ATTACHMENT_1_EXHIBIT_A_FEIR (Section 2 Comments and Responses)The Gateway at Grand Terrace Specific Plan
Final Environmental Impact Report Section 2.0 – Comments and Responses to Draft EIR
City of Grand Terrace July 2024
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Section 2.0 Comments and Responses to Draft EIR
This section includes all comments received by the City on the Draft Environmental Impact Report,
including written comments and comments submitted via email to the City. The City circulated the Draft
EIR for a minimum 45-day review period as required by CEQA. The review period ran from June 26, 2023
through August 14, 2023.
2.1 INTRODUCTION TO COMMENTS AND RESPONSES
In accordance with CEQA Guidelines §15132, Table 2-1: Comments from Public Agencies and
Organizations below provides a list of those parties that provided written comments on the Draft EIR
during the public review period. Copies of the written comments are provided in this section and have
been annotated with the assigned letter along with a number for each comment. Each comment is
followed by a corresponding written response.
Table 2-1: Comments from Public Agencies and Organizations
Reference Commenter Date
A Agua Caliente Band of Cahuilla Indians
Claritsa Duarte, Cultural Resources Analyst July 17, 2023
B Augustine Band of Cahuilla Indians
Geramy Martin, Tribal Secretary June 30, 2023
C City of Colton
Mario Suarez, AICP, CNU-A August 14, 2023
D City of Riverside
Matthew Taylor, Principal Planner August 14, 2023
E Colton Joint Unified School District
Owen Chang, Director of Facilities Planning and Construction August 14, 2023
F
Pala Band of Mission Indians
John Pepper, Lead Cultural Resources Monitor
Shasta C. Gaughen, PhD
August 10, 2023
G San Manuel Band of Mission Indians
Bonnie Bryant June 29, 2023
H South Coast Air Quality Management District
Evelyn Aguilar, Air Quality Specialist, CEQA-IGR June 30, 2023
I Southwest Mountain States Regional Council of Carpenters
Mitchell M. Tsai, Attorney At Law June 26, 2023
J Supporters Alliance for Environmental Responsibility
Lozeau Drury LLP - Rebecca Davis August 10, 2023
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Comment Letter A – Agua Caliente Band of Cahuilla Indians
Claritsa Duarte, Cultural Resources Analyst
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Responses to Comment Letter A – Agua Caliente Band of Cahuilla Indians
Claritsa Duarte, Cultural Resources Analyst
A-1 The comment includes a request for a copy of the records search with associated survey
reports and site records from the information center and a copy of any cultural resource
document for the Project. No response is warranted.
A-2 The City provided the commentor a Dropbox link of the requested documents. No further
response is warranted.
A-3 The commenter requested the files for a second time. No response is warranted.
A-4 The City provided the commentor another Dropbox link of the requested documents. No
further response is warranted.
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Comment Letter B – Augustine Band of Cahuilla Indians
Geramy Martin, Tribal Secretary
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Responses to Comment Letter B – Augustine Band of Cahuilla Indians
Geramy Martin
B-1 Email transmittal of Comment Letter. No response required.
B-2 This comment includes an updated mailing address. No response is warranted.
B-3 The comment acknowledges the City’s effort to enter into consultation regarding the Project’s
potential to impact significant cultural resources. No response is warranted.
B-4 The commentor requested that the City notify the Augustine Band of Cahuilla Indians in the
event that any cultural resources are discovered during the development of the Project. As
stated in Draft EIR Section 4.16, Tribal Cultural Resources (page 4.16-10), the Project would
implement MM CUL-2, and MMs TCR-1 through TCR-3 to reduce impacts to tribal cultural
resources. As requested by the commentor, in the event that Native American cultural
resources are discovered during project activities, MM TCR-1 would require that all work in
the immediate vicinity of the find (within a 60-foot buffer) the Augustine Band of Cahuilla
Indians tribe will be notified and work will cease and a qualified archaeologist meeting
Secretary of Interior standards shall be hired to assess the find.
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Comment Letter C – City of Colton
Mario Suarez, AICP, CNU-A
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Responses to Comment Letter C – City of Colton
Mario Suarez, AICP, CNU-A
C-1 This comment includes introductory statements and a request for notification of all future
public meetings, copies of future staff reports and CEQA responses to comments. The City will
send all future notifications regarding the Project to the City of Colton.
C-2 The comment requests that a wastewater collection system study be submitted for review and
approval by the City of Colton and states that additional infrastructure review may be required
based on the results of the study. The Sewer Improvement Plan, prepared by KWC Engineers,
was submitted to the City of Colton for review and approval on October 2, 2023. The Sewer
System Analysis (May 2023), also prepared by KWC Engineers, was also submitted to the City
of Colton on November 6, 2023. In addition, the DEIR also includes the same Sewer System
Analysis in Appendix K2. The report in Appendix K2 (also attached) presents the planning
criteria used to estimate the sewage flows and evaluate the recommended sewer system
improvements required for the Project. The criteria utilized in the study are in accordance with
the July 2016 City of Colton Sewer Master Plan. See DEIR pages 4.17-2 to -3; -11 to -14; DEIR
Appendix K2. The results of the study indicate that the existing local collector sewers have
adequate capacity to serve the project.
C-3 This comment states that the developer shall provide rehabilitation such as lining of the
existing 18” sewer main crossing the i-215 freeway that coveys all flow coming from the
Project. As future development projects are submitted to the City of Grand Terrace, the City
will require developers to coordinate with the City of Colton regarding sewer system
requirements which may include the re-lining of the existing 18” sewer main crossing the I-215
freeway that conveys flows from the City of Grand Terrace and the Project.
C-4 The comment states that the Applicant, which it identifies as the City of Grand Terrace, shall
construct facilities to mitigate traffic impacts identified in the Transportation Impact Analysis
(TIA). As explained in Section 3.3 of the DEIR, the Project applicant is Lewis Management
Corporation. The City of Grand Terrace is the Lead Agency for purposes of CEQA. Pursuant to
Draft EIR Section 4.15, Transportation, the TIA (Draft EIR Appendix J1) included recommended
improvements for study intersections that would operate below applicable LOS policies in
given jurisdictions. These recommendations include a combination of fee payments to
established programs, construction of specific improvements, payment of a fair-share
contribution toward future improvements, or a combination of these approaches. The
improvements to operational conditions are consistent with Grand Terrace General Plan (GP)
LOS policies. However, as explained in DEIR sections 4.15-1 to 2 and 4.15-7 to 8, LOS and similar
measures of traffic congestion are no longer considered an impact under CEQA. The
recommended improvements are not considered mitigation measures under CEQA but are
considered by the City as part of its General Plan policies.
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C-5 The comment states that the applicant shall optimize signal timing in the PM peak hour for the
intersection of South La Cadena Drive at Barton Road as required for Opening Year (2024) plus
Project Phase One Conditions. Refer to Response to Comment C-4 above.
C-6 The comment states that applicant shall implement the required improvements for Opening
Year (2024) Plus Project Phase One at the intersection of South Iowa Avenue and Main Street.
Refer to Response to Comment C-4 above.
C-7 The comment states that additional detailed analysis is needed during final design that
considers turning movement volumes at adjacent intersection/driveways, evaluates site
distance, and evaluates available gaps before the design should be implemented. Refer to
Response to Comment C-4 above. The Project’s Traffic Study (Appendix J1) noted that the
identified intersection improvements are conceptual and are not required by CEQA but are
considered by the City under its General Plan. Detailed design would be conducted should any
of these improvements or others be selected for implementation based on future analyses.
C-8 The comment states that the applicant shall add a westbound left-turn lane at the intersection
of South La Cadena Drive at Barton Road as required for Opening year (2024) Plus Project Phase
One and Two Conditions. Refer to Response to Comment C-4 above.
C-9 The comment states that the applicant shall implement the required improvements for
Opening Year (2040) Plus Project Phase One and Two Conditions at the intersection of South
Iowa Avenue and Main Street. Refer to Response to Comment C-4 above.
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Comment Letter D – City of Riverside
Matthew Taylor, Principal Planner
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Responses to Comment Letter D – City of Riverside
Matthew Taylor, Principal Planner
D-1 This comment includes an introductory statement and a brief description of the Project
reviewed by the City. No response is warranted.
D-2 This comment states the large freeway-oriented sign identified in the Specific Plan Section 5.5
is not included in Draft EIR Project Description (Section 3.0) and it is unclear whether or not
the sign is proposed as part of the Project. The comment also states that if the sign is proposed
as part of the Project, the Project Description should be revised to specify the proposed
location, height, medium, and nature of the sign.
