Cloverdale City Council
April 26, 2023

1.2 GENERAL PLAN EIR
The General Plan EIR found that with the implementation of policies and programs from the General Plan, the following environmental topic areas would be potentially significant: land use, agriculture, population and housing, hazards and human health, transportation and circulation, air quality, noise, geology and soils, hydrology and water quality, biological resources, cultural and paleontological resources, public services and utilities, visual resources and green house gas and climate change. The General Plan EIR addressed potentially significant impacts by incorporating policies that address and mitigate related environmental impacts. The mitigation measures from the General Plan EIR reduced potentially significant impacts to a less than significant level for the following environmental topic areas:
• Land Use
o Impact: Impacts to future area plan documents within or adjacent the city o Impact: Existing and future land uses within or adjacent to the city o Impact: Demand of open space and parks
• Agriculture
o Impact: Loss of Farmland due to conversion to urban uses o Impact: Urban land uses adjacent to agricultural uses o Impact: Conflict with Williamson Act contracts
o Impact: Conversion of Important Farmland
• Population and Housing
o Impact: Increased population, housing and employment
o Impact: Displacement of Housing
o Impact: Jobs-housing imbalance
o Impact: Substantial population, housing unit and employment increase • Hazards/Human Health
o Impact: Increased exposure
o Impact: Impair emergency response
o Impact: Increased wildland fire risk
• Transportation/Circulation
o Impact: Effects of intersections, interchange and circulation movements • Air Quality
o Impact: Construction-generated pollutants
o Impact: Effects of motor vehicle emissions
o Impact: Effects of stationary emissions
• Noise
o Impact: Increased construction, stationery and traffic noise o Impact: Existing receptors
o Impact: Aircraft noise
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• Geology/Soils
o Impact: Exposure to seismic ground shaking and ground failure o Impact: Soil erosion and expansive soils
• Hydrology/Water Quality
o Impact: Impacts to groundwater
o Impact: Increased stormwater runoff and flooding
o Impact: Increased water demand/groundwater production • Biological Resources
o Impact: Loss of plant and wildlife species
o Impact: Impacts to riparian habitat, wetlands and jurisdictional waters o Impact: Restrict wildlife travel corridors
• Cultural/Paleontological Resources
o Impact: Impacts to paleontological resources and fossil formations o Impact: Impacts to historic and prehistoric resources • Public Services/Utilities
o Impact: Increased demand for fire, law enforcement and emergency services o Impact: Impacts to school enrollment and school construction o Impact: Impacts to waste disposal facilities, park and recreation facilities • Visual Resources/Aesthetics
o Impact: Alteration to scenic resources
o Impact: Overall change in visual character
o Impact: Increased daytime and nighttime glare
• Green House Gas/Climate Change
o Impact: Increased greenhouse gas emissions
o Impact: Impacts to water supply, air pollutants and increased health hazards

1.3 PROJECT SUMMARY
Cloverdale has a variety of programs which have been implemented in the previous Housing Element, some of which were successful. An evaluation of the City’s progress towards achieving the goals in these programs, including an analysis of what was projected and what was achieved, provides useful data for determining any new or revised policies and programs for this current Housing Element.

In the 2015-2023 Housing Element cycle, the City planned for increasing density of local housing supply, especially affordable housing, in the central core as well as maintenance and improvement of the existing housing stock. Implementation programs included:
• Continuing to facilitate the Sonoma County Housing Rehabilitation Program, Capital Improvement Program, and other City funds to maintain existing housing through rehabilitation loans, preservation projects and affordable housing partnerships; 220
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• Preserving the affordability of existing homes that were at risk of conversion to market-rate during the planning period through partnerships with Wallace House and Housing Land Trust of Sonoma County;
• Providing adequate sites at a range of densities to accommodate future housing needs through monitoring of residential land availability, provide discretionary review and flexibility for infill development, and review of development impact fees; • Remove governmental constraints that assist in the development of adequate housing to meet the needs of extremely low, very low, and moderate-income households and special needs households by continuing to update the inclusionary housing program requirements, eliminating impact fees to promote ADUs, disseminating public and private funding, and streamlining of permit requirements; • Promoting energy efficiency and natural resources conservation through the adoption of the California Green Building Standards Code and encouraging housing adjacent to public transit facilities;
• Promoting housing opportunities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability through education, appropriate handling of complaints, and providing nondiscriminatory clauses in rental agreements and deed restrictions.

Table 1-1 provides an evaluation of the programs from the 5th Cycle Housing Element, the City’s level of success in achieving them and any lessons learned for implementation in the 6th Cycle Housing Element. A brief summary of the policy changes and additions identified in the City’s Housing Strategy for the 2023-2031 Housing Element planning period are listed following this table.
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
IP-1.1.1
Rehabilitation/Preservation
Program: Continue to partner
with the Sonoma County
Housing Rehabilitation
Program to provide lowinterest rehabilitation loans for homes and mobile homes
owned or occupied by lower
and moderate-income
households.

Ongoing Successful. The City
provides copies of
pamphlets about the
County Housing Rehab
Program at City Hall and
has posted copies on the
City Website. In 2020, the
City continued
rehabilitation of 2 units.

The City will
continue to
participate in the
programs and will
increase promotion.

IP-1.1.2
Capital Improvement Program:

Review and recommend
projects in the City's Capital
Improvement Program (CIP)
that will maintain and improve
the City's older residential
neighborhoods as well as
projects that will facilitate
opportunities for infill and
transit-oriented housing.

Annually Successful. A draft CIP plan
published in September
2021 outlines proposed
improvements to sewer,
water, drainage, and streets
that support opportunities
for in-fill development.

The City will
continue to review
and recommend
projects for the CIP.

IP-1.2.1 Mobile Home Park
Maintenance: Specifically
advertise the availability of
home rehabilitation loans to
mobile homeowners through
the program described in IP1.1.1. Encourage residents
utilizing program funds to
include an Earthquake
Reinforced Bracing System
(ERBS) to help stabilize the
dwelling during an earthquake
in the rehabilitation work.

Ongoing Partially Successful. The
City continues to partner
with the Sonoma County
Housing Rehabilitation
Program to help provide
low-interest rehabilitation
loan assistance to mobile
homeowners or those
occupied by lower and
moderate-income
households. However,
EBRS funds were not
utilized in the 5th Cycle.

The City will
continue to
participate in the
program and will
provide greater
promotion to
mobile home park
residents (IP-1.2.1)
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
IP-1.3.1 Preservation of
affordable housing: Monitor
the existing stock of affordable
units and work proactively to
retain these units. As
appropriate, partner with
nonprofit housing
organizations, including
developers and community
land trusts, to preserve and
rehabilitate affordable units.

Require permanent or a
minimum 55-year affordability
for units that receive City
funding.

Ongoing Successful. The City
continues to partner with
the Wallace House and
Housing Land Trust of
Sonoma County to preserve
housing in Cloverdale. In
2020 the City-owned
Cherry Creek property
continued design plans to
increase number of units
from 10 to 24 while
rehabilitating some existing
units. All 24 units are leased
at 60% AMI or less.

Modified and
continued to meet
statutory
requirements (IP1.3.1)
IP-1.3.2 Funding: To the
maximum extent possible,
leverage City funds 10:1 in
preservation projects ($1 in City
spending provides $10 in total
housing benefit).

Ongoing Successful. Non-profits
successfully leveraged local
funding sources 10 to 1,
providing significant
financial benefit to
affordable housing
projects.

City will continue to
provide direct
funding subsidies as
funds allow.

Agreement
underway with
County to allow
CFH funds to be
used for projects
within City Limits in
exchange for City’s
acceptance of the
6th Cycle transfer of
150 units from
County.
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
IP-2.1.1 Monitoring: The City
will monitor the supply of
residential land to ensure
sufficient developable land is
available for single-family and
multifamily residential
development. If, at any time,
the supply of sites zoned for
multifamily housing falls below
the quantity of land required to
accommodate the City’s
remaining need for higher
density multifamily housing, the
City will initiate General Plan
Amendments and/or rezonings
to provide additional land.

Ongoing Successful. An updated
Vacant Land Inventory was
completed at the end of
2014 and the City continues
to reference the list when
proposals for Zoning
and/or General Plan
changes come forward.

This successful
monitoring program
will be continued
and expanded to
address new No Net
Loss requirements
and a regional
electronic inventory
project. (IP-2.1.1)
IP-2.1.2 Infill Development:

Wherever appropriate, the City
will grant flexibility to
encourage development on
infill parcels using the tools
currently provided within the
Zoning Ordinance (PUD
permits, density bonus, and
second residential unit
ordinance). This can be applied
on a case-by-case basis in
tandem with required
discretionary review permits.

Ongoing Successful. The City
continues to utilize tools
such as Planned
Development permits,
density bonuses and
Accessory Dwelling Unit
(ADU) Ordinance to
encourage development on
in-fill parcels. In 2020 the
City issued certificates of
occupancy for 29 infill
development units.

The City will
continue to utilize
these tools to
provide flexibility for
infill development
projects, especially
those making use of
the incentive
provisions under
state density bonus
law (IP-2.1.2).
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
IP-2.1.3 Opportunity Sites:

Pending resolution of the
dissolution of the
Redevelopment Agency, the
City will initiate development
on its Thyme Square and
Cherry Creek sites. The process
would include initiating
requests for proposals and
seeking developer partners to
realize the vision for these
properties as established in
planning efforts and past
development initiatives. In
addition, the City will continue
to pursue grants and other
funding to improve connectivity
to the planned SMART station
site and emphasize residential
development opportunity on
nearby sites.

Ongoing Successful. City retained a
consultant to review and
update existing downtown
zoning districts and parking
requirements to reduce
barriers to housing
development. Findings
were adopted by City
Council in April 2021.

Successful program
will be completed
by 2023 and will not
be carried over into
the 6th Cycle.

IP-2.2.1 Inclusionary Housing
Ordinance: Revise the
Inclusionary Housing
Ordinance to improve clarity
regarding requirements and
program administration and
address recent court decisions
regarding inclusionary zoning.

Examine the appropriateness
and potential impacts of
making fee payment the
primary method of compliance
and establish a regular time
frame for updates to the in-lieu
fee schedule.
2015 Successful. In 2018 the City
adopted updated fees and
income limits related to the
Inclusionary Housing
Ordinance and court
decisions, resulting in the
application to both
ownership and rental
projects. All in-lieu fees
placed in affordable
housing fund per
Ordinance 18.13.080. New
Ordinance requires regular
updates.

Program has been
successfully
completed and will
not be continued.
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
IP-2.3.1 Housing Impacts of
Employment-Generating Uses:

Consider preparing a study to
examine the nexus between the
development of large-scale
office, commercial, and
industrial projects on the need
for affordable housing. Identify
the housing impacts of these
projects and the potential
demand for new housing. If a
nexus is found, consider
adopting an impact fee to
generate funds to be used to
mitigate the impacts and assist
in the development of
affordable housing.
2017 Addressed but not
completed. Although staff
brought forward a
preliminary report on
potential costs and benefits
of adoption of such a
program, ultimately the City
Council chose to not move
forward. City does not want
to impose a potential
impediment to new
commercial development.

Program will not be
carried forward in
6th Cycle.

IP-2.4.1 Second Dwelling Units:

Promote the development of
second units as a source of
lower-cost rental housing and a
potential income source for
homeowners. Provide
informational brochures
regarding second unit
opportunities and
requirements at City Hall and
on the City’s website.
2015 Successful. City issued
building permits for 2 ADUs
in 2020. The ADU brochure
was updated in 2017 and
2020 to reflect the City's
current regulations and
2019 State legislation.

Program was
successfully
completed, but
statute requires that
it be carried forward
and enhanced (IP2.2.1).

IP-2.5.1 Manufactured Housing:

Amend the Zoning Ordinance
to eliminate manufactured
homes as a separate use and
clarify that manufactured
homes on permanent
foundations are subject to the
same level of review and
development standards as
conventional single-family
homes, in compliance with
state law.
2015 Successful. In 2020, the City
updated zoning 15.24.010-
060 to allow manufactured
homes in all residential
zoning districts and
eliminate the discretionary
review process.

Program was
successfully
completed and will
not be carried
forward.
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
IP-2.6.1 Flexible Parking
Options: The City will continue
to allow and encourage shared
parking and allow both on-site
and/or off-site provision of
required spaces. In addition,
the City will review and
consider revising its shared
parking program within the
downtown commercial core to
maximize the potential for
mixed use development.

Review by
2015
Successful. In 2020 the City
hired a consultant using
SB2 planning grant funding
to complete a downtown
study to allow more
housing and parking. Code
changes to allow flexibility
in parking standards in the
downtown core were
adopted in 2021.

Program was
successfully
completed and has
not been carried
forward.

IP-2.6.2 Development Impact
Fees: The City shall review its
current development impact
fee program to confirm the
appropriate level of impact fees
to charge for multifamily
residential units and second
units based on the demand
they create for public facilities
and infrastructure. Where
justified, the City shall consider
reducing fees for multifamily
units, second units, co-housing,
and self-help housing units to
encourage their construction.

The City shall consider
deferring the payment of
development impact fees for
projects that include affordable
housing or reducing fees for
lower-income housing on a
sliding scale related to the level
of affordability. The City shall
also consider adopting a
sliding-scale fee depending on
the size of the unit or “locking”
fees to the time of approval.
2016 Partially Successful. The
City published a
Development Impact Fee
Program for FY 2020-21.

Although the City adopted
updated impact fees for
new ADUs in 2018,
legislation passed in 2019
that took effect in 2020
required the City to
eliminate all impact fees for
ADUs less than 750 SF.

ADUs 750 SF or more can
only be charged a
proportional fee based on
the size of the unit
compared to the main
house. Since that time, state
laws have changed again,
and City will defer
implementation of
remainder of this program
to a 6th Cycle Program that
has been revised to meet
new statutory requirements.

Although the
program was
successful, it has
been modified and
continued to
address the
requirements of
new state laws
including setting
development fees
based on size of the
unit and deferral of
fees for residential
projects (IP-2.3.2).
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
IP-3.1.1 Funding Sources:

Assist housing developers in
identifying opportunities to
finance affordable housing
intended for occupancy by
household with special needs,
particularly extremely lowincome households, seniors,
disabled and developmentally
disabled persons, farmworkers,
and homeless persons.

Annually,
ongoing
Successful. The City was
successful in identifying
funding sources and
working with developers
and bringing several
special needs housing
projects to Cloverdale. In
2020 the City-owned
Cherry Creek property
continued design plans to
increase # of units from 10
to 24 while rehabilitating
some existing units. In 2020
and 2021 the City
approved and annexed the
Baumgardner project w/ 59
units for farmworker
families.

The City will
continue to work
with the Community
Development
Commission (CDC)
and housing
developers to locate
funding
opportunities and
will continue to
provide support in
securing funding
(IP-3.1.1)
IP-3.1.2 Housing Fund:

Maintain the City’s housing
fund, with contributions
collected from private and
public sources, including the
in-lieu inclusionary housing
fees to implement and/or
supplement the City's housing
programs. Use the Housing
Fund to make housing
available to extremely low to
moderate-income Cloverdale
residents.

Ongoing Successful. In 2018 the City
adopted updated fees and
income limits related to the
Inclusionary Housing
Ordinance and court
decisions, resulting in the
application to both
ownership and rental
projects. All in-lieu fees
placed in affordable
housing fund per
Ordinance 18.13.080.

Successful program
will be continued.

Existing in-lieu fees
were utilized for the
Cherry Creek
development, and
the City will evaluate
areas of highest
need for affordable
housing in the 6th
Cycle as funds are
generated by
market-rate
projects.

IP-3.2.1 Senior Housing:

Continue to permit senior
housing developments for
persons aged 55 and over, with
reduced parking and flexibility
in the application of other
requirements.

Ongoing Successful. Vine Ridge
Assisted Living project with
58 beds opened in 2020.

Successful program
will be modified,
continued, and
consolidated (IP3.1.1).
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
IP-3.3.1 Grant Funding:

Continue to work with
developers to apply for HOME
grants or Community
Development Block Grant
(CDBG) funds specifically to
accommodate large families.

Ongoing Partially Successful. The
City continues to
encourage developers to
apply for HOME and CDBG
grants as projects arise.

Cherry Creek Village
applied for CDBG funding
but did not receive it.

Successful program
to be continued and
consolidated. (IP3.1.1)
IP-3.4.1 Sonoma
Developmental Center:

Monitor the potential closing of
the Sonoma Developmental
Center, a large group care
facility for persons with
developmental disabilities, and
coordinate with the North Bay
Regional Center, other local
jurisdictions, and housing and
service providers to provide
support and assistance with the
relocation of former residents,
as needed.
2018 Successful. The State
officially closed the Sonoma
Developmental Center
(SDC) on December 31,
2018. The City continues to
monitor the Specific Plan
efforts that are underway by
agreement between the
State and the County and
continues to advocate for
services to this population.

The SDC has been
closed by the State
and this Program is
no longer
necessary.

IP-3.5.1 Emergency Housing
Demand: Continue to consult
with the Cloverdale Police
Department and homeless
providers in the community to
maintain ongoing estimates of
the demand for emergency
housing in the City.

Ongoing Successful. City adopted
Reso No. 036-2019 per
Homelessness Strategic
Plan Framework (HSPF),
establishing participation in
the annual homeless
counts, collaboration
between Police Dept. and
homelessness community
advisory group, and
coordinated entry system to
rapidly match homeless
individuals with housing
and services.

Successful program
to be continued.
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
IP-3.5.2 Inter-Agency
Cooperation: Continue to work
with private, county, and State
agencies to provide emergency
housing for the homeless.

Ongoing Successful. City coordinates
with Sonoma County and
County Sheriff Department
per HSPF to provide
housing services for
homeless individuals.

Successful program
to be continued.

IP-3.6.1 Regional Coordination:

Work closely with Sonoma
County representatives to
address farmworker housing
needs and coordinate the
construction of farm worker
housing in the community.

Actively participate in Countywide committees and task forces to identify funding
solutions such as a housing
assessment.

Twice a
year
Successful. The City
regularly attends meetings
with the Sonoma County
Community Development
Commission to address
housing issues including
housing for farmworkers. In
2020 the Baumgardner
project approved w/ 59
rowhouses for farmworker
families.

This program
reflects an ongoing
practice and has
been continued as
Policy H-3.3.

IP-3.6.2 Application Assistance:

Provide technical assistance to
developers seeking to provide
affordable units for farm
workers in the City. Assist
developers in the preparation
of funding applications to the
Joe Serna Jr. Farmworker
Housing Grant program and
other appropriate funding
sources.

Ongoing Successful. The City
provided assistance related
to Joe Serve funding for the
Alexander Valley
Apartments and will
provide additional
assistance for the
apartments associated with
the Baumgardner project.

The City will
continue to assist
developers in the
preparation of
funding applications
for Joe Serna funds
and other
appropriate funding
sources (IP-3.4.1)
IP-4.1.1 Fair Housing
Information: Promote equal
housing opportunity by
providing and distributing
information regarding fair
housing laws and resources to
the public at City Hall, the
public library, social service
centers, public transit
Ongoing Successful. City continues
to provide and distribute
information regarding fair
housing laws and resources
to the public at City Hall
and on the City website.

The City also partners with
the Sonoma County
Community Development
Commission to help
Successful program
to be continued (IP4.1.1).
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
providers, and on the City’s
website.
promote equal housing
opportunities for all people
in Cloverdale.

IP-4.1.2 Discrimination
Complaint Processing:

Establish and document a City
procedure for investigating and
appropriately handling housing
discrimination complaints.
2016 Successful. The City has
initiated a code
enforcement tracking
system specifically for
housing discrimination
complaints.

Program has been
completed and is
ongoing.

IP-4.1.3 Nondiscrimination
Clause: Continue to provide
nondiscrimination clauses in
rental agreements and deed
restrictions for housing
constructed with City
assistance.

Ongoing Successful. The City
provides nondiscrimination
clauses in rental
agreements and deed
restrictions and will
continue this practice.

Successful practice
to be continued (IP4.1.3).

IP-5.1.1 Housing Element
Update: Continue to hold
public hearings to discuss
proposed revisions to the City’s
Housing Element.

Until
adoption
of the
Housing
Element
Successful. The City
completed the public
hearing process and the
2015-2023 Housing
Element was formally
adopted in January 2015.

Program has been
completed and will
not been carried
forward.

Policy H-5.2 Annual Review of
Housing Element
Implementation: Annually
review the City’s progress in
implementing Housing Element
programs and achieving
housing goals.

Ongoing Successful. The City has
developed a process in
which the annual housing
element report is be
brought to the Planning
Commission and then the
City Council to review and
track the progress of its
implementation.

Successful program
to be expanded and
continued (IP-5.2.1).
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
IP-5.2.1 Annual Report: Prepare
an annual report that describes
the amount and type of
housing constructed and
housing-related activities for
review by the Planning
Commission and the City
Council and submittal to the
California Department of
Housing and Community
Development.

