PUBLIC COMMENT LETTER IN
OPPOSITION TO THE PROPOSED MESA
VERDE SPECIFIC PLAN DEVELOPMENT
Executive Summary
The proposed Mesa Verde Plan is one of the largest development project considered within the City of Calimesa. While the project has been revised from earlier concepts, the proposal still consists of 3,650 residential units on 474.6 acres. According to the Proposed Project Compared to the 2017 Mesa Verde Plan, Area 2 Amendment No. 1, this reflects a 36 percent reduction in utilized acreage. However, this reduction does not eliminate the significant environmental, public safety, infrastructure, fiscal, and community impacts associated with a development of this magnitude. Instead, it concentrates thousands of residential units into a smaller area, increasing development intensity and fundamentally changing the character of our community.
Calimesa has long distinguished itself from surrounding cities by preserving a unique blend of suburban convenience and rural living. Residents value the City's open spaces, agricultural heritage, equestrian properties, wildlife habitat, scenic views, and small-town atmosphere.
These qualities are central to Calimesa's identity and are among the primary reasons many live here.
Approval of the Mesa Verde Plan, as currently proposed, would permanently alter that identity.
Increased residential density, expanded roadways, additional traffic, loss of open land, degradation of wildlife habitat, increased demand on public services, and significant changes to the City's visual character would transform Calimesa into a more urbanized community with little remaining to distinguish it from neighboring cities.
The City Council and Planning Commission have a responsibility to ensure that any development of this magnitude is consistent with the City's General Plan, adequately evaluated under the California Environmental Quality Act (CEQA), and designed to protect the health, safety, and welfare of both current and future residents. The issues raised in this letter—including emergency evacuation, wildfire preparedness, biological resources, hazardous infrastructure, traffic congestion, fiscal sustainability, and long-term maintenance obligations—deserve careful consideration before any approvals are granted.
We respectfully urge the City to either deny the proposed Mesa Verde Specific Plan in its current form, require substantial revisions that better protect Calimesa's residents, natural resources, public infrastructure, and rural character or to consider making the W. County Line Rd residents "whole,' buy purchasing their properties at fair prices. 1
Introduction and Statement of Opposition
To the Honorable Mayor, Members of the Calimesa City Council, Members of the Planning Commission, and City Staff:
We, the undersigned residents of the City of Calimesa and specifically W County Line Rd residents, respectfully submit this public comment in strong opposition to the proposed Mesa Verde Specific Plan.
Our opposition is not based upon resistance to all future growth. We recognize that Calimesa will continue to evolve and that thoughtful development can provide benefits when it is carefully planned and appropriately scaled. Rather, our concerns arise from the unprecedented size, density, and long-term impacts of the proposed project, which we believe are inconsistent with the character, infrastructure capacity, environmental resources, and public safety needs of our community.
The City has a legal and moral responsibility to evaluate not only the immediate impacts of this proposal but also its cumulative consequences over future decades. Decisions made today will permanently shape the future of Calimesa long after the developer has completed construction and sold the final home.
Many current residents in the area of this proposed development plan chose Calimesa because it offers something rare in Southern California—a community where rural and suburban lifestyles coexist. Families maintain horses, goats, sheep, chickens, geese, and other agricultural animals. Open spaces support native wildlife. Neighborhoods remain diverse in appearance, with homes situated on varying lot sizes rather than uniform high-density subdivisions.
Residents enjoy relatively low traffic volumes, quieter neighborhoods, scenic vistas, and a strong sense of community.
The Mesa Verde Specific Plan, as proposed, would dramatically change these defining characteristics. The cumulative effect of thousands of additional homes, expanded transportation corridors, increased traffic, commercial development, and associated infrastructure would permanently alter the appearance and function of Calimesa. Once this transformation occurs, the rural identity that generations of residents have worked to preserve cannot be restored.
We respectfully request that the Planning Commission and City Council carefully evaluate every aspect of this proposal through the lens of public safety, environmental stewardship, fiscal responsibility, infrastructure capacity, and long-term community planning before approving a project that would permanently reshape the future of our City. 2
Project Overview
The Mesa Verde Specific Plan proposes the development of 3,650 residential units on 474.6 acres within the City of Calimesa. Compared to the 2017 Mesa Verde Plan, although this current proposal maintains the same number of residential units, it unbelievably reflects a 36 percent reduction in utilized acreage.
By concentrating thousands of residential units into a smaller footprint, the proposal increases development intensity while creating substantial demands on transportation infrastructure, emergency services, utilities, schools, parks, open-space management, and public resources.
The proposal also includes approximately 50.3 acres of public parks together with 497.2 acres of open space and a trail system. Although these amenities are presented as benefits to the community, they also create long-term financial obligations for maintenance, habitat management, security, fire prevention, irrigation, and public safety. Before approving the project, the City should carefully evaluate how these areas will be maintained over future decades and whether sufficient funding mechanisms exist to prevent these responsibilities from becoming a financial burden on Calimesa taxpayers. A perpetual trust fund should be required to be established by the developer to ensure Calimesa is not unduly burdened by ongoing future maintenance.
The project must also be evaluated in the broader context of existing regional development. The surrounding area already experiences increasing traffic associated with Interstate 10, regional commercial development, future warehouse operations, truck traffic, and existing residential growth. The cumulative impacts of adding 3,650 additional homes extend well beyond the project boundaries and will directly affect existing neighborhoods throughout Calimesa, particularly residents along W County Line Road ("Street A"), who will experience significant changes in traffic, roadway configuration, neighborhood compatibility, noise, safety, and overall quality of life.
As discussed in the following sections of this letter, the project raises substantial concerns regarding consistency with the City's General Plan, compliance with CEQA, public safety, wildfire evacuation, hazardous infrastructure, biological resources, traffic congestion, fiscal sustainability, neighborhood compatibility, and preservation of Calimesa's unique rural character.
These concerns warrant careful consideration before any approvals are granted.
IV. Loss of Calimesa's Rural Character
One of Calimesa's greatest assets is its unique identity. Unlike many neighboring communities that have become increasingly urbanized, Calimesa has maintained a balance between suburban and rural living. This character is reflected not only in the City's landscape, but also in the lifestyle of its residents. 3
Many properties within and adjacent to the proposed project area are larger rural parcels where residents raise horses, goats, sheep, chickens, geese, and other agricultural animals. Some residents' livelihoods are based on this. Mature trees, open fields, native vegetation, and scenic views contribute to a community atmosphere that is increasingly rare in Southern California. Families choose to live in Calimesa because it offers a quieter pace of life while still providing convenient access to employment, schools, and regional transportation. The resulting increase in residential density would permanently alter the visual landscape and substantially reduce the rural character that distinguishes Calimesa from neighboring cities.
Once thousands of homes, expanded roadways, commercial services, traffic signals, and supporting infrastructure are constructed, the transformation cannot be reversed.
Existing rural neighborhoods will become isolated remnants surrounded by higher-density subdivisions.
The northern entrance along W. County Line Road ("Street A") illustrates this concern particularly well. Existing homes along this corridor are individually designed, situated on varying lot sizes, and reflect the rural character that has long defined West Calimesa.
Introducing a high-density master-planned community immediately adjacent to these homes would create an abrupt transition in scale, architecture, and intensity of use. Such a dramatic contrast is inconsistent with sound planning principles, which generally encourage compatible transitions between established neighborhoods and new development.
The loss of Calimesa's rural identity is not simply an aesthetic issue. Community character directly influences quality of life, property values, neighborhood cohesion, and residents' sense of place. Once that identity is lost, it cannot be recreated through future planning efforts.
For these reasons, we respectfully request that the City carefully evaluate whether the Mesa Verde Specific Plan, as proposed, reflects the long-term vision residents have for Calimesa or whether it would permanently erase the very qualities that make our community unique.
V. General Plan Consistency
California planning law requires that specific plans and development approvals be consistent with the City's adopted General Plan. The General Plan serves as Calimesa's long-term blueprint for growth and establishes policies intended to protect the health, safety, and welfare of current and future residents while preserving the City's unique identity.
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Before approving the Mesa Verde Specific Plan, the City should clearly demonstrate how the project is consistent with the goals and policies of the General Plan relating to land use, community character, public safety, circulation, conservation, open space, and environmental protection.
Residents are particularly concerned that the proposed density and scale of development may conflict with policies intended to preserve Calimesa's rural atmosphere, provide orderly transitions between neighborhoods, maintain adequate infrastructure, and protect environmentally sensitive resources.
If substantial amendments to the General Plan are required to accommodate this project, the City should carefully consider whether those amendments continue to reflect the community's vision for Calimesa or instead represent a significant departure from the planning principles that residents have long supported.
Ultimately, consistency with the General Plan is not merely a procedural requirement. It is intended to ensure that development occurs in a manner that preserves community values while promoting orderly, sustainable, and fiscally responsible growth.
VI. California Environmental Quality Act (CEQA)
Concerns
The California Environmental Quality Act (CEQA) requires public agencies to identify, disclose, and, where feasible, avoid or substantially lessen the significant environmental impacts of proposed projects before making approval decisions. CEQA exists not to prevent development, but to ensure that decision-makers and the public fully understand a project's environmental consequences and consider reasonable alternatives and mitigation measures.
Given the unprecedented scale of the Mesa Verde Specific Plan, we respectfully request that the City ensure its environmental review thoroughly evaluates both the direct and cumulative impacts of this project.
Particular attention should be given to:
● Traffic congestion and transportation infrastructure; ● Wildfire risk and emergency evacuation;
● Air quality and greenhouse gas emissions;
● Noise impacts to surrounding neighborhoods;
● Biological resources and wildlife habitat;
● Hydrology, drainage, and stormwater management;
● Water supply and long-term sustainability;
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● Public services and utilities;
● Geologic and seismic hazards;
● Visual resources and community character; and
● Cumulative impacts when considered together with existing and reasonably foreseeable development throughout Calimesa and neighboring communities.
Residents are especially concerned that wildfire evacuation has become one of California's most significant planning issues. Recent catastrophic fires throughout the state—including the Sandalwood Fire that affected Calimesa and the devastating Camp Fire in Paradise—demonstrate the importance of designing communities with multiple reliable evacuation routes and sufficient roadway capacity during emergencies.
The environmental review should also carefully evaluate biological resources. Calimesa lies within or adjacent to habitat supporting several protected and sensitive species, including the federally endangered Quino Checkerspot Butterfly, the Western Monarch Butterfly migration corridor, the endangered Crotch's Bumble Bee, the Western Burrowing Owl, and the San Diego Horned Lizard. Habitat fragmentation, increased human activity, roadway construction, lighting, and wildfire management all have the potential to affect these species and should be thoroughly analyzed using current biological surveys and accepted scientific methodologies.
Public safety concerns extend beyond wildfire. California Code of Regulations, Title 5, Section 14010(h), prohibits the siting of a school within 1,500 feet of an easement for an above-ground or underground pipeline carrying hazardous substances, petroleum, or pressurized natural gas, or being located near large public utility above-ground water or fuel storage tanks. The City should evaluate how the location of pipelines, above-ground water storage facilities, and other potentially hazardous infrastructure may affect future schools, parks, recreational facilities, and residential neighborhoods associated with this project.
Finally, we respectfully request that the City fully evaluate a reasonable range of project alternatives that would reduce environmental impacts while still meeting the project's stated objectives. Alternatives involving lower residential density, increased open-space preservation, improved neighborhood transitions, additional evacuation routes, and reduced traffic impacts should receive meaningful consideration before any final action is taken.
VII. Public Safety
The protection of public health and safety is the City of Calimesa's foremost responsibility when considering any proposed development. While residential growth can provide housing opportunities, it should never come at the expense of exposing current or future residents to avoidable hazards or creating unnecessary risks during emergencies.
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The Mesa Verde Specific Plan proposes a community of 3,650 residential units, together with parks, trails, recreational facilities, and the public infrastructure necessary to support thousands of new residents. A development of this scale requires careful consideration of emergency preparedness, hazardous infrastructure, wildfire evacuation, utility safety, and the long-term protection of the families who will live there.
As communities throughout California have experienced in recent years, disasters rarely occur under ideal circumstances. Wildfires, earthquakes, utility failures, hazardous material releases, and severe weather events often occur simultaneously or create cascading emergencies. Consequently, land use decisions should emphasize resilience, redundancy, and public safety rather than relying upon minimum regulatory compliance.
We respectfully request that the City require independent evaluations of all public safety issues before considering approval of the Mesa Verde Specific Plan.
Title 5, Section 14010(h) – School Siting and Hazardous Infrastructure California Code of Regulations, Title 5, Section 14010(h), establishes an important public safety standard near school sites. While this regulation specifically applies to school siting, its underlying public safety principles are equally relevant when evaluating large residential developments that will inevitably create future demand for schools, parks, recreational facilities, childcare centers, and other community-serving uses.
We respectfully request that the City require comprehensive mapping of all utilities affecting the project area, together with an evaluation of appropriate safety setbacks, emergency response capabilities, evacuation procedures, and long-term compatibility between residential development and existing utility corridors.
The City should also consider whether future residents will be fully informed of the presence of hazardous infrastructure prior to purchasing homes within the development.
Above-Ground Water Storage Facilities
The proposed development should also be evaluated with respect to any existing or planned above-ground water storage facilities serving the project that is adjacent to school sites.
The City should ensure that any proposed water storage infrastructure is designed to meet current engineering standards and does not create unnecessary public safety risks.
Adequate setbacks, structural integrity, emergency access, and long-term maintenance responsibilities should all be fully addressed before project approval.
VIII. Wildlife and Biological Resources
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This proposed project's location is part of a biologically significant region supporting numerous native plant and animal species that have become increasingly rare throughout Southern California.
The space surrounding the proposed project provides valuable habitat, migration corridors, nesting areas, and foraging opportunities for a variety of protected wildlife. As development continues throughout the region, these remaining natural areas become increasingly important for maintaining biodiversity and ecological connectivity.
We respectfully request that the City ensure all biological resource studies are objective, thorough, scientifically sound, and conducted during appropriate seasonal survey periods. Habitat conditions can change significantly over time, and outdated biological surveys may fail to accurately reflect existing environmental conditions. Even where individual projects may appear to have limited biological impacts, the gradual fragmentation of habitat across multiple developments can significantly affect species survival.
Quino Checkerspot Butterfly
The federally endangered Quino Checkerspot Butterfly has experienced dramatic population declines due primarily to habitat loss and fragmentation throughout Southern California.
Remaining habitat supporting this species is both limited and highly sensitive to disturbance. Development activities that remove native vegetation, alter drainage patterns, increase recreational use, or fragment open-space corridors may adversely affect habitat capable of supporting this endangered butterfly.
Western Monarch Butterfly
The Western Monarch Butterfly has experienced substantial population declines throughout California during recent decades. Calimesa lies within a region that contributes to the migration and seasonal movement of Western Monarch populations.
Native flowering plants, nectar sources, and habitat connectivity are essential components supporting these migrations.
Removal of native vegetation and continued urbanization may reduce the availability of these important resources.
Crotch's Bumble Bee
The endangered Crotch's Bumble Bee is one of California's most imperiled native pollinators. Native bees perform critical ecological functions by pollinating both wild vegetation and agricultural crops. Their populations have declined due to habitat loss, pesticide exposure, invasive species, and landscape fragmentation. 8
This species depends upon diverse native flowering plants throughout its active season, preservation of natural habitat and pollinator-friendly landscaping should be incorporated into project design wherever feasible.
Western Burrowing Owl
The Western Burrowing Owl occupies open grasslands and agricultural landscapes similar to portions of the proposed project area.
Unlike many owl species, Burrowing Owls nest underground, making them particularly vulnerable to grading and construction activities. Even where active burrows are not immediately present, repeated disturbance may reduce the suitability of habitat over time.
San Diego Horned Lizard
The San Diego Horned Lizard's habitat has steadily declined as urban development has expanded throughout Southern California.
This species relies upon native shrublands and open habitat supporting the harvester ants that comprise much of its diet. Habitat fragmentation, increased roadway traffic, invasive species, and landscape alteration all contribute to continued population declines.
Long-Term Stewardship of Biological Resources
The preservation of biological resources extends beyond project approval. Habitat areas require ongoing management, invasive species control, fire management, monitoring, restoration, and enforcement of protective measures.
Accordingly, if this project is approved, the City should require the developer to establish a permanent funding mechanism dedicated to the long-term stewardship of preserved habitat and open-space areas. This funding should remain available long after project construction has been completed, ensuring that future maintenance responsibilities do not become an unfunded obligation borne by Calimesa taxpayers.
We respectfully request that the City ensure comprehensive biological surveys have evaluated the presence of suitable habitat and considered both direct and indirect impacts associated with this project. incorporates landscape designs that support native pollinators rather than relying primarily upon ornamental landscaping. The City needs to ensure the developer incorporates landscape designs that support native pollinators rather than relying primarily upon ornamental landscaping. 9
The biological richness of Calimesa is one of the City's defining assets. Protecting these resources is not only an environmental responsibility but also an investment in preserving the natural heritage that makes Calimesa unique for future generations.
IX. Wildfire Risk and Emergency Evacuation
Wildfire preparedness and emergency evacuation planning must be among the highest priorities when considering any large-scale development in Calimesa. The increasing frequency, intensity, and speed of wildfires throughout the state demonstrate that communities must be designed not only for normal daily conditions but also for worst-case emergency scenarios.
The Mesa Verde Specific Plan proposes thousands of new residents living within a landscape that includes open space, natural vegetation, hillsides, and areas that may be susceptible to wildfire. While open space can provide valuable environmental benefits, it can also present significant fire-management challenges if vegetation, access, fuel reduction, and evacuation routes are not carefully planned.
Emergency evacuation planning should not rely on assumptions that residents will have adequate time to leave. During major fires, roads may become blocked by flames, smoke, fallen trees, emergency vehicles, or traffic congestion. A community's safety depends on multiple reliable evacuation routes–this plan consists of only two roads, insufficient roadway capacity, and lacks general safety consideration for residents and/or employees in the area.
The City should require further serious comprehensive wildfire evacuation analysis prepared by qualified professionals using current fire behavior modeling and realistic emergency scenarios. That analysis should evaluate the ability of residents to evacuate during a fast-moving wildfire while also accounting for emergency responders entering the area.
Lessons from the Sandalwood Fire
The City of Calimesa has firsthand experience with the devastating consequences of wildfire. The Sandalwood Fire demonstrated how quickly a fire emergency can develop and how critical evacuation planning, emergency access, and preparedness are for protecting residents.
During that incident, students at Mesa View Middle School were trapped on campus while the surrounding area was affected by fire conditions and a number of residents of the mobile home park lost their lives. This event serves as a reminder that emergency situations can overwhelm normal transportation systems and that communities must have adequate evacuation options before a disaster occurs. 10
The Sandalwood Fire should be viewed as a planning lesson. Future development decisions must account for the reality that wildfire risk is not theoretical. New residential areas should be designed to provide safe evacuation routes, adequate emergency access, and defensible space without placing existing residents or future residents at unnecessary risk.
Lessons from the Paradise Fire
The catastrophic Camp Fire in Paradise, California, demonstrated the consequences of limited evacuation capacity. Many residents were forced to evacuate under dangerous conditions as the two lane road became congested and emergency access became increasingly difficult.
Although each community has unique circumstances, Paradise provides an important planning lesson: evacuation routes must be evaluated before development occurs, not after a disaster exposes deficiencies.
The City of Calimesa should carefully consider whether the proposed Mesa Verde Specific Plan provides sufficient evacuation redundancy for both current and future residents. The question should not be whether evacuation is possible under normal conditions, but whether evacuation remains possible during a worst-case wildfire scenario.
Need for Additional Evacuation Routes
Based on the project maps and proposed circulation system, City residents should be concerned about potential evacuation limitations affecting portions of the development, particularly if open-space areas identified in Figure 2, including OS-N 91, OS-N 93, and OS-N 110, were impacted by wildfire.
If those areas became affected by fire, earthquake or any other natural disaster, portions of the western area could potentially be trapped without any means of evacuation.
Reliance on a limited number of primary access points creates a vulnerability that should be addressed before construction begins.
The City should require additional entrance and exit routes, especially for the west side of this proposed development. Consideration is needed for improved roadway redundancy and emergency access planning that protects both new residents and existing neighborhoods.
Approval of a project of this magnitude should be conditioned upon demonstrating that evacuation routes meet the needs of the entire community—not only under ordinary circumstances, but during the type of emergency events California communities increasingly face.
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X. Geology and Faulting
Geologic safety is another important consideration when evaluating development within Southern California. Although the developer reports that the local fault is inactive, we as residents know otherwise. The region is characterized by active seismic conditions, and responsible planning requires careful evaluation of potential earthquake hazards before approving large residential projects.
The project documentation indicates that identified faults within the development area have been determined to be inactive. However, the City should also consider the broader regional seismic environment, including nearby fault systems and the potential for ground shaking, secondary hazards, and infrastructure impacts.
Residents along and near W. County Line Road have reported observations including cracks in interior and exterior home walls, driveways, and other property features over time. Recently, one resident on W. County Line Rd had her in-ground swimming pool condemned because of thirteen cracks caused by small earthquakes. The pool maintenance company stated they "could no longer service her pool because their chemicals were leaching out of the cracks into the natural environment." These local observations demonstrate the importance of ensuring that geotechnical conclusions are based upon thorough investigation and objective independent review.
The City should require a comprehensive peer review of all geotechnical studies by an objective and independent qualified professional before project approval. This review should be transparent and evaluate:
● Seismic hazards;
● Ground shaking potential;
● Fault rupture concerns;
● Soil stability;
● Liquefaction potential;
● Landslide risks;
● Infrastructure resilience; and
● Long-term safety of residential structures and public facilities.
