15. Response to Comments — Cathedral City City Council, January 8, 2025

Wren Apartments Project
GPA 23-002, CZ 23-001, DR 23-002,
Response to Comments

The City received two comment letters during the comment period for the Initial Study/Mitigated Negative Declaration for the proposed Project. In addition, an email was received from Caltrans 10 days after the close of the public review period.

The following provides individual comments and responses. The complete comments are attached to this response in Appendix A.

Riverside County Flood Control District
Letter dated October 24, 2024

Comment 1:

The Riverside County Flood Control and Water Conservation District (District) does not normally recommend conditions for land divisions or other land use cases in incorporated cities. The District also does not plan check City land use cases or provide State Division of Real Estate letters or other flood hazard reports for such cases. District comments/recommendations for such cases are normally limited to items of specific interest to the District including District Master Drainage Plan facilities, other regional flood control and drainage facilities which could be considered a logical component or extension of a master plan system, and District Area Drainage Plan fees (development mitigation fees). In addition, information of a general nature is provided.

The District's review is based on the above-referenced project transmittal, received October 16, 2024. The District has not reviewed the proposed project in detail, and the following comments do not in any way constitute or imply District approval or endorsement of the proposed project with respect to flood hazard, public health and safety, or any other such issue:

☒ This project would not be impacted by District Master Drainage Plan facilities, nor are other facilities of regional interest proposed. The project is located within Coachella Valley Water District's (CVWD) jurisdiction. CVWD is the responsible agency to review and comment on regional flood control drainage systems within their jurisdictional limits. ☐ This project involves District proposed Master Drainage Plan facilities, namely, . The district will accept ownership of such facilities on written request by the City. The Project Applicant shall enter into a cooperative agreement establishing the terms and conditions of inspection, operation, and maintenance with the District and any other maintenance partners. Facilities must be constructed to District standards, and District plan check and inspection will be required for District acceptance. Plan check, inspection, and administrative fees will be required. All regulatory permits (and all documents pertaining thereto, e.g., Habitat Mitigation and Monitoring Plans, Conservation Plans/Easements) that are to be secured by the Applicant for both facility construction and maintenance shall be submitted to the District for review. The regulatory permits' terms and conditions shall be approved by the Di strict prior to improvement plan approval, map recordation, or finalization of the regulatory permits. There shall be no unreasonable constraint upon the District's ability to operate and maintain the flood control facility(ies) to protect public health and safety.
☐ This project proposes channels, storm drains larger than 36 inches in diameter, or other GPA 23-002, CZ 23-001, DR 23-002
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facilities that could be considered regional in nature and/or a logical extension a District's facility, the District would consider accepting ownership of such facilities on written request by the City. The Project Applicant shall enter into a cooperative agreement esta blishing the terms and conditions of inspection, operation, and maintenance with the District and any other maintenance partners. Facilities must be constructed to District standards, and District plan check and inspection will be required for District acceptance. Plan check, inspection, and administrative fees will be required.

The regulatory permits' terms and conditions shall be approved by the District prior to improvement plan approval, map recordation, or finalization of the regulatory permits.

There shall be no unreasonable constraint upon the District's ability to operate and maintain the flood control facility(ies) to protect public health and safety. ☐ An encroachment permit shall be obtained for any construction related activities occurring within District right of way or facilities, namely, . If a proposed storm drain connection exceeds the hydraulic performance of the existing drainage facilities, mitigation will be required. For further information, contact the District's Encroachment Permit Section at 951.955.1266.
☐ The District's previous comments are still valid.

GENERAL INFORMATION
The project proponent shall bear the responsibility for complying with all applicable mitigation measures defined in the California Environmental Quality Act (CEQA) document, and/or Mitigation Monitoring and Reporting Program, and with all other federal, s tate, and local environmental rules and regulations that may apply, such as, but not limited to, the Multiple Species Habitat Conservation Plan (MSHCP), Sections 404 and 401 of the Clean Water Act, California Fish and Game Code Section 1602, and the Porter Cologne Water Quality Control Act. The District's action associated with the subject project triggers evaluation by the District with respect to the applicant's compliance with federal, state, and local environmental laws. For this project, the Lead Agenc y is the agency in the address above, and the District is a Responsible Agency under CEQA. The District, as a Co - permittee under the MSHCP, needs to demonstrate that all District related activities, including the actions identified above, are consistent with the MSHCP. This is typically achieved through determinations from the CEQA Lead Agency (if they are also a Co -permittee) for the project. For the MSHCP, the District's focus will be particular to Sections 6.1.2, 6.1.3, 6.1.4, 6.3.2, 7.3.7, 7.5.3, and Appendix C of the MSHCP. Please include consistency determination statements from the Lead Agency/Co - permittee for the project for each of these sections in the CEQA document. The District may also require that an applicant provide supporting technical docu mentation for environmental clearance.

This project may require a National Pollutant Discharge Elimination System (NPDES) permit from the State Water Resources Control Board. Clearance for grading, recordation, or other final approval should not be given until the City has determined that the p roject has been granted a permit or is shown to be exempt.

If this project involves a Federal Emergency Management Agency (FEMA) mapped floodplain, then the City should require the applicant to provide all studies, calculations, plans, and other information required to meet FEMA requirements, and should further require that the applicant GPA 23-002, CZ 23-001, DR 23-002
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obtain a Conditional Letter of Map Revision (CLOMR) prior to grading, recordation, or other final approval of the project and a Letter of Map Revision (LOMR) prior to occupancy.

Response 1:

The City thanks the District for its comments, and notes that the District has no facilities that would be impacted by the Project. No further response is required.

California Department of Fish and Wildlife
Letter dated November 4, 2024

Comment 1:

The California Department of Fish and Wildlife (CDFW) received a Notice of Availability and Notice of Intent to Adopt a Mitigated Negative Declaration (MND) from the City of Cathedral City (City) for the Project pursuant to the California Environmental Quality Act (CEQA) and CEQA Guidelines.1

Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife. Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

CDFW ROLE
CDFW is California’s Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State. (Fish & G. Code, §§ 711.7, subd. (a) & 1802; Pub. Resources Code, § 21070; CEQA Guidelines § 15386, subd. (a).) CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species. (Id., § 1802.) Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on Projects and related activities that have the potential to adversely affect fish and wildlife resources.

CDFW is also submitting comments as a Responsible Agency under CEQA. (Pub. Resources Code, § 21069; CEQA Guidelines, § 15381.) CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code. As proposed, for example, the Project may be subject to CDFW’s lake and streambed alteration regulatory authority. (Fish & G. Code, § 1600 et seq.) Likewise, to the extent implementation of the Project as proposed may result in “take” as defined by State law of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.), the Project proponent may seek related take authorization as provided by the Fish and Game Code.

PROJECT DESCRIPTION SUMMARY

Proponent: S2 Builders
GPA 23-002, CZ 23-001, DR 23-002
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Objective: The Project proposes to amend the General Plan land use designation for the Project site from General Commercial (GC) to Residential High Density (RH) and change the zone district from Planned Community Commercial (PCC) to Multiple -Family Residential (R3) to permit construction of a 204-unit apartment complex on a 10.48 acre lot.

Location: The Project site is located in the northeast corner of Date Palm Drive and the future west extension of Rosemount Road, generally located on the east side of Date Palm Drive, south of 30th Avenue and north of McCallum Way, in the City of Cathedral City, in the Coachella Valley region of Riverside County. The Project is located within Accessor’s Parcel Number (APN) 670- 110-043.

Timeframe: Project construction is proposed to begin in 2025.

Response 1:

The comment is noted. It provides a description of the Project and requires no further response.

Comment 2:

COMMENTS AND RECOMMENDATIONS
CDFW has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species (i.e., biological resources). CDFW offers the comments and recommendat ions below to assist the City in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources. The MND has not adequately identified and disclosed th e Project’s impacts (i.e., direct, indirect, and cumulative) on biological resources and whether those impacts are reduced to less than significant.

CDFW’s comments and recommendations on the MND are explained in greater detail below and summarized here. CDFW is concerned that the MND does not adequately identify or mitigate the Project’s significant, or potentially significant, impacts to biological resources. CDFW requests that additional information and analyses be added to a revised MND, along with avoidance, minimization, and mitigation measures that avoid or reduce impacts to less than significant.

Response 2:

The comment is noted. Individual responses to specific issues are provided below.

Comment 3:

Existing Environmental Setting
Compliance with CEQA is predicated on a complete and accurate description of the environmental setting that may be affected by the proposed Project. CDFW is concerned that the assessment of the existing environmental setting has not been adequately analyze d in the MND. CDFW is concerned that without a complete and accurate description of the existing environmental setting, the MND may provide an incomplete analysis of Project -related environmental impacts.