Annually Successful. 2020 APR
submitted to HCD. The City
has initiated a process in
which the annual housing
element report will be
brought to the Planning
Commission and then the
City Council to review and
track the progress of its
implementation.

Successful program
to be expanded and
continued (IP-5.2.1).

IP-6.1.1 Education and
Information: Develop
informational materials for
dissemination to developers
and project designers during
the initial stages of project
design and review. These
materials may include, but not
be limited to, passive solar
planning through subdivision,
lot and structure orientation,
protection of solar access, and
application of passive and
active energy saving features.

The City shall also review its
land use regulations and
subdivision ordinance and
where appropriate add
provisions which promote
and/or require energy
conservation planning as a
factor in project approval.
2016 Successful. In 2020 the City
updated information on the
City website page
dedicated to providing
information on electric
vehicles, including
information on funding
available for the installation
of electric vehicle charging
stations on private
property. Through the
Building Permit process,
the City works with
applicants and property
owners to ensure that the
standards of Title 24 are
met, and where possible,
exceeded.

Program has been
completed and will
not be carried
forward in this form;
see also IP-6.1.1.

IP-6.2.1 Green Building: The
City should support Green
Building standards which aim
to support a sustainable
community by incorporating
green building measures into
2016 Successful. The City has
adopted the California
Green Building Standards
Code as part of the City's
Municipal Code. The City
also distributes information
Completed
program will not be
carried forward in
this form; see also
IP-6.1.1.
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
the design, constructions, and
maintenance of new buildings.

The City will also work with
stakeholders to develop a list of
incentives that will help
developers meet mandatory
green building standards.
at City Hall and on the City
website with helpful tips on
how to reduce water
consumption and use less
electricity. In 2019 the City
website was updated with
information on funding
available for the installation
of electric vehicle charging
stations on private
property.

IP-6.3.1 Public Transit: Work
with local and regional public
transit providers and
developers to encourage
housing development located
in close proximity to public
transit facilities, particularly on
sites located within close
proximity to the planned
SMART station. Incorporate
development features that
facilitate bicycle and pedestrian
access and networking in
project design.

Ongoing Successful. In 2020 the City
hired consultant to create
downtown study to
encourage more units and
reduce parking
requirements in DTC &
TOD zones. Zoning
Ordinance 18.05.010-050
for commercial zoning
districts contain provisions
for reduced parking
standards for mixed use
developments in the DTC
and TOD Zoning Districts,
two districts in which transit,
rail and bicycle access is
provided and/or planned to
be provided.

Successful program
has been
completed and will
be carried forward
in IP-6.2.1.

IP-6.3.2 Housing Preferences:

Require that developers utilize
City workforce housing
preferences in the sale of
below market rate homes to
improve local affordable
housing opportunities for those
that work and/or live in
Cloverdale.

Ongoing Successful. Baumgardner
project approved in 2020
w/ 166 apartments & 59
rowhouses which will all be
made available for
farmworker families and/or
income groups between
>50%-120% AMI.

Successful program
has been
completed and will
not be continued
due to State law that
may challenge the
practice as
exclusionary.
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
IP-6.4.1 Capital Improvement
Program: The City shall
continue to update and
implement its five-year Capital
Improvement Program to guide
development of public facilities
required by new residential
demand and to improve
existing facilities in need of
upgrading. The City will
continue to implement facilities
master plans to increase water
and sewer processing capacity.

Annually Successful. In 2015 the City
made significant
improvements to the
wastewater and water
treatment plants to ensure
adequate infrastructure and
public services exist to
serve the community. The
2010 Master Water Plan
update supports the City’s
General Plan update for
increased housing
development and build-out
by 2035. In 2021 the City
released the latest CIP.

Approved projects are
conditioned to install
necessary infrastructure
and public services as
applicable.

Successful practice
will be continued
(IP-6.3.1).
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Table 1-1: 2015-2023 Housing Element Program Implementation Status Program Timeframe Progress Lessons Learned
IP-6.5.1 Water Provisions for
Lower-Income Households:

The City’s urban water
management plans shall
include projected water use for
single-family and multifamily
housing needed for lowerincome households.

UWMP
Update
Successful. An Urban Water
Management Plan (UWMP)
was adopted by the City
Council on June 14, 2016.

The projected water
demand for lower income
housing was conservatively
estimated based on the
average 2015 water
demands for single-family
residential customers. At

0.064 MG per household
and 715 lower income
household units (Housing
Element 2015-2023), the
projected water demand
for lower income housing
units is 45.8 MG in 2020.

This demand is
incorporated in overall
demand projections in this
UWMP by assuming lower
income housing grows
proportionally to City
population growth.

Program has been
completed and will
not be carried
forward but has
been continued as
Policy H-6.4
because it is a
statutory
requirement.

Source: City of Cloverdale Public Draft Housing Element 2023–2031, Table 6 As shown in Table 1-1 above, many of the goals of the existing 2015 Housing Element have been maintained, with new or revised policies and programs proposed to meet changing needs and legal requirements. Most ongoing policies and programs are successful and are continued in the Housing Element update; limited-term programs that have already been accomplished have not been carried forward. To meet state requirements the following goals, policies, and programs are designed to address the existing and projected housing needs of the City of Cloverdale. Each program has one or more individuals, bodies, or agencies responsible for its implementation, along with a potential or committed funding source, and a schedule for its implementation during the 2023-2031 planning period. 235
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The focus of the 2023 Housing Element update process has been to continue to implement the programs that are working, adding new policies and programs where community needs have changed or where necessary to comply with new State laws. These amendments are identified within the housing goals, policies and implementation programs are provided below.

Housing Goals, Policies, and Implementation Programs
Goal H-1 Conserve and improve the existing housing stock to provide adequate, safe, and decent housing for all Cloverdale residents.

Policy H-1.1 Housing Rehabilitation. Facilitate the rehabilitation, improvement, and preservation of existing housing in Cloverdale.

IP-1.1.1 Rehabilitation/Preservation Program (amended to include timeframe). Continue to partner with the Sonoma County Housing Rehabilitation Program to provide low-interest rehabilitation loans for homes and mobile homes owned or occupied by lower and moderate-income households.

Facilitate resident awareness of the rehabilitation loan program by:
a. making pamphlets on this program available at City Hall and at the public library;
b. providing program information to neighborhood groups in older residential areas and mobile home parks, with active outreach to mobile home parks conducted every 2 years;
c. posting program information on the City’s website; and d. providing program information in the process of building code enforcement.

Responsibility: Planning/Community Development and Building Departments Funding: CDBG
Timeframe: Ongoing; contact neighborhood groups and mobile home parks every 2 years, provide information on the City’s website by 2022 and update as needed.
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IP-1.1.2 Neighborhood Revitalization (amended to include timeframe). Review and recommend projects in the City's Capital Improvement Program (CIP) that will maintain and improve the City’s older residential neighborhoods as well as projects that will facilitate opportunities for infill and transitoriented housing.

Responsibility: Planning/Community Development and Public Works Departments Financing: General Fund
Timeframe: Annually, reported in Annual Progress Report (APR) Policy H-1.2 Mobile Home Parks. Encourage the preservation and maintenance of the community’s three existing mobile home parks.

IP-1.2.1 Mobile Home Park Maintenance (amended to include timeframe). Specifically advertise the availability of home rehabilitation loans to mobile homeowners through the program described in IP-1.1.1. Encourage residents utilizing program funds to include an Earthquake Reinforced Bracing System (ERBS) to help stabilize the dwelling during an earthquake in the rehabilitation work.

Responsibility: Planning/Community Development and Building Departments Funding: CDBG
Timeframe: Ongoing; advertise the program to mobile homeowners directly every two years beginning in 2024
Goal H-2 Provide housing for all economic segments of the community.

Policy H-2.1 Regional Housing Needs. Ensure that adequate residentially designated land is available to accommodate the City’s share of the regional housing need.

IP-2.1.1 Sites Monitoring (amended to comply with State No Net Loss Law). The City will monitor the supply of residential land to ensure that sufficient developable land is available for housing development throughout the eight-year planning period. If, at any time the supply of sites zoned for multifamily housing falls below the quantity of land required to accommodate the City’s remaining housing needs, the City will add additional appropriately zoned sites to ensure ongoing sites capacity.

Responsibility: Planning/Community Development Department 237
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Funding: General Fund
Timeframe: Annually; sites inventory evaluated in APR
IP-2.1.2 Infill Development (continued program). Wherever appropriate, the City will grant flexibility to encourage development on infill parcels using the tools currently provided within the Zoning Ordinance. This can be applied on a case-by-case basis in tandem with development approvals.

Responsibility: Planning/Community Development Department, Planning Commission, City Council
Funding: General Fund
Timeframe: Ongoing; as development projects are proposed Policy H-2.2 Accessory Dwelling Units. Continue to facilitate the construction of accessory dwelling units.

IP-2.2.1 Accessory Dwelling Units (amended to quantify and include regional effort).

Promote the development of accessory units as a source of lower-cost rental housing and a potential income source for homeowners. Provide informational brochures regarding accessory unit opportunities and requirements at City Hall and on the City’s website. Support regional effort to provide homeowners with free property assessment, preapproved ADU plans, and information on financing options.

Responsibility: Planning/Community Development Department Funding: General Fund
Timeframe: Update brochure with JADUs and estimated fees by end of 2023; join regional program by end of 2023
Policy H-2.3 Mitigate Development Constraints. Address and mitigate, as appropriate, regulatory constraints to facilitate the development of housing affordable to lower- and moderate-income households.

IP-2.3.1 Flexible Parking Options (amended for AB 2345 compliance). The City will continue to allow and encourage shared parking and allow both on-site and/or off-site provision of required spaces. In addition, the City will promote its shared parking program within the downtown commercial core to maximize the potential for mixed use development and ensure compliance with AB 2345 (Density Bonus Law) and other state provisions allowing parking flexibility in development.
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Responsibility: Planning/Community Development Department Funding: General Fund
Timeframe: Ongoing, as projects are proposed; code compliance reviewed annually IP-2.3.2 Development Impact Fees (amended for AB 602 compliance). The City shall review its current development impact fee program to confirm the appropriate level of impact fees to charge for multifamily residential units based on the demand they create for public facilities and infrastructure. Where justified, the City shall consider reducing fees for multifamily units, second units, co-housing, and self-help housing units to encourage their construction. The City shall defer the payment of development impact fees for residential projects and will consider reducing development fees for lower-income housing on a sliding scale related to the level of affordability. The City shall also comply with the new laws (AB 602) for the assessment of development fees based on the size of the unit.

Responsibility: Planning/Community Development Department Funding: General Fund
Timeframe: Complete review by 2023 (during the next impact fee review) IP-2.3.3 Code Changes (new program added for compliance with SB 330, SB 35, AB 1397, AB 2162, SB 9, et al). The City shall establish a program to keep City code up to date with state mandates, particularly surrounding streamlining provisions, density bonus law, and other state policy directly impacting the process of development of housing including but not limited to affordable housing, permanent supportive housing, and low-barrier navigation centers. The City shall maintain resources for developers seeking to utilize these resources and procedures on the City’s website.

Responsibility: Planning/Community Development Department Funding: General Fund
Timeframe: Complete initial code changes to achieve compliance with State law by 2023; annual review reported in APR.
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Goal H-3 Expand affordable housing opportunities for persons with special housing needs including the elderly, disabled, large families, farmworkers, homeless persons, households with extremely low to moderate incomes, and first-time home buyers.

Policy H-3.1 Available Funding Sources. Utilize County, State and federal programs and other funding sources that provide housing opportunities for extremely low-, very low-, low-, and moderate-income households and special needs households.

IP-3.1.1 Funding Affordable Housing (amended to address special needs groups and support compliance with streamlining law). Assist housing developers in identifying opportunities to finance affordable housing intended for occupancy by household with special needs, particularly in rounding out unmet needs for extremely low-income households, seniors, disabled and developmentally disabled persons, large families and households, farmworkers, and homeless persons. The City shall provide free preapplications for developers of affordable housing. Funding sources may include:
• Rural Development Loan Program financed by the State Department of Housing and Community Development (HCD).
• Community Development Block Grant (CDBG) funds.
• Mortgage Revenue Bond Program through the CHFA. The City can issue revenue bonds on behalf of affordable housing developers or work with developers to secure these bonds.
• Housing Enables by Local Partnerships Program (HELP) operated by the CHFA.
• HOME Investment Partnerships Program (HOME).

The City will promote use of these funds by listing potential funding sources on its website and planning staff will inform housing developers of these funding possibilities.

Responsibility: Planning/Community Development Department Funding: General Fund
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Timeframe: Annually review and disseminate information on funding opportunities; assist developers on an ongoing basis as notices of funding availability are issued and/or as development projects are proposed. Report progress in APR.

IP-3.1.2 Housing Fund (amended to assess threshold). Maintain the City’s housing fund, with contributions collected from private and public sources, including the in-lieu inclusionary housing fees to implement and/or supplement the City's housing programs. Use the Housing Fund to make housing available to extremely low to moderate-income Cloverdale residents.

The City shall evaluate the 5-unit threshold for local funding to achieve greater flexibility in funding smaller multifamily units and accessory dwelling units.

Responsibility: Planning/Community Development and Finance Departments Funding: Housing Fund
Timeframe: Fund maintenance ongoing; allocate funds as projects are proposed; evaluate threshold by 2023
Policy H-3.2 Senior Housing (amended for AB 2345 compliance). Continue to allow senior housing projects for persons aged 55 and over to be developed with requirements less stringent than those specified in the Zoning Ordinance for parking and other requirements, pursuant to Density Bonus Law (CA Govt Code § 65915). Maintain a requirement for on-site sidewalks for senior housing projects.

Policy H-3.3 Inter-Agency Cooperation Continue to work with private, county, and State agencies, including local school districts, to provide housing for special needs populations including emergency housing for the homeless.

Responsibility: Planning/Community Development Department Funding: General Fund
Timeframe: Ongoing, attend meetings and events as scheduled Policy H-3.4 Farmworker Housing (amended to incorporate prior program). Promote improved housing conditions for farmworker households and the construction of additional farmworker housing. The City will continue to work closely with Sonoma County representatives to address farmworker housing needs, coordinate the construction of farmworker housing in the community, and actively participate in committees and task forces to identify funding solutions such as a housing assessment.
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IP-3.4.1 Application Assistance (amended to quantify). Provide technical assistance to developers seeking to provide affordable units for farm workers in the City. Assist developers in the preparation of funding applications to the Joe Serna Jr. Farmworker Housing Grant program and other appropriate funding sources.

Responsibility: Planning/Community Development Department Funding: General Fund
Timeframe: Ongoing; as development projects are proposed, with annual outreach reported in APR
Goal H-4 Promote housing opportunities for all persons regardless of race, gender, age, sexual orientation, marital status, or national origin.

Policy H-4.1 Equal Housing Opportunity. Continue to promote equal access to housing for all persons in Cloverdale.

IP-4.1.1 Fair Housing Information (continued program). Promote equal housing opportunity by providing and distributing information regarding fair housing laws and resources to the public at City Hall, the public library, social service centers, public transit providers, and on the City’s website.

Responsibility: Planning/Community Development Department Funding: General Fund
Timeframe: Ongoing; distribute information annually
IP-4.1.2 Discrimination Complaint Processing (amended to quantify). Continue existing City procedure for investigating and appropriately handling housing discrimination complaints.

Responsibility: Planning/Community Development Department Funding: General Fund
Timeframe: Ongoing; reported annually
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IP-4.1.3 Nondiscrimination Clause (continued program). Continue to provide nondiscrimination clauses in rental agreements and deed restrictions for housing constructed with City assistance.

Responsibility: Planning/Community Development Department Funding: General Fund, housing fund
Timeframe: Ongoing, as developments are proposed and receive City assistance.

Report outcomes annually in APR.

IP-4.1.4 Limit Code Enforcement Action for ADUs (new program). The City will limit code enforcement of unpermitted ADUs to those instances where they pose an imminent threat to public health and safety.

Responsibility: Building and Code Enforcement/Community Development Department Funding: General Fund
Timeframe: Ongoing, as developments are proposed and receive City assistance.

Report on ADU enforcement actions annually in APR.

Goal H-5 Ensure public participation in the development of the City’s housing policies.

Policy H-5.1 Public Participation. Continue to encourage and facilitate public participation in the formulation and review of the City's housing and development policies.

IP-5.1.1 Equitable Representation (new program). Promote the involvement of minority populations and their representatives on City Boards, Committees, and Commissions related to housing, land use, and equity matters. At the time of new vacancies, the Cities will advertise the availability of these positions to minority communities through social media, connections with trusted community partners, and direct outreach where applicable.

Responsibility: City Manager/Community Development Department Funding: General Fund
Timeframe: As openings arise, beginning 2023
Policy H-5.2 Annual Review of Housing Element Implementation. Annually review the City’s progress in implementing Housing Element programs and achieving housing goals.
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IP-5.2.1 Annual Report (amended in compliance with CA Govt Code § 65400 & 65700).

Prepare an annual progress report using forms required by the State HCD, to describe the amount and type of housing constructed and approved for each calendar year. The Annual Progress Report (APR) will also include reporting on the City’s progress in implementing each of the programs in this Element and shall be presented to the Planning Commission and the City Council prior to submittal to the California Department of Housing and Community Development and the Office of Planning and Research on or before April 1 of each year.

Responsibility: Planning/Community Development Department Funding: General Fund
Timeframe: Annually
Goal H-6 Promote effective and efficient land use when meeting housing needs, including consideration of energy and natural resources conservation, and green building technologies.

Policy H-6.1 Energy Use and Conservation. Encourage the reduction of energy use and the conservation of natural resources in the development of housing through implementation of the State Energy Conservation Standards.

IP-6.1.1. Education and Information (amended to combine previous programs). Develop informational materials for dissemination to developers and project designers during the initial stages of project design and review. These materials may include, but not be limited to, passive solar planning through subdivision, lot and structure orientation, protection of solar access, and application of passive and active energy saving features including water capture and recycling. The City shall also review its land use regulations and subdivision ordinance and where appropriate add provisions which promote and/or require energy conservation planning as a factor in project approval. The City shall continue to participate in monthly coordination with the Regional Climate Protection Authority (SCTA/RCPA) to collaborate on climate resiliency measures.

Responsibility: Planning/Community Development Department Funding: General Fund
Timeframe: Develop informational materials by end of 2023; review regulations annually; participate in regional coordination meetings monthly. 244
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Policy H-6.2 Reduction of Vehicle Use. Encourage a development pattern that helps reduce vehicle miles traveled and promotes transit ridership as well as pedestrian and bicycle access.

IP-6.2.1 Public Transit (continued program). Continue to work with local and regional public transit providers and developers to encourage housing development located in close proximity to public transit facilities, particularly on sites located within close proximity to the planned SMART station. Incorporate development features that facilitate bicycle and pedestrian access and networking in project design.

Responsibility: Planning/Community Development Department Funding: General Fund
Timeframe: Ongoing and as projects are proposed
Policy H-6.3 Infrastructure and Public Services. Ensure adequate infrastructure and public services are in place to serve existing and planned residential development.

IP-6.3.1 Capital Improvement Program (continued program). The City shall continue to update and implement its five-year Capital Improvement Program to guide development of public facilities required by new residential demand and to improve existing facilities in need of upgrading. The City will continue to implement facilities master plans to increase water and sewer processing capacity.

Responsibility: Planning/Community Development Department Funding: General Fund
Timeframe: Annually; implementation of facilities improvements ongoing Policy H-6.4 Water and Sewer Services. Consistent with State Law, first priority for water and sewer hook-ups shall be given to developments that help meet the community’s share of the regional need for lower-income housing.

IP-6.4.1 Water Provisions for Lower-Income Households (continued program).The City’s urban water management plans shall include projected water use for single-family and multifamily housing needed for lower-income households.

Responsibility: Planning/Community Development Department 245
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Funding: General Fund
Timeframe: As management plans are updated

1.4 PURPOSE OF AN EIR ADDENDUM
According to CEQA Guidelines Section 15164(a), an addendum shall be prepared if some changes or additions to a previously adopted EIR are necessary, but none of the conditions enumerated in CEQA Guidelines Sections 15162(a)(1) through (3) calling for the preparation of a subsequent EIR have occurred. As stated in CEQA Guidelines Section 15162 (Subsequent EIRs and Negative Declarations):

When an EIR has been certified or negative declaration adopted for a project, no subsequent EIR shall be prepared for that project unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more of the following:
(1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;
(2) Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or
(3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or negative declaration was adopted, shows any of the following:
(a) The project will have one or more significant effects not discussed in the previous EIR or negative declaration;
(b) Significant effects previously examined will be substantially more severe than shown in the previous EIR;
(c) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or
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(d) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

The proposed project would fulfill none of the conditions outlined in CEQA Guidelines Sections 15162(a)(1) through (3) because these changes would not result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects requiring major revisions to the 2012 General Plan EIR. Accordingly, this checklist provides the substantial evidence required by CEQA Guidelines Section 15164(e) to support the finding that a subsequent EIR is not required and an addendum to the General Plan EIR is the appropriate environmental document to address changes to the project.