A development of this size will introduce thousands of residents and substantial infrastructure investment. The City has a responsibility to ensure that geologic hazards have been fully evaluated and that appropriate design standards and mitigation measures are incorporated.
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XI. Traffic and Air Quality
The transportation impacts of the Mesa Verde Specific Plan represent a major concern for existing residents. A development consisting of 3,650 homes (as well as the commercial, business, multiuse, etc.) will generate a substantial increase in daily vehicle trips, placing additional pressure on roads that already serve existing neighborhoods, regional commuters, commercial uses, and freight traffic.
Using a conservative estimate of approximately 2.5 vehicles per household, the project would introduce more than 9,000 additional resident vehicles into the local area. Even if only a portion of those vehicles use W. County Line Road ("Street A"), the increase would significantly affect air pollution, vehicle congestion, travel times, roadway safety, and emergency response capabilities.
W. County Line Road is especially concerning because it is expected to function as one of the two primary divided collector routes serving the development. Existing residents may experience overall gridlock at the freeway entrance , as well as even basic difficulty entering and exiting their properties from the road, particularly during peak travel periods.
The project traffic must also be evaluated in combination with existing and approved regional traffic sources, including:
● Interstate 10 interchange activity;
● Commercial traffic;
● Truck routes;
● Fueling and service facilities;
● Warehouse and industrial traffic; and
● Future development throughout the region.
A traffic analysis that considers only the project itself may underestimate the actual burden placed on local roads. The City should require a comprehensive cumulative traffic study that reflects realistic future conditions.
Air Quality Impacts
Increased traffic will also affect air quality. More vehicles mean increased emissions from vehicle exhaust, brake dust, tire particles, and idling during congestion. These impacts are especially concerning for residents living near major traffic corridors, Mesa View Junior HS students, and those students attending the proposed elementary schools.
Construction activities associated with thousands of homes will also generate temporary air quality impacts through grading, excavation, heavy equipment use, and increased truck activity.
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The City should require meaningful mitigation measures, including:
● Transportation improvements;
● Traffic management strategies;
● Construction emission controls;
● Dust suppression measures;
● Reduced vehicle dependency where possible; and
● Monitoring of air quality impacts.
The rural environment currently enjoyed by many Calimesa residents contributes to the community's quality of life. Increased traffic congestion and declining air quality would represent a permanent change that should be seriously and fully considered before approving this project.
A responsible development plan must balance housing growth with the preservation of safe roads, clean air, and a livable community for existing and future residents of Calimesa.
XII. W. County Line Road Impacts
The proposed Mesa Verde Specific Plan will significantly affect existing residents along W. County Line Road ("Street A"). While roadway improvements and widening may be necessary to support a development of this size, those improvements must be carefully evaluated to ensure that the burden of accommodating new growth does not unfairly fall on existing residents.
W. County Line Road currently serves a community with a rural residential character.
Existing homes along this corridor vary in architectural style, lot size, and land use. Many properties include open space and agricultural characteristics that allow residents to maintain animals and enjoy a lifestyle that reflects the traditional character of Calimesa.
The proposed development would dramatically increase the intensity of use along this corridor. Considering the 3650 new residential units alone, the amount of daily traffic generated by the project would substantially change the current function of W. County Line Road.
Based on a conservative estimate of approximately 2.5 vehicles per residential unit, the project would introduce more than 9,000 additional vehicles associated with future residents. If even half of those vehicles utilize W. County Line Road as part of their daily travel patterns, existing residents could experience thousands of additional vehicle trips every day.
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This increase would occur in an area already affected by regional traffic demands, including:
● Interstate 10 access and freeway congestion;
● Commercial traffic;
● Truck routes;
● Convenience Store Usage;
● Fueling and service facilities;
● Regional warehouse traffic; and
● Future development throughout the surrounding area.
The combination of residential traffic and commercial truck traffic raises concerns about congestion, roadway safety, noise, and air quality. Existing residents may face increased difficulty entering and exiting their driveways, particularly during peak commute periods with the new road capacity resulting from the population growth from the proposed Mesa Verde development project.
As residents we are also concerned that project mapping and public materials may not fully communicate the extent of roadway widening, improvements, or potential right-of-way impacts along W. County Line Road. The City should ensure they provide clear and transparent information showing:
● The final roadway design;
● Proposed widening areas;
● Potential property impacts;
● Pedestrian and bicycle improvements;
● Emergency access routes; and
● Construction impacts.
Affected homeowners deserve a complete understanding of how the project may change their properties and daily lives before the City approves a project of this magnitude.
If roadway expansion is required, the City should require the developer to work collaboratively with affected property owners and consider design solutions that create an asthetically acceptable and functionally compatible transition between existing neighborhoods and the proposed development. If the project is approved, the City should consider requiring the developer to offer voluntary, fair-market buyout options to property owners along West County Line Road whose homes may be significantly affected by project-related roadway improvements or adjacent high-density development.
XIII. Neighborhood Compatibility
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A fundamental principle of responsible planning is that new development should be compatible with the neighborhoods that surround it. Compatibility does not require every property to remain unchanged; however, it does require thoughtful consideration of scale, density, design, traffic, and quality-of-life impacts.
The Mesa Verde Specific Plan represents a significant change in land use intensity.
Existing rural residential neighborhoods near the project area were developed with larger lots, lower traffic volumes, and a more open landscape. The proposed development introduces a substantially different pattern of development, with thousands of homes, increased roadway infrastructure, and higher population density.
The transition between existing neighborhoods and the proposed project should be carefully designed. Abrupt changes from rural properties to high-density residential development can negatively affect neighborhood character and create long-term conflicts between existing and future residents.
W. County Line Road provides an example of this concern. Existing residents have homes with individual designs, varying acreage, mature landscaping, and agricultural uses. Many residents maintain animals and use their properties in ways consistent with Calimesa's rural traditions.
Placing a large-scale residential subdivision directly adjacent to these properties risks creating an incompatible mix of uses. Increased traffic, noise, lighting, pollution, and reduced privacy may substantially change the quality of life currently enjoyed by existing residents.
The City should require a design approach that includes:
● Adequate buffers between existing rural properties and new development; ● Preservation of meaningful open-space areas;
● Appropriate transitions in density and building scale; ● Protection of existing residents' privacy;
● Reduced lighting impacts;
● Noise mitigation; and
● Preservation of scenic views where feasible.
The goal should not simply be to maximize the number of residential units constructed.
The goal should be to create a community that integrates successfully with the existing character of Calimesa.
A development that permanently eliminates the rural qualities residents value would represent a significant loss to the entire community.
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XIV. Fiscal Responsibility and Long-Term Maintenance
Obligations
The financial impacts of the Mesa Verde Specific Plan must be carefully evaluated before approval. Large developments create long-term obligations for cities, including maintenance of roads, parks, trails, open space, landscaping, drainage systems, public facilities, and emergency services.
While new development may generate additional revenue, it also creates ongoing costs that continue long after construction is complete. The City must ensure that future maintenance responsibilities do not become an unfunded burden on existing residents or require reductions in other essential services.
The proposed project includes:
● 50.3 acres of public parks; and
● 497.2 acres of open space and trails.
These areas represent valuable community amenities, but they also require significant long-term resources. Maintaining open space requires ongoing funding for:
● Vegetation management;
● Fire fuel reduction;
● Habitat protection;
● Trail maintenance;
● Landscaping;
● Irrigation;
● Public safety;
● Trash removal;
● Repairs; and
● Monitoring.
The City should carefully consider whether it currently has the financial capacity to maintain these areas at the level promised to residents.
Existing concerns regarding public access, maintenance, and safety at community facilities demonstrate why long-term funding mechanisms must be established before approving additional obligations. The City should not approve hundreds of additional acres of public amenities without a guaranteed plan is in place for their future care.
Perpetual Maintenance Trust Fund
If the Mesa Verde Specific Plan is approved, the developer should be required to establish a perpetual maintenance trust fund dedicated specifically to the preservation 17
and maintenance of parks, trails, open space, landscaping, and habitat areas created by the project.
This fund should be legally protected and structured so that it remains available after the developer has completed construction and transferred ownership responsibilities.
The purpose of this requirement is simple: the entity creating the long-term maintenance obligation should provide the financial resources necessary to sustain it.
Developer Funding Per Residential Unit
A fair and responsible approach would require the developer to contribute a defined amount for every residential unit constructed into the maintenance trust fund.
With approximately 3,650 residential units proposed, even a modest per-unit contribution could create a meaningful long-term funding source for:
● Park operations;
● Open-space management;
● Fire prevention activities;
● Habitat stewardship;
● Trail maintenance; and
● Public safety needs.
This approach would protect existing Calimesa taxpayers from inheriting future costs associated with a development they did not create.
The City should also evaluate whether additional financing mechanisms, such as a community facilities district or similar funding structure, are appropriate to ensure that the project remains financially sustainable.
Fiscal responsibility requires looking beyond the initial approval and construction phase.
The true cost of a development includes decades of operation, maintenance, and public service demands. The City must ensure that the Mesa Verde Specific Plan strengthens Calimesa rather than creating future financial challenges for the community.
Before approval, the City should require a complete financial analysis demonstrating that the project can support its own long-term obligations without negatively affecting existing residents.
XV. Creekside Park and Existing Open-Space
Management Concerns
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The proposed Mesa Verde Specific Plan includes 50.3 acres of public parks and 497.2 acres of open space and trails. These features are presented as important community benefits; however, the City must demonstrate that it has a realistic and sustainable plan for maintaining, securing, and managing these areas over the long term.
Residents have legitimate concerns based on current conditions at existing public facilities. Creekside Park, located near 7th Street and County Line Road ("Street A"), has reportedly been mostly unavailable for public use for an extended period of time.
Residents have also expressed concerns regarding conditions in the adjacent dry riverbed/open-space area, including homeless encampments, safety issues, and impacts affecting surrounding neighborhoods. Residents frequently witness drug deals and littered paraphernalia along our streets and lining our easements.
These concerns raise an important question: if the City is currently experiencing challenges maintaining and protecting existing park and open-space areas, what assurances can be provided that nearly 550 additional acres of parks, trails, and open space associated with the Mesa Verde Specific Plan will be properly maintained and available for public benefit?
Open space is only a community asset if it is:
● Safe for residents to access;
● Properly maintained;
● Protected from degradation;
● Managed for fire prevention;
● Monitored for public safety;
● Maintained for habitat preservation; and
● Financially supported over time.
The City should not approve additional public amenities without a clear and enforceable plan demonstrating how those areas will be managed after construction is complete.
If approved, the Mesa Verde Specific Plan should include legally binding requirements establishing responsibility for long-term maintenance. The developer should be required to provide adequate funding mechanisms before the transfer of parks, trails, and open-space responsibilities to the City or another entity.
The City should also consider whether the proposed open-space areas will function as meaningful environmental resources or simply become isolated remnants surrounded by development. Open space should preserve wildlife habitat, provide recreational opportunities, reduce wildfire risk, and enhance community quality of life—not create additional unfunded obligations or public safety challenges. 19
XVI. Specific Requests to the Planning Commission and
City Council
Based on the concerns outlined throughout this letter, we respectfully request that the Planning Commission and City Council take the following actions before approving the Mesa Verde Specific Plan:
1. Require a Complete and Transparent Environmental Review The City should ensure that all environmental review documents fully analyze the project's direct, indirect, and cumulative impacts, including:
● Traffic;
● Air quality;
● Greenhouse gas emissions;
● Noise;
● Biological resources;
● Wildlife habitat;
● Water resources;
● Wildfire risk;
● Evacuation capacity;
● Geologic hazards;
● Public services; and
● Community character.
Any significant impacts should be fully and transparently disclosed, and all feasible mitigation measures should be required.
2. Require Additional Wildfire and Evacuation Analysis
The City should require an independent wildfire evacuation study addressing worst-case scenarios, including:
● Fast-moving wind-driven fires;
● Multiple road closures;
● Emergency responder access;
● Evacuation timing;
● Traffic congestion during evacuation;
● Adequacy of existing routes; and
● Need for additional entrances and exits.
The project should not move forward unless evacuation capacity is demonstrated to protect both future residents and existing neighborhoods. 20
3. Require Additional Transportation Improvements
The City should require a comprehensive traffic analysis that evaluates cumulative impacts from:
● The Mesa Verde development;
● Existing regional traffic;
● Interstate 10 access;
● Semi-Truck Warehouse traffic;
● Commercial uses; and
● Future development.
Any roadway improvements necessary to accommodate the project should be clearly identified and funded by the development rather than shifting costs to existing residents.
4. Protect Existing W. County Line Road Residents
The City should provide complete transparency regarding any proposed roadway expansion, widening, right-of-way acquisition, or property impacts along County Line Road ("Street A").
Affected residents should have a clear understanding of proposed changes before any approval occurs.
The City should also require design measures that create a compatible transition between existing rural properties and the proposed development.
The City should consider requiring the developer to provide voluntary, fair-market buyout options for current West County Line Road residents directly affected by project-related changes.
5. Require Strong Wildlife Protection Measures
The City should require updated biological surveys and appropriate mitigation measures for sensitive species, including:
● Quino Checkerspot Butterfly;
● Western Monarch Butterfly;
● Crotch's Bumble Bee;
● Western Burrowing Owl; and
● San Diego Horned Lizard.
Preserved habitat areas should receive long-term protection and funding.
6. Establish a Permanent Maintenance Funding Requirement 21
Before approving the project, the City should require the developer to establish a perpetual maintenance trust fund or similar legally protected funding mechanism.
The fund should include a mandatory contribution for every residential unit constructed and should provide sufficient resources for:
● Parks;
● Trails;
● Open space;
● Habitat management;
● Fire fuel reduction;
● Landscaping; and
● Public safety.
The financial responsibility for maintaining project-created amenities should remain with the project rather than becoming an obligation of future taxpayers.
7. Evaluate General Plan Consistency
The City should carefully determine whether the Mesa Verde Specific Plan is consistent with Calimesa's long-term vision regarding:
● Rural character;
● Open-space preservation;
● Compatible development;
● Public safety;
● Infrastructure capacity; and
● Quality of life.
If the project represents a substantial departure from the City's adopted vision, that issue should be openly addressed before approval.
8. Consider a Reduced-Intensity Alternative
The City should evaluate alternatives that would:
● Preserve additional open space;
● Reduce traffic impacts;
● Improve evacuation safety;
● Protect wildlife habitat;
● Maintain neighborhood compatibility; and
● Preserve the rural qualities that define Calimesa.
22
XVII. Conclusion
The decision before the City of Calimesa is not simply whether to approve additional housing. It is a decision about the future identity, safety, and sustainability of the community.
The Mesa Verde Specific Plan represents a permanent transformation of land that has long contributed to Calimesa's rural character, open-space values, wildlife habitat, and quality of life. A project of this scale will affect not only the future residents who move into the development but also the existing families, neighborhoods, and natural resources that define Calimesa today.
The City must carefully weigh the benefits of additional housing against the long-term consequences of increased density, traffic, infrastructure demands, wildfire risk, environmental impacts, and loss of community character.
Growth should not come at the expense of the qualities that make Calimesa unique.
We respectfully request that the Planning Commission and City Council prioritize public safety, environmental stewardship, fiscal responsibility, and the preservation of Calimesa's identity when considering the Mesa Verde Specific Plan.
For these reasons, we respectfully request that the project be denied in its current form unless and until the significant concerns identified in this letter are fully addressed through additional analysis, meaningful mitigation, enforceable conditions, and a development plan that truly serves the long-term interests of the entire Calimesa community.
Thank you for your consideration and for your responsibility to protect the future of our City.
Respectfully submitted,
Concerned Residents of 780 W. County Line Rd, Calimesa, CA Saralyn Tossetti
Griffin Tossetti
Jennifer Gysbers
Pamela Salazar
Gary Salazar
23
Outlook
6/23/26- MESA VERDE SPECIFIC PLAN
From SCG SE Region Redlands Utility Request <[email protected]> Date Tue 6/23/2026 9:38 AM
To Yaiza Benson <[email protected]>
Cc SCG SE Region Redlands Utility Request <[email protected]> 1 attachment (3 MB)
20260623070110.pdf;
External ([email protected]) Report This Email FAQ Protection by INKY
Hello,
Regarding: MESA VERDE SPECIFIC PLAN
SoCalGas Distribution does not appear to have a conflict with this project, but we do fave facilities in the area. Please include a note to have the developer contact 811 / USA at DigAlert | Utility Locating California | Underground Wire & Cable Locator prior to any excavation / demolition activities so we can Locate & Mark out our facilities.
If the Developer needs new gas service, please have them contact our Builder Services group to begin the application process as soon as practicable, at https://www.socalgas.com/for-yourbusiness/builder-services.
To avoid delays in processing requests and notifications, please have all Franchise correspondence sent to our Utility Request inbox.
Utility Request Contact Information by Region
Southeast Region – Redlands
For requests in the southeastern areas of Los Angeles County, Riverside County, San Bernardino County, and Imperial County, please contact:
[email protected]
Southeast Region – Anaheim
For all of Orange County and the southern portions of Los Angeles County, please send Map and/or Will Serve Letter requests to:
AtlasRequests/[email protected]
Northwest Region – Compton HQ
For West and Central Los Angeles County, please direct Map Requests and Will Serve Letters to:
[email protected]
Northwest Region – Chatsworth
For requests from the northernmost parts of Los Angeles County extending up to Visalia, San Luis Obispo, Fresno, and Tulare, please contact:
[email protected] Shared with Planning Commission via email on 07/02/2026
Transmission
For Transmission-related requests, please contact:
[email protected]
New Business
For new gas service, please contact our Builder Services group to begin the application process:
https://www.socalgas.com/for-your-business/builder-services Project Notification Requirements
Minor Street Improvement Projects
(Chip Seal, Slurry Seal, Grind & Overlay)
Please notify SoCalGas (SCG) a minimum of four (4) months prior to the start of pavement work to allow sufficient time to conduct required leak surveys and any necessary repairs.
Major Street Improvement Projects
Projects including, but not limited to:
Excavations greater than 9 inches
Street widening
Installation of new curbs and gutters
Bus pads
Traffic signals
Street realignments
Grade separations
AND
Pipeline Projects
Including:
Storm drain
Water and sewer lines
Electrical
Telecommunications
Please provide signed and approved design plans showing all SCG facilities clearly identified:
4–6 months prior to construction for potential relocation of SCG medium‑pressure facilities.
9–12 months prior to construction for potential relocation of SCG high‑pressure facilities.
This time is required to review plans and design any necessary modifications to conflicting SCG facilities.
Coordination & Relocation Requests
Please keep SCG informed of:
Pre‑construction meetings
Construction schedules
Project phasing updates
This information allows SCG to coordinate and schedule any required work.
Potholing may be required to determine whether conflicts exist between proposed improvements and existing SCG facilities.
If SCG facilities are in conflict and relocation is required, requests must be submitted in writing and include the following:
A signed “Notice to Owner” on official City, County, and/or company letterhead.
Project name, number, and responsible title.
Project address, location, anticipated start date, parameters, and full scope of work.
A Thomas Guide page and/or Google Maps screenshot clearly highlighting the project area.
Requestor company’s contact name, title, phone number, email address, and any additional relevant information.
Thank you,
Josh Rubal
Lead Planning Associate
Distribution Planning & Project Management (Franchise)
Redlands HQ - Southeast Region
Office: (213) 231-7978
Email: [email protected]
Outlook
Attention : Deputy City Clerk
From Suzee Wills <[email protected]>
Date Mon 8/3/2026 10:33 AM
To Yaiza Benson <[email protected]>
Caution: External ([email protected])
First-Time Sender Details
Report This Email FAQ Protection by INKY
City of Calimesa Planning Commission,
Please accept this letter as our FORMAL OPPOSITION to the proposed Mesa Verde Specific Plan Amendment 2 Project, Environmental Assessment NO. EA-23-02 and Subsequent Environmental Impact Report (SEIR) (SCH No. 2004071045), General Plan Amendment NO. GPA-23-01, Development Agreement, Specific Plan Amendment NO.23-01/Zone Change NO. 23-01, scheduled for public hearing on July 13, 2026.
I am writing to state my explicit and formal objection.
As a local stakeholder and resident, I urge the Planning Commission to deny certification of the SEIR and reject the General Plan Amendment. The SEIR is legally inadequate under the California Environmental Quality Act (CEQA) because it completely fails to analyze severe, localized environmental impacts on West County Line Road residents. Furthermore, the proposed amendments fundamentally destroy the "Rural" character guaranteed to this community in the 2017 approved plan.
My formal objections are based on the following unaddressed, unmitigated impacts:
1. Inadequacy of the SEIR Regarding Localized Traffic and Resident Safety The project’s Traffic Analysis indicates that the development will generate an astronomical **24,000 daily vehicles and heavy truck traffic trips**. Despite this staggering volume, the SEIR is entirely silent on how this influx will impact the safety and daily operations of the residents living along West County Line Road.
This specific section of West County Line Road is zoned rural/residential. A large percentage of residents here own trailers, boats, and RVs. Due to current road configurations and residential designs, backing into our driveways is a structural necessity. Forcing residents to maneuver large trailers and RVs into their driveways while competing with 24,000 daily vehicle trips is an extreme safety hazard that will render routine property access physically impossible. The SEIR’s complete failure to evaluate this critical barrier to localized traffic safety and property access invalidates its findings and should negate its certification.
