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(Posted to Web 7/6/09, Last Updated 7/22/09)

July 22, 2009
9:00 A.M.

AGENDA
REGULAR MEETING
RIVERSIDE COUNTY PLANNING COMMISSION
4080 LEMON STREET
1ST FLOOR, BOARD CHAMBERS
RIVERSIDE, CALIFORNIA 92501

CALL TO ORDER - ROLL CALL
SALUTE TO THE FLAG

Please be aware that the indicated staff recommendation shown below for each item may differ from that presented to the Planning Commission during the public hearing.

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In compliance with the Americans with Disabilities Act, if any accommodations are needed, please contact Chantell M. Griffin at (951) 955-3251 or E-mail at cgriffin@rctlma.org. Request should be made at least 48 hours or as soon as possible prior to the scheduled meeting.

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1.0

CONSENT CALENDAR

 

1.1

RESOLUTION NO. 2009-01 - The Redevelopment Agency for the County of Riverside - Amended and Restated Preliminary Plan adoption and boundary designations for the I-215 Corridor Redevelopment Project Area, Amendment No. 2

REQUEST: That the Planning Commission adopt Resolution No. 2009-01 approving and adopting the Amended and Restated Preliminary Plan for the I-215 Corridor Redevelopment Project Area, Amendment No. 2.

Project Planner: Rohini Dasika
Ph: (951) 955-3109 or E-mail RDasika@rivcoeda.org

Staff Recommendation: APPROVAL OF RESOLUTION NO. 2009-01 AND ADOPTION OF THE AMENDED AND RESTATED PRELIMINARY PLAN, AMENDMENT NO. 2

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1.2

TENTATIVE TRACT MAP NO. 29997 - Applicant: Albert A. Webb Associates - Second Supervisorial District - Prado-Mira Loma Zoning District - Eastvale Area Plan: Community Development: Commercial Retail (CD-CR) (0.20 - 0.35 Floor Area Ratio) and Medium Density Residential (CD-MDR) (2-5 Dwelling Units Per Acre) - Location: Northerly of Sixth Street, southerly of Chandler Street, easterly of Hellman Street and westerly of Archibald Avenue. - 41.84 Acres - Zoning: Planned Residential (R-4) (3,500 Square Foot Minimum) and General Commercial (C-1/C-P) - Schedule A subdivsion of 41.84 acres into 122 single family residential lots with a minimum parcel size of 6,500 square feet and one 11.42 acre commercial lot.

REQUEST: EXTENSION OF TIME TO JANUARY 15, 2009 - FOURTH EXTENSION.

Project Planner: Raymond Juarez
Ph: (951) 955-9541 or E-mail rjuarez@rctlma.org

Staff Recommendation: APPROVAL subject to all previous conditions.

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2.0

ORAL COMMUNICATION ON ANY MATTER NOT ON THE AGENDA.

 
 

3.0

ITEMS THAT STAFF RECOMMENDS BE CONTINUED WITHOUT DISCUSSION: 9:00 a.m. or as soon as possible thereafter. (Presentation available upon Commissioners request)

 

3.1

CONDITIONAL USE PERMIT NO. 3462 / CONDITIONAL USE PERMIT NO. 3558 - Intent to Adopt a Mitigated Negative Declaration - Applicant: John Belczak - Engineer/Representative: Barry Adnams - Second Supervisorial District - Glen Avon Zoning District - Jurupa Area Plan - Community Development: Commercial Retail (CD:CR) (0.20 - 0.35 Floor Area Ratio) - Location: Northerly of Mission Boulevard, easterly of Agate Street, and westerly of Vernon Avenue - 2.99 Gross Acres - Zoning: Scenic Highway Commercial (C-P-S) and Light Agriculture (A-1)

REQUEST: CONDTIONAL USE PERMIT NO. 3462 proposes to construct a Boat and RV Storage Facility consisting of 82 covered spaces and 109 uncovered spaces. The proposed project includes 31,480 square feet of total building area and 13,150 square feet (10 %) of landscaping on a 2.99 Gross Acre lot. CONDITIONAL USE PERMIT NO. 3558 proposes to construct a Boat and RV Storage Facility consisting of 48 covered spaces and 48 open spaces. The proposed project includes 18,760 square feet of total building area and 13,710 square feet (14 %) of landscaping on a 2.15 Gross Acre lot.