GPA 23-002, CZ 23-001, DR 23-002
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The MND lacks a complete assessment of biological resources within the Project site and surrounding area specifically as it relates to an assessment of biological resources specifically for western burrowing owl ( Athene cunicularia hypugaea ; burrowing owl). A complete and accurate assessment of the environmental setting and Project-related impacts to burrowing owl is needed to both identify appropriate avoidance, minimization, and mitigation measures and demonstrate that these measures reduce Project impacts to less than significant.

Response 3:

The comment is noted. However, the Initial Study/MND contains a description of the lack of habitat on page 37, a complete description of the species on page 8 of Appendix B, and a report of survey findings on page 10 of Appendix B. Also see Response 5 below.

Comment 4:

Mitigation Measures
CEQA requires that a MND include mitigation measures to avoid or reduce significant impacts.

CDFW is concerned that the mitigation measures proposed in the MND are not adequate to avoid or reduce impacts to biological resources to below a level of signific ance. To support the City in ensuring that Project impacts to biological resources are reduced to less than significant, CDFW recommends adding mitigation measures for burrowing owl and artificial nighttime lighting, as well as revising the mitigation measure for nesting birds.

1) Nesting Birds
It is the Project proponent’s responsibility to comply with all applicable laws related to nesting birds and birds of prey. Fish and Game Code sections 3503, 3503.5, and 3513 afford protective measures as follows: section 3503 states that it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by Fish and Game Code or any regulation made pursuant thereto. Fish and Game Code sec tion 3503.5 makes it unlawful to take, possess, or destroy any birds in the orders Falconiformes or Strigiformes (birds-of-prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by Fish and Game Code or any reg ulation adopted pursuant thereto. Fish and Game Code section 3513 makes it unlawful to take or possess any migratory nongame bird except as provided by rules and regulations adopted by the Secretary of the Interior under provisions of the Migratory Bird Treaty Act of 1918, as amended (16 U.S.C. § 703 et seq.).

With regard to the Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP), per its associated Implementing Agreement and Permits from CDFW and the U.S. Fish and Wildlife Service (USFWS), Take associated with Covered Activities will not be in violation of the Migratory Bird Treaty Act and will be consistent with Fish and Game Code sections 3503 and 3503.5; therefore, all Covered Activities within and outside Conservation Areas must undertake measures to avoid the take of individuals, nests, and eggs of nesting birds.

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potential to provide nesting opportunities for birds.” Based on review of historical aerial and street view imagery using Google Earth, the Project site contains a sp arce cover of shrubs, habitat suitable for birds that nest in shrubs and on the ground. CDFW is concerned about impacts to GPA 23-002, CZ 23-001, DR 23-002
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nesting birds including loss of nesting/foraging habitat and potential take from ground-disturbing activities and construction. Although the MND includes a Mitigation Measure BIO -1 for nesting birds, CDFW finds the measure to be insufficient in scope and t iming to reduce impacts to nesting birds to a level less than significant. Mitigation Measure BIO-1 indicates that the “nesting bird nesting season generally extends from February 1 through September 15 in southern California and specifically, March 15 through August 31 for migratory passerine birds. To avoid impacts to nesting birds (common and special status) during the nesting season, a qualified Avian Biologist will conduct pre -construction Nesting Bird Surveys (NBS) no more than 3 -days prior to Project related disturbance to nestable vegetation to identify any active nests.” Conducting work outside the peak nesting season is an important avoidance and minimization measure. CDFW also recommends the completion of nesting bird surveys regardless of the time of year to ensure that impacts to nesting birds are avoided. The timing of the nesting season varies greatly depending on several factors, such as bird species, weather conditions in any given year, and long -term climate changes (e.g., drought, warming, etc.). In response to warming, birds have been reported to breed earlier, thereby reducing temperatures that nests are exposed to during breeding and tracking shifts in availability of resources (Socolar et al., 20172). CDFW staff have observed that climat e change conditions may result in nesting bird season occurring earlier and later in the year than historical nesting season dates. CDFW recommends that disturbance of occupied nests of migratory birds and raptors within the Project site and surrounding area be avoided any time birds are nesting on - site. CDFW therefore recommends the completion of nesting bird surveys regardless of the time of year to ensure compliance with all applicable laws pertaining to nesting and migratory birds.

To support the City in reducing impacts to nesting birds to a level less than significant, CDFW recommends that the City revise Mitigation Measure BIO -1 with the following additions in bold and removals in strikethrough:

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August 31 for migratory passerine birds. To avoid impacts to nesting birds (common and special status) during the nesting season, a qualified Avian Biologist will conduct pre - construction Nesting Bird Surveys (NBS) no more than 3-days prior to Project related disturbance to nestable vegetation to identify any active nests. If no active nests are found, no further action will be required. If an active nest is found, the biologist will set appropriate no-work buffers around the nest which will be based upon the nesting species, its sensitivity to disturbance, nesting stage, and expected types, intensity, and duration of the disturbance. The nests and buffer zones shall be field-checked weekly by a qualified biological monitor. The approved no -work buffer zone shall be clearly marked in the field, within which no disturbance activity shall commence until the qualified biologist has determined the young birds have successfully fledged and the nest is inactive.

Response 4:

The comment is noted. However, the commenter appears to imply that birds may nest on the site outside of the established nesting period, without providing substantial evidence. The City’s responsibility is to assure that nesting birds are not disturbed, and that construction be avoided until the young have fledged. It is important to note that MBTA covered specie s include almost all bird species that could nest on the site, and that since a pre -construction survey will be required, all birds nesting on the site will be identified, regardless of MBTA status. The Initial Study mitigates impacts to nesting bird speci es to less than significant levels as written. The mitigation measure and the Initial Study correctly protect nesting birds, and do not require amendment.

Comment 5:

2) Burrowing Owl
On October 10, 2024, the Fish and Game Commission determined that western burrowing owl warrants protection as a candidate species under the California Endangered Species Act (Fish & G. Code, § 2050 et seq.). During the candidacy period, western burrowing owl will be afforded the same protection as threatened and endangered species under CESA.

Take of individual burrowing owls and their nests is defined by Fish and Game Code section 86, and prohibited by sections 3503, 3503.5, and 3513. Take is defined in Fish and Game Code section 86 as “hunt, pursue, catch, capture or kill, or attempt to hunt, pursue, catch, capture or kill.” Fish and Game Code sections 3503, 3503.5, and 3513 afford protective measures as follows: It is unlawful to take, possess, or destroy any birds in the order Strigiformes, including western burrowing owls, except as otherwise provided in the Fish and Game Code and related regulations. (Fish & G. Code, § 3503.5.) It is also unlawful to take, possess, or destroy western burrowing owl nests or eggs, except as otherwise provided in the Fish and Game Code and related regulations. (Fish & G. Code, §§ 3503, 3503.5.) State law also explicitly incorporates the GPA 23-002, CZ 23-001, DR 23-002
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prohibitions on take and possession set forth in the federal Migratory Bird Treaty Act. (Fish & G.

Code, § 3513.)

With regard to the CVMSHCP, the CDFW Natural Community Conservation Plan (NCCP) Permit #2835-2008-001-06 does not provide Take Authorization for burrowing owl individuals, nests, or eggs. To the contrary, section 3.5.6 of the NCCP Permit states burrowing owl “pairs or individuals will not be Taken” and reiterates that the “HCP/NCCP does not authorize Take of [burrowing owl] nests [or] eggs[.]” Therefore, throughout the CVMSHCP area —both within and without Conservation Areas— Permittees must ensure that activities occurri ng within their jurisdictions do not result in the take, possession, or destruction of burrowing owl individuals, nests, or eggs.

Any activity occurring within the CVMSHCP area that results in the take of burrowing owl individuals, nests, or eggs would be unlawful and would not be a Covered Activity under the CVMSHCP.

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contain suitable habitat for this species. No burrowing owls were observed during the site visit.

No burrows of any kind were located within the Project Site. No portion of the Project Site showed any evidence of past or present BUOW activity. No feathers, whitewash, or castings were found and no suitable burrow surrogate species are present onsite. Therefore, no suitable habitat exists on-site and no focused surveys are required.” Page 4 of the Project’s Biological Resources Assessment (Biological Assessment) states that a “general reconnaissance survey [was competed] within the Project site to identify the potential for the occurrence of special status species, vegetation communities, or habitats that could support special status wildlife species.

The surveys were conducted on foot, throughout the Project site between 0800 and 0900 hours on August 9, 2023.” The MND and the Biological Assessment do not indicate if a h abitat assessment or focused surveys for burrowing owl, conducted independently of surveys for other species, were completed. The Biological Assessment also does not indicate if a habitat assessment and/or surveys were conducted in open- space areas to the north, west, or south of the Project area. Given the MND’s lack of findings from a recent habitat assessment and focused surveys for burrowing owl following the guidelines in the Staff Report on Burrowing Owl Mitigation,3 the number of suitable and occupied burrows within the Project site and surrounding areas is unknown.