### 2. Unanalyzed Encroachment, Setback Violations, and Property Value Loss The project proposes to widen County Line Road to its maximum 60-foot right-of-way width. This widening severely encroaches upon existing residential homes, placing the active roadway directly inside the current 30-foot residential setback established by the City of Calimesa.
The SEIR contains zero analysis regarding how violating these established setbacks will impact local residents. Furthermore, the SEIR completely ignores the devastating **loss of property value** that Shared with Planning Commission via email on 08/03/2026
West County Line Road homeowners will suffer. Converting a quiet, rural residential street into a highvolume logistics and transit corridor—while physically encroaching onto private properties and erasing established safety setbacks—inflicts severe financial injury on homeowners that has been entirely unacknowledged by the City and the developer.
### 3. Severe Omissions of Localized Noise and Air Pollution The SEIR is fundamentally flawed because it fails to evaluate the localized noise and air pollution impacts forced specifically upon the West County Line Road residential corridor:
* **Noise Pollution:** Introducing 24,000 daily trips, including heavy diesel trucks idling, braking, and accelerating directly adjacent to residential bedrooms, will shatter the ambient noise levels of this rural zone. The SEIR fails to address the lack of sound walls or mitigation measures required to protect residents from 24/7 acoustic disruption.
* **Air Pollution:** West County Line Road residents will be subjected to concentrated diesel particulate matter (DPM), fine particulate matter ($PM_{2.5}$), and localized emissions from heavy truck traffic. The SEIR fails to conduct a localized Health Risk Assessment (HRA) for these specific residents, ignoring the heightened risks of respiratory illness and toxic air contaminants brought directly to our doorsteps.
### 4. Failure to Account for Existing Cumulative Truck Traffic The cumulative impact analysis in the SEIR is deeply flawed because it fails to calculate or factor in the actual, active truck traffic originating from the newly built Yucaipa warehouse located at the I-10 and County Line Road offramp. By ignoring this existing bottleneck and heavy vehicle load, the SEIR relies on inaccurate baseline data, rendering its traffic, air quality, and noise projections completely invalid. ### 5. Violation of the General Plan, Destructive Land Use Alteration, and Elimination of Rural Options The General Plan Amendment must be rejected because it completely strips away the "Rural" character explicitly promised and heavily emphasized in the 2017 approved plan. Amendment 2 aggressively eliminates low-density, rural living options by completely removing the **Very Low Density** residential category. Furthermore, it slashes the **Low Density** category by 289 lots and the **Medium Density** category by 219 lots.
In place of these rural options, the developer is forcing extreme urban density and industrialization onto our community. **Extreme High Density** residential increases by 250 lots, and **Multifamily High Density** spikes by 432 units. Compounding this destruction is the addition of **4,133,800 square feet of massive warehouse business parks**. This industrial encroachment completely violates the 2017 approval that embraced a cohesive rural theme.
To make matters worse, the developer is attempting to alter primary project access points. In the 2017 approval, Sandalwood Drive was designated as the main access route for residential development, while County Line Road was strictly designated as emergency-access-only and secured with a gate.
Amendment 2 attempts to flip this entirely by making County Line Road a main access point, dumping massive amounts of daily residential and industrial traffic onto a rural residential corridor that was never designed or intended to handle it.
Conclusion
Because the SEIR fails to address localized driveway access, ignores the violation of the City's own 30- foot setbacks, fails to baseline existing Yucaipa warehouse truck traffic, and completely omits localized property value loss, noise pollution, and air pollution impacts, it cannot legally be certified under CEQA.
For these reasons, I reiterate my formal objection to every project action listed on the hearing notice. I respectfully request that the Planning Commission recommend **denial** of the Mesa Verde Specific Plan Amendment 2 and the associated General Plan Amendment to the City Council.
Mesa Verde already has an approval for their project. Amendment 2 looks nothing like the original in which countless hours were put in by not only the City staff, but the residents of Calimesa in shaping the project to its approval. This was all built around the “Rural” character of Calimesa. Creating a high
density mega development but leaving more open area to bait us with ruralness does NOT work.
Amendment 2 has issues that can not be mitigated as stated in the SEIR, and that fact alone should be enough to send this back with a NO VOTE.
Thank you for your time and consideration of our community's safety, identity, and integrity.
Sincerely,
Lee & Suzee Wills
Family home since 1953
801 W County Line Rd
Calimesa, Ca 92320
Sent from my iPhone
Mesa Verde Specific Plan Area 2
Amendment 2 Project
Responses to Additional
Comments Received – Vol. I
State Clearinghouse No. 2004071045
AUGUST 2026
Prepared by:
CITY OF CALIMESA
908 Park Avenue
Calimesa, California 92320
Prepared with assistance from:
225 South Lake Avenue, Suite M210
Pasadena, California 91101
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1 Introduction
The City of Calimesa (City) has received additional public comments letters after the close of the public review period for the Draft Subsequent Environmental Impact Report (SEIR)1 for the Mesa Verde Specific Plan Area 2 Amendment 2 Project (Project) and prior to the Planning Commission hearing on August 10th, 2026. As shown in Table 1, as of July 28, 2026, the City received a total of seven additional comment letters on the Project and/or SEIR (inclusive of the Draft and Final SEIR) from one organization, one utility company, three individuals, and two agencies. These additional comment letters (referred to herein as “Vol. I”) are organized into four categories:
Category A (written comments from public agencies and jurisdictions), Category U (written comments from utility companies), Category O (written comments from organizations), and Category I (written comments from individuals).
Table 1. Comment Letters and Commenters (Vol. I)
Comment
Letter Commenter Type Date Received
Agency/Jurisdiction
A1 Santa Ana Regional Water Quality Control Board Agency July 10, 2026 A2 California Department of Transportation, District 8 Agency July 13, 2026 Utility
U1 Southern California Gas Company Utility June 23, 2026 Organization
O1 Bicycle Commuter Coalition of the Inland Empire Organization July 9, 2026 Individual
I1 Juan Banuelos Individual June 22, 2026
I2 Saralyn Tossetti Individual June 23, 2026
I3 Concerned Residents of 780 W. County Line Rd. Individuals July 2, 2026 For reference purposes, each comment letter has been assigned a corresponding letter based on category and numbered in order of date received, starting with the earliest date. In turn, each specific comment within a particular letter has also been numbered and bracketed. For example, the second comment in letter “A1” is identified as “Comment A1-2.” The corresponding response uses the same convention, so the reader can match each response to the comment to which it refers. The bracketed letter precedes responses to the letter’s comments.
Most comments received were adequately addressed in the SEIR and/or were previously responded to in Chapter 8, Response to Comments, of the Final SEIR. Regardless, all comments submitted have been responded to below.
As presented in Section 2 of this document, none of the comments received identified deficiencies in the SEIR analysis that would require recirculation of the SEIR pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15088.5, Recirculation of an Environmental Impact Report Prior to Certification. CEQA Guidelines Section 15088.5 is provided below for reference:
A lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review under Section 15087 but before 1 The Draft SEIR was circulated for public review from July 11, 2025, through August 25, 2025, in accordance with Section 15105(a) of the California Environmental Quality Act Guidelines.
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certification. As used in this section, the term “information” can include changes in the project or environmental setting as well as additional data or other information. New information added to an EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. “Significant new information” requiring recirculation include, for example, a disclosure showing that:
A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance.
A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the environmental impacts of the project, but the project’s proponents decline to adopt it.
The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. (Mountain Lion Coalition v. Fish and Game Com. (1989) 214 Cal.App.3d 1043)
Although no comments have been raised that would require revisions to the SEIR, these comments and responses are available to the Planning Commission for their review and consideration as part of their deliberations on the Project’s environmental documentation.
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2 Comments and Responses
This section presents responses to all additional comments received as of July 28, 2026.
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Response to Comment Letter A1
Santa Ana Regional Water Quality Control Board
Claudia Tenorio, Senior Environmental Scientist (Supervisory), Regional Planning Programs Section July 10, 2026
A1-1 This introductory comment does not state any specific concerns with the analysis provided in the SEIR.
A1-2 The previous jurisdictional delineation, included as Appendix C to the 2017 Addendum for the Mesa Verde Estates Specific Plan EIR (2017 Addendum), was conducted by Glenn Lukos Associates on February 24, March 3 and 11, and April 7, 2014. In 2022, Dudek reviewed all features previously delineated in accordance with current state and federal policies (i.e., State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State, and the U.S. Army Corps of Engineers’ 1987 Corps of Engineers Wetlands Delineation Manual and its 2008 Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region [Version 2.0]).
Features previously mapped by Glenn Lukos Associates that do not overlap the current Dudek aquatic resource mapping did not display ordinary-high-water-mark indicators (e.g. bed and bank, shelving, break in slope at ordinary high water mark, scour, etc.) or other evidence of flow during field surveys conducted by Dudek. The Project Applicant is currently working with Santa Ana Regional Water Quality Control Board (Santa Ana Water Board) staff to update the jurisdictional delineation based on feedback received during the field visit to the Project site with Santa Ana Water Board staff on November 5, 2025, as well as feedback received from Santa Ana Water Board staff as recently as June 18, 2026. If it is determined that revisions to the aquatic resource features mapped within the Project site are necessary, these revisions will be addressed during the permitting process. The mitigation proposed in the SEIR as MM-BIO-11 includes a clearly defined performance standard that establishes restoration target ratios based on the final identified impact acreages (and not a total acreage), which will ensure impacts are adequately mitigated. (For the full text of MM-BIO-11, please refer to Section 4.3, Biological Resources of the Final SEIR, beginning on p. 4.3-83.) Therefore, no revisions to the SEIR are required.
This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
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Response to Comment Letter A2
California Department of Transportation, District 8
Abdullahi Bihi, Transportation Planner, Planning Division July 13, 2026
A2-1 This comment does not state any specific concerns related to the adequacy of the SEIR. California Department of Transportation District 8 is already listed as a Responsible Agency under CEQA in Section 1.7, Lead, Responsible, and Trustee Agencies and again in Section 3.11.3, Responsible Agency Approvals in the SEIR. The City and Project Applicant will work together to comply with all applicable California Department of Transportation District permitting requirements. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
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Response to Comment Letter U1
Southern California Gas Company (SoCalGas)
Josh Rubal, Lead Planning Associate – Distribution Planning and Project Management, Southeast Region June 23, 2026
U1-1 The comments provided are the same as those submitted by SoCalGas on July 31, 2025, for the Draft SEIR. These comments were included as Comment Letter U1 in the Final SEIR (see pp. 8-69 through 8-73 of the Final SEIR). As such, see Response to Comment Letter U1 of the Final SEIR (p. 8-73) for more discussion. This comment does not state any specific concerns related to the adequacy of the environmental analysis in the SEIR and does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
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Response to Comment Letter O1
Bicycle Commuter Coalition of the Inland Empire
Jonathan Baty, Government Affairs Manager
July 9, 2026
O1-1 This comment does not state any specific concerns related to the adequacy of the SEIR. The Project site is already approved for development (including 3,650 dwelling units) under the 2017 Specific Plan, as analyzed in the previously certified 2007 Mesa Verde Estates Specific Plan Final EIR and 2017 Addendum. The Project would not increase the number of dwelling units compared to the prior approval. As discussed throughout the SEIR, the Project would provide approximately 497 acres of open space areas (zoned as Open Space – Natural [OS-N]), in addition to public parks (zoned Open Space - Public [OS-PR]) and private recreation areas (zoned Open Space - Private [OS-PR]), as shown in Table 3-6 in Chapter 3, Project Description of the SEIR. The SEIR also acknowledges that fire history is an important component that contributes to the wildfire environment (see Final SEIR p. 4.18-4 in Section 4.18, Wildfire). Fire history for the general vicinity of the Project site is shown in SEIR Figure
4.18-3, Fire History Map. As discussed in Sections 4.3, Biological Resources, and 4.18, Wildfire, after implementation of proposed mitigation measures, the Project would not result in any significant impacts related to sensitive wildlife/habitat or wildfire hazards. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
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Response to Comment Letter I1
Juan Banuelos
June 22, 2026
I1-1 The commenter expresses opposition to a “proposed travel center” and states concern for traffic, noise, air quality, and public safety associated with the travel center. There is no travel center component proposed as part of the Mesa Verde Specific Plan Area 2 Amendment 2 Project (State Clearinghouse No. 2004071045; referred to in the SEIR and herein as the “Project”). The commenter appears to be conflating the Project with the Sandalwood Travel Center and Tentative Parcel Map 38215 (State Clearinghouse No. 2026020244), which is a separate project proposed by a different applicant directly to the east of the Project site on the east side of 7th Street (north of Sandalwood Drive). The Sandalwood Travel Center is identified as a cumulative project in the SEIR (see item No. 42 in Table 2-3, Final SEIR p. 2-13). Although the Sandalwood Travel Center is appropriately considered as part of the cumulative analyses provided throughout Chapter 4 of the SEIR, the focus of the SEIR analysis is on the potential environmental impacts (including potential traffic, noise, air quality, and public services impacts) associated with the Project as described in Chapter 3, Project Description of the SEIR, which does not include a travel center component.2 The Sandalwood Travel Center is subject to its own project-specific CEQA review process (specifically, an Initial Study/Mitigated Negative Declaration, which was circulated by the City for public review from February 6, 2026 to March 9, 2026). 3 This
comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
2 For more information on potential Project impacts related to traffic, see SEIR Section 4.15, Transportation; impacts related to noise, see SEIR Section 4.11, Noise; impacts on air quality, see SEIR Section 4.2, Air Quality; and impacts on public safety, see SEIR Section 4.13, Public Services.
3 The Draft Initial Study/Mitigated Negative Declaration for the Sandalwood Travel Center (State Clearinghouse No. 2026020244) is available for review on CEQAnet: https://ceqanet.lci.ca.gov/2026020244.
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Response to Comment Letter I2
Saralyn Tossetti
June 23, 2026
I2-1 This introductory comment expresses general opposition to the Project but does not identify specific concerns regarding the adequacy of the SEIR. This comment has been forwarded to the decision makers for their consideration.
I2-2 The City acknowledges its responsibility as Lead Agency under CEQA (Public Resources Code Section 21000 et seq.) and the CEQA Guidelines (California Code of Regulations, Title 14, Chapter 3, Section 15000, et seq.) and as the decision-making body for the proposed Project approvals. The SEIR has been prepared to evaluate the physical environmental effects of the Project, identify mitigation measures where required, and provide the Planning Commission and City Council with the environmental information necessary to consider certification of the SEIR and approval of the Project.
The issues raised by the commenter (as they relate to the potential physical, environmental effects of the Project), including emergency evacuation, wildfire, biological resources, hazards, and transportation4 were adequately analyzed in the SEIR (see SEIR Sections 4.3, Biological Resources;
4.8, Hazards and Hazardous Materials, 4.15, Transportation, and 4.18, Wildfire). Furthermore, the Project site is already approved for development under the 2017 Specific Plan, as analyzed in the previously certified 2007 Mesa Verde Estates Specific Plan Final EIR (Certified EIR) and 2017 Addendum. While acknowledging that the Project site has been previously approved for development, the SEIR still evaluates the Project as a whole, including its development footprint, density/intensity, open space, circulation, and other infrastructure.
To the extent the comment raises concerns regarding fiscal sustainability, Project financing, or longterm maintenance obligations, those issues are generally outside the scope of CEQA unless they would result in a reasonably foreseeable physical environmental impact. CEQA is concerned with physical changes to the environment, not the economic merits of a project standing alone. However, where infrastructure, services, or maintenance obligations could result in physical environmental effects, those effects have been evaluated in the applicable SEIR sections. Additionally, the Specific Plan Amendment includes detailed assignments of facility ownership and maintenance responsibilities.5 Implementation of the Project would also require the Project Applicant/Developer to pay applicable fees for the development of the Project site that contribute to public services. (See Section 4.13, Public Services, of the SEIR for more discussion on required developer fees.) This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-3 This comment does not state any specific concerns related to the adequacy of the SEIR and has been forwarded to the decision makers for their consideration. 4 As discussed in SEIR Section 4.18, Transportation, vehicle delay in and of itself (as measured by “level of service”) is no longer considered an environmental impact under CEQA.
5 The Mesa Verde Specific Plan Area 2 Amendment 2 (including Table 7-2, Construction Ownership, and Maintenance Responsibilities) is available for review on the City’s website: https://www.calimesa.gov/ArchiveCenter/ViewFile/Item/456.
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I2-4 The City has prepared the SEIR for the Project in accordance with CEQA. Because the Project site has previously been approved for development, the current environmental document is properly prepared as an SEIR. The SEIR evaluates the proposed Project in light of the previously approved 2017 Specific Plan and analyzes the environmental effects associated with the currently proposed modifications to an already-approved development program. The SEIR includes a cumulative impact analysis in accordance with CEQA. CEQA requires an EIR to discuss cumulative impacts when a project’s incremental effect is cumulatively considerable per Public Resources Code Section 21083(b) and CEQA Guidelines Section 15130. Consistent with those requirements, the SEIR evaluates the Project’s contribution to cumulative environmental conditions for each applicable resource topic, using the cumulative assumptions and methodology identified in Section 2.6, Cumulative Projects, of the SEIR.
The SEIR therefore considers not only project-level impacts, but also the Project’s incremental contribution to cumulative impacts in combination with past, present, and reasonably foreseeable future development. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-5 This comment does not state any specific concerns related to the adequacy of the SEIR and is similar to previous comments. Please refer to Response to Comments 12-2 and I2-4 above.
I2-6 Please refer to Response to Comments I2-2 above. As stated therein, the Specific Plan Amendment includes detailed assignments of facility ownership and maintenance responsibilities. In general, Project-site open space, improvements and facilities (e.g., natural open space, public parks, private recreation areas, fuel modification zones, trails, paseos, greenways, landscape areas, water quality basins, lighting) would be owned and/or maintained by one or a combination of the master homeowner’s association, sub-homeowners association, commercial/business owner’s association, maintenance district, City, and/or Riverside County Flood Control. The Yucaipa-Calimesa Joint Unified School District would own, operate, and maintain the proposed schools. The City would own, operate, and maintain the public works facilities and fire station on the Calimesa Public Works planning area (i.e., Planning Area 56). This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-7 As stated above, the SEIR has been prepared as a subsequent environmental review document in accordance with CEQA. The Project site was previously approved for development of 3,650 dwelling units as part of the 2017 Specific Plan. The SEIR evaluates the environmental effects of the currently proposed Project (i.e., the Specific Plan Amendment), including its relationship to existing and reasonably foreseeable local and regional development. The Project does not propose to increase the number of dwelling units that were previously approved as part of the 2017 Specific Plan. Nonetheless, as stated above, the SEIR includes an adequate cumulative impact analysis consistent with CEQA Guidelines Section 15130. The SEIR evaluates the project’s potential contribution to cumulative environmental conditions for each applicable resource area in Chapter 4.
The commenter’s concerns regarding traffic associated with Interstate 10 (I-10), regional commercial development, warehouse-related truck traffic, and residential growth are addressed in accordance with CEQA within the SEIR’s transportation analysis. The SEIR evaluates Project-level and cumulative transportation impacts, including vehicle miles travelled (VMT), roadway improvements, access,
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circulation, and the effects of Project traffic on the surrounding roadway network. See SEIR Section 4.15, Transportation, and the supporting transportation technical studies included as Appendix J-1, Transportation Impact Assessment and Appendix J-2, Traffic Analysis. The commenter’s concerns regarding residents along County Line Road were also considered in the SEIR’s analysis of roadway improvements, circulation, emergency access, noise, and neighborhood interface conditions.
Potential changes in roadway configuration and traffic conditions are addressed in SEIR Section 4.15, Transportation. Potential noise effects associated with increased traffic, construction, and operation are addressed in SEIR Section 4.13, Noise. Potential safety-related considerations, including emergency access, wildfire, and other hazards, are addressed in SEIR Section 4.9, Hazards and Hazardous Materials, and Section 4.19, Wildfire, including Appendix L-1, Fire Protection Plan, and Appendix L-2, Wildfire Evacuation Study. The potential for proposed construction and operational activities along County Line Road to physically divide an established community is addressed in Section 4.10, Land Use and Planning, of the SEIR.
To the extent the comment raises generalized concerns regarding “quality of life” or “neighborhood compatibility,” those concerns are broader planning and policy considerations and are not independent CEQA impact categories unless they are tied to a physical environmental effect. The potential for the Project to result in a significant impact (i.e., a significant, physical environmental effect) due to a conflict with the City’s General Plan, which reflects the City’s long-term planning objectives, was addressed Section 4.10, Land Use and Planning, of the SEIR. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-8 This is a summary paragraph of the commenter’s concerns enumerated above and below in further detail. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-9 This comment does not identify specific concerns regarding the adequacy of the SEIR. CEQA requires analysis of reasonably foreseeable physical environmental effects; it does not require preservation of an existing community lifestyle or prohibit development on land previously planned and approved for development. The SEIR evaluates whether the proposed Specific Plan Amendment would result in new or substantially more severe significant environmental effects. The physical environmental effects associated with construction and operation of the Project have been analyzed in the SEIR, including effects related to changes to scenic views, visual character, conversion of open land, roadway improvements, lighting, and infrastructure. For example, the SEIR’s aesthetics analysis addresses the Project’s potential to substantially degrade exiting visual character or quality and evaluates changes associated with development and operation of the Project (see SEIR Section 4.1, Aesthetics). This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-10 This comment does not state any specific concerns related to the adequacy of the SEIR. As previously stated, the Project site is already approved for development, including 3,650 dwelling units and various transportation and utility improvements (refer to Section 3.6, Comparison to 2017 Mesa Verde Specific Plan Area of the SEIR for a summary of the approved 2017 Specific Plan compared to the proposed
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Project). Of the approximately 1,463-acre Project site, only a portion would be utilized for “high density” (24 dwelling units per acre) or “medium-high density” (20 dwelling units per acre) residential development (refer to Table 3-2 in Chapter 3, Project Description of the SEIR for a summary of residential densities proposed for each residential planning area). These high and medium-high density residential areas would not be located adjacent to any parcels along County Line Road. The nearest higher-density residential planning areas are located south of proposed “Street B” and thus the residences along County Line Road would be buffered by the existing Mesa View Middle School to the south (as shown in Figure 3-1, Proposed Land Use, in Chapter 3, Project Description of the SEIR). As discussed throughout the SEIR, the Project would also provide approximately 497 acres of open space areas (zoned as Open Space – Natural [OS-N]), in addition to public parks (zoned Open Space - Public [OS-PR]) and private recreation areas (zoned Open Space - Private [OS-PR]), as show in in Table 3-6 in Chapter 3, Project Description of the SEIR.