As stated in CEQA Guidelines Section 15164 (Addendum to an EIR):
(a) The lead agency or responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.
(b) An addendum to an adopted negative declaration may be prepared if only minor technical changes or additions are necessary or none of the conditions described in Section 15162 calling for the preparation of a subsequent EIR or negative declaration have occurred.
(c) An addendum need not be circulated for public review but can be included in or attached to the final EIR or adopted negative declaration. (d) The decision-making body shall consider the addendum with the final EIR or adopted negative declaration prior to making a decision on the project. (e) A brief explanation of the decision not to prepare a subsequent EIR pursuant to Section 15162 should be included in an addendum to an EIR, the lead agency’s findings on the project, or elsewhere in the record. The explanation must be supported by substantial evidence.

A copy of this addendum, and all supporting documentation, may be reviewed or obtained at the City of Cloverdale, Planning & Community Development Department, 124 N. Cloverdale Boulevard, Cloverdale, California 95425.
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2. CEQA Analysis

2.1 ENVIRONMENTAL ANALYSIS
The City of Cloverdale 2009 General Plan provided a comprehensive update, addressing the required elements—land use, circulation (transportation), housing, conservation, open space, noise, and safety—as well as three optional elements—parkland and recreation, community design, and urban lighting. The General Plan is largely designed to be self-mitigating by incorporating policies that address and mitigate related environmental impacts, such as zoning codes and design standards.

As previously described in Section 1.2, the General Plan EIR addresses significant impacts related to land use, agriculture, population/housing, hazards and human health, transportation, noise, air quality, visual resources, geology and landforms, hydrology/water quality, biological resources, cultural and paleontological resources and greenhouse gases. Table 1-1 shows that most of the existing Housing Element policies will remain unchanged with the proposed project and are either informative or result in no physical change to the environment. The programs were modified to comply with state law, combine programs with similar intent to aid in implementation, or eliminate programs where the City has already completed the identified task.

A brief summary of the policy changes and additions are listed by Goal below:

Goal H-1: Conserve and improve the existing housing stock to provide adequate, safe, and decent housing for all Cloverdale residents.
• Existing programs have been retained and amended
• SB 510 (mobile home park conversions and resident support requirements) to be implemented to protect park residents
• Various programs amended to quantify timelines and outreach mechanisms Goal H-2: Provide housing for all economic segments of the community. • Sites monitoring program amended to comply with No Net Loss requirements • Accessory dwelling units facilitated through regional cooperation • Development constraints mitigated through parking flexibility expanded to comply with AB 2345 requirements
• Development impact fee program revised to comply with AB 602 248
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• Code changes for qualifying affordable housing, permanent supportive housing, lowbarrier navigation centers, and multiplexes per various State laws • Various programs amended to quantify timelines and outreach mechanisms Goal H-3: Expand affordable housing opportunities for persons with special housing needs such as the elderly, disabled, large families, farmworkers, homeless persons, households with extremely low to moderate incomes, and first-time home buyers. • Five-unit threshold for housing financing evaluated for revision in planning cycle • Various programs amended to quantify timelines and outreach mechanisms Goal H-4: Promote housing opportunities for all persons regardless of race, gender, age, sexual orientation, marital status, or national origin. • New programs to codify fair housing enforcement and outreach per AB 686 • New program to limit code enforcement actions for unpermitted ADUs in order to avoid actions that do not affirmatively further fair housing (AB 686) Goal H-5: Ensure public participation in the development of the City’s housing policies. • New program to achieve equitable representation on local boards, committees, and commissions and expand public participation in housing and policy development • Annual reporting requirements quantified in compliance with State law Goal H-6: Promote effective and efficient land use in meeting housing needs, including consideration of energy and natural resource conservation, and green building technologies. • Policies and programs continued and amended to quantify timelines and procedures • Existing and continued programs pertain to education, outreach, reduction of vehicle miles traveled (VMT), increased use of public transportation, water conservation efforts, and equitable distribution of infrastructure improvements including priority for affordable housing development
New development resulting from these programs would occur on land already designated for housing development in the General Plan. Furthermore, all future development in the city would be required to comply with local regulations, including the General Plan, Zoning Code, and subdivision standards. These local regulations guide future development and would address physical impacts resulting from development. Moreover, the City’s Zoning Code contains a list of permitted uses for each respective zoning district. The General Plan EIR anticipated physical impacts associated with the permitted uses in the City’s Zoning Code, and 249
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the proposed project would, therefore, result in no new impact as part of development. The policies and action items in the General Plan EIR to reduce physical environmental effects would continue to apply to all development.

The proposed project establishes targets for the income accessibility of future housing; however, the ability to construct the housing is based on the designations in the Land Use Element. Because the City can meet its Regional Housing Needs Allocation (RHNA) without changing any land use designation, the Land Use Element remains unchanged from the document evaluated in the General Plan EIR. Therefore, development of housing as considered in the proposed Housing Element would be consistent with what was analyzed in the General Plan EIR. The General Plan EIR relied on policies from various elements of the General Plan, as well as implementation of federal and state laws and the City zoning ordinance and development standards to address the physical impacts of future development. The proposed project does not change these policies. Further, based on review of the General Plan EIR, and consideration that the proposed 2023–2031 Housing Element does not add new programs that would increase development in the city, the project would not result in new or more severe impacts than disclosed in the General Plan EIR.

All future development in the city would be required to comply with local regulations, including the General Plan, Zoning Ordinance, and subdivision standards. These local regulations guide future development and would address potential physical impacts resulting from development. Moreover, the City’s Zoning Ordinance contains a list of permitted uses for each respective zoning district. The General Plan EIR evaluated permitted uses and anticipated physical impacts associated with development and would therefore result in no new impact as part of development. As the proposed project does not change the permitted uses allowed by the Zoning Ordinance, there would be no new impact. Building regulations are applied as part of the building permit process and are independent of CEQA.

As the proposed 2023–2031 Housing Element does not change any land use designation or zoning district, the impacts of the proposed project would be no more substantial than analyzed in the General Plan EIR. No new mitigation measures are necessary.

2.2 FINDING
The discussion in this addendum confirms that the proposed project has been evaluated for significant impacts pursuant to CEQA. The discussion is meaningfully different than a determination that a project is “exempt” from CEQA review, because the proposed 2023–2031 Housing Element update is not exempt. Rather, the determination here is that the 2009 General Plan EIR evaluated all the physical impacts likely to result from future development. Because the proposed 2023–2031 Housing Element does not change any land use designation or 250
ADDENDUM TO THE GENERAL PLAN EIR FOR THE 202 3 – 20 31 HOUSING ELEMENT UPDATE

CITY OF CLOVERDALE

2. CEQA Analysis

approve any development, the General Plan EIR provides a sufficient and adequate analysis of the environmental impacts of the proposed 2023–2031 Housing Element.

There are no substantial changes in the circumstances or new information that was not known and could not have been known at the time of the adoption of the General Plan EIR. The proposed project consists entirely of land uses permitted by project sites’ existing General Plan land use designation and zoning and represents no change from the impacts that were assumed and analyzed by the General Plan EIR.

As a result, and for the reasons explained in this addendum, the project would not cause any new significant environmental impacts or substantially increase the severity of significant environmental impacts disclosed in the General Plan EIR. Thus, the proposed project does not trigger any of the conditions in CEQA Guidelines Section 15162 allowing the preparation of a subsequent EIR, and the appropriate environmental document as authorized by CEQA Guidelines Section 15164(b) is an addendum. Accordingly, this EIR addendum has been prepared.

The following identifies the standards set forth in Section 15162 as they relate to the project.

The text that follows the provisions of the law relates to the proposed 2023–2031 Housing Element.

1. No substantial changes are proposed in the project which would require major revisions of the EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

As discussed above, the program changes included in the proposed Housing Element are limited to complying with state law, combining programs with similar intent to aid in implementation, or eliminating programs where the City has already completed the identified task. The proposed project does not result in the rezoning of land or approval of any development project. All development in the city must be consistent with the General Plan, and if a discretionary action, would also be subject to CEQA.

The proposed changes to the Zoning Code identified in Table 1-1 represent modification of existing policy to either streamline development that is already allowed or make the code consistent with state law. The modified programs would affect sites currently designated for development in the Land Use Element of the General Plan, so there would be no change in the physical impacts associated with future development. Therefore, policies and action items identified in the General Plan EIR to reduce physical environmental effects would continue to apply to future development and would reduce impacts to the same significance level as identified in the General Plan EIR. 251
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CITY OF CLOVERDALE

2. CEQA Analysis
February 2023 Page 35

2. The project will have one or more significant effects not discussed in the previous EIR.

As discussed above, the proposed Housing Element programs are similar to the existing policies of the General Plan. The proposed 2023–2031 Housing Element includes seven amended programs that would not result in new significant environmental impacts. As shown in Table 6 of the proposed 2023–2031 Housing Element consolidates many programs from the previous Housing Element to aid in implementation and to eliminate redundancy.

3. Significant effects previously examined will be substantially more severe than shown in the previous EIR.

The proposed project includes policy-level changes that are limited to complying with state law and would not result in physical changes to the environment that were not disclosed in the General Plan EIR. Moreover, the proposed project would not create new impacts or the need for additional mitigation measures. The policies identified in the General Plan EIR to reduce physical environmental effects address significant impacts for land use, agriculture, population/housing, hazards and human health, transportation, noise, air quality, visual resources, geology and landforms, hydrology/water quality, biological resources, cultural and paleontological resources and greenhouse gases. These policies and action items in the General Plan EIR would also apply to the 2023–2031 Housing Element. The City is required to adopt a Housing Element, and the element must be reviewed and certified by the Housing and Community Development Department. There is no feasible alternative to adopting a Housing Element. As with the existing Housing Element evaluated in the General Plan EIR, the proposed Housing Element would not result in significant environmental impacts that are substantially more severe than shown in the previous EIR.

4. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative.

The proposed project includes policy-level changes that are limited to complying with state law and does not result in physical changes to the environment. As discussed above, the proposed project would not create new impacts or the need for additional mitigation measures. As with the existing Housing Element evaluated in the General Plan EIR, the proposed Housing Element would not result in significant environmental impacts that would require new mitigation measures.
252
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CITY OF CLOVERDALE

2. CEQA Analysis

5. Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

The proposed project would have the same impacts as identified in the previously certified General Plan EIR, and all associated policies identified in the General Plan EIR to reduce physical environmental effects would continue to apply. As stated in the response to Standard 3, there are no new significant impacts resulting from adoption of the 2023–2031 Housing Element; therefore, there is no need for new mitigation measures or alternatives to the proposed project.
253
1 City Of Cloverdale
General Plan Update
Final Environmental Impact Report
State Clearinghouse No. 2007082143
January 2009
254
2 TABLE OF CONTENTS
City of Cloverdale General Plan Update
Final Environmental Impact Report
Executive Summary 3
Introduction 3
Project Description 3
Project Objectives 4
Summary of Environmental Impacts 6

1. Introduction 31
Introduction 31
California Environmental Quality Act Compliance 31
CEQA Final EIR Process 33
Organization of the Document 33

2. Comments on the Draft EIR 35
Introduction 35
List of Comments 36
Comment Letters and Minutes (Oral Comments) 37

3. Response to Comments on the Draft EIR 75
Introduction 75
Response to Comments 76

4. Minor Changes and Edits to the Draft EIR 106
Introduction 106
Minor Changes to the Environmental Analysis 106

5. Report Preparation ***
City of Cloverdale ***
General Plan Consulting Team ***
List of Tables
Summary of Impacts and Mitigation Measures 6
Comment Letters Received on the Draft EIR 36
255
3 EXECUTIVE SUMMARY
Introduction
The California Environmental Quality Act (CEQA) requires that all state and local government agencies consider the environmental consequences of programs and projects over which they have discretionary authority before taking action on them. The primary purpose of this Final Environmental Impact Report (Final EIR) is to inform agencies and the public of any significant environmental effects associated with the City of Cloverdale General Plan Update (Proposed Project). The Final EIR consists of the Draft EIR and the responses to comments on the Draft. The Draft document was distributed on October 24, 2008.

The City of Cloverdale will be the CEQA lead agency for the Proposed Project and will consider the information presented in this Final EIR before taking discretionary action on the Proposed Project. Other agencies may use some or all of the analysis presented in this document for purposes of permit review and approval.

Project Description
The proposed project is the update and adoption of the City of Cloverdale General Plan and the associated Program Environmental Impact Report prepared pursuant to the requirements of the California Environmental Quality Act. The City last updated the General Plan 1993, and since that time, the City has experienced population growth, residential and economic development, and changes in community interests and attitudes that are addressed in the updated General Plan. Additionally, the General Plan update addresses the pertinent planning, development, and environmental statutes that may have changed since the General Plan was last adopted. The overall purpose of the project is to adoptaPlanthatwillnotonlypreserve,butenhancethequalityoflifeforCloverdale’s residents.Ideally,theGeneralPlanshouldserveasthecommunity’soverall implementation tool to achieve its vision for the future.

State law requires each county and city to prepare and adopt a comprehensive and longrange general plan for its physical development (Government Code Section 65300). The lawspecificallyrequiresthattheGeneralPlanaddressseventopicsor“elements.”These are land use, circulation (transportation), housing, conservation, open space, noise, and safety.Inaddition,theCityofCloverdale’sGeneralPlanincludesthreeoptional elements -- Parkland and Recreation, Community Design, and Urban Lighting Elements. 256
4 Project Objectives
The General Plan Citizen's Advisory Committee identified the following 14 major objectives for the General Plan.

Community Setting

1. Maintain and encourage undeveloped hillsides, river and creek frontages, and forest setting that complement the natural visual setting of Cloverdale.

2. Maintain the urban forest by expanding the tree canopy within the City.

Recommend preparation of a Tree Preservation Ordinance.

3. Maintain and improve the design of the built environment, including entrances and approaches to the community and downtown, site planning and development, highway frontages, and street and sidewalk design.

4. Minimize impacts of urban lighting.

5. Conserve or preserve historic buildings and the character of the older parts of town using conservation and form based zoning ordinances.

Maintain a balance of land uses

1. The General Plan should provide for a balance of land uses for housing, jobs, economic development, destination commercial sites, and a jobs/housing balance.

2. Residential land use should have a target population of 12,000 people.

3. Downtown economic development continues to be important in the updated General Plan.

4. Industrial lands should be reserved for industrial purposes, and not for typical household retail items.

Geographical Growth

1. The City should grow to the north or south if needed. There should be no expansion east of the Russian River, and expansion, if any, into hillside areas should be very low intensity, with controlled visibility and impacts.

2. The City may consider use of areas outside the urban service boundary and General Plan study area for recreation sites, even though they would not be considered for residential, commercial, or industrial use.

3. The City should adopt an Urban Growth Boundary.

Community Recreation

1. Recreation assets should match population growth, including an evaluation of various groups who would like recreation assets such as youth, sports, walkers, elderly citizens, and land area and facilities targeted to those groups, including residential, commercial, and industrial areas.

2. Consider water-based recreation.
257
5 TABLE: ES-1

GENERAL PLAN UPDATE IMPACTS AND PROPOSED MITIGATION MEASURES Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance

4.1 Land Use
Impact 4.1.1 Implementation of the
proposed General Plan Update
may conflict with relevant land
use planning documents
within and adjacent to the City
of Cloverdale.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 1-1 (LU 1-1.a.): promotes land use density and intensity ranges to servethecommunity’sneeds;
LU 1-5 (LU1-5.a.): provides for the development of guidelines to protect the hillsides within the County to the west of the City; LU 2-1 (LU 2-1.a and b): supports the downtown as the core of the City;
LU 3-1 and 3-2 (LU 3-1a, LU 3-2a, b and c.): provide for development of an Urban Growth Boundary to protect important farmlands and hillsides from urban development;
LU 5-1 (LU 5-1.a, c and d.): provides for future school needs; LU 8-1 (LU 8-1.a.): provides for airport compatible land uses near the airport:

NE 1-1 (NE 1-1.a, b, c and d.): provide for a quiet community by reducing existing noise problems and assuring that new development meets noise standards;
PS 7-1; PS 7-2; PS 7-3; PS 7-5; PS 7-6; PS 7-7; PS 7-12 Requires future development and use of the City Airport to be consistent with the Cloverdale Municipal Airport Master Plan. Sets policies for ensuring safety at the Airport and within the referral area.

LS
Impact 4.1.2 Implementation of the
proposed General Plan may
create conflicts between
existing and future land uses
within or adjacent to the City
of Cloverdale General Plan
Study Area.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 1-1 (LU 1-1.a.): Allowable land uses are shown the General Plan Land Use Map with allowable population density and building intensity in the Land Use Table. Requires the Zoning Ordinance and other Ordinances to be amended to bring City Ordinances into conformity with the General Plan Map and Table;
LU 1-4 (LU 1-4.a; LU 1-4.c.) Provides for a balance of commercial and LS
258
6 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
industrial lands and ensures buffers between industrial and residential uses;
LU 1-5 (LU 1-5.a; LU 1-5.b.) The General Plan contains guidelines as a basis for comments to the County on projects within the Study Area.

Requires development of a statement of preferred land use practices that would be sent to the county annually for county areas adjoining the City. Ensures adequate room for children play areas and resident needs;
LU 2-1 (LU 2-1.a.) Provides for economic development resources to the downtown in order to maintain a focal point for the community.

Requires maintenance of an up-to-date downtown plan,
implementation of downtown plan policies and encouragement of cultural facilities and events in the downtown;
LU 2-2 (LU 2-2.a.) Retains and encourages residential uses near the downtown to preserve a close-in customer and pedestrian base.

LU 2-4 Discourages the creation of retail areas outside the downtown; LU 3-1 (LU 3-1.a.) Requires development of an Urban Growth Boundary (UGB) that allows urban development only within the boundaries with the areas outside the boundary to be retained as Conservation Features, except for the Industrial and Asti Exception areas;
LU 6-2 (LU 6-2.a.) Requires provision of adequate public facilities and services to meet the needs of the community;
LU 6-3, LU 6-3.a. Discourages development beyond areas with planned expansions of public services;
LU 8-1 Requires future development and use of the City Airport to be consistent with the Cloverdale Municipal Airport Master Plan; Impact 4.1.3 Future development associated
with build-out within the
General Plan Update Study
Area will place additional
demands upon the amount of
space required for use as open
space, parks, and active and
PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

PR 1-1 (PR 1-1.a.) Establishes an ad hoc parks and recreation committee to review existing and proposed park facilities; PR 1-2 (PR 1-2.a.) Provides for five acres of City-owned park and recreation land per 1,000 residents;
PR 1-3 (PR 1-3.a.) Provides for potential acquisition of parklands LS
259
7 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
passive recreation areas. through purchase, dedication or transfer from other agencies; PR 1-4 (PR 1-4.a.) Provides for hillside open areas and trails on sites shown in General Plan Exhibit 5.1.;
PR 1-5 (PR 1-5.a, b.) Provision of pedestrian and bicycle trails with a gold of providing looped trail systems;
PR 1-6 (PR 1-6.a.) Provides assistance to the Cloverdale Citrus Fair; PR 1-7 (PR 1-7.a, b.) Encourages participation with Sonoma County, the Cloverdale School District, other government agencies and private property owners to establish recreational facilities and uses;

4.2 Agriculture
Impact 4.2.1 Implementation of the
proposed General Plan would
result in the loss of farmlands
as designated under the
Farmland Mapping and
Monitoring Program, due to
conversion to urban uses.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 3-1(LU 3-1.a, b and c) Develops an Urban Growth Boundary (UGB) outside of which no urban development would be permitted except in two existing developed areas (Industrial and Asti Exception areas).

Retains land outside the UGB as conservation Features, except for the Industrial and Asti Exception Areas;
LU 3-3 (LU 3-3. a, b) Provides for protection of hillsides, land outside the UGB and prime, unique and of statewide importance farmland from urban development,
CDO 1-1 (CDO 1-1. a, b) Limits urban development to the valley floor.

CDO 1-2 (CDO 1-2.a) Reserves the conservation areas north and south of the City for agricultural uses unless a Specific Plan is prepared and the General Plan is amended.

CDO 1-5 (CDO 1-5.a) Encourages the County to retain surrounding lands in very low density residential, agricultural, open space and natural resource uses. Promotes the creation of a community separator.