APNs: 171-090-010, 171-090-012 and 171-090-013

Project Planner: Ray Juarez
Ph: (951) 955-2419 or E-mail rjuarez@rctlma.org
(Quasi-Judicial) (Continued from 12/3/08, 1/7/09, 2/4/09, 3/4/09 and 6/24/09)

Staff Recommendation: CONTINUE WITHOUT DISCUSSION TO 9/30/09

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4.0

ITEMS THAT STAFF RECOMMENDS APPROVAL UNDER ONE MOTION UNLESS A COMMISSION MEMBER OR MEMBER OF THE PUBLIC DESIRES TO DISCUSS THE MATTER: 9:00 a.m. or as soon as possible thereafter.

 

4.1

TENTATIVE PARCEL MAP NO. 35726 - CEQA Exempt - Applicant: Meruelo Ent/ Oullette Robert - Engineer/Representative: Carlos Losada - Second Supervisorial District - Rubidoux Zoning District - Jurupa Area Plan: Community Development: High Industrial (CD:HI) (0.15 - 0.50 Floor Area Ratio) - Location: Easterly of Agua Mansa Road and southerly of Brown Avenue - 10.00 Gross Acres - Zoning: Manufacturing-Heavy (M-H)

REQUEST: The Tentative Parcel Map proposes a schedule E subdivision of 10.00 gross acres into two (2) parcels. Proposed parcel 1 is 4.00 gross acres and proposed parcel 2 is 6.00 gross acres.

APN: 175-190-024

Project Planner: Jeff Childers
Ph: (951) 955-3626 or E-mail jchilder@rctlma.org
(Quasi-Judicial)

Staff Recommendation: APPROVAL

Click The Links Below to View Items Related to Agenda Item 4.1

 
 

5.0

PUBLIC HEARING: 9:00 a.m. or as soon as possible thereafter:

 

5.1

ORDINANCE AMENDMENT NO. 348.4637

This ordinance amendment is designed to create a new zoning overlay in the Mecca Community called the Mecca Additional Dwelling Unit Overlay Zone. This new overlay zone will be bounded by 7th Street to the North, 66th Avenue to the South, Lincoln Street to the West, Hammond Road to the Southwest, and Johnson Street to the East. The Mecca Additional Dwelling Unit Overlay Zone is intended to provide for a regulatory mechanism to allow additional dwelling units on a lot in which a primary single family home now exists.

Project Planner: Larry Ross, Principal Planner
Ph: (951) 955-3585 or E-mail lross@rctlma.org
(Legislative) (Continued from 4/29/09 and 6/10/09)

Staff Recommendation: APPROVAL

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5.2

ENVIRONMENTAL IMPACT REPORT NO. 515 / CHANGE OF ZONE NO. 7611 / TENTATIVE PARCEL MAP NO. 35865 / PLOT PLAN NO. 23219 - Intent to Certify Environmental Impact Report - Applicant: Birtcher Development, LLC - Engineer/Representative: Albert A. Webb Associates - Second Supervisorial District - Prado-Mira Loma Zoning District - Eastvale Area Plan: Community Development: Light Industrial (CD: LI) (0.25-0.60 Floor Area Ratio) - Location: Northerly of 65th Street, easterly of the Cucamonga Creek, and westerly of Archibald Avenue - 53.37 Gross Acres - Zoning: Heavy Agriculture - 10 acre minimum (A-2-10)

REQUEST: The Environmental Impact Report has been prepared to inform decisions makers and the public of the potential significant environmental effects associated with the development of the proposed project per the California Environmental Quality Act (CEQA). The Change of Zone proposes to change the project site's zoning classification from Heavy Agriculture - 10 Acre Minimum (A-2-10) to Industrial Park (I-P). The Tentative Parcel Map is a Schedule E subdivision of 53.37 gross (48.77 net) acres into fourteen (14) industrial parcels and four (4) lettered lots for ingress/egress purposes. The Plot Plan proposes to develop fourteen (14) industrial buildings, Birtcher Center at Corona Valley, with a total building area of 738,432 square feet including 266,461 square feet of landscaping area (16%), 1,188 parking spaces, and 78 loading docks on a 53.37 gross (48.77 net) acre site with a floor area ratio of 0.32 (Light Industrial requires a 0.25-0.60 Floor Area Ratio).