Although The Gateway at Grand Terrace Specific Plan states that the Specific Plan area can
contain a large freeway-oriented sign; no sign would be developed upon approval of the
Project or certification of this FEIR. Analysis of any such sign in the Draft EIR would therefore
have been speculative. Pursuant to The Gateway at Grand Terrace Specific Plan Section 1.4,
Specific Plan Authority, it is intended that site and architectural review, grading permits and
building permits, or any other action requiring ministerial or discretionary approval be
consistent with the Specific Plan. Therefore, if a future applicant decides to construct the large
freeway-oriented sign, the sign would be designed in accordance with The Gateway at Grand
Terrace Specific Plan zone development standards and guidelines, regulations, and
infrastructure requirements, and require City (and possibly Caltrans) review and approval
under Grand Terrace MC §18.80.060 (Sign Permit).
D-3 The comment states that Draft EIR Section 4.1 Aesthetics should be revised to assess potential
impacts to aesthetics associated with the large freeway-oriented sign. Refer to Response to
Comment D-2 above. As explained in Draft EIR Section 4.1, Aesthetics (page 4.1-11), all future
Project development would be subject to Grand Terrace MC §§18.60.040, 18.74.080, 18.80060
and 18.80.140 which establish lighting standards and illumination requirements for sign
permits that would reduce the impacts from light and glare. Under these code provisions,
“no sign, or lighting fixture would create illumination on adjacent property that exceeded three
foot-candles.” Draft EIR at p. 4.1-11; Grand Terrace MC 18.74.080. Any future development
proposal that would include a freeway-oriented sign would be required to prepare a Sign Plan
inclusive of lighting for City review and approval pursuant to the cited Grand Terrace MC
provisions. Therefore, any impacts from a future potential freeway-oriented sign, which is not
currently proposed, would not have aesthetic impacts and if a sign were to be proposed in the
future that does not comply with these standards, CEQA review would occur at that time.
D-4 The commenter states that consultation with the local transit service provider as part of
MM AQ-2 “is not an effective or adequate measure to reduce vehicle trip generation
associated with the Project.” Requiring the Project Applicant to consult with local transit
service provider is only one step in the development of an effective TDM plan, and enables the
transit provider to identify potential transit access needs. See DEIR 4.2-26. The language of
MM AQ-2 does more than require consultation, it also requires the Project to develop a
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Transportation Demand Management (TDM) plan to reduce mobile emissions from commuter
trips by encouraging alternative modes of transportation such as carpooling, taking transit,
walking and biking. MM AQ-2 requires the TDM to provide ride-matching assistance,
carpooling, and bicycle facilities. The emissions reductions from MM AQ-2 were quantified in
CalEEMod 2022 using the methods, criteria, and formulas within the California Air Pollution
Control Officers Association (CAPCOA) Handbook for Analyzing Greenhouse Gas Emissions
Reduction, Assessing Climate Vulnerabilities, and Advancing Health and Equity: Designed for
Local Governments, Communities, and Project Developers (2021) (Draft EIR at p. 4.7-18), and
result in less than 1% reduction in operational emissions. MM AQ-2 has been refined to require
the emissions reduction shown in Table 4.2-10. The TDM plan shall reduce emissions
consistent with Table 4.2-10 and be approved by the City of Grand Terrace prior to the issuance
of building permits and incorporated into the Project’s Codes Covenants and Restrictions
(CC&Rs). Refer to FEIR Section 3.0, Errata to the Draft EIR. Despite adopting all identified
feasible mitigation measures, the operational emissions remain significant and unavoidable,
see Table 4.7-3. The City of Grand Terrace must approve the requirements of a future TDM
plan prior to issuing building permits, ensuring the Applicant will develop a TDM plan that
meets the EIR requirements.
D-5 The comment states that the Project Description does not address whether the Project intends
to demolish the on-site housing units and that the Draft EIR needs to address applicable
California statutes related to the preservation and replacement of the existing housing. The
Project’s impacts concerning the six existing residential homes and displacement of the
associated population were disclosed and analyzed in Draft EIR Section 4.12, Population and
Housing. The correct number of existing nonconforming residential structures is five and the
correction has been made and clarified in the Errata of the Draft EIR. All five structures are
considered nonconforming as they are located in the area zoned as Commercial Manufacturing
(CM). As noted in the Errata to the Draft EIR, only four of the five existing nonconforming
residential structures within the Specific Plan boundary are occupied. The fifth nonconforming
structure is unoccupied and boarded up. One of the residences, located on Van Buren Street,
is not expected to be part of future residential development and will not be affected. The
other three occupied units in the current CM zone are within the proposed commercial area
of the Specific Plan. Currently, the landowners these three nonconforming residences are not
participating in the Specific Plan and no specific development is proposed on those parcels and
no demolition of those units is proposed at this time which has been clarified in the Errata to
the Draft EIR. As to whether these units are protected units under SB 8 and SB 330, these units
are not listed or registered as participating in any affordable housing program and are not deed
restricted as affordable units. Since the landowner of those units is not participating, the
income of the current residents cannot be obtained. If and when that landowner proposes a
nonresidential use and demolition of those residents, the SB 8 and SB 330 provisions will apply
at that time. As to no net loss of the two residential units that will be demolished, they are not
protected units and the Specific Plan provides for the future development of up to 695 housing
units, therefore, the requirement for no net loss in the number of residential units is more than
met by the project. Refer to Draft EIR Section 4.12, Impact 4.12-2, for further information.
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D-6 The comment states that the reference of the Gage Canal is incorrect. Additionally, the
comment states that the Riverside Canal is not a storm flow conveyance facility, and other
County Flood channels should be considered for storm water conveyance. The incorrect
mention of the ‘Gage Canal’ in Draft EIR Section 3.0 has been revised in FEIR Section 3.0, Errata
to the Draft EIR. Per Appendix A, Hydrology and Hydraulics Report Update, no discharge is
proposed to flow into the Riverside Canal and the canal will not receive any regional runoff
after the proposed basin is implemented. The existing connection will be removed after
construction of the proposed basin.
D-7 The comment states that 3.11 – Conceptual Storm Drain Plan is not consistent with the Draft
EIR text at page 3-12 or in Appendix H1. The text in the Draft EIR that refers to a second
connection from the basin in the Gage Canal has been revised; there would be no impacts to
the Gage Canal or the Riverside Canal, but to the Highgrove Storm Channel located adjacently
to the upstream end of the Riverside Canal. Refer to FEIR Section 3.0, Errata to the Draft EIR,
to see the revisions.
D-8 The comment states that no connections shall be permitted into the canal by the City of
Riverside. See Response to Comment D-7 above.
D-9 This comment states that Draft EIR Appendix H1’s flood routing analysis treats the Riverside
Canal as storm drain facility. Pursuant to Section 3.0, Errata, Appendix A, Hydrology and
Hydraulics Report Update of this FEIR, the flood routing analysis has been revised to remove
the Riverside Canal as a storm drain facility. No discharge is proposed to flow into the Riverside
Canal and the existing connection will be removed. Additionally, see FEIR Section 3.0 for errata
changes.
D-10 The comment states that the Project is proposing to use the Riverside Canal via POC#2/Node
200 to receive stormwater runoff, although stormwater runoff from Grand Terrace was never
permitted to be discharged into the canal. The City acknowledges that stormwater runoff from
Grand Terrace was never permitted to be discharged into the canal, or any of Riverside Public
Utility’s facilities. Refer to the updated Appendix A, Hydrology and Hydraulics Report Update,
found in Section 3.0, Errata, of this Final EIR, does not propose to use or connect to the
Riverside Canal. The Project will not discharge into the Riverside Canal.
D-11 The comment states that Exhibits 6 and 7 of Draft EIR Appendix H1 should be revised. The
exhibits have been updated in Appendix A, Hydrology and Hydraulics Report Update and no
longer display storm drain connections and ponding at Cage Park.
D-12 The comment states that the Riverside Canal is incorrectly referred to as the ‘Gage Canal.’ Edits
have been made to reflect the correction from “Gage Canal” to “Riverside Canal” where
applicable. Refer to Section 3.0 of this FEIR for those changes.
D-13 The comment states that, if a fire or severe flooding were to occur at Grand Terrace’s Battery
Energy Storage Facility Project, hazardous runoff could enter the Riverside Canal and Santa
Ana Riverbed, which could contaminate the groundwater basin used for water supply by local
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water wells. This comment has been noted. The Battery Storage System Facility Project is a
separate project by a different applicant. It is not located within the boundaries of The
Gateway at Grand Terrace Specific Plan area and is not part of the Project.
D-14 The comment refers to the hazards described in Comment D-13 and states that mitigation is
required to address these concerns. Please refer to Response to Comment D-13.
D-15 This comment contains concluding statements and therefore, no response is warranted.