LS
Impact 4.2.2 Implementation of the
proposed General Plan could
result in the placement of
urban uses adjacent to existing
PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 3-1, (LU 3-1a, b and c.) Provides for an Urban Growth Boundary (UGB) outside of which no urban development would be permitted except in two existing developed areas (Industrial and Asti Exception areas). Retains land outside the UGB as conservation Features, except LS
260
8 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
agricultural uses. for the Industrial and Asti Exception Areas LU 3-3 (LU 3-3. a, b.) Provides for protection of hillsides, land outside the UGB and prime, unique and of statewide importance farmland from urban development
CDO 1-5 (CDO 1-5.a.) Encourages the County to retain surrounding lands in very low density residential, agricultural, open space and natural resource uses. Promotes the creation of a community separator Impact 4.2.3 Implementation of the
proposed General Plan could
result in a conflict with
existing Williamson Act
contracts.

PS
LU 3-1(LU 3-1.a, b and c.) Provides for an Urban Growth Boundary (UGB) outside of which no urban development would be permitted except in two existing developed areas (Industrial and Asti Exception areas). Retains land outside the UGB as conservation Features, except for the Industrial and Asti Exception Areas
CDO 1-5 (CDO 1-5.a.) Encourages the County to retain surrounding lands in very low density residential, agricultural, open space and natural resource uses. Promotes the creation of a community separator.

LS
Impact 4.2.4 Implementation of the
proposed General Plan, along
with other proposed
development in Sonoma
County, would contribute to
the additional conversion of
Important Farmland to other
uses.

PCC
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 3-1 (LU 3-1.a, b and c.) Provides for an Urban Growth Boundary (UGB) outside of which no urban development would be permitted except in two existing developed areas (Industrial and Asti Exception areas). Retains land outside the UGB as conservation Features, except for the Industrial and Asti Exception Areas
LU 3-3 (LU 3-3. a, b.) Provides for protection of hillsides, land outside the UGB and prime, unique and of statewide importance farmland from urban development
CDO 1-1 (CDO 1-1. a, b.) Limits urban development to the valley floor.

CDO 1-5 (CDO 1-5.a.) Encourages the County to retain surrounding lands in very low density residential, agricultural, open space and natural resource uses. Promotes the creation of a community separator.

LTCC

4.3 Population and Housing
Impact 4.3.1 Implementation of the
proposed General Plan Update PS Plan policies and implementation measures which avoid orsubstantially reduce this impact: LS 261
9 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
would include land uses that
would promote an increase in
population, housing, and
employment to the area.

LU 1-2 (LU 1-2.a.) Infrastructure and land use policies are based on a maximum anticipated population of 12,000 residents and 4,700 housing units in 2025. Calls for a Growth Management program to allow an average of 75 units per year, with flexibility so that growth does not exceed 375 units in any five year period.

LU 1-5 (LU 1-5.a.) Requires development of a statement of preferred land use practices that would be sent to the county annually for county areas adjoining the City.

LU 2-2 (LU 2-2.a.) Retains and encourages residential uses near the downtown to preserve a close-in customer and pedestrian base.

Encourages mixed-use development downtown.

LU 3-1 (LU 3-1.a.) Provides for an Urban Growth Boundary (UGB) outside of which no urban development would be permitted except in two existing developed areas (Industrial and Asti Exception areas).

LU 3-2 (LU 3-2.a, b and c.) Any expansion into hillside areas must be consistent with the Conservation, Design and Open Space element.

Requires development of a hillside ordinance and coordination with the County to assure that City hillside view policies are implemented in county approvals.

LU 4-4 (LU 4-4.b.) Encourages elimination of blighted and visually undesirable conditions and provides for abatement.

LU 6-1 (LU 6-1.a.) Ensures adequate water and wastewater capacities prior to granting entitlements for future development.

LU 6-3 Discourages development beyond areas with planned expansions of sewer, water and road systems.

CDO 1-1(CDO 1-1. a.) Limits urban development to the valley floor.

CDO 1-2 (CDO 1-2.a.) Reserves the conservation areas north and south of the City for agricultural uses.

CDO 1-3 (CDO 1-3.a.) Provides for land use designations outside of the Sphere of Influence to be used as guidelines for County review of projects.

CDO 2-2 (CDO 2-2.a.) Provides for transfer of development rights where a parcel has land both below and above the base of hill to preserve the hillside areas as visual open space.

CDO 2-3 (CDO 2-3.a.) Allows residential development above the base 262
10 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
of hill in certain circumstances if a property currently in the City limits does not have lands below the base of hill.

CDO 2-4 (CDO 2-4.a.) Discourages annexation of lands above the base of hill, except for lands described in Policy CDO 2-2 or where open space use is provided.

Impact 4.3.2 Implementation of the General
Plan may result in the
displacement of housing
and/or persons due to the
construction associated with
new development or
revitalization efforts.

LS
None required
LS
Impact 4.3.3 Development as guided by the
proposed project may result in
a jobs-housing imbalance. PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 1-2 (LU 1-2.a.) Infrastructure and land use policies are based on a maximum anticipated population of 12,000 residents and 4,700 housing units in 2025. Calls for a Growth Management program to allow an average of 75 units per year, with flexibility so that growth does not exceed 375 units in any five year period.

LU 1-3 (LU 1-3.a.) Provides a jobs/housing balance by encouraging new business in the City, by encouraging housing production for local employees and by targeting a portion of City housing funds to provide housing for essential employees who live and work in the City.

LU 7-1 (LU 7-1.a and b.) Requires amending the Housing Element to provide programs encouraging housing for farmworkers and local employees.

LS
Impact 4.3.4 Buildout under the proposed
General Plan, in conjunction
with development in Sonoma
and Mendocino Counties,
would include substantial
population, housing unit and
PCC
Plan policies and implementation measures which avoid or substantially reduce this impact:

See Impacts 4.3.1 and 4.3.3 LTCC
263
11 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
employment increases.

4.4 Hazards and Human Health
Impact 4.4.1 Implementation of the
proposed General Plan Update
may result in the potential to
expose persons to known and
unknown hazardous materials
contamination in areas
identified for development.

Additionally, the development
and activities anticipated in the
General Plan Update may
involve the routine transport,
use, or disposal of hazardous
materials, as well as the
potential for accidents
involving the release of
hazardous materials.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

PS 4-1 Where allowed by law, regulate the transportation of hazardous materials to minimize the potential for damage
Policy PS 6-1 (PS 6-1.a.) ProvidesfortheregularupdateoftheCity’s Multi-Hazard Emergency Plan.

Policy PS 6-2 (PS 6-2.a.) Supports theCounty’sHazardousWaste Management Plan.

Policy PS 6-3 (PS 6-3.a.) Utilizing State and County sources, maintains an inventory of sites with storage or use of significant quantities of hazardous materials.

Policy PS 6-4 (PS 6-4.a.) Requires a use permit and management plan for any commercial or industrial use involving significant quantities of hazardous materials.

Policy PS 6-5 (PS 6-5.a.) Tests the effectiveness of City emergency response procedures.

Policy PS 6-6 (PS 6-6.a.) Requires periodic emergency response exercises.

LS
Impact 4.4.2 Future development within the
Study Area could impair
implementation of the existing
emergency response plan.

LS
None required
LS
Impact 4.4.3 The City is located in
proximity to wildlands, so the
risk of wildland fires is high,
especially in the residential
hillside neighborhoods.

Additionally, emergency
vehicle access is constrained
PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

PS 3-1 Continue to utilize available information of wildland and structural fire hazards.

PS 3-2 Consider the severity of natural fire hazards, potential damage from wildland and structural fires, adequacy of fire protection and mitigation measures consistent with this element in the review of LS
264
12 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
by steep, winding, and narrow
roads.
projects.

PS 3-3 Require on-site detection and suppression, including automatic sprinkler systems, where available services do not provide acceptable levels of protection.

Policy PS 5-3 (PS 1-5) The City will require improvements to ensure emergency vehicle access as a condition of approval of proposed development.

Policy PS 5-4 Develop and implement City programs for fuel breaks, brush management, controlled burning, revegetation, and construction and maintenance of fire roads.

Policy PS 5-5 (PS 1-5) Incorporate and expand upon the fire safety standardsrecommendedinCDF’s“FireSafetyGuidelines”intoCity development standards and the Uniform Fire Code.

Policy PS 5-6 (PS 1-5) Require that fire/police facilities and equipment are adequate for proposed development before granting approval.

Policy PS 5-7 Require all new development in areas of potential fire hazards to provide for clearance around structures, the use of fire resistant ground cover materials, and require installation of automatic fire sprinklers.

Policy PS 5-8 (PS 1-5) Prepare and implement a Policy/Fire Department Master Needs Assessment.

Policy PS 5-11 Require development adjacent to hillside areas to minimize geologic and fire hazards. Require all new development, including single-family residential, to provide built-in fire protection (i.e. automatic fire sprinklers).

Impact 4.4.5 Land use and in-fill
development under the
proposed General Plan would
not result in cumulative
hazardous materials and
human health risks impacts.

LTCC
None Required
LTCC

4.5 Transportation and Circulation
265
13 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
Impact 4.5.1 It is projected that
implementation of the
proposed General Plan Update
would necessitate
improvements/modifications to
the intersections of Cloverdale
Boulevard/ South Interchange,
US 101 Southbound
Ramps/South Interchange, US
101 Northbound Ramps/
South Interchange and Asti
Road/South Interchange in
order to ensure adequate
circulation movements.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

CE 1-1 (CE 1-1.a, b.) Requires that the City develop and maintain the Circulation Plan network of freeway/highways, arterials, collectors and local streets to serve the functions they are intended to serve with adequate capacity and safety.

Policy CE 1-2 (CE 1-2.a, b and c.) Directs that the City plan and reserve in advance of development, the street alignments and building setbacks necessary to handle anticipated future growth and traffic requirements.

Policy CE 2-1 (CE 2-1.a, b and c.) States that the City shall strive to maintain mid-level of Service (LOS, D operation during the weekday morning and evening peak periods at intersections of an arterial street with either another arterial or a collector street and intersections of the two collector streets. Requires that the City evaluate traffic impacts of major development and provide signalization and reconfigurations as needed to achieve the LOS D.

LS

4.6 Air Quality
Impact 4.6.1 Project-related construction
and development over the
planning horizon of the GPU
associated with vegetation
removal, excavation, grading,
paving, operation of vehicles,
painting, and other
construction activities may
increase the potential for air
pollutants, thereby affecting air
quality.

PS
Adherence to the NSCAPCD regulations
LS
Impact 4.6.2 Negative air quality impacts
associated with long-term
emissions from projected
growth over the planning
PS
Adherence to the NSCAPCD regulations
LS
266
14 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
horizon of the GPU may result
in violations of ambient air
quality standards or create
significant nuisance impacts
(e.g., wood smoke).

Impact 4.6.3 Negative air quality impacts
associated with long-term
emissions from projected
growth over the planning
horizon of the GPU may result
in violations of ambient air
quality standards or create
significant nuisance impacts
(e.g., wood smoke).

PCC
Adherence to the NSCAPCD regulations
LTCC

4.7 Noise
Impact 4.7.1 Implementation of the
proposed General Plan
would result in the
adoption of the new goals,
policies and
implementation measures
designed to address noise.

This would be considered a
less than significant
impact.

LS
None Required
LS
Impact 4.7.2 Future development of
noise-sensitive land uses
within areas which are
PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

NE 1-1 (NE 1-1.a, b, and c.) All new development are required to be constructed to meet the adopted interior noise levels after a review of LS
267
15 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
either currently impacted
by noise or are in areas
which may be impacted
by noise in the future
would result in potentially
significant noise impacts
under the proposed
General Plan.
existing and potential future noise generation by allowable land uses and transportation corridors.

NE 1-2 (NE 1-2.a.) Establishes acceptable exterior noise levels to be met by new development, except school playgrounds during daytime use.

NE 1-4 (NE 1-4.a, NE 1-1.d,) Requires that noise from stationary sources such as music, machinery and pumps, shall be contained on the generating and receiving site at the property line. Required that multi-family, townhouse, mixed use and condominium projects shall use unit separation partitions and assemblies that guarantee interior noise levels
NE 1-6 (NE 1-6.b, c.) Requires the City to mitigate potential transportation noise, including high traffic streets and truck routes Impact 4.7.3 Future development of noiseproducing land uses near noise-sensitive land uses
would result in potentially
significant noise impacts under
the proposed General Plan.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

NE 1-1 (NE 1-1.a, b, and c.) All new development are required to be constructed to meet the adopted interior noise levels after a review of existing and potential future noise generation by allowable land uses and transportation corridors.

NE 1-2 (NE 1-2.a.) Establishes acceptable exterior noise levels to be met by new development, except school playgrounds during daytime use.

NE 1-4 (NE 1-4.a, NE 1-1.d.) Requires that noise from stationary sources such as music, machinery and pumps, shall be contained on the generating and receiving site at the property line. Required that multi-family, townhouse, mixed use and condominium projects shall use unit separation partitions and assemblies that guarantee interior noise levels.

NE 1-6 (NE 1-6.b, c.) Requires the City to mitigate potential transportation noise, including high traffic streets and truck routes.

LS
Impact 4.7.4 Implementation of the
proposed General Plan
would not result in
significant increases in
LS
None Required
LS
268
16 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
traffic noise levels at
existing noise-sensitive
areas within Cloverdale.

This is considered a less
than significant impact.

Impact 4.7.5 Implementation of the
proposed General Plan
may result in an increased
number of individuals
being exposed to aircraft
noise at individual site
locations. As the specific
site designs and locations
of future development are
not currently known, it is
conceivable that an
increased number of
receptors could be
exposed to aircraft noise
levels. As a result, this
impact is considered to be
potentially significant.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

NE 1-1 (NE 1-1.a, b, and c.) All new development are required to be constructed to meet the adopted interior noise levels after a review of existing and potential future noise generation by allowable land uses and transportation corridors.

NE 1-2 (NE 1-2.a.) Establishes acceptable exterior noise levels to be met by new development, except school playgrounds during daytime use.

NE 1-4.a. Requires adoption of noise standards.

PS 7-6 Discourages noise-sensitive development near the airstrip or under an overfly route.

PS 7-6.i. Discourages residential development beneath aircraft traffic pattern.

PS 7-6.j. Work with County and Airport Land Use Commission to ensure consistency in application of land use regulations within referral area.

LS
Impact 4.7.6 Implementation of the
proposed General Plan in
combination with regional
growth and traffic
conditions would increase
traffic-related noise along
area roadways. However,
LTCC
None Required
LTCC
269
17 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
because this increase
would be less than the
threshold of significance
for the project, this impact
is considered to be less
than cumulatively
considerable.

Impact 4.7.7 Future operations on the
NWP in the City of
Cloverdale would
introduce new noise
exposure into the
community. Development
associated with the
proposed General Plan
could introduce noisesensitive land uses into
areas affected by future
railroad noise. This could
produce a potentially
cumulatively considerable
impact.

PCC
Plan policies and implementation measures which avoid or substantially reduce this impact:

NE 1-1 (NE 1-1.a, b, and c.) All new development are required to be constructed to meet the adopted interior noise levels after a review of existing and potential future noise generation by allowable land uses and transportation corridors.

NE 1-2 (NE 1-2.a.) Establishes acceptable exterior noise levels to be met by new development, except school playgrounds during daytime use.

NE 1-4 (NE 1-4.a, NE 1-1.d.) Requires that noise from stationary sources such as music, machinery and pumps, shall be contained on the generating and receiving site at the property line. Required that multi-family, townhouse, mixed use and condominium projects shall use unit separation partitions and assemblies that guarantee interior noise levels.

NE 1-6 (NE 1-6.b, c) Requires the City to mitigate potential transportation noise, including high traffic streets and truck routes.

LTCC
Impact 4.7.8 Future, cumulative noise
exposure at Cloverdale
Municipal Airport is
expected to less than
cumulatively significant.

LTCC
None Required
LTCC
Impact 4.7.9 Implementation of the proposed
General Plan would
increase the number of
PCC
Plan policies and implementation measures which avoid or substantially reduce this impact:

NE 1-1 (NE 1-1.a, b, and c.) All new development are required to be LTCC
270
18 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
stationary noise sources in
the Planning Area and the
number of noise-sensitive
uses in the vicinity of
existing stationary noise
sources. This is considered
to be a potentially
cumulatively considerable
impact.
constructed to meet the adopted interior noise levels after a review of existing and potential future noise generation by allowable land uses and transportation corridors.

NE 1-2 (NE 1-2.a.) Establishes acceptable exterior noise levels to be met by new development, except school playgrounds during daytime use.

NE 1-4 (NE 1-4.a, NE 1-1.d.) Requires that noise from stationary sources such as music, machinery and pumps, shall be contained on the generating and receiving site at the property line. Required that multi-family, townhouse, mixed use and condominium projects shall use unit separation partitions and assemblies that guarantee interior noise levels.

NE 1-6 (NE 1-6.b, c.) Requires the City to mitigate potential transportation noise, including high traffic streets and truck routes.

4.8 Geology and Soils
Impact 4.8.1. Construction of proposed
improvements within areas
delineated on the most recent
Alquist-Priolo Earthquake Fault
Zoning Map issued by the
State Geologist or in areas
know to be directly above
active faults could expose
people or structures to
potential substantial adverse
effects, including the risk of
loss, injury or death due to
fault surface rupture.

However, as no Alquist-Priolo
Earthquake Fault Zones are
mapped within the project site,
and our literature review did
not suggest the presence of
active faults, we consider this
NI
None Required
NI
271
19 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
issue to have no impact on the
GPU Study Area.

Impact 4.8.2 Construction of proposed
improvements within the GPU
Study Area could expose
people or structures to
potential substantial adverse
effects, including the risk of
loss, injury or death due to
strong seismic ground shaking.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

PS 1-1 (PS 1-5) Geologic reports shall be required for all new development and redevelopment projects in areas with identified geologic hazards.

PS 1-2 (PS 1-5) Utilize studies of geologic hazards prepared during the development review process.

PS 1-3 (PS 1-5) New development is required to incorporate sound soil conservation practices and keep land grading to a minimum.

PS 1-4 (PS 1-5) Requires review of geologic reports prior to project approval.

PS 1-5 (PS 1-5) Requires adoption of revisions to the building code which increase resistance of structures to geologic hazards.

PS 1-6 (PS 1-5) Requires dynamic analysis of structural response to earthquake forces prior to approval of building permits.

PS 1-7 (PS 1-5) Encourages strong enforcement of state seismic safety requirements for dams, power plants, hospitals and schools.

PS 1-8 (PS 1-5) Measures to mitigate identified geologic hazards shall be incorporated into roads, public facilities and other public agency projects.

PS 5-1 (PS 1-5) Supports the adoption of the County Safety Element into City policy.

PS 5-9 (PS 1-5) Ensures that seismically unsafe buildings do not cause a serious threat to human safety.

PS 5-10 (PS 1-5) Requires study of the risk of seismically-induced liquefaction.

LS
Impact 4.8.3 Construction of proposed
improvements within the GPU
Study Area could expose
people or structures to
PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

PS 1-1 (PS 1-5 )Geologic reports shall be required for all new development and redevelopment projects in areas with identified LS
272
20 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
potential substantial adverse
effects, including the risk of
loss, injury or death due to
Seismic-related ground failure,
including liquefaction.
geologic hazards.

PS 1-2 (PS 1-5) Utilize studies of geologic hazards prepared during the development review process.

PS 1-3 (PS 1-5) New development is required to incorporate sound soil conservation practices and keep land grading to a minimum.

PS 1-4 (PS 1-5) Requires review of geologic reports prior to project approval.

PS 1-5 (PS 1-5) Requires adoption of revisions to the building code which increase resistance of structures to geologic hazards.

PS 1-6 (PS 1-5) Requires dynamic analysis of structural response to earthquake forces prior to approval of building permits.

PS 1-7 (PS 1-5) Encourages strong enforcement of state seismic safety requirements for dams, power plants, hospitals and schools.

PS 1-8 (PS 1-5) Measures to mitigate identified geologic hazards shall be incorporated into roads, public facilities and other public agency projects.

PS 5-1 (PS 1-5) Supports the adoption of the County Safety Element into City policy.

PS 5-9 (PS 1-5) Ensures that seismically unsafe buildings do not cause a serious threat to human safety.

PS 5-10 (PS 1-5) Requires study of the risk of seismically-induced liquefaction.

Impact 4.8.4 Construction of proposed
improvements within the GPU
Study Area could expose
people or structures to
potential substantial adverse
effects, including the risk of
loss, injury or death due to
landslides.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

PS 1-1 (PS 1-5 )Geologic reports shall be required for all new development and redevelopment projects in areas with identified geologic hazards.

PS 1-2 (PS 1-5) Utilize studies of geologic hazards prepared during the development review process.

PS 1-3 (PS 1-5) New development is required to incorporate sound soil conservation practices and keep land grading to a minimum.

PS 1-4 (PS 1-5) Requires review of geologic reports prior to project approval.