APNs: 144-010-002, 144-010-033, 144-010-037 and 144-010-038

Project Planner: Christian Hinojosa
Ph: (951) 955-0972 or E-mail chinojos@rctlma.org
(Legislative)

Staff Recommendation: APPROVAL

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5.3

PLOT PLAN NO. 17763, SUBSTANTIAL CONFORMANCE NO. 1 - Intent to Adopt a Mitigated Negative Declaration - Applicant: Verizon Wireless - Engineer/Representative: Spectrum Surveying and Inc. - Third Supervisorial District - Rancho California Zoning Area - Southwest Area Plan: Rural Community: Estate Density Residential (RC:EDR)(2 Acre Minimum) - Location: Northerly of Calac Road, southerly of Pauba Road, easterly of Calle Contento, and westerly of Altanos Road - 2.33 Gross Acres - Zoning: Rural Residential 1/2 Acre Minimum (R-R)

REQUEST: The Substantial Conformance is a proposal to collocate eighteen (18) antenna panels 55 feet high at centerline above grade level on an existing 103'-6" high monopole. The project will also consist of a 184 square foot equipment shelter, one (1) parabolic antenna, and a 40 square foot generator pad within a 450 square foot lease area.

APN: 951-150-013

Project Planner: Kinika Hesterly
Ph: (951) 955-1888 or E-mail khesterl@rctlma.org
(Quasi-Judicial) (Continued from 6/24/09)

Staff Recommendation: CONTINUE WITH DISCUSSION TO 8/19/09

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5.4

CONDITIONAL USE PERMIT NO. 2149, REVISED NO. 1 - CEQA Exempt - Applicant: Prestige Developers, Inc. - Engineer/Representative: Prestige Developers, Inc. - Third Supervisorial District - Sage Zoning Area - REMAP Area Plan - Rural: Rural Residential (RR) (5 Acre Minimum) - Location: Southerly of Power Line Road, easterly of Getts Road, and westerly of Sage Road - 3.80 Gross Acres - Zoning: Rural Residential (R-R)

REQUEST: The conditional use permit is requesting the renewal of the conditional use permit for an existing auto tow yard.

APN: 581-050-007

Project Planner: Jeff Horn
Ph: (951) 955-4641 or E-mail jhorn@rctlma.org
(Quasi-Judicial) (Continued from 6/24/09)

Staff Recommendation: CONTINUE WITH DISCUSSION TO 8/19/09

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5.5

CHANGE OF ZONE NO. 7419 / PLOT PLAN NO. 23535 - CEQA Exempt - Applicant: Western Land Company - Engineer/Representative: Jim Unland - Third Supervisorial District - Bautista Zoning District - San Jacinto Valley Area Plan: Community Development: Commercial Retail (CD:CR) - Location: Northerly of State Highway 74 (Florida Ave), westerly of 4th Street, southerly of C Street, and easterly of Fairview Avenue. - 1.66 Gross Acres - Zoning: Scenic Highway Commercial (C-P-S) and Rural Residential (R-R)

REQUEST: The Change of Zone proposes to change a portion of the sites existing zoning from Rural Residential (R-R) to Scenic Highway Commercial (C-P-S). The Plot Plan proposes a 9,825 square foot commercial retail building on 0.90 net acre parcel, 5,577 square feet of landscaping, and 50 parking spaces.

APN: 549-153-015

Project Planner: Jeff Horn
Ph: (951) 955-4641 or E-mail jhorn@rctlma.org
(Legislative)

Staff Recommendation: APPROVAL

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5.6

TENTATIVE PARCEL MAP NO. 35734 - CEQA EXEMPT - Applicant: Jim Bradbury/nuevo Community Church - Engineer/Representative: Madison-FCS/ Patrick Crask, PE - Fifth Supervisorial District - Nuevo Zoning Area - Lakeview / Nuevo Area Plan: Community Development: Commercial Retail (CD:CR) (0.20-0.30 Floor Area Ratio) - Location: Westerly of Ramona Avenue and southerly of Nuevo Road - 18.32 Gross Acres - Zoning: Scenic Highway Commercial (C-P-S)

REQUEST: The tentative parcel map proposes a Schedule E subdivision of 18.32 gross acres into one (1) 14.7 net acre parcel, one (1) 2.3 net acre remainder parcel, and one (1) 1.35 net acre lettered (Lot A) for street dedication purposes for financing and conveyance purposes only pursuant to the Conditions of Approval. No grading permits and/or building permits shall be issued under this approval.

