of any subsequent public notices and/or environmental documents. The County will comply with the Commentor's request. No further comment is necessary.
Response to Letter O: City of Ontario
O-1 Figures 1 and 2 in Appendix A of the Draft EIR provide traffic data for the City of Ontario area, comparable to data provided in the EIR for other areas.
Figure 1 shows the difference in daily traffic volumes between the build out of the General Plan and the no-project/no-build condition (see Draft EIR for explanation of no-project/no-build). Figure 2 indicates the percentage increase in traffic on each facility that would occur at build out of the County General Plan, relative to the no-project/no-build condition. Interstate 15 and SR-60 are both projected to operate at Level of Service F, either with or without the build out of the Riverside County General Plan. The traffic attributable to the build out of the General Plan represents approximately 8 percent of the total forecast traffic on those facilities at the Riverside/San Bernardino County line. The percentage of traffic decreases on those facilities as they proceed further into San Bernardino County. The percentage of traffic attributable to the Riverside County General Plan is less than 5 percent on arterial facilities at the south end of the City of Ontario.
Response to Letter P: City of Chino Hills
P-1 The projected changes in traffic volume on SR-71 attributable (Traffic needs to answer question more specifically) to the build out of the Riverside County General Plan are only 2 to 3 percent, less than the limits of a typical traffic model's predictive ability. The concern about traffic congestion on SR-71 is recognized. That is one of the reasons that the Riverside County Measure A extension includes the widening of SR-71 to three lanes in each direction, consistent with the SCAG Regional Transportation Plan. This will match up with the San Bernardino County portion of SR-71 at the County line. It is also understood that these impacts will be paid for either directly by the County or with the implementation of Mitigation Measure 4.16.1A, which states that fair-share contributions will be required of land development.
P-2 This comment notes that the Draft EIR did not identify any potential expansion of the Prado Basin floodplain, and does not raise any substantive issues regarding the adequacy of the Draft EIR. As stated by the Riverside County Flood Control and Water Conservation District, no expansion project within the Prado Basin is currently planned by the County. The U.S. Army Corps of Engineers (Corps) plans to raise the embankment of Prado Dam by 30 feet and raise the elevation of the spillways 20 feet. These actions will result in a maximum ponded elevation of 566 feet (above mean sea level). The Corps has prepared an EIR/EIS addressing potential impacts associated with the proposed expansions of Prado Dam. The Corps would be responsible for the project and any substantial impacts that may result.
P-3 As the Draft EIR discusses, the County is in the process of developing an MSHCP for western Riverside County and Coachella Valley. The County as well as 14 cities in western Riverside County will be signatories to the Implementation Agreement (IA). The Draft Western Riverside County MSHCP and EIR/EIS were released for public review, which ended on January 15, 2003. The public review period on the EIS was extended by the U.S. Fish and Wildlife Service to March 14, 2003. The Coachella Valley MSHCP is in the planning process and has not been released for public review. Subsequent to public review, the MSHCPs and EIR/EISs will be considered by the County's decision-makers for approval. In the event that the proposed MSHCPs are not adopted by the County , the General Plan EIR contains mitigation to reduce impacts on biological resources.
Response to Letter Q: City of Riverside
Q-1 The Commentor is stating concern for land use designations in the cities' spheres of influence. Conflicts between a city's sphere of influence and a County General Plan land use designation are not inherently considered to be impacts under CEQA. For the most part, the County designated land in the cities' spheres of influence in a manner compatible with the plans of the individual cities. However, in certain areas, the cities' designations were not determined to be a viable use of the land, or conflicted with other County General Plan policies. The Draft EIR analyzes the impacts that would result from development as would be permitted in the proposed updated County General Plan, including land use within the cities' spheres of influence. Thus, the Draft EIR adequately addresses the impacts of development of land uses as designated in the County General Plan for all areas, including within the spheres of influence of the cities.
Q-2 This comment refers to a Memorandum of Understanding (MOU) reached between Riverside County and the Cities of Riverside, Corona, and Moreno Valley, and requests that the MOU be incorporated into the County's updated General Plan. The MOU in question did not require the County to address the issues stated in the MOU as a part of the General Plan revision; rather, it allowed the County to use the General Plan revision if it chose. The County has chosen to address the issues outlined in the MOU using other means, such as adopting new ordinances, as appropriate.
Because the Riverside County is responsible for development review and regulation within unincorporated territories, differences in standards between the County and cities within their spheres of influence are not, in and of themselves, environmental impacts. The Draft EIR analyzes the impacts of development within unincorporated territories, assuming that the County's development standards are met. As such, the EIR provides an accurate reflection of impacts that can be expected to result from implementation of the County's updated General Plan. The County's current development requirements, along with the mitigation measures set forth in the EIR, require new development to mitigate its impacts, and thereby "pay its own way" in terms of public services and facilities. Impacts on public services and facilities, as well as required mitigation measures, are clearly set forth in Section 4.15 of the Draft EIR.
The City of Riverside's request that the County jointly plan for development within unincorporated areas adjacent to cities will be considered by the County in its deliberations over the proposed General Plan. Such joint planning must, however, recognize that legitimate differences may exist between the County and adjacent cities regarding development within unincorporated areas that may affect cities, as well as differences between the County and cities regarding proposed development within cities that may affect the County. In such cases, the County and cities should work to resolve such differences, and recognize that if a mutually agreeable resolution of the differences cannot be reached, the agency with legal jurisdiction and the affected jurisdiction will take each action as they deem appropriate.
