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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

1.1 Introduction

1.2 Public Review Period

1.3 Comments on the Draft EIR and Responses

1.4 List of Persons, Organizations, and Public Agencies Commenting on the Draft EIR

1.4.1 Federal Agencies

1.4.2 State Agencies

1.4.3 Local Agencies

1.4.4 Indian Tribes

1.4.5 Districts

1.4.6 Regional Agencies

1.4.7 Citizens and Organizations

1.4.8 Late Comments Received

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

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

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

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

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 2-17

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. Webb Associates

UU Metropolitan Water District of Southern California

Section 3.0 - Addendum

3.1 Text Amendments

3.2 Graphics Amendments

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 means of testing such a system."

S-2 The Commentor is of the opinion that the proposed General Plan tries to address issues facing the region through new approaches such as Community Center Incentives and the Certainty System. 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.

S-3 Impacts on the freeways are not an issue of County development, but a regional issue. Not only growth in the County of Riverside, but every city within western Riverside County and surrounding counties and communities are contributing to the traffic on the regional freeway system. Controlling growth in Riverside County alone will not sufficiently reduce traffic on the freeways. Each jurisdiction within the County and surrounding jurisdictions would have to control growth as well. Is growth control the reasonable solution? Southern California is growing. Cities and counties must meet their housing needs. If commercial and industrial growth were stopped, where will the additional funds come from to facilitate improvements to the roadways? The County has taken the regional lead in securing funding for roadway improvements. The County has put a fee system in place to alleviate traffic issues (e.g., TUMP fees). The County also is taking the lead, through the Riverside County Transportation Commission (RCTC), to secure funding for freeway and roadway improvements.

Furthermore, the County prepared an assessment of what would happen to roadways and freeways if the County would not allow any more growth and the cities continued to grow. Section 6 on page 6-11 of the EIR analyzed the No Project Alternative on traffic. The No Project Alternative assumes no growth in the County and that the cities would build out according to their General Plans. The analysis determined that SR-91, SR-60, and portions of I-15 and I-215 will be affected and would operate at LOS F. The traffic analysis in Appendix C of the EIR , Figure 6, clearly illustrates the freeway deficiencies. The County has done its due-diligence in providing the public with a clear understanding that the impacts on the freeways are not only being caused by the County, but cities within the County are contributing their "fair share" of impacts to the system.

It is understood that the County has continued to process and approve land development requests, such as specific plans and large tentative tract maps, while the RCIP planning effort has moved forward. To do otherwise would constitute a development moratorium.

S-4 Existing land use for unincorporated Riverside County and cities was inventoried for use in quantifying build out development potential. See Tables 2.A, 2.B, and 2.C, Riverside County Integrated Project Existing Setting Report, March 2000, regarding estimates of existing land use within cities and unincorporated Riverside County. Population, dwelling unit, and employment forecasts for the region are based on 2001 RTP SCAG forecasts derived from the General Plans of the cities and counties in the SCAG region, including Riverside, Orange, and San Bernardino Counties. Assessment of impacts that are not site-specific (such as traffic, air quality, and noise) are based on traffic model forecasts from SCAG's RIVSAN and CVATS models, also based on the regional forecasts. The disposition of the CETAP corridors are still in flux. What was the locally preferred alternative is no longer the locally preferred alternative. Regardless, the analysis in the Draft EIR includes scenarios both with and without the most likely implemented CETAP corridors.








Response to Letter T: City of Moreno Valley

T-1 Figure 4.2.2 from the Draft EIR is based on data detailed in the Existing Setting Report. The Existing Setting Report (incorporated by reference into the Draft EIR) identified Riverside County land use characteristics as they existed at the start of the RCIP process. When a large study is contemplated on something that is perpetually changing, a certain limit has to be set. Mapping of farmlands in the State is conducted every two years. At the time the Existing Setting Report was compiled, statistics from the 1998 update had not been released by the State; therefore, 1996 data was utilized. Subsequent to the public release of the Existing Setting Report, farmland mapping has been completed for the 1998 and 2000 mapping periods. Based on the 2000 Land Use Conversion Report, since 1996, the amount of Prime, Unique, and Statewide Important farmland in the County has decreased by 17,772, 390, and 6,407 acres (10.5, 0.9, and 11.5) percent respectively.

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 adopted developments that came after the publication of this report may be reflected in the General Plan map at a future date. This can be accomplished with a Technical Amendment, which involves changes in the General Plan of a technical nature, including technical corrections discovered in the process of implementing the General Plan. Technical amendments may include the following:

• Corrections to statistics;

• Changes in spheres of influence and city boundaries;

• Appendix information useful in interpreting the General Plan but which does not change the General Plan's intent;

• Mapping error corrections;

• Editorial clarifications that do not change the intent of the General Plan; and/or

• Changes in Unincorporated Communities or Communities of Interest.

T-2 The Existing Setting Report, which is incorporated by reference into the proposed General Plan EIR, contains data for Riverside County dams. This data was obtained from the National Inventory of Dams (2000), based on 1998-99 data submitted by local agencies. The hazard types included were defined by the National Inventory of Dams. On page 5.4-14 of the Existing Setting Report there is a listing for Pigeon Pass Dam/Poorman's Reservoir, which shows a high hazard potential. Baseline information used for the analysis was based on the best available information regarding the existence of faults in the area. If the City has different information, this information can be submitted to the County for review and consideration.

T-3 While the City of Moreno Valley may determine fault hazard areas and establish fault protection measures within its corporate limits, it may not require other jurisdictions to alter hazard areas or protection measures identified to reduce potential impacts associated with hazard areas outside its jurisdiction. The County of Riverside has determined that such a fault hazard area exists. As faults do not respect municipal boundaries, revision of Figure 4.10.1 to exclude the fault hazard area within the City would present an inaccurate representation of fault hazard areas as identified by Riverside County. The Commentor is correct in stating that Mitigation Measure 4.10.1A does not apply within the City of Moreno Valley.

T-4 The City of Moreno Valley is empowered to identify hazard areas within its municipal boundary. Baseline information used for the analysis was based on the best available information regarding the existence of faults in the area. In addition, the geotechnical report prepared for the project identified hazards that exist within the study area. Some of the factors that contribute to liquefaction include water-saturated materials including soil, sediment, and certain types of volcanic deposits. Where such a hazard area exists within the County of Riverside, the County's determination shall prevail. As such, no modification of figures in the Draft EIR is required.

T-5 Refer to response T-4.

T-6 Pigeon Pass Road has been included in the Circulation Element south of the "core alignment" developed for the Moreno Valley to San Bernardino Corridor. The section of Pigeon Pass Road north of the core alignment was taken out of the Circulation Element pursuant to a General Plan amendment associated with the Spring Mountain Ranch project in 2001. The CETAP corridor study of the Pigeon Pass Road connection to Main Street is yet to be completed. If this option were found to be viable as a result of the study, it may be included in a future General Plan Circulation Element amendment.








Response to Letter U: City of Corona

U-1 The County transmitted three copies of the Draft EIR to the City of Corona by overnight mail; they were signed for at 9:36 a.m. on August 20, 2002, by a person representing the City. The documents were addressed to the City Manager and the Public Works Director. The close of the 45-day public comment period was October 4, 2002.

U-2 The Commentor states that the alternative analysis for the Density Bonus Alternative does not contain enough information for adequate examination. With this alternative, a 100-percent density bonus for residential development would be allowed in the community centers and up to a 50-percent density bonus would be allowed in the community development areas. Therefore, this alternative would contain a net increase in residential development within unincorporated areas that are already designated for high densities. This alternative would represent (as compared to the proposed General Plan) a more concentrated pattern of development intensity while allowing for an increase in open space. Because the form of development under this alternative would remain unchanged, potential land use incompatibility issues would be similar to those occurring under the proposed General Plan.

The Density Bonus Alternative assumes that development would occur as largely established in the proposed General Plan, except for an allowed density bonus that would increase the intensity of community centers. The Commentor states that this alternative would create a significant number of people, cars, and homes. The Draft EIR (page 6-59) agrees with this statement and states that housing and population increases would occur at a higher rate than under the proposed General Plan. In addition, job increases would occur at the same level as under the proposed General Plan, thus creating a deficit in the jobs/housing balance.

The Commentor states that it is doubtful that traffic would be lessened. Because this alternative would increase the concentration of development, transportation/circulation impacts would be decreased. In other words, the population would be concentrated where the commercial services and jobs are located.

The Density Bonus Alternative, as analyzed in Section 6.2.6 of the Draft EIR, would allow the level of build out of the proposed General Plan, which includes parks and recreation facilities and public services. Impacts to parks and recreation and to public services would be greater than those under the proposed General Plan because of the increase in population. This statement agrees with the Commentor's contention that public services would be affected.

According to the State CEQA Guidelines (Section 15126), the discussion of environmental effects of alternatives may be in less detail than the discussion of the impacts of the project as proposed. The analysis that is presented is adequate to determine that there would be more of an impact for some resources and less for others.

U-3 Provisions in the General Plan, such as the Certainty System (detailed in Chapter 10, pages A-9 through A-16), will slow movement away from the General Plan. The jobs-to-housing balance is one factor to be considered in the Certainty System. It is unclear how the Commentor extrapolated the RHNA forecasts into the future. The SCAG forecasts for Riverside County are based upon a complex set of variables, not a simple growth factor, and cover a longer time span than the RHNA forecasts, which are limited to a five-year horizon.

The unincorporated Riverside County projections (Table 4.3.C) and the jobs-to-housing ratios (Table 4.3.D) are based upon SCAG's projections prior to implementation of the proposed General Plan. Based upon these projections, there will be a natural balancing of jobs and housing within Riverside County during the life of the proposed General Plan. Because there is no potentially significant impact, no mitigation measures are required. Additionally, build out capacity based on the land use designations within the proposed General Plan shows a jobs-to-housing balance, not a deficit. The land use designations were designed to promote the balance between jobs and housing within Riverside County. There are several policies within the Land Use section of the proposed General Plan that provide for economic development and employment opportunities and direct the development of these opportunities to compatible areas. These policies are listed on page LU-26 of the proposed General Plan.

U-4 As stated on pages 4.15-2, 4.15-5, and 4.15-6 of the Draft EIR:

Fire policies and regulations governing the unincorporated areas of Riverside County include Riverside County Ordinance No. 787, Riverside County Master Fire Protection Plan, the California Public Resources Code No. 4290, the Uniform Fire Code, and the Uniform Building Code.

Riverside County Ordinance No. 787 is based on the Uniform Fire Code, and outlines fire protection standards for the safety, health, and welfare of the citizens of the County. Among the items regulated by Ordinance No. 787 are access to a project, storage of hazardous materials, building design, water supply, and brush clearance.

The Riverside County Master Fire Protection Plan outlines the fire protection performance standards for both rural and urban areas, and establishes guidelines for facility and personnel minimum requirements.

The California Public Resources Code No. 4290 includes provisions for the protection of areas that are designated as State responsibility areas.

The Uniform Fire Code established by the International Fire Code Institute and the Uniform Building Code established by the International Conference of Building Officials both prescribe performance characteristics and materials to be used to achieve acceptable levels of fire protection.

The Riverside County standard for the establishment of a new fire station is the development of 2,000 dwelling units or 3.5 million square feet of commercial or industrial uses. Riverside County also requires the payment of mitigation fees to collect revenue for the establishment of new stations. Riverside County currently requires new development proponents to pay mitigation fees to help offset the cost of providing new fire facilities. The current Riverside County fire fees are $400.00 per single family dwelling unit and $0.25 per square foot for all other types of development.

Safety Policy 5.8 Strengthen inter-jurisdictional fire response agreements, and improve firefighting resources to keep pace with development, including construction of additional high-rises, mid-rise business parks, increasing numbers of facilities housing immobile populations, and the risk posed by multiple ignitions to ensure that:

• Fire reporting and response times do not exceed 4.0 minutes;

• Fire flow engine requirements are consistent with Insurance Service Office (ISO) recommendations; and

• The height of truck ladders and other equipment and apparatus is sufficient.

Land Use Policy 5.2 Monitor the capacities of infrastructure and services in coordination with service providers, ensuring that growth does not exceed acceptable levels of service.

Land Use Policy 9.1 Require that new development proponents contribute their "fair share" to fund infrastructure and fire facilities.

The County requires development applicants to pay established fire protection mitigation fees that are to be used by the County Fire Department to construct new fire protection facilities or provide facilities in lieu of the fee as approved by the Riverside County Fire Department. Adherence to Riverside County Ordinances, Riverside County Master Fire Protection Plan, California Public Resources Code, Uniform Fire Code, Uniform Building Code, and the policies of the proposed General Plan will reduce potential impacts to a less than significant level. Additionally, the County has a fire mitigation fee that is already imposed on new development. Therefore, mitigation measures are not required.

U-5 The Commentor objects to the determination of no significant impact to Parks and Recreation, stating that the Quimby Act enabling ordinances are insufficient mitigation. The comment is a reflection of the Commentor's opinion, and is not substantiated by evidence. The General Plan contains policies that are aimed at providing adequate parks and recreational resources to the population, such as Open Space Policy 20.4, which provides for the "needs of all people in the system of County recreation sites and facilities, regardless of their socioeconomic status, ethnicity, physical capabilities or age."

In addition, County Ordinance 659.6 requires that new development pay a development impact fee that is to be used for the purchase of community parks and facilities, regional multi-purpose trails and regional parks.

U-6 Page 20 of the Temescal Canyon Area Plan, Volume I of the General Plan, contains policies that require development within one-half mile of the El Sobrante Landfill to be compatible with the landfill as determined by the County of Riverside Department of Waste Management and the Planning Department. The polices are listed below.

TCAP 2.1 Require development proposals on land within one-half mile of any outer boundary of this policy area to be transmitted to the County of Riverside Department of Waste Management for review and comment at the initial phase of the development review process.

TCAP 2.2 Require that development proposed within one-half mile of the El Sobrante Landfill is inherently compatible with the landfill as determined by the County of Riverside Department of Waste Management and Planning Department and in accordance with the guidelines below:

A. The following uses may be considered compatible with these facilities:

1. Most types of industrial development;

2. Agricultural uses;

3. Grazing;

4. Open space;

5. Mining;

6. Sanitary landfills; and

7. Rural residential development.

B. The following uses are clearly incompatible with these facilities:

1. Public facilities such as schools and uses that involve public assembly;

2. Industrial development using sensitive equipment or conducting manufacturing operations, which would be negatively affected by dust particles, noise, odor, and truck traffic resulting from the operation;

3. Commercial development, which would be negatively affected by dust particles, noise, odor, and truck traffic resulting from the operation; and

4. Community Development Foundation Component-type residential uses.

C. Prohibit residential densities greater than 1 dwelling unit per 2.5 acres.

Land use compatibility with landfills was considered when making land use designations. A one-half mile setback or more from landfills is required under the General Plan, which exceeds the 900-foot setback required by Waste Management. The Temescal Canyon Area Plan reflects the implementation of these policies.

U-7 As explained in the Draft EIR pages 4.17-8 and 4.17-9, SB 221, SB 901, and SB 610 do not tackle the difficult task of analyzing water availability for a project the size of the State of New Jersey (Riverside County) over a 40-year period. The Metropolitan Water District (Metropolitan) is one of the primary water providers for Riverside County. While it does not provide water to the entire County, it covers the majority of the County, particularly western Riverside County, in which increased development is planned. In February 2002, the Metropolitan Water District issued a draft report, Report on Metropolitan Water Supplies, that stated that the Metropolitan Water District has enough water to provide its service area with adequate water for the next 20 years. The Metropolitan Water District used 2020 SCAG projections in its analysis. The Riverside County General Plan is consistent with SCAG's 2020 projections; however, there is no information available for water availability to the year 2040. To the extent possible, water sources have been identified in the EIR. Further details pertaining to water supply will be worked out by water agencies as the County develops and as water sources are identified. Impacts to water supply were analyzed to the best of the County's ability, given the size of the County, the number of water agencies operating within the County, and the number of possible water sources.

Section 4.17.1 (page 4.17.2) of the Draft EIR has been revised to include the following text:

The chief challenge to obtaining, conveying, and managing water in Southern California is its location in an arid region and the general lack of local water sources adequate to support the ever-increasing population and growing economy. An intricate network of canals, aqueducts, reservoirs, and distribution lines allows for the continued flow of water from local, as well as more distant sources. Connections between the myriad agencies and private entities that supply and manage the flow of water to Southern California is equally complex. The interaction between the various State, regional, and local agencies tasked with the planning, maintenance and oversight of a water supply system that results in the continued flow of water to the region is an involved and dynamic process.

The State Department of Water Resources (DWR) is charged with the management of water resources within the State. The DWR cooperates with other agencies to benefit the State and to protect, restore, and enhance natural and human environments. Regionally, more than 300 public agencies and private companies provide water on a retail basis to approximately 17 million people living in a 5,200-square mile, six-county area. Some of these, such as Metropolitan Water District of Southern California (Metropolitan), act as regional wholesale providers, while others may be substantially smaller, providing water to a limited area or number of connections. Providing a safe, reliable, and cost-effective water supply requires cooperation between public and private water agencies that emphasizes a regional approach to the water supply problem. Difficulties in identifying, securing, and maintaining a safe, cost-effective, and reliable water supply are compounded by the arid climate, past and current land use practices, projected population growth, and changing governmental regulations. Further complicating this process is the fact that the region spans different watershed areas, which themselves are further divided into smaller sections by internal surface water drainage areas and groundwater basins. In addition to the physical obstacles that must be surmounted, water supply planning and the delivery of water from the source to the tap is overseen by State, regional, and local agencies, which may or may not have a common perception of the water supply or water need.

The supply and management of water resources must take into account not only the flow of water to the spigot, but the ancillary issues involved (i.e., impacts resulting from the use of a particular water source). Besides human consumption, water is utilized beneficially for habitat management, recreation, groundwater recharge, and the maintenance of water quality. Water supply planning must not only consider surface and groundwater water supplies, but water derived from conservation practices and the use of innovative and alternative sources. Such practices such as desalinization and the use of reclaimed water for irrigation and other non-consumptive purposes, which currently supply only a fraction of region's water inventory, may increase in importance in future years. Water planners must plan for climatic conditions that may or may not occur in the future (such as drought years), as well as comply with the requirements mandated by State and local authorities (which may be amended or revised per the changing inclinations of legislators).

While State and regional water demands can be projected based on the demographic and economic variables in the forecast by regional authorities, the use of different planning horizons may complicate or confuse the water planning. The use of different "baseline" projections or planning horizons by local water agencies in their planning documents and the focus on a more precisely defined identification of water supply and demand (versus a more broad regional, or even more broad Statewide approach) may render the analysis of local and regional water supply and demand impacts more difficult.

Coachella Valley Water District

The Coachella Valley Water District (CVWD), encompassing 995 square miles, extends from San Gorgonio Pass to the Salton Sea. The district provides water to approximately 284,700 residents, 72,900 acres of irrigated farmland, and a variety of commercial, resort, and industrial users. Services provided by the District include: the delivery of domestic and irrigation water; water conservation; wastewater reclamation and recycling; stormwater protection; agricultural drainage; groundwater recharge; and water education. In addition to groundwater supplies, the District obtains water from the State Water Project, and Metropolitan. The District's SWP entitlement totals 23,100 af/yr. The District does not receive this allotment directly, rather it is delivered to Metropolitan, which in turn delivers to the District an equal amount of Colorado River water.

Total water demand in 1999 was approximately 669,000 af/yr of which 310,000 was for urban uses and 359,000 was for agricultural uses. Groundwater provided approximately 56 percent of the District's 1999 demand. Development within the District has contributed to the continued decline of groundwater resources.

As outlined in Coachella Valley Water Management Plan (September 2002), the District's goal is to assure adequate supplies of safe, high-quality water at the lowest cost to District users. The Plan estimates states that under current conditions, total groundwater overdraft in the District will total 136,700 af/yr in 2035. The Plan states the preferred water management alternative for the district includes water conservation, increased delivery of water supplies to the Coachella Valley, and a combination of source substitution and groundwater recharge.

Metropolitan Water District

Water in Southern California is provided through a complex system of infrastructure operated by many institutional entities. More than 300 public agencies and private companies provide water on a retail basis to persons and businesses within the Southern California region. Metropolitan is the primary wholesale provider of imported water for the region, serving 26 member agencies, which in turn serve customers in more than 145 cities and 94 unincorporated communities. Metropolitan is the primary water provider for the majority of the areas that would be developed within the County pursuant to the General Plan. Through its Integrated Resources Plan (IRP), a key objective of Metropolitan is to, "... have the full capability to meet full-service demands at the retail level at all times." To meet this objective, Metropolitan, its member agencies, and retail providers must closely coordinate the development of imported and local water resources to meet retail demands in an efficient and affordable way. Key elements of Metropolitan's strategy for achieving this goal include: maintaining a portfolio of diversified water supplies; securing reserves to mitigate supply uncertainties; and maintaining a rate schedule that provides financing capabilities to support the IRP.

Water demands on Metropolitan are projected according to four key parameters: retail demands, local replenishment demands, local supplies, and Metropolitan system storage requirements. To forecast retail demand, Metropolitan utilizes a forecasting system that relates water use to independent variables such as population, housing, employment, income, price, weather, and conservation. The demographic and economic variables in the forecast are based on the Southern California Association of Governments (SCAG) Regional Transportation Plan and the San Diego Association of Government (SANDAG) 2020 forecast. These demographic projections are supported by environmental impact reports and based on city, county, and regional general plans.

Water demands on Metropolitan are calculated as the retail demands plus local replenishment demands less local supplies. Based on the RUWMP, demand on Metropolitan will total 1.9 million acre feet in 2002, increasing to 2.3 million acre feet in 2020. Based on existing supply capabilities, Metropolitan can meet 100 percent of its member agencies projected supplemental demands over the next 20 years in average and wet years; over the next 15 years in multiple dry years; and over the next ten years in single dry years. With the addition of all water supplies that are under development, Metropolitan will have the capability to meet 100 percent of its members agencies' projected supplemental demands over the next 20 years even under a repeat of the worst drought; while providing a 15 to 20 percent reserve supply, and making available sufficient water deliveries for the replenishment of local and regional storage.

Page 4.17-15 of the Draft EIR (after Table 4.17.B) has been revised to include the following:

In addition to Riverside County, the South Coast and Colorado Hydrologic Regions encompass areas outside the boundaries of Riverside County. While the DWR water projections presented in Tables 4.17.A and 4.17.B are useful, they do not reflect conditions pertaining specifically to Riverside County alone. Riverside County is served by a myriad of water districts with boundaries spanning multiple counties. Thus, it is not feasible to obtain an estimate of the existing water use within Riverside County, as the districts do not report based on uses per County. The following discussion provides an estimate of future water demand required to support development envisioned in the proposed General Plan. Thus, future water demand is estimated here based on generation factors for different land uses.

Agriculture

In the absence of readily-available generation rates for agricultural uses, a generation factor was calculated based on the composition of crops in Riverside County using crop water demand information from San Diego County. Agricultural water demand for different crops in San Diego were calculated based on the acres of each type of crop (in 1999) presented in Table 3-2 (Citrus/Subtropical, Fruits and Vegetables, Avocados, Flowers/Nurseries, Corn and Field Crops, and Pasture) and the water demand (in 1999) for each crop type presented in Table 8-2 of the Agricultural Water Management Plan (prepared for the San Diego County Water Authority, Valley Center Municipal Water District, Mission Resource Conservation District, and Member Agencies, accessed on the Internet at http://www.sdcwa.org/manage/awmp.phtml).

The following annual rates were determined for each category:

Citrus/Subtropical4.32acre-feet (af) per acre (ac)
Fruits and Vegetables5.67af/acres
Avocados4.14af/acres
Flowers/Nurseries6.11af/acres
Corn and Field Crops5.81af/acres
Pasture3.77af/acres


The primary agricultural uses are field crops (187,000 acres), citrus crops (30,000 acres), and vegetable crops (41,700 acres). To generate an approximate water demand rate for agricultural lands in Riverside County, the rates generated for citrus/subtropical, field crops, and fruits and vegetables in San Diego County were averaged in proportion to their occurrence in Riverside County. Additionally, an extra 10 percent was added to the generation factor to account for the dryer climate in Riverside County. The resulting water demand generation rate for agriculture in Riverside County is 6.17 af/ac/yr.

As stated in the Existing Setting Report, Riverside County supported approximately 339,000 acres of agricultural land use in 1998. Thus, the estimated water use for agriculture in 1998 was 2,091,630 af. At build out, Riverside County is estimated to support approximately 204,842 acres of agriculture, resulting in a demand in 1,263,875 af/yr.

Open Space

This category includes natural and recreational areas. The calculation assigns the ‘non-turf' water demand factor to natural lands and the ‘turf' factor to recreational lands. In 1998, Riverside County had approximately 837,500 acres of natural lands (not including ‘vacant' lands) and approximately 27,000 acres of recreational lands. Using a factor of 1,571 gallons per acre (Federal Water Use Indices, Federal Emergency Management Program, 2003), recreation uses would require approximately 47,491 af/yr.

Residential

This category includes single- and multi-family residential areas. The demand factor is based on dwelling units and is applied uniformly. Section 9.0 (Public Services and Facilities) of the Riverside County Existing Setting Report, identifies water consumption factors utilized by various water utilities throughout the County. Averaging the water consumption factors of nine water utilities throughout the County (Eastern Municipal Water District, Western Municipal Water District, Western San Bernardino County Water District, Lake Elsinore Water District, Lee Lake Water District, Rancho California Water District, Lake Hemet Water District, Pinyon Pines Water District, and Coachella Valley Water District) resulted in a water demand of 902 gallons per day per residential unit, which equals 329,230 gallons (or 1.01 ac/ft) per year.

At build out of the General Plan, 563,376 dwelling units would be located within unincorporated areas of the County. Using a demand factor of 1.01 af/yr per residential unit, this would result in a residential water demand of approximately 569,000 af/yr.

Industrial, Commercial, and Public Facilities

This category includes light and heavy industrial, mineral extraction; commercial, office, and business park; and public facility uses. Depending on the unique demands of each use, the water demand within the industrial, commercial and public facility use varies substantially. As derived from Cucamonga County Water District factors, commercial/office uses were assigned a demand factor of 3.5 af/ac/yr; industrial uses were assigned a demand factor of 0.97 af/ac/yr; and public facilities were assigned a factor of 2.4 af/ac/yr. Utilizing land use acreage totals summarized in Table 3.B, the 18,802 acres of commercial uses planned at build out of the proposed General Plan would require 65,807 af/yr; the 20,658 acres of commercial/mineral extraction uses would require 20,038 af/yr; and the 20,075 acres of public facility uses would require 48,180 af/yr.

Combined, the land uses in unincorporated areas of the County envisioned under the proposed General Plan would require approximately 2,008,818 acre feet of water per year. While Metropolitan and non-Metropolitan water purveyors have identified sufficient water supplies to 2020, forecast of water supply beyond the Year 2020 is speculative. In the absence of a definitive identification of future water supply, potential impacts associated with water supply and demand must be considered significant and unavoidable.

The following text has been added to Section 4.17 on page 4.17-15, to the end of the paragraph, which precedes Table 4.17.B:

The proposed General Plan includes policies (discussed below) that require water management strategies, including conservation, collection of information, decreasing demand, outreach and education programs, assurances of adequate groundwater recharge areas, and water supply monitoring. No adverse impacts are anticipated to result from such strategies, as they would reduce overall water demand and, in some instances, supply additional sources of water for irrigation and other non-potable uses. Infrastructure projects are likely to be proposed both by the County and by water suppliers. The construction of additional water storage facilities, as well as water reclamation plants, would be subject to additional environmental analysis to determine on-site impacts. These additional water sources would not further deplete groundwater supplies or increase reliance on imported water. Securing additional imported water is another way to increase the water supply. This water could come from existing imported sources (i.e., the Colorado River or other State Water Project sources), or could come from as-yet unnegotiated sources. The impacts of drawing water from sources outside the region would require further analysis if such proposals were undertaken. They could include impacts to biological resources (i.e., from decreased water flow in rivers), impacts to other jurisdictions that rely on that water source, growth inducing impacts, and other environmental and economic impacts.

U-8 Under CEQA, an EIR must evaluate projects as they are proposed. Since the proposed General Plan did not include a bi-County corridor connecting Riverside County to Orange County, such a corridor was proposed as Mitigation Measure 4.16.1C, which clearly commits the County to pursue the corridor. The mitigation measures reads:

"4.16.1C The County shall add a transportation corridor to its General Plan Circulation Element, if feasible, showing a connection between I-15 and the Orange County freeway system, and complete that portion of the CETAP program involving the bi-County corridor to Orange County as a means of relieving traffic congestion along State Route 91. The transportation corridor shall provide an alternative route for traffic on State Route 91 between I-15 and State Route 241."

As noted in the Draft EIR, implementation of Mitigation Measure 4.16.1C would result in the construction of a transportation corridor through the Cleveland National Forest between Riverside and Orange counties, connecting to the existing highway system in Orange County. Thus, delineation of a route for this corridor requires approval of the US Forest Service, the local agencies within Orange County through which the corridor would run, and the Orange County Transportation Authority (OCTA). Because the San Mateo Canyon Wilderness Area, where the corridor would not be permitted, is located south of SR-74 in the Cleveland National Forest, the corridor it is assumed that the corridor would be built north of SR-74 and south of SR-91 from Riverside to Orange Counties.

Such basic questions as where would a bi-County corridor connect to highway systems in Riverside and Orange counties and would the corridor be located above ground, consist of a tunnel, or a combination of both are the subject of a cooperative planning program that needs to be completed prior to incorporating this bi-County corridor on the Riverside County Circulation Element map. To that end, Riverside County and the Riverside County Transportation Commission have committed more than $5 million for planning and engineering studies for the corridor. The recent approval of AB 1010 (Correa) future commits Riverside County to a joint planning program with Orange County for the corridor. Until the Forest Service and Orange County authorities commit to the concept of the corridor and planning studies are undertaken, the feasibility of constructing a bi-County corridor to Orange County cannot be known, and it would be inappropriate to include it in the Riverside County General Plan Circulation Element.

U-9 Refer to responses U-8 and U-10. An analysis with no further development in the County, only the cities, was performed revealing that no better than LOS F conditions would be achieved. As a result, it was conceded that the problem is exclusively with the freeway system. Nonetheless, Riverside County does not accept that LOS F conditions on the SR-91 freeway are a foregone conclusion. The proposed Riverside County General Plan makes a substantial effort to improve the balance of jobs and housing within County territory as a means of reducing impacts on the primary commuter routes connecting Riverside County to Orange and Los Angeles Counties.

In addition to improving jobs/housing balance and as noted in response U-8, above, the County is pursuing bi-County corridors connecting Riverside County to Orange County and San Bernardino County as a means providing relief to crowded freeways. Riverside County, the Riverside County Transportation Commission, and others are also undertaking a number of other initiatives to ease traffic congestion along the SR-91 freeway:

• With its purchase of the 91 freeway toll road complete and the "noncompete" clause eliminated, the Riverside County Transportation Commission (RCTC), OCTA, and Caltrans are starting an ambitious series of projects that will help reduce congestion and improve traffic flow on the 91 freeway. Proposed improvements include fixing freeway bottlenecks and choke points, adding additional lanes and improving interchanges.

During spring 2003, OCTA and Caltrans plan to break ground on an additional auxiliary lane on the westbound 91 between the Riverside County line and the Coal Canyon exit.

• Starting this fall, OCTA will introduce new Express Bus service between Riverside and Orange Counties, offering a new alternative to commuters who use the 91 Freeway.

U-10 The principal traffic impact in the City of Corona of the build out of the Riverside County General Plan is on I-15. There is very little impact on SR-91 or SR

71. Even on I-15, the contribution of the build out of the County General Plan to traffic growth on I-15 in Corona is a maximum of 10 percent of total traffic volume at build out. It is correct that SB 45 transferred control of much of the transportation project programming and funding to the County commissions that regulate traffic congestion; however, this change in control relates to how transportation improvement projects are selected at the county level. There has not been a change in how freeway projects are funded - they are funded exclusively by Federal and State gas tax monies that are distributed by Caltrans to the appropriate regional transportation planning agency. There is a substantial amount of funding in the recently passed (November 2002) Measure A extension devoted to freeway improvements in the Corona area (SR-91, SR-71, and I-15).

The Circulation Element predates the MOU between the City and County, which calls for City/County coordination. The County's General Plan contains the following policy in Chapter 4 that addresses the inconsistency issue between City and County roadways that cross jurisdictional boundaries. The policy states:

• 7.6 Collaborate with all incorporated cities and all adjacent counties to implement and integrate right-of-way requirements and improvement standards for General Plan roads that cross jurisdictional boundaries. Detailed procedures have been developed and include the following:

• For development under the County jurisdiction but within the sphere of influence (SOI) of a city having roadway standards different from the County, city and County staff will cooperate and agree on a reasonable choice of design standards for the particular circumstances involved, and negotiate logical transitions from city to County standards.

• In general, for such development under County jurisdiction but within the SOI of an incorporated jurisdiction, city standards should apply if the staffs concur that annexation to the City will logically occur in the short to intermediate range future. Where annexation seems doubtful into the long-term future, County standards should apply.

• Transition areas at meeting points of roadways designed to differing city and County standards or differing functional classifications should be individually designed to facilitate satisfactory operational and safety performance. Further, the County should update the road standards to reflect the intent of this policy and standards agreed upon by the County and other local agencies.

U-11 Section 4.1, Assumptions, on pages 4.1-1 through 4.1-4 provides the methodology used in the Draft EIR to extrapolate dwelling units and population projected with the proposed General Plan. In addition, Appendix E of the General Plan provides a detailed analysis of the methodology used to extrapolate dwelling units, population, and employment. The Commentor's method of extrapolating the RHNA numbers into the future is not clear. Assuming consistent growth over time is not a valid assumption. The SCAG forecasts for Riverside County are based upon a complex set of variables, not a simple growth factor, and cover a longer time span than the RHNA forecasts, which are limited to a five-year horizon. Thus, SCAG forecasts form the basis of the analysis.

U-12 Refer to response U-2.

U-13 Refer to response Q-2.

U-14 The response to comments will be sent directly to the Planning Director with the City of Corona 10 days prior to certification of the EIR as mandated by CEQA Section 21092.5(a).








Response to Letter V: Morongo Band of Mission Indians

The General Plan and its policies, and by association the General Plan EIR, do not apply to Indian lands.

V-1 Thank you for your comments on the Draft EIR. No further response is necessary.

V-2 Pursuant to the Commentor's request, the County will amend the General Plan to include the Morongo Indian Reservation as a community in the Pass area.

V-3 The letter is providing comments on the Draft General Plan and not the Draft EIR.

V-4 The General Plan contains the following polices that would protect downstream properties from flood hazards.

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.

Safety Policy 4.6 Direct flood control improvement measures toward the protection of existing and planned development.

Safety Policy 4.8 Require development in the floodway fringe, following a site-specific hydrology study, to implement measures that avoid erosion or sedimentation on adjacent land, or water flows or velocities, that would be detrimental to the health and safety of persons or adjacent property, or adversely affect adjacent wetlands or riparian habitat.

Safety Policy 4.9 Minimize encroachment of development into the floodway fringe to convey floodwater without property damage and risk to public safety.

Safety Policy 4.11 Require all projects anywhere in the County to mitigate any impacts that they may have on the carrying capacity of the local storm drain system.

Additionally, the adherence to Riverside County Ordinance 458 will reduce flooding impacts to a less than significant level. Riverside County Ordinance 458 states that whenever an application for a permit involves land within a flood zone and the existing land use does not provide for a specific recommendation by a flood control district, the development must receive approval from the Riverside County Flood Control District and meet very stringent requirements to ensure that flood hazard impacts will not occur.

V-5 The comment is stating that there should be a requirement that any proposals for airport usage or development be submitted to the Morongo Band of Mission Indians for review. This comment refers to the Draft General Plan, where policy statements can be made, and not the Draft EIR. It should be noted that any development proposals will be reviewed by the Airport Land Use Commission. The function of the ALUC is to make recommendations regarding the need for height restrictions on buildings near airports; make recommendations for the use of the land surrounding airports to assure safety of air navigation and the promotion of air commerce. The ALUC will also consult with the Morongo Band of Mission Indians on these development proposals before making its recommendations on the project. Furthermore, the Banning Municipal Airport is under the jurisdiction of the City of Banning and not the County of Riverside.

V-6 In general, the County's approach is not to apply land use designations to tribal lands within the County. In those cases where it is determined that tribal lands are incorrectly depicted within the General Plan, they will be corrected.

V-7 The traffic analysis anticipated substantial growth in the Pass Area, including growth on tribal lands. Additional interchanges or interchange improvements have been anticipated in the analyses.

V-8 This roadway indicates how continuity could be maintained within the roadway system between Banning and the unincorporated County. The County uses a similar approach when showing roadway connections adjacent to incorporated Cities. It is not intended to identify County jurisdiction.

V-9 Pursuant to the Commentor's request, the County will amend the General Plan text to indicate that State Route 243 passes through the Morongo Indian Reservation.

V-10 Pursuant to the Commentor's request, the County will amend the General Plan text regarding State Route 243.

V-11 Pursuant to the Commentor's request, the County will review and amend, as appropriate, the General Plan to indicate the proper jurisdictional boundaries and land use designation in the Outlet Mall area.

V-12 This comment is suggesting changes to land use designations. Land use designations are implemented in the General Plan and not 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 W: Agua Caliente Band of Cahuilla Indians

W-1 The County in its formulation of the proposed General Plan considered all existing and proposed land uses on a multitude of jurisdictions, including the Bureau of Land Management, U.S. Forest Service, 24 incorporated cities, Caltrans, and the individual Native American Tribes. The County took the Tribe's comment on the NOP into consideration and chose not to address the effects of the County's proposed General Plan on individual Native American Tribes separately in the Draft EIR.






Response to Letter X: Palo Verde Irrigation District

X-1 The Draft EIR was available at both Kinko's in Palm Desert and Riverside Blueprint in Riverside for purchase after August 20, 2002. The Commentor did not provide a date as to when he called the County or the reproduction companies for the information. Also, the RCIP web site www.rcip.org had the location, phone number, and contact person for both Kinko's and Riverside Blueprint. The County regrets if the Commentor was given incomplete information. Copies of the General Plan and Draft EIR were available at the Riverside County Library in Blythe and 19 other libraries and 5 County buildings for review. Copies are also available on CD-Rom at no charge.

X-2 The County or its environmental consultants has a written or verbal request from the Palo Verde Irrigation District for a copy of the Draft EIR. Because the District is requesting a copy of the Final EIR, the County will transmit a copy when it is complete. The County would like to thank the District for its interest.

X-3 The following Mitigation Measure has been added to the Section 4.17, page 4.17-18, of the EIR to ensure that development in the Palo Verde Area Plan area supplied by the Colorado River meets existing legal requirements:

4.17.1E For any development within the Palo Verde Planning Area supplied with water from the Colorado River, the project applicant shall enter into a contract with the City of Needles, pursuant to the "Lower Colorado Water Supply Project" program. Evidence of such a contractual agreement shall be submitted to the County prior to the approval of any development entitlement for the project.

X-4 This area depicts the location of two parks and a wildlife area (Goose Flats Wildlife Area, McIntyre Park and Miller Park). In previous mapping efforts, the park designation "spilled" over onto the adjacent agricultural designation. The General Plan Land Use Map has been corrected to reflect the appropriate land designations.

X-5 Refer to response X-4.

X-6 As noted in Table 4.3.B the geographic locations depicted are "Planning Areas." The purpose of including this table and the incorporating text is to demonstrate the difference in population, housing, and employment between western and eastern Riverside County, not the difference between cities and unincorporated areas. Similarly, this table was included in the County of Riverside Draft Housing Element Update (2001) for the same purpose. The point of the table was to illustrate the dramatic difference in population, housing, and employment between western and eastern Riverside County.

X-7 Figure 4.9.1 shows the 100- and 500-year flood hazard zones for the entire County. Because of the scale of the map, exact locations of flood zones may be difficult to see. For this reason, within the Palo Verde Valley Area Plan of the Riverside County General Plan, Figure 7 on page 39, shows a more specific graphic of flood hazards in the Palo Verde Valley Area. As shown, the entire Palo Verde Valley is not within the flood hazard zone. Specifically, only the eastern portion of the Palo Verde Valley is within the 100-year flood zone.

X-8 Comment noted. The requested revision will be made by the General Plan team in revisions to land use and circulation maps for the Palo Verde Area Plan.












Response to Letter Y: Rancho California Water District

Y-1 Please see Response U-7. To the extent possible, water sources have been identified in the EIR. Further details pertaining to water supply will be worked out by water agencies as the County develops and as water sources are identified. Impacts to water supply were analyzed to the best of the County's ability, given the size of the County, the number of water agencies operating within the County, and the number of possible water sources.

Y-2 Refer to response Y-1.

Y-3 Refer to response Y-1.

Y-4 Refer to response Y-1.

Y-5 Section 4.15.4.2, pages 4.15-19 through 4.15-20 of the Draft EIR has been revised as follows in response to the Commentor's request:

The County of Riverside has ordinances that strictly regulate the construction and maintenance of septic tanks. Section 8.124.030 of the County of Riverside Government Code states that all septic facilities require written approval for construction from the County Health Officer. Approval for septic tanks require detailed review and on-site inspections, which include a scaled, contoured plot plan, a soils feasibility report that adequately evaluates soil percolation, a special feasibility boring report (groundwater and/or bedrock), and an engineered topographical map.

Additionally, the U.S. Environmental Protection Agency (EPA) has established standards governing the placement of septic systems in the proximity of water supply wells. The EPA's "Zone A" is classified as a potential area of direct microbiological and chemical contamination based on an estimated two-year time of (contaminant) travel within an aquifer from the wellhead to the potential source of contamination. Waste discharges from conventional septic tank/subsurface disposal systems may adversely affect both the quality and beneficial uses of the water and/or violate local, regional or State water quality standards. As excerpted from EPA's Design Manual On-Site Wastewater Treatment and Disposal Systems, "... State Codes that specify 100-foot separation distances between convention subsurface wastewater infiltration system treatment units and down-gradient wells or surface waters should not be expected to always protect these resources from dissolved, highly mobile contaminants ... published data indicate that viruses that reach groundwater can travel at least 220 vertical feet and 1,338 feet laterally in some porous soils and still remain effective." Any such degradation of water quality would be a potentially significant impact.

....

Effectiveness of Proposed General Plan Policy Implementation of the proposed General Plan policies, and existing County regulations related to wastewater, and the following measure will reduce potential wastewater impacts resulting from future development to a less than significant level. would reduce the effects of future development to less than significant and no further mitigation is required.

Mitigation Measures

4.15.4A Conventional septic tanks/subsurface disposal systems shall be prohibited within any designated Zone A of an Environmental Protection Agency wellhead protection area. Where a difference between Riverside County and EPA septic tank setback distance requirements exists, the EPA standard shall apply.

Y-6 Refer to response Y-5.

Y-7 Refer to response Y-5.

Y-8 The Water Conservation in Landscaping Act requires local agencies to adopt a water efficient landscape ordinance. Local water efficient landscape ordinances must be consistent with the model ordinance drafted by the State. Where such an ordinance has not been adopted, the policies and regulation contained in the model ordinance shall apply. Mitigation Measure 4.17.1D requires the County to enforce compliance with Federal, State, and local water conservation standards, which will result in the ordinance being amended. The County is required to adhere to these same standards, including applicable provisions of the Water Conservation in Landscaping Act.

Y-9 The Draft EIR includes Mitigation Measure 4.17.1C ,which states that potable water shall not be used for non-potable uses where recycled water is available. The availability of recycled water within portions of the Rancho California Water District service area is noted.








Response to Letter Z: Southern California Association of Governments

Z-1 The County concurs with the Commentor. Thank you for your comment.

Z-2 Table 4.3.B, which includes the 1997 employment totals, on page 4.3-2 of the Draft EIR was taken from the adopted County of Riverside Housing Element Update, from June 15, 2001.

Z-3 The County concurs with SCAG's findings. Thank you for your comment.

Z-4 The County concurs with SCAG's findings. Thank you for your comment.

Z-5 Refer to response Z-2.

Z-6 The County concurs with the Commentor. A mitigation and monitoring program is provided in Section 4.0 of the Final EIR in accordance with State CEQA Guidelines Section 15097.




Response to Letter AA: Old Ranchers Canning Company

AA-1 The Commentor is requesting a meeting with County staff to discuss land use concerns of the proposed General Plan. Jerry Jolliffe of County staff met with him several times. 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 BB: J.B.J Ranch

BB-1 The Commentor indicates that vegetation mapping for the 160-acre J.B.J Ranch property is incorrect and that there is a resulting potential for error in the various environmental analyses of the General Plan. The vegetation map used for the analysis is a composite of the best available data. Geographic Information System (GIS) databases recording land cover were obtained from the California Department of Fish and Game (CDFG), the Bureau of Land Management (BLM), and the County of Riverside. The J.B.J Ranch property is included in the database cover obtained from the County of Riverside that was prepared in 1995 by Pacific Southwest Biological Services and KTU+A. The vegetation map is limited by the time frame within which the data were assembled as well as the precision of those data. The vegetation map represents conditions at the time the data were assembled, in this case 1991 through 1995; the current extent and character of vegetation may differ from that depicted on the vegetation map. If a development proposal is submitted in the area of the Ranch, site-specific information will be gathered and considered for that proposal.

Comments regarding the MSHCP should be directed to that document. 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 MSHCP.

BB-2 The Commentor assumes that the MSHCP is a part of the General Plan EIR. Because there is the possibility that the MSHCP may not be adopted at all or may be changed appreciably, the provisions of the CVAG and Western Riverside County MSHCPs were not incorporated within the General Plan EIR. Thus, the General Plan EIR does not contain an analysis of the MSHCP impacts, economic or otherwise. The General Plan EIR is an analysis of the impacts of implementation of the General Plan. Pertinent policies, however, were transferred wholesale to the General Plan EIR to mitigate biological resource impacts of the General Plan.

The Riverside County General Plan is a regional planning effort intended to meet regulatory and other obligations including:

• 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 General Plan is not intended to be a surrogate MSHCP.










Response to Letter CC: Wintec

CC-1 The County has amended the language in Section 4.4.1, Page 4.4-3, Table 4.4.A of the Draft EIR as follows:

12: San Gorgonio PassBordered by the San Bernardino and San Jacinto Mountains; small town urban uses; San Gorgonio River; Morongo Band of Mission Indians Reservation lands, wind energy facilities, large-lot rural residential and agricultural uses; desert and hillside vegetation.

CC-2 Open Space Policy 10.1 is a policy proposed by the County in its General Plan and is not the recommendation or a mitigation of the preparers of the EIR. The County decision-makers will take into consideration the Commentor's comments in their deliberation of the General Plan. It is the County's responsibility to consider the effects of any development proposal on the human as well as the natural environment when approving a project. The same consideration for wind energy facilities will be taken as for any development proposal brought forth for approval in the County.

CC-3 Wind energy facilities do generate energy, and may have other impacts depending on location. These impacts may include noise (particularly from vibrations) and adverse effects on visual resources. The Commentor's opinion that they have no adverse impacts is noted. It should also be noted that nowhere in the Draft EIR is it stated that wind energy facilities have a detrimental effect on the environment.

CC-4 The County will consider it in its deliberations on the General Plan, and whether to amend the policy accordingly. It is the opinion of the County that the following statement on page 4.8-7, last paragraph, is valid:

The implementation of the preceding General Plan policies and mitigation measures will result in less than significant impacts on energy resources. However, it must be noted that electricity costs to consumers will likely increase compared to past levels until additional generating capacity can be brought on-line and the cost and supply adjustment is stabilized.

CC-5 The text of the Draft EIR on page 4.13-63 does not suggest that wind energy facilities cannot comply with the Wind Energy Ordinance in the Noise Element. Although wind energy facilities are categorized as an industrial/commercial use, they are considered a low-frequency noise generator. The Commentor's disagreement with the proposed noise policy is noted.

CC-6 The Commentor's disagreement with the proposed noise policy is noted.

CC-7 If the Mission Springs Water District wastewater treatment plant were to be expanded, the District would be responsible for any existing violations with the plant.

CC-8 The complete sentence on page 5-5 of the Draft EIR states, "Because alternative energy sources such as solar, geothermal, or wind energy are not currently in widespread local use, it is unlikely that real savings in non-renewable energy supplies (e.g., oil and gas) could be realized in the immediate future. There is nothing in the statement that is not factual or discounts the wind energy facilities in the San Gorgonio Pass. County is extremely large and geographically diverse. The County cannot support the statement of the Commentor that the wind energy facilities within the Pass can serve the needs of the "entire" County and that the County will not continue in the short-term to use non-renewable resources to produce energy. The County welcomes new sources of "clean" environmentally friendly sources of energy. Until such time as alternatives forms of energy are in "wide-spread" use by the consumer, non-renewable resources of energy will continue to be depleted.

CC-9 Refer to response CC-8.