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Comment Letter E – Colton Joint Unified School District
Owen Chang, Director of Facilities Planning and Construction
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Responses to Comment Letter E – Colton Joint Unified School District
Owen Chang, Director of Facilities Planning and Construction
E-1 This comment is an introductory statement and the commenter’s understanding of the Project.
No response is warranted.
E-2 Comment noted. No further response is warranted.
E-3 The City acknowledges the commenter’s breakdown of total number of students potentially
generated by the Project but the Project is considered programmatic and therefore, it is not
possible to determine the students at each grade level that would result from the Project’s
future population. As shown in Draft EIR Section 4.13, Public Services Table 4.13-3
(page 4.13-14), the Project was projected to generate an increased student population
demand in the City by approximately 456 potential students by using a demand factor for
student populations multiplied by 21.3 percent of persons under 18 years of age within the
City. Refer to the following responses for further details concerning the Project’s impact on the
Colton Joint Unified School District’s (CJUSD) facilities.
E-4 Comment noted. The City acknowledges the existing Category 3 status of Grand Terrace
Elementary and Terrace Hills Middle which indicates that they currently require “major
modernization, reconfiguration, and/or complete replacement,” and the Category 0 status of
Grand Terrace High School which indicates the school is in good condition. This comment does
not identify a specific concern with the adequacy of the Draft EIR or note a specific issue or
comment related to the Draft EIR’s environmental analysis but is noted and will be taken into
consideration by decision-makers.
E-5 Comment has been noted. The comment explains that planning is underway to upgrade the
schools, however because of budgetary concerns, not all desired upgrades are progressing. No
further response is required.
E-6 The comment states that, while the Project’s payment of school impact fees pursuant to
Education Code section 17620 would help fund some improvements, these fees would not be
sufficient to modernize Grand Terrace Elementary School and Terrace Hills Middle School with
state-of-the-art facilities and cites to the Colton Joint Unified School District’s (CJUSD) Fee
Justification Report for support while acknowledging that the Education Code limits school
impact fees, absent of the Project’s development. The comment asks the City and developer
to consider formation of a Mello-Roos District to help raise additional funds.
The comments regarding the funds required to make the CJUSD’s facilities state of the art are
noted, however the comments do not relate to CEQA matters. As described in the Draft EIR,
CEQA requires analyzing the Project’s potential public service impacts on schools based on
whether the Project could require the construction or expansion of existing public service
facilities resulting in a physical impact to the environment. Draft EIR Section 4.13.1. The Draft
EIR explains that the Project could result in approximately 456 new students in the CJUSD
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school system and notes that, with declining enrollment, the existing schools are expected to
have sufficient capacity to accommodate these new students (Draft EIR at p. 4.13-14). The
Draft EIR includes detailed discussion about the relevant regulatory provisions that apply to
schools in the context of development approvals (Draft EIR at p. 4.13-7 to -8) and the potential
impacts of the Project on school facilities. Impact 4.13-1(III), Draft EIR at pgs. 4.13-13 to -15.
As explained in Section 4.13.3 (Public Resources – Regulatory Setting) of the Draft EIR, various
Education and Government Code sections govern the school fees to be paid for development
projects. The Draft EIR explains that the Project applicant will be required to pay school fees
to the CJUSD in compliance with those state law provisions. Accordingly, the Draft EIR
concludes that the Project’s impacts to schools would be less than significant.
With respect to CJUSD’s suggestion that the Project applicant and City consider formation of a
Mello-Roos District to provide additional funds for school facilities since the need for additional
funding for schools is not specific to this project, instead the CJUSD could address additional
funding with additional school fees that apply to this project as well as others who generate
the need for schools.
E-7 The incorrect distance from the Project to Grand Terrace Elementary has been noted and
corrected. See FEIR Section 3.0, Errata to the Draft EIR.
E-8 The comment states that De Berry Street and Van Buren Street between their current western
terminus and Michigan Street are missing sidewalks and that students generated by the Project
would use these roads to get to school. As stated in the DEIR, the Project provides pedestrian
connections to Taylor/Commerce and which will have continual pedestrian access to Grand
Terrace High School and Grand Terrace Elementary for residents from the proposed project on
Van Buren Street, De Berry Street, and Michigan Street. Students generated by the Project
would use these roads to get to school. The Project will provide nearly one mile of new
sidewalks and bike lanes which will enhance safer pedestrian routes to Grand Terrace
Elementary and Grand Terrace High School.
For students to get to Terrace Hills Middle School from the Project’s residential development,
they would utilize Van Buren Street. Currently, there are existing sidewalks in between the
western terminus at the proposed new Taylor/Commerce extension to Mt. Vernon Avenue of
approximately 3,300 feet in total length. The Project would provide street improvements on
Van Buren Street within the Project boundary that would include a new sidewalk segment of
nearly 1,700 feet. Although the Project would add a significant amount of new sidewalks of
over 50% of the length of the existing sidewalks on Van Buren Street, there would still be a
small portion on Van Buren Street that would not have sidewalks. This portion is outside of the
Project area and approximately 550 feet in length, measuring west from where Van Buren
Street meets with Mt. Vernon Avenue. Due to the physical site constraints from overhead
powerlines and drainage pipes, it is infeasible to construct sidewalk in this portion along
Van Buren Street as additional right-of-way acquisition or condemnation would be required by
the City. Thus, the following Mitigation Measure will be added in the Errata to the Draft EIR:
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MM-TRA-1 Upon the City’s acquisition of the area on Van Buren Street necessary to connect
the project’s sidewalk to the remainder of Van Buren Street, the applicant will
pay its fair share of the cost of construction of that portion of the sidewalk.
As to other areas of Grand Terrace that have existing conditions described in the EIR, the City
of Grand Terrace, a member of SBCTA, has participated in the Phase I and Phase II of SBCTA’s
Regional Safe Routes to School (SRTS) Plan, which has identified eligible sidewalk and other
improvements outside the Project area that are eligible for SBCTA funding for future
improvements. The City will work to address these existing conditions that are not related to
the project.
E-9 The comment states that the both the EIR Appendix J1 and the Draft EIR inaccurately describe
sidewalks along De Berry Street west of Michigan Street and Van Buren Street west of
Michigan Street. The Draft EIR will be updated to correct the statement that, "De Berry Street
west of Michigan Street and Van Buren Street west of Michigan Street provide continuous
sidewalks." Refer to FEIR Section 3.0, Errata to the Draft EIR.
E-10 The comment states that the City of Grand Terrace Active Transportation Plan (ATP), which
includes Safe Routes to School Recommendations was prepared before publication of the
Gateway at Grand Terrace Specific Plan and Draft EIR and therefore, the Project was not
accounted for in the ATP. The comment states that two figures in the ATP should be updated
to reflect the pedestrian facilities that CJUSD believes would be required as a result of the
Project. The comment also asserts that the ATP’s recommendations regarding traffic calming,
increased safety, and pedestrian and bicycle safety infrastructure for Grand Terrace
Elementary School and Terrace Hills Middle School should be similarly updated.
As discussed in the Draft EIR, the ATP is a planning document adopted by the City in 2018 that
provides recommendations to support increased bicycling and walking within the City. Draft
EIR at p. 4.15-11. The Draft EIR identifies the ATP’s planned and recommended bicycle and
pedestrian facilities in the Project Area. See Draft EIR at pgs. 4.15-14 to -15.
The Draft EIR includes analysis of the proposed Project’s consistency with the ATP with respect
to its recommendations regarding bicycle and pedestrian facilities and concludes that the
Project is consistent with the ATP because of the Project’s incorporation of bicycle lanes and
pedestrian facilities. See Draft EIR at pgs. 4.15-14 to -15. With respect to the Safe Routes to
School Recommendations, the ATP includes recommendations for improving bicycle and
pedestrian accessibility and safety around the City’s schools. ATP at 78-87. With the exception
of specific bike lane suggestions, the ATP’s recommendations concerning schools are generally
high-level and include such items as installing stop signs and repairing sidewalks and the
Project is consistent with these recommendations. The comments recommendations
regarding other updates to the ATP are beyond the scope of the Project.
E-11 The comment states that the Project would directly contribute to the need for off-site
pedestrian facilities and thus the City should require the Project to include a Safe Routes to
School Plan specific to the Project that would amend the ATP with improvement
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recommendations along De Berry Street, Van Buren Street, and Michigan Street to be required
as part of the Project.