Regarding aesthetic visual quality and character, while the Project in and of itself would not result in a significant impact regarding visual quality or character compared to the prior approvals, the Project combined with proposed, approved or otherwise anticipated cumulative development along the west side of I-10 would result in a significant and unavoidable cumulative aesthetic impact, even after implementation of required mitigation. Please refer to Section 4.1.5, Cumulative Impact Analysis, of the SEIR for a detailed discussion of the cumulative aesthetic impacts. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-11 This comment does not state any specific concerns related to the adequacy of the SEIR and has been forwarded to the decision makers for their consideration. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-12 This comment does not state any specific concerns related to the adequacy of the SEIR. The commenter correctly notes that a specific plan must be consistent with the City’s adopted General Plan. The State Planning and Zoning law (Cal. Government Code Section 65454) states that a specific plan may not be adopted or amended unless the proposed plan or amendment is consistent with the general plan.
Accordingly, the City may adopt the proposed Specific Plan Amendment only if it determines that the amendment is consistent with the General Plan.
A specific plan need not conform perfectly to every General Plan policy. Consistency depends on whether the specific plan, considered as a whole, furthers the General Plan’s objectives and policies and does not obstruct their attainment. General plans commonly reflect a range of competing interests, and the City has substantial discretion to interpret and balance applicable policies, including balancing policies with which the proposed action may not be fully consistent against countervailing policies supporting the action (Orange Citizens for Parks & Recreation v. Superior Court (2016) 2 Cal.5th 141, 153, 155–157). Perfect conformity is not required because “it is nearly, if not absolutely, impossible for a project to be in perfect conformity with each and every policy set forth in the applicable plan” (Pfeiffer v. City of Sunnyvale City Council [2011] 200 Cal.App.4th 1552, 1563). The City, as lead agency, is responsible for determining whether an activity is consistent with the General Plan (LCI 2017).
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The SEIR itemizes and analyzes over 140 goals/policies from 10 different General Plan elements in order to effectively capture and demonstrate compatibility with the General Plan’s overarching goals and objectives. As demonstrated in Table 4.10-1 and summarized on p. 4.10-50 of the Final SEIR, with the implementation of required mitigation measures discussed throughout the SEIR, the Project would be consistent with a vast majority of the City’s General Plan goals and policies and would not obstruct or otherwise prevent the City from continuing to implement said policies or achieving its overarching goals and objectives. At the request of a previous commenter, Table 4.10-1 was revised in Section 4.10 of the Final SEIR to include discussion of several additional General Plan policies and one goal (refer to Response to Comment O5-13 on p. 8-209 of the Final EIR). These revisions do not change the conclusions in the Draft SEIR and would not result in a new significant impact or in a substantial increase in the severity of a previously identified significant impact and, therefore, do not constitute significant new information as defined in CEQA Guidelines Section 15088.5 that would warrant recirculation of the SEIR.
I2-13 As stated above in Response to Comment I2-4, the City has prepared the SEIR for the Project in accordance with CEQA and the CEQA Guidelines. All of the topics listed by the commenter have been adequately addressed in the SEIR in accordance with CEQA. Below, we have listed the relevant section(s) of the SEIR where the environmental topics listed in this comment are discussed and analyzed:
▪ “Traffic congestion and transportation infrastructure” → Section 4.15, Transportation (including Appendices J-1 and J-2)
6 ▪ “Wildfire risk and emergency evacuation” → Sections 4.8, Hazards and Hazardous Materials and
4.18, Wildfire (including Appendices L-1 and L-2)
▪ “Air quality and greenhouse gas emissions” → Sections 4.2, Air Quality and 4.7, Greenhouse Gas Emissions (including Appendix B-1, Air Quality Impact Analysis Report; Appendix B-2, Construction and Operational Health Risk Assessment; Appendix B-4, Greenhouse Gas Analysis Report; and Appendix B-5, Carbon Sequestration Assessment Memorandum) ▪ “Noise impacts to surrounding neighborhoods” → Section 4.11, Noise (including Appendix H, Noise Technical Report)
▪ “Biological resources and wildlife habitat?” → Section 4.3, Biological Resources (including Appendix C, Biological Resources Technical Report)
▪ “Hydrology, drainage, and stormwater management” → Section 4.9, Hydrology and Water Quality (including Appendix G-1, Preliminary Water Quality Management Plan; Appendix G-2, Preliminary Groundwater Infiltration Memorandum; Appendix G-3, Preliminary Hydrology Report; and Appendix F, Phase I Environmental Site Assessment)
▪ “Water supply and long-term sustainability” → Section 4.17, Utilities and Service Systems (including Appendix K-1, Water Supply Assessment and Written Verification of Supply) ▪ “Public services and utilities” → Sections 4.13, Public Services and 4.17, Utilities and Service Systems (including Appendix I, Public Services Correspondence, and Appendix K-1) 6 As discussed in Section 4.15, Transportation of the SEIR, traffic congestion is no longer considered a significant environmental impact under the CEQA due to the adoption of Senate Bill 743 and subsequent updates to the CEQA Guidelines.
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▪ “Geologic and seismic hazards” → Section 4.6, Geology and Soils (including Appendix E-1, Limited Geotechnical Investigation; Appendix E-2, 2004 Fault Investigation Report; Appendix E-3, 2014 Preliminary Geotechnical Investigation; Appendix E-4, 2023 Re-evaluation of the Portion of the Cherry Valley Fault; and Appendix E-6, 2021 Geotechnical Due-Diligence/Feasibility Assessment) ▪ “Visual resources and community character” → Sections 4.1, Aesthetics and 4.10, Land Use and Planning
▪ “Cumulative impacts when considered together with existing and reasonably foreseeable development throughout Calimesa and neighboring communities” → The SEIR’s cumulative analyses are provided throughout Chapter 4, Environmental Impact Analysis, of the SEIR in each relevant topical section (i.e., Sections 4.1 through 4.18). An overview of the approach to the cumulative analysis and the list of cumulative projects is provided in Section 2.6, Cumulative Projects, of the SEIR. Existing development was considered in the SEIR analysis as part of the baseline condition, which was set at the time of Notice or Preparation publication (i.e., May 10,2024) in accordance with CEQA Guidelines Section 15125(a)(1).
This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-14 As discussed in Response to Comments A7-13, A7-23, and I2-3 in the Final SEIR (pp. 8-53, 8-55, and 8-284, respectively), potential impacts related to wildfire evacuation and consideration of fire history were sufficiently addressed in the SEIR (please refer to Threshold 4.8f in Section 4.8, Hazards and Hazardous Materials, Thresholds 4.15c and 4.15d in Section 4.15, Transportation, and Threshold
4.18a in Section 4.18, Wildfire of the SEIR). The SEIR acknowledges that fire history is an important component that contributes to the wildfire environment and that most of the Project site burned in 2017 and 2019 during the Palmer and Sandalwood Fires, respectively (see Final SEIR p. 4.18-4 in Section 4.18, Wildfire). Fire history for the general vicinity of the Project site is shown in SEIR Figure 4.18-3, Fire History Map. The Camp Fire in Northern California’s Butte County is not included on the Fire History Map as this fire occurred over 400 miles northwest of the Project site.
The proposed Specific Plan Amendment (which includes a master tentative tract map [TTM] showing the locations of the planning areas and the backbone of the proposed roadway circulation system) has been analyzed at a programmatic level in the SEIR, as appropriate and required under CEQA. The master TTM (i.e., TTM No, 33931, included as Figure 3-11A through 3-11I in Chapter 3, Project Description, of the SEIR) and the Wildfire Evacuation Study (Appendix L-1 of the SEIR) have been reviewed and approved by an independent environmental consulting firm, the City, and the Calimesa Fire Department. As stated on p. 3-19 of Chapter 3, Project Description of the Final SEIR, in addition to ingress/egress along County Line Road and Sandalwood Drive, which both have direct connections to I-10, the Yucaipa Valley Water District (YVWD) is anticipated to construct a designated emergency vehicle access roadway connecting to Street A through the YVWD property, northwest to Live Oak Canyon Road. This roadway will be gated and the connection of the roadway from the Street A/Street E intersection to the YVWD property boundary. Completion of the paved roadway from the YVWD property boundary to Live Oak Canyon Road will be completed by YVWD prior to occupancy of Phase 3 of the Project (as required per MM-WF-2, Emergency Access Roadway, discussed in Section 4.18, Wildfire of the SEIR). In the event of an evacuation of the Project site, it would be at the discretion of
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the evacuation management officials (e.g., Sherriff’s Department, Calimesa Fire Department, etc.) to use this emergency roadway as a westerly evacuation route. The future planning-area specific site plans and TTMs will also be reviewed by the City and the Calimesa Fire Department for compliance with applicable roadway design and safety standards as well as for conformance with the certified Final SEIR and approved Specific Plan Amendment. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-15 The SEIR analyzed potential impacts to special status wildlife species in Section 4.3, Biological Resources, as supported by SEIR Appendix C, Biological Resources Technical Report. The analysis relied on field surveys as well as database searches to determine which special-status species have a potential to occur within the Project site. The following paragraphs summarize the impact analysis for each species mentioned in this comment.
Dudek conducted extensive and comprehensive field surveys spanning three seasons and three years and there were no observations of any Quino checkerspot butterflies (Euphydryas editha quino) or monarch butterflies (Danaus plexippus) within the Project site. There are no California Natural Diversity Database (CNDDB) occurrence records for these species within the nine U.S. Geological Survey 7.5- minute quadrangles containing and surrounding the Project site. The Project site occurs outside the U.S. Fish and Wildlife Service historical range for Quino checkerspot butterfly and therefore focused surveys are not required. Furthermore, the Project site is not an established overwintering area for monarch butterflies as the site lacks eucalyptus/pine/cypress groves and given its distance from the California coast. The Project site does not provide any monarch butterfly host plants (i.e., milkweeds in the Asclepias genus or other closely-related genera including Gomphocarpus [balloon plant)] Funastrum [twinevine], and Cynanchum [swallow-wort]). Because these species are not expected to occur within the Project site, these species were not analyzed in the SEIR.
Section 4.3.4.2 of the SEIR provides an impact analysis for Crotch’s bumble bee (Bombus crotchii), which includes MM-BIO-9 to reduce any potential impacts to less than significant by requiring a preconstruction survey for Crotch’s bumble bee and avoidance of nesting resources, if present, until the nesting period has concluded.
The Project site is within a burrowing owl (Athene cunicularia) habitat assessment area for the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) as stated in Section 4.3.1.4 of the SEIR. Therefore, a habitat assessment and protocol surveys were conducted for this species in accordance with the Burrowing Owl Survey Instructions for the MSHCP Area (County of Riverside 2006), with modifications. Burrowing owl survey results were negative within the Project site (i.e., no burrowing owls or burrows with confirmed burrowing owl sign were detected). However, as required by mitigation measure MM-BIO-4, potential impacts would be reduced to a less-than-significant level by requiring a pre-construction survey for burrowing owl within 30 days prior to ground disturbance pursuant to the MSHCP to confirm conditions have not changed prior to construction.
Section 4.3.4.2 of the SEIR provides an impact analysis for Blainville’s horned lizard (Phrynosoma blainvillii; referred to as San Diego horned lizard in the comment letter), which is a MSHCP Covered Species and has moderate potential to occur within the Project site as summarized in SEIR Table 4.3-2, Special-Status Wildlife Species. Impacts to species covered by the MSHCP shall be mitigated through
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payment of the Local Development Mitigation Fee as specified in MM-BIO-3 (refer to Section 4.3.6.2 of the SEIR).
This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-16 The Project site is largely undeveloped open space and does not support any existing hazardous pipeline infrastructure or aboveground water- or fuel-storage tanks. As discussed in Section 2.3.2, Physical Conditions Overview of the SEIR, the Project site includes two inactive water wells and an inactive oil well site. The SEIR includes mitigation measures to address potential hazards associated with the previous well operations and ensure adequate abandonment procedures (refer to SEIR Section
4.8, Hazards and Hazardous Materials, Threshold 4.8b). As discussed on p. 4.8-19 of the Final SEIR, MM-HAZ-2 requires that, prior to issuance of a grading permit, the Project Applicant/Developer must retain a California-registered design professional to evaluate the exact location, condition, and abandonment status of the well on the Project site, evaluate the potential for gas leakage, and ensure that the abandonment is conducted in compliance with California Geologic Energy Management Division standards. MM-HAZ-3 requires that the on-site water wells are abandoned in accordance with the appropriate Riverside County Department of Environmental Health procedures, County Code Chapter 13.20, and Bulletins of the California Department of Water Resources. The Applicant/Developer must also coordinate with the Riverside County Department of Environmental Health regarding the necessary permits, notifications, and reports (Final SEIR pp. 4.8-5 and 4.8-36).
Regarding proposed infrastructure, as stated on p. 3-21 of the Final SEIR, the Project would not implement any extensions of natural gas infrastructure onto the Project site. As with the approved 2017 Specific Plan, service stations that sell and dispense gasoline are conditionally permitted (i.e., require a Conditional Use Permit [CUP]) within the Project site’s Mixed-Use zone (Planning Area 1) as well as within the proposed Commercial zone (Planning Area 114, which is located in the same area as the previously approved Mixed-Use zone under the 2017 Specific Plan). As such, these uses are already conditionally permitted to occur on the southeastern portion of the Project site. Any future service station uses proposed within the Project site’s Mixed-Use or Commercial zones would be subject to discretionary review by the City, including subsequent environmental review in accordance with CEQA.
Furthermore, the Commercial and Mixed-Use zones are not located within 1,500 feet of any existing or proposed school sites. The potential to emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school is addressed under Threshold 4.8c in Section 4.8, Hazards and Hazardous Materials, of the SEIR. Per MM-HAZ-5, Project-site land uses located within 0.25 miles (approximately 1,320 feet) of existing or proposed schools are prohibited from storing, handling, or using toxic or highly toxic gases at quantities that exceed threshold levels established by California Health and Safety Code 25532.
As with the previously approved 2017 Specific Plan, the Project would also include the installation of an aboveground water-storage tank in the northeastern corner of the Project site as required by the Yucaipa Valley Water District. Under the proposed Project, the water-storage tank would be located within Planning Area 59. As shown on SEIR Figure 3-1, Proposed Land Use Plan, Planning Area 59 is located on the north side of County Line Road and is not adjacent or near to any existing or proposed
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school locations. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-17 Pursuant to Section 15126.6, an analysis of alternatives to the Project was provided in Chapter 6, Alternatives, of the SEIR. The CEQA Guidelines state that an EIR is required to “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. An EIR need not consider every conceivable alternative to a project” (CEQA Guidelines Section 15126.6[a]). As stated in CEQA Guidelines Section 15126.6(c), “[t]he range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects.” The range of alternatives is guided by a “rule of reason,” such that only those alternatives necessary to permit a reasoned choice are included (CEQA Guidelines Section 15126.6[f]).
The CEQA Guidelines do not require analysis of alternatives that would reduce all project impacts to less than significant levels. The suggestion for an alternative involving a lower residential density would not satisfy the Project objective to provide the same number of residential units as in the approved 2017 Specific Plan in a more clustered development area to maximize the efficient use of regional infrastructure, while helping the City meet its regional housing needs. Regarding increased open-space preservation, as discussed in further detail in SEIR Section 6.4, Alternatives to the Project, both Alternatives 3 and 4 consider alternatives that would increase the total Project-site open space by approximately 260 acres. Furthermore, as summarized in SEIR Table 3-7, the land use changes proposed as part of the Project allow for a moderate increase in the amount of total open space provided compared to the 2017 Specific Plan (amounting to an increase of approximately 7.5 acres).
Regarding an alternative considering additional evacuation routes, the Project already proposes to add an additional evacuation route north through the Yucaipa Valley Water District property (See Response to Comment I2-14, above). Furthermore, after implementation of mitigation, the Project would not result in any significant impacts related to emergency evacuation or access (please refer to Threshold
4.8f in Section 4.8, Hazards and Hazardous Materials, Thresholds 4.15c and 4.15d in Section 4.15, Transportation, and Threshold 4.18a in Section 4.18, Wildfire of the SEIR). This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-18 This comment does not state any specific concerns related to the adequacy of the SEIR. The required CEQA topics related to public safety and the potential physical environmental effects of the Project are adequately addressed in the SEIR. Please refer to the discussion and analyses provided in SEIR sections such as: 4.6, Geology and Soils; 4.8, Hazards and Hazardous Materials, Section; 4.9, Hydrology and Soils; 4.13 Public Services; 4.15, Transportation; 4.17, Utilities and Service Systems; and 4.18, Wildfire of the SEIR. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
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I2-19 This comment is similar to comment I2-16. As such, please refer to Response to Comment I2-16, above.
Figures 3-7, 3-8, 3-9,3-10, 3-12b, and 3-12c in Chapter 3, Project Description of the SEIR, illustrate the conceptual potable water plan, recycled water plan, wastewater system, and storm drain/basin plan for the Project site, which is appropriate for the current programmatic level of review. Site-specific utility plans and connection points (including for electrical, water, wastewater, etc.) are required and will be provided as part of the development review and entitlement process. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-20 This comment is similar to comment I2-16. As such, please refer to Response to Comment I2-16, above.
I2-21 This comment does not state any specific concerns related to the adequacy of the SEIR. Potential impacts to biological resources are addressed in the SEIR in Section 4.3, Biological Resources, supported by SEIR Appendix C, Biological Resources Technical Report. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-22 The species and concerns identified in this comment are addressed in Response to Comment I2-15, above. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-23 This comment does not state any specific concerns related to the adequacy of the SEIR. As directed by MM-BIO-6 of the SEIR, the Project must dedicate open space lands to the MSHCP Reserve to be placed under long-term protection (i.e., with a conservation easement or through a transfer of the land to the RCA in fee title) and managed in perpetuity. Refer to SEIR Section 4.3, Biological Resources, and/or Appendix N, Mitigation Monitoring and Reporting Program of the Final SEIR for the complete text of the mitigation measure. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-24 Dudek conducted extensive and comprehensive field surveys spanning three seasons and three years, which included vegetation mapping, habitat assessments, aquatic resources delineation, and focused special-status species surveys. As stated in SEIR Appendix C, Biological Resources Technical Report and SEIR Section 4.3, Biological Resources, all Dudek surveys conformed to the currently accepted protocols, guidelines, and policies required by the resource agencies (e.g., A Manual of California Vegetation, California Natural Community List, California Native Plant Society Botanical Survey Guidelines, Protocols for Surveying and Evaluating Impacts to Special Status Native Populations and Natural Communities, General Rare Plant Survey Guidelines, Burrowing Owl Survey Instructions for the MSHCP Area, U.S. Army Corps of Engineers’ 1987 Corps of Engineers Wetlands Delineation Manual and its 2008 Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region [Version 2.0], etc.). Therefore, surveys conducted by Dudek provided all appropriate and required surveys to form an accurate baseline analysis under CEQA.
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Project implementation of MM-BIO-6 of the SEIR would ensure that there is a minimum of 303.8 acres of conserved or avoided open space that could support native pollinators and MM-BIO-2 of the SEIR would require landscape plans with an emphasis on using native species that occur in the region and avoidance of invasive, non-native plant species. Refer to SEIR Section 4.3, Biological Resources, and/or Appendix N, Mitigation Monitoring and Reporting Program of the Final SEIR for the complete text of these mitigation measures. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-25 This comment does not identify specific concerns regarding the adequacy of the SEIR. This comment has been forwarded to the decision makers for their review and consideration.
I2-26 The stated concerns in this comment related to wildfire and emergency access/evacuation are adequately addressed in the SEIR and supported by technical reports provided as appendices to the SEIR. Please refer to Response to Comment I2-14, above.
I2-27 The stated concerns in this comment related to wildfire and emergency access/evacuation are adequately addressed in the SEIR and supported by technical reports provided as appendices to the SEIR. The risk of wildfire in the City and fire history of the Project site and surrounding area is understood and was thoroughly analyzed in SEIR and the Fire Protection Plan (FPP; included as Appendix L-1 of the SEIR) prepared for the Project. There is a specific reference to the Sandalwood Fire on Final SEIR p. 4.18-4 in Section 4.18, Wildfire. As discussed in the FPP, the existing land uses, topography, climate, vegetation, fire hazard severity zones and fire history of the area were analyzed.