CC-10 There were over 100 letters sent on June 23, 1999, to special districts requesting facts that would be used in the Existing Setting Report. Many follow-ups were performed to clarify information or request additional data. Over 300 notices were sent of the Notice of Preparation (NOP) of the Draft EIR on May 28, 2002. The NOP was sent to special districts, State and federal agencies, cities, and others. NOP responses, some of which expressed specific desires, were used in the Draft EIR analysis. Public scoping meetings, which are an opportunity for anyone to communicate any concerns, were held on June 20, 2002, in Hemet, and on June 25, 2002, in the Coachella Valley. Almost 700 Draft EIRs were sent to those who requested a document and to special districts, State and federal agencies, cities, and others. The telephone number and fax number of the County staff were available to anyone who wanted any information or wanted to express any concerns. In addition, a web site was extensively publicized. Public notices were placed in newspapers of wide circulation along each step of the way. For more information on public notices and other steps in the process, see Section 1.0 of the Draft EIR. The lack of response to the County by the Mission Springs Water District is not the responsibility of the County. In addition, it would not be prudent of the County to accept information on a particular agency and its facilities from someone who does not represent that agency. Again, the County appreciates the Commentor's concerns; however, it is Mission Springs Water District's responsibility to mitigate an existing deficiency in its operations.

CC-11 The General Plan Existing Setting Report provided that the biological resources for the County were based on Geographic Information System (GIS) databases recording land cover obtained from the California Department of Fish and Game (CDFG), the Bureau of Land Management (BLM) and the County of Riverside. The natural communities covered by each database are shown in Table 4.2.A, of the Existing Setting Report and 4.6.A of the Draft EIR. For purposes of a natural community map for this study, natural communities were grouped into the 16 generalized natural communities listed in the leftmost column of Table 4.2.A and Tables 4.6.A and 4.6.B of the Draft EIR. This table lists generalized natural community categories used for the Natural Communities of Riverside County map (Figure 4.2.1 of the Existing Setting Report and Figure 4.6.1 of the Draft EIR) and component categories in GIS coverages available from Riverside County, the CDFG, and the Coachella Valley Associated Governments. Federal and State listed, proposed, and candidate species that may be expected to occur in these Natural Communities are listed in Table 4.2.B, in the Existing Setting Report and in Tables 4.6.A and 4.6.B of the Draft EIR (third column).

As stated on page 4.6-19 of the Draft EIR, "... The biological resources impacts discussion is primarily qualitative with some quantitative data generated through GIS analysis." Site-specific biological resources surveys were not conducted as a part of the General Plan process.






Response to Letter DD: Stuckeman

DD-1 The conclusion of the Draft EIR is that implementation of the General Plan will have unavoidable adverse effects on air quality, loss of prime farmland, biological resources, water supply, transportation, and aesthetics. The decision-makers are required to take these factors into consideration when approving the General Plan. According to State CEQA Guidelines Sections 15092,15096 (h), to approve the General Plan, the County must find that the benefits of the General Plan outweigh the unavoidable adverse environmental effects. However, when approving a project (in this case, the General Plan), the Lead Agency (County) is required by CEQA to prepare a Statement of Overriding Considerations. The Statement of Overriding Considerations is a written statement explaining why the agency is willing to accept each significant effect (Public Resources Code Section 21081; Guidelines Section 15093); in other words, CEQA requires that the decision-makers balance the benefits of the proposed General Plan against the unavoidable environmental risks in determining whether to approve the General Plan.

DD-2 The Commentor is referring to land use designations and density ranges, which are discussed and implemented in the Draft General Plan. The Commentor's suggested density of 1 unit per acre is also not consistent with agriculture and open space preservation. This comment will be taken into consideration by the decision-making body in its deliberations on the General Plan.

DD-3 Refer to response DD-2.

DD-4 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.

DD-5 Refer to response U-7. To the extent possible, water sources have been identified in the EIR. Further details pertaining to water supply will be worked out by water agencies as the County develops and as water sources are identified. Impacts to water supply were analyzed to the best of the County's ability, given the size of the County, the number of water agencies which operate within the County, and the number of possible water sources.

DD-6 As stated in the Riverside County General Plan EIR, the population throughout Riverside County will increase. The General Plan will accommodate this anticipated growth. In anticipation of this growth, Riverside County has included the Land Use Policy as stated below.

Land Use Policy 5.2 Monitor the capacities of infrastructure and services in coordination with service providers, utilities, and outside agencies and jurisdictions to ensure that growth does not exceed acceptable levels of service.

On pages 4.15-22 and 4.15-23, the EIR also states that:

The policy in the proposed General Plan does not protect the school districts in the County from the increase in school children anticipated with build out of the proposed General Plan. However, as discussed below, State law limits the power of the County to impose mitigation for development impacts on schools.

SB 50 states that the exclusive method of mitigating the impact of school facilities according to CEQA is to pay the maximum school fees and that such fees are "deemed to provide full and complete school facilities mitigation" related to the adequacy of school facilities when considering the approval or the establishment of conditions for the approval of a development project (Government Code 65996 (a) and (b)). Because the Government Code states that compliance with SB 50 will provide full and complete mitigation, no significant impact would occur.

The anticipated growth in population and lack of sufficient school facilities is an issue throughout the State of California. Riverside County will adhere to the policy above and shall impose the maximum mitigation for development impacts on schools.

DD-7 The General Plan contains a Circulation Plan. Anticipating a build out of the General Plan land uses, this plan includes roadways of the future that accommodate existing and planned growth. Section 4.16 of the Draft EIR analyzes the effectiveness of the planned roadways and policies within the General Plan. In the Draft EIR (page 4.16-21, paragraph 2), it was determined that with the General Plan policies, planned roadways for western Riverside County would operate at acceptable levels of service. The exception would be freeways, which would operate at LOS F during peak hours.

DD-8 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 EE: McKibben

EE-1 The distribution of land uses set forth in the proposed General Plan was determined after considering the location and potential severity of hazard areas (as shown in the Riverside County Existing Setting Report) and, therefore, represents the identification of potentially cumulative hazard impacts. The proposed General Plan and Draft EIR identifies hazard areas for seismic, flooding, wildfire, steep slopes, slope instability, and wind erosion. These potential hazard areas are individually identified in further detail in each of the proposed Area Plans.

EE-2 As the County of Riverside encompasses a myriad of geologic, topographic, and developed conditions, the mitigation measures offered at the programmatic EIR level would reduce the significance of potential site-specific hazards. It is appropriate at a General Plan level to address potential site-specific hazard impacts only after conducting an investigation of specific site conditions. As determined by the County Geologist, such an investigation must take into account all the potential geotechnical hazards that may be associated with a project site. Accompanying mitigation measures mandate the use of design/construction standards to reduce potential geotechnical impacts. Mitigation measures in the Draft EIR require that site- or project-specific design/construction standards and/or limitations be reviewed and approved by the County Geologist. Thus, the potential cumulative impacts associated with development in identified geotechnical hazard zones would be reduced to less than significant.

EE-3 Section 4.10, page 4.10-2 of the Draft EIR has been revised as follows:

Ground shaking is the movement of the earth resulting from an earthquake. Shaking can cause lateral movement and vertical ground acceleration which can contribute to the collapse of buildings. building reason for collapse of buildings.

EE-4 Table 4.10.A in the Draft EIR, Probable Earthquake Scenarios for Riverside County, has been replaced with Table 5.2B from the Riverside County Existing Setting Report, Fault Source Parameters for Riverside County. See Section 3.0 of the Final EIR to view the new table.

EE-5 The following statement has been removed from the first paragraph of page 4.1017 in the Draft EIR:

In Riverside County, risk due to regional subsidence is greatest at valley margins.

EE-6 The proposed General Plan includes policies that recognize potential geologic and seismic impacts, require specific studies, and delineate standards and establish procedures for the review of development within potential geologic/seismic hazard areas. Additionally, Mitigation Measures 4.10.1A, 4.10.2B, and 4.10.3A require (as appropriate) the preparation of a geotechnical investigation and the identification of measures that would reduce the significance of potential site-specific geologic/seismic hazards. Mitigation Measure 4.10.1A further states that development would be prohibited within 50 feet of any identified fault; Measure 4.10.2.A requires the construction of structures and facilities utilizing the Uniform Building Code and other engineering standards for the construction of structures; and Measure 4.10.3B requires the implementation of design measures to mitigate for potential impacts in areas susceptible to liquefaction. While the Draft EIR requires the preparation of site-specific geotechnical investigations, accompanying mitigation mandates the use of design/construction standards to reduce potential geotechnical impacts. Because of the varied geotechnical environment of the County, specific design/construction standards have not been identified in the Draft EIR. Rather, the mitigation in the Draft EIR requires that site- or project-specific design/construction limitations and/or limitations be reviewed and approved by the County Geologist. Without the review and approval of the County Geologist, development in potential geotechnical hazard areas could not proceed. The use of project- and/or site-specific design/construction standards that have been review and approved by the County Geologist would reduce the potential geotechnical impacts to a less than significant level.

Also refer to response to Comment I-3 for a discussion on the level of analysis that is appropriate to a Program EIR.

EE-7 The Draft EIR identifies potential geotechnical hazards that may occur throughout the County as well as mitigation measures, the implementation of which will reduce impacts associated with these hazards to a less than significant level. The potential geotechnical hazards identified in the Draft EIR are based on Natural Hazards Mapping, Analysis and Mitigation: A Technical Background Report of the Safety Element of the New Riverside County 2000 General Plan (Earth Consultants International, August 1, 2000) and represent a thorough analysis of potential impacts at the time the General Plan and General Plan EIR were prepared.

EE-8 Mitigation Measure 4.10.1A states, " Before a project is approved or otherwise permitted within an A-P Zone, County Fault Zone, within 150 feet of any other active or potentially active fault mapped in a published United States Geologic Survey (USGS) or CGS reports, or within other potential earthquake hazard area (as determined by the County Geologist), a site-specific geologic investigation shall be prepared to assess potential seismic hazards resulting from development of the project site...." As written, this measure provides the County Geologist sufficient authority to require site-specific geologic investigations within, adjacent to, or outside an Alquist-Priolo zone.

EE-9 As stated in Mitigation Measure 4.10.1A the County Geologist may require the preparation of a site-specific geotechnical investigation within "other" earthquake hazard areas. To ensure an adequate and appropriate investigation, Mitigation Measure 4.10.1A, on page 4.10-29 of the Draft EIR, has been revised as follows:

4.10.1A Before a project is approved or otherwise permitted within an A-P Zone, County Fault Zone, within 150 feet of any other active or potentially active fault mapped in a published United State Geologic Survey (USGS) or CGS reports, or within other potential earthquake hazard area (as determined by the County Geologist), a site-specific geologic investigation shall be prepared to assess potential seismic hazards resulting from development of the project site.

Where and when required, the geotechnical investigation shall address the issue(s), hazard(s), and geographic area(s) determined by the County Geologist to be relevant to each development. The site-specific geotechnical investigation shall incorporate up-to-date data from government and non-government sources.

The Alquist-Priolo Act requires a 50-foot setback for development from active fault zones. The County requirement to conduct studies for any project within 150 feet of an A-P Zone is consistent with this requirement.

EE-10 As evidenced by the number and scope of comments received on the Draft EIR, environmental documents are subject to public review. Geotechnical investigations and the measures to reduce the significance of potential geologic/seismic impacts are reviewed by County staff, Responsible and Trustee Agencies, and the general public. Information submitted by qualified experts is considered adequate. The County reserves the ability to require further analysis, particularly if the qualifications of the expert are in question. Nothing in the General Plan or General Plan EIR precludes the County Geologist from contracting for the independent review of geotechnical investigations when such review is deemed necessary. The Commentor's opinion that there is an "... unfortunate tendency for developers to ‘shop around' for the least controversial (least critical) geotechnical analysis possible, in an effort to minimize their expenses at the cost of public safety" is not supported by factual evidence. Staff is recommending the inclusion of a policy that mandates special engineering studies be completed prior to constructing on slopes that exceed 25 percent. These studies will be used to ensure that development will be situated safely on sloped areas.

EE-11 The policy in the General Plan is proposed to be amended to the following:

Safety Policy 7.13 Develop a system to respond to short-term increases in hazard on the southern San Andreas, San Jacinto, and Elsinore faults, based on probabilities associated with foreshocks.

EE-12 Mitigation Measures 4.10.3A and 4.10.3 require the preparation of a site-specific liquefaction assessment and the identification of measures and/or the identification of design features to reduce the significance of potential liquefaction impacts for any development (including residential structures) within a liquefaction hazard zone.

EE-13 Section 4.10 (Geology and Slope Stability) of the Draft EIR was based on Natural Hazards Mapping, Analysis and Mitigation: A Technical Background Report of the Safety Element of the New Riverside County 2000 General Plan (Earth Consultants International, August 1, 2000). Section 15150(a) of the State CEQA Guidelines state, "An EIR or negative declaration may incorporate all or portions of another document which is a matter of public record ..." The aforementioned report is included as Appendix H to the General Plan. This reference is included in Section 9.1 (General References) of the Draft EIR and is provided in its entirety at www.rcip.org.

EE-14 As stated in the preceding response, Section 4.10 (Geology and Slope Stability) of the Draft EIR was based on a technical background report prepared specifically to support the Safety Element of the General Plan, and represents an adequate, complete, and good faith effort to disclose and evaluate potential geologic and slope stability impacts. The opinion of the Commentor on the necessity of incorporating the findings of additional technical reports into the Draft EIR is noted.

EE-15 While the General Plan is a component of the Riverside County Integrated Project work effort, it must also be a stand-alone document. The General Plan has "independent utility," meaning that the adoption of any one component of the RCIP effort is not dependent on the adoption of the others. This allows, that in the event either the CETAP or MSHCP documents are not approved, the County would still possess an up-to-date legally adequate General Plan, as required by State law. Government Code 65300 states that "... the general plan and elements and parts thereof comprise an integrated, internally consistent, and compatible statement of policies for the adopting agency." The various elements presented in the General Plan meet this requirement.

While the objective of the RCIP effort is to fully integrate the component plans, it does not necessarily follow that the various documents will be prepared, reviewed, or approved simultaneously. Copies of the various documents have been made available for public review at offices of the County Planning Department and public libraries. The noticing of public scoping meetings and the public review of the documents has followed State and federally mandated guidelines. Since the inception of the integrated planning process, the County of Riverside has provided on-line access to the documents prepared during the Riverside County Integrated Project work effort. The RCIP website at www.rcip.org provides a calendar of public meetings, a library of RCIP material, press releases, contact information, RCIP team members, and the means to contact the County with comments and concerns about the RCIP process. For those with the desire, sufficient opportunity has been provided to provide input to and comment on the various RCIP documents.

EE-16 As required by the California Environmental Quality Act, all comments received on the Draft EIR have been responded to by the Lead Agency. The comments and responses are included in the Final EIR, which incorporates all comments received on the Draft EIR.

It is noted that the Commentor incorporates by reference several reports and studies. Section 15150(b) of the State CEQA Guidelines requires material incorporated by reference in an EIR "... shall be made available to the public for inspection at a public place or building." Further, information incorporated by reference must be summarized or briefly described if the reference cannot be summarized. As the Commentor incorporates by reference several highly technical reports, the public would have been better served if those reports had been presented along with the comments on the Draft EIR.




Response to Letter FF: McManus

FF-1 The comment is aimed at the notice for the General Plan document itself, and does not raise any substantive or procedural issues regarding the EIR. The Commentor states that the public notice information was inadequate, inaccurate, and deceptive. The County followed notification procedures required by law. In addition to meeting these legal requirements, the County also made copies available at Planning Department Offices in Riverside, Murrieta, and Indio. Further, the County has made copies available at libraries throughout the County and has posted the information on-line. The County provided several documents to all of the property owners in Riverside County, including the RCIP Blueprint mailer and relevant public hearing notices. This is above and beyond what is required under CEQA. The County maintains that the information provided in these mailers, and on the RCIP website, is accurate, and was not written in such a manner as to be deceptive.

The Commentor also expresses his concern that he was not able to understand public notices regarding the General Plan and cannot determine what land use designations (incorrectly noted in the comment as "zoning") have been applied to his property. As part of the geographic information system (GIS) set up for the General Plan update, any landowner providing the County with their Assessor's Parcel Number can determine what land use designation(s) are proposed. This system was operated successfully at numerous public hearings and workshops before the County Planning Commission. Similar information is also available through the General Plan website: www.rcip.org. Comments on the General Plan itself will be accepted by the County until the final public hearing before the County Board of Supervisors.

FF-2 The conclusion of the Draft EIR is that implementation of the General Plan will have unavoidable adverse effects on air quality, loss of prime farmland, biological resources, water supply, transportation, and aesthetics. The decision makers are required to take these factors into consideration when approving the General Plan. According to State CEQA Guidelines Sections 15092,15096 (h), to approve the General Plan, the County must find that the benefits of the General Plan outweigh the unavoidable adverse environmental effects. However, when approving a project (in this case the General Plan), the Lead Agency (County) is required by CEQA to prepare a Statement of Overriding Considerations. The Statement of Overriding Considerations is a written statement explaining why the agency is willing to accept each significant effect (Public Resources Code, Section 21081; Guidelines Section 15093); in other words, CEQA requires the decision makers to balance the benefits of the proposed General Plan against the unavoidable environmental risks in determining whether to approve the General Plan.

FF-3 Section 4.17 Water Resources, in the Draft EIR supports the opinion of the Commentor that implementation of the proposed General Plan will have an adverse effect on water supply. High density housing does not use more water than lower density housing. The water district uses a generation factor based on a per person use of water, not residential density. It is the number of people that live in an area that determines water use, not the type of land use or density. A family living in a single-family house on a one-half-acre lot that is fully landscaped will use more water daily than the same family living in an apartment complex. As the Commentor points out, electricity will be required to serve the higher density housing.

As stated on page 4.8-6 of the Draft EIR, "... past shortages of electricity were solved by the additional power plants being brought "on-line" in California. The matter of electrical generation capacity is not one of physical shortages due to power plant limitations; rather, it is a function of market forces and the wholesale cost of electricity. This cost and supply adjustment was evident when energy producers withheld electricity from the market and were unwilling to sell electricity at market prices. This enabled energy suppliers to create a false electricity shortage that artificially inflated prices to a desired point."

FF-4 The Commentor is discussing land use designations and densities, which are set forth in the Draft General Plan. 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 GG: Graber

GG-1 The Commentor cites Public Resources Code and CEQA law. The County has complied with these requirements. Comment noted.

GG-2 The Planning Commission does have before it for consideration the following documentation, which constitutes a complete public record in which to make an informed decision. The Planning Commission makes a recommendation to the County Board of Supervisors as to whether or not the General Plan should be approved and the EIR certified. It is the Board of Supervisors, not the Planning Commission, that approves the General Plan.

• The Draft General Plan including 19 Area Plans and technical appendices;

• Existing Setting Report (March 2000);

• Draft Environmental Impact Report on the General Plan and technical appendices (August 20, 2002); and

• County staff reports.

The Planning Commission has held public hearings on the General Plan on the following dates:

• June 19, 2002;

• September 12, 2002;

• September 25, 2002;

• October 10, 2002;

• October 30, 2002;

• November 6, 2002;

• November 13, 2002; and

• January 8, 2003.

The public record will encompass all documents in accordance with Public Resources Code 21167.6(e).

GG-3 The public record is available for anyone who wants to review it.














Response to Letter HH: Hewitt

HH-1 The Commentor is discussing land use designations, which are set forth in the Draft General Plan and not the Draft EIR. The land use designations for the community of Hemet were developed as a result of existing land use, input of local residents at Community Meetings and overall County goals. Furthermore, adoption of the proposed General Plan would not render any existing agricultural use non-conforming, regardless of the proposed land use designation.

HH-2 Refer to response HH-1.

HH-3 Refer to response HH-1.

HH-4 The Commentor is discussing literature received in regard to the Draft General Plan. This comment is not relevant to the adequacy of the Draft EIR.

HH-5 Refer to responses HH-1 and HH-4.

HH-6 Refer to responses HH-1 and HH-4.

HH-7 The Commentor is discussing aspects of the General Plan update, including literature received, the availability of information, and the comment period on the General Plan. Further response is unnecessary.

HH-8 Refer to response HH-1.

HH-9 Refer to response HH-1.

HH-10 The conclusion of the Draft EIR is that implementation of the General Plan will have unavoidable adverse effects on air quality, loss of prime farmland, biological resources, water supply, transportation, and aesthetics. The decision-makers are required to take these factors into consideration when approving the General Plan. According to State CEQA Guidelines Sections 15092,15096 (h), to approve the General Plan, the County must find that the benefits of the General Plan outweigh the unavoidable adverse environmental effects. However, when approving a project (in this case, the General Plan), the Lead Agency (County) is required by CEQA to prepare a Statement of Overriding Considerations. The Statement of Overriding Considerations is a written statement explaining why the agency is willing to accept each significant effect [Public Resources Code Section 21081; Guidelines Section 15093]; in other words, CEQA requires that the decision-makers to balance the benefits of the proposed General Plan against the unavoidable environmental risks in determining whether to approve the General Plan. The Draft EIR addresses the General Plan's effects on water supply in Section 4.17.

HH-11 The Commentor is concerned that the proposed General Plan is not compatible with the existing rural and agricultural lifestyle of the unincorporated southeast Hemet. The comments will be considered by the County's decision-makers during their deliberations on the proposed General Plan. Build out of the land uses in the proposed General Plan were analyzed for environmental impacts in the EIR on agriculture, water supply, traffic, and schools. The findings of the EIR determined that the proposed General Plan will have significant unavoidable adverse impacts that can not be mitigated on loss of prime agricultural lands, air quality, loss of open space, biological resources, and traffic on freeways.

HH-12 Refer to responses HH-1 and HH-10.

HH-13 Refer to responses HH-1 and HH-10.

HH-14 Refer to response HH-1.

HH-15 The Commentor is providing an opinion. This comment will be taken into consideration by the decision-making body in its deliberations on the General Plan.

HH-16 Refer to response HH-1.

HH-17 Refer to response HH-1.

HH-18 This comment will be taken into consideration by the decision-making body in its deliberations on the General Plan.

HH-19 This comment will be taken into consideration by the decision-making body in its deliberations on the General Plan.

HH-20 Refer to response HH-1.

HH-21 Refer to response HH-1.

HH-22 Refer to response HH-1.




Response to Letter II: Tyler

II-1 Refer to response FF-1, which addresses the issue of public notices.
II-2 Refer to response HH-1, which addresses community planning near Hemet.




Response to Letter JJ: Cliff

JJ-1 Thank you for your comment. The Commentor is stating that the City of Hemet has deteriorated throughout the years. No further response is necessary.

JJ-2 Thank you for your comment. The Commentor is stating that the community of Valle Vista has plenty of housing opportunities. No further response is necessary.

JJ-3 The Commentor is stating that the agricultural lands in Valle Vista should be preserved. Land use designations are set forth in the Draft General Plan. Refer to response HH-1, which addresses community planning near Hemet. 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 KK: San Gorgonio Chapter of the Sierra Club, San Bernardino Valley Audubon Society, Friends of theNorthern San Jacinto Valley

KK-1 Comment noted. The suggestion falls within the range of alternatives analyzed in Section 6 of the Draft EIR.

KK-2 The County respectfully disagrees. The Draft EIR complies with CEQA and the State CEQA Guidelines. The Draft EIR contains traffic modeling that was based on land use; thus, the document complies with State laws in it correlation of circulation and land use elements. In addition, there is adequate identification of open space lands for parks and recreation, as discussed in Section 4.14 of the Draft EIR. Furthermore, the General Plan Circulation Element was derived from the Land Use Element. The Commentor claims that the General Plan does not comply with State planning law, but provides no specifics. The County maintains that the General Plan is in compliance with all applicable laws.

KK-3 While the General Plan is a component of the Riverside County Integrated Project work effort, it must also be a stand-alone document. The General Plan has "independent utility," meaning that the adoption of any one component of the RCIP effort is not dependent on the adoption of the others. This allows, that in the event either the CETAP or MSHCP documents are not approved, the County would still possess an up-to-date legally adequate General Plan, as required by State law. Government Code 65300 states that "... the general plan and elements and parts thereof comprise an integrated, internally consistent, and compatible statement of policies for the adopting agency." The various elements presented in the General Plan meet this requirement.

While the objective of the RCIP effort is to fully integrate the component plans, it does not necessarily follow that the various documents will be prepared, reviewed, or approved simultaneously. Copies of the various documents have been made available for public review at offices of the County Planning Department and public libraries. The noticing of public scoping meetings and the public review of the documents has followed State and federally mandated guidelines. Since the inception of the integrated planning process, the County of Riverside has provided on-line access to the documents prepared during the Riverside County Integrated Project work effort. The RCIP website at www.rcip.org provides a calendar of public meetings, a library of RCIP material, press releases, contact information, RCIP team members, and the means to contact the County with comments and concerns about the RCIP process. For those with the desire, sufficient opportunity has been provided to provide input to and comment on the various RCIP documents.

KK-4 Refer to response KK-3. In addition, the Commentor requests that there be a moratorium on development. In order for a moratorium to be placed on development, the County must adopt an interim urgency ordinance prohibiting any uses that may be in conflict with the General Plan. In accordance with Section 65858 of the California Government Code, the County must adopt legislative findings that state that there is a current and immediate threat to the public health, safety, or welfare, and that the approval of additional subdivisions, use permits, variances, building permits, or any other applicable entitlement for use which is required in order to comply with a zoning ordinance would result in that threat to public health, safety, or welfare. The County has not adopted such findings.

KK-5 This comment identifies CEQA requirements as they would apply to the General Plan EIR, which does, in fact accomplish each of the objectives set forth in the comment. The General Plan EIR analyzes the physical impacts of future development, including both residential and non-residential development, as well as both urban and rural development, that would be permitted by the proposed General Plan. Within Section 4.0 of the Draft EIR, Impacts and Mitigation Measures, impacts are analyzed for:

• Land Use/Agriculture

• Population and Housing

• Aesthetics/Visual Resources

• Air Quality

• Biological Resources

• Cultural Resources

• Energy Resources

• Flood and Dam Hazards

• Geology and Slope Stability

• Hazardous Materials

• Mineral Resources, Noise

• Parks and Recreation

• Public Services

• Transportation and Circulation

• Water Resources

Within each of these sections, environmental impacts are analyzed based on the levels of development that would be permitted by the proposed Riverside County General Plan. Following the analysis of impacts, relevant General Plan policies are identified for each impact, and the effectiveness of General Plan policies to avoid or mitigate identified impacts is analyzed. Where significant impacts are found to remain after implementation of General Plan policies, the EIR proposes specific mitigation measures to address the significant impact. These measures are presented in the form of modifications to proposed development, modifications to proposed General Plan policies, or stand-alone measures to mitigate impacts, as appropriate.

KK-6 Extensive constraints and opportunities analyses were performed using GIS to the parcel level. Subsequent development is required to comply with General Plan policies. For the purpose of analysis in the General Plan EIR, land use designations have been applied on a parcel-specific basis. Land use designations were made based on a balanced approach that took into account environmental and ecological factors, growth patterns, agriculture and open space values, the presence of infrastructure, and housing needs, among other factors.

KK-7 When a large study is contemplated on something that is perpetually changing, a certain limit has to be set. That is to say, 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 adopted developments that came after the publication of this report may be reflected in the General Plan map at a future date. This can be accomplished with a Technical Amendment, which involves changes in the General Plan of a technical nature, including technical corrections discovered in the process of implementing the General Plan. Technical amendments may include the following:

• Corrections to statistics;

• Changes in spheres of influence and city boundaries;

• Appendix information useful in interpreting the General Plan but which does not change the General Plan's intent;

• Mapping error corrections;

• Editorial clarifications that do not change the intent of the General Plan; and/or

• Changes in Unincorporated Communities or Communities of Interest.

KK-8 The project description for the General Plan as a whole describes anticipated future growth over the long-term. The General Plan is a comprehensive document that is meant to express the community's goals with respect to the man-made and natural environments in Riverside County. The General Plan is prepared as a stand alone document, independent of whether other documents are approved. Although the MSHCP and CETAP are also considered planning documents, the County General Plan does evaluate and cover impacts associated with conservation and circulation issues. An agency, such as Riverside County, is not permitted to "segment" or "piecemeal" a project into small parts if the effect is to avoid full disclosure of environmental impacts. This rule arises from the definition of "project" pursuant to CEQA, which includes the phrase "whole of the action." This phrase has been interpreted by the California Supreme Court to mean it is generally inappropriate to chop a project into small segments to avoid preparing an EIR (Bozung v. Local Agency Formation Commission [1975] 13 Cal.3d 263.). Therefore, an agency may not treat each separate permit or approval as a separate project for the purpose of evaluating environmental impacts. Riverside County has not avoided presenting an EIR to the public with respect to analysis of the General Plan; therefore, Riverside County has not engaged in "piecemealing."

The Commentor has a different definition of "piecemealing," stating that it is deferment of environmental analyses to other RCIP components (CETAP and Western Riverside County MSHCP). On the contrary, the CETAP EIR/EIS, which involves the analysis of transportation corridors, has been incorporated into analysis of the transportation impacts of the General Plan Circulation Element. According to State CEQA Guidelines Section 15150, an EIR may incorporate all of a publicly available document or portions of it prepared for other projects. As required, the General Plan EIR described the CETAP EIR/EIS briefly, summarized its relationship to the EIR, and stated where the document is available for public inspection.

The Western Riverside County MSHCP EIR/EIS was sent to the public after the General Plan EIR. It could not be incorporated by reference into the General Plan EIR, as it was not available to the public at that time.

KK-9 Refer to response KK-3. The traffic analysis was based on the full build out of the Riverside County General Plan. The analysis assumed development densities that were reasonably likely to occur, on average, given the land use classifications. Some parcels may be developed at slightly higher densities than the averages assumed, while others may be developed at slightly lower densities. It is believed that the average densities used in the analysis are a reasonable representation of what is likely to occur on an aggregate basis. Also, because actual build out rarely occurs, it is possible that the traffic forecasts provided in the analysis could well be higher than would actually occur. Regarding the CETAP corridors, the General Plan traffic analysis assumed that a new limited access facility would be in place in the Winchester to Temecula Corridor linking SR-79 in Winchester with I-215 near Scott Road (generally representing Alternative 7b, which has been recommended by RCTC staff). There was no assumption of a freeway-level eastern bypass around Temecula. It should be noted that, at the time of preparation of this document, the CETAP alternatives have only received a staff recommendation, and that there is currently no locally preferred alternative that has been adopted by RCTC or the Federal Highway Administration.

KK-10 The analysis assumed development densities that were reasonably likely to occur, on average, given the land use classifications, per professional judgment. Although minimum, midrange, and maximum projections of population, dwelling unit, and employment development were estimated as part of technical tasks, the midrange procedure correlates to the average, and therefore expected, level of development intensity analyzed as part of the EIR. Some parcels may be developed at slightly higher densities than the averages assumed, while others may be developed at slightly lower densities. It is believed that the average densities used in the analysis are a reasonable representation of what is likely to occur on an aggregate basis. Also, because actual build out rarely occurs, it is possible that the traffic forecasts provided in the analysis could well be higher than would actually occur.

KK-11 Refer to response KK-8. All the information requested by the Commentor is in the EIR.

KK-12 The Commentor alleges several deficiencies regarding the project setting in the Draft EIR. The Draft EIR incorporates the Existing Setting Report (March 2000) by reference. This document contains many of the elements referred to by the Commentor. The comments are responded to item-by-item below:

(1) sufficient details concerning approved projects within the County, cities, and adjacent counties of Orange, San Bernardino and San Diego

The Existing Setting Report describes existing approved projects in sections 2.3 and 2.4. Furthermore, these projects were utilized in the baseline data that is incorporated into the Land Use Map. Prior to certification of the proposed General Plan, the Land Use Map will be updated to reflect projects that have been approved subsequent to the preparation of the initial Land Use Map. Approved projects in cities and adjacent counties were taken into account in the preparation of the Circulation Element. A detailed description of individual projects in adjacent jurisdictions is not appropriate or required for a program-level document for a project of this geographical scale.

(2) information about the adequacy of existing public services and facilities

The Existing Setting Report describes existing public services and facilities in Section 9.0, Public Services and Facilities (see also Section 3.4, Major Utility Corridors; Section 4.3, Water Resources; Section 4.7, Parks and Recreation; Section 5.3, Fire Hazards; Section 5.7, Hazardous Materials; Section 5.8, Emergency Preparedness).

(3) information about existing groundwater problems

The Existing Setting Report describes water resources in Section 4.3. Section 4.3.3 in particular addresses water quality.

(4) information concerning infill capacity both within unincorporated communities and existing cities and their spheres of influence

The County has jurisdiction over unincorporated areas, which includes unincorporated communities as well as spheres of influence of cities. The County has no planning authority within the cities. The Existing Setting Report contains an Open Space Land Inventory in Section 4.9. Furthermore, the Draft EIR includes a wide range of alternatives that rely on the infill capacity within unincorporated areas of the County to varying degrees. The infill capacity is reflected in the range of alternatives, which are discussed in Section 6.0 of the Draft EIR.

(5) information concerning approved and proposed development at March Air Reserve Base

At the time of the preparation of the Existing Setting Report, there were no known approved or proposed development plans for March Air Reserve Base. Although the County is a member of the Joint Powers Authority for the Base, it does not have final planning authority over the area. March Air Reserve Base has its own master plan, and is not subject to the policies and regulations to the County of Riverside General Plan. Any approved development at March Air Reserve Base which was not accounted for in the initial Land Use Map will be taken into consideration, insofar as it affects land uses within unincorporated County land.

(6) information concerning the direction of flood flows and their relationship to sustaining special status species

The Existing Setting Report contains information about flood zones and flood areas in Section 5.4, Flood Hazards. It also discusses biological resources in Section 4.2. CEQA does not require a description of the direction of flood flows and their relationship to special-status species. The County has complied with CEQA regulations.

(7) information concerning existing dams and a map showing their location

The Existing Setting Report, in Section 5.4, Flood Hazards, contains information about dam inundation hazards (which is depicted in Figure 5.4.2). CEQA does not specifically require a map showing the location of dams in an EIR. The County has complied with CEQA regulations.

(8) information and maps indicating the location of existing power lines

Section 3.4, Major Utility Corridors, in the Existing Setting Report describes the major electrical transmission lines in the County.

(9) information concerning Riverside County's concept of developing as an "inland port"

The proposed General Plan sets forth a Vision Statement for the future of Riverside County. This is further delineated in the elements and policies set forth within the Plan. The Draft EIR analyzes the effects of the elements and policies within the Plan that derive from the Vision Statement. The concept of the County developing as an "inland port" is analyzed to the extent that it is reflected in the General Plan elements and policies. If this concept is to result in more effects on the County, revisions to the General Plan elements and/or policies would be required. Such revisions would require additional environmental review.

KK-13 Refer to response KK-8.

KK-14 The discussion of agriculture in the Draft EIR is based on Riverside County Integrated Plan Existing Setting Report (LSA Associates, March 2000). This report is intended to provide a common factual basis for the preparation of the three components of the County's integrated planning effort and provides a single environmental baseline inventory that will be used in the preparation of subsequent environmental documents. The Existing Setting Report presents the results of an intensive research effort aimed at identifying the physical, social, and economic characteristics of Riverside County which need to be understood to formulate goals, objectives, and policies for the integrated planning effort. Copies of the Existing Setting Report on CDROM were distributed with the Draft EIR. Additionally, copies of the Existing Setting Report are available for public review at County Planning Offices and public libraries throughout the County. As stated in Section 2.2.1 of the Draft EIR, the Existing Setting Report was incorporated by reference into the Draft EIR.

KK-15 The following response addresses the baseline used in the EIR.

The Environmental Setting

Under CEQA, a draft EIR "must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time the notice of preparation is published, or if no notice of preparation is published, at the time the environmental analysis is commenced, from both a local and a regional perspective." (CEQA Guidelines, § 15125, subd. (a).)

The description of physical environmental conditions should describe existing environmental resources the project may affect. The description should provide sufficient information to allow meaningful analysis of the project's impacts. (See San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 Cal.App.4th 713, 722-729; Galante Vineyards v. Monterey Peninsula Water Management Dist. (1997) 60 Cal.App.4th 1109, 1122.)

The description of the environmental setting "will normally constitute the baseline physical conditions by which a lead agency determines whether an impact is significant." (CEQA Guidelines, § 15125, subd. (a); see also CEQA Guidelines, § 15126.2, subd. (a) ("In assessing the impact of a proposed project on the environment, the lead agency should normally limit its examination to changes in the existing physical conditions in the affected area as they exist at the time the notice of preparation is published...."); Fat v. County of Sacramento (2002) 97 Cal.App.4th 1270 (upholding County's environmental analysis because agency did not abuse its discretion by adhering to the "normal" rule for purposes of establishing baseline conditions).)

As one Court explained, "[b]efore the impacts of a project can be assessed and mitigation measures considered, an EIR must describe the existing environment. It is only against this baseline that any significant environmental effects can be determined. [Citations omitted.]" (County of Amador v. El Dorado County Water Agency (1999) 76 Cal.App.4th 931, 952.)

Because the analysis of a project's impacts turns in large part on the baseline against which those impacts are measured, the description of the baseline, and the agency's basis for determining that baseline, should appear in the EIR. (Save Our Peninsula Committee v. Monterey County(2001) 87 Cal.App.4th 99, 119-120.)

Consistent with these principles:

• The description of the environmental setting must be stable and accurate, and must encompass and fairly describe the resources the project may affect. (See San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus, supra, 27 Cal.App.4th at pp. 722729.)

• The description of the environmental setting must contain sufficient information to enable the agency to determine whether, and to what extent, the proposed project will change those conditions. (See County of Amador v. El Dorado County Water Agency, supra, 76 Cal.App.4th at pp. 952-956.)

• The analysis must reflect a good-faith effort to "investigat[e] and obtain documentation to support a determination of pre-existing conditions. [Citation omitted.]" (Save Our Peninsula Committee

• v. Monterey County Board of Supervisors, supra, 87 Cal.App.4th at p. 122.)

• The EIR should not engage in plan-to-plan analysis for purposes of determining the project's environmental effects. Instead, "the impacts of the project must be measured against the ‘real conditions on the ground.' [Citations omitted.]" (Save Our Peninsula Committee v. Monterey County Board of Supervisors, supra, 87 Cal.App.4th at p. 121.) Thus, for purposes of determining a project's environmental effects, the EIR should compare the project's impacts with physical conditions, rather than with hypothetical conditions upon build-out under existing land-use designations. (See, e.g., City of Carmel-by-the-Sea v. Board of Supervisors (1986) 183 Cal.App.3d 229, 246-247; Environmental Planning & Information Council v. County of El Dorado (1982) 131 Cal.App.3d 350, 352-355.)

• "Where a proposed project is compared with an adopted plan, the analysis shall examine the existing physical conditions at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced as well as the potential future conditions discussed in the plan." (CEQA Guidelines, § 15125, subd. (e).)

Although the "normal" rule calls for fixing the setting as of the date the agency commences the CEQA process, agencies do have discretion to "adjust the baseline" under appropriate circumstances. As a leading CEQA treatise has stated:

"Both the Guidelines and following Discussion provide that physical conditions at the time of the Notice of Preparation normally constitute the baseline for determining impacts, but a lead agency may determine that another baseline is more appropriate, either for overall evaluation of a project's impacts or for evaluation of a particular project impact. For example, if it is known that a certain surrounding environmental condition will either improve or degrade by the time the project is implemented, the lead agency may have a basis for selecting a different baseline for evaluating environmental impacts related to that condition. If the lead agency does elect a different baseline, the lead agency should be careful to explain in the EIR why a different baseline has been selected and to summarize the evidence or determinations surrounding the selection of the different baseline."

(Kostka and Zischke, Practice under the California Environmental Quality Act (2002 Cont. Ed. Bar), Vol. 1, § 12.26, p. 489; see also id., Vol. 1, § 13.12, pp. 511-513; Remy et al., Guide to the California Environmental Quality Act (1999 Solano Press Books), p. 165 ("... by using the word ‘normally,' the Resources Agency has implicitly recognized that, at least in some circumstances, a ‘past' or ‘future' baseline might be appropriate.").)

A recent Court of Appeal decision confirms that, in appropriate circumstances, the EIR may adjust the baseline to reflect actual, physical conditions at some point other than the date the agency publishes the Notice of Preparation. In Save Our Peninsula Committee v. Monterey County Board of Supervisors, supra, the petitioners argued that the lead agency had to adopt as its baseline physical conditions "as closely as possible to the date the notice of preparation of the EIR is filed, as that is the date the project is officially commenced within the meaning of CEQA. (87 Cal.App.4th at p. 125.) The Court of Appeal agreed that, as a "general rule," the baseline does consist of environmental conditions at the time the lead agency commences the environmental review process. The Court continued:

"[T]he date for establishing baseline cannot be a rigid one. Environmental conditions may vary from year to year and in some cases it is necessary to consider conditions over a range of time periods. In some cases, conditions closer to the date the project is approved are more relevant to a determination whether the project's impacts will be significant. For instance, where the issue involves an impact on traffic levels, the EIR might necessarily take into account the normal increase in traffic over time. Since the environmental review process can take a number of years, traffic levels as of the time the project is approved may be a more accurate representation of the existing baseline against which to measure the impact of the project."

(87 Cal.App.4th at pp. 125-126 (citations omitted).)

Similarly, in Cadiz Land Co v. Rail Cycle (2000) 83 Cal.App.4th 74, the Court of Appeal upheld an EIR's estimate of air pollutant emissions for a proposed landfill based on anticipated changes in emissions due to regulations proposed by the California Air Resources Board (CARB). In that case, solid waste would be transported to the landfill by locomotives. The EIR estimated air pollutant emissions from the locomotives based on regulations. The EIR also estimated baseline air pollutant emissions under the assumption that CARB would approve new locomotive emissions regulations. The Court held that CEQA authorized this approach. (83 Cal.App.4th at pp. 106109.)

These decisions explicitly recognize the implicit rule reflected in the language of CEQA Guidelines section 15125: ordinarily, the environmental setting consists of a snap-shot of conditions as of the date the agency commenced the CEQA process; but under appropriate circumstances the baseline may depart from that general rule, so long as the agency provides an explanation for why its approach is reasonable under the circumstances.

The "No Project" Alternative

The obligations to describe the environmental setting, and to analyze the project's impacts on that setting, are distinct from the obligation to analyze the "no project" alternative. (See CEQA Guidelines, § 15126.6, subd. (e).) "The purpose of describing and analyzing a no project alternative is to allow decisionmakers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project." (Id., § 15126.6, subd. (e)(1).) In keeping with this purpose, the analysis of the no-project alternative "shall discuss the existing conditions at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced, as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services." (Id., § 15126.6, subd. (e)(2).) "The existing conditions, supplemented by a reasonable forecast, are characterized as the no project alternative. The description must be straightforward and intelligible, assisting the decision maker and the public in ascertaining the environmental consequences of doing nothing...." (Planning and Conservation League v. Department of Water Resources (2000) 83 Cal.App.4th 892, 911.)

The no project alternative analysis is not the baseline for determining whether the proposed project's environmental impacts may be significant, unless it is identical to the existing environmental setting analysis which does establish that baseline (see Section 15125). (CEQA Guidelines, § 15126, subd. (e)(1).) For example, if the site of a proposed project is currently undeveloped, but existing land-use designations authorize some level of development, then the descriptions of the environmental setting and the no-project alternative diverge: the environmental setting consists of the existing, undeveloped site, and the no-project alternative consists of likely development in accordance with existing land-use designations (i.e. "based on current plans and consistent with available infrastructure and community services"). In that case, the "baseline" for purposes of analyzing the impacts of the proposed project consists of the environmental setting, and not the no-project alternative. (See Environmental Planning & Information Council v. County of El Dorado, supra, 131 Cal.App.3d at pp. 352-355.)

"When the project is the revision of an existing land use or regulatory plan, policy or ongoing operation, the ‘no project' alternative will be the continuation of the existing plan, policy or operation into the future. Typically this is a situation where other projects initiated under the existing plan will continue while the new plan is developed. Thus, the projected impacts of the proposed plan or alternative plans would be compared to the impacts that would occur under the existing plan." (CEQA Guidelines, § 15125, subd. (e)(3)(A).)

Having identified the no-project alternative in this manner, "the lead agency should proceed to analyze the impacts of the no project alternative by projecting what would reasonably be expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services." (CEQA Guidelines, § 15125, subd. (e)(3)(C).)

Draft EIR for Proposed General Plan

In this case, the County received a number of comments raising concerns about the Draft EIR's description of the environmental "baseline." Comment KK-82, for example, states that the Draft EIR erred by using as an environmental baseline those conditions projected to exist upon build-out of the existing General Plan, rather than current physical conditions.

In fact, the Draft EIR did not take this approach. Each section in Chapter 4 of the Draft EIR contains a description of the existing environmental setting. (See, e.g., Draft EIR, §§ 4.2.1 (land use and agricultural resources), 4.3.1 (population and housing), 4.4.1 (aesthetics).) The description of the existing environmental setting was, in turn, based on a comprehensive inventory of environmental resources in the County published in March 2000. (LSA Associates, Existing Setting Report (2000).) The County incorporated by reference the Existing Setting Report into the Draft EIR. Thus, the Draft EIR was based on unusually detailed information regarding the existing environmental setting, particularly in view of the large geographic area encompassed by the EIR, and the breadth of the resources potentially affected by the proposed project.

Nor did the County rely on "plan-to-plan" analysis for purposes of analyzing the impacts of approving the General Plan. The analysis of project impacts assumes theoretical build-out of the plan as proposed. (Draft EIR, p. 4.1-2.) The Draft EIR measures the conditions at build-out as compared to the current environmental setting, as reflected in the Existing Setting Report.

For example, the analysis of impacts to agricultural resources describes the character and amount of land currently dedicated to agricultural uses. (See Draft EIR, p. 4.2-6, Figure 4.2-2, p. 4.2-20.) Further details regarding the existing agricultural setting are provided in the Existing Setting Report. The Draft EIR also describes the extent to which build-out of the General Plan will result in impacts to agricultural resources. (Draft EIR, pp. 4.2-20 – 4.224.) This approach is consistent with the requirements of CEQA Guidelines section 15125 and related caselaw.

The Draft EIR also contains an analysis of the no-project alternative. The no-project alternative assumes build-out of the existing General Plan, Specific Plans, and Community Plans. (See Draft EIR, p. 6-13.) The impacts of this alternative are compared with those that would result under the proposed General Plan. (See Draft EIR, pp. 6-14 – 6-21.)

In sum, the Draft EIR contains all of the following information:

• A detailed description of the existing environmental setting;

• An analysis of the impacts resulting upon build-out of the proposed General Plan, measured against that existing setting; and

• An analysis of impacts resulting from build-out of the existing General Plan ("no project").

For this reason, the County believes it has complied with CEQA Guidelines sections 15125 and 15126.6, and related case law. Moreover, the County also believes the Draft EIR provides the public and decision-makers with a complete understanding of the consequences of approving the project.

KK-15 As stated previously, the Existing Setting Report (incorporated by reference into the Draft EIR) identified Riverside County land use characteristics as they existed at the start of the RCIP process. Included in this information are listings and maps of all planned land uses within Riverside County, community plans, adopted specific plans, and existing development agreements.

The listing of specific plan developments below will be added to the EIR, following the first paragraph on page 4.2-6 of the Draft EIR. The Board of Supervisors will be provided with updated land use maps which will include these specific plans.