APN: 309-080-001

Project Planner: Jeff Horn
Ph: (951) 955-4641 or E-mail jhorn@rctlma.org
(Quasi-Judicial) (Continued from 4/15/09, 5/13/09, and 6/24/09)

Staff Recommendation: APPROVAL

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6.0

General Plan Amendment Initiation Proceedings: 9:00 a.m. or as soon as possible thereafter. (Presentation available upon Commissioners' request)

 

6.1

GENERAL PLAN AMENDMENT NO. 981 - Foundation-Regular - Applicant: Dace Housing Alliance - Engineer/Representative: MSA Consulting - Fourth Supervisorial District - Lower Coachella Valley Zoning District - Eastern Coachella Valley Area Plan: Rural: Rural Desert (R.RD) (10 Acre Minimum) - Location: Northerly side of 70th Avenue, Easterly of Vander Veer Road, Southerly of the All American Canal - 30.08 Gross Acres - Zoning: Controlled Development Areas (W-2) (20,000 Square Foot Minimum)

REQUEST: Proposal to change the General Plan from Rural: Rural Desert (R:RD) (10 Acre Minimum) to Community Development: Medium Density Residential (CD:MHDR) (5-8 Dwelling Units per Acre).

APNs: 721-290-028 and 721-290-030

Project Planner: Tamara Harrison
Ph: (951) 955-9721 or E-mail tharriso@rctlma.org
(Continued from 3/4/09 and 4/15/09)

Staff Recommendation: CONTINUE WITHOUT DISCUSSION OFF CALENDAR

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6.2

GENERAL PLAN AMENDMENT NO. 1022 - Foundation-Regular - Applicant: JBL Investment, Inc. - Engineer/Representative: Medofer Engineering, Inc. - Fifth Supervisorial District - Mead Valley Zoning District - Mead Valley Area Plan: Rural: Rural Residential (RUR-RR) (5 Acre Minimum) - Location: Northerly of Metz Road, easterly of Rocky Hills Road, southerly of Nuevo Road, and westerly of Lukens Lane. - 36.71 Gross Acres - Zoning: Rural Residential - 1/2 Acre Minimum (R-R-1/2)

REQUEST: This General Plan Amendment proposes to amend the General Plan Foundation Component of the subject site from Rural to Community Development and to amend the land use designation of the subject site from Rural Residential (RUR-RR) (5 Acre Minimum) to Medium Density Residential (CD-MDR) (2-5 Dwelling Units Per Acre).

APNs: 323-100-019 and 323-100-020

Project Planner: Tamara Harrison
Ph: (951) 955-9721 or E-mail tharriso@rctlma.org
(Continued from 5/13/09 and 6/24/09)

Staff Recommendation: CONTINUE WITHOUT DISCUSSION OFF CALENDAR

Click The Links Below to View Items Related to Agenda Item 6.2

 
 

7.0

General Plan Amendment Initiation Proceedings: 1:30 p.m. or as soon as possible thereafter. (Presentation available upon Commissioners' request)

 

7.1

GENERAL PLAN AMENDMENT NO. 939 - Foundation-Regular - Applicant: John Paul St. Clair - Engineer/Representative: Action Surveys - First Supervisorial District - North Perris Zoning Area - Mead Valley Area Plan: Rural: Rural Residential (R:RR) (5 Acre Minimum) - Location: northerly of Orange Avenue, easterly of Decker Road, southerly of Placentia Street, and westerly of Tobacco Road - 162.02 Gross Acres - Zoning: Rural Residential (R-R), Rural Residential- One Acre Minimum (R-R-1) and Rural Residential- Five Acre Minimum (R-R-5)

REQUEST: This General Plan Amendment proposes to amend the General Plan Foundation Component of the subject site from Rural to Community Development and the amend the land use designation of the subject site from Rural Residential (RUR:RR) (5 Acre Minimum) to Estate Density Residential (CD:EDR) (2 Acre Minimum).