CDFW is also concerned with the MND’s conclusion that the Project site does not contain suitable habitat for burrowing owl. The Project’s Biological Assessment indicates that the “habitat on-site consists of sparse vegetation and bare ground.” CDFW notes that in California, preferred habitat for burrowing owl is generally typified by short, sparse vegetation with few shrubs, and that burrowing owls may occur in ruderal grassy fields, vacant lots, and pastures if the vegetation structure is suitable and ther e are useable burrows and foraging habitat proximity. Based on review of historical aerial imagery and street imagery using Google Earth and photos included in the Biological Assessment, the Project site and surrounding areas to the west, north, and south contain habitat with sparse cover of native vegetation that is suitable nesting and foraging habitat for burrowing owl. CDFW considers the Project site to contain suitable habitat for burrowing owl; however, the status of burrowing owl presence within and surrounding the Project site is unknown. In addition, burrowing owls frequently move into disturbed areas prior to and during construction activities since they are adapted to highly modified habitats.

GPA 23-002, CZ 23-001, DR 23-002
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CDFW is concerned that the Project has the potential to impact burrowing owl, yet the MND lacks appropriate analysis on presence of the species within the Project site and surrounding area and appropriate avoidance, minimization, and mitigation measures. C DFW recommends the MND is revised to include the findings, including survey methods and survey reports, from recent focused burrowing owl surveys following the guidelines in the Staff Report on Burrowing Owl Mitigation along with appropriate avoidance, minimization, and mitigation measures.

To support the City in reducing impacts to burrowing owl to a level less than significant, CDFW recommends the City add the following mitigation measure to a revised MND:

Mitigation Measure BIO-[A]: Burrowing Owl Surveys
Suitable burrowing owl habitat has been confirmed on the site; therefore, focused burrowing owl surveys shall be conducted by a qualified biologist according to the Staff Report on Burrowing Owl Mitigation (CDFG, 2012 or most recent version) prior to vegetation removal or ground-disturbing activities. If burrowing owls are detected during the focused surveys, the qualified biologist and Project proponent shall begin coordination with CDFW and USFWS immediate ly, and shall prepare a Burrowing Owl Plan that sh all be submitted to CDFW for review and approval prior to commencing Project activities. The Burrowing Owl Plan shall describe proposed avoidance, minimization, mitigation, and monitoring actions. The Burrowing Owl Plan shall include the number and locatio n of occupied burrow sites (occupied site means at least one burrowing owl has been observed within the last three years; may also be indicated by owl sign including feathers, pellets, prey remains, eggshell fragments, or excrement at or near a burrow entr ance or perch site), acres of burrowing owl habitat that will be impacted, details of site monitoring, and details on proposed buffers and other avoidance measures. If impacts to occupied burrowing owl habitat or burrow cannot be avoided, the Burrowing Owl Plan shall also describe minimization and relocation actions that will be implemented. Proposed implementation of burrow exclusion and closure should only be considered as a last resort, after all other options have been evaluated as exclusion is not in itself an avoidance, minimization, or mitigation method and has the possibility to result in take. If impacts to occupied burrows cannot be avoided, informa tion shall be provided regarding adjacent or nearby suitable habitat available to owls along with proposed relocation actions. The Project proponent shall implement the Burrowing Owl Plan following CDFW and USFWS review and approval. If Project activities, including burrow exclusion and closure, could result in take of burrowing owl, appropriate CESA authorization should be obtained prior to commencement of Project activities.

Preconstruction burrowing owl surveys shall be conducted no less than 14 days prior to the start of Project-related activities and within 24 hours prior to ground disturbance, in accordance with the Staff Report on Burrowing Owl Mitigation (CDFG, 2012 or most recent version). Preconstruction surveys should be performed by a qualified biologist following the recommendations and guidelines provided in the Staff Report on Burrowing Owl Mitigation. If the preconstruction surveys confirm occupied burrowing owl h abitat, Project activities shall be immediately halted. The qualified biologist shall coordinate with CDFW and prepare a Burrowing Owl Plan that shall be submitted to CDFW and USFWS for review and approval prior to commencing Project activities.

GPA 23-002, CZ 23-001, DR 23-002
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Response 5:

The comment is noted. The project biologist found no evidence of burrowing owl, or of burrows which would be appropriate for burrowing owl in the field survey conducted for the project . The commenter does not provide any new facts or evidence to contradict that fact.

There was no need for habitat assessments, since no habitat or sign was identified on the site.

Based on the lack of habitat or burrows, contrary to the commenter’s statement, “the number of suitable and occupied burrows within the Project site ” is known – there are none. Further, contrary to the commenter’s assertion that the species can occur in “ruderal grassy fields, vacant lots, and pastures if the vegetation structure is suitable and there are useable burrows and foraging habitat proximity,” the biologist found neither the vegetation structure nor any burrows on the property.

In addition, the site is not surrounded by open space. The site is surrounded by a church on the north, a six-lane major arterial roadway on the west, and a fully built out residential neighborhood on the east.

Finally, the commenter used only Google Earth to assess the value of the habitat. It must be noted that the imagery on Google Earth dates back 2 years (October 2022), and that the project biologist conducted an on -site field survey, which results in much more accurate findings. The commenter provides no further evidence, including any data on the occurrence of the species in this part of the City (which was not identified in the database searches conducted by the project biologist), or any other substantial evidence in support of their opinion.

In addition, the professional biologist conducting the preconstruction bird survey will report the presence of burrowing owl, as they are now proposed for listing. Should that occur, the biologist will be responsible for implementing the CDFW protocols established in the Staff Report for burrowing owl.

The Initial Study therefore correctly assesses, based on substantial evidence, that there is currently no presence or habitat for the species, and no mitigation is required.

Comment 6:

3) Artificial Nighttime Lighting

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landscape lighting, pole lighting at 18 feet in height, and wall lighting for the apartment buildings”, and that lighting will be “shielded downward consistent with City requirements to protect adjacent property from light, particularly to the east where single family homes occur.” The Project is located adjacent to the open -space areas to the north, west, and south —areas that provide suitable nesting, roosting, foraging, and refugia habitat for birds, migratory birds that fly at night, bats, and other nocturnal and crepuscular wildlife. The Projec t’s proposed artificial nighttime lighting has the potential to significantly and adversely affect wildlife in the open -space areas adjacent to the Project site. Artificial lighting alters ecological processes including, but not limited to, the temporal ni ches of species; the repair and recovery of physiological function; the GPA 23-002, CZ 23-001, DR 23-002
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measurement of time through interference with the detection of circadian and lunar and seasonal cycles; the detection of resources and natural enemies; and navigation. Many species use photoperiod cues for communication (e.g., bird song), determining when to begin foraging, behavioral thermoregulation and migration. Phototaxis, a phenomenon that results in attraction and movement towards light, can disorient, entrap, and temporarily blind wildlife species that experience it.

While plans for shielding artificial nighttime lighting support the Project in limiting lighting impacts to biological resources within areas surrounding the Project site, CDFW considers these minimization plans insufficient in scope and timing to reduce i mpacts to a level less than significant. To support the City in avoiding or reducing impacts of artificial nighttime lighting on biological resources to less than significant, CDFW recommends the City add the following mitigation measure to a revised MND:

Mitigation Measure BIO-[B]: Artificial Nighttime Lighting

Throughout construction and the lifetime operations of the Project, the City of Cathedral City and Project proponent shall eliminate all nonessential lighting throughout the Project area and avoid or limit the use of artificial light at night during the ho urs of dawn and dusk when many wildlife species are most active. The City of Cathedral City and Project proponent shall ensure that all lighting for the Project is fully shielded, cast downward and directed away from surrounding open -space and agricultural areas, reduced in intensity to the greatest extent possible, and does not result in lighting trespass including glare into surrounding areas or upward into the night sky (see the International Dark-Sky Association standards at http://darksky.org/). The City of Cathedral City and Project proponent shall ensure use of LED lighting with a correlated color temperature of 3,000 Kelvins or less, proper disposal of hazardous waste, and recycling of lighting that contains toxic compounds with a qualified recycler.

Response 6:

The commenter’s opinion is noted, but provides no substantial evidence that the Project will result in substantial lighting, or that the lighting proposed for the Project will impact biological resources. The City’s construction hour restrictions make it u nlikely that construction will occur at night. Further, the City’s lighting standards are restrictive to lighting, and it must be fully screened and downward-directed. There is no evidence that lighting on the property would be significant, and no change to the IS is required.

Comment 7:

4) Landscaping

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Langman’s Sage, Sierra Bouquet Barometerbush , La Jolla Bougainvillea, Spreading Sunshine Lantana, Yellow Bells, Iceberg Rose, and Prostrate Natal Plum are proposed.” CDFW recommends that the MND include recommendations regarding landscaping from Section 4.0 of the CVMSHCP “Table 4 - 112: Coachella Va lley Native Plants Recommended for Landscaping” (pp. 4 -180 to 4 - 182; https://cvmshcp.org/plan-documents/). CDFW also recommends incorporation of water -wise concepts in any Project landscape design plans. In particular, CDFW recommends xeriscaping with locally native California species and installing water- efficient and targeted irrigation systems (such as d rip irrigation). Native plants support butterflies, birds, reptiles, amphibians, small mammals, bees, and other pollinators that evolved with those plants. More information on native plants suitable for the Project location and nearby nurseries is availabl e at Calscape: https://calscape.org/. Local water agencies/cities and resource conservation cities in your area may be able to provide information on plant nurseries that carry locally native species, and some facilities display drought -tolerant locally native species demonstration gardens. Information on drought-tolerant landscaping and water-efficient irrigation systems is available on California’s Save our Water website:
https://saveourwater.com/.