Please see Response to Comment E-10, above. Impact 4.15-1 evaluates whether the Project
conflicts with a program, plan, ordinance, or policy addressing the circulation system including
pedestrian facilities. Draft EIR 4.15-14. The Draft EIR’s analysis of Project with regard to this
impact found it would not conflict with the ATP. Draft EIR at pgs. 4.15-14 to -15. Commerce
Way would be constructed with pedestrian facilities (i.e., sidewalks, bicycle facilities) resulting
in a well-connected sidewalk network surrounding the Project. The Project also proposes
sidewalks along De Berry Street and Van Buren Street within the Project’s limits. Pedestrians
would be able to access the Project and other nearby land uses or facilities between Main
Street and Barton Road. Lastly, all roadways and pedestrian facilities would be designed
according to the development standards listed in the proposed Specific Plan. Therefore, the
Project would be compliant with the City’s ATP concerning pedestrian facilities. No additional
projects need to be added to the ATP and no fact-based evidence of inadequacies with the
Draft EIR analysis is presented in the comment.
E-12 The comment states that the projects described in the previous Response to Comment, E-11,
should be conditioned as part of Project approval and should be completed during Phase 1
when residential development occurs. Please see Response to Comments E-11, above.
E-13 The comment states that funding for the projects described in the previous Response to
Comment E-11, could be achieved through private development agreements and the
formation of a Mello-Roos District. Please see Response to Comments E-6, E-10 and E-11
above.
E-14 The comment states that the Draft EIR’s finding of consistency with the ATP is not
substantiated, specifically with respect to General Plan Circulation Element Goal 3.3 regarding
the Project providing a safe circulation system, and Goal 3.5 regarding the provision of efficient
alternative modes of travel for students to school.
Please see Response to Comment E-10 and E-11, above, regarding the Project’s consistency
with the ATP. Table 4.10-3 of the Draft EIR also includes a detailed analysis of the Project’s
consistency with the City’s General Plan. Draft EIR at pgs. 4.10-11 to -19. With respect to
General Plan Goal 3.3, the Draft EIR describes the Project’s consistency with policies regarding
parking and appearance; the Draft EIR also discusses consistency with Goal 3.1 with respect to
the Project’s circulation plan. Draft EIR at p. 4.10-12. Moreover, the Draft EIR’s discussion of
Impact 4.15-3 describes how the Project’s circulation plan would ensure the safety of the
Project. Draft EIR at p. 4.15-19; see also, Draft EIR at p. 3-14, p. 3-30 (Exhibit 3-12), p. 4.7-25,
p. 4.10-14, pgs. 4.10-20 to -22. In addition, as discussed in the Draft EIR, Grand Terrace
Municipal Code section 17.52.010 requires that any approved tentative tract maps conform to
the City’s General Plan, among other requirements. Draft EIR at 4.15-19.
With respect to consistency with General Plan Goal 3.5 regarding providing for efficient
alternative modes of travel, the Draft EIR includes an analysis of the Project’s consistency with
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this goal. Draft EIR at pgs. 4.10-12 to -13. Due to the Project’s recommended Travel Demand
Management measures, the Draft EIR concludes the Project would be consistent with this
General Plan Goal 3.5. Id. As explained in the Draft EIR, overall, the Project’s circulation plan –
including its bicycle and pedestrian components – would “reinforce a pedestrian-friendly
environment that includes new Class II on-street bike lanes, sidewalks and streets connecting
the commercial area with the residential neighborhoods, parks and schools.” Draft EIR at
p. 3-14. All of this substantiates the Draft EIR’s finding regarding Impact 4.15-1 and the ATP
and General Plan.
E-15 Please see Response to Comment, E-14, above. This comment states that without the off-site
improvements along routes to Grand Terrace Elementary, Terrace Hills Middle, and Grand
Terrace High pedestrian safety hazards would increase; however, no substantial data or
evidence is provided. Furthermore, the commenter states that the EIR did not substantiate
how the Project would not cause or increase hazards. Lastly, the commentor states that Impact
4.15-3 should be updated to address the increased pedestrian safety hazards along routes to
school.
As stated in Draft EIR Section 4.15 Transportation (page 4.15-19), the Project’s proposed
circulation improvements would be constructed as approved by the City Engineer and City’s
Fire Department pursuant to Grand Terrace MC Section 17.52.070, Street Design and
Chapter 17.16, and as part of the Project’s proposed tentative tract map approval. This would
ensure that future development within the Project would not significantly increase hazards
due to a geometric design feature.
Per Draft EIR Section 4.15 Transportation (p. 4.15-15), Commerce Way would be constructed
with pedestrian facilities (i.e., sidewalks, bicycle facilities) resulting in a well-connected
sidewalk network surrounding the Project. The Project also proposes sidewalks along De Berry
Street and Van Buren Street within the Project’s limits. Pedestrians would be able to access
the Project and other nearby land uses or facilities between Main Street and Barton Road.
Lastly, all roadways and pedestrian facilities would be designed according to the development
standards listed in the proposed Specific Plan. Therefore, the Project would be compliant with
the City’s ATP concerning pedestrian facilities.
The Project would provide improvements in both bicycle and pedestrian facilities for all areas
of the Project and thus is not expected to create pedestrian safety hazards. Draft EIR Impact
4.15-3 uses a City threshold based on CEQA Guidelines Appendix G. Lead agencies have the
discretion to select thresholds, which the City has done here. King & Gardiner Farms, LLC v.
County of Kern (2020) 45 Cal.App.5th 814, 884. The comment’s discussion of the existing
conditions at Grand Terrace Elementary School, Terrace Hills Middle School and Grand Terrace
High School is a part of the baseline condition and exists independent of the Project. No
evidence of any additional risk has been presented. Assumptions regarding potential future
pedestrian-vehicle conflicts are speculative. No further response is required.
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The City respectfully disagrees that Impact 4.15-3 should be updated to address the existing
lack of pedestrian facilities outside of the Project area along routes to school. Future
development within the Project site would be designed in accordance with all applicable Grand
Terrace MC regulations pertaining to roadway design and safety. Furthermore, the Project
Applicant will pay development impact fees pursuant to Grand Terrace MC Chapter 4.104
Circulation Improvement Fee Program, which the City can use to improve pedestrian facilities
near schools.
E-16 The comment provides assumptions that the Project would add 468 new peak morning trips
to Vivienda Avenue and Commerce Way at Barton Road and would consequently increase
pedestrian-vehicle conflicts at this intersection as well as De Berry Street and Mt. Vernon
intersection. These assumptions have been noted; however the conflicting projections are
speculative. All development within the Project site would be designed in accordance with all
applicable Grand Terrace MC regulations pertaining to roadway design and safety. Please see
Response to Comment E-15.
E-17 The comment states that documented pedestrian/bicycle collisions have already occurred at
the intersections of Vivienda Avenue/Commerce way at Barton Road and De Berry Street at
Mt. Vernon Avenue and asserts that the proposed Project would cause additional pedestrian-
vehicle collisions. The comment requests that, pursuant to California Vehicle Code section
21373, the City and/or developer provide adult crossing guards at these intersections.
Please see Response to Comments E-14 and E-15, above.
E-18 The comment states that the Draft EIR’s Traffic Study concludes that the Project would reduce
the Level of Service (LOS) of Grand Terrace High School’s westernmost driveway at Titan
Way/Sanrive Avenue at Main Street from LOS E (35 seconds/vehicle delay) to LOS F
(>114 seconds/vehicle delay), and that the analysis further concludes that the
driveway/intersection does not meet requirements for installation of a traffic signal. The
comment further states that no other improvements are included to reduce this significant
traffic impact.
As described in detail in the Draft EIR, LOS is no longer an impact under CEQA. Draft EIR at
p. 4.15-7. In summary, SB 743 triggered an update to the CEQA Guidelines that changed how
lead agencies evaluate transportation-related impacts under CEQA to eliminate LOS. The
comment is mistaken in characterizing the Project’s traffic impacts as “significant” due to any
resulting LOS impacts. CEQA Guidelines section 15064.3 now precludes LOS from being the
method used to determine whether a project’s transportation-related environmental impacts
are significant and instead uses vehicle miles traveled to determine a project’s transportation
impacts on traffic. See Draft EIR pgs. 4.15-12 to -14, 4.15-16 to -19. However, the Draft EIR
also includes an LOS analysis for informational purposes only. Draft EIR at pgs. 4.15-1 to -2,
Appendix J1 (Transportation Impact Analysis or TIA). The Draft EIR’s discussion makes very
clear that this information is provided for informational purposes only and does not require a
significance determination, or represent a significant impact, under CEQA. Draft EIR at
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p. 4.15-1. Thus, contrary to the suggestion in the comment, CEQA does not require mitigation
to address the Project’s LOS impacts.