PS 1-5 (PS 1-5) Requires adoption of revisions to the building code LS
273
21 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
which increase resistance of structures to geologic hazards.

PS 1-6 (PS 1-5) Requires dynamic analysis of structural response to earthquake forces prior to approval of building permits.

PS 1-7 (PS 1-5) Encourages strong enforcement of state seismic safety requirements for dams, power plants, hospitals and schools.

PS 1-8 (PS 1-5) Measures to mitigate identified geologic hazards shall be incorporated into roads, public facilities and other public agency projects.

PS 5-1 (PS 1-5) Supports the adoption of the County Safety Element into City policy.

PS 5-9 (PS 1-5) Ensures that seismically unsafe buildings do not cause a serious threat to human safety.

PS 5-10 (PS 1-5) Requires study of the risk of seismically-induced liquefaction.

Impact 4.8.5 Development within the GPU
Study Area could result in
substantial soil erosion or the
loss of topsoil.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

PS 1-1 (PS 1-5 )Geologic reports shall be required for all new development and redevelopment projects in areas with identified geologic hazards.

PS 1-2 (PS 1-5) Utilize studies of geologic hazards prepared during the development review process.

PS 1-3 (PS 1-5) New development is required to incorporate sound soil conservation practices and keep land grading to a minimum.

PS 1-4 (PS 1-5) Requires review of geologic reports prior to project approval.

PS 1-5 (PS 1-5) Requires adoption of revisions to the building code which increase resistance of structures to geologic hazards.

PS 1-6 (PS 1-5) Requires dynamic analysis of structural response to earthquake forces prior to approval of building permits.

PS 1-7 (PS 1-5) Encourages strong enforcement of state seismic safety requirements for dams, power plants, hospitals and schools.

PS 1-8 (PS 1-5) Measures to mitigate identified geologic hazards shall be incorporated into roads, public facilities and other public agency projects.

LS
274
22 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
PS 5-1 (PS 1-5) Supports the adoption of the County Safety Element into City policy.

PS 5-9 (PS 1-5) Ensures that seismically unsafe buildings do not cause a serious threat to human safety.

PS 5-10 (PS 1-5) Requires study of the risk of seismically-induced liquefaction.

Impact 4.8.6 Future development within
some portions of the GPU
Study Area could be located
on a geologic unit or soil that
is unstable, or that would
become unstable as a result of
the project, and potentially
result in on- or off-site
landslide, lateral spreading,
subsidence, liquefaction or
collapse.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

PS 1-1 (PS 1-5 )Geologic reports shall be required for all new development and redevelopment projects in areas with identified geologic hazards.

PS 1-2 (PS 1-5) Utilize studies of geologic hazards prepared during the development review process.

PS 1-3 (PS 1-5) New development is required to incorporate sound soil conservation practices and keep land grading to a minimum.

PS 1-4 (PS 1-5) Requires review of geologic reports prior to project approval.

PS 1-5 (PS 1-5) Requires adoption of revisions to the building code which increase resistance of structures to geologic hazards.

PS 1-6 (PS 1-5) Requires dynamic analysis of structural response to earthquake forces prior to approval of building permits.

PS 1-7 (PS 1-5) Encourages strong enforcement of state seismic safety requirements for dams, power plants, hospitals and schools.

PS 1-8 (PS 1-5) Measures to mitigate identified geologic hazards shall be incorporated into roads, public facilities and other public agency projects.

PS 5-1 (PS 1-5) Supports the adoption of the County Safety Element into City policy.

PS 5-9 (PS 1-5) Ensures that seismically unsafe buildings do not cause a serious threat to human safety.

PS 5-10 (PS 1-5) Requires study of the risk of seismically-induced liquefaction.

LS
Impact 4.8.7 Certain development within
the GPU Study Area could be PS Plan policies and implementation measures which avoid orsubstantially reduce this impact: LS 275
23 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
located on expansive soil, as
defined by 2007 CBC, creating
substantial risks to life or
property.

PS 1-1 (PS 1-5 )Geologic reports shall be required for all new development and redevelopment projects in areas with identified geologic hazards.

PS 1-2 (PS 1-5) Utilize studies of geologic hazards prepared during the development review process.

PS 1-3 (PS 1-5) New development is required to incorporate sound soil conservation practices and keep land grading to a minimum.

PS 1-4 (PS 1-5) Requires review of geologic reports prior to project approval.

PS 1-5 (PS 1-5) Requires adoption of revisions to the building code which increase resistance of structures to geologic hazards.

PS 1-6 (PS 1-5) Requires dynamic analysis of structural response to earthquake forces prior to approval of building permits.

PS 1-7 (PS 1-5) Encourages strong enforcement of state seismic safety requirements for dams, power plants, hospitals and schools.

PS 1-8 (PS 1-5) Measures to mitigate identified geologic hazards shall be incorporated into roads, public facilities and other public agency projects.

PS 5-1 (PS 1-5) Supports the adoption of the County Safety Element into City policy.

PS 5-9 (PS 1-5) Ensures that seismically unsafe buildings do not cause a serious threat to human safety.

PS 5-10 (PS 1-5) Requires study of the risk of seismically-induced liquefaction.

Impact 4.8.8 Some portions within the GPU
Study Area may have soils
incapable of adequately
supporting the use of septic
tanks or alternative wastewater
disposal systems where sewers
are not available for the
disposal of wastewater.

NI
None Required
NI
276
24 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
Impact 4.8.9 Development within the GPU
Study Area will not result in
the loss of availability of a
known mineral resource that
would be of value to the
region and the residents of the
state.

NI
None Required
NI
Impact 4.8.10 Certain developments within
the GPU Study Area could
result in the loss of availability
of a locally important mineral
resource recovery site
delineated on a local general
plan, specific plan or other
land use plan.

LS
None Required
LS

4.9 Hydrology and Water Quality
Impact 4.9.1 Project-related vegetation
removal, excavation, grading,
and other construction
activities involving soil
disturbance may increase the
potential for erosion and
sedimentation, thereby
affecting water quality.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 3.2 (LU 3-2. a. and b) Requires adoption of a Hillside Ordinance.

All development must conform to Urban Growth Boundary
requirements.

CDO 7-1 (CDO 7-1.a, b and c.) Ensures drainage and runoff is not impairing the water quality of the Russian River. Requires buffers on each side from creeks and rivers.

LS
Impact 4.9.2 New development within the
proposed Study Area would
introduce sediments and
constituent pollutants typically
associated with urban
development into storm water
PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

CDO 7-1 (CDO 7-1.a, b and c.) Ensures drainage and runoff is not impairing the water quality of the Russian River. Requires buffers on each side from creeks and rivers.

PS 2-3. Requires preparation of an analysis of potential flood hazards LS
277
25 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
runoff, thereby degrading
downstream storm water
quality.
and drainage impacts associated with adopted land use plans for each major watershed in the City.

PS 2-4. Requires project applicants to analyze and mitigate drainage impacts.

Impact 4.9.3 Implementation of the
proposed General Plan Update
could result in the degradation
of groundwater quality
resulting from future land uses.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 6-1, (LU 6-1.a and b) Ensures adequate water and wastewater capacities or improvements are in place prior to granting approvals for new development.

PS 6-2 (PS 6-2.a) The County’sHazardousWasteManagementPlanis to be incorporated into City policies.

PS 6-3 (PS 6-3.a) Inventory of sites with storage or use of hazardous materials.

PS 6-4 (PS 6-4a and 1-5) Use permits will be required for uses involving significant amounts of hazardous materials. Studies from project developers will be required to ensure that major new development does not adversely affect groundwater quality.

LS
Impact 4.9.4 Implementation of the
proposed General Plan would
increase demand for water,
potentially requiring localized
increases in groundwater
production.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 1-2, (LU 1-2a) Development of Growth Management Plan.

LU 6-1 (LU 6-1.a, b, c and d) Ensures adequate water and wastewater capacities or improvements prior to granting approval for new development.

LU 6-4 (LU 6-4.a) Requires new development to fund processing costs and necessary infrastructure and service improvements.

LS
Impact 4.9.5 Implementation of the General
Plan Update could expose
development to potential
flooding.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

PS 2-1. Requires coordination with the Army Corps of Engineers, FEMA and other responsible agencies for flood hazard analysis and management activities.

PS 2-3. Requires comprehensive analysis of the potential flood hazards and drainage impacts associated with adopted land use plans for each LS
278
26 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
major watershed in the City.

PS 2-4. Project sponsors must analyze and mitigate drainage impacts and flood hazards for individual projects.

PS 2-5. Provides ways to deal with cumulative impacts to downstream flooding.

PS 2-6. Provides for use of 100 year flood event as the City measure of acceptable level of risk.

PS 2-7. Onsite and offsite flood related hazards are to be reviewed for all projects located within areas of known flood hazards.

PS 2-8. Minimizes increase in flooding and related damage.

PS 2-9. Development shall pay the costs for drainage facilities to handle the surface runoff from new development.

PS 2-10. Design and construction of drainage facilities are subject to review and approval of the Sonoma County Water Agency.

PS 2-11. Tentative and final subdivision maps are required to show areas subject to flooding.

PS 2-12. Priority is given to floodplain management over flood control structures.

PS 2-13. Project review includes risk of damage from flooding.

PS 2-14. Enforce City code requirements on construction in flood hazard areas.

PS 2-15. Avoid variances to building setbacks along streams and in 100 year flood plains without the review and approval of the Sonoma County Water Agency.

PS 2-16. Limits filling in areas which could retain significant amount of floodwater.

PS 2-17. Encourages timely completion and filing of inundation maps for all dams within Sonoma County.

PS 5-1. Supports the adoption of the County Safety Element into City policy.

4.10 Biological Resources
279
27 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
Impact 4.10.1: Land uses and development
consistent with the Draft
General Plan Update could
result in the loss of
populations or essential habitat
for special-status plant and
animal species.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

CDO 5-1 (CDO 5-1.a.) Considers dedicating a portion of lands adjacent to the Russian River to restore native grassland habitat for raptors.

CDO 6-2. Provides for preservation of natural vegetation.

CDO 7-1 (CDO 7-1.a.) Conservesand protectsthearea’snatural vegetation.

CDO 7-2 (CDO 7-2.b, c and d.) Conservesandprotectsthearea’s natural wildlife.

LS
Impact 4.10.2: Land uses and development
consistent with the Draft
General Plan Update could
result in the loss of riparian
habitat or other sensitive
natural communities.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

CDO 5-1 (CDO 5-1.a.) Considers dedicating a portion of lands adjacent to the Russian River to restore native grassland habitat for raptors.

CDO 6-1 (CDO 6-1.a.) Maintains and expands the tree canopy.

Requires tree protection measures and an urban forest plan.

CDO 6-2 Provides for preservation of natural vegetation.

CDO 6-3 Encourages retention of large or otherwise significant trees in residential, non-residential and open space areas.

CDO 7-1 (CDO 7-1.d.) Conservesandprotectsthearea’snatural vegetation.

CDO 7-2 Conservesandprotectsthearea’snaturalwildlife.

LS
Impact 4.10.3: Land uses and development
consistent with the Draft
General Plan Update could
result in the loss of
jurisdictional waters of the
U.S, including wetlands.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

CDO 5-1 (CDO 5-1.a.) Considers dedicating a portion of lands adjacent to the Russian River to restore native grassland habitat for raptors.

CDO 6-1 (CDO 6-1.a.) Maintains and expands the tree canopy.

Requires tree protection measures and an urban forest plan.

CDO 6-2 Provides for preservation of natural vegetation.

LS
280
28 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
CDO 6-3 Encourages retention of large or otherwise significant trees in residential, non-residential and open space areas.

CDO 7-1 (CDO 7-1.d.) Conservesandprotectsthearea’snatural vegetation.

CDO 7-2 Conservesandprotectsthearea’snaturalwildlife.

Impact 4.10-4: Land uses and development
consistent with the Draft
General Plan Update could
restrict aquatic or terrestrial
wildlife movement through
travel corridors. This would
be considered a significant
impact.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

CDO 5-1 (CDO 5-1.a.) Considers dedicating a portion of lands adjacent to the Russian River to restore native grassland habitat for raptors.

CDO 6-1 (CDO 6-1.a.) Maintains and expands the tree canopy.

Requires tree protection measures and an urban forest plan.

CDO 6-2 Provides for preservation of natural vegetation.

CDO 6-3 Encourages retention of large or otherwise significant trees in residential, non-residential and open space areas.

CDO 7-1 (CDO 7-1.d.) Conservesandprotectsthearea’snatural vegetation.

CDO 7-2 Conservesandprotectsthearea’snaturalwildlife.

LS
Impact 4.10.5: Proposed policies in the Draft
General Plan Update that
affect biological resources may
differ from local policies and
ordinances currently in effect.

However, potential conflicts
would be addressed by the
revisions of the implementing
ordinances to ensure that they
conform to the proposed
policies.

LS
Plan policies and implementation measures which avoid or substantially reduce this impact:

CDO 5-1 (CDO 5-1.a.) Considers dedicating a portion of lands adjacent to the Russian River to restore native grassland habitat for raptors.

CDO 6-1 (CDO 6-1.a.) Maintains and expands the tree canopy.

Requires tree protection measures and an urban forest plan.

CDO 6-2 Provides for preservation of natural vegetation.

CDO 6-3 Encourages retention of large or otherwise significant trees in residential, non-residential and open space areas.

CDO 7-1 (CDO 7-1.d.) Conservesandprotectsthearea’snatural vegetation.

CDO 7-2 Conservesandprotectsthearea’snaturalwildlife.

LS
281
29 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
Impact 4.10-6: Land uses and development
consistent with the Draft
General Plan Update would
not conflict with any adopted
Habitat or Natural Community
Conservation Plans.

LS
None Required
LS
Impact 4.10.7 The proposed project, in
combination with other
reasonably foreseeable
projects, would result in direct
mortality and loss of habitat for
special-status species, and
waters of the U.S., including
wetlands.

PCC
Plan policies and implementation measures which avoid or substantially reduce this impact:

CDO 5-1 (CDO 5-1.a.) Considers dedicating a portion of lands adjacent to the Russian River to restore native grassland habitat for raptors.

CDO 6-1 (CDO 6-1.a.) Maintains and expands the tree canopy.

Requires tree protection measures and an urban forest plan.

CDO 6-2 Provides for preservation of natural vegetation.

CDO 6-3 Encourages retention of large or otherwise significant trees in residential, non-residential and open space areas.

CDO 7-1 (CDO 7-1.d.) Conservesandprotectsthearea’snatural vegetation.

CDO 7-2 Conservesandprotectsthearea’snaturalwildlife.

LTCC

4.11 Cultural and Paleontological Resources
Impact 4.11.1 Adoption of the City of
Cloverdale General Plan
Update could result in the
potential disturbance of
cultural resources (i.e.,
prehistoric sites, historic
sites, and isolated artifacts)
and human remains. This
impact is considered
PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 3-4 (LU 3-4.b.) Conserves/preserves historic buildings and the character of the older parts of town using conservation and form based zoning ordinances.

CDO 3-5 (CDO 3-5.a.) Preserves the traditional appearance of the downtown by identifying and allowing flexibility in planning standards for structures built prior to 1939.

CDO 4-1 (CDO 4-1.a and b.) Measures for conserving/preserving LS
282
30 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
potentially significant. historic buildings and the character of the older parts of town.

CDO 4-2 (CDO 4-2.a and b.) Discusses preservation of remaining prehistoric camps, villages and use sites.

CDO 4-3 (CDO 4-3.a, b and c.) Identification of historically significant structures or groups of structures for educational purposes. Requires the development of standard conditions of approval for CEQA and project review for preservation of paleontological resources.

CDO 4-4. Preserves paleontological resources.

Impact 4.11.2 Adoption of the City of
Cloverdale General Plan
Update, including the “no
project alternative, or
Alternative 1 or 2, could result
in the potential disturbance of
paleontological resources (i.e.,
fossils and fossil formations).

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

CDO 4-3.a. Requires the development of standard conditions of approval for CEQA and project review for preservation of paleontological resources.

CDO 4-4. Preserves paleontological resources.

LS
Impact 4.11.3 Adoption of the City of
Cloverdale General Plan
Update, including the “no
project” alternative, or
Alternative 1 or 2, in addition
to existing, approved,
proposed and foreseeable
development in the City of
Cloverdale and Sonoma
County could result in
cumulative impacts to
prehistoric and historic
resources, and human remains
in the region.

PCC
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 3-4 (LU 3-4.b.) Conserves/preserves historic buildings and the character of the older parts of town using conservation and form based zoning ordinances.

CDO 3-5 (CDO 3-5.a.) Preserves the traditional appearance of the downtown by identifying and allowing flexibility in planning standards for structures built prior to 1939.

CDO 4-1 (CDO 4-1.a and b.) Measures for conserving/preserving historic buildings and the character of the older parts of town.

CDO 4-2 (CDO 4-2.a and b.) Discusses preservation of remaining prehistoric camps, villages and use sites.

CDO 4-3 (CDO 4-3.a, b and c.) Identification of historically significant structures or groups of structures for educational purposes. Requires the development of standard conditions of approval for CEQA and project review for preservation of paleontological resources.

LTCC
283
31 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
CDO 4-4. Preserves paleontological resources.

Impact 4.11.4 Adoption of the City of
Cloverdale General Plan
Update, including the “no
project” alternative, or
Alternative 1 or 2, in addition
to existing, approved,
proposed and foreseeable
development in the City of
Cloverdale and Sonoma
County could result in
cumulative impacts to
paleontological resources in
the region.

PCC
Plan policies and implementation measures which avoid or substantially reduce this impact:

CDO 4-4. Preserves paleontological resources.

LTCC

4.12 Public Services and Utilities
Impact 4.12.1 Implementation of the
proposed General Plan could
increase the demand for fire
protection.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

PS 3-1 (PS 1-5) Utilize available information on wildland and structural fire hazards.

PS 3-2 Consider fire hazards and adequacy of fire protection in the review of projects.

PS 3-3 Requires on-site detection and suppression where available services do not provide acceptable levels of protection.

PS 4-1 Regulate the transport of hazards materials to minimize the potential for damage.

PS 5-1 Supports the adoption of the County Safety Element into City policy.

PS 5-2 (PS 1-5) Adopt revisions to the Fire and Building Codes.

PS 5-3 (PS 1-5) Ensure adequacy of roadways for emergency vehicle access.

PS 5-4 Develop City programs for fire roads.

LS
284
32 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
PS 5-5 (PS 1-5) IncorporateCDF’sFireSafetyGuidelinesintoCity standards.

PS 5-6 (PS 1-5) Addresses adequacy of fire/police facilities and equipment.

PS 5-7 Requires a police/fire department master needs assessment.

PS 5-9 Addresses seismically unsafe buildings.

PS 5-11 Minimize geologic and fire hazards; new development required to provide built-in fire protection.

Impact 4.12.2 Implementation of the
proposed General Plan Update
could result in an increased
demand for law enforcement
services.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 6-2 (LU 6-2.a.) Requires infrastructure audits if development exceeds 200 units per year.

LU 6-4 (LU 6-4.a.) New development will fund processing costs and necessary infrastructure or services.

LS
Impact 4.12.3 Land uses and development
under the proposed City of
Cloverdale General Plan
Update would increase
population and subsequent
student enrollment in the
district’s schools and may
require new or expanded
school facilities to serve the
increased demand.

LS
None Required
LS
Impact 4.12.4 Land uses and development
under the proposed City of
Cloverdale General Plan
Update would increase the
demand for emergency
services in the Study Area.

LS
None Required
LS
285
33 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
Impact 4.12.5 Implementation of the
proposed General Plan Update
could increase population and
increase the demand for solid
waste disposal facilities. This is
a potentially significant
impact.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 9-1 (LU 9-1.a, b.) Maintains waste management contracts and participation in countywide waste disposal facilities. LS Impact 4.12.6 Implementation of the
proposed General Plan Update
could increase population and
subsequently increase the
demand for park and
recreation related services.

LS
None Required
LS
Impact 4.12.7 Implementation of the
proposed General Plan Update
would increase the demand for
electric, telephone, and natural
gas services.

LS
None Required
LS
Impact 4.12.8 Implementation of the
proposed General Plan Update
would increase the demand for
wastewater collection and
treatment.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 6-1 (LU 6-1.a) Ensures adequate water and wastewater capacities prior to project approvals.

LU 6-2 (LU 6.2.a) Provides for adequate public facilities and service for community needs.

LU 6-3 (LU 6-2.a.) Discourages development beyond areas with planned expansion of services.

LU 6-4 (LU 6-4.a.) Requires new development to fund infrastructure improvements required by new development.

LS
Impact 4.12.9.a Implementation of the LTCC None Required LTCC 286
34 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
proposed General Plan Update
along with potential
development in the
surrounding area could
contribute to the cumulative
demand for fire protection and
emergency medical services.