Response 7:

The comment is noted. The Project is required to comply with both the City’s water efficient landscaping standards and CVWD’s water conservation requirements in landscaping, which includes water budgeting for landscaped areas. The Project will therefore be regulated to assure low water use in landscaping, as clearly stated in the Initial Study.

Comment 8:

ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e).) Accordingly, please report any special-status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB). The CNNDB field survey form can be filled out and submitted online at the following link:
https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported to CNDDB can be found at the following link: https://www.wildlife.ca.gov/Data/CNDDB/Plants-and- Animals.

ENVIRONMENTAL DOCUMENT FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is required in order for the underlying Project approval to be operative, vested, and final. (Cal. Code Regs, tit. 14, § 753.5; Fish & G.

Code, § 711.4; Pub. Resources Code, § 21089.)

CONCLUSION
GPA 23-002, CZ 23-001, DR 23-002
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CDFW appreciates the opportunity to comment on the MND to assist the City in identifying and mitigating Project impacts to biological resources. CDFW concludes that the MND does not adequately identify or mitigate the Project’s significant, or potentially significant, impacts to biological resources. CDFW also recommends that revised and additional mitigation measures and analysis as described in this letter be added to a revised MND.

CDFW personnel are available for consultation regarding biological resources and strategies to avoid and minimize impacts. Questions regarding this letter or further coordination should be directed to Jacob Skaggs, Senior Environmental Scientist Specialist , at [email protected].

Response 8:

The City will continue to assure that biologists report their findings when studies are prepared, and that CDFW fees are paid when necessary. The commenter’s opinions are noted, but as described above, the City has prepared an IS which complies with CEQA and which will mitigate the impacts of the Project to less than significant levels. No changes to the document are necessary.

California Department of Transportation (Caltrans)
Email dated November 14, 2024

Comment 1:

The California Department of Transportation (Caltrans) Local Development Review (LDR) unit has completed the initial evaluation of the Wren Residential Project Draft Initial Study & Mitigated Negative Declaration. We have the following comments:

1. The Traffic Impact Analysis (TIA) should include the study area intersections at Date Palm Drive and the I -10 Eastbound (EB) ramps, as well as Date Palm Drive and the I -10 Westbound (WB) ramps.

Response 1:

The commenter requests analysis of the I -10 eastbound and westbound ramps without explanation, and provides no substantial evidence that such analysis is warranted. As described by the City’s consulting traffic engineer in his response memorandum (Appendix A), the City uses a standard methodology of 50 peak hour trips affecting an intersection in determining the need for analysis. The Project will generate up to 36 peak hour trips northbound on Date Palm Drive during the evening peak hour (the higher of the morning and evening peak hour). Some of these trips will enter the I -10 at Date Palm, but others will turn off at Vista Chino, or continue north past the interstate. There is therefore no potential for the Project to contribute 50 or more trips to the I-10 ramps.

In addition, the General Plan analyzed impacts to the I-10 ramps in its EIR, including commercial land uses designated for this Project site. The EIR found, as shown in Table 2.16.8, that both the east- and westbound ramps will operate at Level of Service C or better in 2040, the horizon GPA 23-002, CZ 23-001, DR 23-002
Response to Comments

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year for the General Plan. Commercial land uses generate a much higher number of trips than residential land uses, and the EIR therefore estimated a higher number of trips accessing the ramps than will now occur, if the General Plan Amendment is approved.

Therefore, the Initial Study correctly analyzed traffic impacts; the Project will not significantly impact the I-10 ramps on Date Palm Drive; and no further analysis is necessary.

Comment 2:

2. Once the I-10 study areas are included in the TIA, the Caltrans Traffic Forecasting and Analysis Division requests to review the Traffic Impact Analysis Report (TIA) and provide concurrence with the Average Annual Daily Traffic (AADT) and the forecasted tr affic volumes.

3. The Caltrans Division of Transportation Planning shall review and provide concurrence with the appropriate ITE trip generation for the land use and size of proposed project.

Response 2:

Please see Response 1 above. The commenter’s request for additional analysis is not supported by substantial evidence, and no further analysis is warranted. As it relates to the ITE trip generation category, the traffic analysis for the Project and the Initial Study correctly used ITE Land Use Code 220, Multi -Family Low Rise (please see Appendix G of the Initial Study, Table 1-1).

GPA 23-002, CZ 23-001, DR 23-002
Response to Comments

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APPENDIX A

COMMENT LETTERS

JASON E. UHLEY 1995 MARKET STREET
General Manager-Chief Engineer RIVERSIDE, CA 92501
951.955.1200
951.788.9965 FAX
www.rcflood.org
259432

RIVERSIDE COUNTY FLOOD CONTROL

AND WATER CONSERVATION DISTRICT
October 24, 2024

City of Cathedral City
Planning Division
68-700 Avenida Lalo Guerrero
Cathedral City, CA 92234-7031

Attention: Cynthia Schultz Re: GPA 23-002, DR 23-002, CZ 23-001, APN 670-110-043

District comments/recommendations for such cases are normally limited to items of specific interest to the District including District Master Drainage Plan facilities, other reg ional flood control and drainage facilities which could be considered a logical component or extension of a master plan system, and District Area Drainage Plan fees (development mitigation fees). In addition, information of a general nature is provided.

The District's review is based on the above- referenced project transmittal, received October 16, 2024. The District has not reviewed the proposed project in detail, and the following comments do not in any way constitute or imply District approval or endorsement of the proposed project with respect to flood hazard, public health and safety, or any other such issue:

☐ This project involves District proposed Master Drainage Plan facilities, namely, . The district will accept ownership of such facilities on written request by the City. The Project Applicant shall enter into a cooperative agreement establishing the terms and conditions of inspection, operation, and maintenance with the District and any other maintenance partners. Facilities must be constructed to District standards, and District plan check and inspection will be required for District acceptance. Plan check, inspection, and administrative fees will be required. All regulatory permits (and all documents pertaining thereto, e.g., Habitat Mitigation and Monitoring Plans, Conservation Plans/Easemen ts) that are to be secured by the Applicant for both facility construction and maintenance shall be submitted to the District for review. The regulatory permits ' terms and conditions shall be approved by the District prior to improvement plan approval, ma p recordation, or finalization of the regulatory permits. There shall be no unreasonable constraint upon the District's ability to operate and maintain the flood control facility(ies) to protect public health and safety.

☐ This project proposes channel s, storm drains larger than 36 inches in diameter, or other facilities that could be considered regional in nature and/or a logical extension a District's facility, the District would consider accepting ownership of such facilities on written request by the City. The Project Applicant shall enter into a cooperative agreement establishing the terms and conditions of inspection, operation, and maintenance with the Distr ict and any other maintenance partners. Facilities must be constructed City of Cathedral City -2 - October 24, 2024
Re: GPA 23-002, DR 23-002, CZ 23-001,
APN 670-110-043 259432

to District standards, and District plan check and inspection will be required for District acceptance.

Plan check, inspection, and administrative fees will be required. The regulato ry permits' terms and conditions shall be approved by the District prior to improvement plan approval, map recordation, or finalization of the regulatory permits. There shall be no unreasonable constraint upon the District 's ability to operate and maintain the flood control facility(ies) to protect public health and safety.

☐ An encroachment permit shall be obtained for any construction related activities occurring within District right of way or facilities, namely, ____________________. If a proposed storm drain connection exceeds the hydraulic performance of the existing drainage facilities, mitigation will be required. For further information, contact the District's Encroachment Permit Section at 951.955.1266.

☐ The District's previous comments are still valid.

The District's action associated with the subject project triggers evaluation by the District with respect to the applicant's compliance with federal, state, and local env ironmental laws. For this project, the Lead Agency is the agency in the address above, and the District is a Responsible Agency under CEQA. The District, as a Co- permittee under the MSHCP, needs to demonstrate that all District related activities, includ ing the actions identified above, are consistent with the MSHCP. This is typically achieved through determinations from the CEQA Lead Agency (if they are also a Co-permittee) for the project. For the MSHCP, the District's focus will be particular to Sections 6.1.2, 6.1.3, 6.1.4, 6.3.2, 7.3.7, 7.5.3, and Appendix C of the MSHCP. Please include consistency determination statements from the Lead Agency/Co -permittee for the project for each of these sections in the CEQA document. The District may also requi re that an applicant provide supporting technical documentation for environmental clearance.