The Project’s fire protection features, as described in the FPP, were designed in accordance with the 2022 California fire and building codes. The Project would thus include code compliant fuel modification zones, fire apparatus access roadways, emergency vehicle access routes, sufficient water supply and Chapter 7A ignition resistant construction features. The Project’s proposed development of higher-density housing with highly maintained, irrigated vegetative landscaping between homes and perimeter fuel modification zones would keep an active flaming front at great distances from Project structures and support defensibility for the existing fire environment. These features would also reduce the existing wildfire threat for land uses to the north and east of the Project site, that would experience greater exposure without Project implementation. These features, and the unified wildland urban interface make the Project substantially more resilient to potential fire hazards than low- to mediumdensity developments where vegetation is allowed to grow between structures, and connective fuel pathways can infiltrate the development (Syphard et al. 2013). Further, as discussed in Appendix L-2, Wildfire Evacuation Study (WES), the Project roadways, including the various access roadways, must be code-compliant and support sufficient evacuation capacities, and allow for the safe egress of evacuees, while simultaneously allowing for emergency vehicles to enter the site to manage evacuations and stage firefighting efforts. As discussed above, the Project would be built to code compliant ignition resistant standards, and provide sufficient defensible space surrounding the entirety of the Project adjacent to unmaintained fuels, and throughout the interior of the on-site developed land uses. The Project would take a conservative approach to evacuation through the implementation of MM-WF-1. This mitigation will provide occupants with emergency information to promote wildfire and evacuation awareness to establish an informed and prepared population that understands wildfire hazards, evacuation procedures, and emergency response expectations, thereby improving community
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readiness, facilitating efficient evacuations, and reducing risks to life and property during a wildfire event.
If a wildfire were to occur within the Project vicinity, emergency managers would implement a phased evacuation strategy that prioritizes the evacuation of areas at greatest risk to reduce congestion and transportation demand on the major transportation routes for those that have been directed to evacuate by law enforcement or fire personnel. The structures in the Mesa Verde community, including the proposed homes on the Project site would conform to the ignition-resistant building codes codified in Chapter 7A of the 2022 California Building Code, would be ignition-resistant, defensible and designed to require minimal firefighting resources for protection, which enables shelter-in-place contingency option when it is considered safer than evacuation.
Through the incorporation of multiple Project access evacuation routes, code-compliant emergency access, ignition-resistant construction, perimeter fuel modification zones, defensible space, and comprehensive wildfire preparedness measures, the Project is designed to reduce wildfire risk to both future and existing residents while supporting safe evacuation and effective emergency response. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-28 The stated concerns in this comment related to wildfire and emergency access/evacuation are adequately addressed in the SEIR and supported by technical reports provided as appendices to the SEIR. As described in the FPP, WES, and Response to Comment I2-27 above, the Project would be served by multiple code-compliant access roadways that support both emergency response and evacuation. These roadways would provide egress routes to the north and east, directing occupants away from the adjacent open space areas containing unmanaged vegetation, which would be the primary wildfire exposure source affecting the Project site. In contrast to the constrained, predominantly rural, and non-code-compliant evacuation routes available during the 2018 Camp Fire, the evacuation network serving the Project must comply with modern California Fire Code and California Building Code requirements for roadway width, vertical clearance, and vehicular capacity, as detailed in the FPP.
Additionally, both on-site roadways and off-site evacuation corridors traverse urbanized and semiurbanized environments. All new on-site roadways, as well as the proposed emergency access/evacuation roadway through the YVWD property to the north would be maintained with roadside fuel modification to, at minimum, the required 20-foot fuel modification zone identified in the FPP.
Collectively, these features, together with occupant emergency preparedness measures and ignitionresistant construction, provide multiple layers of protection that support safe evacuation during a wildfire emergency. Should conditions render evacuation unsafe or impractical, occupants would also have the option to shelter in place within hardened structures, consistent with emergency management direction and established emergency procedures of the City or Riverside County, as described further in the WES. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-29 As discussed above in Response to Comment I2-14, besides Sandalwood Drive and County Line Road, the Project includes a third emergency access route proposed through the YVWD property to the north, which would be complete prior to occupancy of Phase 3 of the Project (as required per MM-WF-2,
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discussed in Section 4.18, Wildfire of the SEIR). Further, as discussed in Comment 12-27 and 12-28, at buildout, the Project would implement code-compliant fuel modification zones surrounding all structures of the Project site, and replace all unmaintained on-site vegetation in these zones with irrigated, maintained vegetation and/or hardscaping. All structures on-site would be built to ignition resistant construction standards and be outfitted with automatic fire sprinklers. As described above in Response to Comments I2-27 and -28, the Project site would offer shelter in place as a last contingency option and protect occupants when a safe, early evacuation is not possible, and sheltering in place is a safer option. Further, the conversion of these unmaintained landscapes to hardscapes and fuel modified areas reduces wildfire risk to nearby existing communities, as shown in the BehavePlus Fire Behavior Modeling analysis in the FPP that demonstrates the reduction in flame lengths and fireline intensity following the buildout of the Project site from unmaintained grasses and shrubs to irrigated, maintained vegetation in the fuel modification zones, and hardscapes onsite. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-30 As shown in Appendix E-4 of the SEIR, the complete history of site-specific geotechnical investigations to determine the presence and/or absence of active faulting at the Cherry Valley Fault was re-evaluated in 2023 by a State of California Professional Geologist (No. EG1952 Certified Engineering Geologist).
General observations by members of the public regarding structures and properties along/near County Line Road do not override the findings of a registered Professional Geologist. As shown in Appendix E-4 of the SEIR, these findings have also been reviewed and accepted by the City’s Engineering Department. As part of the Final SEIR, proposed General Plan Amendment No. 23-01 has been revised to include an update to Figure SAF-1, Fault Zones, in the General Plan to reflect the findings of 2023 re-evaluation of the Cherry Valley Fault and identify the fault as inactive. Furthermore, Section 4.6, Geology and Soils, of the SEIR considered the regional seismic environment including the potential for adverse effects from ground shaking (see Threshold 4.6a[ii]), secondary hazards including seismic related ground failure including liquefaction (see Threshold 4.6a[iii]), and infrastructure impacts are considered as part of all proposed improvements consistent with geotechnical practices and building code requirements. As discussed in the SEIR (Final SEIR pp. 4.6-17 and 4.6-18), all proposed improvements would be designed and constructed in accordance with a project specific geotechnical report prepared by a California licensed geotechnical engineer or engineering geologist as approved by the City’s Engineering Department. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-31 The geotechnical studies/evaluations for the Project have all been prepared by qualified State of California registered and licensed professional engineering geologists and/or geotechnical engineers and reviewed/accepted by the City’s Engineering Department which is consistent with building code requirements. Potential impacts under CEQA related to geology and soils (including fault rupture, strong seismic ground shaking, seismic-related ground failure, landslides, soil erosion, liquefaction, and expansive soils) are addressed in Section 4.6, Geology and Soils, of the SEIR, which has been prepared with assistance from and reviewed by qualified environmental professionals based on the findings of the geotechnical studies/evaluations and other reliable sources noted in Section 4.6.8, References of the SEIR. Final design and construction of all improvements would occur in accordance with a final
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design level geotechnical report after receiving final approval from the City’s Engineering Department to ensure that everything meets seismic and geotechnical standards and requirements prior to approval of a building permit. Please also refer to Response to Comment I2-31, above. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-32 The Project's transportation impacts were comprehensively evaluated in accordance with CEQA in Section 4.15, Transportation of the SEIR, supported by Appendix J-1, Transportation Impact Assessment, and Appendix J-2, Traffic Analysis. The Transportation Analysis was prepared in accordance with the City of Calimesa's Transportation Impact Analysis Guidelines, following a Cityapproved scoping agreement, and evaluated the Project using accepted transportation engineering methodologies. The analysis considered existing conditions, Existing Plus Project conditions, multiple cumulative opening-year scenarios corresponding to the Project's phased buildout (2030, 2035, 2038, and 2040), and Horizon Year (2045) cumulative conditions. The analysis therefore evaluates the Project in conjunction with planned regional growth and reasonably foreseeable cumulative development rather than in isolation. Specifically, the transportation analysis evaluated Project trip generation, trip distribution, roadway segment and intersection operations, traffic signal warrants, freeway off-ramp queuing, internal circulation, site access, roadway improvements, bicycle and pedestrian facilities, transit service, VMT, and fair-share participation in regional transportation improvements. The cumulative analysis incorporates planned background growth and cumulative development identified within the study area and evaluates whether improvements are necessary to maintain consistency with the City's General Plan circulation policies.
Consistent with Senate Bill 743 and the CEQA Guidelines, transportation impacts under CEQA are evaluated primarily using VMT, rather than level of service (LOS). Nevertheless, the Transportation Analysis also provides extensive LOS, operational, and queuing analyses for informational purposes and to evaluate consistency with the City's General Plan transportation policies. Where operational deficiencies were identified under future cumulative conditions, the analysis identifies phased roadway and intersection improvements necessary to maintain acceptable operating conditions as development occurs. Accordingly, the transportation analysis does not ignore congestion concerns; rather, it evaluates roadway operations over the life of the Project and identifies improvements tied to Project phasing and future cumulative conditions.
Regarding emergency response, evacuation, and the proposed improvements along County Line Road.
As discussed above in Response to Comment I2-14, these issues are addressed in multiple sections of the SEIR. Emergency access and hazardous materials are evaluated in Section 4.9, Hazards and Hazardous Materials. Wildfire evacuation, emergency access, and evacuation performance are evaluated in Section 4.19, Wildfire, supported by Appendix L-1, Fire Protection Plan and Appendix L-2, Wildfire Evacuation Study. In addition, the potential effects associated with improvements to County Line Road, including whether the roadway improvements could physically divide an established community, are specifically evaluated in Section 4.10, Land Use and Planning. Accordingly, the comment does not identify any deficiency in the transportation analysis, nor does it constitute new information demonstrating a new significant environmental impact, a substantial increase in the severity of an identified impact, or feasible mitigation that was previously omitted. Therefore, no
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additional transportation analysis or recirculation is required pursuant to CEQA Guidelines section 15088.5.
I2-33 As discussed above in Response to Comment I2-32 and in Section 4.15, Transportation of the SEIR, transportation impacts under CEQA are evaluated using VMT pursuant to Senate Bill 743 and the CEQA Guidelines. Although traffic congestion and LOS, by themselves, are no longer considered significant environmental impacts under CEQA, the City nevertheless prepared a comprehensive traffic analysis evaluating roadway operations, circulation, and cumulative transportation conditions for informational purposes and to assess consistency with the City's General Plan. As stated above in Response to Comment I2-32, Appendix J-2, Traffic Analysis of the SEIR was prepared in accordance with the City of Calimesa's Transportation Impact Analysis Guidelines and a City-approved scoping agreement and evaluates transportation conditions under multiple analysis scenarios, including cumulative conditions, both with and without the Project. These scenarios were specifically developed to evaluate the Project within the context of anticipated regional growth rather than in isolation. The cumulative analysis incorporates existing traffic volumes, Project-generated traffic, ambient growth, and traffic associated with approved, pending, and reasonably foreseeable cumulative development throughout the surrounding region. Future traffic forecasts were developed using the Riverside County Transportation Analysis Model (RIVCOM), cumulative project information provided by the City and neighboring jurisdictions, including the cities of Beaumont and Yucaipa, and other regional planning assumptions.
The analysis therefore reflects the combined effects of regional residential, commercial, industrial, and mixed-use development expected to occur during the planning horizon.
The transportation study evaluates a comprehensive roadway network that includes intersections and freeway interchange facilities serving the Project, including County Line Road, Sandalwood Drive, Singleton Road, Calimesa Boulevard, and the I-10 eastbound and westbound ramp intersections. The analysis also evaluates Project trip generation, trip distribution, roadway operations, traffic signal warrants, freeway off-ramp queuing, site access and circulation, and identifies phased roadway and intersection improvements necessary to maintain consistency with the City's General Plan circulation policies as cumulative development occurs. Existing traffic counts used in the analysis inherently include current passenger vehicle, truck, commercial, and industrial traffic utilizing the roadway network, while future traffic forecasts account for anticipated increases resulting from cumulative regional growth, including industrial and warehouse development. The comment specifically references fueling stations, truck traffic, and other commercial development. These land uses are already represented in the cumulative traffic forecasts through the cumulative development assumptions summarized in Section 4.6, Cumulative Development Traffic, including the cumulative development inventory presented in Table 4-7 of Appendix J-2, which includes known and reasonably foreseeable commercial and service-related development within the study area. Accordingly, these types of regional development were considered in establishing future cumulative traffic conditions.
In addition, the Project's transportation impacts under CEQA were evaluated through the VMT analysis presented in Appendix J-1, Transportation Impact Assessment of the SEIR. The VMT analysis evaluated both baseline and cumulative conditions using RIVCOM and assessed Project-generated VMT on both a citywide basis and within a 10-mile radius of the Project. As discussed in Section 4.15 of the SEIR, the Project's VMT per service population would remain below the City's adopted significance thresholds under both baseline and cumulative conditions and therefore would not result in a significant transportation impact under CEQA. Accordingly, the cumulative transportation analysis requested by
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the commenter has already been completed and fully disclosed in the SEIR. The comment does not identify any deficiency in the methodologies employed, any omission of cumulative development from the analysis, or any new information demonstrating a new significant transportation impact or a substantial increase in the severity of a previously identified impact. Therefore, the comment does not constitute significant new information requiring additional analysis or recirculation pursuant to CEQA Guidelines section 15088.5.
I2-34 The stated concerns regarding vehicle-related air quality impacts, including vehicle exhaust, brake dust, tire particles, and idling have been addressed in accordance with CEQA in the SEIR. Potential operational air quality impacts from Project-generated vehicle trips are evaluated in SEIR Section 4.3, Air Quality, supported by Appendix B-1, Air Quality Impact Analysis, and Appendix B-2, Health Risk Assessment. Sensitive receptors, including nearby residences and schools, are considered in the SEIR’s air quality and health risk analyses. The Project’s mobile-source emissions, traffic volumes, fleet mix, VMT, and localized carbon monoxide (CO) effects were evaluated using accepted South Coast Air Quality Management District (SCAQMD)/California Emissions Estimator Model (CalEEMod) methodologies. For example, fugitive emissions due to the generation of road dust inclusive of brake and tire wear particulates were included as part of the on-road dust calculations in CalEEMod. Localized congestion-related CO effects (which is the typical air quality analysis used to evaluate whether vehicle activity at congested intersections could create localized CO concentrations) were likewise addressed in SEIR Section 4.3 and Appendix B-1. The SEIR concluded that localized operational emissions and CO hot-spot impacts would be less than significant, while regional operational emissions would remain significant and unavoidable, even after implementation of proposed mitigation measures. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-35 Construction-related air emissions are addressed in SEIR Section 4.3, Air Quality, as supported by Appendix B-1. The SEIR specifically evaluates construction emissions from site preparation, mass grading, building construction, paving, architectural coatings, off-site utility and infrastructure improvements, and construction equipment use. The analysis identified fugitive dust as a key concern during grading activities and evaluated emissions of criteria pollutants associated with Project construction. As determined in the SEIR, unmitigated construction emissions would exceed SCAQMD thresholds for volatile organic compounds (VOC) and nitrogen oxides (NOx), but with implementation of proposed mitigation measures, including use of Tier 4 Final construction equipment, low-VOC coatings, dust control, equipment maintenance, and idling restrictions, construction emissions would be reduced to less than significant levels. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-36 The SEIR proposes 27 air-quality-specific mitigation measures. For example, construction emission controls are addressed through MM AQ-2 through MM AQ-9, including Tier 4 Final equipment, equipment maintenance, alternative fuels and electric equipment where feasible, low-VOC coatings, idling restrictions, and worker trip-reduction information. Dust suppression is also addressed through required compliance with SCAQMD Rule 403, as discussed in Section 4.3, Air Quality, of the SEIR.
Measures to reduce vehicle dependency are included in MM AQ-8, MM AQ-9, MM AQ-10, MM AQ-20, and MM AQ-22, including bicycle/pedestrian improvements, transportation demand management, and
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electric vehicle charging infrastructure. Air quality compliance and monitoring-related provisions are addressed through MM AQ-2, MM AQ-6, and MM AQ-17, which include recordkeeping, signage, and complaint tracking. These proposed air quality mitigation measures, which would become requirements in the event of SEIR certification and Project approval, are listed in their entirety in Section 4.2.6, Mitigation Measures of the SEIR. Other proposed SEIR mitigation measures related to transportation, traffic management, and/or dust suppression included the following:
▪ MM-TRA-1, which requires a trip generation and VMT conformity analysis prior to occupancy permits for Business Park planning areas, including review of worker, vendor, and truck trips, remaining trip capacity, Sandalwood Drive/I-10 interchange adequacy, ingress/egress, emergency response, and roadway hazards. If trip generation exceeds capacity or infrastructure is inadequate, occupancy may be withheld or lease restrictions imposed (see SEIR Section 4.15.6, Mitigation Measures).
▪ MM-HAZ-6, which requires preparation of a TMP by a qualified traffic engineer, addressing traffic safety, traffic flow, delays, signage, pedestrian/bicycle safety, truck routes, staging, material storage, parking, MUTCD-compliant traffic controls, public awareness, and emergency service coordination (see SEIR Section 4.8.6, Mitigation Measures). ▪ MM-GEO-1, which requires an Erosion Prevention Plan with best mazement practices for erosion control and compliance with SCAQMD Rule 403 related to dust control, including inspection, maintenance, monitoring logs, soil stabilization, stockpile controls, temporary seeding/planting, and drainage controls (see SEIR Section 4.6.6, Mitigation Measures).
To the extent this comment raises generalized concerns regarding “quality of life” or “a livable community,” those concerns are broader planning and policy considerations and are not independent CEQA impact categories unless they are tied to a physical environmental effect. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-37 This comment is similar to previous comments addressed above. As such, please refer to Responses to Comments I2-7, I2-10, I2-14, I2-32 and I2-33. Regarding emergency access and roadway hazards along County Line Road, please refer to the discussion provided under Thresholds 4.15c and 4.15d in Section 4.15, Transportation of the SEIR. Please also refer to Response to Comment I1-4 in Chapter 8, Response to Comments, of the Final SEIR, which provides further clarification on proposed County Line Road improvements and potential impacts related to setbacks. Potential noise impacts associated with increased traffic volumes along County Line Road are addressed SEIR Section 4.11, Noise. In summary, potential impacts related to proposed improvements and future operation of County Line Road, including potential air quality, noise, hazards, and transportation impacts related to increased traffic volumes, have been adequately addressed in the SEIR as supported by associated technical studies appended to the SEIR. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-38 Proposed improvements to County Line Road are summarized in Section 3.5.1.1, Circulation, in Chapter 3, Project Description of the SEIR. As stated in SEIR Section 4.15, Transportation, under
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Threshold 4.15c, the improvements along County Line Road would require redevelopment of land that may currently include lawns, landscaping, fencing, and/or mailboxes that may function as extensions of front yards but encroach onto City-owned property as part of the public right-of-way. However, the Project does not propose any roadway improvements along County Line Road outside of the existing 60-to-80-foot public right-of-way and would not require acquisition of private parcels through eminent domain or by any other means. Final design plans for the proposed County Line Road improvements will be provided to the City as part of the phased development review process. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-39 Please refer above to Responses to Comments I2-10 and I2-38. This comment does not identify specific concerns regarding the adequacy of the SEIR. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-40 This comment does not state any specific concerns related to the adequacy of the SEIR and expresses similar sentiments as Comments I2-7 and I2-10. As such, please refer above to Responses to Comments I2-7 and I2-10, above. To the extent the comment raises generalized concerns regarding “quality of life” and “neighborhood compatibility,” those concerns are broader planning and policy considerations and are not independent CEQA impact categories unless they are tied to a physical environmental effect. The potential for the Project to result in a significant impact (i.e., a significant, physical environmental effect) due to a conflict with the City’s General Plan, which reflects the City’s long-term planning objectives, was addressed Section 4.10, Land Use and Planning, of the SEIR. Please also refer to Sections 4.10, Noise and 4.15, Transportation, of the SEIR regarding potential Project noise and transportation impacts, as well as Section 4.1, Aesthetics of the SEIR regarding potential impacts related to visual quality and character, scenic vistas, and lighting. This comment has been forwarded to the decision makers for their review and consideration. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-41 This comment does not state any specific concerns related to the adequacy of the SEIR and expresses similar sentiments as Comments I2-2 and I2-6. As such, please refer to Responses to Comments I2-2 and I2-6, above. This comment has been forwarded to the decision makers for their review and consideration. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-42 This comment does not state any specific concerns related to the adequacy of the SEIR and expresses similar sentiments as Comments I2-2 and I2-6. As such, please refer to Responses to Comments I2-2 and I2-6, above. In addition to the Specific Plan Amendment’s discussion on facility ownership and maintenance responsibilities, the Specific Plan Amendment includes discussion on infrastructure financing necessary for implementation. As such, the Specific Plan Amendment notes a Community Facilities District may be formed, which would be enabled by the proposed Development Agreement
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Amendment. Other possible financing could come from impact fees, grants, and loans. The commenter’s suggestions will be forwarded to the decision makers for their review and consideration.