Impact 4.12.9.b Implementation of the
proposed General Plan Update
along with potential
development in the
surrounding area could result
in the increase of the demand
for cumulative law
enforcement services.

LTCC
None Required
LTCC
Impact 4.12.9.c Implementation of the
proposed General Plan Update
as well as potential
development in the
surrounding area could result
in cumulative public school
impacts.

LTCC
None Required
LTCC
Impact 4.12.9.d Implementation of the
proposed General Plan Update
along with potential
development in the
surrounding region would
result in cumulative electric,
telephone, and natural gas
service impacts.

LTCC
None Required
LTCC
287
35 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
Impact 4.12.9.e Implementation of the
proposed General Plan Update
would result in cumulative
wastewater impacts.

LTCC
None Required
LTCC
Impact 4.12.9.f Implementation of the
proposed General Plan Update
along with potential
development in surrounding
communities would result in
cumulative solid waste
impacts. This impact is
considered less than
cumulatively considerable
LTCC
None Required
LTCC

4.13 Visual Resources and Aesthetics
Impact 4.13.1 Implementation of the
proposed General Plan Update
could result in the alteration of
scenic resources.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 1-5 (LU 1-5.a and b.) Provides for comments to the County on lands adjacent to the City limits.

LU 3-1 (LU 3-1.a.) Provides for development of an Urban Growth Boundary.

LU 3-2, (LU 3-2.a, b and c.) Requires expansion into hillside areas to eliminate or minimize visual, access or lighting impacts.

LU 3-3 (LU 3-3.a.) Provides for expansion of tree canopy within and outside the developed areas of the City.

LU 4-3 (LU 4-3.a.) Strives to improve the appearance of formula or chain businesses.

CDO 1-1 (CDO 1-1.a.) Limits development to the valley floor.

CDO 2-1 (CDO 2-1.a.) Adoption of a hillside ordinance.

CDO 2-2 (CDO 2-2.a.) Allows for transfer of development rights to below the base of hill.

CDO 2-3 (CDO 2-3.a.) Allows development above base of hill in LS
288
36 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
certain circumstances.

CDO 2-5 (CDO 2-5.a.) Requires roads serving hillside development to follow natural contours.

CDO 3-2 (CDO 3-2.a.) Addresses pedestrian oriented downtown.

CDO 3-4 (CDO 3-4.a.) Preservation of traditional appearance of existing houses along Cloverdale Boulevard north of downtown.

CDO 3-5 (CDO 3-5.a.) Preservation of residential areas around the downtown.

CDO 3-6 (CDO 3-6.a.) Requires new single family development to resemble past representative development.

CDO 3-7 (CDO 3-7.a.) Provides for upgrading the appearance of Cloverdale Boulevard.

CDO 3-8 (CDO 3-8.a.) Provides for transit oriented development around the rail station.

CDO 3-10 (CDO 3-10.a.) Provides for street trees and landscaping along major streets.

CDO 3-11 (CDO 3-11.a.) Provides for elimination of sign blight.

CDO 3-12 (CDO 3-12.a.) Allows drive-through restaurants only in the South Interchange area.

CDO 3-13 (CDO 3-13.a.) Provides for elimination of overhead utility lines.

CDO 5-1 (CDO 5-1.a.) Consideration of dedication of lands adjacent to the Russian River for native grassland habitat for raptors.

CDO 6-1 (CDO 6-1.a.) Expansion of tree canopy; preparation of tree preservation ordinance.

CDO 6-3 (CDO 6-1.a.) Addresses preservation of trees.

CDO 6-4 (CDO 6-1.a. and 6-4.b.) Provision of trees for shade in new development.

CDO 6-5 (CDO 6-5.a.) Provides for street trees.

CDO 6-6 (CDO 6-5.a.) Requires preparation of a street tree plan.

Impact 4.13.2 Implementation of the
proposed General Plan Update
could result in the alteration of
LS
None Required
LS
289
37 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
visual character.

Impact 4.13.3 Implementation of the
proposed General Plan could
result in an increase of
daytime glare and/or nighttime
lighting. The potential
increases in daytime glare
sources and nighttime lighting
levels could have an adverse
affect on adjacent areas and
land uses relative to scenic
resources and visual character.

PS
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 3-5 (LU 3-5.a.) Strives to minimize the impacts of urban lighting.

UL 1-1 (UL 1-1.a, b and c.) Requires new development to provide minimum lighting levels necessary for safety.

UL 1-2 (UL 1-1.a, b and c.) Limits light spillage off site.

UL 1-3 (UL 1-1.a, b and c.) Reduces light glare from businesses at the south interchange.

UL 1-4 (UL 1-1.a, b and c.) Eliminates excess lighting from signs.

UL 1-5 (UL 1-1.b.) Revises street lighting with down lights.

UL 1-6 (UL 1-1.a, b and c.) Allows for amortization program for high intensity lighting and signs.

UL 1-7 (UL 1-1.a, b and c.) Disallows use of reflective building materials.

LS
Impact 4.13.4 Implementation of the
proposed General Plan would
not result in the significant
conversion of the Study Area’s
undeveloped lands, visual
resources, visual character,
and/or Urban lighting
characteristics.

LTCC
None Required
LTCC

5.0 Cumulative Impacts - Green House Gas & Climate Change Impact 5.22 Buildout of the proposed
General Plan Update may
result in a cumulative
increase of greenhouse
gas emissions, including
CO2. Because technical
and regulatory
S/CC
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 1-1 c. Allow limited numbers of small lots or cluster housing within single-family areas in order to provide variety and affordable housing.

LU 1-6. (LU 1-6.a and b.) Provides recreation to match the population.

LU 2-2 (LU 2-2.a.) Retain existing and encourage new residential uses around the downtown to preserve a close-in customer and pedestrian SU
290
38 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
uncertainties related to
State and national
programs make it
impossible to determine
the precise extent and
effect of any local
increase in emissions from
General Plan Buildout, the
proposed project is
considered to make a
cumulatively considerable
incremental contribution to
this significant cumulative
impact.
base.

LU 3-4 (LU 3-2.b.) Requires adoption of a Hillside Ordinance. All development must conform to Urban Growth Boundary requirements.

LU 7-1 (LU 7-1-.b.) Requires amending the Housing Element to provide programs encouraging housing for farmworkers and local employees.

CE 1-3 (CE 1-3.b.) Design street systems in residential areas to minimize through traffic and encourage bicycling and walking.

CE 2-2 (CE 2-2.a.) Creates a country road appearance for specific streets with narrow pavement, shade trees and protected bicycle and pedestrian ways.

CE 3-1 (CE 3-1.a, b and c) Provides an extensive network of pedestrian and bicycle pathways.

CE 3-2 (CE 3-2.a, b and c.) Provides for sidewalks.
3-3 (CE 3-3.a.) Provides for shade trees along pedestrian routes.

CE 4-1 (CE 4-1.a –d) Supports Passenger rail service.

CE 4-2 (CE 4-2.a.) Provides for plan to coordinate access to rail station CE 4-3 (CE 4-3.a.) Supports local bus service.

CE 4-4. (CE 4-3.a.) Encourages ride sharing.

PR 1-2 (PR 1-2.a.) Addresses parkland needs.

PR 1-3 (PR 1-3.a.) Acquisition of parklands.

PR 1-4 (PR 1-4.a.) Provides for open space and trails on hillside areas above base of hill.

PR 1-5, PR 1-5.a and b.) Provides for looped trail systems.

CDO 3-8 (CDO 3.8.a.) Provides for transit oriented development around passenger rail station.

CDO 6-1 (CDO 6-1.a.) Expands the tree canopy.

CDO 6-2 Protects natural vegetation
CDO 6-3 Encourages retention of significant trees.

CDO 6-4 (CDO 6-4.b.) Provides for mix of trees for shade and cooling.

CDO 6-5 (CDO 6-5.a.) Provides for street trees.

CDO 6-6 Preparation of a street tree plan.

DO 6-7 Requires native landscaping.

CDO 8-1 (CDO 8-1.a.) Provides for energy efficiency in City operations.

CDO 8-2 (CDO 8-2.a and b.) encourages energy can resource 291
39 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
efficiency in private construction.

CDO 8-3 (CDO 8-3.a.) Preparation of Climate Action Plan.

Impact 5.23 Long-term cumulative
impacts of global climate
change may result in
potential decrease in
water supply, increase in
air pollutants and increase
in health hazards. Because
technical and regulatory
uncertainties related to
State and national
programs make it
impossible to determine
the precise extent and
effect of any local
increase in greenhouse
gas emissions from General
Plan Buildout on this
impact, the proposed
project is considered to
make a cumulatively
considerable incremental
contribution to this
significant cumulative
impact.

S/CC
Plan policies and implementation measures which avoid or substantially reduce this impact:

LU 1-1 c. Allow limited numbers of small lots or cluster housing within single-family areas in order to provide variety and affordable housing.

LU 1-6. (LU 1-6.a., b.) Provides recreation to match the population.

LU 2-2 (LU 2-2.a.) Retain existing and encourage new residential uses around the downtown to preserve a close-in customer and pedestrian base.

LU 3-4 (LU 3-2.b.) Requires adoption of a Hillside Ordinance. All development must conform to Urban Growth Boundary requirements.

LU 7-1 (LU 7-1-.b.) Requires amending the Housing Element to provide programs encouraging housing for farmworkers and local employees.

CE 1-3 (CE 1-3.b) Design street systems in residential areas to minimize through traffic and encourage bicycling and walking.

CE 2-2 (CE 2-2.a) Creates a country road appearance for specific streets with narrow pavement, shade trees and protected bicycle and pedestrian ways.

CE 3-1 (CE 3-1.a, b and c) Provides an extensive network of pedestrian and bicycle pathways.

CE 3-2 (CE 3-2.a, b and c.) Provides for sidewalks.
3-3 (CE 3-3.a.) Provides for shade trees along pedestrian routes.

CE 4-1 (CE 4-1.a –d) Supports Passenger rail service.

CE 4-2 (CE 4-2.a.) Provides for plan to coordinate access to rail station CE 4-3 (CE 4-3.a.) Supports local bus service.

CE 4-4. (CE 4-3.a.) Encourages ride sharing.

PR 1-2 (PR 1-2.a.) Addresses parkland needs.

PR 1-3 (PR 1-3.a.) Acquisition of parklands.

PR 1-4 (PR 1-4.a.) Provides for open space and trails on hillside areas above base of hill.

PR 1-5, PR 1-5.a and b.) Provides for looped trail systems.

CDO 3-8 (CDO 3.8.a.) Provides for transit oriented development around passenger rail station.

SU
292
40 Impact
Significance without
General Plan Policies/
Actions and/or Mitigation
Proposed General Plan Policies/Implementation Actions and Mitigation Measure
Resulting
Level of
Significance
CDO 6-1 (CDO 6-1.a.) Expands the tree canopy.

CDO 6-2 Protects natural vegetation
CDO 6-3 Encourages retention of significant trees.

CDO 6-4 (CDO 6-4.b.) Provides for mix of trees for shade and cooling.

CDO 6-5 (CDO 6-5.a.) Provides for street trees.

CDO 6-6 Preparation of a street tree plan.

DO 6-7 Requires native landscaping.

CDO 8-1 (CDO 8-1.a.) Provides for energy efficiency in City operations.

CDO 8-2 (CDO 8-2.a and b.) encourages energy can resource efficiency in private construction.

CDO 8-3 (CDO 8-3.a.) Preparation of Climate Action Plan. 293
41 CHAPTER 1
Introduction
During the public review process for the City of Cloverdale General Plan Update Draft Environmental Impact Report (Draft EIR), the City received a number of written and oral comments from public agencies, organizations, and individuals related to this document.

During the public review period for this document, the City held a public workshop on the Draft EIR and the updated General Plan document.

This Final EIR includes all comments made on the Draft EIR during public review of the Draft EIR and provides written responses to these comments. The required contents of a Final EIR and the certification process are described below. The information in this document will be presented to the City of Cloverdale Planning Commission and City Council for certification and will be used as part of their review, consideration, and approval of the General Plan Update project.

California Environmental Quality Act Compliance
The Final EIR for the Proposed Project has been prepared in accordance with the Title 14, California Code of Regulations, Chapter 3, ("CEQA Guidelines" or "Guidelines") for implementation of CEQA. Specifically, Section 15132 of the Guidelines requires that a Final EIR consist of the following:
•TheDraftEIRorarevisionofthedraft;
•Commentsandrecommendations received on the Draft EIR;
•Alistofpersons,organizations,andpublicagenciescommentingontheDraftEIR; •Theresponsesoftheleadagencytosignificantenvironmentalconcernsraisedinthe review and consultation process; and
•Any other information added by the lead agency.

The Draft EIR for the Proposed Project was prepared in compliance with CEQA and the CEQA Guidelines. As described in the Guidelines, Section 15121(a), an EIR is a public information document that assesses the potential environmental effects of a proposed project, as well as identifies mitigation measures and alternatives to the project that could reduce or avoid adverse environmental impacts. CEQA Guidelines require that state and local government agencies consider the environmental consequences of projects over which they have discretionary authority.

Consequently, the EIR is an information document used in the planning and decisionmaking process. It is not the purpose of an EIR to recommend either approval or denial ofaproject.TheproceduresrequiredbyCEQA“… are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects." (Public Resources Code Section 21002.) 294
42 Asageneralrule,“publicagenciesshouldnotapproveprojectsasproposedifthereare feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects.”(Ibid.) However, in the event specific economic, social, or other conditions make infeasible such project alternatives or such mitigation measures, individual projects may be approved in spite of one or more significant effects thereof. ”(Ibid.)
Theleadagencymust“certify”theFinalEIR.AccordingtotheCEQAGuidelines, “certification”consistsofthreeseparatesteps.Priortoapprovingaproject,thelead agency (in this case the City of Cloverdale) shall certify that: (1) the Final EIR has been completed in compliance with CEQA; (2) the Final EIR was presented to the decisionmaking body of the lead agency and the body has reviewed and considered the information contained in the Final EIR prior to approving the project; and (3) that the FinalEIRreflectstheleadagency’sindependentjudgmentandanalysis. (Guidelines, Section 15090(a); see, also, Public Resources Code Section 21082.1(c)(3).) Under CEQA, a lead agency must make certain determinations before it can approve or carry out a project if the EIR reveals that the project will result in one or more significant environmental impacts. First, before approving a project for which a certified Final EIR has identified significant environmental effects, the lead agency must make one or more of the following written findings for each of the identified significant impacts, accompanied by a brief explanation of the rationale for each finding: include (1) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the Final EIR.
(2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. (3) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the Final EIR. (Guidelines Section 15091(a).)
Second, if there remain significant environmental effects even with the adoption of all feasible mitigation measures or project alternatives,theagencymustadopta“statement ofoverridingconsiderations”beforeitcanproceedwiththeproject.Thestatementof overriding considerations must be supported by substantial evidence in the record (Guidelines Sections 15092(b)(2)(B) and 15093). These overriding considerations include the economic, legal, social, technological, or other benefits of the proposed project. The lead agency must balance these potential benefitsagainsttheproject’s unavoidable environmental effects when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits of a proposed project outweigh the unavoidable adverse environmental effects, the lead agency may consider theadverseenvironmentalimpactstobe“acceptable.”(Guidelines Section 15093(a).) 295
43 These benefits should be set forth in the statement of overriding considerations, and may be based on the Final EIR and/or other information in the record of proceedings. (Guidelines Section 15093(b).)
CEQA Final EIR Process
The Draft EIR for the Proposed Project was submitted to the State Clearinghouse (SCH# 2007082143) and released for public and agency review pursuant to CEQA regulations.

The public review and comment period for the Draft EIR closed on December 8, 2008. A notice of availability was circulated consistent with CEQA.

Upon additional review of the Proposed Project and the Final EIR, the City of Cloverdale Planning Commission, at a public hearing, will recommend to the City Council whether to certify the EIR and whether to approve or deny the project. The City Council will then review the Proposed Project, Final EIR, recommendations of the Planning Commission and Community Development Department staff, and public testimony to decide whether to certify the Final EIR and whether to approve or deny the project.

Organization of the Document
This Final EIR comprises five chapters that meet the requirements of the CEQA Guidelines, as outlined above. The five chapters that make up this Final EIR are as follows:
•“ExecutiveSummary”- provides a brief project description and presents a summary tableoftheProposedProject’senvironmentaleffects.
•Chapter 1 - “Introduction”provides a brief overview of the Proposed Project, environmental compliance activities conducted to date, and outlines the contents and organization of the Final EIR.
•Chapter 2 - “CommentsontheDraftEIR”provides a list of commenting agencies, organizations, and individuals and copies of their oral and written comments (coded for reference).
•Chapter 3 - “ResponsetoCommentsontheDraftEIR”provides the lead agency responses to the comments identified in Chapter 2.
•Chapter 4 - “MinorChangesandEditstotheDraftEIR”includes corrections and/or additions to the Draft EIR text made since publication of the Draft EIR. These changes to the Draft EIR are indicated by revision marks (underline for new text and strikeout for deleted text).
•Chapter 5 - “ReportPreparation”provides a list of the individuals involved in the preparation of the Final EIR. As noted in Guidelines Section 15132(a), , the Draft EIR for the Proposed Project makes up part of this Final EIR. A copy of the Draft EIR is on file at the City of Cloverdale Community Development Department located at 126 N. 296
44 CloverdaleBoulevard,Cloverdale,CA.AcopycanalsobeviewedbyvisitingtheCity’s web site at http://www.cloverdale.net/resources.asp.
297
45 CHAPTER 2
Comments on the Draft EIR
Introduction - This chapter provides a list of all oral and written comments received during the public review period.

List of Comments Received
The public agencies, organizations, and individuals that submitted comments on the Draft EIR are listed below in Table 2-1. As shown in the table, each comment has been designated by a specific letter and number that will be used to refer to particular comments and responses.

Comment Letters
Each of the comments identified above are provided on the following pages, with individual responses to each of the comments providedinChapter3“Responsesto CommentsontheDraftEIR”.Thecontentofeachcomment has been divided into individual comments. To assist in referencing comments and responses, each comment has been assigned a number and each individual topic within a comment has been assigned a corresponding number. The responses to each comment are formatted in a similar fashion.

Where changes to the Draft EIR text result from these responses to comments, those changesarepresentedinChapter4“MinorChangesandEditstotheDraftEIR”ofthis document, with changes shown by underlining new text (e.g., new text) and striking out text to be deleted (e.g., deleted text). Comments which present opinions about the project unrelated to environmental issues or which raise issues not directly related either to the substance of the Draft EIR or to environmental issues are noted without a detailed response.

The comments on the Draft EIR, the responses thereto and the text changes to the Draft EIR do not raiseany“significantnewinformation”withinthemeaningofPublic Resources Code Section 21092.1 and CEQA Guidelines Section 15088.5; therefore, the City of Cloverdale, as the CEQA Lead Agency, directed that a Final EIR be prepared rather than recirculating the Draft EIR.
298
46 NOTE. ALL MNSRW COMMENTS ACCEPTED FOR CHAPTER 2
TABLE 2-1

COMMENTS RECEIVED ON THE DRAFT EIR
Commenter Date Received Comment Code
Public Agencies
Department of Fish and Game November 12, 2008 A1
Department of Transportation December 8, 2008 A2
Sonoma LAFCO November 20, 2008 A3
Sonoma Co. PRMD January 9, 2009 A4
State RWQCB December 8, 2008 A5
Organizations
Citizens for a UGB December 22, 2008 O1
Greenbelt Alliance December 9, 2008 O2
Individuals
Roz Katz November 3, 2008 I1
James Wagele December 8, 2008 I2
John Mackie, Esq., on behalf
of Redwood Empire Sawmills
December 9, 2008 I3
Robert Sexton, on behalf of
Tyris/Alexander Valley Resort
December 5, 2008 I4
John Doble November 5, 2008 I5
Diane Bartleson November 5, 2008 I6
Dick Schwartz November 5, 2008 I7
Melanie Bagby November 5, 2008 I8
Russ Peihl November 5, 2008 I9
299
47 A1
300
48 301
49 302
50 A2-3
A2-4
A2-5
303
51 A3
A3-1
A3-2
304
52 A3-3
305
53 306
54 A3-4
307
55 308
56 A4
A4-1
A4-2
A4-3
A4-4
309
57 A4-5
A4-6
310
58 311
59 A5
A5-1
312
60 A5-1
continued
A5-2
313
61 A5-3
A5-4
A5-5
314
62 A5-6
A5-7
A5-8
315
63 A5-8
continued
A5-9
316
64 A5-10
A5-11
317
65 A5-12
318
66 319
67 O6
O1-1
O1-2
320
68 Greenbelt Alliance
December 9, 2008
Bruce Kibby
Community Development Director
City of Cloverdale
P.O. Box 217
Cloverdale, CA 95425
Re: Draft General Plan Environmental Impact Report
Mr. Kibby:

We have reviewed the proposed General Plan and the draft General Plan Environment Impact Report (DEIR) and have several comments. First, we recognize that the City has spent a great deal of time and effort on preparing and distributing a well thought-out draft of the General Plan and DEIR. In order that these documents be complete to the greatest extent possible, we offer the following questions and recommendations around the DEIR’sanalysis.Asaself-mitigating General Plan, mitigations must be adopted as policies into the General Plan to be valid. As such, we suggest policies to be adopted in the General Plan by way of suggesting acceptable mitigations for impacts identified in the General Plan.