This project may require a National Pollutant Discharge Elimination System (NPDES) permit from the State Water Resources Control Board. Clearance for grading, recordation, or other final approval should not be given until the City has determined that the project has been granted a permit or is shown to be exempt.

If this project involves a Federal Emergency Management Agency (FEMA) mapped floodplain, then the Cit y should require the applicant to provide all studies, calculations, plans, and other information required to meet FEMA requirements, and should further require that the applicant obtain a Conditional Letter of Map Revision (CLOMR) prior to grading, record ation, or other final approval of the project and a Letter of Map Revision (LOMR) prior to occupancy.

Very truly yours,

AMY MCNEILL
Engineering Project Manager

EM:zl

From: McKinney, Elsa
To: Cynthia Schultz
Cc: McNeill, Amy; Cornelius, William
Subject: GPA 23-002, DR 23-002, CZ 23-001-Due 10/24/2024 Date: Thursday, October 24, 2024 2:55:25 PM
Attachments: image001.png
image002.png
image003.png
259432_{83B153B3-B125-CC39-8745-92C057F00000}.pdf
2886_001.pdf
You don't often get email from [email protected]. Learn why this is important Good afternoon Cynthia,
Attached you will find a copy of Riverside County Flood Control’s comments pertaining to the above- mentioned project.

Should you have any questions please feel free to contact us. *please include, Amy McNeill ([email protected]
), Elsa McKinney ([email protected]), and
William (Michael) Cornelius ([email protected]) to the City’s distribution list for Flood Control.

This way we can ensure a timely response even if one of us is out of the office.

Kind Regards,

Elsa McKinney, Engineering Tech 1
Development Review
Riverside County Flood Control & Water Conservation District [email protected]
1995 Market Street, Riverside, CA 92501
951.955.2878

*Off Fridays

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County of Riverside California

CITY OF CATHEDRAL CITY
CASES
LEAD AGENCY:

TO ADOPTTED N
Genera I P la n Ame nd ment G PA 23-003fiUffi0 ilOfVllHl$i00 UilVIA 0W Design Review 23-002 Tufil09000U,Uln0tffl$U3mu
Change of Zone 23-001
tz0ee r 130
City of Cathedral City
68-700 Avenida Lalo Guerrero
Cathedral City, CA 92234
Cynthia Schultz
Associate Planner
(760) 770-0386
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CONTACT PERSON:E@EIVE
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PRoJECT LocArloN: rhe 10.48-acre Project site is
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670-110-043. The Project is located on the northeast corner of Date Palm Drive and the future west extension of Rosemount Road, generally located on the east side of Date Palm Drive, south of 30th Avenue and north of McCallum Way, in the City of Cathedral City, in the Coachella Valley region of Riverside County.

PROJECT DESCRIPTION:The Project proposes to amend the General Plan land use designation for the Project site from General Commercial (GC) to Residential High Density (RH) and change the zone district from Planned Community Commercial (PCC) to Multiple-Family Residential (R3) to permit construction of 204 dwelling units in 12 buildings. The Project will also include a clubhouse and associated residential amenities. The site will include individual garages as well as 127 surface parking spaces and access aisles.

FINDINGS/DETERMINATION: The City has reviewed and considered the proposed project and has determined that the project will not have a significant impact on the environment. The City hereby prepares and proposes to adopt a Mitigated Negative Declaration for this project.

PUBLIC REVIEW PERIOD: A 20-day public review period for the Draft Mitigated Negative Declaration will commence on October 14, 2024, and end on November 4, 2024, for interested individuals and public agencies to submit written comments on the document. Any written comments on the Draft Mitigated Negative Declaration must be received at the above address within the public review period. ln addition, you may email comments to the following address:
[email protected]. The Draft Mitigated Negative Declaration and supporting material are available for review online at: https://mvw.cathedralcitv.qov/departments/planninq/public-hearing- environmental-notices or City Hall, 68700 Avenida Lalo Guerrero, Cathedral City.

PUBLIC MEETING: A separate public hearing notice will be circulated in accordance with the Cathedral City Municipal Code once a public hearing has been scheduled.

D
State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director Inland Deserts Region
3602 Inland Empire Boulevard, Suite C-220
Ontario, CA 91764
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870

November 4, 2024
Sent via email

Cynthia Schultz
Associate Planner
City of Cathedral City
68-700 Avenida Lalo Guerrero
Cathedral City, CA 92234
[email protected]

The Wren Multi-Family Development Project (PROJECT)
Mitigated Negative Declaration (MND)
SCH# 2024100551

Dear Cynthia Schultz:

Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife.

Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

1CEQA is codified in the California Public Resources Code in section 21000 et seq. The “CEQA Guidelines” are found in Title 14 of the California Code of Regulations, commencing with section 15000.

Cynthia Schultz, Associate Planner
City of Cathedral City
November 4, 2024

Page 2 ends

activities that have the potential to adversely affect fish and wildlife resources.

CDFW is also submitting comments as a Responsible Agency under CEQA. (Pub.

Resources Code, § 21069; CEQA Guidelines, § 15381.) CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code. As proposed, for example, the Project may be subject to CDFW’s lake and streambed alteration regulatory authority. (Fish & G. Code, § 1600 et seq.) Likewise, to the extent implementation of the Project as proposed may result in “take” as defined by State law of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.), the Project proponent may seek related take authorization as provided by the Fish and Game Code.

PROJECT DESCRIPTION SUMMARY
Proponent: S2 Builders
Objective: The Project proposes to amend the General Plan land use designation for the Project site from General Commercial (GC) to Residential High Density (RH) and change the zone district from Planned Community Commercial (PCC) to Multiple-Family Residential (R3) to permit construction of a 204-unit apartment complex on a 10.48 acre lot.

Timeframe: Project construction is proposed to begin in 2025.

COMMENTS AND RECOMMENDATIONS
CDFW has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species (i.e., biological resources). CDFW offers the comments and recommendations below to assist the City in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources. The MND has not adequately identified and disclosed the Project’s impacts (i.e., direct, indirect, and cumulative) on biological resources and whether those impacts are reduced to less than significant.

Cynthia Schultz, Associate Planner
City of Cathedral City
November 4, 2024

Page 3 ends

biological resources. CDFW requests that additional information and analyses be added to a revised MND, along with avoidance, minimization, and mitigation measures that avoid or reduce impacts to less than significant.

Existing Environmental Setting

Compliance with CEQA is predicated on a complete and accurate description of the environmental setting that may be affected by the proposed Project. CDFW is concerned that the assessment of the existing environmental setting has not been adequately analyzed in the MND. CDFW is concerned that without a complete and accurate description of the existing environmental setting, the MND may provide an incomplete analysis of Project-related environmental impacts.

The MND lacks a complete assessment of biological resources within the Project site and surrounding area specifically as it relates to an assessment of biological resources specifically for western burrowing owl (Athene cunicularia hypugaea; burrowing owl). A complete and accurate assessment of the environmental setting and Project-related impacts to burrowing owl is needed to both identify appropriate avoidance, minimization, and mitigation measures and demonstrate that these measures reduce Project impacts to less than significant.

Mitigation Measures

CEQA requires that a MND include mitigation measures to avoid or reduce significant impacts. CDFW is concerned that the mitigation measures proposed in the MND are not adequate to avoid or reduce impacts to biological resources to below a level of significance. To support the City in ensuring that Project impacts to biological resources are reduced to less than significant, CDFW recommends adding mitigation measures for burrowing owl and artificial nighttime lighting, as well as revising the mitigation measure for nesting birds.
1) Nesting Birds
It is the Project proponent’s responsibility to comply with all applicable laws related to nesting birds and birds of prey. Fish and Game Code sections 3503, 3503.5, and 3513 afford protective measures as follows: section 3503 states that it is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by Fish and Game Code or any regulation made pursuant thereto. Fish and Game Code section 3503.5 makes it unlawful to take, possess, or destroy any birds in the orders Falconiformes or Strigiformes (birds-of-prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by Fish and Game Code or any regulation adopted pursuant thereto. Fish and Game Code section 3513 makes it unlawful to take or possess any migratory nongame bird except as provided by rules

Cynthia Schultz, Associate Planner
City of Cathedral City
November 4, 2024

Page 4 ends

and regulations adopted by the Secretary of the Interior under provisions of the Migratory Bird Treaty Act of 1918, as amended (16 U.S.C. § 703 et seq.).