APNs: 317-250-006, 317-250-007, 317-250-008 and 317-250-009

Project Planner: Tamara Harrison
Ph: (951) 955-9721 or E-mail tharriso@rctlma.org

Staff Recommendation: NO INITIATION OF THE GENERAL PLAN AMENDMENT

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7.2

GENERAL PLAN AMENDMENT NO. 958 - Foundation-Regular - Applicant: Raymond James - Engineer/Representative: N/A - Fifth Supervisorial District - Good Hope Zoning Area - Mead Valley Area Plan: Rural: Rural Residential (RUR-RR) (5 Acre Minimum) - Location: Northerly of Ethanac Road, easterly of Highway 74, southerly of Margarth Street, and westerly of Phillips Street - 5 Gross Acres - Zoning: Rural Residential (R-R)

REQUEST: This General Plan Amendment proposes to amend General Plan Foundation Component of the subject site from Rural to Rural Community and to amend the land use designation of the subject site from Rural Residential (RUR:RR) (5 Acre Minimum) to Very Low Density Residential (RC:VLDR) (1 Acre Minimum).

APN: 345-100-013

Project Planner: Tamara Harrison
Ph: (951) 955-9721 or E-mail tharriso@rctlma.org

Staff Recommendation: INITIATION OF THE GENERAL PLAN AMENDMENT

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7.3

GENERAL PLAN AMENDMENT NO. 1036 - Foundation-Regular - Applicant: Miguel Sandoval - Engineer/Representative: Miguel Sandoval - Fifth Supervisorial District - Good Hope Zoning Area - Mead Valley Area Plan: Rural: Rural Residential (RUR: RR) (5 Acre Minimum) - Location: Northerly of Stelle Peak Drive, easterly of Belita Drive, southerly of Mountain Avenue, and westerly of Read Street. - 4.19 Gross Acres - Zoning: Rural Residential (R-R)

REQUEST: This General Plan Amendment proposes to amend the General Plan Foundation Component of the subject site from Rural to Rural Community and to amend the land use designation of the subject site from Rural Residential (RUR:RR) (5 Acre Minimum) Very Low Density Residential (RC:VLDR) (1 Acre Minimum).

APN: 343-180-002

Project Planner: Tamara Harrison
Ph: (951) 955-9721 or E-mail tharriso@rctlma.org

Staff Recommendation: INITIATION OF THE GENERAL PLAN AMENDMENT

Click The Links Below to View Items Related to Agenda Item 7.3

 
 

7.4

GENERAL PLAN AMENDMENT NO. 1038 - Foundation-Regular - Applicant: MDMG, Inc. - Engineer/Representative: MDMG, Inc. - First Supervisorial District - Gavilan Hills Zoning District - Lake Mathews/Woodcrest Area Plan: Rural: Rural Residential (RUR-RR) (5 Acre Minimum) - Location: Northerly of Two Bit Trail, easterly of Goldfield Road, southerly of Lake Matthews Drive, and westerly of Valley Street - 365.1 Gross Acres - Zoning: Residential Agriculture - 2 Acre Minimum (R-A-2) and Residential Agriculture - 5 Acre Minimum (R-A-5)

REQUEST: This General Plan Amendment proposes to amend the General Plan Foundation from RURAL (RUR) to RURAL COMMUNITY (RC) and to amend the General Plan land use designation from Rural Residential (RUR:RR) (5 Acre Minimum) to Estate Density Residential (RC:EDR) (2 Acre Minimum).

APNs: 289-180-003, 289-180-005, 289-180-006, 286-180-013, 289-190-009, 289-190-010, 289-190-012, 289-190-013, 289-190-014, 289-190-015 and 289-190-016

Project Planner: Tamara Harrison
Ph: (951) 955-9721 or E-mail tharriso@rctlma.org
(Continued from 10/1/08, 8/12/08 and 6/24/09)

Staff Recommendation: INITIATION OF THE GENERAL PLAN AMENDMENT

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7.5

GENERAL PLAN AMENDMENT NO. 1043 - Foundation-Regular - Applicant: MDMG Inc. - Engineer/Representative: MDMG, Inc. - First Supervisorial District - Rancho California Zoning Area - Southwest Area Plan: Rural: Rural Mountainous (RUR-RM) (10 Acre Minimum) - Location: Northerly of the San Deigo County Line, southerly of Ranch Santa Rosa, and westerly of Interstate 15 - 629.19 Gross Acres - Zoning: Rural Residential (R-R)

REQUEST: This General Plan Amendment proposes to add the subject site to the General Plan's Santa Rosa Plateau Policy Area.