Urban Growth Boundary
While the GeneralPlancallsfortheadoptionofanurbangrowthboundary,theDEIR’s analysis does not include an analysis of the impacts or mitigating benefits of adopting the urbangrowthboundary.WefinditproblematicthattheDEIR’sanalysisreliesona potential line, yet the General Plan does not actually identify the urban growth boundary, nor allowed uses inside and outside the line. Nor does the General Plan and DEIR identify the urban growth boundary as a Planning Area in Table 3.0-2 We are also concernedthattheCity’sproposedmethodofadoptionoftheurbangrowth boundary fails to mitigate possible inconsistencies with the General Plan that may occur through adoption of an ordinance. Under California State planning regulation, the General Plan is the top-tier planning document. Land use policies adopted into the General Plan supersede all other ordinances, which are subservient to them. Based on several court cases, and based on principles of General Plan consistency outlined in the Government Code (Gov. Code 65300 et seq.), we conclude that an ordinance adopted by voters must be included into the General Plan in order to ensure consistency. While this may be possible, we suggest that the City adopt the urban growth boundary language O2
02 O2
O2
321
69 directly into the General Plan during this process in order to avoid potential consistency conflicts in the future.

Furthermore,aUGBadoptedbyordinancealone,evenifitis“lockedin”undervoter control, could be rendered ineffective through passage of a General Plan amendment in the future. Thus, the General Plan and DEIR may not rely on the existence of the urban growth boundary as a mitigation for impacts on farmlands and natural areas inside the Sphere of Influence but outside the proposed urban growth boundary. The only way to use the urban growth boundary as a mitigation is to adopt language into the General Plan that spells out allowed uses inside and outside the line, and that includes the line on the Land Use Map. Will the urban growth boundary be adopted into the General Plan with language specifying allowed and disallowed uses outside the line? In order for the UGB to carry weight in the General Plan, and to maintain General Plan consistency, a map must be included in the General Plan that shows where the intended UGB line lies. This map may use a hillside slope descriptor for the western edge of the UGB, but must show visually in an understandable format where the line will lie. To be an effective UGB, the UGB policies and the General Plan's UGB map should then be referred to the voters after the General Plan is adopted. Will the General Plan include a map of the intended UGB line?
Conservation Areas
We were confused by the dramatic increase in conservation feature lands included within the General Plan study area, as seen in Table 3.0-7. We are concerned that the DEIR lacksanalysisoftheimpactsofaddingthese“conservation”areastothesphereof influence for an urban area. Nor do General Plan policies adequately control for potential development that might occur in these areas in the future once they are added to the Sphere of Influence. An adequate mitigation might be adoption of the urban growth boundary into the General Plan language. How does the General Plan mitigate the development potentialcreatedon“conservationareas”throughtheiradditiontothe Sphere of Influence, development of industrial and commercial uses nearby, and the extensionofurbanservicesthroughthese“conservationareas”? Agricultural Land
As stated by the DEIR in Section 4.2, Table 4.2-5, Sonoma County experienced a 4% loss of Important Farmland from 1994-2004. Including grazing lands, the total loss of agricultural lands in that period was 28,641 acres. We are concerned that the General Plan allows for the future conversion of agricultural lands to urban and developed uses.

The DEIR does not adequately address the potential conversion of agricultural lands, due to their addition to the Sphere of Influence to the north and south of town. Conversion of Important Farmland is listed as a potentially cumulatively considerable impact.

However, the DEIR fails to thoroughly analyze the impacts adding farmland to the urban service area.

O2-3
continued
O2-4
O2-5
322
70 We do not find adequate policies in the General Plan to protect these lands from future development. We would recommend as a potential mitigation the adoption of stronger policies that would ensure that agricultural lands are protected from development pressures. This could be through the adoption of a policy that would keep pipes for urban services that are extended through agricultural lands to developments, both within the City Limits and within designated Urban Growth Boundary Expansion Areas, to the minimum size necessary to serve urban development. This may look similar to the Sonoma LAFCO policy A(3) for Agricultural Lands, which considers whether public facilities are sized and situated in a manner that would facilitate the conversion of adjacent or nearby agricultural lands at a future time. However, even this policy may not be an adequate mitigation. Therefore, we recommend that the City adopt as a mitigation a revised Sphere of Influence that would exclude the Asti area and adjacent vineyards from the proposed Sphere of Influence. We also recommend that the City adopt the following policy language into the General Plan:

Policy LU 6-3
Plan expansions of sewer, water, and road systems to support development within the Urban Growth Boundary. Any expansion of sewer or water service to the UGB Exception Areas shall be provided with pipes sized at the minimum diameter necessary to serve the Exception Areas at buildout.

Riparian Corridors
With the recent adoption of the Sonoma County General Plan, the County adopted setbacks for development from riparian corridors, such as the Russian River, creeks, streams, and wetlands. In reviewing the Cloverdale General Plan, we did not find policies that addressed the adoption of a similar setback for the City. We were disappointed to find that there were three impacts identified to riparian areas and waterways in the DEIR - Impacts 4.9.1, 4.9.2, and 4.10.2. While these impacts are listed as less than significant, theCityLimitsandSphereofInfluencearecontiguoustotheRussianRiver’sbanks.

When allowing development alongside a significant waterway, such as the Russian River, which is already impaired for water quality on several indicators, it is unlikely that less than significant impacts would be found. We have concerns that less than thorough analysis was completed with regards to the possible impacts on water quality in the Russian River and creeks within the General Plan Study Area. What are the full impacts of potential development done in the riparian corridors within the General Plan Study Area? As a possible mitigation, we recommend that the City adopt a riparian setback standard similar to that of Sonoma County:

Policy OSRC-8b: Establish streamside conservation areas along both sides of designated Riparian Corridors as follows, measured from the top of the higher bank on each side of the stream as determined by PRMD:

O2-5
continue
O2-6
323
71 (1) Russian River Riparian Corridor: 200'
(2) Flatland Riparian Corridors: 100'
(3) Other Riparian Corridors: 50'*
School Siting
We note that the DEIR Impacts 4.12.3 and 4.12.9c recognize that population growth may put pressure on existing schools, and may require the expansion of existing school facilities or construction of additional facilities. We are concerned that the policies and mapping in the General Plan do not adequately allow for these expanded facilities to be located within the urban growth boundary.

As land available for residential development exceeds that necessary to meet the population targets laid out in General Plan by 28%, and twice the land necessary is allocated for commercial and industrial to achieve a 1:1 jobs to housing ratio (source:

Bruce Kibby, presentation to City Council, February 20, 2008), we recommend that the City mitigate Impact 4.12.3 and 4.12.9c by designating lands within the proposed urban growth boundary for public facilities for new or expanded school facilities. Why has the City not designated new lands within the proposed urban growth boundaries in the General Plan for expanded school facilities?
Furthermore, we recommend the adoption of the following policies to the General Plan as mitigations:

Goal LU 5
Encourage the Cloverdale Unified School District and other educational institutions to identify and provide sites and facilities for a full spectrum of educational opportunities within the City.

Implementation LU 5-1.c. Monitor school needs in south Cloverdale to determine if an elementary school site will be needed, located within the Urban Growth Boundary and preferably within walking distance of housing.

Implementation LU 5-1.e. Encourage educational institutions to open or establish Cloverdale campuses, including college and junior college campuses or satellite programs, private educational and trade schools at all levels, and in-city offices for campuses or programs within the Urban Growth Boundary, including co-located resources meeting a variety of educational needs at shared locations.

Hillside Protection
After reviewing the General Plan and DEIR, we are confused as to how the City will designatewhichlandsqualifyas“above”and“below”Baseof Hill. By using a line that is not yet delineated as a marker for where certain policies begin to be in effect, we are concerned that adopted mitigation may not be carried through on all of the intended lands.

O2
O2-8
324
72 In order to avoid possible impacts to hillside areas, we ask that the City adopt policies into the General Plan as mitigations that:
 Ensures surveying of the slope for each project that comes through on parcels near the UGB line.
 ExpressestheCity’sintentionthatlandownerswithapartiallydevelopable parcel would donate conservation easements to the Open Space District on the lands above 20% slope in exchange for the right to develop on the flat portion of the parcel.

Will the City adopt policies that ensure that hillside development does not occur as mitigations to policies 4.8.3, 4.8.4, and 4.8.6?
We thank you for your time and consideration of these comments.

Sincerely,
Daisy Pistey-Lyhne
Sonoma-Marin Field Representative
Greenbelt Alliance
O2-8
continued
325
73 I1
I1-1
326
74 I2
I2-1
327
75 I3
328
76 I3-1
329
77 I3-2
I3-3
330
78 Tyris Corporation
December 5, 2008
VIA FACSIMILE; Original by Mail
(707) 894-4673
Mr. Bruce Kibby
Community Development Director
City of Cloverdale
126 North Cloverdale Boulevard
Cloverdale, CA 95425
Re: City of Cloverdale General Plan Update/Draft Environmental Impact Report Dear Mr. Kibby:

As you are aware, Tyris Corporation is the developer of the Alexander Valley Resort ("AVR Project") and has been processing a Specific Plan ("AVR Specific Plan") for the development with the City of Cloverdale since March of 2002. A Draft EIR for the AVR Specific Plan was issued in July of 2004, and a new Recirculated Draft EIR is anticipated to be issued before the end of the year. Tyris offers the following comments on the City General Plan Update and the Draft Environmental Impact Report ("EIR") prepared for the Update.

General Plan Update (references are to Section numbers)

1.7 - SPHERE OF INFLUENCE (Page 7): We suggest adding as sentence to the effect that "The City plans additions to its Sphere of Influence in connection with future projects and related annexations." As you are aware, a part of the AVR projectisnotcurrentlyintheCity’sSphereofInfluenceandwillneedtobeadded prior to annexation to the City.

Policy LU 2-4 (Page 25): We suggest that new language be added to the beginning of this policy to the effect "Unless included in or adjacent to a commercialareainanapprovedSpecificPlan…"TheAVRprojectincludesa small commercial area. The original AVR Draft EIR included an approximately 13-acre commercial development which was subsequently removed from the project and the Specific Plan. Future development of the 13-acre parcel as a commercial development is likely and should not be "discouraged." I4
I4-1
I4-2
331
79 Implementation LU 3-2.a (Page 26): We wish to comment on the restrictions on "Base of the Hill." The AVR Project has an isolated hill that is in the middle of what is otherwise a relatively flat area. We understood that the Base of the Hill provisions would not apply to the isolated hill on the AVR Project site, rather the intent was to make the provisions applicable to the base at the beginning of the hills surrounding the City. However, the maps showing the Base of the Hill areas include the isolated hill on the AVR Project site. We request that Exhibits/Figures showing the area to be subject to the Base of the Hill provisions be modified to exclude the AVR isolated hill. The AVR Specific Plan and its EIR will contain mitigations for all environmental impacts including Base of the Hill development.

Implementation LU 6.1.c (Page 32): You may wish to consider changing the first sentence to read "Promote water conservation and encourage the use of water conserving landscaping, and the use of secondary treated water for landscaping and other watering needs where appropriate." The AVR Project plans on using secondary treated water to water its golf course.

General Plan Update Draft EIR
Section 3.0
Table 3.0-3: You may wish to clarify that the reference to "Resort" in the AVR Project description includes a hotel (i.e. "Resort Hotel").

Figure 3.03: With reference to the AVR Project, this figure showing Pending Projects leaves out approximately 16 acres of the AVR Project site and should be corrected to include the entire AVR Project site.

that there is more than one area so designated, the text only describes the use for one of the areas. The AVR project is included in Area II of destination commercial, which the current General Plan text describes as "The primary uses encouraged within Area II are golf course or commercial recreation facilities, hotel, motel, convention center recreational vehicle parks, or campgrounds, and residential uses in conjunction with recreational amenities." We believe this distinction is important.

I4-3
I4-4
I4-5
I4
I4-7
332
80 Section 4.0
Table 4.0-3: You may wish to clarify that the reference to "Resort" in the AVR Project description includes a hotel (i.e. "Resort Hotel"). The AVR Project description should be corrected to provide for "40 attached res., 2.4 acre commercial" instead of "80 attached res., 2.5 acre commercial." Figure 4.0-1: With reference to the AVR Project, this figure showing Pending Projects leaves out approximately 16 acres of the AVR Project site and should be corrected to include the entire AVR Project site.

Section 4.2
Figure 4.2-2: This appears to show a part of the AVR project site as Prime Farmland and a portion as Farmland of Statewide Importance. Attachment "A" to this letter is an Exhibit provided by the State Department of Conservation showing all but the most northerly finger of the AVR project site as Farmland of Local Importance. These distinctions can be meaningful for CEQA purposes and the discrepancy should be resolved.

Section 4.3
Impact 4.3.1: In the chart on page 4.3-11, Implementation LU 1-2.a should include the following lead-in language "Unless included in an approved Specific Plan…"BecausetheAVRSpecific Plan will include all required mitigations, the limits provided in this measure should not apply.

Section 4.7
Impact 4.7.5 - Implementation PS 7-6.10: This implementation measure should begin with the words "Unless approved by the Sonoma County Airport Land Use Commission…"
Section 4.9
Impact 4.9.3 - Implementation 6-1.b: Consider adding "Encourage the use of secondary treated water for landscaping and related uses where appropriate." I4-8
I4
I4-10
I4-11
I4-12
I4-13
333
81 Section 4.12
Impact 4.12.6 - Policies PR 1-4 and 1-5: These policies reference Exhibit 5.1 as showing open space and trails. Exhibit 5.1 shows an open space area in the middle of the residential portion of the proposed AVR Project and does not show the open space areas included in the proposed AVR project. The Exhibit should be conformed to the AVR Project.

Please feel free to contact me if there are any questions or clarifications needed related to the above comment.

Sincerely,
Robert H. Sexton
Enclosure
Copy: Ms. Nina Regor, City Manager
Members of the City Council
I4-14
334
82 335
83 Planning Commission Minutes –November 5, 2008
Individual Comments from Citizens
I5 I5-1
I6 I6-1
I7 I7-1
I8 I8-1
336
84 I9
I9-1
337
85 CITY OF CLOVERDALE GENERAL PLAN UPDATE
Final Environmental Impact Report –January 2009
State Clearinghouse No. 2007082143
338
86 CHAPTER 3
Response to Comments on the Draft EIR
Introduction - Individual responses to each of the comment letters identified in Chapter 2“CommentsontheDraftEIR”areincludedinthischapter.Neitherthe comments on theDraftEIRnortheCity’sresponsestheretoraiseany“significantnewinformation” within the meaning of Public Resources Code Section 21092.1 or CEQA Guidelines Section 15088.5 so as to require reirculation of the Draft EIR. Therefore, the City of Cloverdale, as the CEQA Lead Agency, has directed that a Final EIR be prepared.

Comments that do not directly relate to the analysis in this document (i.e., that are outside the scope of this document) are not given specific responses. However, all comments are addressed in this chapter so that the City of Cloverdale Planning Commission and City Council will know the opinions of the agencies, organizations, and individuals that provided comments.

In some cases, multiple comments were received with respect to several planning and/or environmental issues raised in the Draft EIR. In order to provide the commenter with a complete picture regarding his or her concern, the City prepared a master response to all comments regarding a given subject. These master responses provide some background regarding the issue, identify how the issue was addressed in the Draft EIR, and provide additional explanation regarding the issue as needed. In some cases, these responses have been prepared to address specific land use or planning concerns related to the Project but unrelated to the EIR or environmental issues associated with the Project.

Comments which present opinions about the project unrelated to environmental issues or which raise issues not directly related either to the substance of the EIR, the General Plan Update, or to environmental issues are noted without a detailed response.

Response to Comments
The following responses correspond to the numbers for each comment presented in Chapter2“CommentsontheDraftEIR”.Thissectionbeginswiththemasterresponses that have been prepared to address multiple comments related to a single given subject. 339
87 Master Response #1: Comments Related to the General Plan Update Document During the public review period for the draft EIR, several respondents provided a variety of comments related to planning concepts and updates (i.e., Urban Growth Boundary, etc.)proposedintheCity’sUpdatedGeneralPlan.Thismasterresponsehasbeen developed to address various comments related to the General Plan Update policy document.

The primary objective of this final EIR is to respond to comments received during the public review period that address concerns specific to environmental impacts of the Proposed Project or the adequacy or completeness of the draft EIR analysis. Not surprisingly, given the broad nature and multiple functions of a General Plan, not all comments received in response to the draft EIR were environmental in character. CEQA does not require a formal response to such comments, even though they may well address legitimate concerns of public policy (e.g., economic, fiscal, or social issues). Some comments merely express approval or disapproval of the Proposed Project or particular policies. Some comments criticize the Proposed Project from a policy standpoint, or characterize it in negative terms, but do not argue that the draft EIR is in any way deficient. Still other comments offer suggested changes to proposed new policy language. All such comments are part of the administrative record for the General Plan process, and all will be forwarded, as part of this final EIR, to City decision-makers for their careful consideration, as, in weighing the various benefits and detriments associated with the Preferred Alternative and the other alternatives, these decision-makers have to balance economic, social, fiscal, and other concerns against the environmental impacts of the various options.

Master Response #2: Programmatic Nature of the EIR
Several comments received regarding the draft EIR provided requests to have additional impact analysis provided regarding specific developments that may occur through implementation of the proposed Cloverdale General Plan Update. This master response has been developed to address various comments.

According to CEQA Guidelines Section 15168(a), a local agency may prepare a program-level EIR to address a series of actions that can be characterized as one large project and are related geographically, as logical parts of a chain of contemplated events, through rules, regulations, or plans that govern the conduct of a continuing program, or as individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental effects that can be mitigated in similar ways. This EIR was prepared as a Program EIR. As a Program EIR, this document serves as a first-tier document that assesses and documents the broad environmental impacts of a program with the understanding that a more detailed sitespecific environmental review may be required to assess future projects implemented under the program. As individual projects with specific site plans and facilities are planned, the City will evaluate each project to determine the extent to which this EIR 340
88 covers the potential impacts of the project and to what extent additional environmental analysis may be required for each specific future project. (See Public Resources Code ItisalsoimportanttonotethattheCity’sdraftGeneral Plan Update, Policy LU 1-2, calls for the establishment of a growth management program based upon a maximum anticipated City population of 12,000 residents within 4700 housing units through the buildout horizon of the General Plan Update. This is a reduction in the total population which would have been allowed under continuation of the existing General Plan.

Master Response #3 Agricultural Land
Several comments from agencies and organizations focused upon the potential conversion of agricultural lands within the project area over the planning horizon of the General Plan. This Master Response has been developed to address these comments.

Implementation of the proposed project would affect 484.4 acres of Farmland in the Study Area. Table 4-2-6 in the DEIR identifies 484.4 acres of significant farmland (Prime Farmland, Unique Farmland, and Farmland of Statewide Importance as identified in the California Department of Conservation Farmland Mapping and Monitoring Program [FMMP]) within the General Plan Study Area. Based on EIR comment 14-10 and public hearing comments on February 4, 2009, two parcels in the Study Area are not significant farmland (16.8 acres in Alexander Valley Resort and 16.1 acres in the McCray Road area to be removed from the Farmland Mapping and Monitoring Program per Department of Conservation Staff); therefore, the revised acreage of significant farmland within the Study Area is 451.5 acres. There are 29 acres of significant agricultural land within the proposed Urban Growth Boundary (northeast of the existing City limits and Highway 101) which are designated as Conservation Features. That land also has Williamson Act designation. That 29 acre property is within the Urban Growth Boundary, and the General Plan could be amended to change potential use, following the normal General Plan policies, including environmental review. With the exception of the 29 acre site, the remaining areas of significant farmland will be designated as Conservation features and are outside of the Urban Growth Boundary. As such, they cannot be developed and will be preserved under an agricultural designation after annexation to the City. Conservation Features land outside the UGB cannot be changed to non-agricultural uses.

The following proposed General Plan Policies and Implementation Measures provide mitigation of this item:

General Plan Policy Implementation Measure
Policy LU 3-1. Develop an Urban Growth
Boundary that allows urban development within
the boundaries and does not allow urban
development outside the boundaries except in
two existing developed areas (Industrial and
Asti Exception Areas). Urban development
should be within the General Plan Study Area
Implementation LU 3-1.a. Prepare an Urban
Growth Boundary to be passed by the voters
substantially as shown in Exhibit 2.5.