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the potential to provide nesting opportunities for birds.” Based on review of historical aerial and street view imagery using Google Earth, the Project site contains a sparce cover of shrubs, habitat suitable for birds that nest in shrubs and on the ground. CDFW is concerned about impacts to nesting birds including loss of nesting/foraging habitat and potential take from ground-disturbing activities and construction. Although the MND includes a Mitigation Measure BIO-1 for nesting birds, CDFW finds the measure to be insufficient in scope and timing to reduce impacts to nesting birds to a level less than significant. Mitigation Measure BIO-1 indicates that the “nesting bird nesting season generally extends from February 1 through September 15 in southern California and specifically, March 15 through August 31 for migratory passerine birds. To avoid impacts to nesting birds (common and special status) during the nesting season, a qualified Avian Biologist will conduct pre-construction Nesting Bird Surveys (NBS) no more than 3-days prior to Project related disturbance to nestable vegetation to identify any active nests.” Conducting work outside the peak nesting season is an important avoidance and minimization measure. CDFW also recommends the completion of nesting bird surveys regardless of the time of year to ensure that impacts to nesting birds are avoided. The timing of the nesting season varies greatly depending on several factors, such as bird species, weather conditions in any given year, and long-term climate changes (e.g., drought, warming, etc.). In response to warming, birds have been reported to breed earlier, thereby reducing temperatures that nests are exposed to during breeding and tracking shifts in availability of resources (Socolar et al., 20172).

CDFW staff have observed that climate change conditions may result in nesting bird season occurring earlier and later in the year than historical nesting season dates.

CDFW recommends that disturbance of occupied nests of migratory birds and raptors within the Project site and surrounding area be avoided any time birds are nesting on- site. CDFW therefore recommends the completion of nesting bird surveys regardless of

2 Socolar JB, Epanchin PN, Beissinger SR and Tingley MW (2017). Phenological shifts conserve thermal niches. Proceedings of the National Academy of Sciences 114(49): 12976-12981.

Cynthia Schultz, Associate Planner
City of Cathedral City
November 4, 2024

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the time of year to ensure compliance with all applicable laws pertaining to nesting and migratory birds.

To support the City in reducing impacts to nesting birds to a level less than significant, CDFW recommends that the City revise Mitigation Measure BIO-1 with the following additions in bold and removals in strikethrough:

Mitigation Measure BIO-1: Nesting Birds
To the greatest extent feasible, Project construction activities will avoid the peak nesting season (February 1 through September 15). Regardless of the time of year, nesting bird surveys shall be performed by a qualified avian biologist no more than 3 days prior to vegetation removal or ground-disturbing activities. Pre- construction surveys shall focus on both direct and indirect evidence of nesting, including nest locations and nesting behavior. The qualified avian biologist will make every effort to avoid potential nest predation as a result of survey and monitoring efforts. If active nests are found during the pre-construction nesting bird surveys, a qualified biologist shall establish an appropriate nest buffer to be marked on the ground. Nest buffers are species specific and shall be at least 300 feet for passerines and 500 feet for raptors. A smaller or larger buffer may be determined by the qualified biologist familiar with the nesting phenology of the nesting species and based on nest and buffer monitoring results. Construction activities may not occur inside the established buffers, which shall remain on-site until a qualified biologist determines the young have fledged or the nest is no longer active. Active nests and adequacy of the established buffer distance shall be monitored daily by the qualified biologist until the qualified biologist has determined the young have fledged or the Project has been completed. The qualified biologist has the authority to stop work if nesting pairs exhibit signs of disturbance. Nesting bird nesting season generally extends from February 1 through September 15 in southern California and specifically, March 15 through August 31 for migratory passerine birds. To avoid impacts to nesting birds (common and special status) during the nesting season, a qualified Avian Biologist will conduct pre- construction Nesting Bird Surveys (NBS) no more than 3-days prior to Project related disturbance to nestable vegetation to identify any active nests. If no active nests are found, no further action will be required. If an active nest is found, the biologist will set appropriate no-work buffers around the nest which will be based upon the nesting species, its sensitivity to disturbance, nesting stage, and expected types, intensity, and duration of the disturbance. The nests and buffer zones shall be field-checked weekly by a qualified biological monitor. The approved no-work buffer zone shall be clearly marked in the field, within which no disturbance activity shall commence until the qualified biologist has determined the young birds have successfully fledged and the nest is inactive.

Cynthia Schultz, Associate Planner
City of Cathedral City
November 4, 2024

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Pursuant to the CEQA Guidelines, section 15097(f), CDFW has prepared a draft mitigation monitoring and reporting program (MMRP) in Attachment 1 for revised Mitigation Measure BIO-1, as well as CDFW-recommended Biological Resources Mitigation Measures BIO-[A] and BIO-[B].
2) Burrowing Owl
On October 10, 2024, the Fish and Game Commission determined that western burrowing owl warrants protection as a candidate species under the California Endangered Species Act (Fish & G. Code, § 2050 et seq.). During the candidacy period, western burrowing owl will be afforded the same protection as threatened and endangered species under CESA. .

Take of individual burrowing owls and their nests is defined by Fish and Game Code section 86, and prohibited by sections 3503, 3503.5, and 3513. Take is defined in Fish and Game Code section 86 as “hunt, pursue, catch, capture or kill, or attempt to hunt, pursue, catch, capture or kill.” Fish and Game Code sections 3503, 3503.5, and 3513 afford protective measures as follows: It is unlawful to take, possess, or destroy any birds in the order Strigiformes, including western burrowing owls, except as otherwise provided in the Fish and Game Code and related regulations. (Fish & G. Code, § 3503.5.) It is also unlawful to take, possess, or destroy western burrowing owl nests or eggs, except as otherwise provided in the Fish and Game Code and related regulations. (Fish & G. Code, §§ 3503, 3503.5.) State law also explicitly incorporates the prohibitions on take and possession set forth in the federal Migratory Bird Treaty Act. (Fish & G.

Code, § 3513.)

With regard to the CVMSHCP, the CDFW Natural Community Conservation Plan (NCCP) Permit #2835-2008-001-06 does not provide Take Authorization for burrowing owl individuals, nests, or eggs. To the contrary, section 3.5.6 of the NCCP Permit states burrowing owl “pairs or individuals will not be Taken” and reiterates that the “HCP/NCCP does not authorize Take of [burrowing owl] nests [or] eggs[.]” Therefore, throughout the CVMSHCP area—both within and without Conservation Areas— Permittees must ensure that activities occurring within their jurisdictions do not result in the take, possession, or destruction of burrowing owl individuals, nests, or eggs. Any activity occurring within the CVMSHCP area that results in the take of burrowing owl individuals, nests, or eggs would be unlawful and would not be a Covered Activity under the CVMSHCP.

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does not contain suitable habitat for this species. No burrowing owls were observed during the site visit. No burrows of any kind were located within the Project Site. No portion of the Project Site showed any evidence of past or present BUOW activity. No feathers, whitewash, or castings were found and no suitable burrow surrogate species are present onsite. Therefore, no suitable habitat exists on-site and no focused surveys

Cynthia Schultz, Associate Planner
City of Cathedral City
November 4, 2024

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are required.” Page 4 of the Project’s Biological Resources Assessment (Biological Assessment) states that a “general reconnaissance survey [was competed] within the Project site to identify the potential for the occurrence of special status species, vegetation communities, or habitats that could support special status wildlife species.

The surveys were conducted on foot, throughout the Project site between 0800 and 0900 hours on August 9, 2023.” The MND and the Biological Assessment do not indicate if a habitat assessment or focused surveys for burrowing owl, conducted independently of surveys for other species, were completed. The Biological Assessment also does not indicate if a habitat assessment and/or surveys were conducted in open- space areas to the north, west, or south of the Project area. Given the MND’s lack of findings from a recent habitat assessment and focused surveys for burrowing owl following the guidelines in the Staff Report on Burrowing Owl Mitigation,3 the number of suitable and occupied burrows within the Project site and surrounding areas is unknown.

CDFW is also concerned with the MND’s conclusion that the Project site does not contain suitable habitat for burrowing owl. The Project’s Biological Assessment indicates that the “habitat on-site consists of sparse vegetation and bare ground.” CDFW notes that in California, preferred habitat for burrowing owl is generally typified by short, sparse vegetation with few shrubs,4 and that burrowing owls may occur in ruderal grassy fields, vacant lots, and pastures if the vegetation structure is suitable and there are useable burrows and foraging habitat proximity.5 Based on review of historical aerial imagery and street imagery using Google Earth and photos included in the Biological Assessment, the Project site and surrounding areas to the west, north, and south contain habitat with sparse cover of native vegetation that is suitable nesting and foraging habitat for burrowing owl. CDFW considers the Project site to contain suitable habitat for burrowing owl; however, the status of burrowing owl presence within and surrounding the Project site is unknown. In addition, burrowing owls frequently move into disturbed areas prior to and during construction activities since they are adapted to highly modified habitats.6,7

3 California Department of Fish and Game (CDFG). 2012. Staff report on burrowi ng owl mitigation. State of California, Natural Resources Agency. Available for download at:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83843&inline 4 Haug, E. A., B. A. Millsap, and M. S. Martell. 1993. Burrowing owl (Speotyto cunicularia), in A. Poole and F. Gill, editors, The Birds of North America, The Academy of Natural Sciences, Philadelphia, Pennsylvania, and The American Ornithologists’ Union, Washington, D.C., USA. 5 Gervais, J. A., D. K. Rosenberg, R. G. Anthony. 2003. Space use and pesticide exposure risk of male burrowing owls in an agricultural landscape. Journal of Wildlife Management 67: 155 -164. 6 Chipman, E. D., N. E. McIntyre, R. E. Strauss, M. C. Wallace, J. D. Ray, and C. W. Boal. 2008. Effects of human land use on western burrowing owl foraging and activity budgets. Journal of Raptor Research 42(2): 87-98.
7 Coulombe, H. N. 1971. Behavior and population ecology of the Burrowing Owl, Speotyto cunicularia, in the Imperial Valley of California. Condor 73:162–176.