Riverside County Specific Plan Developments - February 2003
Specific
Plan
Maximum
Dwelling Units
Built
Dwelling Units
"A" Street Corridor - -
Highland Springs 1,630 993
Dutch Village 1,500 658
Mission Lakes 2,358 369
Frank Domeno 71 -
Tract Map 4437 310 259
The Farm 1,934 952
Mission De Anza 3,458 2,249
Red Mountain 49 48
Sky Country 1,159 1,159
Republic 452 216
El Nino 203 155
Sky Mesa 112 92
River City 461 -
Newport Estates 856 -
Lake Hills 1,757 1,012
North Star Ranch 1,666 -
Horsethief Canyon 2,132 1,959
Menifee Village 5,254 2,742
Green River Medows 507 507
Walker Basin 1,444 -
Riverview Ranch 172 -
Wild Rose 1,181 1,013
Four Seasons 896 896
Rancho Nuevo 508 -
Rancho Bella Vista 1,998 1,137
Countryside 1,154 -
Belle Meadows 141 -
Cal Neva 1,670 676
Audie Murphy Ranch 3,596 -
Agua Mansa 376 -
Andreas Cove - -
Mesa Grande 200 -
Winchester Properties 2,669 1,462
Redhawk 4,188 1,792
Coral Mountain 1,360 -
Mountain Springs 1,571 392
Woodcrest Country Club 310 -
Centerpointe 280 -
HB Ranches 1,421 -
Adams 34 Ranch 939 -
Crown Valley Village 591 -
Stoneridge 2,236 -
Rio Vista 1,687 -
Preissman 3,088 -
Menifee East 1,283 -
Newport Hub - -
Gateway Center 553 -
Lakeview Nuevo 185 -
Sycamore Creek 1,733 -
Menifee North 2,388 5
Arbor Creek Estates 56 -
Borel Airpark - -
I-15 Corridor 2,400 283
Victoria Grove 1,144 450
Canyon Heights 775 -
Del Webb 5,075 4,095
Canyon Cove 485 -
Quinta Do Lago 1,318 291
Winchester 1800 5,196 486
The Crossroads at Winchester 795 -
Winchester Hills 5,633 -
Alta Cresta Ranch 3,438 -
Eastvale 2,769 1,635
Menifee Ranch 4,067 -
Kohl Ranch 7,171 -
Eagle Mountain - -
Eagle Mountain Townsite 432 -
Gavilan Hills Golf Course - -
Domenigoni-Barton 4,600 -
French Valley 1,793 -
Morgan Hill 1,129 -
The Retreat 545 -
Oak Valley 4,356 -
BSA Properties 421 -
Spring Mountain Ranches 1,518 -


Proposed Specific Plans In Riverside County
Proposed Specific Plan Dwelling Units in Proposal
Dutch Village 1,450
Dutch Village 1,550
Walker Basin 77
Audie Murphy 2,129
Mesa Grande 499
Menifee North 2,677
Canyon Heights 439
Winchester 1800 4,870
Gavilan Hills 644
The Highlands 1,440
Sierra Highlands 65
Murietta Hills 1,879
Vail Lake 5,172
McAllister Hills 321
Victoria Grove East 1,345
Temescal Hills 1,800
Creekside 1,312
Springbrook Estates 1,000
Eastvale 2 473


The Commentor also states that the EIR lacks analysis of whether the proposed land use policies will achieve General Plan "goals." However, on page 4.2-20 of the EIR it states:

Effectiveness of Proposed General Plan Policies While several proposed General Plan land use policies allow the County to "encourage," "promote," or "coordinate" efforts to minimize potential land use impacts, they do not definitively mandate the scope of action required by the County. Several more do provide concrete and specific requirements with the intent to reduce potential impacts that may result from the development of land uses as envisioned in the proposed General Plan. Specifically, LU 2.1, 3.1, and 6.1 state that development within the County will occur in conformance with the proposed General Plan and Area Plans. Other policies, LU 6.4, 6.5, 22.6, and 26.10 require the use of buffering, setbacks and design features to ensure compatibility between adjacent uses and to mitigate/minimize potential impacts.

A main purpose of the proposed General Plan is to ensure future development follows a consistent and orderly pattern. As development occurs, it would be required to be consistent with the goals and policies of the proposed General Plan. Because the aforementioned policies will ensure compliance with the proposed General Plan and provide for the implementation of measures to buffer adjacent uses from potentially adverse impacts of neighboring uses, potential impact associated with the alteration of land use designations will be reduced to a less than significant level. No additional mitigation is required.

While the amount of land in the County utilized for agricultural production has generally decreased, the amount of crops and value of said production has generally increased. As set forth in proposed Land Use Policy LU 1.1, the General Plan would, "...allow for the continued occupancy, operation, and maintenance of legal uses and structures that exist at the time of the adoption of the General Plan...." As such, existing agricultural uses that exist on land designated for other land uses, would be permitted to continue operation. It is upon the conversion from agriculture to new development that the requirements of the underlying land use would apply.

The General Plan EIR does state that the proposed Agricultural Land Mitigation Bank would be established within three years from adoption of the General Plan and require projects converting more than 160 acres of Prime, Unique, or Statewide Important farmland to purchase agricultural land credits. While designated by the State as Prime, Unique, or Statewide Important, land may or may not be currently utilized for agricultural production (the Prime and Statewide Important designations require production of irrigated crops in only one of the four years prior to mapping studies). As stated earlier in this response, agricultural operations existing at the time the General Plan is adopted will be permitted to continue. The stated mitigation attempts to preserve a portion of those lands deemed suitable for agricultural production, but not necessarily harboring agricultural uses. As with the extent, configuration, type, and mix of agricultural crops; the demographic, economic, social, and political inclinations of farmers and/or landowners varies between jurisdictions. Each jurisdiction must be permitted to address potentially significant impacts in a manner best suited to the unique combination of conditions that exist within the jurisdiction . While the agricultural protection measures noted by the Commentor may "work" in Livermore or Davis, it does not follow that they will adequately satisfy the desires of the landowners and residents of Riverside County, or achieve the goals and objectives set forth in the County General Plan. The Commentor does not provide substantial evidence that the stated mitigation would be infeasible; therefore; it will remain (as revised below) as a component of the EIR.

The discussion of potential impacts to agricultural land included in Section 4.2, pages 4.2-20 and 4.2-24 of the EIR has been revised as follows:

Impact 4.2.2 The proposed General Plan update will result in the conversion of prime farmlands, unique farmlands, farmland of statewide importance, or land actively utilized for agricultural production to a variety of non-agricultural uses.

4.2.2A The County shall establish an Agricultural Land Mitigation Bank. The formation, authority, and operation shall be established by the County of Riverside and shall adhere to applicable statutes of the State of California and Riverside County. The Agriculture Land Mitigation Bank shall be established no later than two years from the date of adoption of the 2002 Riverside County General Plan.

4.2.2B Subsequent to the establishment of an Agricultural Land Mitigation Bank, any development within any unincorporated area of the County resulting in the conversion of more than 80 acres of Prime, Unique, or Statewide Important farmland (designated farmland), as designated by the most recent version of the Important Farmland Map as prepared by the California Department of Conservation, Farmland Mapping and Monitoring Program, shall purchase credits in the Agricultural Land Mitigation Bank at the rate of 1 acre (credit) for every four acres (or portion thereof) of designated farmland converted to non-agricultural uses. The 80acre threshold shall be met by any combination of designated farmland. All designated farmland within a project site shall be included in the threshold computation, regardless of the size, or location within the project site, or current status (fallow or farmed).

4.2.2C Subsequent to the establishment of an Agricultural Land Mitigation Bank, any development within unincorporated Riverside County resulting in the conversion of more than 40 acres of land actively utilized for agricultural production (active farmland), shall purchase credits in the Agricultural Land Mitigation Bank at the rate of one acre (credit) for every acre (or portion thereof) of active farmland converted to non-agricultural uses. To be considered "active farmland," land must have been utilized for agricultural production for two of the previous five years (prior to application). The 40-acre threshold shall be met only by the footprint of land on which crops are grown or livestock raised regardless of whether the land is State designated or not; and shall not include roadways, residential or production areas, equipment storage areas, or other non-production areas.

State CEQA Guidelines Section 15126.4(a)(1) states an EIR shall, "...describe feasible measures that could minimize significant adverse impacts..." The stated measures will require the preservation of an as-of-yet undetermined amount of agricultural land in the County, and therefore; "minimizes" an identified significant adverse impact. Despite the incorporation of the stated mitigation, and despite the implementation of General Plan policies and mitigation, the potential loss of farmland would remain significant and unavoidable impact. Per Sections 15091 through 15093 of the State CEQA Guidelines, the County, acting in the capacity of Lead Agency, shall provide written findings that significant and unavoidable impacts to agricultural resources are "acceptable" per due to "overriding concerns."

KK-17 Section 4.2 of the Draft EIR adequately addresses the physical impact that the proposed General Plan will have on agriculture within the County. As documented in the Draft EIR, implementation of the proposed General Plan will result in a substantial loss of land currently devoted to agricultural use, including prime agricultural soils, as the result of conversion to various urban and rural uses. This impact will occur incrementally over the more than 40-year build out period of the proposed General Plan. The assertion in Comment KK-17 that the Draft EIR needs to include an analysis of how the proposed General Plan is consistent with the factors set forth in the Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 (Government Code Section 56000 et. seq.) is incorrect.

The Cortese-Knox-Hertzberg Local Government Reorganization Act1, encourages the orderly formation and development of local government agencies through Local Agency Formation Commissions (LAFCOs), which are regulatory agencies within each county. The Act does not address General Plans, nor does it create any land use requirementsto be met in a community's General Plan. The Act does not bestow LAFCOs with authority over land uses that are proposed within a city or county General Plan, nor does it set forth General Plan requirements for cities and counties. Government Code Section 56375(a)(3) specifically states that LAFCOs "shall not impose any conditions that would directly regulate land use density or intensity, property development, or subdivision requirements." LAFCOs are authorized to address issues of conversion of agricultural land to open space use only in the context of reviewing proposals for annexations to cities or special districts and modifications to their spheres of influence.

Section 56377 of the Government Code requires LAFCOs, when reviewing and approving or disapproving proposals to modify boundaries or spheres of influence for cities and special districts that could "reasonably be expected to induce, facilitate, or lead to the conversion of existing open-space lands to uses other than open-space uses," to "consider" all of the following policies and priorities.

(a) "Development or use of land for other than open-space uses shall be guided away from existing prime agricultural lands in open-space use toward areas containing non-prime agricultural lands, unless that action would not promote the planned, orderly, efficient development of an area.

(b) Development of existing vacant or non-prime agricultural lands for urban uses within the existing jurisdiction of a local agency2 or within the sphere of influence of a local agency should be encouraged before any proposal is approved which would allow for or lead to the development of existing open-space lands for non-open-space uses which are outside of the existing jurisdiction of the local agency or outside of the existing sphere of influence of the local agency."

The Act does not establish any CEQA requirements nor does it set criteria that are to be used for the analysis of the impacts that a proposed project might have on agricultural resources pursuant to CEQA. The only responsibility bestowed by the Act is for the County LAFCO to consider the above policies and priorities in their review of proposals for annexations to cities or special districts and modifications to their spheres of influence.

Although there is no requirement to determine the consistency of the General Plan with respect to the Cortese-Knox-Hertzberg Local Government Reorganization Act, the Draft EIR does recognize the existence of agricultural preservation policies in the proposed General Plan. Some of these policies include:

1The Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 is briefly described in Section 4.2 of the General Plan EIR.

2As used in the Act, "local agency" in this context refers to cities, county service areas, and special districts.

Land Use Element Policy 16.1 Retain agriculturally designated lands where agricultural activity can be sustained at an operational scale, accommodates lifestyle choice and in locations where impacts to potentially incompatible uses, such as residential uses are minimized.

Land Use Element Policy 16.2 Protect agricultural uses, including those with industrial characteristics (diaries, poultry, hog farms, etc.) by discouraging inappropriate land division in the immediate proximity and allowing only uses and intensities that are compatible with agricultural uses.

Land Use Element Policy 16.4 Encourage conservation of productive agricultural lands. Preserve prime agricultural lands for high-value crop production.

Land Use Element Policy 16.5 Continue to participate in the California Land Conservation Act (The Williamson Act) of 1965.

Land Use Element Policy 16.6 Require consideration of State agricultural land classification specifications when a five-year Foundation Component amendment to the General Plan is reviewed that would result in a shift from an agricultural to a non-agricultural use.

Open Space Element Policy 7.2 Consider the use of agricultural land conservation programs that improve the viability of farms and ranches, thereby ensuring long-term conservation of viable agricultural operations. Examples of programs to be considered include land trusts; conservation easements; dedication incentives; Farmland Security Act contracts; the Agricultural Land Stewardship Program Fund; agricultural education programs; and transfer and purchase of development rights.

Open Space Element Policy 7.3 Encourage conservation of productive agricultural lands. Preserve prime agricultural lands for high-value crop production.

Open Space Element Policy 7.5 Encourage the combination of agriculture with other compatible open space uses in order to provide an economic advantage to agriculture. Allow by right, in areas designated Agriculture, activities related to the production of food and fiber, and support uses incidental and secondary to the on-site agricultural operation.

The Act also does not give LAFCOs with authority over land uses that are proposed within a city or county General Plan, nor does it set forth General Plan requirements for cities and counties. Government Code Section 56375(a)(3) specifically states that LAFCOs "shall not impose any conditions that would directly regulate land use density or intensity, property development, or subdivision requirements." LAFCOs are authorized to address issues of conversion of agricultural land to open space use only in the context of reviewing proposals for annexations to cities or special districts and modifications to their spheres of influence. According to the Riverside LAFCO Strategic Plan, the following objectives and policies will be followed to protect the conversion of agricultural land:

Objective No. 2: Preserve the physical and economic integrity of agricultural lands.

Strategy 1.2.1 City SOIs shall be directed away from substantial areas of prime agricultural land, unless:

1. The result would not facilitate an orderly development pattern; and,

2. The city's general plan allows for the continued operation of agricultural uses and provides guidelines for the ultimate development of agricultural land at the time the use is terminated or development is proposed.

Strategy 1.2.2 LAFCO shall deny the annexation of agricultural lands unless they meet the criteria specified below:

1. The annexation of land located within an agricultural preserve may be approved only when:

a) A notice of non-renewal or cancellation has been filed on the affected property proposed for annexation, or,

b) The jurisdiction's General Plan contains appropriate language:

1) To allow for the effective and continued operation of agricultural uses, and;

2) To provide guidelines for the ultimate development of agricultural land at the time the preserve is terminated or development is proposed.

2. The loss of non-prime agricultural lands should not be a central issue for annexation where city or county general plans provide for urban development and the proposal would not impact the integrity of surrounding prime agricultural lands.

Section 56377 of the Government Code requires LAFCOs, when reviewing and approving or disapproving proposals to modify boundaries or spheres of influence for cities and special districts that could "reasonably be expected to induce, facilitate, or lead to the conversion of existing open-space lands to uses other than open-space uses," to "consider" all of the following policies and priorities.

KK-18 The size requirements of the buffers required by the General Plan policies will be determined on a project-by-project basis, as appropriate to the circumstances of each project.

KK-19 CEQA does not require the inclusion of such a map. The information provided is sufficient for a program-level EIR. If an individual wants information regarding a specific parcel that is in a Williamson Act contract, the County can provide this information. For a General Planlevel analysis, it is not feasible to provide this information on a County-wide basis.

KK-20 The consistency between the proposed General Plan and the MSHCP is discussed extensively in Sections 1.1 and 3.1 of the Draft EIR. As indicated as follows and in Section 3.0 of the Final EIR, this text has been amended to clarify the issue.

Section 1.1, page 1-1, second paragraph

The challenge of balancing the housing, transportation, and economic needs of existing and future populations with limited natural resources and the sensitivity of the natural environment has led Riverside County to develop the Riverside County Integrated Project (RCIP). The RCIP, which consists of three coordinated plans, will determine future planning, transportation, and conservation needs for Riverside County. These three plans include the following:

• The 2002 Riverside County General Plan (Comprehensive General Plan Amendment No. GPA00618)

• The creation of a Multiple Species Habitat Conservation Plan (MSHCP) for the western portion of Riverside County, and the integration of an ongoing Coachella Valley Multi-Species Habitat Conservation Plan effort (which is not a part of RCIP but is a related program) into the fabric of comprehensive planning for the County.

• The identification of transportation corridors to meet the future transportation needs of Western Riverside County through the Community Environmental and Transportation Acceptability Program (CETAP).

Each of the plans has independent utility, and each can be approved without approval of the others. They will, however, be coordinated such that if all three are adopted, no conflicts between the plans will occur. This document focuses on the 2002 Riverside County General Plan, which is the proposed project.

Section 3.1, page 3-1, paragraph 4

The challenge of balancing the housing, transportation, and economic needs of existing and future populations with limited natural resources and the sensitivity of the natural environment required Riverside County to develop the Riverside County Integrated Plan (RCIP), which consists of three coordinated plans to determine future planning, transportation, and conservation needs for Riverside County. These plans include the 2002 Riverside County General Plan, the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP), and the Community Environmental and Transportation Acceptability Program (CETAP). Each of the plans has independent utility, and each can be approved without approval of the others. They will, however, be coordinated such that if all three are adopted, no conflicts between the plans will occur.

Section 3.1, page 3-6, paragraph 1

The Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) involves the assembly and management of a reserve system for the conservation of natural habitats and their constituent wildlife populations. The MSHCP establishes a framework for complying with State and federal endangered species regulations, while accommodating future growth within the cities and unincorporated portions of western Riverside County. Thus, unlike the proposed General Plan, the MSHCP covers only the western portion of the County, and covers not only unincorporated areas, but cities as well. The MSHCP is designed to be complementary to the 2002 Riverside County General Plan, but could also be adopted in the event that the 2002 Riverside County General Plan were not.

Section 3.1, page 3-7, paragraph 1

The CETAP component of RCIP identifies transportation corridors to meet the future transportation needs of Riverside County. CETAP is a multi-modal planning effort that considers highway options, and also looks at transit and other forms of travel demand management and goods movement. CETAP is designed to be complementary to the 2002 Riverside County General Plan, but could also be adopted in the event that the 2002 Riverside County General Plan were not.

Section 3.1, page 3-7, fourth paragraph

Relationships and Differences Between RCIP Components

The 2002 Riverside County General Plan recognizes the Western Riverside County MSHCP, and incorporates the MSHCP into its Area Plans as mitigation for the biological impacts that will result from development permitted by the proposed General Plan. The proposed General Plan also incorporates by reference the Coachella Valley MSHCP being prepared by the Coachella Valley Association of Governments parallel to, but separate from, RCIP. The proposed General Plan Circulation Element includes proposed CETAP corridors as part of its proposed roadway and highway system.

The MSHCP provides comprehensive mitigation for the development impacts that will result from development of the proposed General Plan land uses and transportation facilities (including CETAP corridors) within the western portion of the County, including development of proposed CETAP corridors. The MSHCP also includes CETAP corridors as permitted activities where they cross MSHCP preserve areas.

The RCIP consists of three coordinated plans, the 2002 Riverside County General Plan (which is the subject of this Program EIR), the Western Riverside County MSHCP, and the CETAP. Although coordinated, these three plans are independent components of RCIP. As an independent plan, the 2002 Riverside County General Plan is not reliant upon the approval of either MSHCP or CETAP. The proposed General Plan is, however, coordinated with the MSHCP and the CETAP, so that no substantive conflicts or inconsistencies exist among the three plans. The General Plan is consistent with the draft MSHCP in that some of the draft MSHCP policies for biological resource preservation and mitigation are incorporated into the proposed General Plan's Area Plans. The biological resource policies incorporated into the Area Plans provide partial mitigation for development impacts that would result from development proposed by the General Plan's identified land uses, infrastructure, and transportation facilities. The proposed General Plan also is consistent with the draft CETAP in that the proposed General Plan Circulation Element recognizes the potential for proposed CETAP corridors as part of its proposed roadway and highway system.

Section 3.1, page 3-8, paragraph 2

Although they are clearly related projects, and are each part of an integrated planning program, as described above, each RCIP component covers a different physical area, is being prepared pursuant to different State and federal laws, involves different agencies in their approval, and has different lead agencies for their environmental documentation. In addition, each RCIP component is on a slightly different schedule. As a result of these differences, preparation of a single environmental document was found to be impractical. Such a document would prove to be overly complex and impossible difficult to understand. Instead, each environmental document prepared from components of the RCIP program contains a cumulative impact analysis, summarizing the overall impacts of RCIP. Finally, each RCIP component has independent utility, and could be adopted in the absence of adoption of the other components.

Section 3.4, page 3-81, after last paragraph

The EIR analysis relies on GIS data, which is based on the proposed General Plan description. However, because of the nature of GIS calculations, some acreages reported in the EIR may be slightly different from those indicated in the 2002 Riverside County General Plan Area Plans. These minor discrepancies do not affect the adequacy or accuracy of the EIR's environmental analysis..

KK-21 The EIR does provide a discussion on the on the effects on the General Plan on regional plans in Section 5.5. The State CEQA Guidelines do not require that the EIR discuss the internal consistency of the General Plan. The General Plan is required to be internally consistent per State planning law. The Commentor does not identify specific inconsistencies purported to be in the EIR. Absent this information, no further response is possible.

KK-22 This comment is a summary of the Commentor's issues relating to population and housing impacts of the proposed General Plan. These issues are discussed in further detail following the summary. Detailed responses to the issues raised are below.

KK-23 The Commentor states that the EIR provides insufficient setting information; therefore, analyses cannot be complete. However, page 2-4, section 2.2.1

of the Draft EIR states that the Riverside County Integrated Plan (RCIP) Existing Setting Report is incorporated by reference and provides a single environmental baseline inventory that will be used in the preparation of subsequent environmental documents for each of the three plans comprising the RCIP. The Existing Setting Report presents the results of an intensive research effort aimed at identifying the physical, social, and economic characteristics (including population, housing, and employment) of Riverside County, which need to be understood to formulate goals, objectives, and policies for the integrated planning effort. Additionally, the EIR includes both current and projected jobs/housing balance information without the proposed General Plan. This information is contained in Table 4.3.B, 4.3.C, and 4.3.D. The purpose of the General Plan was to improve the jobs-tohousing imbalance in the County. As a result, more land is designated to accommodate job-related uses, which will provide the opportunity for development. The County General Plan provides the means for balancing jobs and housing but it cannot control market forces that encourage development. The SCAG projections are based on the existing Riverside County General Plan without the adoption of the Proposed General Plan.

KK-24 The purpose of the proposed General Plan EIR is not to ensure that the General Plan objectives are attained; the purpose of the EIR is to evaluate the potential environmental impacts associated with the implementation of the proposed General Plan. The EIR has the ability to propose mitigation measures to avoid significant environmental impacts; however, it cannot consider adding any additional policies. The Commentor had the opportunity to propose objectives and policies through the General Plan community outreach process. The community outreach process for the General Plan included workshops, surveys, public hearings, and written comments to the General Plan Advisory Committee.

KK-25 The proposed Riverside County General Plan and the EIR cover the entire unincorporated portion of the County. The County has no land use jurisdiction in the Cities. The analysis in the EIR included build out of the Cities at their General Plan densities. The General Plan build out is depicted in Table 4.3C on page 4.3-5 of the Draft EIR. This includes the infill potential within the unincorporated County. Furthermore, an infill alternative was considered for land use within the County's jurisdiction. The housing discussed by the Commentor is within the range of alternatives analyzed in the Draft EIR.

KK-26 The Commentor is assuming that if roadways are expanded to Orange County that job growth will not occur in Riverside County. Obviously, there is an abundance of people who live in western Riverside County and San Bernardino County and commute to Orange County on the SR-91 and various surface streets everyday to work. The commute on the SR-91 is one of the worst in California. It is unreasonable to assume that these people enjoy their commute to and from Orange County each day so they may live in an affordable community. It is also unreasonable to assume that if the roadways are improved into Orange County that job growth will not occur in Riverside County. Job growth occurs because of a number of factors including work force education and availability, regional transportation facilities including airports and rail lines, quality of life for employees and the employer, availability of affordable land, and various other factors. Since our economy works on a free enterprise system, you one can not force a person to live in the same community that they work in. Besides improving the roadways between Riverside and Orange County will improve the movement of goods which is essential to strong economy.

KK-27 The type of analysis the Commentor is requesting is required by State law within the Housing Element portion of the General Plan and must be reviewed by the State Department of Housing and Community Development for compliance. The Riverside County Board of Supervisors adopted the current Housing Element as an amendment to the existing General Plan on December 4, 2001.

The State of California Housing Element law requires all cities and counties to "make adequate provision for the housing needs of all economic segments of the community" (Section 65583 (a) (1)-(2)). This requires the Housing Element to contain a detailed analysis of the locality's housing needs, resources, and constraints to housing development (including affordability); and a 5-year program of actions to address those needs, resources, and constraints. The statute specifically requires the housing element to include a comparison of the housing payment with the ability to pay. Overpaying for housing is also known as the housing cost burden. The housing element law requires that the County prepare a new housing element every five years and submit the element to the state Department of Housing and Community Development (HCD) for review and approval. The housing element update must be accompanied by adequate environmental analysis per CEQA. The housing element update is the proper document to analyze such impacts, not only because it is required by law and is subject to CEQA, but also because it is updated every 5 years and can remain current with the needs of the County.

Additionally, the jobs/housing analysis in Section 4.3 of the Draft EIR includes data derived from land use designations, which are indicative of the number of employment opportunities that will arise from the proposed General Plan. However, without specific details regarding future developments, it is impossible to evaluate the income of new workers. Through the County's environmental review process, future development projects would be evaluated for potential jobs/housing imbalance impacts.

KK-28 Refer to responses KK-29 through KK-36.

KK-29 The transportation analysis was based on a traffic model that included not only Riverside County, but also San Bernardino, Orange, and Los Angeles Counties. The mapping used to illustrate results focused mainly on Riverside County, but also included portions of San Bernardino County to the north of the City of Riverside and Moreno Valley. In review of this information, the out-of-county impacts of the build out of the Riverside County General Plan are most evident on the freeway system, and range up to 8 percent of total traffic volume on freeway segments at the Riverside County/San Bernardino County line. Farther into San Bernardino County, the impacts are reduced. Impacts in Orange and San Bernardino County are negligible, partly because the General Plan places substantial emphasis on job creation in Riverside County, which helps to reduce out-of-county trips. The improved jobs/housing balance should also help reduce regional impacts.

KK-30 The analysis of transit included an assessment of what might be called "background" transit ridership as well as transit ridership that might be associated with the Transit Oasis express transit system developed through the RCIP. The overall result of this analysis was an approximate 3-percent capture rate for transit trips in the build out condition. The capture rate would be higher for peak commuting periods. The capture rate for trips between transit nodes would be considerably higher than the countywide average capture rate. The analysis was not constrained by transit capacity. It is believed that the method used to analyze this long range transit program is a reasonable representation of what is likely to occur. The County's General Plan provides land uses that support an increase in transit ridership. The General Plan states in Housing Element under implementation 1.2i: "As part of the General Plan update, designate residential land use districts in the unincorporated County within close proximity to major transportation corridors and transit nodes with more intensive uses and mixed-use development. Designate less intensive uses in more rural area."

KK-31 The analysis assumed development densities that were reasonably likely to occur, on average, given the land use classifications. Some parcels may be developed at slightly higher densities than the averages assumed, while others may be developed at slightly lower densities. It is believed that the average densities used in the analysis are a reasonable representation of what is likely to occur on an aggregate basis. Also, because actual build out rarely occurs, it is possible that the traffic forecasts provided in the analysis could well be higher than would actually occur.

KK-32 Response to #1: The traffic analysis in the Section 4.16 of the EIR and provided in Appendix C of the EIR is based on the land uses proposed under the General Plan. The traffic analysis was based on the full build out of the Riverside County General Plan. The analysis assumed development densities that were reasonably likely to occur, on average, given the land use classifications. Some parcels may be developed at slightly higher densities than the averages assumed, while others may be developed at slightly lower densities. It is believed that the average densities used in the analysis are a reasonable representation of what is likely to occur on an aggregate basis. Also, because actual build out rarely occurs, it is possible that the traffic forecasts provided in the analysis could well be higher than would actually occur.

Response to #2: Regarding the CETAP corridors, the General Plan traffic analysis assumed that a new limited access facility would be in place in the Winchester to Temecula Corridor linking SR-79 in Winchester with I-215 near Scott Road (generally representing Alternative 7b, which has been recommended by RCTC staff). There was no assumption of a freeway-level eastern bypass around Temecula. It should be noted that the CETAP alternatives have only received a staff recommendation, and that there is currently no locally preferred alternative that has been adopted by RCTC or the Federal Highway Administration.

Respone to #3: The EIR includes the Riverside/Orange County corridor as mitigation for impacts to the SR-91. It is not a General Plan policy. As discussed in response to #1 the Circulation Element and the impacts to traffic and circulation are based on build out of the proposed land uses in the General Plan so the two elements of the General Plan are correlated.

Response to #4: Whether to adopt a policy mandating LOS requirements (like El Dorado County) is at the discretion of the County Board of Supervisors.

Response to #5: The voters of the County have passed Measure A, which extends the tax on gasoline so that the monies can be used on roadway improvements. Also, new development will be required to pay its fair-share for roadway infrastructure improvements.

KK-33 Initiatives to improve job/housing ratios and to create transit nodes have been expressed as policies in the General Plan. Although Caltrans has a desire to design freeways to accommodate traffic demand, they have no formal LOS standard and recognize that peak period congestion has to be expected on the freeway system. As a matter of policy, the County is not proposing a level of service standard for freeways. Freeways are under the jurisdiction of Caltrans. Since Caltrans has different standards, it are responsible for addressing service levels on the freeway system. The traffic analysis indicates that the build out of the County General Plan contributes relatively small percentages of the total traffic expected on the freeways at build out. Through traffic and land development in the cities contribute substantially to future congestion on the freeway system. Each of the freeways will ultimately include High Occupancy Vehicle (HOV) lanes, and these will be important to the functioning of a viable express transit system, enabling transit vehicles to substantially avoid freeway congestion when it occurs. The expectation is that as freeway congestion grows on the mixed flow lanes, transit will become more attractive, and commuters will still have reasonable modal choices. The General Plan cannot dictate or require that people use transit, but the General Plan supports Caltrans, RCTC, and RTA initiatives to implement HOV lanes and to run efficient express transit services on those lanes or on other dedicated or non-dedicated facilities.

KK-34 The EIR does address the indirect effects of the Circulation Element on the physical environment. The CETAP corridors that are necessary roadways to facilitate growth projected in the General Plan are included on the Circulation Map; therefore, the indirect effects fo the CETAP corridors were analyzed in the EIR.

KK-35 The Commentor is assuming that the ultimate build out of the proposed General Plan was not analyzed in the EIR. As discussed previously, the average build out for land uses was used for all impacts analyzed in the EIR. The traffic analysis clearly states its land use assumptions in analyzing the impacts. The County disagree with the Commentor and believes the traffic analysis undertaken represents a reasonable assessment of land uses that will develop over build out of the General Plan.

KK-36 Mitigation Measure 4.16.1.A requires development projects to mitigate their traffic impacts on roadways. Circulation Element Policy 2.1 establishes roadway level of service to be applied to new developments. Findings of consistency with the General Plan will require that new development projects demonstrate that the standards set forth in that policy will be met. If, as the result of such development, level of service standards will not be met, the project will be required to provide appropriate improvements to ensure that level of service standards will be met. If level of service standards are not met as the result of existing development, a finding of consistency with Circulation Element Policy 2.1 will require appropriate mitigation. Circulation Element Policy 2.3 addresses development projects that propose to increase the development intensity set forth in the General Plan, and ensures mitigation of impacts in those cases.

Riverside County has adopted a Transportation Uniform Mitigation Fee for the western portion of the County, as have many of the cities. This fee will provide funding for implementation of the General Plan Circulation map, and will mitigate the impacts of new development.

Policies aimed at reducing traffic impacts through design measures are set forth in the General Plan as follows:

Land Use Element Policy 2.1 Accommodate land use development in accordance with the patterns and distribution of use and density depicted on the General Plan Land Use Map (Figure LU-1) and the Area Plan Land Use Maps, in accordance with the following:

d. Concentrate growth near community centers that provide a mixture of commercial, employment, entertainment, recreation, civic, and cultural uses.

e. Concentrate growth near or within existing urban and suburban areas to maintain the rural and open space character of Riverside County to the greatest extent possible.

f. Site development to capitalize upon multi-modal transportation opportunities and promote compatible land use arrangements that reduce reliance on the automobile.

Land Use Element Policy 3.1 Accommodate land use development in accordance with the patterns and distribution of use and density depicted on the General Plan Land Use Maps (Figure LU-1) and the Area Plan Land Use Maps in accordance with the following concepts:

d. Create street and trail networks that directly connect local destinations, and that are friendly to pedestrians, equestrians, bicyclists, and others using non-motorized forms of transportation.

e. Re-plan existing urban cores and specific plans for higher density, compact development as appropriate to achieve the RCIP Vision.

f. In new towns, accommodate compact, transit-adaptive infrastructure (based on modified standards that take into account transit system facilities or street network).

g. Provide the opportunity to link communities through access to multi-modal transportation systems.

Land Use Element Policy 12.1 Provide land use arrangements that reduce reliance on the automobile and improve opportunities for pedestrian, bicycle, and transit use in order to minimize congestion and air pollution.

Land Use Element Policy 12.2 Locate employment and service uses in areas that are easily accessible to existing or planned transportation facilities.

Land Use Element Policy 12.3 Locate transit stations in community centers and at places of public, employment, entertainment, recreation, and residential concentrations.

Land Use Element Policy 12.4 Incorporate safe and direct multi-modal linkages in the design and development of projects, as appropriate.

The General Plan Land Use Element also designates Community Centers, including Village Centers and Town Centers to provide "walkable communities," and reduce reliance on the private automobile. The General Plan states that Community Centers "accommodate a variety of residential densities, nonresidential intensities and public spaces that are integrated in a manner that promotes pedestrian activity and minimizes the dominance of the automobile. Public and quasi-public uses such as civic buildings, schools, open space, recreational and cultural facilities are also integral parts of community centers. Because of their more intense, compact nature of development, community centers accommodate and enhance the feasibility of providing transit service and other forms of transportation, including pedestrian and bicycle travel."

Within this broad category, Village Centers are designated to be "pedestrianoriented community centers that serve adjacent and nearby residential neighborhoods. These are the smallest scale community centers and are intended to reflect a village, or small downtown atmosphere. The Village Center is most appropriately located in a suburban type environment." The General Plan also designates Town Centers to "allow for a more intense and intimate mix of land uses when compared to the Village Center. Town Centers can be located in dense urban areas or as a core for a large area of suburban development. The Town Center provides uses such as those found in a traditional "downtown" district. Town Centers provide regional attractions and facilities in addition to those uses that serve local residents and workers."

Circulation Element Policy 11.2 Incorporate the potential for public transit service in the design of developments that are identified as major trip attractions (i.e., community centers, tourist and employment centers), as indicated in ordinances Regulating the Division of Land of the County of Riverside.

Circulation Element Policy 11.3 Design the physical layout of arterial and collector highways to facilitate bus operations. Locations of bus turn outs and other design features should be considered.

Circulation Element Policy 11.4 Offer incentives to new development to encourage it to locate in a transit-oriented area such as a community center or along a designated transit corridor near a station.

Circulation Element Policy 11.5 Accommodate transit through higher densities, innovative design, and right-of-way dedication.

Circulation Element Policy 11.6 Encourage the designation of exclusive transit-only lanes on freeways.

Circulation Element Policy 11.7 Promote development of transit centers and park-n-rides for use by all transit operators, including development of multi-modal facilities.

The Circulation Element also sets forth the "transit oasis" concept as a means of the reducing reliance on the private automobile. The Transit Oasis is a "system that can provide transit service to concentrations of employment, community activity, and residences while maintaining reasonable travel times and just as importantly, be built and operated at a reasonable cost....The concept of the Transit Oasis is to provide an integrated system of local serving, rubber-tired transit that is linked with regional transportation opportunities. In this manner, convenient options to travel are provided. In the Transit Oasis, the transit vehicles would be given prioritization on roadways so they could operate at consistently high frequencies and regular intervals."

The intent of the General Plan Circulation Element is the "integration of the Transit Oasis into the predominately suburban lifestyle of Riverside County." As envisioned by the General Plan, the Transit Oasis is a "fundamental part of the community that is designed to fit with the density, scale, pedestrian-friendly atmosphere, and safe environment of each neighborhood or community center. Community centers provide the type of concentrated development patterns, residential densities, and employment intensities that are necessary to allow the Transit Oasis concept to become a reality."

KK-37 Although a Federal standard for PM2.5 was adopted, the EPA (or any State air quality agency) has not established any emission factor for PM2.5 from potential sources, such as construction activity or vehicle exhaust. The air quality analysis provided a good faith estimate for four criteria pollutants (CO, NOX, PM10, and SOX) and one ozone precursor (ROC) from construction activity, and three criteria pollutants (CO, NOX, and PM10) and one ozone precursor (ROC) from vehicular exhaust under future General Plan build out conditions. Lead emissions are not estimated, because the entire State of California has been in attainment for federal and State standards in the past 10 years and fewer sources containing lead are being used. In addition, the California Air Resources Board's emission models, such as EMFAC and URBEMIS, no longer provide emissions estimates for SOX, due to similar reason for lead. Until the EPA or ARB establish emission factors for PM2.5, emissions estimates for PM2.5 are not available.

KK-38 The proposed General Plan provides a conceptual vision for the future build out scenario over the entire County. It is impractical at this time to map out individual developments throughout the entire County. Air quality policies for trip reduction, Air Quality Policies 10.1 through 10.4, encourage "walkable" projects that would reduce trips in the County.

KK-39 Similar to response KK-38, the General Plan provides a conceptual vision for the future build out scenario over the entire County. It is impractical at this time to map out individual developments throughout the entire County. To avoid sensitive uses being approved that have the potential to be near point sources of air pollution, the County, together with the South Coast Air Quality Management District (SCAQMD), has the mechanism in place that will ensure review of each proposed sensitive use and registered stationary source of air pollution emissions in the vicinity.

The Community Center proposed in the General Plan were designed to be transit nodes by concentrating mixed use development along transportation corridors. The General Plan states under its land use concept the following:

"Accommodate strategically located community centers and re-plan existing urban cores with a transit-adaptive, integrated mixture of commercial, residential, employment, parks, civic, recreational, and cultural uses within walking distance of transit facilities. These community centers are intended to accommodate a portion of future growth by allowing increased densities and intensities in order to reduce sprawl and the amount of land required for public infrastructure."

KK-40 Air quality is a regional issue. The SCAQMD and Southern California Association of Governments (SCAG) have published documents such as the regional Air Quality Management Plan (AQMP) that contains information concerning existing health problems associated with air pollution. The proposed General Plan, once adopted by the County, will be used in the update of the AQMP; therefore, providing information on how the proposed General Plan could contribute to increased air pollution within the basin.

Emissions associated with regional transportation, such as truck traffic between Riverside and Ports in San Diego, Long Beach, and Los Angeles, have been included in the AQMP emissions estimate. Their impacts on health and air quality have been fully accounted for in the AQMP projections. Most of these truck traffic occurs or will occur along the major freeway corridors, and their potential health impacts have been properly documented by the SCAQMD and SCAG.

KK-41 Refer to responses KK-37 through KK-40.

KK-42 In comments KK-42 through KK-44, the Commentor is disagreeing with the direction, standards, policies, and thresholds of significance of the General Plan. However, within the General Plan and EIR there are several methods of reducing flood hazard impacts to a less than significant level. This includes the proposed policies as listed below:

Safety Policy 4.1 For new construction and proposals for substantial improvements to residential and nonresidential development in 100- and 500-year floodplains and dam inundation areas, Riverside County shall apply a minimum level of acceptable risk; and disapprove projects that cannot mitigate the hazard to the satisfaction of the Building Official or other responsible agency.

Safety Policy 4.2 Enforce provisions of the Building Code in conjunction with the following guidelines:

a. The ground floor of any development proposed for human occupancy within any area determined to be a flood hazard shall, at a minimum, be constructed 1.0 foot above the projected inundation depth. Critical facilities should be constructed above grade to the satisfaction of the Building Official, based on federal, Sate, or other reliable hydrologic studies.

b. Critical facilities shall not be permitted in floodplains unless the project design ensures that there are two routes for emergency egress and regress, and minimizes the potential for debris or flooding to block emergency routes, through the construction of dikes, bridges, or large-diameter storm drains under roads used for primarily access.

c. Facilities using, storing, or otherwise involved with substantial quantities of on-site hazardous materials shall not be permitted, unless all standards for elevation, anchoring, and all flood-proofing have been satisfied; and hazardous materials are stored in watertight containers not capable of floating.

d. Specific flood-proofing measures shall include permanent sealing of grade level openings; use of paints, membranes, or mortar to reduce water seepage through walls; installation of watertight doors, bulkheads, and shutters; installation of floodwater pumps in structures; and other proper modification and protection of all electrical equipment, circuits, and appliances so that the risk of electrocution or fire is eliminated.

Safety Policy 4.3 Prohibit construction of permanent structures for human housing or employment to convey floodwaters without property damage or risk to public safety. Agricultural, recreational, or other low-density uses are allowable, if floodplain functions are maintained and groundwater recharge is protected.

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.

Safety Policy 4.6 Direct flood control improvement measures toward the protection of existing and planned development.

Safety Policy 4.8 Require development in the floodway fringe, following a site-specific hydrology study, to implement measures that avoid erosion or sedimentation on adjacent land, or water flows or velocities, that would be detrimental to the health and safety of persons or adjacent property, or adversely affect adjacent wetlands or riparian habitat.

Safety Policy 4.9 Minimize encroachment of development into the floodway fringe to convey floodwater without property damage and risk to public safety.

Safety Policy 4.10 Require all uses within the floodway fringe to be capable of withstanding flooding and to minimize use of fill.

Safety Policy 4.11 Require all projects anywhere in the County to mitigate any impacts that they may have on the carrying capacity of the local storm drain system.

Safety Policy 4.18 Continue to assess and upgrade inundation risk and protection in the County.

Safety Policy 4.19 Require that the design and upgrade of street storm drains be based on the depth of inundation, relative risk to public health and safety, the potential for hindrance of emergency access and regress from excessive flood depth, and the threat of contamination of the storm drain system with sewage effluent.

Safety Policy 4.21 Balance flood control mitigation with open space and environmental protection.

Safety Policy 4.22 Encourage the use of specific plans to allow increased densities in certain areas of a proposed development; or apply Transfer of Development Credits to encourage the placement of appropriate land uses in natural hazards areas, including open space, passive recreational uses, or other development capable of tolerating these hazards.

Safety Policy 4.23 Take an active role in acquiring property in high-risk flood zones and designating the land as open space for public use or wildlife habitat.

This also includes the following mitigation measures on pages 4.9-12 and 4.9-14 (with changes to mitigation measures 4.9.1B and 4.9.1C):

4.9.1A LOMA and LOMR-F are documents issued by FEMA that officially remove a property and/or structure from a special flood hazard area of a Flood Insurance Rate Maps (FIRM). These letters shall be accepted by Riverside County where applicable.

4.9.1B Riverside County shall prohibit alteration of floodways and channelization unless alternative methods of flood control are found to be technically, economically, and practically infeasible.

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, concentration of flows, and adverse impacts to water quality from point and nonpoint sources of pollution.

4.9.1.D Riverside County shall require the 10-year flood flows to be contained within the top of curbs and the 100-year flood flows within the street rights-of-way.

4.9.2A Riverside County shall require that all structures (residential, commercial, and industrial) be flood-proofed from the 100-year storm flows. In some cases, this may involve elevating the finished floor more than 1 foot.

4.9.2B Riverside County shall require that fully enclosed areas that are below finished floors have openings to equalize the forces on both sides of the walls.

4.9.2C Riverside County shall require that for agricultural, recreation, or other low-density uses, flows are not obstructed and that upstream and downstream properties are not adversely affected by increased velocities, erosion backwater effects, or concentration of flows.

Additionally, the adherence to Riverside County Ordinance 458 will reduce flooding impacts to a less than significant level. Riverside County Ordinance 458 states that whenever an application for a permit involves land within a flood zone and the existing land use does not provide for a specific recommendation by a flood control district, the development must receive approval from the Riverside County Flood Control District and meet very stringent requirements to ensure that flood hazard impacts will not occur.

KK-43 Refer to response to KK-42.

KK-44 Refer to response to KK-42.

KK-45 The distribution of land uses set forth in the proposed General Plan was determined after considering the location and potential severity of hazard areas (as shown in the Riverside County Existing Setting Report) and, therefore, represents the identification of potentially cumulative hazard impacts. The proposed General Plan and EIR identify hazard areas for seismic, flooding, wildfire, steep slopes, slope instability, and wind erosion. These potential hazard areas are individually identified in further detail in each of the proposed Area Plans.

KK-46 As the County of Riverside encompasses a myriad of geologic, topographic, and developed conditions dispersed throughout 7,200 square miles, the General Plan relies on a broad identification of potential geologic and slope stability hazards supported by a requirement for site-specific geotechnical investigations. It is not prudent to assume that mitigation offered at the programmatic EIR level would reduce the significance of potential site-specific hazards. It is more appropriate to address potential site-specific hazard impacts only after conducting an investigation of specific site conditions. Review of said investigations by the County Geologist, Responsible and Trustee Agencies, and the general public will ensure potential impacts resulting from development that may be exposed to geologic or slope stability hazards is adequately mitigated. The General Plan contains the following policies to ensure that development projects are analyzed on a project specific basis for geologic hazards:

Safety Policy 2.1 Minimize fault rupture hazards through enforcement of Alquist-Priolo Earthquake Fault Zoning Act provisions and the following policies:

a. Require geologic studies or analyses for critical structures, and lifeline, high-occupancy, schools, and high-risk structures, within 0.5 miles of all Quaternary to historic faults shown on the Earthquake Fault Studies Zones map.

b. Require geologic trenching studies within all designated Earthquake Fault Studies Zones, unless adequate evidence, as determined and accepted by the County Engineering Geologist, is presented. The County may require geologic trenching of non-zoned faults for especially critical or vulnerable structures or lifelines.

c. Require that lifelines be designed to resist, without failure, their crossing of a fault, should fault rupture occur.

d. Support efforts by the California Department of Conservation, Division of Mining and Geology to develop geologic and engineering solutions in areas of disseminated ground deformation due to faulting, in those areas where a through-going fault cannot be reliably located.

e. Encourage and support efforts by the geologic research community to define better the locations and risks of County faults. Such efforts could include data sharing and database development with regional entities, other local governments, private organizations, utility agencies or companies, and local universities.

Safety Policy 2.2 Require geological and geotechnical investigations in areas with potential for earthquake-induced liquefaction, landsliding or settlement as part of the environmental and development review process, for any structure proposed for human occupancy, and any structure whose damage would cause harm.

Safety Policy 2.3 Require that a State-licensed professional investigate the potential for liquefaction in areas designated as underlain by "Susceptible Sediments" and "Shallow Groundwater" for all general construction projects.

Safety Policy 2.4 Require that a State-licensed professional investigate the potential for liquefaction in areas identified as underlain by "Susceptible Sediments" for all proposed critical facilities projects.

Safety Policy 2.5 Require that all engineered slopes be designed to resist seismically induced failure. For lower risk projects, slope design could be based on pseudo-static stability analyses using soil engineering parameters established on a site-specific basis. For higher risk projects, the stability analyses shall factor in the intensity of expected ground shaking, using a Newmark-type deformation analysis.

Safety Policy 3.1 Require the following in landslide potential management zones, or when deemed necessary by CEQA.

a. Preliminary geotechnical and geologic investigations.

b. Evaluations of site stability, including any possible impact on adjacent properties; before final project design is approved.

c. Consultant reports, investigations, and design recommendations required for grading permits, building permits, and subdivision applications be prepared by State-licensed professionals.

Safety Policy 3.3 Before issuance of building permits, require certification regarding the stability of a project site against the adverse effects of earthquake.

Safety Policy 3.8 Require geotechnical studies within documented subsidence zones, as well as areas that may be susceptible to subsidence, as identified in the Safety Element Technical Background Report, prior to the issuance of development permits. Within the documented subsidence zones of the Coachella, San Jacinto, and Elsinore Valleys, the studies must address the potential for reactivation of these zones, consider the potential impact of the proposed development, and provide acceptable mitigation measures.

Safety Policy 3.11 Require studies that address the potential of wind hazard on proposed development within "High" and "Very High" wind erosion hazard zones as shown on the Safety Element's Wind Erosion Susceptibility Map.

Safety Policy 7.7b Require mitigation measures to reduce potential damage caused by ground failure for sites determined to have potential for liquefaction. Such measures shall apply to critical facilities, utilities, and large commercial and industrial projects as a condition of project approval.

Safety Policy 7.7d Review proposed uses of fault setback areas close to ensure that County infrastructure (roads, utilities, drains) are not unduly placed at risk by the developer. Insurance, bonding, or compensation plans should be used to compensate the County for the potential costs of repair.

Safety Policy 7.7 Strengthen the project permit and review process to ensure that proper actions are taken to reduce hazard impacts and to encourage structural and nonstructural design and construction. Damage must be minimized for critical facilities, and susceptibility to structural collapse must be minimized, if not eliminated.

a. Ensure that special development standards, designs, and construction practices reduce risk to tolerable levels for projects involving critical facilities, large-scale residential development, and major commercial and industrial development through conditional uses permits and the subdivision review process. If appropriate, impact fees should be assessed to finance required actions.

b. Require that planned lifeline utilities, as a condition of project approval, be designed, located, structurally upgrades fit with safety shutoff valves, be designed for easy maintenance, and have redundant back up lines where unstable slopes, earth cracks, active faults, or areas of liquefaction cannot be avoided.

Safety Policy 7.8 Promote strengthening of planned and existing utilities and lifelines, the retrofit and rehabilitation of existing weak structures, and the relocation of certain critical facilities.

KK-47 The Draft EIR identifies several General Plan policies that address potential hazards that may result from development on or adjacent to sloped slope areas. Specifically, these policies include the requirement for slope evaluations, the identification of mitigation for slope instability, or other hazardous slope conditions, and the development of slopes to minimize slope failures. Please refer to response to Comment EE-10

KK-48 Measures to mitigate site-specific geotechnical hazards, as identified by geotechnical investigations, will be reviewed and approved by the County Geologist and the County Department of Building and Safety. As County departments are tasked with protecting the health, safety, and welfare of the public, through the implementation of policies, development would not be permitted in areas where potentially significant geotechnical and/or slope stability impact could not be mitigated to a less than significant level.