I2-43 This comment does not state any specific concerns related to the adequacy of the SEIR and expresses similar sentiments as Comments I2-2 and I2-6. As such, please refer to Responses to Comments I2-2 and I2-6, above. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-44 This comment expresses similar sentiments as Comments I2-2, I2-4, and I2-13. As such, please refer to Responses to Comments I2-2, I2-4, and I2-13, above. For reference, Table ES-2, Summary of Project Impacts, provides a summary of all the Project’s potentially significant impacts and applicable mitigation measures (which are discussed and analyzed in further detail in Chapter 4, Environmental Analysis, of the SEIR by environmental topic area). This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-45 This comment expresses similar sentiments as Comments I2-14, I2-27, I2-28, and I2-29. As such, please refer to Responses to Comments I2-14 and I2-27 through I2-29 above. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-46 This comment does not state any specific concerns related to the adequacy of the SEIR. The traffic analysis prepared for the Project was provided as Appendix J-2 of the SEIR and includes recommendations for required transportation-related improvements based on the Project’s phased development and taking into consideration existing and future cumulative development conditions. The City will impose Conditions of Approval on the Project to ensure that the phased implementation of adequate transportation infrastructure (as identified in Appendix J-2) is in place for Project buildout.
This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-47 This is a summary of previously stated comments. As such, please refer to Responses to Comments I2- 17 through I2-39. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-48 This is a summary of previously stated comments. As such, please refer to Responses to Comments I2- 15 and I2-23, above. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-49 This is a summary of previously stated comments. Please refer to Responses to Comments I2-2, I2-6, and I2-42. This comment does not identify a new significant environmental impact, a substantial
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increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-50 This is a summary of previously stated comments. Please refer to Response to Comment I2-12, above.
This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-51 This is a summary of previously stated comments. Please refer to Response to Comment I2-17, above.
This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring additional analysis or recirculation under CEQA Guidelines Section 15088.5.
I2-52 This concluding statement expresses opposition to the Project as currently proposed and includes repetitions of previously stated concerns. This comment does not state any specific concerns with the analysis provided in the SEIR and has been forwarded to the decision makers for their review and consideration.
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Response to Comment Letter I3
Concerned Residents of 780 W. County Line Rd, Calimesa, California Saralyn Tossetti, Griffin Tossetti, Jennifer Gysbers, Pamela Salazar, Gary Salazar July 2, 2026
I3-1 This comment letter is the same as Comment Letter I2. As such, please refer to Response to Comment Letter I2, above.
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3 References
LCI (Governor’s Office of Land Use and Climate Innovation). 2017. “Chapter 9: Implementation.” State of California General Plan 2017 Guidelines. Accessed July 2026. https://lci.ca.gov/wp-content/ uploads/OPR_COMPLETE_7.31.17.pdf.
Syphard, AD, Bar Massada, A, Butsic, V, Keeley, JE. 2013. Land Use Planning and Wildfire: Development Policies Influence Future Probability of Housing Loss. PLoSONE8(8):e71708. doi:10.1371/journal.pone. 0071708. Accessed, July 2026. https://journals.plos.org/plosone/article/file?id=10.1371/ journal.pone.0071708&type=printable.
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Mesa Verde Specific Plan Area 2
Amendment 2 Project
Responses to Additional
Comments Received – Vol. II
STATE CLEARINGHOUSE NO. 2004071045
AUGUST 2026
Prepared by:
CITY OF CALIMESA
908 Park Avenue
Calimesa, California 92320
Prepared with assistance from:
225 South Lake Avenue, Suite M210
Pasadena, California 91101
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1 Introduction
The City of Calimesa (City) has received additional public comments letters after the close of the public review period for the Draft Subsequent Environmental Impact Report (SEIR)1 for the Mesa Verde Specific Plan Area 2 Amendment 2 Project (Project) and prior to the Planning Commission hearing on August 10th, 2026. As shown in Table 2, between July 28, 2026 and August 6, 2026, the City received a total of two additional comment letters on the Project and/or SEIR (inclusive of the Draft and Final SEIR) from one organization and one individual. These additional comment letters (referred to herein as “Vol. II”) are organized into two categories: Category O (written comments from organizations), and Category I (written comments from individuals).
Table 2. Comment Letters and Commenters (Vol. II)
Comment
Letter Commenter Type Date Received
Organization
O2 Golden State Environmental Justice Alliance Organization August 2, 2026 Individual
I4 Clarence Hoefer Individual July 29, 2026
For reference purposes, each comment letter has been assigned a corresponding letter based on category and numbered in order of date received, starting with the earliest date. In turn, each specific comment within a particular letter has also been numbered and bracketed. For example, the second comment in letter “O2” is identified as “Comment O2-2.” The corresponding response uses the same convention, so the reader can match each response to the comment to which it refers. The bracketed letter precedes responses to the letter’s comments.
Most comments received were adequately addressed in the SEIR and/or were previously responded to in Chapter 8, Response to Comments, of the Final SEIR. Regardless, all comments submitted have been responded to below.
As presented in Section 2 of this document, none of the comments received identified deficiencies in the SEIR analysis that would require recirculation of the SEIR pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15088.5, Recirculation of an Environmental Impact Report Prior to Certification. CEQA Guidelines Section 15088.5 is provided below for reference:
(a) A lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review under Section 15087 but before certification. As used in this section, the term “information” can include changes in the project or environmental setting as well as additional data or other information. New information added to an EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. “Significant new information” requiring recirculation include, for example, a disclosure showing that:
1 The Draft SEIR was circulated for public review from July 11, 2025, through August 25, 2025, in accordance with Section 15105(a) of the California Environmental Quality Act Guidelines.
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-4
(1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
(2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance. (3) A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the environmental impacts of the project, but the project’s proponents decline to adopt it.
(4) The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. (Mountain Lion Coalition v. Fish and Game Com. (1989) 214 Cal.App.3d 1043)
Although no comments have been raised that would require revisions to the SEIR, these comments and responses are available to the Planning Commission for their review and consideration as part of their deliberations on the Project’s environmental documentation.
2 Comments and Responses
This section presents responses to all additional comments received between July 28, 2026 and August 6, 2026.
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-5
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-6
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-7
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-8
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-9
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-10
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-11
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-12
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-13
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-14
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-15
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-16
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-17
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-18
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-19
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-20
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-21
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-22
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-23
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-24
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-25
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-26
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-27
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-28
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-29
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-30
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-31
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-32
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-33
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-34
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-35
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-36
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-37
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-38
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-39
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-40
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-41
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-42
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-43
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-44
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-45
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-46
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-47
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-48
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-49
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-50
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-51
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-52
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-53
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-54
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-55
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-56
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-57
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-58
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-59
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-60
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-61
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-62
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-63
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-64
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-65
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-66
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-67
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-68
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-69
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-70
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-71
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-72
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-73
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-74
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-75
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-76
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-77
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-78
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-79
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-80
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-81
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-82
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-83
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-84
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-85
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-86
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-87
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-88
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-89
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II)
– PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-90
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II)
– PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-91
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II)
– PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-92
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II)
– PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-93
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II)
– PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-94
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II)
– PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-95
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II)
– PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-96
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-97
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-98
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-99
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-100
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-101
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-102
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-103
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-104
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-105
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-106
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-107
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-108
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-109
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-110
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-111
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-112
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-113
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-114
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-115
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-116
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-117
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-118
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-119
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-120
INTENTIONALLY LEFT BLANK
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-121
Response to Comment Letter O2
Golden State Environmental Justice Alliance
Steven Piepkorn
August 2, 2026
O2-1 This is an introductory comment. The commenter’s specific concerns with the Final SEIR are addressed below in Responses to Comments O2-2 through O2-20. The commenter (Golden State Environmental Justice Alliance [GSEJA]) also resubmitted their comments on the Draft SEIR, which were previously submitted by Blum Collins, and Ho LLC on their behalf on August 21, 2025, and subsequently responded to in Response to Comment Letter O5 in Chapter 8, Response to Comments of the Final SEIR (beginning on p. 8-203). Collectively, and as discussed in further detail below, these comments do not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
O2-2 This comment summarizes concerns addressed in greater detail in the following responses: O2-6 (environmental justice); O2-8 (Project description and grading); O2-9 (energy); O2-10 (land use and General Plan consistency); O2-11 (growth inducement); O2-12 (greenhouse gas and air quality mitigation measures); O2-13 (VMT and transportation); and O2-14 through O2-16 (biological resources and mitigation). These comments do not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
O2-3 Please refer to Chapter 8, Response to Comments, of the Final SEIR for responses to the comments previously submitted by SWAPE (beginning with Response to Comment O5-49) and Shawn Smallwood, PhD (beginning with Response to Comment O5-67) as part of GSJEJA’s Comment Letter O5 (Submitted in August 2025). As demonstrated therein, these comments do not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
O2-4 CEQA Guidelines Section 15088 requires a lead agency to evaluate and respond in good faith to significant environmental issues raised during public review. It does not require the agency to agree with a commenter’s conclusions, adopt the commenter’s preferred methodology, or provide a response satisfactory to the commenter. In Chapter 8 of the Final SEIR, the City provided written responses to GSEJA’s comments and the supporting technical opinions of SWAPE and Dr. Smallwood. Those responses identify the applicable SEIR sections, technical studies, significance thresholds, methodologies, mitigation measures, and legal authorities and explain the basis for the City’s agreement or disagreement with the positions presented. Where additional explanation was warranted, the Final SEIR included revisions or clarifications. The record therefore demonstrates that the City considered the comments and provided reasoned responses as required by CEQA Guidelines Section 15088.
Regarding the claims of “deferred” analysis and responses to SWAPE and Dr. Smallwood, please refer below to Responses to Comments O2-8, O2-12, O2-13, and O2-14 through O2-16.
RESPONSES TO ADDITIONAL COMMENTS RECEIVED (VOL. II) – PLANNING COMMSSION HEARING (AUGUST 10, 2026) 14341.04 AUGUST 2026 RTC-122
The comment incorrectly suggests that the City's citation to CEQA statutes, Guidelines, and case law constitutes a substitute for substantive analysis or a dismissal of the concerns raised by GSEJA, SWAPE, and Dr. Smallwood. Throughout Chapter 8, Response to Comments, and in subsequent responses incorporated into the administrative record, the City addresses the specific technical issues raised regarding transportation, air quality, biological resources, growth inducement, emergency access, wildfire evacuation, and other environmental topics. These responses reference the relevant technical studies, methodologies, significance thresholds, modeling assumptions, survey data, mitigation measures, and analyses contained in the SEIR and its appendices. Where the City disagreed with conclusions offered by SWAPE, Dr. Smallwood, or other commenters, it explained the basis for that disagreement and identified the substantial evidence supporting the SEIR's conclusions.
Ultimately, a disagreement regarding CEQA interpretation or the conclusions of the technical analyses does not establish that the responses are legally or factually deficient. It would be a double standard to suggest that legal authorities may be cited when supporting the commenter's position (e.g., in Comment O2-08) but may not be cited when supporting the City's. The relevant question is whether the City provided reasoned responses supported by substantial evidence and applicable law. The administrative record demonstrates that it did. Accordingly, this comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
O2-5 The comment correctly notes that the Project would amend the adopted specific plan (i.e., the 2017 Specific Plan) to permit additional land uses and development intensity beyond those previously approved. However, rather than relying on a CEQA exemption, streamlined infill provision, addendum, or other abbreviated form of environmental review, the City prepared a Subsequent Environmental Impact Report (SEIR) and evaluated the Project in accordance with the substantive and procedural requirements of CEQA. The comment's reference to employment growth exceeding Southern California Association of Governments (SCAG) projections likewise does not demonstrate a CEQA violation. The SEIR expressly evaluates the Project's employment-generating potential and associated growthinducing effects in Section 4.12, Population and Housing as well as in Section 5.3.2, Economic Growth, and other relevant resource chapters. The question under CEQA is not whether a project exactly matches regional growth forecasts, but whether the environmental effects associated with the project have been adequately disclosed, analyzed, and mitigated to the extent feasible. The SEIR provides that analysis and identifies the resulting significance determinations.2 Accordingly, the comment reinforces the reason an SEIR was prepared. Because the Project proposes changes to previously approved development, including Business Park uses and a modified development program, the City prepared a comprehensive SEIR to evaluate those changes and their environmental consequences. Accordingly, this comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
2 For example, as stated in SEIR Section 5.3.2, although the additional workers generated by the Project would exceed SCAG projections for employment through 2050 at the City level, the Project’s proposed 3,650 dwelling units would provide capacity for approximately 10,038 persons, which would be sufficient to house the additional workers generated by the Project. This growth would occur incrementally across five development phases, and sufficient housing would be available by 2045 to accommodate the future workers generated by the Project. The physical environmental effects associated with these additional homes, businesses, residents, and employees (e.g., related to air quality, transportation, greenhouse gas emissions, etc.) are the subject of the analyses provided throughout the SEIR where all significant impacts have been clearly disclosed and mitigated to the extent feasible.
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O2-6 This comment mischaracterizes both CEQA's environmental justice requirements and the analysis contained in the SEIR. Neither CEQA nor the CEQA Guidelines require a stand-alone environmental justice impact analysis for every project. Rather, CEQA requires disclosure and evaluation of a project's physical environmental effects, including those that may cause substantial adverse effects on human beings and consistent with CEQA Guidelines Section 15065(a)(4), the SEIR evaluates the Project's potential effects on human beings.
The commenter likewise misinterprets CEQA Guidelines Section 15131(c). That provision does not establish an independent environmental justice impact category, significance threshold, or mitigation requirement. Rather, CEQA Guidelines Section 15131(c) provides that economic, social, and housing factors may be considered together with technological and environmental factors when determining the feasibility of mitigation measures or project changes (e.g., alternatives). CEQA Guidelines Section 15131 further explains that economic and social effects are not themselves significant environmental effects under CEQA, although such information may inform the evaluation of physical environmental changes. Consistent with these requirements, the SEIR evaluates the Project's environmental impacts using the significance thresholds established in Appendix G of the CEQA Guidelines, City standards, South Coast Air Quality Management District (SCAQMD) thresholds, and other applicable regulatory criteria.
The comment also incorrectly suggests that the City ignored localized community conditions identified through CalEnviroScreen. The City did not dismiss concerns regarding existing environmental burdens, sensitive populations, or human health effects. Rather, the SEIR evaluated the Project's physical environmental impacts in the context of existing baseline conditions, including existing air quality conditions, sensitive receptors, health risk exposure, cumulative impacts, and project-generated emissions. For example, Section 4.2, Air Quality, includes analyses of construction and operational emissions, localized air quality impacts, health-related exposure issues, sensitive receptors, and consistency with applicable air quality planning documents. The SEIR concluded that certain air quality impacts would remain significant and unavoidable even after mitigation and expressly disclosed those impacts to decision makers and the public.
Finally, the record does not support the assertion that the City "dismissed" environmental justice concerns. Throughout Chapter 8, Response to Comments, of the Final SEIR the City responded to comments regarding air quality, traffic-related emissions, sensitive receptors, public health concerns, and impacts on nearby residents. The Final SEIR consistently explains that these issues were evaluated under the applicable CEQA standards and supported by technical studies included in the administrative record. Accordingly, the Project's effects on nearby residents were analyzed, disclosed, and will be considered by decision makers as required by CEQA. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5 O2-7 Please refer to Response to Comment O2-6, above. Further, regarding “calibrated” mitigation measures, CEQA requires agencies to identify and adopt feasible mitigation measures that reduce or avoid significant physical environmental impacts. While demographic and socioeconomic information may provide context regarding affected communities, CEQA does not require a separate set of mitigation measures based solely on socioeconomic characteristics. As required, the SEIR identified feasible mitigation measures, including 27 air-quality-related mitigation measures (listed in SEIR
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Section 4.2.6), evaluated a reasonable range of alternatives, and disclosed all remaining significant and unavoidable impacts.
O2-8 CEQA Guidelines Section 15146 provides that the degree of specificity required in an EIR must correspond to the degree of specificity of the action under review and that environmental review prepared for planning-level land use approvals need not be as detailed as review prepared for subsequent site-specific construction projects. Here, the Project consists of amendments to an adopted specific plan (i.e., the 2017 Specific Plan) establishing a development framework for approximately 1,493 acres. As described in Chapter 3, Project Description, the SEIR identifies the proposed land use program, development envelope, circulation system, infrastructure improvements, grading concept, and anticipated earthwork quantities, including approximately 33.5 million cubic yards of grading shown on the Master Tentative Tract Map. The purpose of the SEIR is to evaluate the environmental consequences of that development program, not to approve final engineering drawings, grading plans, or building designs.
The comment also overlooks the well-established CEQA framework for programmatic environmental review. CEQA Guidelines Section 15168 authorizes programmatic EIRs for large, related actions and recognizes that subsequent site-specific activities may be evaluated in light of the broader programlevel analysis. Consistent with that framework, the SEIR did not defer grading-related impacts. Rather, grading and site disturbance activities were evaluated throughout the document using the information available at the planning level. For example, Section 4.2, Air Quality evaluates construction emissions associated with grading activities; Section 4.3, Biological Resources evaluates habitat disturbance and vegetation removal; Section 4.6, Geology and Soils evaluates earth movement, erosion, and slope stability; Section 4.9, Hydrology and Water Quality evaluates erosion and sedimentation; and Section
4.18, Wildfire evaluates site conditions associated with development and grading. These analyses are based on the Project's disclosed development program, anticipated earthwork quantities, acreage disturbances, technical studies, and engineering information available at the time of environmental review.
The commenter also misapplies Sundstrom v. County of Mendocino. The key takeaway from Sundstrom is that an agency cannot use a negative declaration (or mitigated negative declaration) while postponing critical environmental analysis and mitigation until after project approval. Here, by contrast, the City prepared a full SEIR and analyzed grading-related impacts based on the maximum development program under consideration. The fact that future final grading plans or pad configurations may be refined during subsequent approvals does not render the planning-level analysis inadequate.
Finally, nothing in the record indicates that the absence of final grading plans prevented meaningful public review. The SEIR disclosed the overall development program, anticipated grading quantities, environmental impacts, mitigation measures, alternatives, and significant and unavoidable impacts.
Accordingly, the SEIR provided decision makers and the public with sufficient information to evaluate the environmental consequences of the Project consistent with CEQA Guidelines section 15121. The comment therefore does not demonstrate that the SEIR improperly deferred analysis, failed to provide adequate disclosure, or identifies new information requiring recirculation under CEQA Guidelines Section 15088.5.
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O2-9 The use of CalEEMod to evaluate the Project's total energy demand at the entitlement stage represents a conservative standard estimate given that final construction drawings and engineering plans are not completed at this stage. The California Energy Commission (CEC)-approved compliance software discussed in the comment requires highly specific inputs, including architectural working drawings, mechanical duct sizing, specific heating, ventilation, and air conditioning, (HVAC) equipment models, insulation R-values, and lighting wattage density schedules. Instead, demonstration of compliance with Title 24 using CEC-approved software will occur during building plan check prior to construction.
Because compliance with Title 24 is a statutory requirement in California, Lead Agencies may reasonably rely on mandatory regulatory compliance to conclude that the Project would not conflict with state building energy efficiency standards.
O2-10 The comment mischaracterizes the purpose of the revisions made to Table 4.10-1 of the SEIR and the role of the land use conflict analysis. As explained in Response to Comment O5-12 in Chapter 8 of the Final SEIR, the courts have held that the issue of whether a proposed project is consistent with a general plan is not a CEQA issue. Rather, CEQA is concerned with the potential for projects to result in significant, physical environmental impacts. An analysis of the Project’s potential to result in a significant environmental impact due to a conflict with applicable General Plan policies adopted for the purpose of avoiding or mitigating an environmental effect is provided in Section 4.10, Land Use and Planning, of the SEIR. Importantly, the SEIR does not rely solely on the General Plan conflict analysis to determine the significance of environmental impacts. Potential impacts related to aesthetics, air quality, greenhouse gas emissions, and noise were independently analyzed in the applicable sections of SEIR Chapter 4 using CEQA significance thresholds, and the SEIR disclosed significant and unavoidable impacts where supported by substantial evidence. The revisions to Table 4.10-1 added additional General Plan goals and policies; however, these revisions did not change the significance determinations or conclusions of the SEIR. Nor did they identify a new significant impact or a substantial increase in the severity of a previously identified impact.
CEQA expressly contemplates that comments may result in clarifications and revisions to an EIR as part of the Final EIR process. The fact that additional policy discussion was added in response to comments demonstrates that the public review process functioned as intended. The underlying environmental impacts identified by the commenter were fully disclosed in the Draft SEIR and were available for public review and comment prior to the close of the comment period. Accordingly, the revisions to Table 4.10- 1 do not demonstrate that the Draft SEIR was incomplete or that the public was deprived of meaningful review. Rather, the SEIR disclosed the Project's environmental effects, analyzed those effects under the applicable CEQA standards, and supplemented the General Plan conflict discussion in response to comments without altering the substance of the environmental analysis. Thus, this comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
O2-11 The SEIR explicitly states that the proposed Business Park uses were not included in prior approvals and would generate approximately 8,509 jobs, and those uses are the subject of the proposed specific plan amendment and are expressly evaluated throughout the SEIR. The resulting employment growth is therefore not an unforeseen consequence occurring outside the planning process; it is an intended and disclosed component of the development program being considered by decision makers.
Importantly, the Project does not simply add employment-generating uses without accounting for how that growth may be accommodated. The development program includes up to 3,650 residential units,
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as well as supporting commercial uses and infrastructure, intended to accommodate future residents and employment opportunities within the Project site. The SEIR further evaluates the environmental impacts associated with both the residential and nonresidential components of the Project, including the housing, utilities, roadways, public services, and other infrastructure necessary to support future growth.
The commenter also conflates the Project's population and housing analysis with its air quality significance determination. The SEIR's finding that the Project would conflict with the applicable air quality management plan and result in significant and unavoidable air quality impacts does not demonstrate that the growth is substantial and unplanned. Rather, it demonstrates that the environmental consequences of the proposed development program, including the Business Park uses and associated employment growth, were disclosed, analyzed, and mitigated to the extent feasible.