In addition, the comment incorrectly states the Traffic Study conclusions. The TIS explains that
the >114 second/vehicle delay noted by the comment is estimated from the northbound left
movement from Sanrive Drive, not from school access. [Page 369 of the TIA in Appendix D:
Level of Service (LOS Worksheets) The southbound movement delay from the school access
driveway is estimated to be 20.4 seconds (LOS C). Average intersection delay is estimated to
be 6.9 seconds for all vehicles. Thus, the Project is not expected to detrimentally affect school
access from an LOS perspective.
E-19 The comment states that the driveway discussed in Comment E-18 provides the only ingress
and egress to three of the high school’s parking lots and bus loading area. The comment states
that the Project will cause delays at these areas, which it finds unacceptable and further states
that the Project should include mitigation to address these impacts, which would occur during
peak morning and afternoon periods.
Please see Response to Comment E-18, above. LOS is not a significant impact under CEQA and,
therefore, no mitigation or further response is required.
E-20 The comment states that mitigation must be included to address the impact discussed in the
previous Comment, E-18, and notes that such mitigation could include creating new driveways
on Taylor Street. Please see Response to Comment E-18, above. LOS is not a significant impact
under CEQA and, therefore, no mitigation is required.
E-21 Per Draft EIR Section 4.15, Transportation, the Project’s proposed circulation will be designed
in conformance with the applicable Grand Terrace MC design guidelines and regulations, which
includes but are not limited to use of traffic control devices, and payment of fair share
contributions. Draft EIR at p. 4.15-20. Furthermore, the Project would be void of gated
communities and speed bumps, and thus would provide free and clear access for emergency
personnel throughout the Project area. Lastly, the Project’s Specific Plan and future project-
specific development plans, would be reviewed by the City Engineer and Fire Department to
ensure that adequate emergency access is provided. Therefore, the Project’s impact
concerning emergency access is less than significant and no mitigation is required.
E-22 This comment includes a conclusionary statement requesting that the Project form a Mello-
Roos District to finance school facility improvements Grand Terrace Elementary and Terrace
Hills Middle, off-site pedestrian facilities between the Project and assigned schools, and
crossing guards at the Vivienda Avenue/Commerce Way at Barton Road and De Berry Street at
Mt. Vernon Avenue intersections. The commentor is also requesting that the Project fully
mitigate the indirect significant traffic impact at Grand Terrace High’s western driveway at the
Titan Way/Sanrive Avenue at Main Street intersection. See Responses to Comments E-8
through E-21.
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E-23 The City appreciates the CJUSD comments. As discussed through the responses above, the
Project would not create potentially significant environmental impacts to existing schools or
create potentially significant risks on the health and safety of students. The Project will comply
with all applicable laws, regulations, and ordinances pertaining to the Project’s development
and circulation improvements. Further, the Project Applicant will pay all applicable
development, circulation, and school fees required for the Project. Therefore, no further
response is warranted.
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Comment Letter F – Pala Band of Mission Indians
John Pepper, Lead Cultural Resources Monitor
Shasta C. Gaughen, PhD
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Responses to Comment Letter F – Pala Band of Mission Indians
John Pepper, Lead Cultural Resources Monitor
Shasta C. Gaughen, PhD
F-1 Email transmittal of Comment Letter. No response required.
F-2 Introductory comment. No response required.
F-3 The comment concludes that the Project is not within the boundaries of the recognized Pala
Indian Reservation. Additionally, commenter concludes that the Project is also beyond the
boundaries of the territory that the tribe considers its Traditional Use Area. Therefore, no
further response is warranted.
F-4 The City appreciates the commenter’s acknowledgment of the City’s willingness to consult with
the tribe. The comment is conclusionary and no further response is warranted.
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Comment Letter G – San Manuel Band of Mission Indians
Bonnie Bryant
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Responses to Comment Letter G – San Manuel Band of Mission Indians
Bonnie Bryant
G-1 This comment is an introductory statement that indicates the Project exists within Serrano
ancestral territory and is of interest to the tribe. No response is warranted.
G-2 Per the commenter’s request, the City has provided the Tribe two Dropbox Links in total
containing the requested Cultural Reports, Geotechnical Reports, and Project plans showing
the depth of the proposed disturbance on July 7, 2023 and July 18, 2023.
G-3 Refer to Response to comment G-2 above.
G-4 The comment requests that the City resend the information in the Dropbox Link as the link had
expired. The requested information was resent.
G-5 Refer to Response to Comment G-2 above.
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Comment Letter H – South Coast Air Quality Management District
Evelyn Aguilar, Air Quality Specialist, CEQA-IGR
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Responses to Comment Letter H – South Coast Air Quality Management District
Evelyn Aguilar, Air Quality Specialist, CEQA-IGR
H-1 This comment is an introductory statement indicating that South Coast AQMD staff received
the Notice of Availability (NOA) of a Draft Environmental Impact Report for the Project and are
currently reviewing the documents. No response is warranted.
H-2 The comment states that the commenter was able to access the Draft EIR and associated
material. No further response is warranted.
H-3 The commenter requested an electronic copy of any live modeling and emission calculation
files that were used to quantify the air quality impacts from construction and/or operation of
the Project. Per the commenter’s request, the City emailed the commenter on July 11, 2023
with a Dropbox Link of the requested emissions calculation files. To date, no additional
comment letters have been received from the commenter.
H-4 The requested information was provided. See Response to Comment H-3 above.
H-5 The commenter confirmed that they received the requested emission calculation files. No
further response is warranted.
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Comment Letter I – Southwest Mountain States Regional Council of Carpenters
Mitchell M. Tsai, Attorney At Law
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Responses to Comment Letter I – Southwest Mountain States Regional Council of Carpenters
Mitchell M. Tsai, Attorney At Law
I-1 Receipt of the NOA is noted and a current address provided. The commenter’s address and
email address has been updated per the commenter’s request.
I-2 Introductory comment stating that the office of Mitchell M. Tsai, Attorney At Law is submitting
comments on behalf of the Southwest Mountain States Regional Council of Carpenters
(SWMRCC).
I-3 Overview of the commenter’s understanding of the Project. This comment does not identify a
specific concern with the adequacy of the Draft EIR or note a specific issue or comment related
to the Draft EIR’s environmental analysis. No response is required.
I-4 The SWMRCC labor union’s background is noted. This comment does not identify a specific
concern with the adequacy of the Draft EIR or note a specific issue or comment related to the
Draft EIR’s environmental analysis. No response is required.
I-5 The commenter’s right to supplement the submitted comment letter is noted. This comment
does not identify a specific concern with the adequacy of the Draft EIR or note a specific issue
or comment related to the Draft EIR’s environmental analysis. No response is required.
I-6 Comment notes that all comments raising issues regarding the project and its environmental
review and associated documents and reports are incorporated by reference. This comment
does not identify a specific concern with the adequacy of the Draft EIR or note a specific issue
or comment related to the Draft EIR’s environmental analysis. No response is required.
I-7 The comment requests the City provide notice regarding the Project. The City will provide all
notices pertaining the Project to the Commenter. This comment does not identify a specific
concern with the adequacy of the Draft EIR or note a specific issue or comment related to the
Draft EIR’s environmental analysis. No further response is required.
I-8 The comment suggests that the Applicant provide additional community benefits such as
requiring local hire and use of a skilled and trained workforce for the Project. This comment
does not identify a specific concern with the adequacy of the Draft EIR or note a specific issue
or comment related to the Draft EIR’s environmental analysis. However, your comment will be
taken into consideration by decision-makers.
I-9 The comment states that local hire requirements requiring a certain percentage of workers to
reside within 10 miles of the Project site can help to reduce environmental impacts and
improve positive economic impacts from the Project. The comment states that such
requirements reduce vendor trips and greenhouse gas (GHG) emissions, and provide localized
economic benefits. The opinion expressed about hiring local workers is noted.
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Commenter’s opinion about hiring local workers is noted. Commenter is advocating for
imposition of local hire requirements with respect to the carpenters union, which would apply
only during the construction phase of the Project. Commenter mentions potential reductions
of vendor trips (i.e., vehicles miles traveled [VMT] associated with vendors) and GHG emissions
that would result from such requirements. However, any environmental benefits that would
be realized as a result of local hire requirements would apply only during the construction
phase. The Draft EIR analyzes construction-phase VMT impacts and construction-phase GHG
impacts (Draft EIR, pp. 4.7-19 through 4.7-21).
With respect to GHG emissions, while the Project’s overall impacts were determined to be
significant and unavoidable, the portion attributable to the construction phase is very minor
compared to the operational emissions (59 tons/year versus 18,480 tons per year) and only a
small portion of that is attributable to construction worker commutes (Draft EIR, p. 4.7-21).
The comment assume workers would not be local but there is no evidence that they would
and any reduction to this fractional portion of the Project’s GHG emissions is both negligible
and speculative.