KK-49 The General Plan Update provides a conceptual vision for the future build out scenario over the entire County. It is impractical at this time to map out individual developments throughout the entire County. Therefore, it is not feasible to provide detailed information about the number of new units or other sensitive land uses that are permitted by the land use map in areas of noise in excess of 65 dBA CNEL. To avoid potential conflicts, the General Plan provides policies that will be used by County planning staff to discourage, limit, or mitigate for sensitive uses in areas of excessive noise.

KK-50 The Draft Master EIR for the General Plan for the March Joint Powers Authority (1999) used the 1992 Air Installation Compatibility Use Zone (AICUZ) Study as its baseline for the existing aviation related noise environmental. A subsequent AICUZ Study was prepared in 1998 and it reflects the permitted aviation use of March Field (both civilian and miliary uses) forecasted for the year 2010.

The Mead Valley Area Plan includes the March ARB Airport Influence Policy Area (page 19). According to the Mead Valley Area Plan, the County will enforce the provisions of the March Joint Powers Authority and the March Inland Port Cargo Development Plan. Noise impacts for the March Joint Powers Authority General Plan were found to be less than significant as were cumulative noise impacts with the implementation of mitigation measures. The policy in the Mead Valley Area Plan commits the County to implement the mitigation in the March Joint Powers Authority General Plan EIR (June 1999)

Noise contour maps, including those for truck traffic, are shown in Figures 4.13.3 through 4.13.21.

KK-51 Refer to response to KK-49. Citing policies as mitigation for environmental impacts is appropriate for a broad policy document such as a General Plan.

KK-52 Potential for growth of noisy land uses as a result of the increase in population allowed by the General Plan have been included in the noise projections. For example, most civil aviation airports project the need for capacity expansion based on future growth of the population in the region, and project their future noise contours based on the expansion. The airport noise contour maps included in the General Plan update reflect such future projections. Noise contour maps shown in Figures 4.13.3 through 4.13.21 for freeways and highways would also accommodate future projections in traffic noise.

KK-53 The Commentor states that there is insufficient park mitigation in the Draft EIR, and that the Draft EIR maps do not identify needed new parks and open space. The General Plan policies and open space element address the needs for parks and recreation. There is no requirement under CEQA or State law to provide maps identifying needed new parks and open space. 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.

KK-54 The Commentor states that the Draft EIR needs to identify the impact of needed recreational lands as significant and unavoidable in the absence of a detailed open space plan. This comment is a statement of the Commentor's opinion. Impacts to parks and recreation were analyzed according to approved significance criteria.

KK-55 The Commentor states that the public services section is inadequate. The following comments go into specifics, and the following responses address the specific issues raised by the Commentor.

KK-56 The Public Services Section (section 4.15, page 4.15-1 and 4.15-6) specifically details current levels of service within the County; for example, the number of fire or Sheriff stations and the number of personnel or sworn officers. The EIR also details the standards for services or generation factors related to each public service. From this information it is evident what services are currently lacking within the County. Additionally, within the discussion of each service area is a table depicting what facilities or personnel will be needed by the General Plan build out. If General Plan policies do not ensure that the need for these public services will be met, additional mitigation measures are included to ensure that development does not exceed the ability to adequately provide supporting infrastructure and public services.

KK-57 As stated previously, the Draft EIR describes the current status of services within Riverside County (refer to response KK-56). To ensure adequate services during and at the General Plan build out, several policies and mitigation measures are included in the General Plan and EIR. These include the following:

Safety Policy 5.8 Strengthen inter-jurisdictional fire response agreements, and improve firefighting resources to keep pace with development, including construction of additional high-rises, mid-rise business parks, increasing numbers of facilities housing immobile populations, and the risk posed by multiple ignitions to ensure that:

• Fire reporting and response times do not exceed 4.0 minutes;

• Fire flow engine requirements are consistent with Insurance Service Office (ISO) recommendations; and

• The height of truck ladders and other equipment and apparatus is sufficient.

Land Use Policy 9.1 Require that new development proponents contribute their "fair share" to fund infrastructure and fire facilities.

Land Use Policy 5.1 Ensure that development does not exceed the ability to adequately provide supporting infrastructure and services.

Land Use Policy 5.2 Monitor the capacities of infrastructure and services in coordination with service providers, utilities, and outside agencies and jurisdictions to ensure that growth does not exceed acceptable levels of service.

4.15.2C Riverside County shall meet and maintain a goal of 1.5 sworn officers per 1,000 population, as recommended by the International City Managers' Association.

4.15.2D The County shall require the development applicant to pay the County Sheriff's established development mitigation fee prior to issuance of a certificate of occupancy on any structure as they are developed. The fees are for the acquisition and construction of public facilities.

4.15.3F The County shall require all development projects to coordinate with appropriate County departments and/or agencies to ensure that there is adequate waste disposal capacity to meet the waste disposal requirements of the project, and the County shall recommend that all development projects incorporate measures to promote waste reduction, reuse, recycling, and composting.

4.15.6A Riverside County shall provide a minimum of approximately 0.5 square foot of library space and 2.5 volumes per County resident.

4.15.7A Riverside County shall perform a periodic medical needs assessment to evaluate the current medical demand and level of medical service provided within each Area Plan. A periodic medical needs assessment shall be conducted every three years.

4.15.7B Riverside County shall fund the new construction and/or expansion of existing medical facilities according to the level of demand for medical services. The level of demand will be based on and determined by the outcome of the periodic medical needs assessments.

KK-58 The General Plan is a long-range document, hence it is not possible to foresee the costs of services or infrastructure throughout the entire life of the plan. The exactions that new development must pay are decided at the time of development and are created to ensure that proponents pay their "fair share" as stated in Land Use Policy 9.1. The policies and mitigation measures listed above in response KK-57 are included in the EIR to ensure that services will be adequate to serve new development without decreases in services to existing residents and business.

KK-59 The document states (on page 4.15-17) that "With the build out of the proposed General Plan, the number of households would grow to 557,849 in the next 40 years. These households would produce 128,305,270 gallons of wastewater per day. This would be an increase of 22,960,440 gallons of wastewater per day." Through the development review process and the environmental review required by CEQA, wastewater providers will be informed of proposed projects, and they will have the opportunity to comment on any possible impacts to services. As stated previously the new developments will be required to pay their "fair share" for the extension of services and infrastructure; and policies previously mentioned exist to ensure that there will not be any service impacts to existing residents and businesses. The section cannot foresee the placement and time line of new development throughout the next 40 years; likewise, the EIR cannot foresee when and where a new plant and/or expanded services will be required. Additionally, at the time of development of a new plant and/ or expansion of services appropriate environmental review required by CEQA will be performed and impacts will be analyzed.

The service districts will use the growth projections anticipate through the build out of the County's General Plan to determine future needs.

KK-60 On page (4.15-19) the EIR states "The proposed General Plan will continue to allow and encourage development of rural residential land uses in areas that are not served by municipal sewer facilities." Any area of the County that is served by municipal sewer facilities is required to utilize these facilities and not use septic systems. Therefore, any area that may convert from septic to sewer systems would do so because the wastewater provider has expanded services to the area and has estimated the existing and future needs of the area, and has undergone required CEQA review. The General Plan includes the following policy to ensure that development pays its fair share to fund infrastructure.

Land Use Policy 9.1 Require that new development contribute their fair share to fund infrastructure and public facilities such as police and fire facilities.

KK-61 Riverside County's Environmental Health Department, Community Health Agency, regulates land applications of Class B sewage sludge. Class A sludge is not regulated. In response to concerns raised regarding potential health issues and odor complaints, the agency stopped all land application of Class B sewage sludge facilities in 2001. Currently, wastewater treatment plant operators are seeking alternative disposal methods, such as trucking the sludge to farmlands in Kern County and to Arizona. The creation and disposition of sewer sludge is highly regulated by the Riverside County Community Health Agency.

Prior to the expansion of wastewater facilities and development of new plants, the projects must undergo all environmental review required by CEQA. Because the time and place of the expansions or development of new wastewater treatment plants is unknown, the impacts associated cannot be adequately analyzed at this time.

KK-62 The County of Riverside has no known areas that have failing septic systems.

As stated on page 4.15-19 and 4.15-20 and in amended text:

The County of Riverside has ordinances that strictly regulate the construction and maintenance of septic tanks. Section 8.124.030 of the County of Riverside Government Code states that all septic facilities require written approval for construction from the County Health Officer. Approval for septic tanks require detailed review and on-site inspections, which include a scaled, contoured plot plan, a soils feasibility report that adequately evaluates soil percolation, a special feasibility boring report (groundwater and/or bedrock), and an engineered topographical map.

Additionally, the U.S. Environmental Protection Agency (EPA) has established standards governing the placement of septic systems in the proximity of water supply wells. The EPA's "Zone A" is classified as a potential area of direct microbiological and chemical contamination based on an estimated two-year time of (contaminant) travel within an aquifer from the wellhead to the potential source of contamination. Waste discharges from conventional septic tank/subsurface disposal systems may adversely affect both the quality and beneficial uses of the water and/or violate local, regional or State water quality standards. As excerpted from EPA's Design Manual On-Site Wastewater Treatment and Disposal Systems, "... State Codes that specify 100-foot separation distances between conventional subsurface wastewater infiltration system treatment units and down-gradient wells or surface waters should not be expected to always protect these resources from dissolved, highly mobile contaminants ... published data indicate that viruses that reach groundwater can travel at least 220 vertical feet and 1,338 feet laterally in some porous soils and still remain effective." Any such degradation of water quality would be a potentially significant impact.

Effectiveness of Proposed General Plan Policy Implementation of the proposed General Plan policies, existing County regulations related to wastewater, and the following measure will reduce potential wastewater impacts resulting from future development to a less than significant level.

Mitigation Measure

4.15.4A Conventional septic tanks/subsurface disposal systems shall be prohibited within any designated Zone A of an Environmental Protection Agency wellhead protection area. Where a difference between Riverside County and EPA septic tank setback distance requirements exists, the EPA standard shall apply.

KK-63 As stated previously, the proposed General Plan is a 40-year plan. Due to the inability to foresee when and where new development will occur and the inability to foresee when and where wastewater providers will expand services and construct new wastewater treatment plants over the next 40 years, there exists an inability to foresee how much development will rely on septic systems. In order to regulate the installation and maintenance of septic tanks, Section 8.124.030 of the County of Riverside Zoning Code states that all septic facilities require written approval for installation from the County Health Officer. It is anticipated that most of the septic system installations would occur in the rural residential areas of the County. Prior to installation, approval of the septic systems requires detailed review and on-site inspections by the County Health Officer.

KK-64 The continued use of septic systems in accordance with County Ordinances, EPA standards, and Mitigation Measure 4.15.4A will reduce potential wastewater impacts resulting from future development to a less than significant level, as stated in the amended EIR.

The CEQA Guidelines do not prohibit the use of septic systems. Section 15064 (h) of the CEQA Guidelines identifies the environmental standard used for purposes of environmental protection.

KK-65 Impacts to approved HCPs have been accounted for in the land use plan. Under CEQA, it is not necessary to analyze the consistency of a proposed project with a proposed, but not yet adopted, Habitat Conservation Plan (such as the Western Riverside County MSHCP).

Section 3.1 of the Draft EIR, as revised in the Final EIR Section 3, states the following:

"The RCIP consists of three coordinated plans, the 2002 Riverside County General Plan (which is the subject of this Program EIR), recognizes the Western Riverside County MSHCP, and the CETAP. Although coordinated, these three plans are independent components of RCIP. As an independent plan, the 2002 Riverside County General Plan is not reliant upon the approval of either MSHCP or CETAP. The proposed General Plan is, however, coordinated with the MSHCP and the CETAP, so that no substantive conflicts or inconsistencies exist among the three plans. The General Plan is consistent with the draft MSHCP in that some of the draft MSHCP policies for biological resource preservation and mitigation are incorporated into the proposed General Plan's Area Plans. The biological resource policies incorporated into the Area Plans provide partial mitigation for development impacts that would result from development proposed by the General Plan's identified land uses, infrastructure, and transportation facilities. The proposed General Plan also is consistent with the draft CETAP in that the proposed General Plan Circulation Element recognizes the potential for proposed CETAP corridors as part of its proposed roadway and highway system"

Thus, the information contained in the MSHCP was incorporated and fully considered in preparation of the proposed General Plan. The Commentor recommends that "a comprehensive map" be produced to show where proposed land use may be in conflict with proposed reserve areas and areas of high habitat value in the MSHCP. The MSHCP is intended to be a flexible process that will allow for selective conservation of 153,000 acres of private lands within the larger Criteria Area. ( Public open spaces are generally conserved already.) It is not feasible to generate such a comprehensive map, as the ultimate configuration of conserved and developed lands within the MSHCP cannot be known at this time.

As stated in Section 3.0 of the proposed MSHCP, public and private development within the Criteria Area that is determined to be consistent with the criteria is a "covered activity."

Existing HCPs are incorporated and were fully considered in the preparation of the proposed General Plan. As is shown in Table LU-3 (page LU-36) of the proposed General Plan, the OS-CH land use designation "applies to public and private lands conserved and managed in accordance with Habitat Conservation Plans, such the Multiple Species Habitat Conservation Plan." Thus, lands conserved for the Stephens' Kangaroo Rat HCP are incorporated in the General Plan as conserved open space. 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 their deliberations on the MSHCP.

KK-66 Project-related impacts of all biological habitat lands are quantified in detail in Table 4.6.C of the Draft EIR. Impacts of sensitive biological habitat lands (i.e., key habitats) are also quantified in Table 4.6.D and are shown in Figure 4.6.4. Cumulative impacts to biological resources are discussed in Section 5.4 of the Draft EIR.

KK-67 As described in Section 2.1 of the Draft EIR, this EIR is a "Program EIR" that 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 focus on policy rather than project-related impacts. They contain a more general discussion of impacts, alternatives, and mitigation measures. The General Plan EIR 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 that 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. These site-specific analyses typically include the evaluation of the impacts of a single activity undertaken to implement the overall plan.

The General Plan EIR does identify policies intended to avoid and minimize impacts to biological resources. However, the proposed land use designations of the General Plan are depicted at too broad a scale to produce a meaningful "overlay map" of potential conflicts with valuable habitat areas. The implementation of the avoidance and minimization policies will occur as part of subsequent development projects and will be dependent on the site specific design of each subsequent project. Design and analysis of subsequent development projects will include maps of potential conflict areas.

KK-68 Pursuant to the State CEQA Guidelines Section 15126.4 (a)(1), an EIR shall describe feasible measures which could minimize significant adverse impacts. Section 15126.4 (a)(4)(B) states "The mitigation measures must be roughly proportional to the impacts of the project." The 1:1 habitat replacement ratio is feasible and roughly proportional to the impacts of implementing the General Plan. Other agencies may require greater than a one-to-one replacement ratio. This minimum replacement ratio is a policy decision that was made by the County. If this minimum mitigation ratio is considered infeasible by the development community, justification will need to be submitted for further review by the County.

KK-69 The Commentor does not indicate which policies are under discussion. Absent this information, a more specific response is difficult. The "permissive" nature of certain avoidance policies is intended to allow for flexibility in future conservation and land use planning. Such flexibility will allow for site planning at a site-specific level where conservation objectives can be appropriately balanced with other land use planning requirements, including the protection of public health and safety, providing housing to all economic segments of the population, and providing necessary public services.

KK-70 The impact assessment in the EIR is adequate for a Program level EIR. The analysis in the biological resources section of the EIR (Section 4.6) assumes that the number of acres to be impacted by mineral resource extraction, recreation, and rural residential as 14,000 acres. The Open Space designation in the proposed General Plan "identifies those areas appropriate for the preservation of open space for habitat, recreation, scenic value, mineral resource extraction, and natural resource preservation. This category also identifies remote, large-parceled areas that allow limited development." (County of Riverside General Plan Hearing Draft, page LU-12.)

KK-71 While the General Plan is a component of the Riverside County Integrated Project work effort, it also is a stand-alone document. The General Plan has "independent utility," meaning that the adoption of any one component of the RCIP effort is not dependent on the adoption of the others. This allows, that in the event either the CETAP or MSHCP documents are not approved, the County would still possess an up-to-date legally adequate General Plan, as required by State law. Government Code 65300 states that "... the general plan and elements and parts thereof comprise an integrated, internally consistent, and compatible statement of policies for the adopting agency." The various elements presented in the General Plan meet this requirement.

While the objective of the RCIP effort is to fully integrate the component plans, it does not necessarily follow that the various documents will be prepared, reviewed, or approved simultaneously. Copies of the various documents have been made available for public review at offices of the County Planning Department and public libraries. The noticing of public scoping meetings and the public review of the documents has followed State and federally mandated guidelines. Since the inception of the integrated planning process, the County of Riverside has provided on-line access to the documents prepared during the Riverside County Integrated Project work effort. The RCIP website at www.rcip.org provides a calendar of public meetings, a library of RCIP material, press releases, contact information, RCIP team members, and the means to contact the County with comments and concerns about the RCIP process. For those with the desire, sufficient opportunity has been provided to provide input to and comment on the various RCIP documents.

KK-72 This comment outlines the Commentor's overall objections to the water supply analysis in the EIR. The issues are discussed in more detail in responses KK-73 and KK-74.

KK-73 Refer to response U-7.

KK-74 While it is anticipated that the demand for water will increase, it is not possible to identify the water supplies or facilities required to satisfy future demand. Water management plans generally do not project demands, supplies, or facilities beyond a 20-year period. There are several possible approaches that could satisfy anticipated future water demands. These potential approaches may include the use of tertiary treated water, the construction and operation of desalinization plants, the towing to icebergs to coastal waters, the construction and operation of new water supply and delivery facilities, or the use of water from previously untapped sources. The analysis of each of these possible approaches and the environmental impacts resulting from their construction and operation would be highly speculative. Speculation on the appropriateness or adequacy of measures to mitigate potential future impacts is not permitted by CEQA.

Riverside County has used its best efforts to predict impacts but cannot predict the unforeseeable. That is, Riverside County cannot determine the precise timing of future projects.

The General Plan will not result in new development. Rather, it will dictate where new development will occur. While the Draft EIR anticipates that water demand will increase, because of the extended time frame of the General Plan (Year 2040 build out) and speculative nature of the analysis of potential future water supplies and facilities, it is not possible to demonstrate that future water supplies are available to supply the County's projected growth beyond 20 years. Mitigation Measure 4.17.1A states, in part, "... Development shall not be permitted unless an adequate supply of water, available for use and sufficient to supply a proposed project, in wet and drought years, is identified." Despite this measure, the Draft EIR concludes that water supply impacts are significant and unavoidable.

As explained in the Draft EIR pages 4.17-8 and 4.17-9, SB 221, SB 901, and SB 610 do not tackle the difficult task of analyzing water availability for a project the size of the State of New Jersey (Riverside County) over a 40-year period. In February 2002, the Metropolitan Water District issued a draft report, Report on Metropolitan Water Supplies, that stated that the Metropolitan Water District has enough water to provide its service area with adequate water for the next 20 years. The Metropolitan Water District used 2020 SCAG projections in its analysis. The Riverside County General Plan is consistent with SCAG's 2020 projections; however, there is no information available for water availability to the year 2040.

KK-75 Refer to responses KK-73 and KK-74. It should be noted that it is a policy in the General Plan that proposed development projects are required to be consistent with the General Plan.

KK-76 Refer to responses KK-74 and KK-75.

KK-77 Refer to response KK-74 regarding water supply. Based on comments received from other parties, the discussion of potential water quality impacts resulting from implementation of the General Plan has been revised to incorporate EPA standards governing the placement of water supply wells in the proximity of septic tank systems. As with water supply, the nature and extent of potential water quality impacts at build out are speculative. Mitigation Measures 4.17.5C and 4.17.5D require preparation of water quality analysis and evidence that water quality protection measures suitable to the County and the RWQCB are in place prior to approval of development project. The existing mitigation measures in the Draft EIR are sufficient. Prohibitions on septic systems in groundwater recharge systems are not necessary in light of sufficient policies, mitigation measures, and regulations to address potential impacts.

KK-78 The Commentor states that the EIR contains no discussion of global warming, and inquires whether the transportation system is consistent with AB1493. Assembly Bill No. 1493 (AB1493) applies primarily to the California State Air Resources Board, and does not affect County regulations. The proposed General Plan would not interfere with the provisions of AB1493. The CEQA Guidelines states in Section 15064(3) that "An indirect physical change is to be considered only if that change is a reasonably foreseeable impact that may be caused by the project. A change that is speculative or unlikely to occur is not reasonably foreseeable." The effects and existence of global warming have not been universally accepted or proven, and thus any analysis of the potential impacts of global warming would be speculative.

KK-79 Mitigation Measure 4.17.1A requires the identification of available water supplies sufficient to supply a project during wet years and drought conditions. Similar to the identification of water supplies and facilities necessary to satisfy future water demand; impacts to water supply or delivery facilities resulting from future climatic conditions, catastrophic natural or manmade disasters, or terrorist action is speculative. Speculation in the Draft EIR of the potential impacts resulting from any of these events is not required by CEQA.

KK-80 The Draft EIR is a programmatic analysis of potential environmental impacts resulting from implementation of the proposed General Plan. Program EIRs are typically more conceptual, containing a more general discussion of impacts, alternatives, and mitigation measures. Water quality standards are monitored and regulated by a number of State, County, and local entities.

Because the extent and nature of development that may occur in the future cannot be precisely determined, it is not possible to ascertain the scope of potential future water quality impacts. Any such attempt to precisely quantify future potential water quality impacts, in the absence of data as to the nature, extent, and location of development would be speculative. The Draft EIR acknowledges that development of the land uses envisioned in the proposed General Plan may lead to a degradation of the quality of local/regional surface and groundwater and identifies measures that will eliminate or limit these potential impacts.

KK-81 The Commentor questions the validity of the growth inducing analysis presented in the Draft EIR. The comment states that the Draft EIR fails to adequately describe the nature of the growth resulting from the General Plan, and that a map should be included. It also states that mitigation measures should be included to address the impacts of growth. The General Plan is a model for the growth, and contains detailed descriptions and maps of the planned location and nature of development. The land use map contained in the General Plan provides information to anyone interested in the planned location of future growth. CEQA indicates that growth inducing effects are not necessarily adverse or beneficial, and does not require mitigation for these effects.

KK-82 CEQA Guidelines Section 15126.2, which is cited in Comment KK-82, states that the lead agency "should normally limit its examination to changes in existing physical conditions in the affected area as they exist at the time the notice of preparation is published." The statement contained in the Draft EIR and cited in the Comment KK-82 is merely a notice that the tables quantifying environmental impacts in the EIR identify conditions at General Plan build out, and do not subtract out the effects of existing development. Thus, throughout the General Plan, a cumulative analysis is presented to provide the reader with a clear understanding of environmental conditions as they will exist at the time of General Plan build out. The General Plan EIR also incorporates a detailed description of environmental setting, providing an understanding of the existing conditions against which the impacts of implementing the proposed General Plan can be understood. Impact sections for each issue describe, and, where feasible, quantify future environmental conditions should the proposed General Plan be adopted. The combination of analyzing future environmental conditions at General Plan build out and describing existing environmental conditions provides an examination of changes in existing physical conditions.

Generally, the thresholds of significance set forth in the General Plan EIR focus on physical environmental conditions at General Plan build out, and not to the incremental differences between existing and future conditions. For example, thresholds of significance for traffic are based on level of service standards that are measured by comparing future traffic against future roadway capacity. Thus, if an existing roadway segment has a daily traffic volume of 5,000 vehicles per day, and will increase in the future to 40,000 vehicles per day, the General Plan EIR's impact analysis reports the future traffic volume as 40,000 vehicles per day, and analyzes whether the resulting level of service meets County standards or not. Analysis of the incremental difference between existing and future conditions (35,000 vehicles per day) would not provide any meaningful information, since it may or may not result in exceedances of level of service standards. Where thresholds of significance incorporate incremental changes from existing to future conditions, such as noise thresholds, the incremental difference between existing and future environmental conditions is addressed in the EIR.

KK-83 This comment introduces the next several comments, and the issues raised are addressed in responses KK-84, KK-85, and KK-86.

KK-84 The Commentor states that the study area for the proposed General Plan should be tailored by impact analyzed. In the Draft EIR, certain analyses incorporate data from areas outside of the County as part of the analysis. For example, traffic models are based on data for the area within Riverside County (including both incorporated and non-incorporated areas) as well as areas in adjacent counties. The noise and air quality analyses are based to a large degree on the traffic model output (as vehicular traffic accounts for a substantial amount of noise and air quality impacts). Sensitive biological and agricultural resources are classified by State and Federal agencies in accordance with their Statewide and nationwide status. Thus, the identification of these resources may utilize data from areas outside of Riverside County. Water quality assessments were based on Water Quality Control Board Regions as well as watersheds, as indicated in Figure 4.17-1. Other impact analyses similarly were based on data from relevant areas, inside and outside of Riverside County, as appropriate.

KK-85 The proposed General Plan and Draft EIR contain policies that regulate both development and conservation. However, market forces dictate when and where permitted development occurs. Thus, it is not possible to quantify impacts to resources in terms of acres at this level of analysis. Additional environmental analysis will be required on a project-by-project basis, and mitigation measures and General Plan Policies will apply to these projects.

KK-86 While the General Plan is a component of the Riverside County Integrated Project work effort, it is a stand-alone document. The General Plan has "independent utility," meaning that the adoption of any one component of the RCIP effort is not dependent on the adoption of the others. This allows, that in the event either the CETAP or MSHCP documents are not approved, the County would still possess an up-to-date legally adequate General Plan, as required by State law. Government Code 65300 states that "... the general plan and elements and parts thereof comprise an integrated, internally consistent, and compatible statement of policies for the adopting agency." The various elements presented in the General Plan meet this requirement.

While the objective of the RCIP effort is to fully integrate the component plans, it does not necessarily follow that the various documents will be prepared, reviewed, or approved simultaneously. Copies of the various documents have been made available for public review at offices of the County Planning Department and public libraries. The noticing of public scoping meetings and the public review of the documents has followed State and federally mandated guidelines. Since the inception of the integrated planning process, the County of Riverside has provided on-line access to the documents prepared during the Riverside County Integrated Project work effort. The RCIP website at www.rcip.org provides a calendar of public meetings, a library of RCIP material, press releases, contact information, RCIP team members, and the means to contact the County with comments and concerns about the RCIP process. For those with the desire, sufficient opportunity has been provided to provide input to and comment on the various RCIP documents.

KK-87 Refer to response KK-86.

KK-88 The Commentor mistakenly assumes that the sentence on page 3-7, which refers to the Western Riverside County MSHCP, is a mitigation measure for the General Plan EIR. This section merely describes the General Plan and is relating the fact that the proposed General Plan relies heavily on adoption of programs (such as the Western Riverside County MSHCP) for mitigation of biological resources impacts.

The Commentor additionally states that the Western Riverside County MSHCP cannot provide mitigation measures, as it lagged behind the General Plan and must be approved concurrently with the General Plan to do so. The MSHCP EIR/EIS was not available for public review until after the General Plan EIR became available to the public. Thus, the MSHCP EIR/EIS could not be incorporated by reference pursuant to State CEQA Guidelines Section 15150, which states that an EIR may incorporate all or a portion of a document if it is publicly available. Therefore, the potential biological impacts are analyzed without the MSHCP.

As described on page 4.6-1 of the General Plan EIR, the Western Riverside County MSHCP and the Coachella Valley Association of Governments (CVAG) MSHCP programs are recognized, but the MSHCPs are not included in the existing setting description. In other words, the adoption of provisions contained within the MSHCPs was not assumed. Only conservation measures that are currently adopted are included. However, MSHCP provisions were incorporated throughout the General Plan EIR and include, for example, the following policy:

17.4 Require the preparation of biological reports in compliance with Riverside County Planning Department Biological Report Guidelines for development-related uses that require discretionary approval to assess the impacts of such development and provide mitigation for impacts to biological resources until such time as the CVAG MSHCP and/or Western Riverside County MSHCP are adopted or should one or both MSHCPs not be adopted.

It was concluded in the General Plan EIR that in the absence of a comprehensive plan that addresses regional conservation issues (such as an approved MSHCP), implementation of the policies and mitigation measures on a project-by-project basis would result in the preservation of fragmented habitat patches and the isolation of associated biological resources.

Additionally, in the absence of an approved MSHCP for both the Coachella Valley and Western Riverside County, implementation of the proposed General Plan would result in cumulative significant unavoidable adverse effects on biological resources by causing the following:

• A direct loss of sensitive natural communities, especially coastal sage scrub and meadow and marsh habitats;

• Fragmentation of sensitive habitats resulting in isolation of habitat patches and creating a "checkerboard" pattern of small habitat patches of limited biological value; and

• The fragmentation of habitat that constricts, inhibits, or eliminates wildlife movement.

KK-89 Refer to response KK-16.

KK-90 The project-specific impacts from water demands to biological habitats and special status species from future Riverside County projects cannot be foreseen. Broad-brush impacts can and have been analyzed, and policies and mitigation address these impacts. Action is deferred only for specific projects that will require more detailed, site-specific analysis; however, Mitigation Measures 4.17.1A and 4.6.2A have been put forth to mitigate potential future impacts caused by a project's forecasted water demand and its potential to result in alteration or loss of special status species or their habitat. The Commentor puts forth that these mitigation measures improperly defer identification of mitigation measures. Riverside County has used its best efforts to predict impacts but cannot predict the unforeseeable. That is, Riverside County cannot determine the precise timing of future projects. Deferment of these mitigation measures at the time of a future project is essential to avoid, minimize, rectify, reduce over time, and/or compensate for impacts resulting from low water supply or impacts to special status species or their habitat at the time of project implementation.

KK-91 The Commentor has suggested the addition of several mitigation measures to the General Plan EIR to include recycling requirements, avoidance policies, flooding areas, infill development, new housing and job creation, greater than 1:1 habitat mitigation, and adoption of the Western Riverside County MSHCP.

Recycling Requirements. For recycling requirements, the California Integrated Waste Management Act of 1989 (Statutes of 1989, Chapter 1095 [AB 939, as amended]) redefined solid waste management in terms of objectives and planning responsibilities for local jurisdictions and the State. AB 939 requires that each of the cites and unincorporated portions of counties throughout the state divert a minimum of 25 percent of the solid waste landfilled by 1995 and 50 percent by 2000. In 1992, compliance with AB 939 was no longer determined by what percentage of solid waste is diverted, but rather by the reduction in the solid waste disposed through landfilling or incineration. The Commentor indicates that Riverside County should follow the lead of San Francisco, a city which is "closing in on achieving 50% of all waste recycled at this time." This is a requirement by law and, as such, is also a requirement for Riverside County. At this time, the County has met the requirement to divert 50 percent of solid waste.

Avoidance Policies. The Commentor requests that all areas of hazard and biological resources should be avoided. This is accomplished through policies and mitigation measures in Section 4.6 (Biological Resources), 4.9 (Flood and Dam Inundation Hazards), and 4.10 (Geologic Hazards). Figures that are located in the General Plan EIR include the mapping of habitat types, 100-year and 500-year flood hazard zones, dam failure inundation zones, Alquist-Priolo earthquake hazard zones, earthquake probability, areas susceptible to liquefaction, areas of steep slopes, areas of documented subsidence or areas susceptible to subsidence, and wind hazard areas. As each project is presented to the Riverside County Planning Department, areas of hazard and biological resources would be avoided as appropriate.

Flooding Areas. In areas where natural flooding sustains special status plants and other species, the Commentor would like a prohibition of development of incompatible land uses and a prohibition of the use of flood control measures. Several General Plan policies and mitigation measures would facilitate this prohibition and are in place already. They include the following General Plan policies and one additional mitigation measure: OS 5.7., OS 9.1, OS 9.2, OS 9.3, OS 17.1, OS 17.2, OS 17.3, OS 18.1, OS 18.2, and Mitigation Measure 4.6.1.

With these General Plan policies and the additional mitigation measure, there would be a less than significant impact to special status plants and other species with respect to the development of incompatible land uses and the use of flood control measures.

Infill Development. The Commentor suggests that infill development1 should occur before greenfield2 development is permitted. Riverside County agrees. The General Plan, which addresses infill development throughout the document and within the Vision Statement, includes the following policy, which encourages the use of infill development:

LU 3.1.b Assist in and promote the development of infill and underutilized parcels, which are located in Community Development areas, as identified on the General Plan Land Use Map.

In addition, within the Five-Year Action Plan Summary for the Housing Element, Table H-1 (beginning on page H-5), there are several actions that address infill development. They include the following:

1Infill development is development of vacant land (usually individual lots or left-over properties) within areas that are already largely developed.

2Greenfields are sites or areas without a previous history of development.

1.1d Continue to offer fast track/priority processing, gap financing options, density bonus and fee subsidies to developers of County-assisted projects proposing new housing, mixed-use, or infill projects affordable to lower income households, farm workers, seniors, and other special needs groups.

1.1i Promote the continued use of density bonus provisions on a case-by-case basis to provide affordable housing, particularly in high-density, mixed-use, and infill areas.

1.2f Implement an expansion of the County GIS system to facilitate preliminary strategic planning studies to identify vacant or underutilized commercial properties for infill construction or adaptive reuse in high-density areas.

1.2h Identify areas of the County where urban infill is appropriate based on General Plan land use policy and Area Plan designations, and encourage infill development through the use of incentives.

4.2.c Identify and map areas of the County where urban infill is appropriate.

New Housing and Job Creation. The Commentor stated that there should be policies linking development of new housing to job creation in the County. The General Plan contains an assorted variety of these policies, some of which follow:

AQ 6.1 Assist small businesses by developing education and job training programs, especially in job-poor areas.

AQ 6.2 Collaborate with local colleges and universities to develop appropriate educational programs to assist residents in obtaining job skills to meet market demands.

AQ 7.1 Provide incentives to encourage new firms to locate within the County and existing firms to expand operations.

AQ 7.5 Reduce regulations on small businesses wherever possible and thereby encourage small business development and job creation. The County shall set performance standards as well as design standards, thus giving small business owners as many options as possible to comply with County regulations.

LU 7.10 Locate job centers so they have convenient access to the County's multi-modal transportation facilities.

LU 7.12 Improve the relationship and ratio between jobs and housing so that residents have an opportunity to live and work within the County.

AQ 8.1 Locate new public facilities in job-poor areas of the County.

AQ 8.3 Time and locate public facilities and services so that they further enhance job creation opportunities.

AQ 8.5 Develop community centers in conformance with policies contained in the Land Use Element.

AQ 8.6 Encourage employment centers in close proximity to residential uses.

AQ 8.7 Implement zoning code provisions which encourage community centers, telecommuting, and home-based businesses.

Greater than 1:1 Habitat Mitigation. The Commentor suggests that here should be greater than 1:1 mitigation for impacts to high value habitat areas. Riverside County agrees. Mitigation measure 4.6.1B describes the replacement ratio for the preservation of habitat. It is worded as follows:

4.6.1B Preserve habitat at minimum [emphasis added] of 1:1 replacement ratio in locations that provide long-term conservation value for impacted resource. This could involve acquisition of habitat occupied by the affected species, acquiring a key parcel that fills in a missing link or gap in a reserve that provides conservation for the species, or acquisition of credits in a mitigation bank (endorsed by the USFWS and/or CDFG) that has been established to provide conservation value for the species. Implementation of the mitigation measure shall include provisions for the preservation of such areas in perpetuity.

Further, on page 4.6-58 of the General Plan EIR, there is acknowledgment of the possibility of replacement ratios that are higher:

It is recognized that while a minimum replacement ratio of 1:1 is sufficient mitigation for CEQA purposes, the USFWS and the CDFG may not accept the 1:1 ratio for Federal and State Endangered Species Act mitigation. The County of Riverside recognizes that the USFWS and CDFG may, and in some cases will, require a higher replacement ratio (i.e., 2:1 or 3:1 are typical replacement ratios required for ESA compliance).

Adoption of MSHCP. The Commentor suggests that the adoption of the Western Riverside County MSHCP should be a condition of General Plan approval. The General Plan can be described as the Riverside County "blueprint" for future development. It represents the community's view of its future, a constitution made up of the goals and policies upon which the Board of Supervisors will base their land use decisions. The Western Riverside County MSHCP covers all of western Riverside County, including County and City jurisdictions, and provides a Plan for that area with respect to certain biological resources. If the Western Riverside County MSHCP were not adopted by the Wildlife Agencies (U.S. Fish and Wildlife Service and California Department of Fish and Game), in the scenario described by the Commentor, the General Plan also would not be adopted. There would be no updated "blueprint" for future development in Riverside County.

The General Plan and the Western Riverside County MSHCP have been treated as separate entities to ensure that the General Plan could go forward and not be precluded from being adopted. Proposed in the General Plan EIR were certain mitigation measures that would apply only to areas that may not be subject to an MSHCP (i.e., Riverside County east of Coachella Valley, western Riverside County, and the Coachella Valley). Thus, mitigation measures were provided for these areas regardless of whether an HCP existed.

KK-92 Refer to responses KK-93, KK-94, KK-95, KK-96, and KK-97.

KK-93 State Housing Element law precludes the types of agreements described in Comment KK-93. Currently, State Housing Element requires counties to provide their fair share of housing for all economic segments of the county within unincorporated territories. Should State law be changed to permit the County to meet its housing objectives within lands annexed to cities, and permit cities and counties to reach agreements that would permit residential development within lands annexed into cities to be credited to the County, Riverside County could then consider the Rural Emphasis Alternative.

The scenario set forth in Comment KK-94 is inconsistent with the intent of the Rural Emphasis alternative. Essentially, the scenario set forth in Comment KK-94 would not result in any net reduction in the intensity of development, and would only result in an incremental expansion of city limits with little or no change in long-term land use. The Rural Emphasis was intended to represent a substantial net reduction in development on lands that are currently within unincorporated territory. If the Rural Emphasis alternative were to be adopted by the County, transportation and infrastructure planning for unincorporated areas would be based on the development densities set for in the County General Plan, and not on speculative development densities that might occur if lands were to be annexed into cities. Continual annexation of lands designated in the County's General Plan for rural development into cities for the purpose of higher density urban development would create a burden on County roadways that were not designed to accommodate the higher traffic volumes that would result from expanding cities, and also result in ongoing conflicts between rural development approved pursuant to a County General Plan based on the Rural Emphasis Alternative and urban development within lands annexed to cities to meet what would otherwise have been the County's housing need.

KK-94 The process described in Comment KK-94 describes the process used to generate the proposed General Plan land use map with one major exception. Comment KK-94 suggests an alternative that would eliminate incorporation into the General Plan of SCAG regional growth projections, the County's obligation to provide new housing to meet the needs of all economic segments of the community as set forth in State Housing Element law, the County's need for economic development activity to create new jobs (e.g, industrial land), and the need to generate sales tax dollars to pay for the services demanded by existing and future residents (e.g., commercial lands).

The process set forth in the comment would also ignore existing development approvals and the land use plans of the cities within the County. While such an alternative would likely achieve environmental protection objectives, it would not likely meet community development objectives that are equally important.

To prepare the General Plan, a massive GIS database was created, providing mapping of existing land uses, steep slopes, wildlife habitats and linkages, and hazard areas. Services agencies throughout Riverside County were queried as to their capacity to address the need of future growth. This information was compiled in the Riverside County Integrated Project Existing Setting Report. Information in the Existing Setting Report, along with habitat mapping conducted for the Western Riverside County Multi-Species Habitat Conservation Plan (MSHCP) and mapping conducted for the Coachella Valley Association of Governments' MSHCP was used in preparing the General Plan land use map.

Section 15126.6a of CEQA Guidelines requires that an EIR "describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives....There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason." Section 15126.6f of California CEQA Guidelines sets forth this rule of reason, stating that an EIR is required to set forth "only those alternatives necessary to permit a reasoned choice." CEQA does not require that alternatives include the level of detail of the original project, but that they provide a basis for reasonable discussion.

To meet CEQA requirements for a reasonable range of alternatives, the County first identified the concepts that would mitigate impacts of future growth and development. These concepts included the following.

• Achieving a net overall reduction in development (Rural Emphasis alternative) to reduce overall traffic generation, demand for public services and facilities, and loss of agricultural land.

• Reducing the intensity of development within community centers with no net reduction in the overall amount of development within unincorporated areas, thereby providing a less concentrated form of development (Less Intense Community Centers Alternative) aimed at reducing potential traffic impacts and overcrowding within community centers.

• Increasing the intensity of development within community centers with no net reduction in the overall amount of development within unincorporated areas, thereby providing a more concentrated form of development (More Intense Community Centers Alternative) aimed at facilitating regional transit and reducing impacts involving the loss of agricultural and open space lands.

• Increasing the overall amount of development within unincorporated areas by providing density bonuses as a means of improving the overall quality of new development and raising funds to purchase lands for open space preservation.

Section 6.0 of the Draft EIR describes these concepts and provides an analysis of the General Plan alternatives related to each, along with an analysis of the "No Build" and "No Project (Existing General Plan)" alternatives. As shown in Table 6.K, each of these alternatives is capable of reducing some, but not all of the environmental impacts that would result from the proposed General Plan. Section 6.0 and Table 6.K demonstrate that reducing the overall amount of development occurring within unincorporated Riverside County would reduce the following environmental effects as compared to the proposed General Plan.

• Aesthetic impacts, including impacts related to increases in light and glare and loss of open space;

• Air quality impacts, including construction impacts and long-term stationary and mobile source emissions;

• Consumption of non-renewable energy resources;

• Noise impacts related to construction and long-term vehicular sources; and

• Solid waste generation.

Section 6.0 and Table 6.K also demonstrate that increasing the intensity of community centers without reducing the overall amount of development occurring within unincorporated Riverside County would reduce the following environmental effects as compared to the proposed General Plan.

• Aesthetic impacts, including impacts related to loss of open space;

• Air quality impacts resulting from long-term stationary and mobile source emissions;

• Loss of biological resources;

• Consumption of non-renewable energy resources;

• Noise impacts related to long-term vehicular sources; and

• Traffic impacts on area roadways and highways.

KK-95 The Rural Emphasis Alternative is intended to be the "infill" alternative suggested in Comment KK-95. The Rural Emphasis Alternative would direct new urban development to cities and to existing developed unincorporated areas, but would not expand the area devoted to urban development within unincorporated Riverside County.

KK-96 Refer to response KK-94 for a description of the alternatives that were evaluated in the Draft EIR. Of the six project alternatives that were evaluated, the Draft EIR notes that the No Build Alternative would result in no physical changes to the environment. The No Project Alternative would allow the development according to the existing County General Plan, and four alternatives would alter the density patterns throughout the unincorpo-rated County. The EIR found that relocating the proposed project to an alternative site is not feasible, and no alternative site was considered.

The reasoning behind the identification of the Intensified Community Center Alternative as the environmentally superior alternative is presented in the Draft EIR starting on Page 6-58.

The EIR found that the No Build Alternative would reduce or eliminate impacts in all categories except mineral resources and transportation and circulation. Since no new development would occur within unincorporated Riverside County under this alternative, there would be no conversion of open space or agricultural lands, no increases in noise and air quality impacts associated with increased traffic, and no increase in the demand for public services and facilities. Traffic impacts were found to be greater under the No Build Alternative than under the proposed project. As the result of not having any new development within unincorporated areas, there would also be no road building undertaken. However, development within cities would continue, and such city-generated development would impact County roads. Unless the new development occurring within cities would construct needed roadways within unincorporated areas (which does not now occur), levels of service on County roadways would deteriorate rapidly. The EIR also found that under the No Build Alternative, existing mineral resources within unincorporated areas would not be mined, and would be effectively lost. The No Build Alternative was formulated primarily to serve as a baseline against which the proposed project could be evaluated. It would not be legally possible to enforce a General Plan that permitted no new development within unincorporated lands. Such a General Plan would result in substantial taking of private property, would be inconsistent with State Housing Element law requiring cities and counties to provide opportunities for meeting the housing needs of all economic segments of the community, not achieve any of the County's economic development objectives, and would be inconsistent with regional growth projections adopted by the Southern California Association of Governments (SCAG). For these reasons, the No Build Alternative was rejected.

The EIR found that build out of the County's existing General Plan (No Project Alternative) would result in similar or greater impacts than would the proposed General Plan. Impacts to transportation and circulation, long-term regional air quality emissions, and long-term vehicular noise would be greater under this alternative. This was due to the greater amount of development that would be generated by the existing General Plan, as compared to the proposed plan.

The Density Bonus Alternative would result in both an increased concentration of development, as well as a net increase in the amount of development as compared to the proposed project. Thus, impacts to traffic and circulation, long-term regional air quality emissions, long-term vehicular noise, and biological resources would be reduced. Traffic impacts are anticipated to be reduced as compared to the proposed project because of increased transit usage resulting from the ability to place larger concentrations of housing and employment within proximity to transit stops and routes. Traffic and associated air quality emissions impacts would be reduced as compared to the proposed General Plan due to a closer physical relationship between employment and housing areas that would result in a greater use of non-motorized transit and shorter home-to-work trips distances than would the proposed General Plan.

The Less Intense Community Centers Alternative would permit the same overall amount of the development as the proposed General Plan, but in a less concentrated, more dispersed pattern. Asa result, this alternative would have a greater impact relative to the loss of open space and agricultural land than would the proposed General Plan. Because of the spread out nature of future development, the EIR also found that long-term vehicular noise and regional air quality emissions would be greater under there alternatives than under the proposed project. Transportation and Circulation impacts associated with the Less Intense Community Centers Alternative were found in the Draft EIR to be greater than those anticipated for the proposed General Plan. Two factors led to this conclusion: first, by spreading out development, jobs and housing would be located at a greater distance from each other, thereby increasing the need for longer-distance automobile travel (with concurrent increases in air pollutant emissions). Second, by reducing development intensities within community centers, their ability to support transit use between centers and non-motorized travel within each center would be significantly reduced.

The two most promising alternatives in terms of representing an environmentally superior alternative to the proposed General Plan were the Rural Emphasis Alternative and the More Intense Community Centers Alternative.

Because the Rural Emphasis alternative represents a net reduction in development throughout unincorporated Riverside County, it would result in fewer demands for the expansion of public services and facilities to meet the needs of future residents and businesses. Because of the mitigation programs being implemented a part of the proposed General Plan to ensure adequate services and facilities, reducing the amount of future development would not reduce significant impacts associated with the proposed General Plan. Reductions in future development would, however, reduce impacts to aesthetics, light and glare, air quality, noise associated with construction and long-term vehicular use, and solid waste as compared to the proposed General Plan.

Traffic analysis of the Rural Emphasis Alternative found that transportation/circulation impacts would be similar to those anticipated for the proposed General Plan. Reductions in unincorporated development would not be sufficient to eliminate congestion resulting from rural development in the County and urban development in cities. The Rural Emphasis Alternative and the spread out nature of resulting development would reduce opportunities to support transit use within unincorporated areas. In addition, unless the County's Rural Emphasis Alternative were to be accompanied by a concurrent increase in the development intensity permitted within cities, opportunities for supporting transit overall within Riverside County would be reduced as compared to the proposed General Plan.

Of importance in the review of the Rural Emphasis Alternative and in determining that it was not the environmentally superior alternative were two factors: its effect on the County's ability to meet its housing needs and its effect on agricultural and natural open space lands. Comment KK-93 recognizes the need that the County would have under the Rural Emphasis Alternative to meet its fair share of regional housing needs within cities. As noted in Response KK-93, State law does not permit the County to accomplish that. Instead, State law requires each city and county to provide housing opportunities for "all economic segments of the community" within lands under its jurisdiction. Providing housing opportunities for very and low income households (those having median incomes less than 50% and 80% of the County's median income, respectively) requires higher density development than could normally be accomplished with rural development. Also important in determining that the Rural Emphasis Alternative was not the environmentally superior alternative was a finding that permitting widespread rural development would result in a loss of agricultural and natural open space similar to that of the proposed General Plan. This results because the Rural Emphasis Alternative essentially substitutes rural development intensities in areas where the proposed General Plan would permit future urban development. Thus, although the Rural Emphasis Alternative has many attributes of an environmentally superior alternative, it falls short in two critical areas: providing adequate housing for all economic segments of the community and preservation of agricultural and natural open space lands.

The More Intense Community Centers Alternative allows the same level of development as the proposed General Plan. Thus, the More Intense Community Centers Alternative essentially substitutes agriculture and natural open space for urban development while concentrating future urban development into a more compact form. Whereas the Rural Emphasis Alternative reduces the overall amount of development without reducing the land area devoted to urban and rural development, the More Intense Community Centers Alternative reduces the amount of land devoted to urban and rural development, while maintaining the amount of development. This is accomplished by clustering development into more intensive centers.

As a result, impacts to parks and recreation, solid waste, wastewater, and water resources would be similar to the proposed General Plan. The Density Bonus Alternative would allow an overall increase in urban population within unincorporated Riverside County that could be accommodated. Thus, impacts to parks and recreation, solid waste, wastewater, and water resources would be greater than under the Density Bonus Alternative than the proposed General Plan. Of critical importance in determining the More Intense Community Centers Alternative to be the environmentally superior alternative was this alternative's compact urban form. By reducing the amount of land devoted to urban and rural development, this alternative was more effective than other alternatives at preserving agricultural land and natural open space, while still meeting the County's need for housing and economic development.