Those impacts are evaluated in Section 4.2, Air Quality, disclosed in the SEIR, and clearly summarized in SEIR Section 5.1, Significant and Unavoidable Environmental Impacts.
Finally, the discussion of SCAG regional growth projections in Response to Comment O5-28 in the Final SEIR provides context regarding regional growth trends; it is not the basis for the SEIR's population and housing significance conclusions. The relevant issue is whether the Project would induce substantial unplanned growth that could result in unforeseen significant physical environmental effects (for example, through the need to construct additional housing elsewhere to accommodate employment generated by a solely industrial or commercial project). Because the proposed employment growth is expressly contemplated, disclosed, and evaluated as part of a phased specific plan amendment that includes housing, infrastructure, public services, and supporting land uses, the record does not support the assertion that the Project would induce substantial unplanned growth within the meaning of CEQA.
Accordingly, this comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
O2-12 CEQA Guidelines Section 15364 defines feasibility as "capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors." The infeasibility determinations in the SEIR and Responses to Comments O5-52 through O5-65 are grounded in several Project-specific constraints. First, neither the Lead Agency nor the Project Applicant owns, operates, or controls the third-party heavy-duty commercial truck fleets servicing the site. Imposing site-specific operational bans or zero-emission fleet requirements on independent freight carriers would create enforceable access constraints that cannot be legally or practically implemented by the Applicant at this single location. Further, the implementation of a zero-emission fleet depends on the ability to install high-capacity charging stations for heavy-duty trucks at the site, which require utility interconnection upgrades with lead times entirely controlled by Southern California Edison, not the Project Applicant. Imposing rigid zero-emission truck triggers untethered to utility capacity delivery would risk creating an unserviced, non-operational site, constituting an economic and operational infeasibility. Finally, with recent rollbacks in California Air Resources Board’s (CARB's) Advanced Clean Fleets rule and Zero-Emission Transport Refrigeration Unit (TRU) regulations, the future commercial availability and feasibility of zero-emission trucks and TRUs is currently unknown due to a rapidly evolving regulatory environment.
Response to Comment O5-63 in Chapter 8 of the Final SEIR correctly notes that over 86% of the Project’s greenhouse gas (GHG) emissions are attributable to transportation and energy sources
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governed by upstream market-based compliance mechanisms under the California Cap-and-Trade Program (specifically fuel suppliers and electrical utilities). To address the remaining 14% of emissions not subject to Cap-and-Trade compliance obligations, the City evaluated all feasible project-level mitigation measures pursuant to CEQA Guidelines Section 15126.4(c). The SEIR incorporates all feasible, enforceable, on-site measures to minimize these emissions.
Finally, the rejection of carbon offsets as a feasible mitigation measure is supported by substantial legal and practical evidence. Under CEQA Guidelines Section 15126.4(c)(3), GHG offset protocols must be real, permanent, quantifiable, verifiable, additional, and legally enforceable to the lead agency. Local lead agencies lack the administrative infrastructure, expertise, and jurisdictional authority to continuously audit, track, and verify out-of-basin or out-of-state carbon offset credits over a multidecade project lifetime. Accordingly, this comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
O2-13 This comment incorrectly states that the Project’s cumulative VMT analysis has been deferred and misinterprets the purpose of the conformity analysis required in accordance with MM-TRA-1. Appendix J-1, Transportation Impact Assessment of the SEIR includes both a Project-generated VMT analysis and a cumulative effect-on-VMT analysis. The analysis did not rely solely on Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) consistency. Instead, it compared the approved 2017 Specific Plan under the “Cumulative No Project” condition with the proposed Project under the “Cumulative with Project” condition. The analysis found that citywide boundary VMT per service population under proposed Project conditions would decrease from 16.3 to 14.7 compared to the approved 2017 Specific Plan and that VMT per service population within a 10-mile boundary would decrease from 16.4 to 16.3. Accordingly, and as discussed in Section 4.15 of the SEIR, the Project's VMT per service population would remain below the City's adopted significance thresholds under both baseline and cumulative conditions and would not result in a significant VMT impact under CEQA.
Furthermore, the VMT conclusion does not rely on the future I-10 interchange improvements being constructed. The interchange improvements are related to roadway operations and level of service, while the CEQA VMT analysis was performed separately using the Riverside County Transportation Model (RIVCOM). Under the City’s adopted methodology, the Project would have a significant cumulative VMT effect only if boundary VMT per service population increased with the Project. As stated above, the analysis found that citywide VMT per service population decreases from 16.3 to 14.7, and the 10-mile boundary decreases from 16.4 to 16.3. Therefore, the less-than-significant VMT conclusion is not dependent on completion of the future I-10 interchange improvements or the Caltrans Project Study Report.
Finally, the purpose of MM-TRA-1 is not to require a “deferred” VMT analysis; rather, it is to ensure that future Business Park uses, once operational, do not exceed the trip generation determined in the quantitative VMT analysis already provided in Appendix J-1 of the SEIR. In summary, the required cumulative VMT analysis was completed and supports the conclusion that the Project’s effect on VMT would be less than significant. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
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O2-14 The comment asserts that Dr. Smallwood’s perimeter survey observations were dismissed by Dudek as unreliable; however, neither this comment nor Comment O5-89 from the August 2025 letter (included as Comment Letter O5 in Chapter 8 of the Final SEIR) explain how these observations demonstrate any deficiency in the analysis or conclusions presented in the SEIR. Of the 55 wildlife species identified on Noriko Smallwood’s species list, 45 species were also documented by Dudek biologists during the comprehensive field surveys conducted within the Project site. In other words, approximately 82% of the species observed by Noriko Smallwood were independently documented by Dudek and are included in Appendix D, Wildlife Compendium, of the SEIR and were therefore used as the baseline for the Project’s impact analysis. The remaining 10 species were observed by Noriko Smallwood during surveys conducted from locations outside the Project site boundary. Of the 10 species not observed by Dudek, only two, black swift and western mastiff bat, have special-status designations that warrant consideration under CEQA (i.e., listed, or candidates for listing, as threatened or endangered by the U.S. Fish and Wildlife Service [USFWS] and the California Department of Fish and Wildlife [CDFW]; those designated as species of special concern by CDFW; as sensitive by USFWS; species with a California Rare Plant Rank [CRPR] of 1 or 2; and species that meet the definition of rare, threatened, or endangered under Section 15380 of the CEQA Guidelines; and/or species considered to be a taxon of special concern by local agencies). The remaining 8 are not considered special status and do not require analysis under CEQA.
Importantly, although neither the black swift nor western mastiff bat were observed by Dudek, both species were analyzed within the SEIR. As discussed in Appendix F of Appendix C to the SEIR, black swift is afforded special-status consideration by CDFW only during the nesting portion of its life cycle.
The species is not expected to nest within the Project site because suitable nesting habitat is absent.
Black swifts typically nest in moist crevices, caves, or cliff faces associated with waterfalls and deep canyon environments, none of which occur within the Project site. Accordingly, the species was appropriately addressed in the SEIR.
Western mastiff bat was also evaluated in Appendix C of the SEIR. The analysis concluded that the species has potential to forage within the Project site due to the presence of suitable chaparral and coastal scrub habitats. However, because bats are mobile and capable of utilizing adjacent areas of comparable habitat, Project implementation would not result in direct impacts to foraging individuals.
The SEIR also evaluated the potential for roosting western mastiff bats and determined such potential to be low. While the Project site does not contain the rocky canyons, cliffs, tunnels, or other features typically associated with western mastiff bat roosting habitat, two incised drainages with vertical faces occur in the central portion of the site and were conservatively identified as marginal roosting habitat (see Figure 4.3-8, Impacts to Jurisdictional Aquatic Resources, in Section 4.3, Biological Resources, of the SEIR). These drainage features would be avoided by Project grading activities and therefore would not be impacted by Project implementation. Furthermore, western mastiff bat is not listed under the federal or California endangered species acts and has not been observed within the Project site despite biological surveys. Accordingly, the SEIR concluded that Project impacts to western mastiff bat would be less than significant, and no mitigation measures are required.
Therefore, both special-status species identified from Noriko Smallwood’s observations were considered in the SEIR’s analysis, and the information provided does not identify any omission or inadequacy in the biological resources analysis.
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O2-15 First, because Proposed Constrained Linkage 23 is not spatially defined in the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) and is instead described conceptually, it is unclear how the commenter derived the claim that the Project would affect "approximately 336 acres" of the linkage. The comment provides no methodology or supporting evidence for this acreage estimate. As discussed in Section 4.3 of the SEIR, the Project occurs within several MSHCP Criteria Cells that contribute to Proposed Constrained Linkage 23. The MSHCP establishes a comprehensive framework for conserving Core, Linkage, and Constrained Linkage areas through the HANS process using Reserve Assembly analysis. The purpose of this framework is to create a regional conservation network that maintains habitat connectivity and wildlife movement throughout western Riverside County. Proposed Constrained Linkage 23 is one of the linkage features identified in the MSHCP conservation design to facilitate wildlife movement. Accordingly, consistency with the MSHCP is an appropriate consideration in evaluating impacts related to wildlife movement. It is also important to note that Proposed Constrained Linkage 23 is described in the MSHCP as providing connection to Boggart County Park and San Timoteo Creek, a region that extends far outside of the Project site. It is not the sole responsibility of the Project to contribute the conservation for this Proposed Constrained Linkage; the Project is only required to conserve its share as identified through the HANS and Joint Project Review (JPR) process.
The comment's characterization of the Western Riverside County Regional Conservation Authority’s (RCA's) March 2025 Amended JPR findings as demonstrating procedural compliance is inaccurate. The RCA, the joint powers authority responsible for implementing the MSHCP, reviewed the Project through the JPR process and determined that it satisfies the applicable Reserve Assembly requirements. In addition, CDFW and USFWS, collectively referred to as the Wildlife Agencies and the permitting agencies under the MSHCP, concurred with the MSHCP Consistency Analysis and Determination of Biologically Equivalent or Superior Preservation (DBESP) report. Through these reviews, the responsible MSHCP implementation and permitting entities confirmed that the Project is consistent with the Reserve Assembly goals of the MSHCP.
. Finally, the SEIR does not rely solely on procedural compliance with the MSHCP. The biological resources analysis specifically evaluated the Project's location within Proposed Constrained Linkage 23 and identified design features and mitigation measures intended to support wildlife movement. In particular, the Project prioritizes conservation of lands adjacent to Garden Air Wash, the feature identified by the MSHCP as Proposed Constrained Linkage 23, and along a major tributary to San Timoteo Creek, and the vast majority of drainages on the Project site. The preservation of these drainage systems is expected to continue to allow for wildlife movement through the site south towards Garden Air Wash, minimizing impacts to wildlife movement. Additionally, the created Roberts Road will include an undercrossing located approximately 400 feet north of the southern property boundary, that would help facilitate wildlife movement through Proposed Constrained Linkage 23. The undercrossing will have a 42-inch diameter and be approximately 140 feet long. Fencing shall be installed along Roberts Road, as required by MM-BIO-2 for areas that interface with the MSHCP Conservation area, that will help direct wildlife to use the undercrossing. The fencing design will have a minimum height of 6 feet with no greater than 2-inch openings (i.e., tubular steel fencing with tines set on 2-inch centers) and a metallic or masonry component (i.e., wire mesh cloth) buried to a minimum depth of 12 inches below ground surface level. Pursuant to MM-BIO-6, these areas would be permanently protected through conservation easements or transfer to the RCA and incorporated into the MSHCP Conservation Area, ensuring long-term preservation and management while preventing future degradation from
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incompatible uses. Pursuant to MM-BIO-2, additional project design features such as incorporation of barriers to prevent unauthorized public access to open space areas and stipulations that nighttime lighting be directed away from open space areas will ensure that avoided natural space throughout the project design can continue to be used to facilitate wildlife movement. Therefore, the comment does not identify a deficiency in the SEIR's wildlife movement analysis or provide substantial evidence that impacts to wildlife movement would be greater than disclosed in the SEIR.
O2-16 The comment incorrectly characterizes the survey results as the sole basis for the SEIR's conclusions.
As discussed in Response to Comment O5-83 in Chapter 8 of the Final SEIR and Section 4.3, Biological Resources of the SEIR, the determinations regarding Stephens' kangaroo rat and San Bernardino kangaroo rat were based on multiple lines of evidence, including applicable MSHCP requirements and species habitat suitability.
With respect to San Bernardino kangaroo rat, Appendix F of Appendix C of the SEIR concludes that San Bernardino kangaroo rat is not expected to occur on the Project site based on the absence of suitable habitat and the lack of nearby documented occurrences. Specifically, the Project site does not support Riversidean alluvial fan sage scrub, the habitat most commonly associated with the species, and no California Natural Diversity Database (CNDDB) records occur in the vicinity of the Project site. In addition, Section 4.3.1.6 of the SEIR states that the Project site is located outside the MSHCP Section
6.3.2 Additional Survey Needs and Procedures area for small mammals, including San Bernardino kangaroo rat. The MSHCP survey areas were developed using species-specific expertise and the best available biological information to identify areas where target species have a moderate or high potential to occur. Because the Project site is located outside these survey areas, surveys are not required to obtain MSHCP coverage for the species.
With respect to Stephens’ kangaroo rat, Appendix F of Appendix C of the SEIR concludes that Stephens’ kangaroo rat has a low potential to occur within the Project site. While the site contains suitable sparse grasslands, the Project site is located at the edge of the known geographic range for the species.
Furthermore, as stated in Section 4.3.2.3 of the SEIR, the Project site is outside of the Stephens’ Kangaroo Rat HCP Core Reserve Area and is located outside the Stephens’ Kangaroo Rat HCP fee area and therefore is not subject to its requirements. However, because the Project is located within the MSHCP plan area, the Project has “take” coverage for any Stephens’ kangaroo rat potentially occurring on the site through the MSHCP. Surveys were not conducted for the Stephens’ kangaroo rat because this species is fully covered by the MSHCP and the MSHCP does not require surveys for this species.
Accordingly, the comment does not identify a deficiency in the SEIR's analysis of Stephens' kangaroo rat or San Bernardino kangaroo rat, nor does it provide substantial evidence that additional surveys are necessary to support the impact conclusions.
O2-17 The comment incorrectly asserts that the SEIR failed to consider alternatives that would reduce the Project's significant impacts through increased residential density, reduced employment uses, or additional open space. Chapter 6, Alternatives of the SEIR evaluates alternatives specifically designed to achieve those objectives. Notably, Alternative 3 (Reduced Grading/Increased Residential Density/Decreased Business Park) and Alternative 4 (Reduced Grading/Increased Residential Density/Decreased Business Park – Emergency Access Only on County Line Road) reduce the amount of Business Park development, increase residential density, and preserve additional open space compared to the proposed Project. These alternatives were expressly analyzed because they have the
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potential to lessen environmental impacts while still meeting many of the Project's objectives.While CEQA does not require every alternative to satisfy every Project objective, it likewise does not require analysis of every conceivable alternative. Rather, CEQA requires a reasonable range of feasible alternatives that could attain most of the Project's basic objectives while avoiding or substantially lessening significant impacts. The SEIR satisfies that standard through its evaluation of six alternatives, including alternatives with reduced development intensity and reduced Business Park acreage.
The commenter also suggests that the alternatives analysis is inadequate because no alternative reduces all significant and unavoidable air quality and greenhouse gas impacts to a less-thansignificant level. However, CEQA does not require identification of an alternative that eliminates every significant impact. Instead, the SEIR compares the relative environmental benefits and drawbacks of each feasible alternative and identifies the environmentally superior alternative in accordance with CEQA requirements. Moreover, the commenter's proposed alternative emphasizing housing, mixed-use development, and local-serving commercial uses is conceptually similar to Alternatives 3 and 4, both of which increase residential density, reduce Business Park development, and retain more open space than the proposed Project. The SEIR evaluated these alternatives and concluded that, while they would reduce certain impacts, they would also reduce the Project's ability to achieve key objectives related to economic development and employment growth. Additionally, Alternative 4 would result in new significant and unavoidable impacts for public services related to increased response times for fire, police, and emergency medical providers and to transportation, hazards and hazardous materials, and wildfire due to inadequate emergency access. However, both Alternatives 3 and 4 were determined to be feasible (see SEIR Section 6.4.3 and 6.4.4 under the subheadings “Feasibility”). Alternative 3 was also clearly identified as the environmentally superior alternative (see Section 6.6, Environmental Superior Alternative of the SEIR) and will be considered by the decisions makers as part of the review and approval process. The alternatives analysis therefore satisfies CEQA Guidelines Section 15126.6 and the rule of reason. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
O2-18 The comment incorrectly asserts that recirculation is required under CEQA Guidelines Section 15088.5.
Neither the revisions made to the Draft SEIR in the Final SEIR nor the issues identified by the commenter constitute "significant new information" requiring recirculation. CEQA Guidelines Section 15088.5 requires recirculation only where new information added to an EIR results in: (1) a new significant environmental impact; (2) a substantial increase in the severity of a previously identified impact; (3) identification of a feasible mitigation measure or alternative considerably different from those previously analyzed that would clearly lessen impacts and has been declined by the project applicant; or (4) an EIR that is so fundamentally inadequate that meaningful public review was precluded. The record does not support any of those circumstances.
The commenter points to revisions to Table 4.10-1 and modifications to the General Plan Amendment discussion as evidence that the Draft SEIR was incomplete. However, as explained in Response to Comment O5-12 in Chapter 8 of the Final SEIR and reiterated in Response O2-10 above, these revisions were clarifications that added discussion of additional General Plan goals and policies in response to comments. The revisions did not alter the Project description, environmental baseline, significance determinations, mitigation measures, or conclusions of the SEIR. Nor did they identify a new significant impact or a substantial increase in the severity of a previously disclosed impact. The
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environmental effects of the Project (including the significant and unavoidable impacts related to cumulative aesthetics, air quality, greenhouse gas emissions, and noise) were fully disclosed and analyzed in the Draft SEIR and were available for public review prior to the close of the comment period.
The commenter likewise references alleged deficiencies related to VMT conformity, energy compliance, and biological mitigation. However, these issues have been extensively addressed in the administrative record, including the responses contained in Chapter 8 of the Final SEIR and the City's subsequent responses to additional comments provided above (see Response to Comment Letter O5 in the Final SEIR and Responses to Comments O2-10, O2-13, and O2-14 through -16 above). As stated above in Response to Comment O2-10, CEQA expressly anticipates that comments on a Draft EIR may result in clarifications, amplifications, and revisions in the Final EIR. The existence of revisions in response to comments is evidence that the public review process functioned as intended, not evidence that recirculation is required. Recirculation is not triggered merely because additional explanations are provided or because a commenter continues to disagree with the conclusions reached in the SEIR.
Rather, the question is whether the revisions deprive the public of a meaningful opportunity to comment on a previously undisclosed significant environmental effect or feasible mitigation measure.
Here, the revisions cited by the commenter do neither. Accordingly, the record demonstrates that the Draft and Final SEIR disclosed the Project's environmental impacts, evaluated feasible mitigation measures and alternatives, responded to comments received during public review, and provided clarifications where appropriate. The commenter has not identified a new significant impact, a substantial increase in impact severity, a previously undisclosed feasible mitigation measure or alternative, or a fundamentally inadequate analysis that would trigger recirculation under CEQA Guidelines Section 15088.5. Therefore, recirculation is not warranted.
O2-19 The commenter’s opposition to the Project is noted. Their concerns summarized in this comment have been responded to above in detail.
O2-20 This concluding paragraph reiterates concerns expressed in previous comments. These issues have been addressed extensively in the SEIR, Chapter 8 of the Final SEIR, and the City's additional responses to comments provided herein. The City concurs that the Planning Commission has an obligation to consider a legally adequate environmental document before taking action on the Project. The purpose of the Draft and Final SEIR (including Chapter 8, Response to Comments) and the additional response to comments documents added to the record during the public hearing process is to ensure that decision makers have a complete understanding of the Project and the potential environmental effects of the Project, including significant impacts, mitigation measures, and alternatives. The record demonstrates that the Project's environmental impacts have been disclosed, analyzed, and mitigated to the extent feasible in accordance with CEQA. The comment therefore does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or other new information requiring additional environmental review or recirculation under CEQA Guidelines Section 15088.5.
O2-21 The entirety of this comment letter (including attachments from SWAPE and Dr. Smallwood) was previously submitted in August 2025 and was responded to as part of the Final SEIR. As such, please refer to Response to Comment Letter O5 in Chapter 8 of the Final SEIR (with responses beginning on p. 8-203). This comment letter does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
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Response to Comment Letter I4
Clarence Hoefer
July 29, 2026
I4-1 This introductory comment expresses opposition to the Project but does not identify specific concerns regarding the adequacy of the SEIR. (Specific concerns are enumerated elsewhere in the letter and are responded to in further detail, below.) The Project and SEIR will be considered at the Planning Commission hearing scheduled for August 10, 2026. This comment has been forwarded to the decision makers for their consideration.
I4-2 The comment incorrectly asserts that the SEIR “completely fails” to analyze localized impacts on County Line Road residents. County Line Road is specifically identified in the SEIR as a Project access route, a location of proposed off-site improvements, and a roadway evaluated throughout the environmental analysis (see Chapter 3, Project Description, including Section 3.5.1, Off-Site Improvements as Project Components, and Section 3.5.2.1, Circulation Improvements, where the Project's proposed improvements to County Line Road and its role in the Project circulation system are described).