The comment also states that local economic benefits that would result from local hire
requirements. Such considerations are beyond the scope of CEQA. No further response is
required.
I-10 The comment references a 2020 paper prepared by the Institute for Research on Labor and
Employment at the University of California, Berkley which states that a workforce of skilled
trades can yield sustainable economic development and that well-trained workers are key to
reducing GHG emissions and moving California closer to its climate targets. No comment is
made regarding the Project or the EIR relevant to CEQA. No further response is required.
I-11 The comment states that workforce policies have significant environmental benefits by
improving job-housing balance and decreasing the length of commutes. The commenter
further states that local state-certified apprenticeship programs can result in air pollutant
reductions. The link commenter provides is blocked. No comment is made regarding the
Project or the EIR relevant to CEQA. No further response is required.
I-12 The comment states that locating jobs close to residential areas can have significant
environmental benefits and cites to the California Planning Roundtable for support. This
comment does not identify a specific concern with the adequacy of the Draft EIR or note a
specific issue or comment related to the Draft EIR’s environmental analysis. Please see
Response to Comment, I-9, above. The California Planning Roundtable report cited in the
comment examines permanent jobs-housing balance, not the temporary relationship between
construction jobs and development that a local hire mandate would require. It should be noted
that, as relates to a permanent jobs-housing balance, the Project would generate some retail
jobs that are not technical and would be filled by a broad sector of any local community.
I-13 The comment states that local hire mandates and skill training are critical facets of a strategy
to reduce VMT and cites two planning experts to support the argument that placing jobs near
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housing stock may be insufficient to achieve VMT reductions due to a mismatch in required
skills. Please see Response to Comment, I-9, above. The Cervero and Duncan research cited
relates to permanent jobs, not temporary construction jobs as Commenter is advocating.
Contrary to the suggestion from Commenter, the article concludes that “Linking jobs and
housing holds significant potential to reduce VMT and VHT [vehicle hours travelled].” Cervero
and Duncan at 488. The cited article does not discuss local hire mandates or skill training as
suggested by Commenter. Placing workers in permanent proximity to their residences – the
subject of the cited article – would result in very different environmental gains than employing
a limited number of construction workers at a job in proximity to their homes for a limited
period of time. It should be noted that the Project would generate some retail jobs that are
not technical and would be filled by a broad sector of any local community.
I-14 The comment cites to the Cervero and Duncan article’s discussion of the City of Berkeley’s First
Source program, which encourages contractors working on publicly funded construction
projects to hire Berkeley Residents. The First Source program applies to City of Berkeley
construction projects for which Berkeley is able to set their own policy for hiring decisions. In
addition, the cited text asserts that Berkeley is addressing its jobs-housing imbalance concerns
by bringing new jobs – rather than housing – to the Berkeley. This concept is inapplicable to
the Project where the City wants to bring more housing.
I-15 Comment noted. No comment is made regarding the Project. No further response is required.
I-16 Comment noted. As discussed on page 4.12-4 of the DEIR, the State EDD reports that that City’s
labor force was 6,800 persons in September 2022. Of the City’s labor force, 300 persons were
unemployed representing an unemployment rate of approximately 3.9 percent. According to
EDD, jobs in the City totaled 6,500. Comparatively, the City’s existing unemployment rate is
0.1 percent higher than the County’s unemployment rate of 3.8 percent. Therefore, as
development within the Specific Plan occurs, contractors are likely to hire locally. No comment
is made regarding the Project or the EIR relevant to CEQA. No further response is required.
I-17 The commenter provides information regarding CEQA and the commenter’s understanding
regarding preparation of EIRs including CEQA’s requirements for environmental analysis and
reducing environmental impacts. Several court cases are cited. The comment also describes
the commenter’s understanding of the standard of review that courts apply to determine the
sufficiency of an EIR. The comment states that an EIR must include sufficient information so
that foreseeable impacts can be understood and the public can comment on them. The
comment also describes its view of the “fair argument” standard and when it is to be applied.
The comment’s general description of CEQA’s goals and requirements is noted. With respect
to the description of the standard of review applicable to a court’s review of the sufficiency of
an EIR, the City notes that an EIR’s adequacy with respect to, for example, methodology,
baseline conditions, scope of environmental impact analysis, and adequacy of mitigation
measures is reviewed under the substantial evidence standard. Vineyard Area Citizens for
Responsible Growth v. City of Rancho Cordova (2007) 40 Cal.4th 412, 435; Mission Bay All. v.
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Office of Cmty. Inv. & Infrastructure (2016) 6 Cal.App.5th 160, 192, 206; Guidelines §15384(a).
Disagreements among experts do not invalidate an EIR, and the lead agency may adopt the
environmental conclusions reached by the experts that prepared the EIR, even though others
may disagree with the underlying data, analysis, or conclusions. Laurel Heights Improvement
Assn. v. Regents of Univ. of California (1988) 47 Cal.3d 376, 407-08. Only with respect to
questions about whether the agency complied with the legal requirements of CEQA is the
agency’s action reviewed under a less deferential standard to determine whether the agency
failed to proceed in a manner required by law. Pub. Res. Code § 21168.5. No comment was
made specific to the Project or the Draft EIR; therefore, no further response is required.
I-18 The comment provides general background regarding initial studies, negative declarations, and
mitigated negative declarations. The comment is noted. The City prepared an EIR for the
proposed Project that is compliant with CEQA. No comment was made specific to the Project
or the Draft EIR; therefore, no further response is required. As such, this response provides no
opinion regarding the legal content of the comment.
I-19 The comment provides a summary and discussion about how exemptions to CEQA can be used
and the standards for doing so. No CEQA exemption was used for this project nor was any
comment made specific to this Project or the Draft EIR; therefore, no further response is
required. As such, this response provides no opinion regarding the legal content of the
comment.
I-20 The comment provides a summary and discussion of when a revision or recirculation of an EIR
may be required and the standards for doing so. The comment summarizes the definitions
used in the Guidelines for this topic. No comment was made specific to this Project or the Draft
EIR; therefore, no further response is required. As such, this response provides no opinion
regarding the legal content of this comment.
I-21 The comment states that Draft EIR failed to consider all feasible, practical, and effective
mitigation measures. However, the comment does not provide any specific feasible, practical,
and effective mitigation measures that should have been included in the Draft EIR analysis. As
such, no further response is needed.
I-22 The comment states that the Draft EIR is required to review all feasible, practical, and effective
mitigation measures. Per Public Resources Code, Sections 21002 and 21002.1(b), CEQA does
not require adoption of every imaginable feasible mitigation measure. CEQA’s requirement
applies only to feasible mitigation that will “substantially lessen” a project’s significant effects.
The Draft EIR has identified all feasible mitigation measures, which are summarized in
Section 1.0, Executive Summary. Although the comment claims that the Draft EIR does not
contain the details for several mitigation measures in the context of air quality, biological
resources and GHG impact, the comment does not identify any additional information
regarding feasible mitigation measures in these or any other areas. Therefore, no further
response is required.
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I-23 The comment makes various statements regarding an EIR’s analysis of potentially significant
impacts and cites to various legal cases. The comment made no reference specific to this
Project or the Draft EIR; therefore, no further response is required. As such, this response
provides no opinion regarding the legal content of the comment.
I-24 The comment states that referring to regulatory compliance to prevent significant adverse
impacts must be based on a project-specific analysis of potential impacts and the effect of
regulatory compliance. The comment made no reference specific to this Project or the Draft
EIR; therefore, no further response is required. As such, this response provides no opinion
regarding the legal content of the comment.
I-25 The comment is a summary of the commenter’s view of State CEQA Guidelines 15064.4. A lead
agency is allowed to determine the significance of a project’s GHG impact via qualitative
analysis and/or a quantitative analysis. The comment goes on to state that the lead agency can
select the model or methodology used to estimate GHG emissions as long as the selection is
supported by substantial evidence and the lead agency should explain the limitations of the
particular model or methodology used.
The GHG analysis for this EIR was prepared using CalEEMod version 2020.4.0 which was the
latest version of the program when the technical studies were prepared. CalEEMod, was
developed for the California Air Pollution Officers Association (CAPCOA) in collaboration with
the California Air Districts. The purpose of CalEEMod is to provide a uniform platform for
government agencies, land use planners, and environmental professionals to estimate
potential emissions associated with both construction and operational use of land use projects.
It is intended that these emission estimates are suitable for quantifying air quality and climate
change impacts as part of the preparation of California Environmental Quality Act (CEQA)
documents. In addition, individual districts may rely on the model’s emission estimates to show
compliance with local agency rules. CalEEMod utilizes widely accepted methodologies for
estimating emissions combined with default data that can be used when site-specific
information is not available. The analysis in the Draft EIR follows the methodology included in
the CalEEMod User’s Guide.