The EIR found that the More Intense Community Centers Alternative would result in similar or reduced impacts when compared with the proposed General Plan (with the exception of land use impacts). All other feasible alternatives were found to result in greater impacts than the proposed General Plan. Thus, the EIR found the More Intense Community Centers Alternative to be the Environmentally Superior Alternative. The More Intense Community Centers Alternative was also found to meet the objectives of the proposed General Plan, which are to preserve crucial open space, provide a range of community design options in response to varied lifestyle choices, focus on high quality growth by using land resources efficiently, retain economically valuable agricultural lands, provide a comprehensive transportation system, provide public access to recreation opportunities, and expand local employment opportunities and broaden choices of transportation systems. Overall, the EIR found that reducing the amount of land devoted to all forms of urban and rural development was environmentally superior to simply reducing the amount of urban development without preserving agricultural resources and natural open space.

KK-97 Refer to responses KK-93 through KK-96 for discussion as to why additional alternatives do not need to be defined and evaluated. While it is clear that each alternative needs to have a description that is sufficiently detailed so as to permit quantified analysis, it is not necessary to draw a new countywide General Plan land use map and new Area Plan land use maps for each alternative. As noted in Response KK-94, Section 15126.6a of CEQA Guidelines requires that an EIR describe and evaluate a range of reasonable alternatives that would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project. Section 15126.6a also states that there is "no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason." As stated in Response KK-94, CEQA does not require that alternatives include the level of detail of the original project, but that they provide a basis for reasonable discussion. The level of detail afforded by a textual description of alternatives permitted a quantified analysis of alternatives without requiring preparation of new land use maps for each Area Plan and the Countywide General Plan land use map.

KK-98 Comment noted. Riverside County will comply with State law.

KK-99 Comment noted. A Mitigation Monitoring Program is provided in Section 4.0 of the Final EIR. This is a requirement of CEQA.

KK-100 The County disagrees. Comment noted.




Response to Letter LL: Endangered Habitats League

LL-1 The Commentor is discussing land use designations, specifically the preservation of open space. Land use designations are set forth in the Draft General Plan. The General Plan defines existing rural residential communities with one-half, one, and two-acre lot densities in areas such as Mead Valley, Cherry Valley, and Woodcrest (where this reflects existing development). The General Plan allows for conservative growth near these areas, but still clusters the growth near these communities. Modifications to the land use designations were based upon the input received from local residents.






Response to Letter MM: Conservation Biology Institute

MM-1 The analysis in the biological resources section of the EIR (Section 4.6) assumes that the number of acres to be impacted by mineral resource extraction, recreation, and rural residential as 14,000 acres. Further breakdown of how this acreage will be distributed is infeasible at a Program EIR level. Any proposed use will have to comply with policies and mitigation measures in the General Plan and General Plan EIR.

MM-2 Pursuant to the 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 "The mitigation measures must be roughly proportional to the impacts of the project." The 1:1 habitat replacement ratio is roughly proportional to the impacts of implementing the General Plan. As is described in the Draft EIR (Section 4.6.4 Biological Resources Level of Significance after Mitigation) implementation of the numerous policies and mitigation measures will reduce impacts to biological resources, however, not to below a level of significance. Furthermore, the 1:1 ratio is a minimum; the County reserves the ability to require additional mitigation if appropriate. Further, biological resources are frequently under the jurisdiction of other agencies, including CDFG, USFWS, and US Army Corps of Engineers. These agencies may require additional mitigation measures, particularly concerning impacts to wetlands, waters of the US, and threatened and endangered species.

Pursuant to the 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."

Because there is the possibility that the Western Riverside County MSHCP may not be adopted at all or may be changed appreciably, the provisions of the CVAG and Western Riverside County MSHCPs were not incorporated within the General Plan EIR. Thus, the General Plan EIR does not contain an analysis of the MSHCP impacts, economic or otherwise, except as analyzed in Section 5 as part of a cumulative analysis. The MSHCPs are the subject of their own stand alone environmental analysis in their individual EIR/EISs. The General Plan EIR is an analysis of the impacts of implementation of the General Plan. Pertinent policies, however, were incorporated and adapted to the General Plan EIR to facilitate implementation of the Western Riverside County MSHCP should it be adopted.

MM-3 As is described in Section 2.1 of the Draft EIR, this EIR is a "Program EIR" that 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. The General Plan EIR 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 and to formulate appropriate mitigation measures. 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. These analyses typically evaluate the impacts of a single activity undertaken to implement the overall plan.

The mitigation measures recommended by the Commentor are consistent with the Open Space policies of the General Plan and with the additional mitigation measures outlined in the Draft EIR. The Commentor is correct that mitigation requirements must also include provision of perpetual management of mitigation properties. It is anticipated that provisions for long-term management of mitigation lands will be included in future project-specific environmental analyses.

MM-4 The Draft EIR discusses Impact 4.6.3 (the loss of sensitive habitats, including wetlands) and identifies 19 policies and measures of avoidance, minimization, or compensation for such impacts. Measure 4.6.3 was formulated for precisely the reasons identified by the Commentor (i.e., treatment wetlands do not typically compensate for the loss of natural wetland communities). The other relevant policies and measures will, when implemented at a project-specific scale, provide mitigation for impacts to wetlands.








Response to Letter NN: Property Owners Association of Riverside County

NN-1 The Commentor assumes that the MSHCP is a part of the General Plan EIR. Because there is the possibility that the Western Riverside County MSHCP may not be adopted at all or may be changed appreciably, the provisions of the CVAG and Western Riverside County MSHCPs were not incorporated within the General Plan EIR. Thus, the General Plan EIR does not contain an analysis of the MSHCP impacts, economic or otherwise, except as analyzed in Section 5 as part of a cumulative analysis. The MSHCPs are the subject of their own stand alone environmental analysis in their individual EIR/EISs. The General Plan EIR is an analysis of the impacts of implementation of the General Plan. Pertinent policies, however, were incorporated and adapted to the General Plan EIR to facilitate implementation of the Western Riverside County MSHCP should it be adopted.

The Commentor states that property assessments would be reduced by the following:

• A 5-year limitation on the frequency of General Plan Foundation Component Amendments; and

• Change of a significant portion of the County through new lower density land use designations.

The Commentor does not provide a link between the 5-year limitation or change in land use density and reduction in property assessments; therefore, no useful response can be made to this comment. Moreover, property assessment changes are generally not considered to be an environmental impact. The Commentor is correct in stating that the General Plan Foundation Component Amendments can be changed every 5 years. These amendments involve changes in the Riverside County Vision, the General Plan Planning Principles, and/or a Foundation Component of the General Plan. These changes would be basic to the entire process of land management in the County and, as such, are allowed to be changed every 5 years. As for changes in land use designations, implementation of the policies in the proposed General Plan would reduce most land use impacts to a less than significant level. While the implementation of proposed General Plan policies and mitigation measures would help reduce the conversion of agricultural lands to urban uses, the potential loss of Prime, Unique, or Statewide Important farmland remains a significant unavoidable impact.

The Commentor further puts forth that a reduction of property assessments would result in adverse reductions of public services and deterioration of the physical environment. The Commentor does not propose what the connection is between an asserted reduction of property assessments and reduction in services and deterioration of the physical environment. It is Riverside County's contention that, even as a large population increase is projected, a well-planned land use map can secure a high quality of life for County residents by integrating and balancing the need for community and economic development. Features of the General Plan are designed to keep Riverside County economically competitive within the region and to provide an attractive environment and mobility for the high-wage employers sought by the County.

NN-2 The policies and mitigation measures are not intended to apply to every property or project in the County. Rather, the policies and measures will apply only to those properties or projects for which a clear nexus to impacts is identified through subsequent environmental review. 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. The policies and mitigation measures will be applied in conjunction with a project-specific analysis of biological impacts of future development projects.

NN-3 The MSHCP mitigation measures are incorporated into the Draft EIR where appropriate. If the MSHCP were not adopted, the Draft EIR mitigation measures would stand alone.

NN-4 Refer to response NN-3.

NN-5 The current Riverside County Comprehensive General Plan sets a Level of Service (LOS) C for all County-maintained roadways and conventional State highways. LOS D can be allowed in urban areas at intersections of any combination of major streets, arterials, expressways, or conventional State highways within 1.0 mile of a freeway interchange, and also at freeway ramp intersections. Development projects are currently required to mitigate impacts on roadways based on the LOS C standard. The Riverside County Board of Supervisors can approve the use of LOS D at intersections where mitigating to LOS C is deemed to be impractical.

The proposed General Plan will permit LOS D in Community Development Areas. This change in LOS will increase the vehicle delay from 35 to 55 seconds, not from 10 to 15 minutes as stated in the comment. LOS E will be permitted in designated community centers to the extent that it will support transit-oriented development and walkable communities. This change in LOS will increase the vehicle delay from 35 to 80 seconds, not from 10 to 25 minutes as stated in the comment.

The projected regional vehicle emissions generated by the additional vehicle miles traveled due to the proposed Riverside County General Plan have been calculated and are provided in Table 4.5.L of the Air Quality Analysis. These emissions were calculated at the average vehicle speed within the County both with and without the proposed General Plan. Therefore, any additional delay due to the changes in LOS has been incorporated into the regional emission calculations.


























Response to Letter OO: Riverside County Farm Bureau, Inc.

OO-1 During the General Plan process, the County of Riverside solicited and received input from a variety of agencies, organizations, and individuals with many opposing views. The General Plan includes numerous policies that represent an objective effort to address the concerns of the various parties involved in the General Plan process. Additionally, the Draft EIR includes measures to reduce potential impacts to agricultural resources that may result from implementation of the General Plan. The Commentor's opinion of the General Plan's effect on County agricultural production is noted.

OO-2 Page 4.2-6 of the Draft EIR has been revised as follows:

The existing Riverside County General Plan defines productive agricultural lands as land "which is involved in a long-term, substantial investment to agricultural use, and which has a long-term economic viability for agricultural use." Some of the factors affecting the economic viability of these areas include weather, water prices, crop selection, management techniques, commodity prices, new technology, and proximity of developed lands. The total gross valuation of agricultural crops in the County in 20011997 was $1,087,920,000. $1,124,908,400. This amount represents an increase of $76,346,800 over the 2000 gross value. Although this represents a $53.9 million decrease from 1996 crop values, Within the Southern California region, the total value of agricultural production in the Riverside County is exceeded only by San Diego County. Statewide, Riverside County is ranked ninth in the value its agricultural production. Riverside County is the leading agricultural county in Southern California.

Agricultural statistics are maintained by the County in four districts: Riverside/ Corona, San Jacinto/Temecula Valley, Coachella Valley and Palo Verde Valley. The Coachella Valley District recorded highest valuation in non-livestock related agricultural production, followed by the San Jacinto/Temecula Valley District alo Verde Valley District, the Palo Verde Valley District San Jacinto/Temecula Valley District, and the Riverside/Corona District (Table 4.2.B).

Table 4.2.B - Crop Valuation (in millions)
 1993 1994 1995 1996 1997
Riverside/Corona $71.1 $47.4 $46.7 $40.7 $29.0
San Jacinto/Temecula Valley $92.6 $85.6 $93.1 $95.3 $97.8
Coachella Valley $341.1 $324.4 $406.1 $319.6 $331.7
Palo Verde Valley $79.2 $89.6 $100.2 $103.1 $102.9
County Total $584.0 $547.0 $646.1 $558.7 $561.4
Note: Crop valuations do no include the value of livestock and poultry produced in the County.
Source: Riverside County Agricultural Commissioner.


Table 4.2.B - Crop Valuation (in millions)
 1997 1998 1999 2000 2001
Riverside/Corona $29.0 $38.4 $31.5 $31.2 $49.70
San Jacinto/Temecula $97.8 $112.0 $94.4 $102.3 $138.8
Valley
Coachella Valley $331.7 $398.1 $427.6 $324.7 $450.7
Palo Verde Valley $102.9 $92.0 $90.4 $93.9 $99.0
County Total $561.4 $640.5 $643.9 $552.1 $738.2
Note: Crop valuations do no include the value of livestock and poultry produced in the County.
Source: Riverside County Agricultural Commissioner.

The Commentor does not identify the restrictions referred to. The County notes that, to be viable, agriculture needs to have flexibility.

OO-3 The Commentor does not identify the specific "far-reaching and long-term implications" and "deficiencies" of the General Plan and Draft EIR. The Commentor's request for the correction and recirculation of the Draft EIR is noted.

OO-4 The MSHCP is not required by law. As an alternative, property owners can do individual HCPs when activities result in the take of listed species. Apart from the Endangered Species Act, the County has an obligation to mitigate impacts to biological resources to the maximum extent feasible.

The burden of mitigating the effects of urbanization now falls largely on the County, the cities, and private landowners who hold much of the last remaining intact habitats in the region. As development pressure has increased, so have conflicts between landowning interests and the State and federal regulatory processes associated with protecting endangered, threatened, and rare species. Conflicts over species conservation threaten the ability of local jurisdictions to plan for and provide the infrastructure necessary for economic development and a high quality of life in the County. This process, however, has resulted in costly delays in public and private development projects and created an assemblage of unconnected habitat areas on a project-by-project basis. This piecemeal and uncoordinated effort to mitigate the effects of development does not sustain wildlife mobility, genetic flow, or ecosystem health, which require large, interconnected natural areas.

The proposed MSHCP replaces the current piecemeal approach to project approval and mitigation with a coordinated, comprehensive approach based on the basic conventions of biological reserve design. This approach ensures that project mitigation is directed to those areas most critical to maintenance of ecosystem function and species viability. A goal of the proposed MSHCP is to target the highest quality habitats for preservation, while allowing development of less important habitat areas.

OO-5 General Plan policies will apply to new development that requires a permit or other authorization from the County. Existing permitted uses will not be affected. Based on an interpretation of land uses prepared to support the RCIP process, 266,926 acres in unincorporated areas were utilized for agricultural production. General Plan policies could affect the development of new agricultural land uses; however, to attempt to quantify the effects would be speculative at this time. If no permit is needed, the General Plan policies will not apply.

OO-6 The Commentor incorrectly assumes that the MSHCP is part of the General Plan EIR. As described on page 4.6-1 of the General Plan EIR, the Western Riverside County MSHCP and the Coachella Valley Association of Governments (CVAG) MSHCP programs are recognized, but the MSHCPs are not included in the existing setting description. In other words, the adoption of provisions contained within the MSHCPs was not assumed. Only conservation measures that are currently adopted are included.

The Commentor's further position is that the National Environmental Policy Act (NEPA) applies to the General Plan EIR. NEPA established an environmental review process that is separate from but similar to that under CEQA. However, NEPA applies only to federal agencies. A project that is already subject to CEQA will also be subject to NEPA when a federal agency does one or more of the following:

• Directly undertakes a federal project;

• Issues permits or entitlements for a state, local, or private project; and/or

• Provides funding for all or a portion of a state, local, or private project.

Thus, a State, local, or private activity may be subject to NEPA if federal contract, approval, or funding is involved as stated in 40 Code of Federal Regulations [CFR] 1508.18(b)(4). The General Plan is not a federal project; it can be described as the local Riverside County "blueprint"for future development. There is no federal "nexus." That is, the federal government is not issuing permits or entitlements necessary to develop the General Plan nor is it providing funding for all or a portion of the General Plan.

A NEPA document could replace the CEQA document. State and local agencies are encouraged to use NEPA documents to replace CEQA documents if the NEPA process is proceeding faster than the CEQA process and the NEPA document complies with CEQA (State CEQA Guidelines Section 15221). However, there is no federal document that specifically analyzes the environmental impacts of the General Plan of the entire Riverside County area. No NEPA document could substitute for the General Plan EIR.

As for the CETAP EIR/EIS, according to State CEQA Guidelines Section 15150, an EIR may incorporate all of a publicly available document or portions of it. The incorporated document must be summarized or described briefly, its relationship to the EIR must be summarized, and the EIR must state where the document will be made available for public inspection. The CETAP EIR/EIS was thus incorporated by reference. The Western Riverside County MSHCP EIR/EIS, on the other hand, was sent to the public after the General Plan EIR. It could not be incorporated by reference into the General Plan EIR, as it was not available to the public at that time.

OO-7 The Commentor quotes only a portion of the State CEQA Guidelines. In Section 15131(b), it goes on to say, in part, the following:

Economic or social effects of a project may be used to determine the significance of physical changes caused by the project. For example, if the construction of a new freeway or rail line divides an existing community, the construction would be the physical change, the social effect on the community would be the basis for determining that the effect would be significant....

Economic or social effects need to be considered in EIRs only if they would lead to an environmental effect. In practice, the evaluation of economic or social effects is generally treated as optional. Economic or social effects may be evaluated but are not required; however, the County chose to analyze all effects, including economic effects.

In fact, economic effects have been extensively analyzed in the Draft EIR. These effects and their resulting environmental impacts include the increase in population and housing and the potential associated effects on parks and recreation, water resources, and public services, such as fire protection, solid waste management, wastewater, schools, libraries, and medical facilities. Economic effects and their linked environmental effects also include the related issues of air quality, transportation, energy, and noise. In addition, economic effects could have potential indirect effects on biological and cultural resources, hazardous materials, and mineral resources.

Because the proposed General Plan would not mandate the conversion of existing agriculture to other uses, and would permit agricultural uses in the majority of land use designations, an adverse economic impact to agriculture is not anticipated outside of that which could result from normal market forces. Please see response OO-15.

OO-8 Refer to response OO-6 with regard to NEPA.

OO-9 The Certainties System would not lock up agricultural lands permanently. Agricultural lands can be converted to other uses every five years. Additionally, staff is recommending the implementation a program is in development which will allow an additional 5 percent of agricultural lands to be converted outside the Certainties System.

OO-10 The Commentor is not specific. The facilities mentioned in the comment are not specified, therefore it is difficult to respond. The General Plan policies require adequate facilities prior to development. These policies from the proposed General Plan include: LU 1.7, LU 5.1, LU 5.2, LU 22.3, and LU 23.6. Expanding public facilities into agricultural areas is not contemplated, nor would it be cost effective.

OO-11 This statement is intended to apply to new agricultural uses (e.g., request for a plot plan and zone change for a poultry ranch) and not pre-existing agriculture. In the case of pre-existing agriculture, in-coming development must recognize potential impacts and provide appropriate mitigation for the new use. This does not exempt existing operations from following industry standards with respect to housekeeping.

OO-12 Staff will recommend the amendment of policies OS 7.3, LU 16.4, AI3, and AI79 to include the text: Preserve prime agricultural lands for agricultural activities.

OO-13 Staff will recommend the amendment of policy LU 16.1 to state: Retain agriculturally designated lands where agricultural activity can be sustained, or where it accommodates lifestyle choice in locations where impacts to potentially incompatible uses, such as residential uses, are minimized.

OO-14 The Commentor's objection to policies LU16.10 and AI1 is noted. The County recognizes that to be viable, agriculture needs to have flexibility. This comment, as with all comments, will be taken into consideration by the decision-making body during the its deliberation on the General Plan. Additional changes to the proposed General Plan may be made pursuant to staff recommendations and comments received by the public during the public hearings.

OO-15 A change in General Plan land use designations never renders an existing use non-conforming. When the consistency zoning is adopted, it will allow agricultural operations where they currently exist (including in zones not designated agriculture), not as a non-conforming use but as an allowable use. The General Plan is a long-range plan. The consistency zoning will not force a change of land use.

OO-16 Refer to response OO-15. Agricultural operations will also be allowed in areas other than those specifically designated for Agriculture as part of the consistency zoning.

OO-17 Refer to response OO-14. If no discretionary permits are required, the General Plan policies will not apply. No discretionary permit is required by the County for existing agricultural uses.

OO-18 Agricultural impacts resulting from other proposed projects, such as the Western Riverside County MSHCP and the Coachella Valley MSHCP are not the result of the General Plan and are not analyzed in detail in the EIR. However, the other RCIP elements are considered in the Cumulative Impacts discussion in Section 5.4. The Coachella Valley MSHCP, as presently drafted, does not affect agricultural lands.

OO-19 Refer to response OO-18. The proposed Western Riverside County MSHCP does not contemplate taking land or coerced conversions of property. Rather, land would be obtained through willing sellers and as mitigation for projects. The Riverside County General Plan does not mandate adoption of either the Western Riverside County MSHCP or the Coachella Valley MSHCP. These projects are subject to additional environmental analysis in their respective CEQA/NEPA documents.

Under the Western Riverside County MSHCP, existing agricultural operations will be permitted to continue as a covered use within the Criteria Area. If the expansion of existing agricultural operations within the Criteria Area requires a City or County discretionary authorization, the Criteria will be applied and appropriate mitigation imposed. Expansion projects within the Criteria Area will not be subject to Criteria and mitigation requirements if the expansion is limited to areas that have been recently and consistently disturbed and exhibit little or no habitat value. If the expansion of agricultural operations requiring a discretionary authorization occurs outside the Criteria Area, the criteria and mitigation requirements will not apply. The Coachella Valley MSHCP, as presently drafted, does not affect agricultural lands.

OO-20 The Riverside County General Plan does not mandate adoption of either the Western Riverside County MSHCP or the Coachella Valley MSHCP. These projects are subject to additional environmental analysis in their respective CEQA/NEPA documents.

OO-21 Refer to response OO-20.

OO-22 Existing agricultural operations will be allowed to continue operation under the Western Riverside County MSHCP. In addition, 10,000 acres of new agricultural land will be allowed to operate within the conservation area of the MSHCP.

OO-23 Refer to response OO-22.

OO-24 Refer to response OO-19. The proposed General Plan and the proposed Western Riverside County MSHCP, as well as their associated environmental documentation, are intended to be stand-alone plans. Staff has recommended that the County clarify any policies or other text in the proposed General Plan that indicate reliance on the Western Riverside County MSHCP.

OO-25 It is not clear from the Comment OO-25 what the author of the comment believes the indirect impacts of the General Plan's habitat conservation policies to be. As part of the Draft EIR, the County reviewed potential direct and indirect impacts of the General Plan's habitat conservation policies. The direct impacts would be preservation of habitat areas and mitigation for the impacts of development otherwise permitted by the General Plan. The indirect impacts of the General Plan's habitat conservation policies are those that would result from the development that would be permitted by adherence to the habitat conservation policies. The Draft EIR found that by protecting certain areas because of the significance or sensitivity of their habitats, the General Plan would direct future development to other lands. The resulting pattern of development is the indirect impact of habitat conservation policies, and is addressed throughout the Draft EIR in the context of the direct impacts of development that would be permitted by the General Plan.

OO-26 The Commentor has not provided the County with any feasible mitigation measures to consider. The Commentor is concerned about agricultural lands being subject to policies in the General Plan that relate to habitat-conservation. All agricultural lands are subject to the provisions of the Federal and State Endangered Species Act. Staff has recommended that the County clarify any policies or other text in the proposed General Plan that indicate reliance on the Western Riverside County MSHCP. Such changes will be taken into consideration at the public hearings before the County Board of Supervisors. The Commentor's concern that agricultural resources will be converted to conservation use is noted; however, neither the proposed General Plan nor the proposed Western Riverside County MSHCP would require such conversion of existing agricultural lands. The Western Riverside County MSHCP would allow agricultural land within the Criteria Area that is desirable for conservation to be set aside, either to be purchased for conservation or as mitigation for development, but does not mandate this conversion. Existing agricultural uses would not be rendered non-conforming by the proposed General Plan, regardless of which Foundational Component contains them. Any newly proposed agricultural facilities will be subject to all applicable policies of the General Plan and any adopted HCPs for the area.

OO-27 The Commentor requests that a listing of "Responsible" and "Trustee" agencies, list of permits and other approvals, and list of environmental review and consultation requirements be included in the EIR. In this instance, the sole agency responsible for approving the General Plan EIR is the County of Riverside. The General Plan will be adopted by the County, and the Housing Element will be subject to review by the California Department of Housing and Community Development (HCD). Development that occurs as a result of implementation of the General Plan would involve additional environmental review; responsible and trustee agencies involved in implementing the General Plan policies will likely include most of the local and State agencies (with the likely exception of the California Coastal Commission). Such a listing is not applicable to the program-level General Plan EIR; however, it is anticipated that trustee agencies such as CDFG, State Lands Agencies, water use agencies, and those providing infrastructure will use the EIR analysis as the basis for reviewing resource agency permits needed for development.

OO-28 Refer to responses OO-14, OO-15, OO-19, OO-24, and OO-27.

OO-29 The proposed Western Riverside County MSHCP would not result in coerced conversions of agricultural land to other land uses. The No Project and No Build Alternatives (Existing General Plan) analyzed in the EIR do provide for a reduced effect on agricultural lands that is not provided with the proposed General Plan. The County is not dismissing the unavoidable impacts on agricultural lands; however, has provided an objective analysis of the proposed General Plan on the conversion of agricultural lands and has determined the loss of agricultural lands as significant and unavoidable. Refer to responses OO-14, OO-15, OO-19, and OO-24.

OO-30 Refer to responses OO-14, OO-15, OO-19, and OO-24. The County will review the existing right-to-farm ordinance and consider expanding its notice perimeter and applying it to areas that are not agriculturally zoned. The incentives system would include agricultural lands. Agricultural operations will be allowed in most zones.

OO-31 This comment is a summary of the preceding comments. The issues raised are discussed in responses OO-19 through OO-30.

OO-32 Refer to Response KK-16. Under the proposed General Plan, the number of acres of land within unincorporated Riverside County designated for agricultural operations is reduced from that which is currently utilized for such activities. The Draft EIR states that potential impacts to agricultural operations would remain significant despite the implementation of proposed General Plan policies and mitigation measures identified in the Draft EIR. The decision to maintain land in agricultural operation is a decision made by individual property owners.

The intent of the mitigation is not to relocate agricultural operations (in their entirety), rather it is an attempt to preserve a portion of the agricultural acreage that is lost when a landowner exercises his or her right to cease agricultural operations.

OO-33 Section 4.2 of the Draft EIR will be revised to incorporate the data contained in 2001 Agricultural Production Report for Riverside County (refer to response OO-2).

OO-34 The Commentor's contribution to the General Plan process and request for the recirculation of the Draft EIR is noted.




Response to Letter PP: Sierra Club, San Gorgonio Chapter

PP-1 While the General Plan is a component of the Riverside County Integrated Project work effort, it is a stand-alone document. The General Plan has "independent utility," meaning that the adoption of any one component of the RCIP effort is not dependent on the adoption of the others. This allows, that in the event either the CETAP or MSHCP documents are not approved, the County would still possess an up-to-date legally adequate General Plan, as required by State law. Government Code 65300 states that "... the general plan and elements and parts thereof comprise an integrated, internally consistent, and compatible statement of policies for the adopting agency." The various elements presented in the General Plan meet this requirement.

While the objective of the RCIP effort is to fully integrate the component plans, it does not necessarily follow that the various documents will be prepared, reviewed, or approved simultaneously. Copies of the various documents have been made available for public review at offices of the County Planning Department and public libraries. The noticing of public scoping meetings and the public review of the documents has followed State and federally mandated guidelines. Since the inception of the integrated planning process, the County of Riverside has provided on-line access to the documents prepared during the Riverside County Integrated Project work effort. The RCIP website at www.rcip.org provides a calendar of public meetings, a library of RCIP material, press releases, contact information, RCIP team members, and the means to contact the County with comments and concerns about the RCIP process. For those with the desire, sufficient opportunity has been provided to provide input to and comment on the various RCIP documents.














Response to Letter QQ: Building Industry Association of Southern California

QQ-1 The County concurs with the Commentor on this issue. The following text amendments will be made in Section 1.1, page 1-1, second paragraph:

The challenge of balancing the housing, transportation, and economic needs of existing and future populations with limited natural resources and the sensitivity of the natural environment has led Riverside County to develop the Riverside County Integrated Project (RCIP). The RCIP, which consists of three coordinated plans, will determine future planning, transportation, and conservation needs for Riverside County. These three plans include the following:

• The 2002 Riverside County General Plan (Comprehensive General Plan Amendment No.GPA00618).

• The creation of a Multiple Species Habitat Conservation Plan (MSHCP) for the western portion of Riverside County, and the integration of an ongoing Coachella Valley Multi-Species Habitat Conservation Plan effort (which is not a part of RCIP but is a related program) into the fabric of comprehensive planning for the County.

• The identification of transportation corridors to meet the future transportation needs of Western Riverside County through the Community Environmental and Transportation Acceptability Program (CETAP).

Each of the plans has independent utility, and each can be approved without approval of the others. They will, however, be coordinated such that if all three are adopted, no conflicts between the plans will occur.

This document focuses on the 2002 Riverside County General Plan, which is the proposed project.

Section 3.1, page 3-1, paragraph four, will be changed as follows:

The challenge of balancing the housing, transportation, and economic needs of existing and future populations with limited natural resources and the sensitivity of the natural environment required Riverside County to develop the Riverside County Integrated Plan (RCIP), which consists of three coordinated plans to determine future planning, transportation, and conservation needs for Riverside County. These plans include the 2002 Riverside County General Plan, the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP), and the Community Environmental and Transportation Acceptability Program (CETAP). Each of the plans has independent utility, and each can be approved without approval of the others. They will, however, be coordinated such that if all three are adopted, no conflicts between the plans will occur.

Section 3.1, page 3-6, paragraph one, will be changed as follows:

The Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) involves the assembly and management of a reserve system for the conservation of natural habitats and their constituent wildlife populations. The MSHCP establishes a framework for complying with State and federal endangered species regulations, while accommodating future growth within the cities and unincorporated portions of western Riverside County. Thus, unlike the proposed General Plan, the MSHCP covers only the western portion of the County, and covers not only unincorporated areas, but cities as well. The MSHCP is designed to be complementary to the 2002 Riverside County General Plan, but could also be adopted in the event that the 2002 Riverside County General Plan were not.

Section 3.1, page 3-7, paragraph one, the following changes will be incorporated:

The CETAP component of RCIP identifies transportation corridors to meet the future transportation needs of Riverside County. CETAP is a multi-modal planning effort that considers highway options, and also looks at transit and other forms of travel demand management and goods movement. CETAP is designed to be complementary to the 2002 Riverside County General Plan, but could also be adopted in the event that the 2002 Riverside County General Plan is not.

In Section 3.1, page 3-8, paragraph 2, the following changes will be incorporated:

Although they are clearly related projects, and are each part of an integrated planning program, as described above, each RCIP component covers a different physical area, is being prepared pursuant to different State and federal laws, involves different agencies in their approval, and has different lead agencies for their environmental documentation. In addition, each RCIP component is on a slightly different schedule. As a result of these differences, preparation of a single environmental document was found to be impractical. Such a document would prove to be overly complex and impossible to understand. Instead, each environmental document prepared from components of the RCIP program contains a cumulative impact analysis, summarizing the overall impacts of RCIP. Finally, each RCIP component has independent utility, and could be adopted in the absence of adoption of the other components.

QQ-2 The County concurs with the Commentor on this issue. The following text amendments shall be made and included in Section 3.1, page 3-7, fourth paragraph of the Draft EIR:

Relationships and Differences Between RCIP Components

The 2002 Riverside County General Plan recognizes the Western Riverside County MSHCP, and incorporates the MSHCP into its Area Plans as mitigation for the biological impacts that will result from development permitted by the proposed General Plan. The proposed General Plan also incorporates by reference the Coachella Valley MSHCP being prepared by the Coachella Valley Association of Governments parallel to, but separate from, RCIP. The proposed General Plan Circulation Element includes proposed CETAP corridors as part of its proposed roadway and highway system.

The MSHCP provides comprehensive mitigation for the development impacts that will result from development of the proposed General Plan land uses and transportation facilities (including CETAP corridors) within the western portion of the County, including development of proposed CETAP corridors. The MSHCP also includes CETAP corridors as permitted activities where they cross MSHCP preserve areas.

The RCIP consists of three coordinated plans, the 2002 Riverside County General Plan (which is the subject of this Program EIR), the Western Riverside County MSHCP, and the CETAP. Although coordinated, these three plans are independent components of RCIP. As an independent plan, the 2002 Riverside County General Plan is not reliant upon the approval of either MSHCP or CETAP. The proposed General Plan is, however, coordinated with the MSHCP and the CETAP, so that no substantive conflicts or inconsistencies exist among the three plans. The General Plan is consistent with the draft MSHCP in that some of the draft MSHCP policies for biological resource preservation and mitigation are incorporated into the proposed General Plan's Area Plans. The biological resource policies incorporated into the Area Plans provide partial mitigation for development impacts that would result from development proposed by the General Plan's identified land uses, infrastructure, and transportation facilities. The proposed General Plan also is consistent with the draft CETAP in that the proposed General Plan Circulation Element recognizes the potential for proposed CETAP corridors as part of its proposed roadway and highway system.

QQ-3 The County concurs with the Commentor. The following text will be added in Section 3.4 after the last paragraph on page 3-81:

The EIR analysis relies on GIS data, which is based on the proposed General Plan description. However, because of the nature of GIS calculations, some acreages reported in the EIR may be slightly different from those indicated in the 2002 Riverside County General Plan Area Plans. These minor discrepancies do not affect the adequacy or accuracy of the EIR's environmental analysis.

QQ-4 The size of the size of the average farm in Riverside County was obtained from the California Agricultural Statistical Service (CASS). The CASS determined the average size of farms in the County to be 167 acres in 1997. A more recent determination of farm size has not been completed.

QQ-5 The thresholds of significance on page 4.4-5 of the Draft EIR are based on State CEQA Guidelines, Appendix G(I)(c). The County acknowledges that these thresholds may incorporate a subjective standard. The proposed General Plan does require site-specific review, as indicated by the policies listed on pages 4.4

6 through 4.4-9 of the Draft EIR. These policies give the County the tools to address aesthetic impacts.

QQ-6 The introductory paragraph in Section 4.6 states that: The proposed General Plan and this EIR recognize the ongoing MSHCP programs. In fact, the proposed General Plan relies heavily on adoption of these programs for its biological mitigation. This statement is true, as the General Plan does indeed rely on adoption of the MSHCP. However, to ensure that the proposed General Plan can serve as a stand-alone document, adequate mitigation measures were included (in addition to the measures in the Area Plans of the General Plan) in the EIR in the event that the MSHCP were not adopted. These would apply to areas outside HCP boundaries. As stated in the first paragraph in Section 4.6: Because the proposed General Plan is moving ahead of these programs, their adoption cannot be ensured, and the implementation of MSHCP provisions cannot be assumed.

QQ-7 Comment noted. Staff has recommended the change suggested by the Commentor be made to the proposed General Plan.

QQ-8 The Commentor requests a definition of "Native American Statement" as it relates to General Plan Policy 19.4 (on page 4.7-23 of the Draft EIR). The policy has been modified to read as follows:

OS 19.4 Require a Native American consultation as part of the environmental review process on development projects with identified cultural resources.

QQ-9 Mitigation measure 4.9.1B has been amended as requested to the following:

4.9.1B Riverside County shall prohibit alteration of floodways and channelization unless alternative methods of flood control are not found to be technically, economically, and practically infeasible.

QQ-10 The Commentor requests a more quantitative analysis of impacts to mineral resources. The analysis of mineral resources in the Draft EIR is appropriate for a programmatic EIR. A designation of open space does not preclude the use of land for mineral extraction. Further analysis of impacts to mineral resources will be conducted on a project-by-project basis as a part of environmental review, as lands with mineral resources are developed or set aside.

QQ-11 The following text change will be made to Section 4.13, page 4.13-103:

4.13.2C The County shall require that proposed new commercial and industrial developments prepare acoustical studies, analyzing potential noise impacts on adjacent properties, when these developments abut noise-sensitive land uses. The County will require that all identified direct impacts to noise-sensitive land uses be mitigated to the maximum extent practicable a less than significant level.

Concerning the text in Section 5.4, the County believes the statement of the cumulative noise impacts of the General Plan is accurate.

QQ-12 The County concurs with the comment. No further response is required.

QQ-13 To correspond with legislative efforts requiring the identification of water supplies adequate to support development, the Draft EIR has been revised as follows:

Mitigation Measures

4.17.1A Proponents of new development within unincorporated areas of Riverside County that consist of: a residential development of more than 500 dwelling units; a shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space; a commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space; a hotel/motel development of more than 5,000 rooms; an industrial, manufacturing/processing plant, or industrial park employing more than 1,000 persons or occupying more than 650,000 square feet of floor space or 40 acres of land; a mixed-use development that includes any of the previously referenced projects; or a project with a water demand equivalent to that used by 500 residential units with projected water demand of more than 250 af per year shall be required to submit a water supply assessment report prior to approval of a project. The water supply assessment report shall include the following:

• Project description;

• Water resources environmental setting;

• Conservation and water recycling measures included in the project;

• The identification of existing water entitlements, water rights, or water service contracts relevant to the water supply identified for a proposed project, and the amount of water received pursuant to such entitlements, rights, or contracts;

• Project water demand;

• Water supply alternatives;

• Preferred water supply alternative;

• Impacts associated with use of the preferred water supply alternative;

• Evaluation of compliance with the applicable Urban Water Management Plan;

• Summary and conclusions; and

• Technical appendices and attachment of supporting documents.

Said water supply assessment report shall be submitted to the County and applicable water supply agencies for review. Development shall not be permitted unless an adequate supply of water, available for use and sufficient to supply a proposed project, in wet and drought years, has been identified. Where water supply adequate to supply a project in its entirety does not exist, development of only those portions of a project with an adequate and available water supply shall be permitted. Evidence of the availability of adequate water supply shall be submitted to the County for review and approval prior to the issuance of development permits.

4.17.1B For projects smaller than those stated in Mitigation Measure 4.17.1A, with an estimated annual water use of 250 af or less, the County shall require evidence that the project is in compliance with the Urban Water Management Plan for the area in which the development is located, prior to the issuance of development permits. Evidence of such compliance shall take the form of written verification by the water provider that the project is in compliance with said plan. As determined necessary by the County, preparation of a water supply plan (as required in Mitigation Measure 4.17.1A, above) shall be required for a project that is estimated to use less than 250 af per year, prior to the issuance of development permits.

QQ-14 Section 15126.6a of State CEQA Guidelines requires that an EIR "describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason." Section 15126.6f of State CEQA Guidelines sets forth this rule of reason, stating that an EIR is required to set forth "only those alternatives necessary to permit a reasoned choice." CEQA does not require that alternatives include the level of detail of the original project, but that they provide a basis for reasonable discussion.

To meet CEQA requirements for a reasonable range of alternatives, the County first identified the concepts that would mitigate impacts of future growth and development. These concepts included the following.

• Achieving a net overall reduction in development (Rural Emphasis alternative) to reduce overall traffic generation, demand for public services and facilities, and loss of agricultural land.

• Reducing the intensity of development within community centers with no net reduction in the overall amount of development within unincorporated areas, thereby providing a less concentrated form of development (Less Intense Community Centers Alternative) aimed at reducing potential traffic impacts and overcrowding within community centers.

• Increasing the intensity of development within community centers with no net reduction in the overall amount of development within unincorporated areas, thereby providing a more concentrated form of development (More Intense Community Centers Alternative) aimed at facilitating regional transit and reducing impacts involving the loss of agricultural and open space lands.

• Increasing the overall amount of development within unincorporated areas by providing density bonuses as a means of improving the overall quality of new development and raising funds to purchase lands for open space preservation.

Section 6.0 of the Draft EIR describes these concepts and provides an analysis of the General Plan alternatives related to each, along with an analysis of the ‘No Build" and "No Project (Existing General Plan)" alternatives. As shown in Table 6.K, each of these alternatives is capable of reducing some, but not all of the environmental impacts that would result from the proposed General Plan. Section 6.0 and Table 6.K demonstrate that reducing the overall amount of development occurring within unincorporated Riverside County would reduce the following environmental effects as compared to the proposed General Plan.

• Aesthetic impacts, including impacts related to increases in light and glare and loss of open space;

• Air quality impacts, including construction impacts and long-term stationary and mobile source emissions;

• Consumption of non-renewable energy resources;

• Noise impacts related to construction and long-term vehicular sources; and

• Solid waste generation.

The "No Project" and "No Build" Alternatives assume that neither the Coachella Valley or Western Riverside County MSHCP are approved. The County is of the opinion that according to CEQA Guidelines Section 15126.6a, the EIR analyzes a reasonable range of alternatives and the County did take into consideration that fact that the Coachella Valley or Western Riverside County MSHCP are independent plans from the General Plan in the formulation of the General Plan alternatives.

QQ-15 Section 9.0 of the Draft EIR cites the references consulted in the preparation of the Draft EIR and is not the appropriate place to address concerns related to the development of alternatives to the proposed General Plan. As detailed in Section 6.0, the Draft EIR includes a discussion of six possible alternatives to the proposed General Plan, as well as a brief review of three alternatives that failed to meet the stated objectives of the proposed General Plan. The alternatives carried forward for discussion represent development scenarios ranging from a ban on future development to more intense development of community centers. To satisfy the requirement of Section 15126.6(c) of the CEQA Guidelines, Page 6-1 (following the fourth paragraph) of the Draft EIR has been revised to include the following:

The alternatives included in this section have been selected to represent a range of possible development scenarios. The alternatives have been selected to identify potential impacts that would result from continuation of the policies stated in the current General Plan (No Project Alternative) and from a ban on future development within unincorporated areas of the County (No Build Alternative). "Build" alternatives were identified so that potential impacts resulting from implementation of a General Plan that emphasizes rural residential development (Rural Emphasis Alternative); a more sprawling form of development (Less Intense Community Centers Alternative); and a less sprawling form of development (More Intense Community Centers Alternative). The Density Bonus Alternative was selected to identify potential impacts associated with increasing residential development Community Centers and within the "Community Development" designation without a corresponding increase in commercial and/or industrial development in these areas.

QQ-16 Comment noted.

QQ-17 The following text changes will be made to Section 6.2.5, page 6-47, paragraph four:

The More Intense Community Centers Alternative would reduce energy, long-term vehicular noise, and transportation/circulation impacts compared to the proposed General Plan. Because this alternative would result in an increased decreased level of conversion of farmland to non-agricultural uses, it would result in increased decreased impacts relating to land use and agriculture compared to the proposed General Plan.

The following changes will be made to Section 6.3, page 57, Table 6.K:

Environmental Issue No Build Alternative No Project Alternative Rural Emphasis Alternative Less Intense Community Centers Alternative More Intense Community Centers Alternative1 Density Bonus Alternative
Land Use/Agriculture Less Same Greater Greater Greater (Land Use) Less (Agriculture) Greater

For Section 6.3, page 6-59, paragraph one, the following change will be incorporated:

The More Intense Community Centers and Density Bonus Alternatives would both result in increased concentration of development. Thus, under each of these alternatives, impacts to traffic and circulation, long-term regional air quality emissions, long-term vehicular noise, and biological resources would be reduced. Aesthetic impacts relating to the conversion of open space to urban land uses would also be reduced. Impacts relating to housing and population, mineral resources, construction and stationary noise, aesthetics, light and glare, and public services (except solid waste and wastewater) would be similar to those under the proposed General Plan. Impacts relating to land use would increase, as more people would be concentrated in areas exposed to noise and other hazards. Impacts relating to conversion of agricultural lands to non-agricultural uses would decrease.

QQ-18 The following text amendment will be made to Section 1.5.2, Page 1-17, Table 1.A, under Land Use/Agriculture:

Conflict with any Applicable Habitat Conservation Plan or Natural Community Conservation Plan Policies aimed at protecting biological resources will be are contained in the proposed General Plan. These policies will acknowledge existing habitat conservation plans within the County and ensure that land use plans be are consistent with the provisions of applicable conservation plans, including the Habitat Conservation Plan for the Stephen’s kangaroo rat. Because the proposed General Plan includes policies accommodating existing habitat conservation plans within the County, no significant impact associated with this issue will occur upon implementation of the proposed General Plan. No mitigation required. Less than significant.


QQ-19 The following text amendment will be made to Section 1.5.2, page 1-18, Table 1.A:

Conflict with any Applicable Airport Land Use Plan Under the proposed General Plan, economic development and population growth will continue to increase, requiring the construction of additional places of busi ness and housing. As the land suitable for development becomes increasingly scarce, urban development may be forced to exploit land occur adjacent to airports. Such encroaching development may result in conflicts between new development and the goals and policies outlined in local Airport Land Use Plans.
In addition to the discussion of airports provided in the proposed General Plan, specific areas influenced by airports, located in the County and/or in adjacent cities, are identified in the proposed Area Plans. Area Plans which identify specific areas influenced by airports provide policies to protect flight paths and minimize impacts to residents and employees within that area. These policies provided in the Area Plans are consistent with and support policies identified in the proposed General Plan.
Policies: LU 14.2, C 14.1, 14.5 Less than significant.

In Section 4.2, page 4.2-12, third paragraph under Airport Land Use Plans, the following changes will be made:

Under the proposed General Plan, economic development and population growth will continue to increase, requiring the construction of additional places of business and housing. As the land suitable for development becomes increasingly scarce, urban development may be forced to exploit land occur adjacent to airports. Such encroaching development may result in conflicts between new development and the goals and policies outlined in local Airport Land Use Plans.

QQ-20 The following text amendment will be made to Section 1.5.2, page 1-22, Table 1.A:

4.5 Air Quality
Less than Significant Impacts
Consistency with Air Quality Management Plan The proposed General Plan is consistent with SCAG's Regional Growth Management Plan and SCAQMD's Air Quality Management Plan, and the vehicle miles traveled growth rate under the proposed General Plan is consistent with SCAG's projected population growth. In addition, with the planning and implementation of the proposed General Plan Circulation Element, it is anticipated that the proposed General Plan will be consistent with SCAG's Regional Mobility Plan, locally adopted Congestion Management Plan, as well as the Coachella Valley PM10 Plan. Policies: AQ 1.1-1.11
No mitigation required.
Less than significant.


QQ-21 The following text amendment will be made to Section 1.5.2, page 1-29, Table 1.A:

Impact 4.6.4 Implementation of the proposed General Plan would cause habitat fragmentation resulting in isolation of sensitive habitat patches creating a "checkerboard" pattern of small habitat patches of limited biological value. Policies: OS 5.1--5.7, OS 6.1-6.2, OS 8.1, OS 9.3-9.4, OS 17.1-17.3,OS 18.1-18.2

Implement Mitigation Measure 4.6.1C, above, along with the following mitigation measures.

4.6.4A Comply with Riverside County Planning Department Biological Report Guidelines to include an analysis of the potential for a proposed project to result in habitat fragmentation leading to the isolation of sensitive habitat patches.

   Under the Planning Department Guidelines, biological reports must be conducted as follows:

   a. Reports must be prepared by a biologist on the County's list of qualified consultants.

   b. The County Planning Department must be notified in advance that a report will be prepared for a specific project.

   c. The report must include a signed certification attesting to the report contents.

   d. The report must include specific information as to the type of survey (e.g., General Biological Resources Assessment, Habitat Assessment, etc.), site location, property owner, principal investigator, and contact information for participants in the field surveys.

   e. The report must include specified attachments (summary sheet, level of significance checklist, biological resources/project footprint map, and site photos).

   f. The report must include information on literature sources (e.g., California Natural Diversity Data Base, California Department of Fish and Game, U.S. Fish and Wildlife Service, and environmental documents for nearby projects).

   g. The report must include a description of surveys, including timing, personnel, and weather conditions.

   h. The report must include a description of site conditions including plant and wildlife habitat, disturbances, and sensitive elements.

   i. The report must include an assessment of anticipated project impacts and a discussion of mitigation.

   j. The report must include a list of all species observed or detected and a recommendation for any additional focused surveys that may be necessary.

The above list is a summary of the County's guidelines, the actual guidelines available from the Planning Department shall be used in determining requirements for, and adequacy of, biological reports.
Significant and unavoidable.


QQ-22 The following text amendment will be made to Section 1.5.2, page 1-50, Table 1.A:

4.11 Hazardous Materials
Less than Significant Impacts
Historical Use of Hazardous Materials and Waste Implementation of the proposed General Plan would not result in impacts associated with known and/or suspected hazardous materials. However, there is a potential that previously unknown hazardous materials contamination from historical use of a property may be encountered during future development activities. Should such contamination be found or disturbance occur, existing federal, state, and local policies and procedures would require action by the designated local enforcement agency. It is unlikely that any such contamination or disturbance would be extensive beyond the capacities of typical remediation measures. Therefore, no significant impacts from former uses of properties within Riverside County are anticipated as a result of implementation of the proposed General Plan.

Generation of Hazardous Waste Implementation of the proposed General Plan would introduce new land uses to the unin-corporated areas of Riverside County that may result in the use of hazardous materials and the potential generation of hazardous waste. However, compliance with regulations, standards,
Policies: S 6.1 S 7.1-7.3

No mitigation required.

Less than significant.
Less than significant.

QQ-23 The Commentor requests that the correct number of comment letters in Section 1.3 in the second paragraph of page 1-6 be listed in Section 1.0. The text has been amended as follows:

The objective of distributing a NOP is to solicit public comment in order to identify and determine the full range and scope of issues of concern so that these issues might be fully examined in the EIR. Twenty-one Forty-seven comments responsesding to the NOP and IS were received and are summarized below.