Cynthia Schultz, Associate Planner
City of Cathedral City
November 4, 2024

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CDFW recommends the MND is revised to include the findings, including survey methods and survey reports, from recent focused burrowing owl surveys following the guidelines in the Staff Report on Burrowing Owl Mitigation along with appropriate avoidance, minimization, and mitigation measures.

To support the City in reducing impacts to burrowing owl to a level less than significant, CDFW recommends the City add the following mitigation measure to a revised MND:

Mitigation Measure BIO-[A]: Burrowing Owl Surveys

Suitable burrowing owl habitat has been confirmed on the site; therefore, focused burrowing owl surveys shall be conducted by a qualified biologist according to the Staff Report on Burrowing Owl Mitigation (CDFG, 2012 or most recent version) prior to vegetation removal or ground-disturbing activities. If burrowing owls are detected during the focused surveys, the qualified biologist and Project proponent shall begin coordination with CDFW and USFWS immediately, and shall prepare a Burrowing Owl Plan that shall be submitted to CDFW for review and approval prior to commencing Project activities. The Burrowing Owl Plan shall describe proposed avoidance, minimization, mitigation, and monitoring actions. The Burrowing Owl Plan shall include the number and location of occupied burrow sites (occupied site means at least one burrowing owl has been observed within the last three years; may also be indicated by owl sign including feathers, pellets, prey remains, eggshell fragments, or excrement at or near a burrow entrance or perch site), acres of burrowing owl habitat that will be impacted, details of site monitoring, and details on proposed buffers and other avoidance measures. If impacts to occupied burrowing owl habitat or burrow cannot be avoided, the Burrowing Owl Plan shall also describe minimization and relocation actions that will be implemented. Proposed implementation of burrow exclusion and closure should only be considered as a last resort, after all other options have been evaluated as exclusion is not in itself an avoidance, minimization, or mitigation method and has the possibility to result in take. If impacts to occupied burrows cannot be avoided, information shall be provided regarding adjacent or nearby suitable habitat available to owls along with proposed relocation actions. The Project proponent shall implement the Burrowing Owl Plan following CDFW and USFWS review and approval. If Project activities, including burrow exclusion and closure, could result in take of burrowing owl, appropriate CESA authorization should be obtained prior to commencement of Project activities.

Cynthia Schultz, Associate Planner
City of Cathedral City
November 4, 2024

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Preconstruction burrowing owl surveys shall be conducted no less than 14 days prior to the start of Project-related activities and within 24 hours prior to ground disturbance, in accordance with the Staff Report on Burrowing Owl Mitigation (CDFG, 2012 or most recent version). Preconstruction surveys should be performed by a qualified biologist following the recommendations and guidelines provided in the Staff Report on Burrowing Owl Mitigation. If the preconstruction surveys confirm occupied burrowing owl habitat, Project activities shall be immediately halted. The qualified biologist shall coordinate with CDFW and prepare a Burrowing Owl Plan that shall be submitted to CDFW and USFWS for review and approval prior to commencing Project activities.

3) Artificial Nighttime Lighting

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include landscape lighting, pole lighting at 18 feet in height, and wall lighting for the apartment buildings”, and that lighting will be “shielded downward consistent with City requirements to protect adjacent property from light, particularly to the east where single family homes occur.” The Project is located adjacent to the open-space areas to the north, west, and south—areas that provide suitable nesting, roosting, foraging, and refugia habitat for birds, migratory birds that fly at night, bats, and other nocturnal and crepuscular wildlife. The Project’s proposed artificial nighttime lighting has the potential to significantly and adversely affect wildlife in the open-space areas adjacent to the Project site. Artificial lighting alters ecological processes including, but not limited to, the temporal niches of species; the repair and recovery of physiological function; the measurement of time through interference with the detection of circadian and lunar and seasonal cycles; the detection of resources and natural enemies; and navigation.8 Many species use photoperiod cues for communication (e.g., bird song9), determining when to begin foraging,10 behavioral thermoregulation,11 and migration.12 Phototaxis, a phenomenon that results in attraction and movement towards light, can disorient, entrap, and temporarily blind wildlife species that experience it.15

8 Gatson, K. J., Bennie, J., Davies, T., Hopkins, J. 2013. The ecological impacts of nighttime light pollution: a mechanistic appraisal. Biological Reviews, 88.4: 912-927. 9 Miller, M. W. 2006. Apparent effects of light pollution on singing behavior of American robins. The Condor 108:130–139.
10 Stone, E. L., G. Jones, and S. Harris. 2009. Street lighting disturbs commuting bats. Current Biology 19:1123–1127.
11 Beiswenger, R. E. 1977. Diet patterns of aggregative behavior in tadpoles of Bufo americanus, in relation to light and temperature. Ecology 58:98–108.
12 Longcore, T., and C. Rich. 2004. Ecological light pollution - Review. Frontiers in Ecology and the Environment 2:191–198.

Cynthia Schultz, Associate Planner
City of Cathedral City
November 4, 2024

Page 10 ends

While plans for shielding artificial nighttime lighting support the Project in limiting lighting impacts to biological resources within areas surrounding the Project site, CDFW considers these minimization plans insufficient in scope and timing to reduce impacts to a level less than significant. To support the City in avoiding or reducing impacts of artificial nighttime lighting on biological resources to less than significant, CDFW recommends the City add the following mitigation measure to a revised MND:

Mitigation Measure BIO-[B]: Artificial Nighttime Lighting

The City of Cathedral City and Project proponent shall ensure that all lighting for the Project is fully shielded, cast downward and directed away from surrounding open-space and agricultural areas, reduced in intensity to the greatest extent possible, and does not result in lighting trespass including glare into surrounding areas or upward into the night sky (see the International Dark-Sky Association standards at http://darksky.org/). The City of Cathedral City and Project proponent shall ensure use of LED lighting with a correlated color temperature of 3,000 Kelvins or less, proper disposal of hazardous waste, and recycling of lighting that contains toxic compounds with a qualified recycler.

4) Landscaping

Page 99 ends

xeriscaping with locally native California species and installing water-efficient and targeted irrigation systems (such as drip irrigation).” In contrast, page 9 of the MND indicates that landscaping trees and shrubs will mostly comprise non-native species, including “Shoestring Acacia, Hybrid Fan Palm and Mediterranean Fan Palm that blend with the proposed architecture (Exhibit 5 – Landscape Plan). Shrubs including but not limited to Barbados Aloe, Rio Bravo Langman’s Sage, Sierra Bouquet Barometerbush, La Jolla Bougainvillea, Spreading Sunshine Lantana, Yellow Bells, Iceberg Rose, and Prostrate Natal Plum are proposed.” CDFW recommends that the MND include recommendations regarding landscaping from Section 4.0 of the CVMSHCP “Table 4- 112: Coachella Valley Native Plants Recommended for Landscaping” (pp. 4-180 to 4- 182; https://cvmshcp.org/plan-documents/). CDFW also recommends incorporation of water-wise concepts in any Project landscape design plans. In particular, CDFW recommends xeriscaping with locally native California species and installing water- efficient and targeted irrigation systems (such as drip irrigation). Native plants support butterflies, birds, reptiles, amphibians, small mammals, bees, and other pollinators that evolved with those plants. More information on native plants suitable for the Project location and nearby nurseries is available at Calscape: https://calscape.org/. Local

Cynthia Schultz, Associate Planner
City of Cathedral City
November 4, 2024

Page 11 ends

water agencies/cities and resource conservation cities in your area may be able to provide information on plant nurseries that carry locally native species, and some facilities display drought-tolerant locally native species demonstration gardens.

Information on drought-tolerant landscaping and water-efficient irrigation systems is available on California’s Save our Water website: https://saveourwater.com/.

ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e).) Accordingly, please report any special-status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB). The CNNDB field survey form can be filled out and submitted online at the following link: https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported to CNDDB can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.

CONCLUSION
CDFW appreciates the opportunity to comment on the MND to assist the City in identifying and mitigating Project impacts to biological resources. CDFW concludes that the MND does not adequately identify or mitigate the Project’s significant, or potentially significant, impacts to biological resources. CDFW also recommends that revised and additional mitigation measures and analysis as described in this letter be added to a revised MND.