Potential physical environmental effects associated with County Line Road were evaluated throughout the SEIR, as applicable. For example, please refer to Section 4.15, Transportation, including Threshold
4.15a, which addresses consistency with transportation plans and the adequacy of the proposed County Line Road circulation improvements; Threshold 4.15c, which evaluates whether Project traffic would create roadway hazards, unsafe ingress/egress conditions, queueing issues, or other incompatible roadway design conditions; and Threshold 4.15d, which evaluates whether the Project would result in inadequate emergency access or impair emergency response. Threshold 4.10a in Section 4.10, Land Use and Planning of the SEIR includes discussion/analysis of whether proposed construction-related and operational activities (including increased vehicular traffic) along County Line Road would divide the established community. County Line Road and the adjacent/surrounding residents were also specifically evaluated in Section 4.11, Noise for roadway traffic noise impacts; Section 4.2, Air Quality for traffic-related emissions and pollutant exposure; Section 4.8, Hazards and Hazardous Materials for emergency access considerations; and Section 4.18, Wildfire for evacuation and emergency-access planning.
Please also refer to extensive responses provided in Chapter 8, Responses to Comments, of the Final SEIR that specifically address concerns regarding County Line Road and nearby residents. Most notably, please refer to Response to Comment Letter I1, which address previous comments summitted by Mr. Hoefer regarding County Line Road traffic, roadway-related environmental effects, and the adequacy of the SEIR's analysis. In those responses, it is explained that the physical effects associated with County Line Road improvements and County Line Road's function as a Project ingress/egress route were evaluated under the applicable CEQA topic areas, including transportation, noise, air quality, hazards, emergency access, and wildfire evacuation. It is also stated that the SEIR's analyses are supported by substantial evidence, technical studies, and expert review and do not omit consideration of County Line Road impacts. Additional responses in Chapter 8 of the Final SEIR providing clarity or insight on the SEIR’s consideration and analysis of potential impacts related to County Line Road and it’s residents include the following:
▪ Response to Comment A7-6 explains that County Line Road was recognized as one of the Project's two primary freeway access routes.
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▪ Responses to Comments A7-7, A7-8, and A7-20 discuss the proposed widening and operational improvements to County Line Road within the existing right-of-way. ▪ Responses to Comments A7-22, and A7-30 through A7-33 respond to concerns regarding localized traffic effects, school traffic, commuter travel patterns, trip distribution assumptions, and vehicle miles traveled associated with County Line Road. ▪ Response to Comment A8-1 and A8-4 discuss the existing right-of-way along County Line Road and proposed interchange improvements at the I-10 Freeway interchange, respectively.
The record therefore demonstrates that County Line Road, including traffic patterns, roadway improvements, air quality effects, noise effects, roadway safety, emergency access, and evacuation conditions, were expressly disclosed, evaluated, and/or responded to throughout the SEIR. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
I4-3 This comment does not identify specific concerns regarding the adequacy of the SEIR. The proposed changes to the approved 2017 Specific Plan are the reason the SEIR has been prepared and the subject of its analysis. To the extent the comment raises concerns regarding “rural character,” this is a broader planning and policy consideration that is not considered a CEQA impact category unless tied to a physical environmental effect. The potential for the Project to result in a significant impact (i.e., a significant, physical environmental effect) due to a conflict with the City’s General Plan, which reflects the City’s long-term planning objectives, is addressed Section 4.10, Land Use and Planning, of the SEIR.
This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
I4-4 As previously stated in Response to Comment I1-3 in Chapter 8, Response to Comment of the Final SEIR (starting on p. 8-277), per the modeling conducted for the Traffic Analysis (included as Appendix J-2 of the SEIR) the highest volume of Project vehicles on County Line Road would be 12,572 vehicles per day on a typical weekday, not 24,000. Furthermore, as shown in Exhibit 4.2-27 on page 4.2-27 of the Traffic Analysis (Appendix J-2 of the Draft SEIR), truck traffic associated with the proposed Business Park land uses (e.g., warehouses) would enter and exit the Project site via Sandalwood Drive, not County Line Road. Thus, the Project would not result in a significant increase of heavy truck traffic along County Line Road. Furthermore, the Project includes mitigation measures requiring posting of signage to identify approved truck routes and on-site circulation systems, as well as signage in the Business Park areas providing contact information to receive complaints about any excessive noise, dust, fumes, or odors. (Please refer to MM-AQ-15, MM-AQ-16, and MM-AQ-17 in Section 4.2.6.2 of the SEIR).
As discussed above in Response to Comment I4-2, the SEIR addresses roadway operations and safety considerations related to proposed County Line Road improvements in accordance with the required CEQA thresholds. For example, Threshold 4.15c in SEIR Section 4.15, Transportation, evaluates whether Project traffic would create roadway hazards, unsafe ingress/egress conditions, queueing issues, or other incompatible roadway design conditions while Threshold 4.15d evaluates whether the Project would result in inadequate emergency access or impair emergency response. Regarding relevant setbacks and the proposed widening of County Line Road, please refer to the discussion provided under Threshold 4.15c in Section 4.15 of the Draft SEIR (beginning on page 4.15-27 of the
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Final SEIR). County Line Road was also specifically evaluated in SEIR Section 4.8, Hazards and Hazardous Materials for emergency access considerations and Section 4.18, Wildfire for evacuation and emergency-access planning. County Line Road would be constructed in compliance with applicable safety standards for roadway design and would be within the City’s existing public right-of-way. The redevelopment of land within the City’s public right-of-way for the purposes of roadway redevelopment would not substantially increase roadway hazards.
I4-5 Please refer to Response to Comment I4-4, above.
I4-6 This comment from Mr. Hoefer was already addressed in Chapter 8, Response to Comments of the Final SEIR in Response to Comment Letter I1 (Beginning on p. 8-277 of the Final SEIR). Specifically, please refer to Responses to Comments I-4 and I-9. As stated therein, relevant setbacks and the proposed widening of County Line Road is addressed under Threshold 4.15c in Section 4.15 of the SEIR (beginning on page 4.15- 27 of the Final SEIR). In the current condition, there are five properties on the south side of County Line Road and two properties on the north side of County Line Road, between the Project site and the I-10 interchange, that do not meet the required 30-foot setback as set forth in Chapter 18.20.040, Residential Development Standards of the City’s Municipal Code and are considered to be existing non-conforming properties. The requirements for front yard setbacks in the Rural Residential zone, which is the applicable zone for the residential uses within this stretch of County Line Road, mandate that a building, structure, parking, or other designated item must be located 30- foot from a lot line. The roadway expansion would not alter the property lines of these properties or expand the existing public right-of-way. Although the homes/structures on these nonconforming properties would be closer to the paved roadway upon completion of the expansion of County Line Road, the reconfigured vehicle travel lanes would be buffered by 6-foot bike lanes on either side of the street as well as an approximately 6-foot-wide unpaved buffer area. Therefore, any nonconforming existing structures that are directly adjacent to the property line would be a minimum of 12 feet from a travel lane. Although the roadway would be widened and would accommodate additional vehicular traffic when compared to the current condition, County Line Road would be constructed in compliance with applicable safety standards for roadway design and would be within the City’s existing public right-of-way. The redevelopment of land within the City’s public right-of-way for the purposes of roadway redevelopment would not substantially increase roadway hazards. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
I4-7 Potential reductions in property values or other financial impacts to adjacent or nearby property owners are economic effects, which are not considered significant effects on the environment under CEQA in accordance with CEQA Guidelines Section 15131(a). CEQA defines a significant effect on the environment as a substantial, or potentially substantial, adverse change in the physical conditions within the area affected by the project (Public Resources Code Section 21068; CEQA Guidelines Section 15382). Accordingly, potential changes in property values are not environmental impacts requiring analysis under CEQA absent a demonstrated connection to a physical change in the environment.
Regarding relevant setbacks and the proposed widening of County Line Road, this concern was previously addressed in Mr. Hoefer’s August 2025 letter (see Response to Comment I1-4 in Chapter 8, Response to Comments of the Final SEIR beginning on p. 8-277) and reiterated above in Response to Comment I4-6. This comment does not identify a new significant environmental impact, a substantial
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increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
I4-8 Section 4.11, Noise, of the SEIR includes a detailed, segment‑level analysis of traffic noise at existing residences along County Line Road and identifies both mitigation and residual significant impacts consistent with CEQA. As explained above in Response to Comment I4-4 and previously in Response I1-3 in Chapter 8 of the Final SEIR, the highest projected traffic volume on County Line Road attributable to the Project is approximately 12,572 vehicles per day, not 24,000 vehicles per day. In addition, the SEIR and the above response have already explained that truck traffic associated with the proposed Business Park uses would access the site via Sandalwood Drive, not County Line Road.
SEIR Section 4.11 defines specific off‑site roadway segments—including County Line Road west of County Line Lane (Segment 1), County Line Road west of 7th Place (Segment 2), and County Line Road east of 7th Place (Segment 3)—and classifies adjacent rural residential uses as noise‑sensitive receivers. Using 24‑hour Community Noise Equivalent Level (CNEL) traffic noise modeling, the SEIR evaluates Existing, Opening Year (2030, 2035, 2038, 2040), and Horizon Year 2045 conditions, comparing “No Project” and “With Project” scenarios at these receivers. The analysis applies the City’s incremental increase criteria (e.g., 3 to 5 A-weighted decibel [dBA] thresholds) to determine significance. The results show that Project‑related traffic does in fact increase CNEL noise levels at residences along County Line Road. For example, under “Existing with Project Buildout” conditions at Segment 1 (west of County Line Lane), the SEIR identifies an approximate 9.7 dBA CNEL increase at the sensitive receiving land use, which exceeds the City’s significance threshold and is therefore concluded to be a significant off‑site traffic noise impact. Similar evaluations are presented for Opening Year and Horizon Year scenarios, demonstrating that the SEIR explicitly addresses localized, cumulative traffic noise effects on existing County Line Road residents.
Regarding mitigation, the SEIR evaluates both off‑site noise barriers and roadway pavement treatments. SEIR Appendix H and Section 4.11 explain that constructing sound walls along County Line Road for existing homes would not be feasible and would not reduce off‑site traffic noise levels below a level of significance, due to right‑of‑way constraints, existing development patterns, and physical limitations. As a result, off‑site sound walls are not proposed as mitigation for County Line Road.
Instead, as stated on p. 4.11-33 of the Final SEIR, the SEIR proposes MM‑NOI‑3, requiring the use of rubberized asphalt along County Line Road between County Line Lane and 7th Place (Segment 1), specifically adjacent to existing residential uses, to reduce tire‑pavement noise by about 4 dBA. The SEIR acknowledges that even with rubberized asphalt, the incremental traffic noise increase at these residences remains above City thresholds and therefore remains significant and unavoidable, which is clearly disclosed in the impact conclusion. The SEIR noise mitigation is feasible and enforceable as required under CEQA. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
I4-9 Section 4.2, Air Quality of the SEIR (supported by Appendix B-1, Air Quality Impact Analysis Report and Appendix B-2, Construction and Operational Health Risk Assessment) includes both a localized air quality analysis and a project-specific Health Risk Assessment (HRA) that evaluate potential impacts from diesel-powered construction equipment, truck traffic, transport refrigeration units, and other diesel emission sources at nearby sensitive receptors. The analysis was performed in accordance with South Coast Air Quality Management District (SCAQMD), California Air Resources Board, and U.S.
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Environmental Protection Agency guidance using the American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) dispersion model. The HRA evaluated cancer risk and non-cancer health impacts at sensitive receptor locations, including nearby residences, schools, worker locations, and future residential receptors. A total of 181 receptors extending up to three miles from the Project site were included in the modeling, and localized impacts were evaluated at the receptors closest to the Project site (see SEIR Section 4.2.1.3 and Appendix B-2).
The HRA specifically evaluated diesel particulate matter (DPM) emissions associated with construction equipment, haul trucks, on-site and off-site truck traffic, refrigerated truck operations, and emergency diesel engines. Therefore, the analysis did not ignore truck-related emissions, but instead expressly modeled those sources as part of the health risk analysis. The results demonstrate that health risks from DPM remain below SCAQMD significance thresholds. For construction activities, the highest incremental cancer risk at the nearest residential receptor was 0.94 in one million unmitigated and
0.26 in one million with mitigation, which is substantially below the SCAQMD significance threshold of 10 in one million. Non-cancer hazard indices were less than 0.01, well below the significance threshold of 1.0. For project operation, which includes truck traffic, the highest modeled cancer risk at an off-site residential receptor was 2.52 in one million, while the highest on-site residential risk was 7.35 in one million. Both values remain below the SCAQMD significance threshold of 10 in one million, and associated non-cancer hazard indices were also below significance thresholds. In addition to the HRA, the SEIR conducted a localized significance threshold (LST) analysis for criteria pollutants, including fine particulate matter (PM2.5) and coarse particulate matter (PM10). The analysis concluded that localized concentrations at nearby sensitive receptors would remain below applicable SCAQMD thresholds and would not result in significant localized air quality impacts. With specific regard to potential exposure to residents along County Line Road, localized construction and operational LST results for NO2, CO, PM10, and PM2.5 show that total concentrations (background plus project) are far below the applicable LSTs in each phase. Any receptors along County Line Road are farther from the main emission sources than the modeled maximum exposure receptors evaluated in the SEIR and therefore would experience lower concentrations than those evaluated Accordingly, the SEIR did not fail to evaluate potential health impacts to nearby residents. Rather, it includes a detailed, Project-specific HRA and localized air quality analysis specifically addressing DPM, PM2.5, truck traffic, and other emission sources. In all instances, potential maximum exposure(s) and health risks have been considered and evaluated. All potential impacts are substantiated to be below significance thresholds. Based on the modeling results, health risks to nearby residents, including those along County Line Road, are below SCAQMD significance thresholds and are therefore considered less than significant. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5 I4-10 The comment conflates baseline conditions with cumulative conditions and incorrectly asserts that the SEIR failed to account for traffic associated with the warehouse development near the I-10/County Line Road interchange in the City of Yucaipa. While CEQA baseline conditions are established based on existing conditions at the time environmental review commences (specifically for this Project, when the Notice of Preparation was published), the SEIR also evaluates reasonably foreseeable cumulative development in the Project vicinity. Even though the facility identified by the commenter was not fully operational when baseline conditions were established, its anticipated traffic was considered through
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the cumulative project analysis. Specifically, it was identified as Cumulative Project No. 27 in Figure 2- 4 and Table 2-3 of the SEIR and was incorporated into the cumulative development assumptions used in the SEIR, including for the air quality, noise, and transportation analyses. Furthermore, CEQA does not require the SEIR to individually model truck traffic from every off‑site facility in the region. Regional traffic and goods‑movement conditions on I‑10 are already reflected through the use of EMFAC‑based emission factors, Southern California Association of Government’s (SCAG’s) Connect SoCal 2024-2050 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) growth assumptions, and California Air Resources Board’s (CARB’s) statewide GHG inventories.
At a summary level, cumulative impacts under transportation, air quality, and noise are addressed in the SEIR and associated technical analyses as follows: the Project’s transportation analyses (SEIR Section 4.15) use the City’s adopted vehicle miles traveled (VMT) significance criteria and SCAG’s Connect SoCal 2024–2050 RTP/SCS regional growth assumptions, which inherently incorporate cumulative regional traffic and goods‑movement patterns on I‑10. The SEIR’s air quality analysis (SEIR Section 4.3) evaluates cumulative criteria pollutant impacts against the SCAQMD’s thresholds, which are derived from and tied to regional Air Quality Management Plan (AQMP) assumptions that already account for existing and forecast emissions from traffic and goods movement. Project emissions are added to regional background conditions informed by SCAG growth and SCAQMD planning, and the SEIR discloses when project contributions to regional ozone and particulate matter are cumulatively considerable. Finally, the SEIR noise analysis (SEIR Section 4.11) assesses increases in traffic‑related and operational noise against existing baseline noise levels, then evaluates cumulative future conditions by incorporating traffic forecasts and approved/planned development identified in the SEIR’s cumulative project list. Where cumulative traffic growth on facilities such as I‑10 or local arterials would cause or contribute to exceedances of noise criteria, the SEIR identifies those cumulative impacts and the Project’s incremental contribution.
Accordingly, the SEIR did not ignore or omit the facility (or cumulative traffic in general) from its cumulative impact evaluations. The comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
I4-11 The comment expresses disagreement with the proposed land use changes but does not identify a deficiency in the SEIR's environmental analysis. The Project proposes amendments to the previously approved 2017 Specific Plan, and those changes, including modifications to residential density categories and the introduction of Business Park uses, are fully disclosed in Chapter 3, Project Description, and analyzed throughout the SEIR. To the extent the comment raises generalized concerns regarding changes to the City’s “rural theme” or “rural character,” those concerns are broader planning and policy considerations and are not independent CEQA impact categories unless they are tied to a physical environmental effect. The potential for the Project to result in a significant impact (i.e., a significant, physical environmental effect) due to a conflict with the City’s General Plan, which reflects the City’s long-term planning objectives, was addressed Section 4.10, Land Use and Planning, of the SEIR. Accordingly, the comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
I4-12 As previously stated in response to Mr. Hoefer’s August 2025 comment letter (included as Comment Letter I2 in Chapter 8 of the Final SEIR), the 2017 approval included utilizing County Line Road only for
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emergency access and evacuation purposes. However, the Calimesa Fire Department has since determined that routing all traffic through Sandalwood Drive represents a safety hazard to the public, and that two points of thru ingress/egress to the Project site are required at all times. The role of County Line Road and Sandalwood Drive as Project access routes was specifically analyzed as part of the SEIR’s transportation and emergency access evaluations. County Line Road was recognized as one of the Project's primary access routes and was evaluated using the transportation methodologies and traffic forecasts contained in the Transportation Impact Assessment included as Appendix J-2 of the SEIR. The SEIR also evaluated the roadway improvements proposed along County Line Road and the ability of the surrounding roadway network to accommodate Project traffic. Additional discussion of County Line Road improvements and operations is provided in Chapter 8 of the Final SEIR. These responses specifically address traffic volumes, roadway improvements, trip distribution, interchange operations, and transportation infrastructure. Furthermore, Response I4-2 above explains that County Line Road was evaluated under the transportation, noise, air quality, hazards, and wildfire sections of the SEIR. This comment does not identify a new significant environmental impact, a substantial increase in the severity of a previously identified impact, or new information requiring recirculation under CEQA Guidelines Section 15088.5.
I4-13 These concluding paragraphs summarize the commenter’s concerns, which have been responded to above in detail. The commenter’s opposition to the Project is noted for the record and these comments will be forwarded to the decision makers for their review and consideration.
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Table of Contents
SECTION PAGE NO.
1 Introduction ..........................................................................................................................................................3 2 Comments and Responses .................................................................................................................................4 Response to Comment Letter O2...................................................................................................................121 Response to Comment Letter I4 ....................................................................................................................139 TABLES
Table 2. Comment Letters and Commenters (Vol. II) ......................................................................................................3
Mesa Verde Specific Plan Area 2
Amendment 2 Project
Responses to Additional
Comments Received – Vol. III
STATE CLEARINGHOUSE NO. 2004071045
SEPTEMBER 2026
Prepared by:
CITY OF CALIMESA
908 Park Avenue
Calimesa, California 92320
Prepared with assistance from:
225 South Lake Avenue, Suite M210
Pasadena, California 91101
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1 Introduction
The City of Calimesa (City) has received additional public comments letters after the close of the public review period for the Draft Subsequent Environmental Impact Report (SEIR)1 for the Mesa Verde Specific Plan Area 2 Amendment 2 Project (Project) and prior to the City Council hearing on September 21, 2026. As shown in Table 3, between August 10, 2026 and September 8, 2026, the City received a total of three additional comment letters on the Project and/or SEIR (inclusive of the Draft and Final SEIR). These additional comment letters (referred to herein as “Vol. III”) are organized into one category: Category I (written comments from individuals).2 Table 3. Comment Letters and Commenters (Vol. III)
Comment Letter Commenter Type Date Received
Individual
I5 C.W. Hoefer Individual August 10, 2026
I6 Saralyn Tossetti Individual August 12, 2026
I7 C.W. Hoefer Individual August 19, 2026
For reference purposes, each comment letter has been assigned a corresponding letter based on category and numbered in order of date received, starting with the earliest date. In turn, each specific comment within a particular letter has also been numbered and bracketed. For example, the second comment in letter “I5” is identified as “Comment I5-2.” The corresponding response uses the same convention, so the reader can match each response to the comment to which it refers. The bracketed letter precedes responses to the letter’s comments.
Most comments received were adequately addressed in the SEIR and/or were previously responded to in Chapter 8, Response to Comments, of the Final SEIR. All comments submitted have been responded to below. As presented in Section 2 of this document, none of the comments received identified deficiencies in the SEIR analysis that would require recirculation of the SEIR pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15088.5, Recirculation of an Environmental Impact Report Prior to Certification. CEQA Guidelines Section 15088.5 is provided below for reference:
(a) A lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review under Section 15087 but before certification. As used in this section, the term “information” can include changes in the project or environmental setting as well as additional data or other information. New information added to an EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. “Significant new information” requiring recirculation include, for example, a disclosure showing that:
1 The Draft SEIR was circulated for public review from July 11, 2025, through August 25, 2025, in accordance with Section 15105(a) of the California Environmental Quality Act Guidelines. 2 Comments received after the close of the public review period for the Draft SEIR and prior to the Planning Commission hearing on August 10, 2026 are addressed in Responses to Additional Comments Received Vols. I and II.