QQ-24 The following text amendment will be made to Section 2.1, page 2-1, second paragraph:

The objective of the Program EIR is to inform County of Riverside decision-makers, representatives of other affected/responsible agencies, the public, and other interested parties of the potential environmental effects that may be associated with the proposed General Plan. This Program EIR describes potential impacts relating to a wide variety of environmental issues and methods in which these impacts can be mitigated or avoided. It further analyzes the level of impact remaining after mitigation. Some impacts cannot be mitigated to below a level of significance.

QQ-25 The following text amendment will be made to Section 2.1.2, page 2-2, first paragraph under Program Environmental Impact Report:

This EIR is a "Program EIR," which evaluates the broad-scale impacts of the proposed General Plan. Program EIRs are typically prepared for an agency plan program, or series of actions that can be characterized as one large project, such as a general plan. Tiering refers to the concept of a multilevel approach to preparing environmental documents (CEQA Guidelines, Section 15152). 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 that each of the thousands of individual development projects that will follow and implement the General Plan may have. 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.

QQ-26 The following text amendment will be made to Section 2.1.2, page 2-2, first paragraph after bulleted list:

In this case, the Program EIR will address the General Plan, which is the proposed project. This EIR considers anticipates a series of actions needed to achieve the implementation of the proposed General Plan. Further actions or procedures required to allow implementation of the proposed General Plan include the processing of zoning plans, specific plans, tentative tract maps, site design plans, building permits, and grading permits.

QQ-27 The Commentor requests that a listing of "Responsible" and "Trustee" agencies, list of permits and other approvals, and list of environmental review and consultation requirements be included in the EIR. In this instance, the sole agency responsible for approving the General Plan EIR is the County of Riverside. The General Plan will be adopted by the County, and the Housing Element will be subject to review by the California Department of Housing and Community Development (HCD). Development that occurs as a result of implementation of the General Plan would involve additional environmental review; responsible and trustee agencies involved in implementing the General Plan policies will likely include most of the local and State agencies (with the likely exception of the California Coastal Commission). Such a listing is not applicable to the program-level General Plan EIR.

QQ-28 The following text amendment will be made to Section 3.1, page 3-8, paragraph two:

Although they are clearly related projects, and are each part of an integrated planning program, as described above, each RCIP component covers a different physical area, is being prepared pursuant to different State and federal laws, involves different agencies in their approval, and has different lead agencies for their environmental documentation. In addition, each RCIP component is on a slightly different schedule. As a result of these differences, preparation of a single environmental document was found to be impractical. Such a document would prove to be overly complex and impossible difficult to understand. Instead, each environmental document prepared from components of the RCIP program contains a cumulative impact analysis, summarizing the overall impacts of RCIP.

QQ-29 The Commentor states that the analysis of growth-inducing effects should cover areas outside the County, such as adjacent counties and cities. However, effects pertaining to other jurisdictions are discussed under the Cumulative Impacts heading in Section 5.4 of the Draft EIR.

QQ-30 The Commentor suggests the inclusion of an "Effects not found to be significant" discussion in Section 5.0. Effects not found to be significant are listed in Table 1A in Section 1 of the Riverside County General Plan Draft EIR. The State CEQA Guidelines states in Section 15128 that "An EIR shall contain a statement briefly indicating the reasons that various possible significant effects of a project were determined not to be significant and were therefore not discussed in detail in the EIR. Such a statement may be contained in an attached copy of an Initial Study." The Initial Study for the Riverside County General Plan Draft EIR is included in Attachment A of that document.

QQ-31 The Commentor requests that the EIR include a list of documents incorporated by reference in Section 9.0. The documents incorporated by reference are listed in Section 2.2.1 of the Riverside County General Plan Draft EIR.
















































































































Response to Letter RR: Jackson, DeMarco, Peckenpaugh, representingDomenigoni Family

RR-1 The plans referred to by the Commentor were not approved during the preparation of the prior Land Use Map. The Land Use map will be revised to reflect any additional adopted plans.

When a large study is contemplated on something that is perpetually changing, a certain limit has to be set. That is to say, 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 adopted developments that came after the publication of this report may be reflected in the General Plan map at a future date. This can be accomplished with a Technical Amendment, which involves changes in the General Plan of a technical nature, including technical corrections discovered in the process of implementing the General Plan. Technical amendments may include the following:

• Corrections to statistics.

• Changes in spheres of influence and city boundaries.

• Appendix information useful in interpreting the General Plan but which does not change the General Plan's intent.

• Mapping error corrections.

• Editorial clarifications that do not change the intent of the General Plan.

• Changes in Unincorporated Communities or Communities of Interest.

CEQA does not require agencies to freeze General Plan policies. Public review of the proposed General Plan is anticipated to result in changes to the text of the General Plan Policies. All changes will be subject to public review during the zoning changes and land use change procedures. The Draft EIR contains a full and complete description of the General Plan in Section 3.0. The County anticipates some level of change, and will provide ample opportunity for public review.

RR-2 The incorporated comments refer to a version of the General Plan that has been superceded and substantially revised, and are not specifically in relation to the Draft EIR. No substantive issues are raised regarding the adequacy of the EIR.

RR-3 Refer to response RR-1.

RR-4 The project description is correct as it stands.

RR-5 While the General Plan is a component of the Riverside County Integrated Project work effort, it must also be a stand-alone document. The General Plan has "independent utility," meaning that the adoption of any one component of the RCIP effort is not dependent on the adoption of the others. This allows, that in the event either the CETAP or MSHCP documents are not approved, the County would still possess an up-to-date legally adequate General Plan, as required by State law. Government Code 65300 states that "... the general plan and elements and parts thereof comprise an integrated, internally consistent, and compatible statement of policies for the adopting agency." The various elements presented in the General Plan meet this requirement.

While the objective of the RCIP effort is to fully integrate the component plans, it does not necessarily follow that the various documents will be prepared, reviewed, or approved simultaneously. Copies of the various documents have been made available for public review at offices of the County Planning Department and public libraries. The noticing of public scoping meetings and the public review of the documents has followed State and federally mandated guidelines. Since the inception of the integrated planning process, the County of Riverside has provided on-line access to the documents prepared during the Riverside County Integrated Project work effort. The RCIP website at www.rcip.org provides a calendar of public meetings, a library of RCIP material, press releases, contact information, RCIP team members, and the means to contact the County with comments and concerns about the RCIP process. For those with the desire, sufficient opportunity has been provided to provide input to and comment on the various RCIP documents.

RR-6 In response to another comment letter, text amendments in Section 3.1, page 3-7 (fourth paragraph), have been made in Section 1.0 of the EIR to more clearly state the independence of the three RCIP components. The amended text follows:

Relationships and Differences Between RCIP Components

The 2002 Riverside County General Plan recognizes the Western Riverside County MSHCP, and incorporates the MSHCP into its Area Plans as mitigation for the biological impacts that will result from development permitted by the proposed General Plan. The proposed General Plan also incorporates by reference the Coachella Valley MSHCP being prepared by the Coachella Valley Association of Governments parallel to, but separate from, RCIP. The proposed General Plan Circulation Element includes proposed CETAP corridors as part of its proposed roadway and highway system.

The MSHCP provides comprehensive mitigation for the development impacts that will result from development of the proposed General Plan land uses and transportation facilities (including CETAP corridors) within the western portion of the County, including development of proposed CETAP corridors. The MSHCP also includes CETAP corridors as permitted activities where they cross MSHCP preserve areas.

The RCIP consists of three coordinated plans, the 2002 Riverside County General Plan (which is the subject of this Program EIR), the Western Riverside County MSHCP, and the CETAP. Although coordinated, these three plans are independent components of RCIP. As an independent plan, the 2002 Riverside County General Plan is not reliant upon the approval of either MSHCP or CETAP. The proposed General Plan is, however, coordinated with the MSHCP and the CETAP, so that no substantive conflicts or inconsistencies exist between the three plans. The General Plan is consistent with the draft MSHCP in that some of the draft MSHCP policies for biological resource preservation and mitigation are incorporated into the proposed General Plan's Area Plans. The biological resource policies incorporated into the Area Plans provide partial mitigation for development impacts that would result from development proposed by the General Plan's identified land uses, infrastructure, and transportation facilities. The proposed General Plan also is consistent with the draft CETAP in that the proposed General Plan Circulation Element recognizes the potential for proposed CETAP corridors as part of its proposed roadway and highway system.

Furthermore, as stated in paragraph 4 on pages 5-10 in Section 5.4 (Cumulative Analysis) of the Draft EIR:

The cumulative discussion in this EIR analyzes the cumulative effects of the entire RCIP, to include the proposed General Plan, the proposed Western Riverside County MSHCP and the proposed CETAP. Even though the MSHCP and the CETAP are undergoing separate environmental documentation, they are being considered as foreseeable future projects as a part of the actions of the County. In addition, the cumulative analysis considers the build out of not only the proposed General Plan but the build out of all incorporated cities within the County.

Thus, the Commentor's statement that the cumulative impacts discussion deflects analysis of all RCIP components is incorrect. The reasons for preparing separate environmental documentation for each of the three RCIP components, aside from their independent utility, is presented in Sections 1.1 and 3.1 in the Draft EIR.

RR-7 The Commentor expresses concern over the apparent lack of inclusion of an approved Specific Plan in the proposed General Plan Area Plans. Refer to response RR-1.

RR-8 The Commentor objects to certain policies in the proposed General Plan. The County has the discretion to determine which resources will be protected. This comment, along with all other comments, will be taken into consideration by the decision-making body in its deliberations on the General Plan.

RR-9 The Commentor states that the proposed General Plan and Draft EIR would require a land owner to set aside and conserve land in excess of existing requirements without assurance of compensation. Development that has been approved by the County is still approved regardless of whether a proposed General Plan is adopted. New development, however, is always subject to a General Plan as it is to a Zoning Code.

RR-10 The Commentor states that the proposed General Plan would result in a disproportionate exaction of land to the Domenigonis, and an unconstitutional taking of private property. The comment is unclear because the approved specific plan would not be affected. If future permits are required, they will be subject to normal review under the General Plan and zoning ordinance.

RR-11 The Commentor is convinced that, by not designating the property in question as agricultural, continued use and expansion of existing agricultural lands would be subject to discretionary project approvals and non-conforming use restrictions. The comment is noted. Refer to responses OO-15 and OO-17.

RR-12 Refer to Responses KK-16 and OO-32. State CEQA Guidelines, Section 15131 states, "...Economic or social effects of a project shall not be treated as significant effect on the environment." The Guidelines further state that an EIR may trace the "chain of cause and effect' from a proposed action through anticipated economic/social changes to determine the significance of a physical change in the environment. The focus of such an analysis, "... shall be on the physical changes." A separate economic impact analysis is not required. Because, the Draft EIR already includes a thorough analysis of a wide variety of potential physical impacts that may result from implementation of the General Plan, identifying economic or social changes that may in turn cause physical changes is not necessary.

RR-13 This comment does not raise any substantive environmental issues regarding the adequacy of the Draft EIR. This comment, along with all other comments, will be taken into consideration by the decision-making body in its deliberations on the General Plan. The referenced Circulation Policies are necessary to reduce the impacts of traffic on County roadways.

RR-14 Refer to response RR-1.

RR-15 The Commentor is summarizing opinions and position on the proposed General Plan and the EIR. The comment is noted. Refer to preceding responses.
















































Response to Letter SS: Jackson, DeMarco, Peckenpaugh, representing Murdock

SS-1 Comment noted.

SS-2 An agency, such as Riverside County, is not permitted to "segment" or "piecemeal" a project into small parts if the effect is to avoid full disclosure of environmental impacts. This rule arises from the definition of "project" pursuant to CEQA, which includes the phrase "whole of the action." This phrase has been interpreted by the California Supreme Court to mean it is generally inappropriate to chop a project into small segments to avoid preparing an EIR (Bozung v. Local Agency Formation Commission [1975] 13 Cal.3d 263.). Therefore, an agency may not treat each separate permit or approval as a separate project for the purpose of evaluating environmental impacts. Riverside County has not avoided presenting an EIR to the public with respect to analysis of the General Plan; therefore, Riverside County has not engaged in "piecemealing."

The Commentor has a different definition of "piecemealing," stating that it is deferment of environmental analyses to other RCIP components (CETAP and Western Riverside County MSHCP). On the contrary, the CETAP EIR/EIS, which involves the analysis of transportation corridors, has been incorporated into analysis of the transportation impacts of the General Plan Circulation Element. According to State CEQA Guidelines Section 15150, an EIR may incorporate all of a publicly available document or portions of it prepared for other projects. As required, the General Plan EIR described the CETAP EIR/EIS briefly, summarized its relationship to the EIR, and stated where the document is available for public inspection.

The Western Riverside County MSHCP EIR/EIS was sent to the public after the General Plan EIR. It could not be incorporated by reference into the General Plan EIR, as it was not available to the public at that time.

The contention that the General Plan EIR is "piecemealing" its environmental analysis by deferring mitigation measures is unfounded. Riverside County has used its best efforts to predict impacts but cannot predict the unforeseeable. That is, Riverside County cannot determine the precise timing of future projects. Deferment of these mitigation measures at the time of a future project is essential to avoid, minimize, rectify, reduce over time, and/or compensate for impacts of implementation of the General Plan.

The Draft EIR contains a full and complete analysis of biological and transportation impacts. These issues are also addressed by the Western County MSHCP and CETAP in separate environmental documents. The EIR for the proposed General Plan is sufficient as it stands, independent of whether the Western Riverside County MSHCP or CETAP are approved.

SS-3 The Commentor suggests that the General Plan EIR inadequately describes the project and its impacts, specifically regarding Murdock's properties. The General Plan EIR analysis covers the impacts of the General Plan as put forth in that document. It includes facts, fact-related reasonable assumptions, and expert opinion. It does not include arguments, speculation, unsubstantiated opinion or narrative, clearly inaccurate or erroneous evidence, or socioeconomic impacts that are not related to the physical environment.

SS-4 The Commentor is not specific as to which project-specific and cumulative impacts he is referring. There can be no response to such a broad comment except to say that impact analysis is contained in Section 4.0, and cumulative impacts analysis can be found in Section 5.0 for the proposed General Plan.

SS-5 The Commentor submits that mitigation measures are delayed, unspecified, and/or speculative and do not mitigate project impacts. The Comment is not specific as to which mitigation measures are being referred to, and provides no evidence to support the position. Mitigation measures, in most cases, are to be applied to future projects that occur within the boundaries of the General Plan. Riverside County cannot determine the precise timing of future projects and, thus, must delay the implementation of most mitigation measures at the time of a project. The mitigation measures are as specific as possible. Riverside County has avoided speculating on the time and size of future projects and has used its best efforts to predict impacts but cannot predict the unforeseeable.

SS-6 The Commentor suggests that the General Plan EIR comment period be extended to coincide with the comment periods of the other RCIP components (CETAP and Western Riverside County MSHCP). According to State CEQA Guidelines Section 15105 (a) the public review period for a draft EIR shall not be less than 30 days nor should it be longer than 60 days except under unusual circumstances. In an effort to balance the ability of the public to respond against the interests of development applicants, Riverside County in moving expeditiously to reach an ultimate decision on the General Plan, Riverside County determined that a 45-day period was a good compromise. There does not appear to be a preponderant reason to defer the comment period to coincide with the comment periods of the other RCIP components. The components of the RCIP (the General Plan, CETAP, and the Western Riverside County MSHCP) incorporate each other's documents by reference as each document becomes available. Thus, each analysis takes into account the analysis prepared for the other components.

SS-7 Commentor provides a description of Murdock's properties, their location, and the status of their entitlement processes. Comment noted.

SS-8 Refer to response SS-2. The Commentor suggests that there should be the preparation of one EIR to analyze all components within the RCIP at the same time. This is not practicable, as the federal permits and/or funding for the Western Riverside County MSHCP and CETAP preclude the preparation of a stand-alone EIR. Secondly, each component of the RCIP is a discrete and separate element with different physical boundaries, the application of varied State and federal laws, and dissimilar approval and lead agencies.

Each component has been treated as a separate entity to ensure that each has the chance to go forward. In other words, if one component of the RCIP were not adopted, the other component(s) would not be prevented from being adopted. The following list illustrates the adoption combination possibilities.

Possibilities of Adoption/Certification of Various Riverside County Environmental Documents
Adoption Combination Possibilities General Plan EIR Multiple Species
Habitat Conservation
Plan (MSHCP)
EIR/EIS
Community Environmental
and Transportation
Acceptability
Program (CETAP)
EIR/EIS
All
General Plan EIR and MSHCP EIR/EIS  
General Plan EIR and CETAP EIR/EIS  
General Plan EIR Only    
MSHCP EIR/EIS Only    
MSHCP and CETAP EIRs/EISs  
CETAP EIR/EIS Only    


SS-9 Refer to response SS-2 with regard to "piecemealing."

SS-10 The potential bi-County corridor will be the subject of future EIR/EISs and is not being considered for approval at this time.

SS-11 Comment noted. Refer to responses SS-2 and SS-6.

SS-12 Comment is unclear. Response is difficult as comment is unspecific. Refer to response SS-13.

SS-13 The Draft EIR provides an explanation of an appropriate level of analysis. The Draft EIR for the General Plan is a Program EIR, not a site-specific analysis.

SS-14 Refer to response SS-2 with regard to "piecemealing." The proposed General Plan stands on its own without the Western Riverside County MSHCP and CETAP. The proposed General Plan is a comprehensive policy document that covers the entire County.

SS-15 The Commentor is stating that the project description in the Draft EIR is inaccurate, but does not explain why or what is inaccurate about the project description. The County is of the opinion that the project description adequately represents the proposed General Plan.

SS-16 The County's General Plan has jurisdiction over land in the unincorporated areas of the County. The Western Riverside County MSHCP, when approved, will have jurisdiction over lands within unincorporated Riverside County and 14 incorporated cities within the County. Each one of the 14 cities will implement the MSHCP through its General Plan and zoning codes. The County only has jurisdiction over those lands within the unincorporated areas; therefore, any open space policies within its General Plan only relate to unincorporated lands and not properties within incorporated cities.

SS-17 The Draft EIR analyzes the impacts of implementing the County's General Plan. Regardless of whether the MSHCP is approved, the General Plan could be approved. Furthermore, the Draft EIR contains mitigation for the implementation of the General Plan on biological resources without implementation of the MSHCP.

SS-18 Refer to responses SS-16 and SS-17.

SS-19 The Draft EIR does not provide right-of-way widths for General Plan roadways. The roadway right-of-way widths are shown in the Area Plans, which are a part of the proposed General Plan Volumes I and II.

SS-20 Refer to the response SS-21.

SS-21 The differences between the City of Corona adopted El Cerrito Specific Plan and the proposed Riverside County General Plan are noted. The Commentor submits that the rights-of-way for those roads in close proximity to Murdock's properties are inconsistent with the rights-of-way already adopted by the Cities of Lake Elsinore and Corona. The Commentor feels that there would be a forced expansion of the rights-of-way widths without considering the implications of such an action. Further, the Commentor indicates that there was a lack of analysis concerning the County rights-of way widths.

At the outset, a transportation analysis was undertaken to identify existing traffic conditions within Riverside County. The results of that analysis indicated that the majority of the roadway and highway system of Riverside County operated at Level of Service (LOS) C or better (A or B), meaning that motorists on most roadways did not experience substantial delays, even during peak travel hours. Most of the local, interstate, and State route facilities operating at less than LOS C were located in the western portion of Riverside County. In addition, most of the segments operating at below LOS C occurred on the freeway system and other major arterials. Some 27 of the segments were operating at LOS D, 17 were operating at LOS E, and 59 were operating at LOS F.

As presented in the Riverside County General Plan, Chapter 4: Circulation Element, Riverside County Circulation Plan, Figure C-1, the proposed General Plan Circulation Element presents a comprehensive roadway system for Riverside County, aimed at ensuring adequate roadway rights-of-way within its unincorporated territory. The General Plan EIR addressed segment-level operations and LOS thresholds to determine whether operational deficiencies would exist on the roadway system at build out. In addition, it contained analysis of the overall adequacy of the proposed roadway and highway system contained in the Circulation Element.

Future traffic conditions at the theoretical build out of Riverside County, including a cumulative analysis of build out of the Cities within the County, were modeled. A detailed discussion of these models, including the proposed General Plan build out circulation system and proposed Circulation Element (maps), is provided in the document titled Summary of the Transportation Analysis for the Circulation Element of the Proposed Riverside County General Plan provided in Appendix C.

In addition, the proposed General Plan policies require that individual proponents of development projects analyze LOS at the individual intersection level to ensure that development projects do not create bottlenecks at the intersections of the roadway system whose roadway widths and rights-of-way were previously examined as part of the General Plan and its environmental analysis.

Furthermore, the Commentor answers his concerns about rights-of-way changes when he rightly points out that Riverside County Circulation Policy 7.6 requires that "[t]ransition areas at meeting points of roadways designed to differing city and County standards or differing functional classifications should be individually designed to facilitate satisfactory operational and safety performance."

SS-22 The Commentor is correct in stating that the General Plan should not include land use designations for properties that are located within incorporated Cities of Riverside County.

SS-23 Refer to response RR-1.

SS-24 The Commentor requests that the Murdock Pacific Clay property be changed from a land use designation of "Mineral" to "Low-Density Residential" with a density of one to five dwelling units per acre. Landowners wishing to change designations may seek a General Plan amendment at a future date.

SS-25 Refer to response to SS-23. All adopted development plans will be reflected in an updated General Plan land use map.

SS-26 The County concurs with the Commentor's interpretation of CEQA and believes the EIR addresses the direct, indirect, short-term, long-term, and cumulative environmental impacts of the proposed General Plan.

SS-27 All unincorporated properties within Riverside County are under the jurisdiction of the County and are subject to the policies within the County's General Plan. CEQA requires an EIR to evaluate the consistency of the project with applicable general plans. The applicable general plan for unincorporated properties within Riverside County is the proposed General Plan. A conflict between a city-approved Specific or Area plan within a city's sphere of influence and the County's General Plan is not considered to be a land-use inconsistency under CEQA (Section 15125(d)), as the County has jurisdiction over the area.

SS-28 Refer to response SS-24.

SS-29 The proposed General Plan has balanced the County's need for housing and commercial development with agriculture and open space needs by designating land uses throughout the unincorporated areas of the County. The intent of the Administrative Policy of not allowing amendments to the General Plan foundation components for five years was to ensure stability of the General Plan. The Commentor is concerned that the Pacific Clay property is proposed to be designated as Mineral Resources and not Community Development as requested. This General Plan comment does not raise any substantive environmental issues regarding the adequacy of the Draft EIR. The land use designation change, however, will be taken into consideration by the decision-makers in their deliberations on the General Plan land use.

SS-30 The Commentor is speculating that not allowing General Plan amendments of foundation components for five years will result in land use intensification in other areas of the County and within the cities. The Commentor has provided no evidence that this will occur. Any development will be subject to General Plan policies and mitigation measures to address environmental issues.

SS-31 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.

SS-32 The Commentor is speculating that, by allowing the designation of Murdock's Pacific Clay property to be Low Density Residential, the speculative impacts of land use intensification in other parts of the County would be alleviated. The opinion of the Commentor will be taken into consideration by the decision-making body in its deliberations on the General Plan policies.

SS-33 As stated in Section 4.6.1 of the Draft EIR, "A detailed examination of Riverside County biological resources is included in Section 4-2 of the Riverside County Existing Setting Report (incorporated by reference) ..." A review of the Existing Setting Report will show that a total of 205 species include the 142 contemplated for inclusion in the MSHCP. As is further stated in Section 4.6.1 of the Draft EIR, "This section focuses on those communities and species that, because of their legal status, rarity, or vulnerability, are of greatest concern to state and federal agencies and consequently to land use planners." As is described in the Draft EIR under 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. Should such surveys determine that a project may significantly impact species included in the Existing Setting Report, then appropriate mitigation measures shall be identified at that time.

SS-34 The Draft EIR does not rely on the adoption of the MSHCP. The Draft EIR identifies policies and mitigation measures to be applied whether the MSHCP is adopted or not. 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 to below a level of significance (with the exception of to oak tree impacts, which will be reduced to below a level of significance).

SS-35 As the Commentor notes, the Draft EIR does acknowledge that a large-scale MSHCP is in process for the western Riverside County area. The Draft EIR provides policies that allow for integrating the MSHCP with the General Plan when, and if, an MSHCP is adopted. Further, there are other HCPs in place (e.g., Stephens' Kangaroo Rat HCP, Coachella Valley Fringe-toed Lizard HCP, the Metropolitan Water District's MSHCP for about 20,000 acres in southwestern Riverside County, and various smaller project-specific HCPs). The General Plan policies and mitigation measures identified in the Draft EIR are intended to ensure that applicable provisions of existing HCPs will be considered and met in environmental analyses of future projects. Staff has recommended that any policies or other txt in the proposed General Plan that imply reliance on the Western Riverside County MSHCP be changed to reflect the independence of these plans.

SS-36 The comment is best directed as a comment to the Western Riverside County MSHCP, not the General Plan EIR. This comment does not raise any substantive environmental issues regarding the adequacy of the Draft EIR. Compliance with adopted HCPs is considered adequate mitigation for impacts to addressed species.

SS-37 Refer to response SS-36.

SS-38 Refer to response SS-2. The General Plan only adopts HCPs and MSHCPs as they are formally adopted and approved, following their appropriate environmental review and certification.

SS-39 Refer to response SS-36. The Western Riverside County MSHCP has not yet been approved. Site specific information will be needed, and mitigation will be determined by the General Plan policies and mitigation measures. If the Western Riverside County MSHCP is not approved, projects will be subject to existing regulations such as FESA and CESA. If the Western Riverside County MSHCP is approved, the General Plan mandates compliance with its provisions.

SS-40 Refer to response SS-36.

SS-41 Refer to response SS-36.

SS-42 Refer to response SS-36.

SS-43 Insofar as the Commentor alleges illegal piecemealing of the project, refer response SS-2. The Commentor is concerned that the maps in the biological resources section are not provided in sufficient detail to determine sensitive biological resources (such as endangered species and vegetation communities) on specific properties. The information provided in the EIR is of appropriate detail for a Program EIR. Information concerning the presence or absence of sensitive vegetation communities or special-status species is more appropriately determined by biological surveys conducted on the site, and through consultation with CDFG and USFWS. Detailed information about the presence or absence of sensitive biological resources on specific parcels is not available except where focused surveys have been conducted, as the composition of vegetation communities and the distribution of species is subject to change over time. Refer to responses SS-36 and SS-39.

SS-44 Refer to response SS-21. Whether the improvements needed to implement the General Plan Circulation Element map will result in relocation of "houses, buildings, and commercial uses along County roads" is speculative, as is determining the extent to which relocation of existing uses along County roads might be needed and the specific locations at which relocation would occur. If any relocation of existing development is needed to accommodate improvements to County roadways, the relocated development will be required to comply with the land use, density, and development requirements of the area to which it locates. Thus, there will be no intensification of uses beyond that which is permitted by the proposed General Plan, and is therefore analyzed in the General Plan EIR.

SS-45 Whether the improvements needed to implement the General Plan Circulation Element map will result in relocation of "houses, buildings, and commercial uses along County roads" is speculative, as is determining the extent to which relocation of existing uses along County roads might be needed and the specific locations at which relocation would occur. If any relocation of existing development is needed to accommodate improvements to County roadways, the relocated development will be required to comply with the land use, density, and development requirements of the area to which it locates. Thus, there will be no intensification of uses beyond that which is permitted by the proposed General Plan, and is therefore analyzed in the General Plan EIR.

SS-46 This comment is a summary of preceding remarks made in Comment Letter SS. Riverside County disagrees that any additional analysis is required as the result of the issues set forth in Comment Letter SS beyond responding to the comments set forth in that letter. These responses are contained in Responses SS-1 through SS-50.

SS-47 State CEQA Guidelines Section 15168 allows the preparation of a Program EIR for a General Plan. The Guidelines encourages the use of a Program EIR citing five advantages:

1. Provision for a more exhaustive consideration of impacts and alternatives than would be practical in an individual EIR;

2. Focus on cumulative impacts that might be overlooked in a case-by-case analysis;

3. Avoidance of continual reconsideration of recurring policy issues;

4. Consideration of broad policy alternatives and programmatic mitigation measures at an early stage when the agency has greater flexibility to deal with them; and

5. Reduction of paperwork by encouraging the reuse of data through tiering.

Although the legally required contents are the same in a Program EIR as a project-specific EIR, in practice there are considerable differences in the level of detail. Program EIRs are typically more conceptual in nature. The Courts have indicated that a Program EIR may contain a more general discussion of impacts, alternatives, and mitigation measures. Following this approach, when individual projects are implemented according to the General Plan, the Lead Agency (County of Riverside) is required to determine whether the effects of the individual activities were covered in the Program EIR. If not, additional environmental documentation would occur.

As stated in response SS-2, the County cannot determine the precise timing of future projects. The General Plan is anticipated to have a 40-year build out. Deferment of mitigation measures at the time of a future project is essential to avoid, minimize, rectify, reduce over time, and/or compensate for impacts of the implementation of the General Plan.

SS-48 Refer to response SS-2. Mitigation for the environmental impacts of the Western Riverside County MSHCP and CETAP are provided in the EIR/EISs prepared for those projects.

SS-49 The County does not concur that the Draft EIR for the General Plan is inadequate and that one EIR/EIS should be prepared for the General Plan, MSHCP, and CETAP. As explained in response SS-2, the General Plan is not subject to NEPA because no federal action is being taken. Therefore, it would be inappropriate to prepare an EIS for the General Plan in addition to the EIR.

SS-50 Refer to responses SS-2 and SS-6.






Letter TT: Albert A. Webb Associates

TT-1 The following sentences will be added to the beginning of Paragraph 1 on page 4.13-1 of the Draft EIR:

All sensitive uses along freeways and highways that are or will be exposed to noise levels in excess of applicable noise standards require the consideration of mitigation measures such as sound walls or building facade upgrades. However, State highways, including freeways, under the jurisdiction of Caltrans must consider noise abatement measures when roadways are to be undergoing major changes or improvements that will result in new or continued exposure to traffic noise levels approach or exceed the noise abatement criteria (NAC).

TT-2 Paragraph 8 on page 4.13-5 of the Draft EIR has been amended to read as follows:

Recreational lands and wildlife habitat are also significantly impacted by noise. Recreational uses include those that are quiet in nature and those that are noisy by nature. Quiet in nature recreational uses include trails and picnic areas. Noisy in nature recreational uses include sports park and off-road vehicle recreational areas. However, uncontrolled use of off-road vehicles in parks and open space lands degrades recreational opportunities for the County's residents. Noise intrusion into wildlife habitat drives off wildlife and with prolonged use may effectively reduce the amount of land used as habitat by various species.

TT-3 Ground-borne noise is vibration transmitted through rock or other ground media, similar to noise transmitted via the atmosphere. Ground-borne vibration is usually measured in terms of vibration velocity, either the root-mean-square (rms) velocity or peak particle velocity (PPV). Rms is best for characterizing human response to building vibration and PPV is used to characterize potential for damage. Decibel notation acts to compress the range of numbers required to describe vibration. Vibration velocity level in decibels is defined as: Lv = 20 log10 [V/Vref], where Lv is the velocity in decibels (VdB), "V" is the rms velocity amplitude, and "Vref" is the reference velocity amplitude, or 1x10-6 inches/second used in the USA. Table A illustrates human response to various vibration levels, as described in the Federal Transit Administration Transit Noise and Vibration Impact Assessment (FTA, April 1995). Table B lists the ground-borne noise and vibration criteria recommended by the FTA. A level higher than those shown in Table B is considered to be excessive.

Table A - Human Response to Different Levels of Ground-Borne Noise and Vibration
Vibration Velocity Level Noise Level Human Response
Low Freq1 Mid Freq2
65 VdB 25 dBA 40 dBA Approximate threshold of perception for many humans. Low-frequency sound usually inaudible, mid-frequency sound excessive for quiet sleeping areas.
75 VdB 35 dBA 50 dBA Approximate dividing line between barely perceptible and distinctly perceptible. Many people find transit vibration at this level unacceptable. Low-frequency noise acceptable for sleeping areas, mid-frequency noise annoying in most quiet occupied areas.
85 VdB 45 dBA 60 dBA Vibration acceptable only if there are an infrequent number of events per day. Low-frequency noise unacceptable for sleeping areas, mid-frequency noise unacceptable even for infrequent events with institutional land uses such as schools and churches.
1 Approximate noise level when vibration spectrum peak is near 30 Hz.
2 Approximate noise level when vibration spectrum peak is near 60 Hz. Source: Federal Transit Administration, 1995, and Federal Railroad Administration, 1998


Table B - Ground-Borne Vibration and Noise Impact Criteria
Land Use Category Ground-Borne Vibration Impact Levels
(VdB re 1 micro inch/sec)
Ground-Borne Noise Impact Levels
(dB re 20 micro Pascals)
Frequent1 Events Infrequent2 Events Frequent1 Events Infrequent2 Events
Category 1: Buildings where low ambient vibration is essential for interior operations. 65 VdB3 65 VdB3 4 4
Category 2: Residences and buildings where people normally sleep. 72 VdB 80 VdB 35 dBA 43 dBA
Category 3: Institutional land uses with primarily daytime use. 75 VdB 83 VdB 40 dBA 48 dBA
1 "Frequent Events" is defined as more than 70 events per day.
2 "Infrequent Events" is defined as fewer than 70 events per day.
3 This criterion limit is based on levels that are acceptable for most moderately sensitive equipment, such as optical microscopes. Vibration sensitive manufacturing or research will require detailed evaluation to define the acceptable vibration levels. Ensuring lower vibration levels in a building often requires special design of the HVAC systems and stiffened floors.
4 Vibration-sensitive equipment is not sensitive to ground-borne noise.
Source: Federal Transit Administration, 1995.


TT-4 Modeling of the traffic noise levels under existing conditions (Table 4.13-B) utilized various speeds, truck mix, and day/night mix for vehicular traffic along roadway links within the County. These data are included in the model printouts for the traffic noise modeling.

TT-5 The comment is incorrect. This paragraph states that "Each doubling of the sound sources with equal strength increases the noise level by 3 dBA." This is an energy sum of two equal decibels, not a "drop off/doubling rate" for construction equipment as indicated by the Commentor.

TT-6 In response to a similar comment, the following clarifications were made to Mitigation Measures 4.13.2A and 4.13.4A on pages 4.13-103 and 4.13-108, respectively.

4.13.2A All new residential developments within the County shall conform to a noise exposure standard of 65 dBA Ldn for outdoor noise in noise-sensitive outdoor activity areas and 45 dBA Ldn for indoor noise in bedrooms and living/family rooms. New development, which does not and cannot be made to conform to this standard, shall not be permitted.

4.13.4A All new residential developments within the County shall conform to a noise exposure standard of 65 dBA Ldn for outdoor noise in noise-sensitive outdoor activity areas and 45 dBA Ldn for indoor noise in bedrooms and living/family rooms. New development, which does not and cannot be made to conform to this standard, shall not be permitted.




















Response to Letter UU: Metropolitan Water District of Southern California

UU-1 This comment applies to the MSHCP, the CETAP, and General Plan designations and does not raise any substantive environmental issues regarding the adequacy of the General Plan Draft EIR. This comment will be taken into consideration by the decision-making body in its deliberations on the MSHCP, CETAP, and General Plan.

UU-2 The Commentor is assuming that the Draft EIR is describing ownership. This is not the case. Land use designations would not preclude the management and development of Metropolitan-owned lands.

UU-3 The Open Space designation may be appropriate where Metropolitan-controlled "reserve land" has been established to fulfill conservation commitments or reserve management requirements. Metropolitan "core properties" may be designated as Public Facilities. The County is in the process of meeting with Metropolitan to determine appropriate mapping and land use designations at Metropolitan facilities and/or Metropolitan-controlled land. Land use maps will be amended pending the outcome of consultations between the County and Metropolitan.

UU-4 In response to the Commentor's observation, the text on page 1-8 in Section 1.0 of the EIR has been amended as follows:

• Laura J Simonek, Metropolitan Water District of Southern California (MWDMetropolitan) (June 25, 2002) - This comment letter requested that Metropolitan projects within the Planning Area need to be considered in sufficient detail and evaluated to determine potential impacts. Furthermore, Metropolitan requests that all of its "core" properties (those facilities which are in existence or are proposed) be excluded from any conservation land use designation.

UU-5 Refer to response UU-3.

UU-6 Refer to response UU-3.

UU-7 Refer to response UU-3.

UU-8 The proposed MSHCP is a comprehensive, multiple jurisdictional planning program designed to create, manage, and monitor a system of habitat reserves in western Riverside County. The proposed MSHCP establishes a framework for complying with State and Federal endangered species regulations while accommodating future growth within western Riverside County. The criteria-based approach assumes conservation within the existing public/quasi-public lands, comprising approximately 347,000 acres, and development of criteria to assure additional conservation on private lands comprising approximately 153,000 acres. The proposed MSHCP does not utilize Metropolitan-owned reserve lands or mitigation banks to offset future impacts associated with proposed new development in the County.

UU-9 Refer to response UU-3.

UU-10 Refer to response UU-3.

UU-11 Refer to response UU-3.

UU-12 Refer to response UU-3.

UU-13 Refer to response UU-3.

UU-14 Refer to response UU-3.

UU-15 Refer to response UU-3.

UU-16 Refer to response UU-3.

UU-17 Table 3.B will be revised pending the outcome of consultations between the County and Metropolitan, on the designation of Metropolitan-controlled properties.

UU-18 These are the assumptions that were used in Sections 4.2 through 4.1.7 in the Draft EIR.

UU-19 The projections described in Section 4.1 are based on land use designations as described in Sections 4.2.3 and Table 4.2A in the Draft EIR.

UU-20 Refer to response U-7.

UU-21 The references to existing reserves that the Commentor is indicating need correction are correct within the Draft EIR. The Commentor seems to be confusing similarly named reserves managed by Metropolitan with different reserves that have similar names managed by the California Department of Fish and Game, Nature Conservancy, and Riverside County Habitat Conservation Agency. Therefore, no further respons is necessary.

UU-22 The Commentor is assuming that the Draft EIR is describing ownership. This is not the case. Lake Skinner Recreation Area is described as a County park referring to its location without regard to ownership. The proposed land use designation (Open Space – Recreation and Open Space – Habitat) is correct. These designations would not preclude the management and development of Metropolitan-owned lands.

UU-23 The Commentor states that water use for proposed changes in land use should be developed and compared to water use projections for existing land use designations, so that water agencies could use the information to quantify potential impacts. However, water suppliers are legally obligated to prepare water plans and determine whether supplies are available to meet projected demands. Development that would occur within the County according to land use designations would continue to be subject to Senate Bill 901 (see page 4.17-8 of the Draft EIR) and Senate Bill 610 (see page 4.17-9 of the Draft EIR). Analysis of future water demand and supply would be most meaningful when conducted on a shorter horizon as projects are proposed, as laws prohibit development when sufficient water is not available. In addition to legal regulations, the following mitigation measures from Section 4.17 of the Draft EIR address water use impacts:

Mitigation Measures

4.17.1A Proponents of new development within unincorporated areas of Riverside County that consist of: a residential development of more than 500 dwelling units; a shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space; a commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space; a hotel/motel development of more than 500 rooms; an industrial, manufacturing/processing plant, or industrial park employing more than 1,000 persons or occupying more than 650,000 square feet of floor space or 40 acres of land; a mixed-use development that includes any of the previously referenced projects; or a project with a water demand equivalent to that used by 500 residential units with projected water demand of more than 250 af per year shall be required to submit a water supply assessment report prior to approval of a project. The water supply assessment report shall include the following:

• Project description;

• Water resources environmental setting;

• Conservation and water recycling measures included in the project;

• The identification of existing water entitlements, water rights, or water service contracts relevant to the water supply identified for a proposed project, and the amount of water received pursuant to such entitlements, rights, or contracts;

• Project water demand;

• Water supply alternatives;

• Preferred water supply alternative;

• Impacts associated with use of the preferred water supply alternative;

• Evaluation of compliance with the applicable Urban Water Management Plan;

• Summary and conclusions; and

• Technical appendices and attachment of supporting documents.

Said water supply assessment report shall be submitted to the County and applicable water supply agencies for review. Development shall not be permitted unless an adequate supply of water, available for use and sufficient to supply a proposed project, in wet and drought years, has been identified. Where water supply adequate to supply a project in its entirety does not exist, development of only those portions of a project with an adequate and available water supply shall be permitted. Evidence of the availability of adequate water supply shall be submitted to the County for review and approval prior to the issuance of development permits.

4.17.1B For projects smaller than those stated in Mitigation Measure 4.17.1A, with an estimated annual water use of 250 af or less, the County shall require evidence that the project is in compliance with the Urban Water Management Plan for the area in which the development is located, prior to the issuance of development permits. Evidence of such compliance shall take the form of written verification by the water provider that the project is in compliance with said plan. As determined necessary by the County, preparation of a water supply plan (as required in Mitigation Measure 4.17.1A, above) shall be required for a project that is estimated to use less than 250 af per year, prior to the issuance of development permits.

4.17.1C Development within unincorporated areas of the County shall not use water of any source of quality suitable for potable domestic use for nonpotable uses, including cemeteries, golf courses, parks, highway landscaped areas, industrial and irrigation uses, or other non-domestic use if suitable recycled water is available as provided in Sections 13550-13566 of the State Water Code and/or Sections 65591-65600 and 65601-65607 of the State Public Resource Code. Prior to the issuance of any land use permit, the County shall determine to what extent and in which manner the use of recycled water is required for individual water projects. Future development shall be designed, constructed, and maintained accordance with the recycled water measures mandated by the County.

4.17.1D Riverside County shall enforce compliance with federal, State, and local standards for water conservation within residential, commercial, or industrial projects. Prior to approval of any development within the County, the applicant shall submit evidence to Riverside County that all applicable water conservation measures have been met.

UU-24 The EIR contains a discussion in Section 5.3 concerning the potential growth-inducing effects of the proposed General Plan. Changing land use designations within the County would not automatically result in growth. It would, however, accommodate growth, which would be regulated by market forces. Thus, the proposed General Plan has the potential to be growth-inducing, as it removes barriers to development, although by itself, it would not directly result in growth. Water use projections have been prepared (refer to response UU-20) for Riverside County at build out, but the projection is very rough in nature due to the absence of specific information concerning existing water use within water districts in the County. Because of the coarseness of the analysis and the lack of specific data and water demand generation factors, a comparison between calculated existing demand and calculated future demand would be highly speculative and unreliable. The County agrees that a comparison between existing and projected use would be useful, and encourages the water agencies within the County to cooperate and provide such an analysis based on the proposed General Plan land use.

UU-25 The Commentor is incorrect in stating that "Without the County's analysis of future water demand, water agencies will not be able to assess future water demand and plan accordingly." According to law, the water agencies are responsible for providing water plans regardless of County input. The County is providing adequate information in the proposed General Plan to allow water agencies to anticipate future demand, based on land use designations. Further, as water agencies have access to more detailed information about existing water use and water supplies, they are better qualified to assess future water demand.

UU-26 The Draft EIR contains steps that are being taken to ensure that development does not occur beyond what infrastructure can support. The mitigation measures listed in response to UU-23 above (4.17.1A, 4.17.1B, and 4.17.1C) contain stipulations and provisions to prevent the development of projects when water supply cannot be guaranteed. A useful quantitative analysis of future demand and supply is not feasible given the uncertainty of future water supply and the unpredictability of market forces that would result in development.

UU-27 State CEQA Guidelines Section 15126.2(d) describes "growth inducing" impacts to be those "ways in which the proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Included in this are projects which would remove obstacles to population growth (a major expansion of a waste water treatment plant might, for example, allow for more construction in service areas). Increases in population may tax existing community service facilities, require construction of new facilities that could cause significant environmental effects. Characteristics of some projects which may encourage and facilitate other activities that could significantly effect the environment, either individually or cumulatively. It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment."

Page 5-6 of the Draft EIR states the following:

A project could indirectly induce growth by removing barriers to growth, by creating a condition that attracts additional population or new economic activity, or by providing a catalyst for future unrelated growth in the area. While a project may have a potential to induce growth, it does not automatically result in growth. Growth can only happen through capital investment in new economic opportunities by the public or private sectors.

CEQA does not consider growth inducement to be necessarily detrimental, beneficial, or of significance to the environment. Typically, the growth inducing potential of a project is considered significant if it fosters growth or a concentration of population in excess of what is assumed in pertinent master plans, land use plans, or in projections made by regional planning agencies. Significant growth impacts could also be manifested through the provision of infrastructure or service capacity to accommodate growth beyond the levels currently permitted by local or regional plans and policies. In general, growth induced by a project is considered a significant impact if it directly or indirectly affects the ability of agencies to provide needed public services, or if it can be demonstrated that the potential growth significantly affects the environment in some other way.

The Commentor is correct in his statement that " Metropolitan's obligation is to provide water to its customers and any additional infrastructure needs, in response to increases in development that would occur as a result of implementation of the General Plan." The Commentor goes on to state that providing these infrastructure needs, in response to substantial increases in development that would occur through build out of the General Plan would accommodate and not induce or cause the growth projected by the County. The County concurs with the statement provided by Metropolitan and has amended Section 5.3, page 5-6 (paragraph 4), Growth Inducement, in the EIR as follows:

CEQA does not consider growth inducement to be necessarily detrimental, beneficial, or of significance to the environment. Typically, the growth inducing potential of a project is considered significant if it fosters growth or a concentration of population in excess of what is assumed in pertinent master plans, land use plans, or in projections made by regional planning agencies. Significant growth impacts could also be manifested through the provision of infrastructure or service capacity to accommodate growth beyond the levels currently permitted by local or regional plans and policies. Providing these infrastructure needs (e.g., water, wastewater , roadways) in response to substantial increases in development that would occur through build out of the General Plan, would accommodate, but not induce or cause, the growth projected by the General Plan. In general, growth induced by a project is considered a significant impact if it directly or indirectly affects the ability of agencies to provide needed public services, or if it can be demonstrated that the potential growth significantly affects the environment in some other way.

UU-28 This comment applies to the General Plan and does not raise any substantive environmental issues regarding the adequacy of the General Plan Draft EIR. This comment will be taken into consideration by the decision-making body in its deliberations on the General Plan.

UU-29 Comment noted.

SECTION 3.0 - ADDENDUM

This section of the EIR contains the text changes that have been made to the Draft EIR in response to comments received during the review period. 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. Added text is shown as double underline (i.e., double underline) and the deleted text is shown as strikeout (strikeout). The changes listed below are organized in sequential order as they would occur in the Draft EIR.

3.1 Text Amendments

Section 1.1, page 1-1, second paragraph

The challenge of balancing the housing, transportation, and economic needs of existing and future populations with limited natural resources and the sensitivity of the natural environment has led Riverside County to develop the Riverside County Integrated Project (RCIP). The RCIP, which consists of three coordinated plans, will determine future planning, transportation, and conservation needs for Riverside County. These three plans include the following:

• The 2002 Riverside County General Plan (Comprehensive General Plan Amendment No. GPA00618).

• The creation of a Multiple Species Habitat Conservation Plan (MSHCP) for the western portion of Riverside County, and the integration of an ongoing Coachella Valley Multi-Species Habitat Conservation Plan effort (which is not a part of RCIP but is a related program) into the fabric of comprehensive planning for the County.

• The identification of transportation corridors to meet the future transportation needs of Western Riverside County through the Community Environmental and Transportation Acceptability Program (CETAP).

Each of the plans has independent utility, and each can be approved without approval of the others. They will, however, be coordinated such that if all three are adopted, no conflicts between the plans will occur. This document focuses on the 2002 Riverside County General Plan, which is the proposed project.

Section 1.3, page 1-6, second paragraph

The objective of distributing a NOP is to solicit public comment in order to identify and determine the full range and scope of issues of concern so that these issues might be fully examined in the EIR. Twenty-one Forty-seven comments responsesding to the NOP and IS were received and are summarized below.

Section 1.3, page 1-8, fifth bullet

• Laura J Simonek, Metropolitan Water District of Southern California (MWDMetropolitan) (June 25, 2002) - This comment letter requested that MWD Metropolitan projects within the Planning Area need to be considered in sufficient detail and evaluated to determine potential impacts. Furthermore, Metropolitan requests that all of its "core" properties (those facilities which are in existence or are proposed) be excluded from any conservation land use designation.

Section 1.5.2, page 1-17, Table 1.A, under Land Use/Agriculture

Conflict with any Applicable Habitat Conservation Plan or Natural Community Conservation Plan Policies aimed at protecting biological resources will be are contained in the proposed General Plan. These policies will acknowledge existing habitat conservation plans within the County and ensure that land use plans be are consistent with the provisions of applicable conservation plans, including the Habitat Conservation Plan for the Stephen’s kangaroo rat. Because the proposed General Plan includes policies accommodating existing habitat conservation plans within the County, no significant impact associated with this issue will occur upon implementation of the proposed General Plan. No mitigation required. Less than significant.