Cynthia Schultz, Associate Planner
City of Cathedral City
November 4, 2024

Page 12 ends

Sincerely,

Kim Freeburn
Environmental Program Manager

Attachment 1: MMRP for CDFW-Proposed Mitigation Measures

ec:

Heather Brashear, Senior Environmental Scientist (Supervisor), CDFW [email protected]

Office of Planning and Research, State Clearinghouse, Sacramento [email protected]

ATTACHMENT 1: MITIGATION MONITORING AND REPORTING PROGRAM (MMRP) Mitigation Measures Timing and
Methods
Responsible
Parties
Mitigation Measure BIO-1: Nesting Birds
To the greatest extent feasible, Project construction
activities will avoid the peak nesting season
(February 1 through September 15). Regardless of
the time of year, nesting bird surveys shall be
performed by a qualified avian biologist no more than
3 days prior to vegetation removal or ground-
disturbing activities. Pre-construction surveys shall
focus on both direct and indirect evidence of nesting,
including nest locations and nesting behavior. The
qualified avian biologist will make every effort to
avoid potential nest predation as a result of survey
and monitoring efforts. If active nests are found
during the pre-construction nesting bird surveys, a
qualified biologist shall establish an appropriate nest buffer to be marked on the ground. Nest buffers are
species specific and shall be at least 300 feet for
passerines and 500 feet for raptors. A smaller or
larger buffer may be determined by the qualified
biologist familiar with the nesting phenology of the
nesting species and based on nest and buffer
monitoring results. Construction activities may not
Timing: No more
than 3 days prior
to vegetation
removal or
ground-disturbing
activities.

Methods: See
Mitigation
Measure

Implementation:

City of Cathedral City
and Project
proponent

Monitoring and
Reporting: City of
Cathedral City

Cynthia Schultz, Associate Planner
City of Cathedral City
November 4, 2024

Page 13 ends

occur inside the established buffers, which shall
remain on-site until a qualified biologist determines
the young have fledged or the nest is no longer
active. Active nests and adequacy of the established
buffer distance shall be monitored daily by the
qualified biologist until the qualified biologist has
determined the young have fledged or the Project has
been completed. The qualified biologist has the
authority to stop work if nesting pairs exhibit signs of disturbance.

Mitigation Measure BIO-[A]: Burrowing Owl Surveys

The Burrowing Owl Plan shall describe proposed
avoidance, minimization, mitigation, and monitoring
actions. The Burrowing Owl Plan shall include the
number and location of occupied burrow sites
(occupied site means at least one burrowing owl has
been observed within the last three years; may also
be indicated by owl sign including feathers, pellets,
prey remains, eggshell fragments, or excrement at or
near a burrow entrance or perch site), acres of
burrowing owl habitat that will be impacted, details of site monitoring, and details on proposed buffers and
other avoidance measures. If impacts to occupied
burrowing owl habitat or burrow cannot be avoided,
the Burrowing Owl Plan shall also describe
minimization and relocation actions that will be
implemented. Proposed implementation of burrow
exclusion and closure should only be considered as
a last resort, after all other options have been
evaluated as exclusion is not in itself an avoidance,
minimization, or mitigation method and has the
possibility to result in take. If impacts to occupied
burrows cannot be avoided, information shall be
provided regarding adjacent or nearby suitable
habitat available to owls along with proposed
relocation actions. The Project proponent shall
implement the Burrowing Owl Plan following CDFW
Timing: Focused
surveys: Prior to
vegetation
removal or
ground-disturbing
activities. Pre-
construction
surveys: No less
than 14 days prior
to start of Project-
related activities
and within 24
hours prior to
ground
disturbance.

Methods: See
Mitigation
Measure

Implementation:

City of Cathedral City
and Project
proponent

Monitoring and
Reporting: City of
Cathedral City

Cynthia Schultz, Associate Planner
City of Cathedral City
November 4, 2024

Page 14 ends

and USFWS review and approval. If Project activities,
including burrow exclusion and closure, could result
in take of burrowing owl, appropriate CESA
authorization should be obtained prior to
commencement of Project activities.

Preconstruction burrowing owl surveys shall be
conducted no less than 14 days prior to the start of
Project-related activities and within 24 hours prior to ground disturbance, in accordance with the Staff
Report on Burrowing Owl Mitigation (CDFG, 2012 or
most recent version). Preconstruction surveys
should be performed by a qualified biologist
following the recommendations and guidelines
provided in the Staff Report on Burrowing Owl
Mitigation. If the preconstruction surveys confirm
occupied burrowing owl habitat, Project activities
shall be immediately halted. The qualified biologist
shall coordinate with CDFW and prepare a Burrowing
Owl Plan that shall be submitted to CDFW and
USFWS for review and approval prior to commencing
Project activities.

Mitigation Measure BIO-[B]: Artificial Nighttime
Lighting

The City of Cathedral City and Project proponent
shall ensure that all lighting for the Project is fully shielded, cast downward and directed away from
surrounding open-space and agricultural areas,
reduced in intensity to the greatest extent possible,
and does not result in lighting trespass including
glare into surrounding areas or upward into the night
sky (see the International Dark-Sky Association
standards at http://darksky.org/). The City of
Cathedral City and Project proponent shall ensure
use of LED lighting with a correlated color
temperature of 3,000 Kelvins or less, proper disposal
of hazardous waste, and recycling of lighting that
contains toxic compounds with a qualified recycler.

Timing:

Throughout
construction and
the lifetime
operations of the
Project.

Methods: See
Mitigation
Measure

Implementation:

City of Cathedral City
and Project
proponent

Monitoring and
Reporting: City of
Cathedral City

Victor F. Flores
Transportation Planner
Local Development Review
D-8 Division of Transportation Planning
Work cell: (909) 925-7520
Email: [email protected]

From: Flores, Victor F@DOT on behalf of LDR D8@DOT
To: Cynthia Schultz
Cc: Patel, Janki@DOT
Subject: The Wren Residential Project - SCH: 2024100551 - Cathedral City Date: Thursday, November 14, 2024 10:22:23 AM
Attachments: image001.png
You don't often get email from [email protected]. Learn why this is important Hi Cynthia,

1. The Traffic Impact Analysis (TIA) should include the study area intersections at Date Palm Drive and the I-10 Eastbound (EB) ramps, as well as Date Palm Drive and the I-10 Westbound (WB) ramps.

3. The Caltrans Division of Transportation Planning shall review and provide concurrence with the appropriate ITE trip generation for the land use and size of proposed project.

Please feel free to reach out should you have any questions.

Thank you,

Page 1 of 2 ends

Response to Comments

To: Cynthia Schultz, AICP
Associate Planner, City of Cathedral City

From: Nicholas Lowe, PE, TE
Deputy Director, Albert A. Webb Associates
Consultant Traffic Engineer

Date: November 14, 2024

Re: The Wren Residential Project Traffic Study – Ca ltrans Comments, November 14, 2024

Albert A. Webb Associates (WEBB) provides consultan t traffic engineering services to the City of Cathedral City (City) which includes the review of development traffic studies. WEBB is in receipt of Caltrans comments for the Wren Residential developm ent (Project) traffic study, previously approved by the City, and has the following responses in blue .

1. The Traffic Impact Analysis (TIA) should include the study area intersections at Date Palm Drive and the I-10 Eastbound (EB) ramps, as well as Date Palm Drive and the I-10 Westbound (WB) ramps.

The City follows the County of Riverside (County) Transportation Analysis Guidelines dated December 2020. Intersections to be included in traffic studies are ones that are forecast to handle 50 or more peak hour trips from the development project not exceeding a 5-mile radius from the development project site. Per the Project traffic study, the Project is expected to generate 81 AM peak hour trips and 104 PM peak hour trips. In addition, the Project traffic study forecasts a project trip distribution of 35% of project trips traveling north on Date Palm Drive towards, but not necessarily to, the I-10/Date Palm Drive interchange.

Therefore, only 36 trips are forecasted to be traveling on Date Palm Drive north of 30 th Avenue and no additional intersections north of 30 th Avenue are to be included in the traffic study. Project trip generation table and trip distribution from the traffic study are below.

Page 2 of 2 ends

2. Once the I-10 study areas are included in the TI A, the Caltrans Traffic Forecasting and Analysis Division requests to review the Traffic Impact Analysis Report (TIA) and provide concurrence with the Average Annual Daily Traffic (AADT) and the forecasted traffic volumes.

See response for comment #1 above regarding I-10/Date Palm Drive interchange and not being included in the Project traffic study. Also see comment #1 above for Project trip generation table from the traffic study that includes peak hour and daily trip generation.

3. The Caltrans Division of Transportation Planning shall review and provide concurrence with the appropriate ITE trip generation for the land use and size of proposed project.

Please see comment #1 above for Project trip generation table from the traffic study that includes peak hour and daily trip generation per the ITE Trip Generation Manual, 11 th Edition.

Cathedral City City CouncilJanuary 8, 2025

Cathedral City City Council
January 8, 2025