Q-3 Refer to response Q-2. Differences in the land uses proposed by the County and those by cities within their spheres of influence are not necessarily land use "conflicts." Refer to response Q-1. Thus, each section of the EIR addresses the impacts that would result from increases in development intensity proposed in the Plan. Traffic impacts resulting from such increases are addressed in the Traffic section, impacts on public services and facilities are addressed in the Public Services and Facilities section, noise impacts are addressed in the Noise section, and so on. Thus, the impacts of proposed land use changes are, in fact, addressed in the EIR.
The development densities proposed by the County within unincorporated areas north of Lake Mathews have been incorporated into the analysis of the environmental impacts that are addressed throughout the Draft EIR. That these densities may be greater than those proposed by the City of Riverside outside of its current municipal boundaries does not affect the accuracy of the analysis set forth in the Draft EIR.
Q-4 The City's assertion that the County's proposed General Plan would result in a loss of agricultural land in the area north of Lake Mathews is addressed as part of the discussion of a countywide loss of agricultural land in Section 4.2 of the Draft EIR.
Q-5 Refer to response Q-3.
Q-6 Refer to response Q-3.
Q-7 Refer to response Q-3.
Q-8 As noted in the comment, Riverside County is considering various types of density bonuses for inclusion in the General Plan as part of its public hearing process. Application of density bonuses could increase the overall level of development beyond that which was addressed in the main body of the EIR. Thus, a specific analysis of the alternative of creating a density bonus system was undertaken to address their potential impacts. This analysis is set forth in Section 6.2.6 of the Draft EIR.
Q-9 Refer to response Q-3.
Q-10 When a large study is contemplated on something that is perpetually changing, a certain limit has to be set. Analysis cannot be accomplished if time is spent updating endlessly shifting data; there has to be a point where data is "frozen" and analysis begins. The data used in the preparation of the Existing Setting Report were used throughout the Draft EIR. The changes requested by the City will be reflected in the General Plan.
Q-11 The Circulation Element, Figure C-3, contains typical cross-sections for all General Plan roadways. The City also indicates inconsistencies between the roads designated as collectors in the Woodcrest area. In response, the County will remove the Collector designations for these roadways and continue working with a joint planning committee of City and County residents to resolve Woodcrest issues.
Q-12 The Commentor is concerned that the County's land uses do not match the City's planned land uses in the City of Riverside's sphere of influence. The Commentor is correct; the County's General Plan land uses do not match those of the City's General Plan within the City's sphere of influence. The City is also correct in stating that the EIR prepared for the County's General Plan does not address these incompatibilities. The EIR addresses the environmental effects of the County's proposed General Plan. Those environmental effects of the proposed County General Plan land uses have been evaluated in Section 4.13 of the EIR for parks, Section 4.14 for public services, Section 4.15 for transportation, Section 17 for water supply, and Section 5 for cumulative impacts. Therefore, the impacts of the proposed General Plan on the City's planned land uses in the sphere of influence have been analyzed for parks, public services, water use, and transportation in the EIR.
Q-13 The alternative requested in the city's comment has already been analyzed. The Rural Emphasis Alternative proposes decreased residential development and urbanization throughout unincorporated territories, including the City of Riverside sphere of influence. This alterative is thoroughly analyzed in Chapter 6.0 of the Draft EIR. See also Response to Comment Q-2 for a discussion of the MOU which is referred to in this comment.
Q-14 See Responses to Comments Q-2, Q-3, Q-4, Q-8, and Q-13.
Q-15 See Responses to Comments Q-2, Q-3, Q-4, Q-8, and Q-13.
Response to Letter R: City of Palm Desert
R-1 The Portola Avenue/I-10 Interchange will be added to the circulation map of the General Plan.
R-2 The Commentor is suggesting land use changes. Land use designations and density decisions are related to the Draft General Plan and not the adequacy of the Draft EIR. This comment does not raise any substantive environmental issues regarding the adequacy of the Draft EIR. This comment will be taken into consideration by the decision-making body in its deliberations on the General Plan.
Response to Letter S: City of Temecula
S-1 The Commentor is stating that the City of Temecula is committed to the concept of rural community separators and is concerned that the County Board will continue to approve scattered development in French Valley against the wishes of the citizens. The General Plan contains the following policies to mitigate the issue of community separators:
LU 3.2 Use open space, greenways, recreational lands, and watercourses as community separators.
In addition, the General Plan in the Administration Element states that the incentive program would "encourage community separator and promotes clustering." Page A-18 states the following:
"Considerable discussion occurred during the RCIP process regarding an incentives system to stimulate desired compactness of development in certain areas, to generate funds for preserving permanent multipurpose open space and selected infrastructure improvements. There are three tiers to the Incentives Program; the most intense of which is within Community Centers, followed by an application of the program within Community Development areas, and finally in Rural designations. Increasing density within Community Centers would promote transit use and provide a compact, efficient, and unique living environment. Using the incentives program within the Community Development category (with the exception of Very Low Density Residential) encourages community separators and promotes clustering. Finally, a rural incentives program has also been discussed that would allow location of development on a portion of rural and agricultural parcels in exchange for some increase in overall residential yield. To do this, permanent preservation of remaining open space would be required on the parcels involved, and that open space would have to contribute to a larger open space area or continuous linkage to adjacent open space preserves. At this writing, the details of this system are drafted but not resolved. Prior to the hearing process, a determination will be made regarding direction to be included in the General Plan and commitments to be made in the Implementation Program as a mea