Section 1.5.2, page 1-18, Table 1.A

Conflict with any Applicable Airport Land Use Plan Under the proposed General Plan, economic development and population growth will continue to increase, requiring the construction of additional places of business and housing. As the land suitable for development becomes increasingly scarce, urban development may be forced to exploit land occur adjacent to airports. Such encroaching development may result in conflicts between new development and the goals and policies outlined in local Airport Land Use Plans.

In addition to the discussion of airports provided in the proposed General Plan, specific areas influenced by airports, located in the County and/or in adjacent cities, are identified in the proposed Area Plans. Area Plans which identify specific areas influenced by airports provide policies to protect flight paths and minimize impacts to residents and employees within that area. These policies provided in the Area Plans are consistent with and support policies identified in the proposed General Plan.
Policies: LU 14.2, C 14.1-14.5 Less than significant.

Section 1.5.2, page 1-22, Table 1.A

4.5 Air Quality
Less than Significant Impacts
Consistency with Air Quality Management Plan The proposed General Plan is consistent with SCAG’s Regional Growth Management Plan and SCAQMD’s Air Quality Management Plan, and the vehicle miles traveled growth rate under the proposed General Plan is consistent with SCAG’s projected population growth. In addition, with the planning and implementation of the proposed General Plan Circulation Element, it is anticipated that the proposed General Plan will be consistent with SCAG’s Regional Mobility Plan, locally adopted Congestion Management Plan, as well as the Coachella Valley PM10 Plan. Policies: AQ 1.1-1.11

No mitigation required.
Less than significant.

Section 1.5.2, page 1-29, Table 1.A

Impact 4.6.4 Implementation of the proposed General Plan would cause habitat fragmentation resulting in isolation of sensitive habitat patches creating a "checkerboard" pattern of small habitat patches of limited biological value. Policies: OS 5.1--5.7, OS 6.1-6.2, OS 8.1, OS 9.3-9.4, OS 17.117.3,OS 18.1-18.2

Implement Mitigation Measure 4.6.1C, above, along with the following mitigation measures.

   4.6.4A Comply with Riverside County Planning Department Biological Report Guidelines to include an analysis of the potential for a proposed project to result in habitat fragmentation leading to the isolation of sensitive habitat patches.

   Under the Planning Department Guidelines, biological reports must be conducted as follows:

   a. Reports must be prepared by a biologist on the County's list of qualified consultants.

   b. The County Planning Department must be notified in advance that a report will be prepared for a specific project.

   c. The report must include a signed certification attesting to the report contents.

   d. The report must include specific information as to the type of survey (e.g., General Biological Resources Assessment, Habitat Assessment, etc.), site location, property owner, principal investigator, and contact information for participants in the field surveys.

   e. The report must include specified attachments (summary sheet, level of significance checklist, biological resources/project footprint map, and site photos).

   f. The report must include information on literature sources (e.g., California Natural Diversity Data Base, California Department of Fish and Game, U.S. Fish and Wildlife Service, and environmental documents for nearby projects).

   g. The report must include a description of surveys, including timing, personnel, and weather conditions.

   h. The report must include a description of site conditions including plant and wildlife habitat, disturbances, and sensitive elements.

   i. The report must include an assessment of anticipated project impacts and a discussion of mitigation.


   j. The report must include a list of all species observed or detected and a recommendation for any additional focused surveys that may be necessary. The above list is a summary of the County's guidelines, the actual guidelines available from the Planning Department shall be used in determining requirements for, and adequacy of, biological reports.
Significant and unavoidable.

Section 1.5.2, page 1-50, Table 1.A

4.11 Hazardous Materials
Less than Significant Impacts
Historical Use of Hazardous Materials and Waste Implementation of the proposed General Plan would not result in impacts associated with known and/or suspected hazardous materials. However, there is a potential that previously unknown hazardous materials contamination from historical use of a property may be encountered during future development activities. Should such contamination be found or disturbance occur, existing federal, state, and local policies and procedures would require action by the designated local enforcement agency. It is unlikely that any such contamination or disturbance would be extensive beyond the capacities of typical remediation measures. Therefore, no significant impacts from former uses of properties within Riverside County are anticipated as a result of implementation of the proposed General Plan. Generation of Hazardous Waste Implementation of the proposed General Plan would introduce new land uses to the unincorporated areas of Riverside County that may result in the use of hazardous materials and the potential generation of hazardous waste. However, compliance with regulations, standards, Policies: S 6.1 S 7.17.3

No mitigation required.
Less than significant.
Less than significant.

Section 2.1, page 2-1, second paragraph

The objective of the Program EIR is to inform County of Riverside decision-makers, representatives of other affected/responsible agencies, the public, and other interested parties of the potential environmental effects that may be associated with the proposed General Plan. This Program EIR describes potential impacts relating to a wide variety of environmental issues and methods in which these impacts can be mitigated or avoided. It further analyzes the level of impact remaining after mitigation. Some impacts cannot be mitigated to below a level of significance.

Section 2.1.2, page 2-2, first paragraph under Program Environmental Impact Report

This EIR is a "Program EIR," which evaluates the broad-scale impacts of the proposed General Plan. Program EIRs are typically prepared for an agency plan program, or series of actions that can be characterized as one large project, such as a general plan. Tiering refers to the concept of a multilevel approach to preparing environmental documents (CEQA Guidelines, Section 15152). 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 that each of the thousands of individual development projects that will follow and implement the General Plan may have. 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.

Section 2.1.2, page 2-2, first paragraph after bulleted list

In this case, the Program EIR will address the General Plan, which is the proposed project. This EIR considers anticipates a series of actions needed to achieve the implementation of the proposed General Plan. Further actions or procedures required to allow implementation of the proposed General Plan include the processing of zoning plans, specific plans, tentative tract maps, site design plans, building permits, and grading permits.

Section 3.1, page 3-1, paragraph 4

The challenge of balancing the housing, transportation, and economic needs of existing and future populations with limited natural resources and the sensitivity of the natural environment required Riverside County to develop the Riverside County Integrated Plan (RCIP), which consists of three coordinated plans to determine future planning, transportation, and conservation needs for Riverside County. These plans include the 2002 Riverside County General Plan, the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP), and the Community Environmental and Transportation Acceptability Program (CETAP). Each of the plans has independent utility, and each can be approved without approval of the others. They will, however, be coordinated such that if all three are adopted, no conflicts between the plans will occur.

Section 3.1, page 3-6, paragraph 1

The Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) involves the assembly and management of a reserve system for the conservation of natural habitats and their constituent wildlife populations. The MSHCP establishes a framework for complying with State and federal endangered species regulations, while accommodating future growth within the cities and unincorporated portions of western Riverside County. Thus, unlike the proposed General Plan, the MSHCP covers only the western portion of the County, and covers not only unincorporated areas, but cities as well. The MSHCP is designed to be complementary to the 2002 Riverside County General Plan, but could also be adopted in the event that the 2002 Riverside County General Plan were not.

Section 3.1, page 3-7, paragraph 1

The CETAP component of RCIP identifies transportation corridors to meet the future transportation needs of Riverside County. CETAP is a multi-modal planning effort that considers highway options, and also looks at transit and other forms of travel demand management and goods movement. CETAP is designed to be complementary to the 2002 Riverside County General Plan, but could also be adopted in the event that the 2002 Riverside County General Plan were not.

Section 3.1, page 3-7, fourth paragraph

Relationships and Differences Between RCIP Components

The 2002 Riverside County General Plan recognizes the Western Riverside County MSHCP, and incorporates the MSHCP into its Area Plans as mitigation for the biological impacts that will result from development permitted by the proposed General Plan. The proposed General Plan also incorporates by reference the Coachella Valley MSHCP being prepared by the Coachella Valley Association of Governments parallel to, but separate from, RCIP. The proposed General Plan Circulation Element includes proposed CETAP corridors as part of its proposed roadway and highway system.

The MSHCP provides comprehensive mitigation for the development impacts that will result from development of the proposed General Plan land uses and transportation facilities (including CETAP corridors) within the western portion of the County, including development of proposed CETAP corridors. The MSHCP also includes CETAP corridors as permitted activities where they cross MSHCP preserve areas.

The RCIP consists of three coordinated plans: the 2002 Riverside County General Plan (which is the subject of this Program EIR), the Western Riverside County MSHCP, and the CETAP. Although coordinated, these three plans are independent components of RCIP. As an independent plan, the 2002 Riverside County General Plan is not reliant upon the approval of either MSHCP or CETAP. The proposed General Plan is, however, coordinated with the MSHCP and the CETAP, so that no substantive conflicts or inconsistencies exist among the three plans. The General Plan is consistent with the draft MSHCP in that some of the draft MSHCP policies for biological resource preservation and mitigation are incorporated into the proposed General Plan's Area Plans. The biological resource policies incorporated into the Area Plans provide partial mitigation for development impacts that would result from development proposed by the General Plan's identified land uses, infrastructure, and transportation facilities. The proposed General Plan also is consistent with the draft CETAP in that the proposed General Plan Circulation Element recognizes the potential for proposed CETAP corridors as part of its proposed roadway and highway system.

Section 3.1, page 3-8, paragraph 2

Although they are clearly related projects, and are each part of an integrated planning program, as described above, each RCIP component covers a different physical area, is being prepared pursuant to different State and federal laws, involves different agencies in their approval, and has different lead agencies for their environmental documentation. In addition, each RCIP component is on a slightly different schedule. As a result of these differences, preparation of a single environmental document was found to be impractical. Such a document would prove to be overly complex and impossible difficult to understand. Instead, each environmental document prepared from components of the RCIP program contains a cumulative impact analysis, summarizing the overall impacts of RCIP. Finally, each RCIP component has independent utility, and could be adopted in the absence of adoption of the other components.

Section 3.4, page 3-81, after last paragraph

The EIR analysis relies on GIS data, which is based on the proposed General Plan description. However, because of the nature of GIS calculations, some acreages reported in the EIR may be slightly different from those indicated in the 2002 Riverside County General Plan Area Plans. These minor discrepancies do not affect the adequacy or accuracy of the EIR's environmental analysis.

Section 4.2, page 4.2-6, following first paragraph

Riverside County Specific Plan Developments - February 2003
Specific
Plan
Maximum
Dwelling Units
Built
Dwelling Units
"A" Street Corridor - -
Highland Springs 1,630 993
Dutch Village 1,500 658
Mission Lakes 2,358 369
Frank Domeno 71 -
Tract Map 4437 310 259
The Farm 1,934 952
Mission De Anza 3,458 2,249
Red Mountain 49 48
Sky Country 1,159 1,159
Republic 452 216
El Nino 203 155
Sky Mesa 112 92
River City 461 -
Newport Estates 856 -
Lake Hills 1,757 1,012
North Star Ranch 1,666 -
Horsethief Canyon 2,132 1,959
Menifee Village 5,254 2,742
Green River Medows 507 507
Walker Basin 1,444 -
Riverview Ranch 172 -
Wild Rose 1,181 1,013
Four Seasons 896 896
Rancho Nuevo 508 -
Rancho Bella Vista 1,998 1,137
Countryside 1,154 -
Belle Meadows 141 -
Cal Neva 1,670 676
Audie Murphy Ranch 3,596 -
Agua Mansa 376 -
Andreas Cove - -
Mesa Grande 200 -
Winchester Properties 2,669 1,462
Redhawk 4,188 1,792
Coral Mountain 1,360 -
Mountain Springs 1,571 392
Woodcrest Country Club 310 -
Centerpointe 280 -
HB Ranches 1,421 -
Adams 34 Ranch 939 -
Crown Valley Village 591 -
Stoneridge 2,236 -
Rio Vista 1,687 -
Preissman 3,088 -
Menifee East 1,283 -
Newport Hub - -
Gateway Center 553 -
Lakeview Nuevo 185 -
Sycamore Creek 1,733 -
Menifee North 2,388 5
Arbor Creek Estates 56 -
Borel Airpark - -
I-15 Corridor 2,400 283
Victoria Grove 1,144 450
Canyon Heights 775 -
Del Webb 5,075 4,095
Canyon Cove 485 -
Quinta Do Lago 1,318 291
Winchester 1800 5,196 486
The Crossroads at Winchester 795 -
Winchester Hills 5,633 -
Alta Cresta Ranch 3,438 -
Eastvale 2,769 1,635
Menifee Ranch 4,067 -
Kohl Ranch 7,171 -
Eagle Mountain - -
Eagle Mountain Townsite 432 -
Gavilan Hills Golf Course - -
Domenigoni-Barton 4,600 -
French Valley 1,793 -
Morgan Hill 1,129 -
The Retreat 545 -
Oak Valley 4,356 -
BSA Properties 421 -
Spring Mountain Ranches 1,518 -


Proposed Specific Plans In Riverside County
Proposed Specific Plan Dwelling Units in Proposal
Dutch Village 1,450
Dutch Village 1,550
Walker Basin 77
Audie Murphy 2,129
Mesa Grande 499
Menifee North 2,677
Canyon Heights 439
Winchester 1800 4,870
Gavilan Hills 644
The Highlands 1,440
Sierra Highlands 65
Murietta Hills 1,879
Vail Lake 5,172
McAllister Hills 321
Victoria Grove East 1,345
Temescal Hills 1,800
Creekside 1,312
Springbrook Estates 1,000
Eastvale 2 473

Section 4.2, page 4.2-6, starting at third paragraph

The existing Riverside County General Plan defines productive agricultural lands as land "which is involved in a long-term, substantial investment to agricultural use, and which has a long-term economic viability for agricultural use." Some of the factors affecting the economic viability of these areas include weather, water prices, crop selection, management techniques, commodity prices, new technology, and proximity of developed lands. The total gross valuation of agricultural crops in the County in 2001 1997 was $1,087,920,000. $1,124,908,400. This amount represents an increase of $76,346,800 over the 2000 gross value. Although this represents a $53.9 million decrease from 1996 crop values, Within the Southern California region, the total value of agricultural production in the Riverside County is exceeded only by San Diego County. Statewide, Riverside County is ranked ninth in the value its agricultural production. Riverside County is the leading agricultural county in Southern California.

Agricultural statistics are maintained by the County in four districts: Riverside/ Corona, San Jacinto/Temecula Valley, Coachella Valley and Palo Verde Valley. The Coachella Valley District recorded highest valuation in non-livestock related agricultural production, followed by the San Jacinto/Temecula Valley District alo Verde Valley District, the Palo Verde Valley District San Jacinto/Temecula Valley District, and the Riverside/Corona District (Table 4.2.B).

Table 4.2.B - Crop Valuation (in millions)
 1993 1994 1995 1996 1997
Riverside/Corona $71.1 $47.4 $46.7 $40.7 $29.0
San Jacinto/Temecula Valley $92.6 $85.6 $93.1 $95.3 $97.8
Coachella Valley $341.1 $324.4 $406.1 $319.6 $331.7
Palo Verde Valley $79.2 $89.6 $100.2 $103.1 $102.9
County Total $584.0 $547.0 $646.1 $558.7 $561.4
Note: Crop valuations do no include the value of livestock and poultry produced in the County.
Source: Riverside County Agricultural Commissioner.


Table 4.2.B - Crop Valuation (in millions)
 1997 1998 1999 2000 2001
Riverside/Corona $29.0 $38.4 $31.5 $31.2 $49.70
San Jacinto/Temecula $97.8 $112.0 $94.4 $102.3 $138.8
Valley
Coachella Valley $331.7 $398.1 $427.6 $324.7 $450.7
Palo Verde Valley $102.9 $92.0 $90.4 $93.9 $99.0
County Total $561.4 $640.5 $643.9 $552.1 $738.2
Note: Crop valuations do no include the value of livestock and poultry produced in the County.
Source: Riverside County Agricultural Commissioner.

Section 4.2, page 4.2-12, third paragraph under Airport Land Use Plans

Under the proposed General Plan, economic development and population growth will continue to increase, requiring the construction of additional places of business and housing. As the land suitable for development becomes increasingly scarce, urban development may be forced to exploit land occur adjacent to airports. Such encroaching development may result in conflicts between new development and the goals and policies outlined in local Airport Land Use Plans.

Section 4.2, page 4.2-12, third paragraph under Airport Land Use Plans

Under the proposed General Plan, economic development and population growth will continue to increase, requiring the construction of additional places of business and housing. As the land suitable for development becomes increasingly scarce, urban development may be forced to exploit land occur adjacent to airports. Such encroaching development may result in conflicts between new development and the goals and policies outlined in local Airport Land Use Plans.

Section 4.2, page 4.2-13, add above Proposed General Plan Policies

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.

Section 4.2, page 4.2-20, second paragraph under Agriculture

Impact 4.2.2 The proposed General Plan update will result in the conversion of prime farmlands, unique farmlands, or farmlands of statewide importance, or land actively utilized for agricultural production to a variety of non-agricultural uses.

Section 4.2, page 4.2-24, Mitigation Measures

4.2.2A The County shall establish an Agricultural Land Mitigation Bank. The formation, authority, and operation shall be established by the County of Riverside and shall adhere to applicable statutes of the State of California and Riverside County. The Agriculture Land Mitigation Bank shall be established no later than two three years from the date of adoption of the 2002 Riverside County General Plan.

4.2.2B Subsequent to the establishment of an Agricultural Land Mitigation Bank, any development within any unincorporated area of the County resulting in the conversion of more than 80160 acres (the approximate size of an average farm in Riverside County) of Prime, Unique, or Statewide Important farmland (designated farmland), as designated by the most recent version of the Important Farmland Map as prepared by the California Department of Conservation, Farmland Mapping and Monitoring Program, shall purchase credits in the Agricultural Land Mitigation Bank at the rate of 1 acre (credit) for every four acres (or portion thereof) of designated farmland converted to non-agricultural uses. The 80160-acre threshold shall be met by any combination of designated farmland. Prime, Unique, or State Important. All designated farmland within a project site shall be included in the threshold computa-tion, regardless of the size, or location within the project site, or current status (fallow or farmed).

4.2.2C Subsequent to the establishment of an Agricultural Land Mitigation Bank, any development within unincorporated Riverside County resulting in the conversion of more than 40 acres of land actively utilized for agricultural production (active farmland), shall purchase credits in the Agricultural Land Mitigation Bank at the rate of one acre (credit) for every acre (or portion thereof) of active farmland converted to non-agricultural uses. To be considered "active farmland," land must have been utilized for agricultural production for two of the previous five years (prior to application). The 40-acre threshold shall be met only by the footprint of land on which crops are grown or livestock raised regardless of whether the land is State designated or not; and shall not include roadways, residential or production areas, equipment storage areas, or other non-production areas.

Section 4.4, page 4.4-3, Table 4.4.A

12: San Gorgonio PassBordered by the San Bernardino and San Jacinto Mountains; small town urban uses; San Gorgonio River; Morongo Band of Mission Indians Reservation lands, wind energy facilities, large-lot rural residential and agricultural uses; desert and hillside vegetation.

Section 4.6, page 4.6-28, insert 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.

Section 4.6, page 4.6-50, additional text following third full paragraph

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.

Section 4.6, page 4.6-54, additional text under Mitigation Measures

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.

Section 4.9, page 4.9-10, Thresholds of Significance

Substantially alters existing drainage patterns within Riverside County; Considerably alters existing drainage patterns such that substantial changes to streamflow velocities, erosion patterns, or siltation would occur.

Section 4.9, page 4.9-12, Mitigation Measures

4.9.1B Riverside County shall prohibit alteration of floodways and channelization unless alternative methods of flood control are not found to be technically, economically, and practicably infeasible.

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, concentration of flows, and adverse impacts to water quality from point and nonpoint sources of pollution.

Section 4.9, page 4.9-14, Mitigation Measures

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.

Section 4.10, page 4.10-2, beginning of second paragraph after Ground Shaking

Ground shaking is the movement of the earth resulting from an earthquake. Shaking can cause lateral movement and vertical ground acceleration which can contribute to the collapse of buildings. building reason for collapse of buildings.

Section 4.10, page 4.10-5, Table 4.10A

Table 4.10.A - Probable Earthquake Scenarios for Riverside County
EventMaximum Magnitude (Mw)Chance of Occurring in 30 YearsComments
FaultSegment
San AndreasSan Bernardino7.328%Very high intensity ground shaking throughout the San Bernardino Valley, including north central Riverside County.
San AndreasCoachella7.122%Very high intensity ground shaking throughout the Coachella Valley, affecting desert resort communities and agriculture.
San JacintoSan Jacinto Valley6.943%Highest probability of occurrence of any Southern California fault. Brought closer to failure as a result of stress field changes caused by the 1992 Landers earthquake.
San JacintoAnza Segment7.217%This event would be very destructive within the communities of Hemet and San Jacinto.
ElsinoreTemecula Segment6.816%Has not produced any significant earthquakes in historic time.
ElsinoreGlen Ivy Segment6.816%Would be very destructive in the communities of Lake Elsinore, Murrieta, and Temecula.
WhittierWhittier6.85%Has not broken in over 1,600 years (WGCEP, 1995). Would cause significant landsliding and lifeline damage in the Chino Hills - Corona area.
Notes:
Maximum Magnitude: the magnitude of an earthquake event based on the amount of energy released.
This measurement is more accurate for large earthquake events.
Source: Natural Hazard Mapping, Analysis and Mitigation: A Technical Background Report in Support of the New Riverside County General Plan


Table 4.10.A: Fault Source Parameters for Riverside County
Fault Name and Geometry1Distance from County (km)LengthSlip RateMaximum Magnitude2Maximum PGA3Average Return Interval (yrs)Comments
(km)+/-(mm/
yr)
+/-
San Andreas-Coachella (rl-ss)095102557.10.51naSlip rate based on Sieh and Williams (1990); Sieh (1986); Keller et al. (1982); Bronkowski (1981). Model assumes slip only in S. San Andreas events.
San Andreas-San Bernardino (rl-ss)0107112467.30.53146Slip rate reported by Weldon and Sieh (1985).
San Andreas (southern) (rl-ss)0203202467.40.48220Rupture of San Bernardino and Coachella segments. Slip rate based on Coachella segment.
San Andreas-Mojave (rl-ss)>3099103077.10.25150Slip rate based on Sieh (1984), Salyards et al. (1992), and WGCEP (1995).
San Jacinto-Coyote Creek (rl-ss)0404426.80.48175Slip rate and fault length from WGCEP (1995).
San Jacinto-Anza (rl-ss)09091267.20.52250Slip rate and fault length from WGCEP (1995).
San Jacinto-San Jacinto Valley (rl-ss)04241266.90.4983Slip rate and fault length from WGCEP (1995).
San Jacinto-San Bernardino (rl-ss)03541266.70.53100Slip rate and fault length from WGCEP (1995).
Elsinore-Temecula (rl-ss)0424526.80.47240Slip rate and fault length from WGCEP (1995).
Elsinore-Glen Ivy (rl-ss)0384526.80.48340Reported slip rates vary from 3.0-7.2 (Millman and Rockwell 1986)
Whittier (rl-ss)0374216.80.48641Slip rate based on Rockwell et al. (1990); Gath et al. (1992) description of offset drainage.
Chino-Central Ave. (rl-r-o)0283116.70.47882Unconstrained slip rate based on assumptions of slip transfer between Elsinore and Whittier faults.
1 STYLE OF FAULT: (ss) strike slip, (r) reverse, (n) normal, (o) oblique SENSE OF SLIP: (rl) right lateral, (ll) left lateral
2 Maximum moment magnitude calculated from rupture area regressions (type "all") (from Wells and Coppersmith, 1994).
3 Maximum estimated horizontal peak ground acceleration as a percentage of gravity on bedrock, at closest Riverside County location (from CDMG).


Section 4.10, page 4.10-17, first paragraph

Ground subsidence can disrupt surface drainage, reduce aquifer system storage, form earth fissures, and damage wells, buildings, roads, and utility infrastructure. Regional subsidence generally damages structures that are sensitive to slight changes in elevations, such as canals, sewers, and drainages. In Riverside County, risk due to regional subsidence is greatest at valley margins.

Section 4.10, page 4.10-29, Mitigation Measures

4.10.1A Before a project is approved or otherwise permitted within an A-P Zone, County Fault Zone, within 150 feet of any other active or potentially active fault mapped in a published United State Geologic Survey (USGS) or CGS reports, or within other potential earthquake hazard area (as determined by the County Geologist), a site-specific geologic investigation shall be prepared to assess potential seismic hazards resulting from development of the project site. Where and when required, the geotechnical investigation shall address the issue(s), hazard(s), and geographic area(s) determined by the County Geologist to be relevant to each development. The site-specific geotechnical investigation shall incorporate up-to-date data from government and non-government sources.

Section 4.13, page 4.13-1, last paragraph

All sensitive uses along freeways and highways that are or will be exposed to noise levels in excess of applicable noise standards require the consideration of mitigation measures such as sound walls or building facade upgrades. However, State highways, including freeways, under the jurisdiction of Caltrans must consider noise abatement measures when roadways are to be undergoing major changes or improvements that will result in new or continued exposure to traffic noise levels approach or exceed the noise abatement criteria (NAC). Because of the competing impact of noise or sound wall costs versus benefits, the California Department of Transportation (Caltrans) is sensitive to the wishes of the affected community regarding wall construction. When building or upgrading roadways, Caltrans will generally support design features that minimize local objections as long as their own design standards are met.

Section 4.13, page 4.13-5, last paragraph

Recreational lands and wildlife habitat are also significantly impacted by noise. Recreational uses include those that are quiet in nature and those that are noisy by nature. Quiet in nature recreational uses include trails and picnic areas. Noisy in nature recreational uses include sports park and off-road vehicle recreational areas. However, lands are lands where quiet is a basis for use. Uuncontrolled use of off-road vehicles in parks and open space lands degrades recreational opportunities for the County's residents. Noise intrusion into wildlife habitat drives off wildlife and, with prolonged use, may effectively reduce the amount of land used as habitat by various species.

Section 4.13, page 4.13-97, second 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.

Section 4.13, page 4.13-103, Mitigation Measures

4.13.2A All new residential developments within the County shall conform to a noise exposure standard of 65 dBA Ldn for outdoor noise in noise-sensitive outdoor activity areas and 45 dBA Ldn for indoor noise in bedrooms and living/family rooms. New development, which does not and cannot be made to conform to this standard, shall not be permitted.

Section 4.13, page 4.13-103, Mitigation Measures

4.13.2C The County shall require that proposed new commercial and industrial developments prepare acoustical studies, analyzing potential noise impacts on adjacent properties, when these developments abut noise-sensitive land uses. The County will require that all identified direct impacts to noise-sensitive land uses be mitigated to the maximum extent practicable a less than significant level.

4.13.2D Ensure that all new schools, particularly in subdivisions and specific plans, are sited more than 2 miles away from any airport.

Section 4.13, page 4.13-108, Mitigation Measures

4.13.4A All new residential developments within the County shall conform to a noise exposure standard of 65 dBA Ldn for outdoor noise in noise-sensitive outdoor activity areas and 45 dBA Ldn for indoor noise in bedrooms and living/family rooms. New development, which does not and cannot be made to conform to this standard, shall not be permitted.

Section 4.14, page 4.14-1, first paragraph

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.

Section 4.15, page 4.15-19, insert after fourth full paragraph

The County of Riverside has ordinances that strictly regulate the construction and maintenance of septic tanks. Section 8.124.030 of the County of Riverside Government Code states that all septic facilities require written approval for construction from the County Health Officer. Approval for septic tanks require detailed review and on-site inspections, which include a scaled, contoured plot plan, a soils feasibility report that adequately evaluates soil percolation, a special feasibility boring report (groundwater and/or bedrock), and an engineered topographical map.

Additionally, the U.S. Environmental Protection Agency (EPA) has established standards governing the placement of septic systems in the proximity of water supply wells. The EPA's "Zone A" is classified as a potential area of direct microbiological and chemical contamination based on an estimated two-year time of (contaminant) travel within an aquifer from the wellhead to the potential source of contamination. Waste discharges from conventional septic tank/subsurface disposal systems may adversely affect both the quality and beneficial uses of the water and/or violate local, regional or State water quality standards. As excerpted from EPA's Design Manual On-Site Wastewater Treatment and Disposal Systems, "... State Codes that specify 100-foot separation distances between convention subsurface wastewater infiltration system treatment units and down-gradient wells or surface waters should not be expected to always protect these resources from dissolved, highly mobile contaminants ... published data indicate that viruses that reach groundwater can travel at least 220 vertical feet and 1,338 feet laterally in some porous soils and still remain effective." Any such degradation of water quality would be a potentially significant impact.

Section 4.15, page 4.15-20, starting at Effectiveness of Proposed General Plan Policy

Effectiveness of Proposed General Plan Policy. Implementation of the proposed General Plan policies, and existing County regulations related to wastewater, and the following measure will reduce potential wastewater impacts resulting from future development to a less than significant level. would reduce the effects of future development to less than significant and no further mitigation is required.

Mitigation Measure

4.15.4A Conventional septic tanks/subsurface disposal systems shall be prohibited within any designated Zone A of an Environmental Protection Agency wellhead protection area. Where a difference between Riverside County and EPA septic tank setback distance requirements exists, the EPA standard shall apply.

Section 4.16, page 4.16-3, Table 4.16.A and 4.16.B

Table 4.16.A - Uninterrupted Traffic Flow Facilities Level of Service
Level of
Service
Definition
ARepresents free flow. Individual vehicles are virtually unaffected by the presence of others in the traffic stream. Describes completely free-flow conditions. The operation of vehicles is virtually unaffected by the presence of other vehicles, and operations are constrained only by the geometric features of the highway and by driver preferences. Maneuverability within the traffic stream is good. Minor disruptions to flow are easily absorbed without a change in travel speed.
BIs in the range of stable flow, but the presence of other vehicles in the traffic stream begins to be noticeable. Freedom to select desired speeds is relatively unaffected, but there is a slight decline in the freedom to maneuver. Also indicates free flow, although the presence of other vehicles becomes noticeable. Average travel speeds are the same as in LOS A, but drivers have slightly less freedom to maneuver. Minor disruptions are still easily absorbed, although local deterioration in LOS will be more obvious.
CIs in the range of stable flow, but marks the beginning of the range of flow in which the operation of individual vehicles becomes significantly affected by interactions with other vehicles in the traffic stream. The influence of traffic density on operations becomes marked. The ability to maneuver within the traffic stream is clearly affected by other vehicles. Minor disruptions can cause serious local deterioration in service, and queues will form behind any significant traffic disruption.
DIs a crowded segment of roadway with a large number of vehicles restricting mobility and a stable flow. Speed and freedom to maneuver are severely restricted, and the driver experiences a generally poor level of comfort and convenience. The ability to maneuver is severely restricted due to traffic congestion. Travel speed is reduced by the increasing volume. Only minor disruptions can be absorbed without extensive queues forming and the service deteriorating.
ERepresents operating conditions at or near the level capacity. All speeds are reduced to a low, but relatively uniform value. Small increases in flow will cause breakdowns in traffic movement. Represents operations at or near capacity; an unstable level. Vehicles are operating with the minimum spacing for maintaining uniform flow. Disruptions cannot be dissipated readily, often causing queues to form and service to deteriorate to LOS F.
FIs used to define forced or breakdown flow (stop-and-go gridlock). This condition exists when the amount of traffic exceeds the amount that can travel to a destination. Operations within the queues are characterized by stop and go waves, and they are extremely unstable. Represents forced or breakdown flow. It occurs either when vehicles arrive at a rate greater than the rate at which they are discharged or when the forecast demand exceeds the computed capacity of a planned facility. Although operations at these points - and on sections immediately downstream - appear to be at capacity, queues form behind these breakdowns. Operations within queues are highly unstable, with vehicles experiencing brief periods of movement followed by stoppages.
SOURCE: Highway Capacity Manual, 2000.


Table 4.16.B - Interrupted Traffic Flow Facilities Level of Service
Level of
Service
Definition
ADescribes operations with average intersection stopped delay of five seconds or less (how long a driver must wait at a signal before the vehicle can begin moving again). Describes operations with a low control delay, up to 10 seconds per vehicle. This LOS occurs when progression is extremely favorable and most vehicles arrive during the green phase. Many vehicles do not stop at all. Short cycle lengths may tend to contribute to low delay values.
BDescribes operations with average intersection stopped delay in the range of 5.1 to 15.0 seconds per vehicle, and with reasonably unimpeded operations between intersections. Describes operations with control delay greater than 10 and up to 20 seconds per vehicle. This level generally occurs with good progression, short cycle lengths, or both. More vehicles stop than with LOS A, causing higher levels of delay.
CDescribes operations with higher average stopped delays at intersections (in the range of 15.1 to 25.0 seconds per vehicle). The stable operations between locations may be restricted given the ability to maneuver and change lanes at mid-block locations. These conditions can be more restrictive than LOS B. Further, the longer queues and/or adverse signal coordination may contribute to lower average speeds. Describes operations with control delay greater than 20 and up to 35 seconds per vehicle. These higher delays may result from only fair progression, longer cycle lengths, or both. Individual cycle failures may begin to appear at this level. Cycle failure occurs when a given green phase does not serve queued vehicles, and overflows occur. The number of vehicles stopping is significant at this level, though many still pass through the intersection without stopping.
DDescribes operations where the influence of delay is more noticeable (25.1 to 40.0 seconds per vehicle). Intersection stopped delay is longer and the range of travel speed is about 40 percent below the free flow speed. This is caused by inappropriate signal timing, high volumes, and some combinations of both. Describes operations with control delay greater than 35 and up to 55 seconds per vehicle. At LOS D, the influence of congestion becomes more noticeable. Longer delays may result from some combination of unfavorable progression, long cycle lengths, and high volume-to-capacity ratios. Many vehicles stop, and the proportion of vehicles not stopping declines. Individual cycle failures are noticeable.
EIs characterized by significant approach stopped delay (40.1 to 60.0 seconds per vehicle), and average travel speeds of one-third the free flow speed or lower. These conditions are generally considered to represent the capacity of the intersection or arterial. Describes operations with control delay greater than 55 and up to 80 seconds per vehicle. These high delay values generally indicate poor progression, long cycle lengths, and high volume-to-capacity ratios. Individual cycle failures are frequent.
FCharacterizes arterial flow at extremely low speeds, with high intersection stopped delay (greater than 60 seconds per vehicle). Poor progression, long cycle lengths, and high traffic demand volumes may be a major contributing factor to this condition. Traffic may be characterized by frequent stop-and-go conditions. Describes operations with control delay in excess of 80 seconds per vehicle. This level, considered unacceptable to most drivers, often occurs with oversaturation, that is, when arrival flow rates exceed the capacity of lane groups. It may also occur at high volume-to-capacity ratios with many individual cycle failures. Poor progression and long cycle lengths may also contribute significantly to high delay levels.
SOURCE: Highway Capacity Manual, 2000.


Section 4.16, page 4.16-8, last paragraph

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.

Section 4.17, page 4.17-2

The chief challenge to obtaining, conveying, and managing water in Southern California is its location in an arid region and the general lack of local water sources adequate to support the ever-increasing population and growing economy. An intricate network of canals, aqueducts, reservoirs, and distribution lines allows for the continued flow of water from local, as well as more distant sources. Connections between the myriad agencies and private entities that supply and manage the flow of water to Southern California is equally complex. The interaction between the various State, regional, and local agencies tasked with the planning, maintenance and oversight of a water supply system that results in the continued flow of water to the region is an involved and dynamic process.

The State Department of Water Resources (DWR) is charged with the management of water resources within the State. The DWR cooperates with other agencies to benefit the State and to protect, restore, and enhance natural and human environments. Regionally, more than 300 public agencies and private companies provide water on a retail basis to approximately 17 million people living in a 5,200-square mile, six-county area. Some of these, such as Metropolitan Water District of Southern California (Metropolitan), act as regional wholesale providers, while others may be substantially smaller, providing water to a limited area or number of connections. Providing a safe, reliable, and cost-effective water supply requires cooperation between public and private water agencies that emphasizes a regional approach to the water supply problem. Difficulties in identifying, securing, and maintaining a safe, cost-effective, and reliable water supply are compounded by the arid climate, past and current land use practices, projected population growth, and changing governmental regulations. Further complicating this process is the fact that the region spans different watershed areas, which themselves are further divided into smaller sections by internal surface water drainage areas and groundwater basins. In addition to the physical obstacles that must be surmounted, water supply planning and the delivery of water from the source to the tap is overseen by State, regional, and local agencies, which may or may not have a common perception of the water supply or water need.

The supply and management of water resources must take into account not only the flow of water to the spigot, but the ancillary issues involved (i.e., impacts resulting from the use of a particular water source). Besides human consumption, water is utilized beneficially for habitat management, recreation, groundwater recharge, and the maintenance of water quality. Water supply planning must not only consider surface and groundwater water supplies, but water derived from conservation practices and the use of innovative and alternative sources. Such practices such as desalinization and the use of reclaimed water for irrigation and other non-consumptive purposes, which currently supply only a fraction of region's water inventory, may increase in importance in future years. Water planners must plan for climatic conditions that may or may not occur in the future (such as drought years), as well as comply with the requirements mandated by State and local authorities (which may be amended or revised per the changing inclinations of legislators).

While State and regional water demands can be projected based on the demographic and economic variables in the forecast by regional authorities, the use of different planning horizons may complicate or confuse the water planning. The use of different "baseline" projections or planning horizons by local water agencies in their planning documents and the focus on a more precisely defined identification of water supply and demand (versus a more broad regional, or even more broad Statewide approach) may render the analysis of local and regional water supply and demand impacts more difficult.

Coachella Valley Water District

The Coachella Valley Water District (CVWD), encompassing 995 square miles, extends from San Gorgonio Pass to the Salton Sea. The district provides water to approximately 284,700 residents, 72,900 acres of irrigated farmland, and a variety of commercial, resort, and industrial users. Services provided by the District include: the delivery of domestic and irrigation water; water conservation; wastewater reclamation and recycling; storm-water protection; agricultural drainage; groundwater recharge; and water education. In addition to groundwater supplies, the District obtains water from the State Water Project, and Metropolitan. The District's SWP entitlement totals 23,100 af/yr. The District does not receive this allotment directly, rather it is delivered to Metropolitan, which in turn delivers to the District an equal amount of Colorado River water.

Total water demand in 1999 was approximately 669,000 af/yr of which 310,000 was for urban uses and 359,000 was for agricultural uses. Groundwater provided approximately 56 percent of the District's 1999 demand. Development within the District has contributed to the continued decline of groundwater resources.

As outlined in Coachella Valley Water Management Plan (September 2002), the District's goal is to assure adequate supplies of safe, high-quality water at the lowest cost to District users. The Plan estimates states that under current conditions, total groundwater overdraft in the District will total 136,700 af/yr in 2035. The Plan states the preferred water management alternative for the district includes water conservation, increased delivery of water supplies to the Coachella Valley, and a combination of source substitution and groundwater recharge.

Metropolitan Water District

Water in Southern California is provided through a complex system of infrastructure operated by many institutional entities. More than 300 public agencies and private companies provide water on a retail basis to persons and businesses within the Southern California region. Metropolitan is the primary wholesale provider of imported water for the region, serving 26 member agencies, which in turn serve customers in more than 145 cities and 94 unincorporated communities. Metropolitan is the primary water provider for the majority of the areas that would be developed within the County pursuant to the General Plan. Through its Integrated Resources Plan (IRP), a key objective of Metropolitan is to "... have the full capability to meet full-service demands at the retail level at all times." To meet this objective, Metropolitan, its member agencies, and retail providers must closely coordinate the development of imported and local water resources to meet retail demands in an efficient and affordable way. Key elements of Metropolitan's strategy for achieving this goal include: maintaining a portfolio of diversified water supplies; securing reserves to mitigate supply uncertainties; and maintaining a rate schedule that provides financing capabilities to support the IRP.

Water demands on Metropolitan are projected according to four key parameters: retail demands, local replenishment demands, local supplies, and Metropolitan system storage requirements. To forecast retail demand, Metropolitan utilizes a forecasting system that relates water use to independent variables such as population, housing, employment, income, price, weather, and conservation. The demographic and economic variables in the forecast are based on the Southern California Association of Governments (SCAG) Regional Transportation Plan and the San Diego Association of Government (SANDAG) 2020 forecast. These demographic projections are supported by environmental impact reports and based on city, county, and regional general plans.

Water demands on Metropolitan are calculated as the retail demands plus local replenishment demands less local supplies. Based on the RUWMP, demand on Metropolitan will total 1.9 million acre feet in 2002, increasing to 2.3 million acre feet in 2020. Based on existing supply capabilities, Metropolitan can meet 100 percent of its member agencies projected supplemental demands over the next 20 years in average and wet years; over the next 15 years in multiple dry years; and over the next ten years in single dry years. With the addition of all water supplies that are under development, Metropolitan will have the capability to meet 100 percent of its members agencies' projected supplemental demands over the next 20 years even under a repeat of the worst drought; while providing a 15 to 20 percent reserve supply, and making available sufficient water deliveries for the replenishment of local and regional storage.

Section 4.17, page 4.17-11, Water Quality

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.

Section 4.17, page 4.17-15, add to end of paragraph preceding Table 4.17.B

The proposed General Plan includes policies (discussed below) that require water management strategies, including conservation, collection of information, decreasing demand, outreach and education programs, assurances of adequate groundwater recharge areas, and water supply monitoring. No adverse impacts are anticipated to result from such strategies, as they would reduce overall water demand and, in some instances, supply additional sources of water for irrigation and other non-potable uses. Infrastructure projects are likely to be proposed both by the County and by water suppliers. The construction of additional water storage facilities, as well as water reclamation plants, would be subject to additional environmental analysis to determine on-site impacts. These additional water sources would not further deplete groundwater supplies or increase reliance on imported water. Securing additional imported water is another way to increase the water supply. This water could come from existing imported sources (i.e., the Colorado River or other State Water Project sources), or could come from as-yet unnegotiated sources. The impacts of drawing water from sources outside the region would require further analysis if such proposals were undertaken. They could include impacts to biological resources (i.e., from decreased water flow in rivers), impacts to other jurisdictions that rely on that water source, growth inducing impacts, and other environmental and economic impacts.

Section 4.17, page 4.17-15, following Table 4.17.B

In addition to Riverside County, the South Coast and Colorado Hydrologic Regions encompass areas outside the boundaries of Riverside County. While the DWR water projections presented in Tables 4.17.A and 4.17.B are useful, they do not reflect conditions pertaining specifically to Riverside County alone. Riverside County is served by a myriad of water districts with boundaries spanning multiple counties. Thus, it is not feasible to obtain an estimate of the existing water use within Riverside County, as the districts do not report based on uses per County. The following discussion provides an estimate of future water demand required to support development envisioned in the proposed General Plan. Thus, future water demand is estimated here based on generation factors for different land uses.

Agriculture

In the absence of readily-available generation rates for agricultural uses, a generation factor was calculated based on the composition of crops in Riverside County using crop water demand information from San Diego County. Agricultural water demand for different crops in San Diego were calculated based on the acres of each type of crop (in 1999) presented in Table 3-2 (Citrus/Subtropical, Fruits and Vegetables, Avocados, Flowers/Nurseries, Corn and Field Crops, and Pasture) and the water demand (in 1999) for each crop type presented in Table 8-2 of the Agricultural Water Management Plan (prepared for the San Diego County Water Authority, Valley Center Municipal Water District, Mission Resource Conservation District, and Member Agencies, accessed on the Internet at http://www.sdcwa.org/manage/awmp.phtml).

The following annual rates were determined for each category:

Citrus/Subtropical4.32acre-feet (af) per acre (ac)
Fruits and Vegetables5.67af/acres
Avocados4.14af/acres
Flowers/Nurseries6.11af/acres
Corn and Field Crops5.81af/acres
Pasture3.77af/acres


The primary agricultural uses are field crops (187,000 acres), citrus crops (30,000 acres), and vegetable crops (41,700 acres). To generate an approximate water demand rate for agricultural lands in Riverside County, the rates generated for citrus/subtropical, field crops, and fruits and vegetables in San Diego County were averaged in proportion to their occurrence in Riverside County. Additionally, an extra 10 percent was added to the generation factor to account for the dryer climate in Riverside County. The resulting water demand generation rate for agriculture in Riverside County is 6.17 af/ac/yr.

As stated in the Existing Setting Report, Riverside County supported approximately 339,000 acres of agricultural land use in 1998. Thus, the estimated water use for agriculture in 1998 was 2,091,630 af. At build out, Riverside County is estimated to support approximately 204,842 acres of agriculture, resulting in a demand in 1,263,875 af/yr.

Open Space

This category includes natural and recreational areas. The calculation assigns the ‘nonturf' water demand factor to natural lands and the ‘turf' factor to recreational lands. In 1998, Riverside County had approximately 837,500 acres of natural lands (not including ‘vacant' lands) and approximately 27,000 acres of recreational lands. Using a factor of 1,571 gallons per acre (Federal Water Use Indices, Federal Emergency Management Program, 2003), recreation uses would require approximately 47,491 af/yr.

Residential

This category includes single- and multi-family residential areas. The demand factor is based on dwelling units and is applied uniformly. Section 9.0 (Public Services and Facilities) of the Riverside County Existing Setting Report, identifies water consumption factors utilized by various water utilities throughout the County. Averaging the water consumption factors of nine water utilities throughout the County (Eastern Municipal Water District, Western Municipal Water District, Western San Bernardino County Water District, Lake Elsinore Water District, Lee Lake Water District, Rancho California Water District, Lake Hemet Water District, Pinyon Pines Water District, and Coachella Valley Water District) resulted in a water demand of 902 gallons per day per residential unit, which equals 329,230 gallons (or 1.01 ac/ft) per year.

At build out of the General Plan, 563,376 dwelling units would be located within unincorporated areas of the County. Using a demand factor of 1.01 af/yr per residential unit, this would result in a residential water demand of approximately 569,000 af/yr.

Industrial, Commercial, and Public Facilities

This category includes light and heavy industrial, mineral extraction; commercial, office, and business park; and public facility uses. Depending on the unique demands of each use, the water demand within the industrial, commercial and public facility use varies substantially. As derived from Cucamonga County Water District factors, commercial/office uses were assigned a demand factor of 3.5 af/ac/yr; industrial uses were assigned a demand factor of 0.97 af/ac/yr; and public facilities were assigned a factor of 2.4 af/ac/yr. Utilizing land use acreage totals summarized in Table 3.B, the 18,802 acres of commercial uses planned at build out of the proposed General Plan would require 65,807 af/yr; the 20,658 acres of commercial/mineral extraction uses would require 20,038 af/yr; and the 20,075 acres of public facility uses would require 48,180 af/yr.

Combined, the land uses in unincorporated areas of the County envisioned under the proposed General Plan would require approximately 2,008,818 acre feet of water per year. While Metropolitan and non-Metropolitan water purveyors have identified sufficient water supplies to 2020, forecast of water supply beyond the Year 2020 is speculative. In the absence of a definitive identification of future water supply, potential impacts associated with water supply and demand must be considered significant and unavoidable.

Section 4.17, page 4.17-16, Mitigation Measures

4.17.1A Proponents of new development within unincorporated areas of Riverside County that consist of: a residential development of more than 500 dwelling units; a shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space; a commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space; a hotel/motel development of more than 5,000 rooms; an industrial, manufacturing/processing plant, or industrial park employing more than 1,000 persons or occupying more than 650,000 square feet of floor space or 40 acres of land; a mixed-use development that includes any of the previously referenced projects; or a project with a water demand equivalent to that used by 500 residential units with projected water demand of more than 250 af per year shall be required to submit a water supply assessment report prior to approval of a project. The water supply assessment report shall include the following:

• Project description;

• Water resources environmental setting;

• Conservation and water recycling measures included in the project;

• The identification of existing water entitlements, water rights, or water service contracts relevant to the water supply identified for a proposed project, and the amount of water received pursuant to such entitlements, rights, or contracts;

• Project water demand;

• Water supply alternatives;

• Preferred water supply alternative;

• Impacts associated with use of the preferred water supply alternative;

• Evaluation of compliance with the applicable Urban Water Management Plan;

• Summary and conclusions; and

• Technical appendices and attachment of supporting documents.

Said water supply assessment report shall be submitted to the County and applicable water supply agencies for review. Development shall not be permitted unless an adequate supply of water, available for use and sufficient to supply a proposed project, in wet and drought years, has been identified. Where water supply adequate to supply a project in its entirety does not exist, development of only those portions of a project with an adequate and available water supply shall be permitted. Evidence of the availability of adequate water supply shall be submitted to the County for review and approval prior to the issuance of development permits..

4.17.1B For projects smaller than those stated in Mitigation Measure 4.17.1A, with an estimated annual water use of 250 af or less, the County shall require evidence that the project is in compliance with the Urban Water Management Plan for the area in which the development is located, prior to the issuance of development permits. Evidence of such compliance shall take the form of written verification by the water provider that the project is in compliance with said plan. As determined necessary by the County, preparation of a water supply plan (as required in Mitigation Measure 4.17.1A, above) shall be required for a project that is estimated to use less than 250 af per year, prior to the issuance of development permits.