The comment does not raise a specific issue with the Draft EIR and no further response is
required.
I-26 The commenter provides their view of the State CEQA Guidelines Section 15183.5(b)(1)
requirements of a qualified Climate Action Plan (CAP). The project does not propose
development of a CAP and the City of Grand Terrace does not have a qualified CAP. No
comment was made specific to the Project or the Draft EIR and the Draft EIR describes feasible
mitigation measures for potentially significant GHG impacts. As such, no further response is
required, and this response provides no opinion regarding the legal content of this comment.
I-27 The comment states that the Draft EIR GHG and air quality analyses do not identify consistency
with California Ambient Air Quality Standards, National Ambient Air Quality Standards, and Air
Quality Management Plan as part of the analysis. However, the GHG Threshold 4.7-1.2
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addresses consistency with applicable plans, policies, or regulations adopted to reduce GHG
emissions (Draft EIR at p. 4.7-19). The plans and standards identified by the commenter were
developed to reduce criteria pollutants. Although the reduction of certain criteria pollutants
could indirectly reduce GHG emissions, the goal of the plan and standards listed by the
commenter is not to reduce GHG. No further response is required.
I-28 The comment notes that the Draft EIR identified a significant GHG impact associated with the
Project. The commenter states the Project must consider more stringent mitigation measures
to reduce GHG emissions. However, as stated in the Draft EIR, after mitigation, mobile
emissions associated with the Project would generate 93 percent of the Project’s GHG
emissions. While the Project and the City do not have the ability to regulate vehicle emissions,
state and federal regulations will continue to improve engine efficiency and thus emissions.
California has set a goal of requiring all new vehicles sold in 2035 and beyond to be zero-
emission vehicles. Therefore, as vehicle emissions decrease in the future, GHG impacts
associated with Project will also decrease. The comment does not identify any mitigation
measures for evaluation to reduce environmental impacts. No further response is required.
I-29 The comment states that a fundamental purpose of an EIR is to identify ways to mitigate or
avoid the significant environmental effects of a project. Consistent with and to accomplish this
goal, the comment states that an EIR describes feasible mitigation measures. No comment was
made specific to the Project or the Draft EIR and the Draft EIR does describe feasible mitigation
measures for potentially significant impacts. As such, no further response is required, and this
response provides no opinion regarding the legal content of this comment.
I-30 The comment notes that the Draft EIR identified significant air quality and GHG impacts
associated with the Project, states that the Project must adopt all feasible mitigation measures,
and disputes the adequacy of the analysis under CEQA. The comment does not provide any
suggestions for additional mitigation nor does it identify any missing elements of the analysis.
The Draft EIR provides a complete analysis of air quality and greenhouse gas emissions. The
Draft EIR includes numerous mitigation measures to reduce Project GHG emissions (Draft EIR
at pages 4.2-1 and 4.7-1). MM GHG-1 requires the installation of photovoltaic solar panels to
offset energy emissions in residential buildings. MM GHG-2 requires the Project to meet or
exceed the voluntary CALGreen Tier 2 standards to further improve energy efficiency.
MM GHG-3 requires the residential projects to be all electric (i.e., no natural gas) and
MM GHG-4 requires the Project to divert 75 percent of waste from landfills. Furthermore,
MMs AQ-2 through AQ-4 have been identified in Draft EIR Section 4.2, Air Quality to reduce
operational emissions would also reduce GHG emissions. MM AQ-2 requires the
implementation of a qualifying Commute Trip Reduction (CTR)/ Transportation Demand
Management (TDM) plan to reduce mobile GHG emissions for all uses. MM AQ-3 prohibits the
use of any kind of fireplaces, and MM AQ-4 requires that the Project’s Codes Covenants and
Restrictions (CC&Rs) and/or tenant lease agreements include contractual language that all
landscaping equipment used on-site shall be 100 percent electrically powered. See also
Response to Comment I-28 regarding pollution from mobile sources. The comment does not
specify how any of these mitigation measures are deferred to the future. These mitigation
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measures will reduce impacts and no other mitigation measures are identified by the
commenter that will reduce mobile source emissions to less than significant levels. The EIR
finds that there will still be a significant impact and the City will need to adopt a statement of
overriding consideration.
No further response is required.
I-31 The comment states that the City makes a conclusory statement about future compliance with
the law and does not commit itself to any specific or binding course of action which is project-
specific. The Draft EIR provides a complete analysis of air quality and greenhouse gas emissions
and the comment does not provide a specific comment to the contrary. Refer to Response to
Comment I-30 for more information.
I-32 The comments states that compliance with regulatory requirements may not be enough to
satisfy CEQA, and claims that the Draft EIR does not connect the effect of regulatory
compliance with impacts to determine the effect less than significant. Because this comment
does not refer to any specifics in the Draft EIR, it is unclear to which sections the comment
refers, however the Air Quality and GHG sections provide comprehensive impact analyses and
recommends for adoption all feasible mitigation measures; the mitigations do not only rely
solely upon regulatory compliance. See Draft EIR Sections 4.2, Air Quality (Draft EIR at
page 4.2-1) and 4.7, Greenhouse Gas Emissions (Draft EIR at page 4.7-1). No comment was
made specific to the Project or the Draft EIR and the Draft EIR describes feasible mitigation
measures for potentially significant impacts. As such, no further response is required, and this
response provides no opinion regarding the legal content of this comment.
I-33 The comment incorrectly states that the Draft EIR lacks adequate analysis of air quality impacts
and states concern regarding impacts to sensitive receptors in the vicinity of the Project,
especially Grand Terrace High School to the south. Air Quality Impact 4.2-3 discusses in detail
what impacts the construction and operation of the Project will have on sensitive receptors
(see Draft EIR at pgs. 4.2-30 to -39) which include single-family residences, Veterans Freedom
Park, and Grand Terrace High School. In addition, a Health Risk Assessment (HRA) was prepared
for the Project analyzing health impacts from the construction and operation of the Project
(see Draft EIR, Appendix A). Appendix A specifically discusses and analyzes the effects on
sensitive receptors. Draft EIR Appendix A, p. 10, 18-40. As discussed in the Draft EIR, the
Projects impacts to sensitive receptors would be less than significant. In addition, the comment
states that the GHG analysis lacks adequate discussion of the 112-acre Project. The GHG
chapter specifically discusses the size of the project (Draft EIR at p. 4.7-1) and provides detailed
analysis of its impacts under the thresholds (Draft EIR at pgs. 4.7-19 to -31) and proposes
mitigation measures. No further response is required.
I-34 The comment states that the Draft EIR does not provide adequate analysis of sensitive
receptors, including construction impacts and traffic, VMT and GHG impacts. Please refer to
Response to Comment I-33, regarding analysis of construction and operational air quality and
GHG impacts and effects including those to sensitive receptors. In addition, the Draft EIR
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provides comprehensive analysis of VMT. See Draft EIR Chapter 4.15 and Draft EIR Appendix
J1, Appendix J2. All changes to VMT are discussed and analyzed. The comment does not
identify any specific deficiencies or any bases for its statements. No further response is
required.
I-35 The comment notes the Project would be consistent with SCAG’s regional goals but questions
the conclusion based on the commenter’s belief that the Draft EIR did not analyze impacts to
surrounding sensitive receptors. As previously stated in Response to Comments I-33 and I-34,
Air Quality Impact 4.2-3 discusses in detail the impacts from construction and operation of
Project will have on sensitive receptors (refer to Draft EIR at pages 4.2-30 to 4.2-39) which
include single-family residences, Veterans Freedom Park, and Grand Terrace High School.
Localized significance threshold analysis following AQMD methodology was prepared to
determine impacts from construction and operation of the Project. In addition, a HRA was
prepared for the Project which analyzed impacts to receptors within 1,400 feet of the Project
site. A HRA is a technical study that evaluates how toxic emissions are released from a project
during construction and operations, how those emissions disperse throughout the community,
and the potential for those toxic emissions to impact human health. The air dispersion
modeling for this HRA was performed using the U.S. EPA AERMOD dispersion model. AERMOD
requires hourly meteorological data consisting of wind vector, wind speed, temperature,
stability class, and mixing height. Surface and upper air meteorological data were provided by
the SCAQMD. The HRA follows the methodology outlined in California’s Office of
Environmental Health Hazard Assessment’s (OEHHA) 2015 document, Risk Assessment
Guidelines, Guidance Manual for Preparation of Health Risk Assessments.