APNs: 918-030-004, 918-040-001, 918-040-002 and 918-040-005

Project Planner: Tamara Harrison
Ph: (951) 955-9721 or E-mail tharriso@rctlma.org

Staff Recommendation: NO INITIATION OF THE GENERAL PLAN AMENDMENT

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7.6

GENERAL PLAN AMENDMENT NO. 780 - Foundation-Regular - Applicant: The Preserve at San Juan, LLC - Engineer/Representative: PBR, Inc. - First Supervisorial District - Cleveland Zoning Area - Elsinore Area Plan: Open Space: Conservation Habitat (OS-CH) and Rural: Rural Residential (RUR-RR) (5 Acre Minimum) - Location: Easterly of the boundary of Orange County, westerly of Highway 74, and southerly of the community of Cariso Village - 62.5 acres or 228 acres with USDA Forest Service parcel - Zoning: Rural Residential (R-R), and General Commercial (C-1/C-P)

REQUEST: This General Plan Amendment proposes to amend the General Plan from Open Space: Conservation Habitat (OS-CH) and Rural: Rural Residential (RUR-RR) (5 Acre Minimum) to Community Development: Specific Plan (SP).

APNs: 385-090-001, 385-020-001, 385-030-001 and 385-030-015 (USDA Forest Service)

Project Planner: Mike Harrod
Ph: (951) 955-1881 or E-mail mharrod@rctlma.org

Staff Recommendation: CONTINUE WITHOUT DISCUSSION TO 9/30/09

Click The Links Below to View Items Related to Agenda Item 7.6

 
 

7.7

GENERAL PLAN AMENDMENT NO. 985 - Foundation-Regular - Applicant: Bob Taghdiri - Engineer/Representative: Grant Becklund - First Supervisorial District - Lakeland Village and South Elsinore Zoning Areas - Elsinore Area Plan: Open Space-Conservation - Location: Northerly of Grand Avenue, easterly of Russell Street, southerly of Como Street, and westerly of Lucerne Street - 34.14 Gross Acres - Zoning: Regulated Development Areas (R-D) and Watercourse, Watershed & Conservation Areas (W-1)

REQUEST: The General Plan Amendment proposes to amend the General Plan from Open Space-Conservation (OS:C) to Community Development: Medium High Density Residential (CD:MHDR) (5-8 Dwelling Units Per Acre).

APNs: 3721-090-003, 371-090-004 and 371-150-009

Project Planner: Mike Harrod
Ph: (951) 955-1881 or E-mail mharrod@rctlma.org
(Continued from 6/24/09)

Staff Recommendation: NO INITIATION OF THE GENERAL PLAN AMENDMENT

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7.8

GENERAL PLAN AMENDMENT NO. 1033 - Foundation-Regular - Applicant: Vail Lake USA - Engineer/Representative: RBF Consulting - Third Supervisorial District - Rancho California Zoning Area - Southwest Area Plan: Open Space: Rural (OS-RUR) (20 Acre Minimum) - Location: Northerly of Highway 79, and easterly of Pueblo Rd. - 6980 Gross Acres - Zoning: Rural Residential (R-R)

REQUEST: This General Plan Amendment proposes to amend the General Plan from Open Space: Rural (OS-RUR) (20 Acre Minimum) within the Vail Lake Policy Area to Rural Community: Estate Density Residential (RC-EDR) (2 Acre Minimum) and to amend the boundary of the Citrus Vinyard Policy Area to include the site.

APNs: 927-320-062, 927-320-079, 927-320-080, 927-320-081, 927-320-083, 927-320-084, 927-320-085, 927-320-086, 927-320-087, 927-320-088, 927-320-089, 927-380-019, 927-380-020, 927-380-021, 927-380-023, 927-680-001, 927-680-002, 927-680-004 and 927-680-010

Project Planner: Mike Harrod
Ph: (951) 955-1881 or E-mail mharrod@rctlma.org

Staff Recommendation: NO INITIATION OF THE GENERAL PLAN AMENDMENT

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8.0

PLANNING COMMISSION SECRETARY'S COMMENTS

 

9.0

PLANNING DIRECTOR'S COMMENTS

 

10.0

COMMISSIONERS' COMMENTS