Section 4.17, page 4.17-18, additional text under Mitigation Measures

4.17.1E For any development within the Palo Verde Planning Area supplied with water from the Colorado River, the project applicant shall enter into a contract with the City of Needles, pursuant to the "Lower Colorado Water Supply Project" program. Evidence of such a contractual agreement shall be submitted to the County prior to the approval of any development entitlement for the project.

Section 4.17, page 4.17-21, Mitigation Measures

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.

Section 4.17, page 4.17-23, Mitigation Measures

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.

Section 4.17, page 4.17-23, additional text under Mitigation Measures

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.

Section 4.17, page 4.17-23

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.

Section 4.17, page 4.17-24, additional text following second 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.

Section 4.17, page 4.17-25, Mitigation Measures

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.

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 storm-water runoff flow rates do not differ from the pre-development stormwater 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.

Section 5.3, Growth Inducement, page 5-6, paragraph 4

CEQA does not consider growth inducement to be necessarily detrimental, beneficial, or of significance to the environment. Typically, the growth inducing potential of a project is considered significant if it fosters growth or a concentration of population in excess of what is assumed in pertinent master plans, land use plans, or in projections made by regional planning agencies. Significant growth impacts could also be manifested through the provision of infrastructure or service capacity to accommodate growth beyond the levels currently permitted by local or regional plans and policies. Providing these infrastructure needs (e.g., water, wastewater , roadways) in response to substantial increases in development that would occur through build out of the General Plan, would accommodate, but not induce or cause, the growth projected by the General Plan. In general, growth induced by a project is considered a significant impact if it directly or indirectly affects the ability of agencies to provide needed public services, or if it can be demonstrated that the potential growth significantly affects the environment in some other way.

Section 6.0, Alternatives, page 6-1, insert following the fourth paragraph

The alternatives included in this section have been selected to represent a range of possible development scenarios. The alternatives have been selected to identify potential impacts that would result from continuation of the policies stated in the current General Plan (No Project Alternative) and from a ban on future development within unincorporated areas of the County (No Build Alternative). "Build" alternatives were identified so that potential impacts resulting from implementation of a General Plan that emphasizes rural residential development (Rural Emphasis Alternative); a more sprawling form of development (Less Intense Community Centers Alternative); and a less sprawling form of development (More Intense Community Centers Alternative). The Density Bonus Alternative was selected to identify potential impacts associated with increasing residential development Community Centers and within the "Community Development" designation without a corresponding increase in commercial and/or industrial development in these areas.

Section 6.2.5, page 6-47, paragraph 4

The More Intense Community Centers Alternative would reduce energy, long-term vehicular noise, and transportation/circulation impacts compared to the proposed General Plan. Because this alternative would result in an increased decreased level of conversion of farmland to non-agricultural uses, it would result in increased decreased impacts relating to land use and agriculture compared to the proposed General Plan.

Section 6.3, page 6-57, Table 6.K

Environmental Issue No Build Alternative No Project Alternative Rural Emphasis Alternative Less Intense Community Centers Alternative More Intense Community Centers Alternative1 Density Bonus Alternative
Land Use/Agriculture Less Same Greater Greater Greater (Land Use) Less (Agriculture) Greater

Section 6.3, page 6-59, paragraph 1

The More Intense Community Centers and Density Bonus Alternatives would both result in increased concentration of development. Thus, under each of these alternatives, impacts to traffic and circulation, long-term regional air quality emissions, long-term vehicular noise, and biological resources would be reduced. Aesthetic impacts relating to the conversion of open space to urban land uses would also be reduced. Impacts relating to housing and population, mineral resources, construction and stationary noise, aesthetics, light and glare, and public services (except solid waste and wastewater) would be similar to those under the proposed General Plan. Impacts relating to land use would increase, as more people would be concentrated in areas exposed to noise and other hazards. Impacts relating to conversion of agricultural lands to non-agricultural uses would decrease.

Section 9.0, page 9-1, new second item

California Airport Land Use Planning Handbook, 2002. California Department of Transportation, Division of Aeronautics.

3.2 Graphics Amendments

See the following pages for the changes made to the figures described below.

• Figure 4.13.34 (page 4.13-83) - Acceptable noise range for schools changed to below 65 dBA.

• Figure 4.13.39 (page 4.13-95) - Noise contour labels reversed.






SECTION 4.0 - MITIGATION MONITORING PROGRAM

This document constitutes the Mitigation Monitoring and Reporting Program for the Riverside County General Plan in Riverside County, California. It has been prepared pursuant to the requirements of Public Resources Code 21081.6, which states, among other things, that when a governmental agency adopts or certifies a California Environmental Quality Act (CEQA) document that contains the environmental review of a proposed project:

[T]he public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment. The reporting or monitoring program shall be designed to ensure compliance during project implementation.

This monitoring program contains the following elements:

Mitigation Measures. Mitigation measures are recorded with the action and procedure necessary to ensure compliance. The following table contains mitigation measures from the Final Environmental Impact Report, Riverside County General Plan, Volume I (October 2003).

Specific Action to be Taken. A procedure of compliance and verification has been outlined for each action necessary. This procedure designates what action the Responsible Agencies will take.

Time Frame. This procedure designates when the Responsible Agencies will take the action.

Initials and Date. A representative of the Responsible Agency shall sign and date the appropriate column when a procedure necessary to ensure compliance has been completed.

The program outlined in Table 4A has been designed to be flexible. As monitoring progresses, changes to compliance procedures may be necessary based on recommendations by those responsible for the program. If changes are made, new monitoring compliance procedures and records will be developed and incorporated into the program.

Table 4A - Mitigation Monitoring Program for the Proposed Riverside County General Plan
Mitigation Measures Specific Action to be Taken Time Frame Initials and Date
Land Use/Agricultural Resources
There is no reasonable or feasible mitigation to reduce impacts resulting from the loss of agricultural land to a less than significant level.      
Population and Housing
No mitigation measures for this category.      
Aesthetics and Visual Resources
4.4.1A Development projects shall be subject to the requirements of all relevant guidelines, including the community center guidelines (Appendix J of the proposed General Plan), Riverside County supervisorial district design and landscape guidelines, and all applicable standards, policies, guidelines, and/or regulations of the County of Riverside pertaining to scenic vistas/aesthetic resources. Factors considered in these guidelines include the scale, extent, height, bulk, or intensity of development; the location of development; the type, style, and intensity of adjacent land uses; the manner and method of construction, including materials, coatings, and landscaping; the interim and/or final use of the development; the type, location, and manner of illumination and sign-age; the nature and extent of terrain modification required; and the potential effects to the established visual characteristic of the project site and/or an identified scenic vista/aesthetic resource. The Riverside County TMLA shall verify compliance with the provisions of Mitigation Measure 4.4.1A during the plan review of development projects, prior to project approval. Ongoing (during plan review of development projects.) Riverside County TMLA.
4.4.2A Riverside County shall require that sources of lighting within the General Plan area be limited to the minimum standard required to ensure safe circulation and visibility. The Riverside County Building and Safety Department shall verify compliance with the provisions of Mitigation Measure 4.4.2A during the plan review of development projects, prior to project approval. Ongoing (during plan review of development projects.) Riverside County Building and Safety Department.
4.4.2B Riverside County shall require street lighting to be limited to intersections and other locations that are needed to maintain safe access (e.g., sharp curves). The Riverside County Transportation Department shall verify compliance with the provisions of Mitigation Measure 4.2.2B during the plan review of development projects, prior to project approval. Ongoing (during plan review of development projects.) Riverside County Transportation Department.
4.4.2C Riverside County shall require exterior lighting for buildings to be of a low profile and intensity. The Riverside County Building and Safety Department shall verify compliance with the provisions of Mitigation Measure 4.4.2C during the plan review of development projects, prior to project approval. Ongoing (during plan review of development projects.) Riverside County Building and Safety Department.
4.4.2D The County shall establish a liaison with California Institute of Technology to ensure "dark skies" preservation procedures are incorporated, as necessary, to future County ordinances. The Riverside County Planning Department shall establish and consult with a liaison with the California Institute of Technology during development of County ordinances. During development of County Ordinances. Riverside County Planning Department.
4.4.2E The County shall participate in Palomar Observatory's "dark sky" conservation area. The Riverside County Planning Department shall incorporate ordinances that will ensure participation and compliance in the Palomar Observatory's "dark sky" conservation area. Within 2 years of approval of the General Plan. Riverside County Planning Department.
Air Quality
4.5.1A Applicable Rule 403 Measures: Apply nontoxic chemical soil stabilizers according to manufacturers' specifications to all inactive construction areas (previously graded areas inactive for ten days or more).

• Water active sites at least twice daily. (Locations where grading is to occur will be thoroughly watered prior to earthmoving).

• All trucks hauling dirt, sand, soil, or other loose materials are to be covered, or should maintain at least two feet of freeboard in accordance with the requirements of California Vehicle Code (CVC) Section 23114 (freeboard means vertical space between the top of the load and top of the trailer).

• Pave construction access roads at least 100 feet onto the site from main road.

• Traffic speeds on all unpaved roads shall be reduced to 15 mph or less.
The project proponent shall incorporate Mitigation Measure 4.5.1A in the Construction Contractor's grading plans and submit said grading plans to the County for review and approval. Ongoing (at issuance of grading permit). Riverside County Building and Safety Department.
4.5.1B Additional SCAQMD CEQA Air Quality Handbook Dust Measures:

• Revegetate disturbed areas as quickly as possible.

• All excavating and grading operations shall be suspended when wind speeds (as instantaneous gusts) exceed 25 mph.

• All streets shall be swept once a day if visible soil materials are carried to adjacent streets (recommend water sweepers with reclaimed water).

• Install wheel washers where vehicles enter and exit unpaved roads onto paved roads, or wash trucks and any equipment leaving the site each trip.
The project proponent shall incorporate Mitigation Measure 4.5.1A in the Construction Contractor's grading plans and submit said grading plans to the County for review and approval. Ongoing (at issuance of grading permit). Riverside County Building and Safety Department.
4.5.1C Mitigation Measures for Construction Equipment and Vehicle Exhaust Emissions:

• The Construction Contractor shall select the construction equipment used on-site based on low-emission factors and high energy efficiency.

• The Construction Contractor shall ensure that construction grading plans include a statement that all construction equipment will be tuned and maintained in accordance with the manufacturer's specifications.

• The Construction Contractor shall utilize electric-or diesel-powered equipment, in lieu of gasoline-powered engines, where feasible.

• The Construction Contractor shall ensure that construction grading plans include a statement that work crews will shut off equipment when not in use. During smog season (May through October), the overall length of the construction period will be extended, thereby decreasing the size of the area prepared each day, to minimize vehicles and equipment operating at the same time.

• The Construction Contractor shall time the construction activities so as to not interfere with peak hour traffic and minimize obstruction of through traffic lanes adjacent to the site; if necessary, a flagperson shall be retained to maintain safety adjacent to existing roadways.

• The Construction Contractor shall support and encourage ridesharing and transit incentives for the construction crew.

• Dust generated by the development activities shall be retained on-site, and kept to a minimum by following the dust control measures listed below.

a. During clearing, grading, earthmoving, excavation, or transportation of cut or fill materials, water trucks or sprinkler systems shall be used to prevent dust from leaving the site and to create a crust after each day's activities cease.

b. During construction, water trucks or sprinkler systems shall be used to keep all areas of vehicle movement damp enough to prevent dust from leaving the site. At a minimum, this would include wetting down such areas in the late morning, after work is completed for the day, and whenever wind exceeds 15 miles per hour.

c. Immediately after clearing, grading, earth-moving, or excavation is completed, the entire area of disturbed soil shall be treated until the area is paved or otherwise developed so that dust generation will not occur.

d. Soil stockpiled for more than two days shall be covered, kept moist, or treated with soil binders to prevent dust generation.

e. Trucks transporting soil, sand, cut or fill materials, and/or construction debris to or from the site shall be tarped from the point of origin.
The project proponent shall incorporate Mitigation Measure 4.5.1A in the Construction Contractor's grading plans and submit said grading plans to the County for review and approval. Ongoing (at issuance of grading permit). Riverside County Building and Safety Department.
Biological Resources
4.6.1A Comply with Riverside County Planning Department Biological Report Guidelines to include an analysis of the potential for a proposed project to result in direct mortality of individuals of listed, proposed, or candidate species or loss of habitat occupied by such species and sensitive habitats. Under the Planning Department Guidelines, biological reports must be conducted as follows:

a. Reports must be prepared by a biologist on the County's list of qualified consultants.

b. The County Planning Department must be notified in advance that a report will be prepared for a specific project.

c. The report must include a signed certification attesting to the report contents.

d. The report must include specific information as to the type of survey (e.g., General Biological Resources Assessment, Habitat Assessment, etc.), site location, property owner, principal investigator, and contact information for participants in the field surveys.

e. The report must include specified attachments (summary sheet, level of significance checklist, biological resources/project footprint map, and site photos).

f. The report must include information on literature sources (e.g., California Natural Diversity Data Base, California Department of Fish and Game, U.S. Fish and Wildlife Service, and environmental documents for nearby projects).

g. The report must include a description of surveys, including timing, personnel, and weather conditions.

h. The report must include a description of site conditions including plant and wildlife habitat, disturbances, and sensitive elements.

i. The report must include an assessment of anticipated project impacts and a discussion of mitigation.

j. The report must include a list of all species observed or detected and a recommendation for any additional focused surveys that may be necessary.

The above list is a summary of the County's guidelines, the actual guidelines available from the Planning Department shall be used in determining requirements for, and adequacy of, biological reports.
The Riverside County Planning Department shall require compliance with the provisions of Mitigation Measure 4.6.1A as a condition for project approval. Ongoing (prior to project approval). Riverside County Planning Department.
4.6.1B Preserve habitat at minimum of 1:1 replacement ratio in locations that provide long-term conservation value for impacted resource. This could involve acquisition of habitat occupied by the affected species, acquiring a key parcel that fills in a missing link or gap in a reserve that provides conservation for the species, or acquisition of credits in a mitigation bank (endorsed by the USFWS and/or CDFG) that has been established to provide conservation value for the species. Implementation of the mitigation measure shall include provisions for the preservation of such areas in perpetuity. For those development projects that are determined to have a significant impact on sensitive habitat, the Riverside County Planning Department shall require compliance with the provisions of Mitigation Measure 4.6.1B as a condition for project approval. Ongoing (prior to project approval). Riverside County Planning Department.
4.6.1C Comply with applicable HCPs. The Riverside County Planning Department shall require compliance with the provisions of Mitigation Measure 4.6.1C as a condition for project approval. Ongoing (prior to project approval). Riverside County Planning Department
4.6.2A Comply with Riverside County Planning Department Biological Report Guidelines to include an analysis of the potential for a proposed project to result in alteration or loss of habitat of listed proposed, or candidate species that inhibits or compromises recovery efforts that could otherwise lead or contribute to the delisting of the species. Under the Planning Department Guidelines, biological reports must be conducted as follows:

a. Reports must be prepared by a biologist on the County's list of qualified consultants.

b. The County Planning Department must be notified in advance that a report will be prepared for a specific project.

c. The report must include a signed certification attesting to the report contents.

d. The report must include specific information as to the type of survey (e.g., General Biological Resources Assessment, Habitat Assessment, etc.), site location, property owner, principal investigator, and contact information for participants in the field surveys.

e. The report must include specified attachments (summary sheet, level of significance checklist, biological resources/project footprint map, and site photos).

f. The report must include information on literature sources (e.g., California Natural Diversity Data Base, California Department of Fish and Game, U.S. Fish and Wildlife Service, and environmental documents for nearby projects).

g. The report must include a description of surveys, including timing, personnel, and weather conditions.

h. The report must include a description of site conditions including plant and wildlife habitat, disturbances, and sensitive elements.

i. The report must include an assessment of anticipated project impacts and a discussion of mitigation.

j. The report must include a list of all species observed or detected and a recommendation for any additional focused surveys that may be necessary.

The above list is a summary of the County's guidelines, the actual guidelines available from the Planning Department shall be used in determining requirements for, and adequacy of, biological reports.
The Riverside County Planning Department shall require compliance with the provisions of Mitigation Measure 4.6.2A as a condition for project approval. Ongoing (prior to project approval). Riverside County Planning Department
4.6.3A Construct treatment wetlands outside of natural wetlands, allowing treatment of runoff from developed surfaces prior to entering natural stream systems. The Riverside County Planning Department shall require compliance with the provisions of Mitigation Measure 4.6.3A as a condition for project approval. Ongoing (prior to project approval). Riverside County Planning Department.
4.6.4A Comply with Riverside County Planning Department Biological Report Guidelines to include an analysis of the potential for a proposed project to result in habitat fragmentation leading to the isolation of sensitive habitat patches.

Under the Planning Department Guidelines, biological reports must be conducted as follows:

a. Reports must be prepared by a biologist on the County's list of qualified consultants.

b. The County Planning Department must be notified in advance that a report will be prepared for a specific project.

c. The report must include a signed certification attesting to the report contents.

d. The report must include specific information as to the type of survey (e.g., General Biological Resources Assessment, Habitat Assessment, etc.), site location, property owner, principal investigator, and contact information for participants in the field surveys.

e. The report must include specified attachments (summary sheet, level of significance checklist, biological resources/project footprint map, and site photos).

f. The report must include information on literature sources (e.g., California Natural Diversity Data Base, California Department of Fish and Game, U.S. Fish and Wildlife Service, and environmental documents for nearby projects).

g. The report must include a description of surveys, including timing, personnel, and weather conditions.

h. The report must include a description of site conditions including plant and wildlife habitat, disturbances, and sensitive elements.

i. The report must include an assessment of anticipated project impacts and a discussion of mitigation.

j. The report must include a list of all species observed or detected and a recommendation for any additional focused surveys that may be necessary.

The above list is a summary of the County's guidelines, the actual guidelines available from the Planning Department shall be used in determining requirements for, and adequacy of, biological reports.
The Riverside County Planning Department shall require compliance with the provisions of Mitigation Measure 4.6.5A as a condition for project approval. Ongoing (prior to project approval). Riverside County Planning Department.
4.6.4B Identify local and regional habitat patterns whereby sensitive habitats are connected or where opportunities exist to reconnect isolated patches of sensitive habitat. The baseline data of the Western Riverside County MSHCP provides a biologically sound depiction of habitat linkages that would provide regional connections between existing biological reserves and other conservation lands. Avoid impacts that would fragment sensitive habitat, or acquire land that would reconnect isolated habitat patches and create or restore habitat to reestablish the connection. Where on-site habitat preservation would not provide meaningful mitigation either for an affected sensitive species or for habitat connectivity, off-site mitigation shall be implemented through the acquisition of lands that provide for regional habitat connectivity. Implementation of the mitigation measure shall include provisions for the preservation of such areas in perpetuity. The Riverside County Planning Department shall make available to the public a map showing biologically sensitive habitat in the County. The Riverside County Planning Department shall ensure that proposed development does not fragment sensitive habitat as part of CEQA review. Ongoing (prior to project approval). Riverside County Planning Department.
4.6.5A Comply with Riverside County Planning Department Biological Report Guidelines to include an analysis of the potential for a proposed project to result in fragmentation of habitat that constricts, inhibits, or eliminates wildlife movement. Under the Planning Department Guidelines, biological reports must be conducted as follows:

a. Reports must be prepared by a biologist on the County's list of qualified consultants.

b. The County Planning Department must be notified in advance that a report will be prepared for a specific project.

c. The report must include a signed certification attesting to the report contents.

d. The report must include specific information as to the type of survey (e.g., General Biological Resources Assessment, Habitat Assessment, etc.), site location, property owner, principal investigator, and contact information for participants in the field surveys.

e. The report must include specified attachments (summary sheet, level of significance checklist, biological resources/project footprint map, and site photos).

f. The report must include information on literature sources (e.g., California Natural Diversity Data Base, California Department of Fish and Game, U.S. Fish and Wildlife Service, and environmental documents for nearby projects).

g. The report must include a description of surveys, including timing, personnel, and weather conditions.

h. The report must include a description of site conditions including plant and wildlife habitat, disturbances, and sensitive elements.

i. The report must include an assessment of anticipated project impacts and a discussion of mitigation.

j. The report must include a list of all species observed or detected and a recommendation for any additional focused surveys that may be necessary.

The above list is a summary of the County's guidelines, the actual guidelines available from the Planning Department shall be used in determining requirements for, and adequacy of, biological reports.
The Riverside County Planning Department shall require compliance with the provisions of Mitigation Measure 4.6.5A as a condition for project approval. Ongoing (prior to project approval). Riverside County Planning Department.
4.6.5B Identify local and regional habitat patterns that provide movement routes for wildlife or where opportunities exist to establish movement routes between isolated habitat patches. The baseline data of the Western Riverside County MSHCP provides a biologically sound depiction of habitat linkages that would provide wildlife movement routes between existing biological reserves and other conservation lands. Avoid impacts that would eliminate, substantially constrict, or substantially inhibit wildlife movement, or acquire land that would establish movement routes between isolated habitat patches and create or restore habitat to reestablish the connection. Where on-site habitat preservation would not provide meaningful mitigation either for affected species or for habitat connectivity, off-site mitigation shall be implemented through the acquisition of lands that provide for regional habitat connectivity. Implementation of the mitigation measure shall include provisions for the preservation of such areas in perpetuity. The Riverside County Planning Department shall develop a wildlife movement corridor map that is available to the public. Ongoing (prior to project approval). Riverside County Planning Department.
4.6.6A Comply with Riverside County Planning Department Biological Report Guidelines to include an analysis of the potential for a proposed project to result in direct loss of oak-trees or alteration of natural processes (e.g., hydrology) resulting in indirect loss of oak trees. Under the Planning Department Guidelines, biological reports must be conducted as follows:

a. Reports must be prepared by a biologist on the County's list of qualified consultants.

b. The County Planning Department must be notified in advance that a report will be prepared for a specific project.

c. The report must include a signed certification attesting to the report contents.

d. The report must include specific information as to the type of survey (e.g., General Biological Resources Assessment, Habitat Assessment, etc.), site location, property owner, principal investigator, and contact information for participants in the field surveys.

e. The report must include specified attachments (summary sheet, level of significance checklist, biological resources/project footprint map, and site photos).

f. The report must include information on literature sources (e.g., California Natural Diversity Data Base, California Department of Fish and Game, U.S. Fish and Wildlife Service, and environmental documents for nearby projects).

g. The report must include a description of surveys, including timing, personnel, and weather conditions.

h. The report must include a description of site conditions including plant and wildlife habitat, disturbances, and sensitive elements.

i. The report must include an assessment of anticipated project impacts and a discussion of mitigation.

j. The report must include a list of all species observed or detected and a recommendation for any additional focused surveys that may be necessary.

The above list is a summary of the County's guidelines, the actual guidelines available from the Planning Department shall be used in determining requirements for, and adequacy of, biological reports.
The Riverside County Planning Department shall require compliance with the provisions of Mitigation Measure 4.6.6A as a condition for project approval. Ongoing (prior to project approval). Riverside County Planning Department.
4.6.6B Comply with Oak Tree Management Guidelines, including the use of replacement plantings with acorns or oak saplings when it is determined to be biologically sound and appropriate to do so. The Riverside County Planning Department shall require compliance with the provisions of Mitigation Measure 4.6.6B as a condition for project approval. Ongoing (prior to project approval). Riverside County Planning Department.
4.6.7A Comply with Riverside County Planning Department Biological Report Guidelines to include an analysis of the potential for a proposed project to result in alteration of habitat or natural processes that would result in the direct or indirect mortality of listed, proposed, or candidate species or that would result in loss, fragmentation, or isolation of sensitive habitat(s). Under the Planning Department Guidelines, biological reports must be conducted as follows:

a. Reports must be prepared by a biologist on the County's list of qualified consultants.

b. The County Planning Department must be notified in advance that a report will be prepared for a specific project.

c. The report must include a signed certification attesting to the report contents.

d. The report must include specific information as to the type of survey (e.g., General Biological Resources Assessment, Habitat Assessment, etc.), site location, property owner, principal investigator, and contact information for participants in the field surveys.

e. The report must include specified attachments (summary sheet, level of significance checklist, biological resources/project footprint map, and site photos).

f. The report must include information on literature sources (e.g., California Natural Diversity Data Base, California Department of Fish and Game, U.S. Fish and Wildlife Service, and environmental documents for nearby projects).

g. The report must include a description of surveys, including timing, personnel, and weather conditions.

h. The report must include a description of site conditions including plant and wildlife habitat, disturbances, and sensitive elements.

i. The report must include an assessment of anticipated project impacts and a discussion of mitigation.

j. The report must include a list of all species observed or detected and a recommendation for any additional focused surveys that may be necessary.

The above list is a summary of the County's guidelines, the actual guidelines available from the Planning Department shall be used in determining requirements for, and adequacy of, biological reports.
The Riverside County Planning Department shall require compliance with the provisions of Mitigation Measure 4.6.7A as a condition for project approval. Ongoing (prior to project approval). Riverside County Planning Department.
4.6.7B Avoid or minimize interruption of natural processes in local ecosystems. The Riverside County Planning Department shall require compliance with the provisions of Mitigation Measure 4.6.7B as a condition for project approval. Ongoing (prior to project approval). Riverside County Planning Department.
4.6.7C Identify local and regional habitat patterns whereby sensitive habitats are connected or where opportunities exist to reconnect isolated patches of sensitive habitat. Avoid impacts that would fragment sensitive habitat, or acquire land that would reconnect isolated habitat patches and create or restore habitat to reestablish the connection. Implementation of the mitigation measure shall include provisions for the preservation of such areas in perpetuity. The Riverside County Planning Department shall make available to the public a map showing biologically sensitive habitat in the County. The Riverside County Planning Department shall ensure that proposed development does not fragment sensitive habitat as part of CEQA review. Ongoing (prior to project approval). Riverside County Planning Department.
4.6.7D Construct facilities to treat non-point source runoff outside natural stream systems thereby allowing only treated runoff to enter natural stream systems. Treatment facilities may be mechanical (i.e., filtration devices within storm drain systems), biological (i.e., constructed wetlands at storm drain out-falls), or a combination of the two means. The Riverside County Planning Department shall require compliance with the provisions of Mitigation Measure 4.6.7D as a condition for project approval. Ongoing (prior to project approval). Riverside County Planning Department.
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.
The project proponent shall incorporate Mitigation Measure 4.5.1A in the Construction Contractor's grading plans and submit said grading plans to the County for review and approval. Ongoing (prior to project approval). Riverside County Planning Department.
Cultural Resources
4.7.1A If human remains are encountered during a public or private construction activity, State Health and Safety Code 7050.5 states that no further disturbance shall occur until the Riverside County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. The Riverside County Coroner must be notified within 24 hours.

a. If the coroner determines that the burial is not historic, but prehistoric, the Native American Heritage Commission (NAHC) must be contacted to determine the most likely descendent (MLD) for this area. The MLD may become involved with the disposition of the burial following scientific analysis.
The project proponent shall incorporate Mitigation Measure 4.5.1A in the Construction Contractor's grading plans and submit said grading plans to the County for review and approval. Ongoing (prior to grading permit issuance). Riverside County Building and Safety Department.
4.7.1B Avoidance is the preferred treatment for cultural resources. Where possible, project plans shall be developed to allow avoidance of cultural resources. Where avoidance of construction impacts is possible, capping of the cultural resource site and avoidance planting (e.g., planting of prickly pear cactus) shall be employed to ensure that indirect impacts from increased public availability to the site are avoided. Where avoidance is selected, cultural resource sites shall be placed within permanent conservation easements or dedicated open space. The Riverside County Building and Safety Department and Riverside County Parks and Open Space District shall require Construction Contractors to comply with the provisions of Mitigation Measure 4.5.1A as a condition of grading permit issuance. Ongoing (prior to grading permit issuance). Riverside County Building and Safety Department.
4.7.1C If avoidance and/or preservation in place of cultural resources is not possible, the following mitigation measures shall be initiated for each impacted site:

a. A participant-observer from the appropriate Indian Band or Tribe shall be used during archaeological testing or excavation in the project site.

b. Prior to the issuance of a grading permit for the project, the project proponent shall develop a test level research design detailing how the cultural resource investigation shall be executed and providing specific research questions that shall be addressed through the excavation program. In particular, the testing program shall characterize the site constituents, horizontal and vertical extent, and, if possible, period of use. The testing program shall also address the California Register and National Register eligibility of the cultural resource and make recommendations as to the suitability of the resource for listing on either Register. The research design shall be submitted to the County of Riverside Regional Park and Open-Space District for review and comment. For sites determined, through the Testing Program, to be ineligible for listing on either the California or National Register, execution of the Testing Program will suffice as mitigation of project impacts to this resource.

c. After approval of the research design and prior to the issuance of a grading permit, the project proponent shall complete the excavation program as specified in the research design. The results of this excavation program shall be presented in a technical report that follows the County of Riverside outline for Archaeological Testing. The Test Level Report shall be submitted to the County of Riverside Regional Park and Open-Space District for review and comment. If cultural resources that shall be affected by the project are found ineligible for listing on the California or National Register, test level investigations will have depleted the scientific value of the sites and the project can proceed.

d. If the resource is identified as being potentially eligible for either the California or National Register, and project designs cannot be altered to avoid impacting the site, a treatment program to mitigate project effects shall be initiated. A Treatment Plan detailing the objectives of the Treatment Program shall be developed. The Treatment Plan shall contain specific, testable hypotheses relative to the sites under study and shall attempt to address the potential of the sites to address these research questions. The Treatment Plan shall be submitted to the County of Riverside Regional Park and Open-Space District for review and comment.

e. After approval of the Treatment Plan, the Treatment Program for affected, eligible sites shall be initiated. Typically a treatment program involves excavation of a statistically representative sample of the site to preserve those resource values that qualify the site as being eligible for the California or National Register. At the conclusion of the excavation or research program, a Treatment Report, following the outline of the County of Riverside for Archaeological Mitigation or Data Recovery, shall be developed. This data recovery report shall be submitted to the County of Riverside Regional Park and Open-Space District for review and comment.
The Riverside County Building and Safety Department shall require Construction Contractors to comply with the provisions of Mitigation Measure 4.5.1A as a condition of grading permit issuance. Ongoing (prior to grading permit issuance). Riverside County Building and Safety Department.
Energy
4.8.1A The County shall review all development proposals prior to the approval of development plans to guarantee that sufficient energy resources and facilities are available to supply adequate energy to the proposed project and associated uses. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.8.1A prior to project approval. Ongoing (during plan review process). Riverside County Building and Safety Department.
4.8.1B The County shall review all development plans prior to approval to determine if conservation and efficiency standards of Title 24 are met and are incorporated into the design of the proposed project. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.8.1A prior to project approval. Ongoing (during plan review process). Riverside County Building and Safety Department.
Flood and Dam Inundation Hazards
4.9.1A LOMA and LOMR-F are documents issued by FEMA that officially remove a property and/or structure from a special flood hazard area of a Flood Insurance Rate Maps (FIRM). These letters shall be accepted by Riverside County where applicable. Riverside County Flood Control shall comply with Mitigation Measure 4.9.1A. Ongoing. Riverside County Flood Control.
4.9.1B Riverside County shall prohibit alteration of floodways and channelization unless alternative methods of flood control are found to be technically, economically, and practicably infeasible. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.9.1B prior to project approval. Ongoing (prior to project approval). Riverside County Building and Safety Department.

Riverside County Flood Control.
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, concentration of flows, and adverse impacts to water quality from point and nonpoint sources of pollution. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.9.1B prior to project approval. Ongoing. Riverside County Flood Control.
4.9.1.D Riverside County shall require the 10-year flood flows to be contained within the top of curbs and the 100-year flood flows within the street rights-of-way. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.9.1d prior to project approval. Ongoing (prior to project approval). Riverside County Building and Safety Department.

Riverside County Flood Control.
4.9.2A Riverside County shall require that all structures (residential, commercial, and industrial) be flood-proofed from the 100-year storm flows. In some cases this may involve elevating the finished floor more than 1 foot. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.9.2A prior to project approval. Ongoing (prior to issuance of building permits). Riverside County Building and Safety Department.

Riverside County Flood Control.
4.9.2B Riverside County shall require that fully enclosed areas that are below finished floors have openings to equalize the forces on both sides of the walls. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.9.2B prior to project approval. Ongoing (prior to issuance of building permits). Riverside County Building and Safety Department.

Riverside County Flood Control.
4.9.2C Riverside County shall require that for agricultural, recreation, or other low-density uses, flows are not obstructed and that upstream and downstream properties are not adversely affected by increased velocities, erosion backwater effects, or concentration of flows. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.9.2C prior to project approval. Ongoing (prior to project approval). Riverside County Building and Safety Department.
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 may allow development into the floodway fringe. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.9.2D prior to project approval. Ongoing (prior to project approval). Riverside County Building and Safety Department.

Riverside County Flood Control .
Geology and Slope Stability
4.10.1A Before a project is approved or otherwise permitted within an Alquist-Priolo Zone, County Fault Zone, within 150 feet of any other active or potentially active fault mapped in a published United State Geologic Survey (USGS) or CGS reports, or within other potential earthquake hazard area (as determined by the County Geologist), a site-specific geologic investigation shall be prepared to assess potential seismic hazards resulting from development of the project site. Where and when required, the geotechnical investigation shall address the issue(s), hazard(s), and geographic area(s) determined by the County Geologist to be relevant to each development. The site-specific geotechnical investigation shall incorporate up-to-date data from government and non-government sources.

Based on the site-specific geotechnical investigation, no structures intended for human occupancy shall be constructed across active faults.

This site-specific evaluation and written report shall be prepared by a licensed geologist and shall be submitted to the County Geologist for review and approval prior to the issuance of building permits. If an active fault is discovered, any structure intended for human occupancy shall be set back at least 50 feet from the fault. A larger or smaller setback may be established if such a setback is supported by adequate evidence as presented to and accepted by the County Geologist.
The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.10.1A prior to project approval. Ongoing (prior to project approval). Riverside County Building and Safety Department.

County Geologist.
4.10.2A The design and construction of structures and facilities shall adhere to the standards and requirement detailed in the California Building Code (California Code of Regulations, Title 24), County Building Code, and/or professional engineering standards appropriate for the seismic zone in which such construction may occur. Conformance with these design standards shall be enforced through building plan review and approval by the Riverside County Department of Building and Safety prior to the issuance of building permits for any structure or facility. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.10.2A prior to project approval. Ongoing (prior to issuance of building permits). Riverside County Building and Safety Department
4.10.2B As determined by the County Geologist, a site-specific assessment shall be prepared to ascertain potential ground shaking impacts resulting from development. The site-specific ground shaking assessment shall incorporate up-to-date data from government and non-government sources and may be included as part of any site-specific geotechnical investigation required in Mitigation Measure 4.10.1A. The site-specific ground shaking assessment shall include specific measures to reduce the significance of potential ground shaking hazards.

This site-specific ground shaking assessment shall be prepared by a licensed geologist and shall be submitted to the County Geologist for review and approval prior to the issuance of building permits.
The Riverside County Geologist shall review the ground shaking assessment for compliance with the requirements of Mitigation Measure 4.10.2B. Ongoing (prior to issuance of building permits). Riverside County Building and Safety Department County Geologist
4.10.2C The standards stated in Mitigation Measures 4.10.2A and 4.10.2B shall apply to any structure or facility that undergoes, expansion, remodeling, renovation, refurbishment or other modification. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.10.2C prior to project approval. Ongoing (during plan review process). Riverside County Building and Safety Department County Geologist
4.10.3A As determined by the County Geologist, a site-specific assessment shall be prepared to ascertain potential liquefaction impacts resulting from development. The site-specific liquefaction assessment shall incorporate up-to-date data from government and non-government sources and may be included as part of any site-specific geotechnical investigation required in Mitigation Measure 4.10.1A.

This site-specific ground shaking assessment shall be prepared by a licensed geologist and shall be submitted to the County Geologist for review and approval prior to the issuance of building permits.
The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.10.2C prior to project approval. Ongoing (prior to the issuance of building permits). Riverside County Building and Safety Department.

County Geologist.
4.10.3B Where development is proposed within an identified or potential liquefaction hazard area (as determined by the County Geologist), adequate and appropriate measures such as (but not limited to) design foundations in a manner which limits the effects of liquefaction, the placement of an engineered fill with low liquefaction potential, and the alternative siting of structures in areas with a lower liquefaction risk, shall be implemented to reduce potential liquefaction hazards. Any such measures shall be submitted to the Riverside County Geologist and the County Department of Building and Safety for review prior to the approval of the building permits. The Riverside County Geologist shall review development proposals for compliance with the requirements of Mitigation Measure 4.10.3B. Ongoing (prior to the issuance of building permits). Riverside County Building and Safety Department.

County Geologist.
4.10.7A Proponents of new development within Riverside County shall adhere to applicable policies and standards contained in the most recent version of the Uniform Building Code related to the construction of structures and facilities on expansive soils. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.10.7A prior to project approval. Ongoing (during plan review process). Riverside County Building and Safety Department.
4.10.8A New development within identified or potential (as determined by the County Geologist) wind hazard areas shall adhere to applicable provisions of County of Riverside Ordinance 484.2 or other local, state, or federal requirements established to control or limit the wind borne erosion of soil. Prior to the approval of development permits, the County Building and Safety Department shall confirm that the design of any proposed structure, facility, or use incorporates appropriate features to control and/or limit the windborne erosion of soil. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.10.8A prior to project approval. Ongoing (prior to issuance of development permits). Riverside County Building and Safety Department.

County Geologist.
4.10.9A Riverside County, where required, and in accordance with issuance of a National Pollutant Discharge Elimination System (NPDES) permit, shall require the construction and/or grading contractor for individual developments to establish and implement specific Best Management Practices (BMPs) at time of project implementation. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.10.9A prior to project approval. Ongoing (during plan review process). Riverside County Building and Safety Department.
4.10.9B Prior to any development within the County, a Grading Plan shall be submitted to the Riverside County Building and Safety Department and/or Riverside County Geologist for review and approval. As required by the County, the grading plan shall include erosion and sediment control plans. Measures included in individual erosion control plans may include, but shall not be limited to, the following:

a. Grading and development plans shall be designed in a manner which minimizes the amount of terrain modification.

b. Surface water shall be controlled and diverted around potential landslide areas to prevent erosion and saturation of slopes.

c. Structures shall not be sited on or below identified landslides unless slides are stabilized.

d. The extent and duration of ground disturbing activities during and immediately following periods of rain shall be limited, to avoid the potential for erosion which may be accelerated by rainfall on exposed soils.

e. To the extent possible, the amount of cut and fill shall be balanced.

f. The amount of water entering and exiting a graded site shall be limited though the placement of interceptor trenches or other erosion control devices.

g. Erosion and sediment control plans shall be submitted to the County for review and approval prior to the issuance of grading permits.
The Riverside County Building and Safety Department and County Geologist shall review all development proposals to verify compliance with Mitigation Measure 4.10.9B prior to project approval. Ongoing (prior to issuance of grading permit). Riverside County Building and Safety Department.

County Geologist.
4.10.9C Where required, drainage design measures shall be incorporated into the final design of individual projects on-site. These measures shall include, but will not be limited to:

a. Runoff entering developing areas shall be collected into surface and subsurface drains for removal to nearby drainages.

b. Runoff generated above steep slopes or poorly vegetated areas shall be captured and conveyed to nearby drainages.

c. Runoff generated on paved or covered areas shall be conveyed via swales and drains to natural drainage courses.

d. Disturbed areas that have been identified as highly erosive shall be (re)vegetated.

e. Irrigation systems shall be designed, installed, and maintained in a manner which minimizes runoff.

f. The landscape scheme for projects within the project site shall utilize drought-tolerant plants.

g. Erosion control devices such as rip-rap, gabions, small check dams, etc., may be utilized in gullies and active stream channels to reduce erosion.
The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.10.9C prior to project approval. Ongoing (prior to issuance of grading permit). Riverside County Building and Safety Department.
Hazardous Materials
No mitigation measures are needed.      
Mineral Resources
No mitigation measures are needed.      
Noise
4.13.1A Prior to the issuance of any grading plans, the County shall condition approval of subdivisions adjacent to any developed/occupied noise-sensitive land uses by requiring applicants to submit a construction-related noise mitigation plan to the County for review and approval. The plan should depict the location of construction equipment and how the noise from this equipment will be mitigated during construction of the project through the use of such methods as:

• The construction contractor shall use temporary noise attenuation fences where feasible, to reduce construction noise impacts on adjacent noise sensitive land uses.

• During all project site excavation and grading on site, the construction contractors shall equip all construction equipment, fixed or mobile, with properly operating and maintained mufflers, consistent with manufacturers' standards. The construction contractor shall place all stationary construction equipment so that emitted noise is directed away from sensitive receptors nearest the project site.

• The construction contractor shall locate equipment staging in areas that will create the greatest distance between construction-related noise sources and noise sensitive receptors nearest the project site during all project construction.

• The construction contractor shall limit all construction-related activities that would result in high noise levels to between the hours of 7:00 a.m. and 7:00 p.m. Monday through Saturday. No construction shall be allowed on Sundays and public holidays.
The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.13.1A prior to project approval. Ongoing (prior to issuance of grading permits). Riverside County Building and Safety Department.
4.13.1B The construction-related noise mitigation plan required shall also specify that haul truck deliveries be subject to the same hours specified for construction equipment. Additionally, the plan shall denote any construction traffic haul routes where heavy trucks would exceed 100 daily trips (counting those both to and from the construction site). To the extent practicable, the plan shall denote haul routes that do not pass sensitive land uses or residential dwellings. Lastly, the construction-related noise mitigation plan shall incorporate any other restrictions imposed by County staff. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.13.1B prior to project approval. Ongoing (prior to issuance of grading permits). Riverside County Building and Safety Department.
4.13.2A All new residential developments within the County shall conform to a noise exposure standard of 65 dBA Ldn for outdoor noise in noise-sensitive outdoor activity areas and 45 dBA Ldn for indoor noise in bedrooms and living/family rooms. New development, which does not and cannot be made to conform to this standard, shall not be permitted. The Riverside County Building and Safety Department shall review all residential development proposals to verify compliance with Mitigation Measure 4.13.2A prior to project approval. Ongoing (during plan review process, prior to plan approval). Riverside County Building and Safety Department

Riverside County Planning Department.
4.13.2B Acoustical studies, describing how the exterior and interior noise standards will be met, shall be required for all new residential developments with a noise exposure greater than 65 dBA Ldn. The studies shall also satisfy the requirements set forth in Title 24, Part 2, or the California Administrative Code, Noise Insulation Standards, for multiple family attached homes, hotels, motels, etc., regulated by Title 24. No development permits or approval of land use applications shall be issued until an acoustic analysis is received and approved by the County Planning Department. The Riverside County Planning Department shall review all development proposals to verify compliance with Mitigation Measure 4.13.2B prior to project approval. Ongoing (prior to issuance of development permits or approval of land use applications). Riverside County Planning Department.
4.13.2C The County shall require that proposed new commercial and industrial developments prepare acoustical studies, analyzing potential noise impacts on adjacent properties, when these developments abut noise-sensitive land uses. The County will require that all direct impacts to noise-sensitive land uses be mitigated to the maximum extent practicable. The Riverside County Planning Department and Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.13.2C prior to project approval. Ongoing (during plan review process). Riverside County Building and Safety Department.

Riverside County Planning Department.
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 Riverside County Planning Department and Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.13.2D prior to project approval. Ongoing (during plan review process). Riverside County Planning Department.
4.13.3A Acoustical studies shall be required for all new noise-sensitive projects that may be affected by existing noise from stationary sources. The Riverside County Planning Department and Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.13.3A prior to project approval. Ongoing (during plan review process). Riverside County Building and Safety Department.

Riverside County Planning Department.
4.13.3B To permit new development of residential and noise-sensitive land uses where existing stationary noise sources exceed the County's noise standards, effective mitigation measures shall be implemented to reduce noise exposure to or below the allowable levels of the zoning code/noise control ordinance. The Riverside County Planning Department and Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.13.3B prior to project approval. Ongoing (during plan review process, prior to project approval). Riverside County Building and Safety Department.

Riverside County Planning Department.
4.13.3C No industrial facilities shall be constructed within 500 feet of any commercial land uses or within 2,800 feet of any residential uses without the preparation of a noise impact analysis. This analysis shall document the nature of the industrial facility as well as "noise producing" operations associated with that facility. Furthermore, the analysis shall document the placement of any existing or proposed commercial or residential land uses situated within the noted distances. The analysis shall determine the potential noise levels that could be received at these commercial and/or residential land uses and specify measures to be employed by the industrial facility to ensure that these levels do not exceed County noise requirements. Such measures could include, but are not limited to, the use of enclosures for noisy pieces of equipment, the use of noise walls and/or berms for exterior equipment and/or on-site truck operations, and/or restrictions on hours of operations. No development permits or approval of land use applications shall be issued until an acoustic analysis is received and approved by the County staff. The Riverside County Planning Department and Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.13.3C prior to project approval. Ongoing (during plan review process, prior to project approval). Riverside County Building and Safety Department.

Riverside County Planning Department.
4.13.4A All new residential developments within the County shall conform to a noise exposure standard of 65 dBA Ldn for outdoor noise in noise-sensitive outdoor activity areas and 45 dBA Ldn for indoor noise in bedrooms and living/family rooms. New development, which does not and cannot be made to conform to this standard, shall not be permitted. The Riverside County Building and Safety Department shall review all residential development proposals to verify compliance with Mitigation Measure 4.13.4A prior to project approval. Ongoing (during plan review process, prior to project approval). Riverside County Building and Safety Department.
4.13.4B Acoustical studies, describing how the exterior and interior noise standards will be met, shall be required for all new residential developments with a noise exposure greater than 65 dBA Ldn. The studies should also satisfy the requirements set forth in Title 24, Part 2, or the California Administrative Code, Noise Insulation Standards, for multiple family attached homes, hotels, motels, etc., regulated by Title 24. The Riverside County Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.13.4B prior to project approval. Ongoing (during plan review process, prior to project approval). Riverside County Building and Safety Department.
Parks and Recreation
No mitigation measures are needed.      
Public Services
4.15.2A The County shall require as a part of the development review process, proponents of new businesses, recreational, and commercial land uses such as shopping centers, health clubs, large hotels over 200 rooms, convention centers, and commercial recreational activities be required to provide on-site security. The Riverside County of Building and Safety Department shall review all development proposals to verify compliance with Mitigation Measure 4.15.2A prior to project approval. Ongoing (prior to project approval). Riverside County Planning Department.
4.15.2B The Transportation and Land Management Agency shall inform the Riverside County Sheriff's Department of the existence of all new homeowner associations within the County. The Riverside County Sheriff's Department shall coordinate with homeowners associations to establish a Neighborhood Watch Program. The Riverside County Transportation and Land Management Agency shall assign staff to track the establishment of homeowners associations. The establishment of any new associations will be reported to the County Sheriff's Department, which will be responsible for coordinating with the new associations to establish Neighborhood Watch Programs. Ongoing (as new homeowner associations are established). Riverside County Transportation and Land Management Agency.
4.15.2C Riverside County shall meet and maintain a goal of 1.5 sworn officers per 1,000 population, as recommended by the International City Managers' Association. The Riverside County Sheriff's Department shall evaluate yearly the number of sworn officers per 1,000 population. If and when the ratio falls short of 1.5 officers per 1,000 population, the Sheriff's Department shall determine what is required to attain/maintain the recommended ratio. Ongoing (to be revisited as new census information is available). Riverside County Sheriff's Department.
4.15.2D The County shall require the development applicant to pay the County Sheriff's established development mitigation fee prior to issuance of a certificate of occupancy on any structure as they are developed. The fees are for the acquisition and construction of public facilities. The Riverside County Transportation and Land Management Agency shall review all development proposals to verify compliance with Mitigation Measure 4.15.2D prior to project approval. Ongoing (during plan review process, prior to issuance of a certificate of occupancy). Riverside County Transportation and Land Management agency.
4.15.3A Riverside County shall work with its franchise hauling companies to expand curbside and commercial recycling services throughout the unincorporated area of the County. The Riverside County Waste Management Department shall be responsible for coordinating with the franchise hauling companies to increase the opportunities for curbside and commercial recycling services. Ongoing (following adoption of the 2002 Riverside County General Plan). Riverside County Waste Management Department.
4.15.3B Riverside County shall follow State regulations in implementing the goals, policies, and programs identified in the Riverside County Integrated Waste Management Plan in order to achieve and maintain a 50 percent reduction in solid waste disposal through source reduction, reuse, recycling, and composting. The Riverside County Waste Management Department shall be responsible for implementing and enforcing the goals, policies, and programs identified in the Riverside County Integrated Waste Management Plan. Ongoing (annually). Riverside County Waste Management Department.
4.15.3.C In accordance with State regulations, Riverside County shall prepare an annual report of progress for the CIWMB to determine the County's progress toward meeting its diversion goals and objectives, to project the County's waste disposal needs, and to determine if any of the elements that comprise the Riverside CIWMP require revision to include additional disposal capacity, reflect new or changed local and regional solid waste management issues, or reflect new or changed goals and objectives. The Riverside County Waste Management Department shall be responsible for the preparation of an annual report of progress for the CIWMB as described in Mitigation Measure 4.15.3C. Ongoing (annually). Riverside County Waste Management Department.


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