As discussed in the Draft EIR, impacts to sensitive receptors would be less than significant. All
necessary and required data and analysis is provided in the Draft EIR and the comment
provides only conclusory statements claiming inadequacy. No further response is required.
I-36 The comment provides a summary of requirements related to the development of general
plans and determinations of land use decision’s consistency with them. No comment was made
specific to this Project or EIR; therefore, no further response is required. As such, this response
provides no opinion regarding the legal content of this comment.
I-37 The comment states that the Project is inconsistent with the General Plan and violates state
Planning and Zoning Law. The comment lists fourteen Grand Terrace General Plan goals and
policies with which it states the Project will not be consistent. The letter does not provide any
details to support these assertions. The comment states that the Draft EIR must be revised to
include sufficient analysis of the Project’s consistency with the Grand Terrace General Plan.
As a threshold matter, an EIR is not required to discuss a project’s consistency with a local
general plan. Rather, CEQA Guidelines section 15125(d) specifies that an EIR must discuss a
project’s inconsistency with a relevant general plan. Nevertheless, Table 4.10-3: General Plan
Consistency Analysis, of the Draft EIR includes a detailed analysis of the Project’s consistency
with all relevant Grand Terrace General Plan goals and policies, including all the ones identified
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in the comment. Draft EIR at pgs. 4.10-11 to -19. Moreover, the project is consistent with each
of the cited policies:
37(a) Goal 4.8: Achieve regional water quality objectives and protect the
beneficial uses of the regions surface and groundwater.
See discussion regarding Policies 4.8.1 and 4.8.2, below.
37(b) Policy 4.8.1: Evaluate all proposed land use and development plans for
their potential to create groundwater contamination hazards from point
and non-point sources, and cooperate with other appropriate agencies to
assure appropriate mitigation.
The Draft EIR explains that the Project would be consistent with this policy
because all future development projects within the Project site would be required
to implement a Storm Water Pollution Prevention Plan and Water Quality
Management Plan that will contain best management practices to minimize
groundwater contamination hazards.
37(c) Policy 4.8.2: Comply with the requirements of the National Pollutant
Discharge Elimination System (NPDES).
The Draft EIR explains that the Project would be consistent with this policy
because all site-specific development would be subject to the requirements of
the NPDES permitting process.
37(d) Goal 4.9: Comply with State and federal regulations to ensure the
protection of historical, archaeological, and paleontological resources.
See Discussion regarding Policy 4.9.1, below.
37(e) Policy 4.9.1: The City shall take reasonable steps to ensure that cultural
resources are located, identified and evaluated to assure that appropriate
action is taken as to the disposition of these resources.
The Draft EIR explains that the Project would be consistent with this policy
because it would implement mitigation measures that would minimize impacts
to any unknown cultural resources discovered on the site.
37(f) Goal 5.6: Minimize the exposure of residents, business owners, and
visitors to the impacts of urban and wildland fires.
See discussion regarding Policy 5.6.2, below.
37(g) Policy 5.6.2: Continue the weed abatement program to ensure clearing of
dry vegetation areas.
The Draft EIR explains that the Project would be consistent with this policy
because the Project is located in a local responsibility area and would comply with
the City’s Local Hazard Mitigation Plan.
37(h) Policy 5.6.3: Encourage the use of fire-resistive construction materials.
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The Draft EIR explains that the Project would be consistent with this policy
because it would comply with the California Building Code, which regulates the
design, construction, and quality of materials, etc. for development.
37(i) Goal 7.1: Coordinate and balance the provision of public services with
existing and planned development to eliminate service gaps, maximize
the use of existing public facilities and services, provide a high level of
quality public services at a reasonable cost, and maintain adequate
services to meet the needs of current and future City residents and
businesses.
See discussion regarding Policy 7.1.1, below.
37(j) Policy 7.1.1: All proposed development shall be evaluated to determine
whether current public services and facilities can meet with their needs. If
determined that current services and facilities are inadequate to meet the
needs of new development, appropriate mitigation measures shall be
applied to the new development to assure an adequate level of service.
The Draft EIR explains that the Project would be consistent with this policy
because fire protection and police protections would remain efficient in serving
the proposed Project. The Project is required to adhere to Grand Terrace MC
Chapter 4.80, Development Impact Fees, which would require each applicant to
pay a development impact fee imposed by the City to pay for all or a portion of
costs of providing public services associated with new development.
37(k) Goal 9.2: Reduce the total quantity of waste generated within the City
requiring landfill disposal to meet or exceed the State waste diversion
goals.
See discussion regarding Policy 9.2.2, below.
37(l) Policy 9.2.2: Require all new development projects to recycle construction
and demolition wastes.
The Draft EIR explains that the Project would be consistent with this policy
because all development projects will be required to recycle or handle
construction and demolition wastes, consistent with this Policy and in accordance
with applicable state regulations regarding the use, handling, storage, and
transportation of waste.
37(m) Goal 9.7: Reduce the City’s per capita demand for water consumption.
See discussion regarding Policy 9.7.2, below.
37(n) Policy 9.7.2: The City shall incorporate water conservation into the
development review process.
The Draft EIR explains that the Project would be consistent with this policy
because all projects would be required to incorporate water conservation design
features and landscaping to minimize water consumption.
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In addition, Courts are highly deferential to a city’s determination of a project’s consistency
with its own general plan. See The Highway 68 Coalition v County of Monterey (2017) 14 Cal.
App. 5th 883, 896 (consistency of development permit and development plan with general
plan). California’s Planning and Zoning Law does not require strict conformity with all aspects
of a general plan, but rather consistency with its overall goals and objectives. See, e.g., Friends
of Lagoon Valley v. City of Vacaville (2007) 154 Cal.App. 4th 807, 815 (upholding overall
consistency finding even though project deviated from some plan provisions because plan
allowed for balancing of competing priorities).
As noted, the comment does not point to any specific flaws in this analysis or explain how the
Project is inconsistent with the goals and policies described in detail in Table 4.10-3. As such,
Table 4.10-3 provides the consistency analysis required by CEQA. No further response is
required.
I-38 The commenter’s request for recirculation of the EIR and requirement for local and skilled
workforce is noted but no specifics are provided as to why recirculation is necessary and no
trigger for recirculation is met.
I-39 The comment is introductory to an attachment to Mitchell Tsai’s comment letter, and no
specific comments are made. Responses to specific comments in the attachment are provided
below.
I-40 The comment states that the California Emissions Estimator Model (CalEEMod) is a model
generally used to estimate criteria pollutant and GHG emissions and describes some of the
inputs entered into the model to estimate construction emissions, including VMT. No
comment was made specific to this Project or EIR; therefore, no further response is required.
I-41 The comment discusses how default worker trip lengths in CalEEMod are based on location
specific data and urbanization. While default worker trip lengths vary by location, default
urban worker trip lengths tend to be shorter in length. No comment was made specific to this
Project or EIR; therefore, no further response is required.
I-42 The comment states that, with respect to construction analysis, CalEEMod outputs depend on
the utilized worker trip lengths and the efficacy of a local hire requirement depends upon the
urbanization of a project site and the project’s location. Comment presents example of the
reduction in construction-related GHG emissions associated with a local hire provision. No
comment was made specific to this Project or EIR; therefore, no further response is required.
I-43 The comment provides a boilerplate disclaimer about the information the commenter
received. Comment is noted. No further response is required.
I-44 Comment provides the professional experience resume of the attachment’s author. Comment
noted. No further response is required.
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Comment Letter J – Supporters Alliance for Environmental Responsibility
Lozeau Drury LLP – Rebecca Davis
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Responses to Comment Letter J – Supporters Alliance for Environmental Responsibility
Lozeau Drury LLP – Rebecca Davis
J-1 The comment is an email transmittal of the commenter’s letter regarding the Project’s Draft
EIR. The City acknowledges receipt of the commenter’s letter and has prepared the following
responses to comments.
J-2 Overview of the commenter’s understanding of the Project is noted for the record. No further
response is required.
J-3 The commenter states that the Draft EIR fails as an informational document, fails to analyze all
of the Project’s significant impacts, and fails to impose all feasible mitigation measures to
reduce the Project’s impacts, and requests that a revised Draft EIR be prepared prior to
consideration of approvals. However, the comment does not identify any specific concern with
the adequacy of the Draft EIR or note a specific issue or comment related to the Draft EIR’s
environmental analysis. Therefore, no further response is required.
J-4 Comment noted. This comment does not identify a specific concern with the adequacy of the
Draft EIR or note a specific issue or comment related to the Draft EIR’s environmental analysis.
Therefore, no further response is required.
The Gateway at Grand Terrace Specific Plan
Final Environmental Impact Report Section 2.0 – Comments and Responses to Draft EIR
City of Grand Terrace July 2024
2.0-118
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