Implementation LU 3-1.b. Land outside the
Urban Growth Boundary shall be retained as
Conservation Features, except for the Industrial
341
89 General Plan Policy Implementation Measure
andbelowthe“BaseofHill”asdefinedinExhibit

2.2., except for the area to the south of
Sandholm Lane extended and north of Bluxom
Creek, where development may be allowed
above the base of hill but behind the hill if the
primary access road visible to the City is below
the base of hill, and houses, night lighting, street
lighting, and roadways above the base of hill
are not visible from the balance of the City.
and Asti Exception Areas.

Implementation LU 3-1.c. The City shall develop
a list of exception uses allowed outside the
Urban Growth Boundary, including industrial
uses in the Industrial Exception Area, Destination
Commercial Uses in the Asti Exception area,
and conservation uses in all other areas outside
the Urban Growth Boundary. The conservation
uses shall allow relocation of the Citrus Fair as an
exception.

Policy LU 3-3 Maintain the compact form and
natural setting of Cloverdale by protecting
hillsides, protecting land outside the Urban
Growth Boundary from urban development,
and protecting Prime Farmland, Unique
Farmland, and Farmland of Statewide
Importance from urban development, with
conditions that allow for economic and rational
infill growth.

Implementation LU 3-3.a. Land outside the
Urban Growth Boundary shall be retained as
Conservation Features, except for the Industrial
and Asti Exception Areas, which have no
farmland of statewide significance. Land
shown as Prime Farmland, Unique Farmland,
and Farmland of Statewide Importance shall be
retained as Conservation Features, except that
specific parcels identified in Exhibit 2.6 may be
changed to urban uses if equivalent lands are
place in a land trust within Sonoma county for
permanent and equivalent agricultural use.

Implementation LU 3-3b. The City, in
coordination with Sonoma County, shall
consider implementing a requirement that
future development projects adjacent to
designated agricultural lands under the
Conservation Features designation will maintain
a buffer between the proposed development
and agricultural operations. The width of the
buffer, the allowable land use activities, and a
mechanism for maintenance of the buffer shall
be part of any implementing action of the
requirement.

Policy CDO 1-1. Urban development in the City will
be on the valley floor, defined generally as the land
below the Base of Hill. Development will be framed
by and contained within agricultural lands to the north and south, the Russian River to the east, and below
the Base of Hill (defined as the location where the
valley floor transitions to a 20% slope or greater using 5 foot slope contours or less) on hillside areas).

Implementation CDO 1-1.a. Use Policy CDO-1 as
basis for project review in the City.

Implementation CDO 1-1.b. Adopt an Urban Growth
Boundary (see Policy LU 3-1 above).

Policy CDO 1-2. “ConservationFeatures”areastothe
north and south of the City should be reserved for
agricultural use unless a Specific Plan is prepared and the General Plan is amended for other uses.
“ConservationFeatures”areasinhillsidestothewest
of the City shall be reserved for protection of forested hillsides.

Implementation CDO 1-2.a. Require specific plans as
described in Policy CDO 1-2.

Policy CDO 1-5. Encourage the County to retain
surrounding lands in very low density residential,
agricultural, open space, and natural resource uses
that provide contrast to urbanized Cloverdale.

Implementation CDO1-5.a. Use Policy CDO 1-5 as
guidelines for annexation review.
342
90 General Plan Policy Implementation Measure
Promote the creation of a community separator or
open space buffer between Cloverdale and any urban
development around the City.

As described in Master Response #2, the Draft EIR for the Proposed Project is a program leveldocumentthatevaluatestheeffectsthatgrowthwithintheCity’sGeneralPlan Update Study Area may have on a variety of resources, including agricultural. Because some amount of growth is anticipated and is unavoidable to a certain extent as described in the DEIR, there is an expectation that some amount of agricultural land will be converted in the future. The City will work to conserve and protect agricultural lands on a project by project basis as described in the DEIR and reiterated above. The City will continue to coordinate and cooperate with Sonoma County with respect to this effort.

TheCity’sGeneralPlanlandusedesignationofConservation Features is very similar to theexistingCountylandusedesignationsoutsideoftheCity’sjurisdiction.

Certain comments received called for additional General Plan policy language which would address the issue of agricultural land conversion in the future. Those comments are addressingtheCity’spolicieswhichmaybeadoptedaftertheUGBhasexpired,at least 20 years in the future. That time frame is outside the proposed General Plan time frame, approximately 20 years, and policies are not proposed beyond the General Plan time frame.

Master Response #4 Urban Growth Boundary
Comments were received relative to the proposed future adoption of an Urban Growth Boundary(UGB)asdescribedintheCity’sGeneralPlanUpdate.Thismasterresponse has been developed to address this issue.

For planning purposes, the City selected a study area for the General Plan Update. The Draft EIR analyzes potential impacts upon the study area, as well as smaller areas consideredinthe“Alternatives”analysis.ThestudyareaislargerthantheCity limits, theCity’sSphereofInfluence(SOI),theProposedSphereofInfluence,andtheproposed Urban Growth Boundary (UGB). The study area does not conform to any other existing boundary formally adopted by the City or Sonoma County. It is recognized that the City does not have direct authority over portions of the study area, however, the study area doesimpactandreflectupontheCity’sidentityandwasthereforegivenplanning consideration. The study area encompasses 7.8 square miles (5000 +- acres) and extends generally east to the edge of the Russian River and west to the crest of the ridgeline and south to Asti and the Raines Creek Water District. Highways 101 and 128 are a part of the study area as well as the City Municipal Airport. The northern boundary extends to the north Highway 101 interchange and includes the McCray Road area.

The General Plan planning area includes four separate geographical areas. These are:
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91 City Limits: The legal boundaries of the community, where land use is controlled by the City. They encompass 2.5 square miles (1,615 acres).

Sphere of Influence: The City Sphere of Influence (SOI) is the area of the City that has been approved for future annexation by the Sonoma County Local Agency Formation Commission. It encompasses 2.3 square miles (1,460 acres) beyond the City Limits. The Sphere of Influence has remained generally consistent since the adoption of the first General Plan in 1978, with only one extension approved since the original General Plan was adopted in 1978. The Sonoma County General Plan uses the Sphere of Influence to define the ultimate area to be annexed to the City.

Proposed Sphere of Influence: The Proposed Sphere of Influence (PSOI) is the area where the City anticipates extending urban services (e.g. water, sewer, police, etc.) It encompasses 2.2 square miles (1391 acres) beyond the Sphere of Influence and represents area that the City intends to add to the Sphere of Influence after Local Agency Formation Commission approval.  Study Area:TheCity’sGeneralPlanUpdateStudyAreaencompasses0.8square miles (511 acres) outside of the existing and proposed Sphere of Influence and can be considered the areas under County jurisdiction where the City expresses land use directions to help the County determine transition policies between the urban City areas to the agriculture and very low intensity uses under County jurisdiction.

The DEIR project included a policy calling for the eventual designation and adoption of an Urban Growth Boundary (UGB). Based upon several issues identified during the preparation of the DEIR, the City Council chose to adopt a UGB and include a map depicting the approximate location of the proposed line. The intent of the City Council was to utilize the UGB as part of the General Plan Update policy mitigation program. It is recognized that the CAC did not define the UGB as a specific study area for EIR purposes. The General Plan Update document was modified in September 2008 by the Cloverdale City Council. The Council chose to identify a UGB and two exception areas within which the City may review future requests for urban-type uses and/or extension of City services. The UGB includes the existing City limits and portions, but not all, of the Existing Sphere of Influence and the Proposed Sphere expansion area. In other words, the proposed UGB is smaller than the Study Area upon which the General Plan Update DEIR was based, and therefore potential program level environmental impacts assessed in the DEIR necessarily include the identified UGB area.

The draft General Plan Update document contains an implementation measure calling for the adoption of a UGB ordinance (within 6 months of the GPU adoption) to be placed on the ballot for voter approval. A map has been included in the General Plan Update (Exhibit 2.5) depicting the City-proposed approximate UGB area. The area was selected inordertohelpfitgrowthintothecommunity’snaturalenvironmentandprotect important natural, social and cultural resources. Furthermore, the City has determined 344
92 that the UGB can aid the community to more efficiently and cost effectively to provide a public and community infrastructure to support future growth and development. The City has determined its appropriate growth boundary and has studied the impacts of development within and adjacent to the identified Urban Growth Boundary as part of the General Plan EIR.

CommentswerereceivedrelativetotheCity’sproposedUrbanGrowthBoundaryandits effectiveness as mitigation with respect to agricultural land conversion. Table 4-2-6 in the DEIR identifies 484.4 acres of significant farmland (Prime Farmland, Unique Farmland, and Farmland of Statewide Importance as identified in the California Department of Conservation Farmland Mapping and Monitoring Program [FMMP]) within the General Plan Study Area. Based on EIR comment 14-10 and public hearing comments on February 4, 2009, two parcels in the Study Area are not significant farmland (16.8 acres in Alexander Valley Resort and 16.1 acres in the McCray Road area to be removed from the Farmland Mapping and Monitoring Program per Department of Conservation Staff); therefore, the revised acreage of significant farmland within the Study Area is 451.5 acres. There are 29 acres of significant agricultural land within the proposed Urban Growth Boundary (northeast of the existing City limits and Highway 101) which are designated as Conservation Features. That land also has Williamson Act designation. That 29 acre property is within the Urban Growth Boundary, and the General Plan could be amended to change potential use, following the normal General Plan policies, including environmental review. With the exception of the 29 acre site, the remaining areas of significant farmland will be designated as Conservation features and are outside of the Urban Growth Boundary. As such, they cannot be developed and will be preserved under an agricultural designation after annexation to the City. . It is recognized that the City must follow LAFCO policies and regulations prior to expandingtheCity’sSphereofInfluence(SOI)andpriortoanyannexation.LAFCO approval of any future proposed. The LAFCO and other comments question whether the General Plan Environmental Impact Report reviewed the potential for development on Conservation Features areas outside the Urban Growth Boundary. The above paragraph explains that the Conservation Feature land outside the UGB can only be preserved for agricultural uses. The General Plan and the General Plan Environmental Impact Report fully analyzed the impacts of development outside the existing City limits and for the areas proposed for SOI expansion.

The City will continue to coordinate with the County to ensure that appropriate consideration is givento“greenbelt”areasaspartoftheplanningprocessassociatedwith any future expansions of the City. Community separator protections to lands around Cloverdale will be supported by the proposed General Plan Update document goals, policies, and implementation measures. With the exception of two precisely mapped exception areas, the land outside the Urban Growth Boundary are designated for Conservation Features, which is consistent with protection of agricultural lands in this vicinity.
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93 The following GPU Goals, Policies, and Implementation measures are applicable to this issue: LU 3; LU 3-1; LU 3-1.a; LU 3-1.b; LU 3-1.c; LU 3-2; LU 3-2.a; LU 32-.b; LU 3- 3; LU 3-3.a; and LU 3-3.b.

Individual Responses –Public Agencies
Letter A1. Department of Fish and Game
Response to Comment A1-1:

The commenter states that the City should review future development projects to ensure that rare or sensitive species are not impacted.

The City concurs with this comment as is reflected in the DEIR and in the Draft General Plan Update document. General Plan Update policies and Implementation Measures CDO 5-1, CDO 5-1.a, CDO 6-2, CDO 7-1, CDO 7-1.a, CDO 7-2, CDO 7-2.b, CDO 7-

2.c, and CDO 7-2.d would reduce and/or avoid direct and indirect impacts to specialstatus species within the study area. [It would be more in line with CEQA principles to briefly identify each policy listed and state each policy will reduce impacts –the factual connection is important for public review purposes.] If this is done on the chart above, does it need to be done every time the policies are mentioned? Environmental review procedures adopted as part of the General Plan Update will ensure that adequate mitigationmeasureswillbeidentifiedforfutureprojectsthatwillachieve“nonetloss”of sensitive habitat acreage, values, and function.

Response to Comment A1-2:

The commenter states that future project scoping should include consultation with the DFG’sNaturalDiversityDatabase.

The City recognizes that consistent with existing State regulations, biological surveys may be required in certain instances. The potential for special-status species to occur within the study area was evaluated by querying the CNDDB (CDFG 2007), the USFWS (2007a), and the CNPS (2007) for previously recorded occurrences of special-status species within the Cloverdale, California USGS 7.5-minute quadrangle (USGS 1960) and surrounding eight quadrangles (Asti, Geyserville, Warm Springs Dam, Tombs Creek, Big Foot Mountain, Yorkville, Hopland, and Highland Springs).

CDFG maintains records for the distribution and known occurrences of sensitive species and habitats in the CNDDB. The CNDDB is organized into map areas based on 7.5- minute topographic maps produced by USGS. The CNDDB is based on actual recorded occurrences, but does not constitute an exhaustive inventory of every resource. The absence of an occurrence in a particular location does not necessarily mean that special346 94 status species are absent from that area, but that no data has been entered into the CNDDB inventory. Detailed field surveys are generally required to provide a conclusive determination on presence or absence of sensitive resources from a particular location where there is evidence of potential occurrence. Comment noted.

Response to Comment A1-3:

DFG recommends additional mitigation be added to the GPU in support of Policy CDO 6-2.

The City intends upon adopting the following relevant policies and implementation measure, which in the opinion of the City, adequately address this concern:

Policy CDO 6-2: Protect distinctive natural vegetation such as oak woodlands, riparian corridors and mixed evergreen forests by maintaining the natural features as a whole.

Preservation of individual trees or features rather than the larger habitat does not satisfy this policy. (See Implementation CDO 6-1.a).

Policy CDO 6-1 - Maintain and expand the tree canopy within and outside the developed areas of the City, and including old growth and newly planted trees. Prepare tree protection standards that can be implemented with or without a tree preservation ordinance.

Implementation CDO 6-1.a - Develop an urban forest plan with a management strategy for maintaining existing and newly planted trees, including best practice provisions for installation, maintenance, and succession planning.

Response to Comment A1-4:

The DFG addresses proposed setbacks from waterways, and recommends that waterways which are located outside of the be protected as well. In addition, DFG recommends that the City considerextendingtheproposed50footsetback(50’oneachsideofthe waterway,totaling100’)to100feetoneachsideofawaterway(totaling200’)Note that the Conservation Element Map referenced in the DFG letter is in the 1992 General Plan and will be added to the proposed General Plan.

Inresponsetotheaboveissue,theCity’ssetbackrequirementwillbeappliedinareas over which the City has jurisdiction. Most of the waterways within the proposed UGB are on existing city lots which would be unusable if a 100 foot setback were adopted, raising constitutional issues regarding private property rights. With respect to expansion of the waterway setback area, the GPU recognizes that larger setbacks may be appropriate for land adjacent to the Russian RiverasisreflectedintheCity’s Conservation Features land use designation which reads as follows:

The purpose of this designation is to manage and preserve valuable biological, visual, and agricultural resources in the Cloverdale Planning Area. Primary uses include river/stream-related recreation, open space buffers, and agricultural production. 347
95 Setbacks of 50 feet from tributaries are encouraged, and between 300 feet to 1,000 feet around the Russian River.

The Conservation Features land use designation encompasses much of the land in the vicinity of the Russian River, and along the western portion of the planning area hillsides.

This designation is proposed to be applied to approximately 1875 acres within the GPU Planning Area, almost 37% of the total planning area. Increased waterway setbacks within the already urban developed City area is not feasible in many cases given existing parcel sizes. Many parcels do not contain adequate area to accommodate such a setback, and imposing one would raise raise constitutional issues regarding private property rights.

Letter A2. Department of Transportation
Response to Comment A2-1:

The commenter recommends including a casino/hotel complex proposed by the Cloverdale Rancheria of Pomo Indians in the General PlanUpdate’strafficstudyand evaluation of the adequacy of General Plan transportation improvements.

TheCity’sNoticeofPreparationfortheGeneralPlanUpdateEIRwaspublishedon August 29, 2007. Almost a year later, a Notice of Intent to Prepare an EIS for the Proposed Cloverdale Rancheria of Pomo Indians Fee-to-Trust Acquisition and HotelCasino Project, Sonoma County, California, was published in the Federal Register. On July 20, 2008, a public scoping meeting on the EIS was held, but contrary to normal process, no project details were presented on broadly identified alternative, including no project, an unspecific non-gaming revenue generating alternative, a casino of several sizes with some type of hotel-entertainment complex and a casino without an associated hotel.

Atthatmeeting,theEISconsultantfortheprojectnoted,“Rightnowthereisnota proposedprojectthathasbeendefined.”TheCityaswellasotheragenciesandmembers of the public rightly objected to the lack of detail as placing the burden on the public to analyze the potential environmental impacts before a project was defined.

In august, 2008, the City accepted cooperating agency status in the Bureau of Indian Affairs BIS process, as part of its continuing attempts to require the tribal project to fully identify, analyze and mitigate potential impacts of any future project that may be proposed. Although a draft EIS for the casino project has not yet been published, the City understands that it will analyze projected traffic impacts on local City streets and the U.S. 101 interchanges at the South Cloverdale interchange and Citrus Fair Drive. The City expects that the BIA EIS process will require inclusion of project elements, such as design and/or infrastructure improvements, which will accommodate traffic generated by a casino project, if one is ultimately undertaken. The public will have a full opportunity to be informed and comment on the analysis of casino traffic impacts presented in the federal EIS process.
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96 Although theCity’sinputasacooperatingagencyisentitledtobeconsideredintheEIS process, the City ultimately has no power to either require modifications in the project or to reject the project if its impacts are deemed unacceptable.

CEQA Guideline Section 15130(b) states that the discussion of cumulative impacts in an EIR“shouldbegovernedbystandardsofpracticalityandreasonableness.”Atthetime the City prepared its traffic study for the General Plan, it had no way of even estimating the size, scope and nature of a casino project, nor was there sufficient information to determine the likelihood that a project, of whatever size and scope, would proceed, unlike two previous tribal proposals which did not advance.

The City is taking all possible action to have an active voice on behalf of its citizens in the federal environmental review process now underway for a possible casino or other tribal project. It is neither practical nor reasonable to expect the City, as a small jurisdiction of some 8,500 residents and limited economic resources, to duplicate the federal environmental review process and/or to identify, much less fund and provide infrastructure improvements which will mitigate cumulative impacts from a possible future project of a sovereign tribal entity.

Response to Comment A2-2:

The commenter suggests early consultation with Caltrans regarding proposed roundabouts.

In response, based on the traffic projections evaluated for the General Plan update, the need for the roundabouts may not occur for at least 5-7 years or longer, depending on the pace and location of development. Initial layouts and the operational analysis using the SIDRA software are available in the technical appendix.

Response to Comment A2-3:

The commenter recommends early consultation with Caltrans regarding the alternative of signalized intersections at South Interchange.

In response, the City agrees. The operational analysis for the signalized intersection alternatives is available in the technical appendix.

Response to Comment A2-4:

The commenter raises potential issues associated with the SMART rail and TOD development:

In response, the City acknowledges the comment. The traffic analysis did not take any deductions for potential traffic benefits of transit oriented development. Policies which promote more mixed use and transit oriented development would reduce traffic from levels which are projected in the traffic analysis.
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97 Response to Comment A2-5:

The commenter requests that they be provided with intersection analysis output.

In response, the City notes that the results of the HCM and SIDRA analysis are available in the DEIR technical appendix.

Letter A3. Sonoma LAFCO
Response to Comment A3-1:

The commenter raises the issue of a self-mitigating General Plan.

Early in the process, the City made the decision to prepare a self-mitigating document thusly avoiding the need and possible ineffectiveness of a lengthy list of mitigation measures and associated monitoring requirements. The draft General Plan was formulated to minimize environmental impacts, with the goal that adoption of the General Plan would be the primary mitigation of impacts identified in the Environmental Impact Report. During the DEIR process, the General Plan Update document was modified to address environmental concerns which became apparent but have now been mitigated through effective policy and implementation programs. (See Revised GPU, September 2008)
Response to Comment A3-2:

The commenter requested additional explanation related to the proposed Urban Growth Boundary as shown in the draft General Plan Update document dated September 2008.

Additionally, LAFCO questions the connection between the existing City limits and the Asti exception areas. The Urban Growth Boundary contains two exception areas which would be established outside the UGB and could be served by City services for a precisely defined and limited set of land uses. In order to provide services to the exception areas, those areas would have to be annexed, as well as the intervening lands which would be designated as Conservation Features. Therefore the Sphere of Influence is proposed to extend to the Asti exception area. Because of the precise and defined uses in the UGB, the Conservation Features could only be used for agricultural uses, preserving the important farmlands as required by LAFCO regulations, and the preexisting developed industrial and winery use in the exception areas could be served for industrial and winery uses.

See also Master Response #4, Urban Growth Boundary.

Response to Comment A3-3:

The commenter expressed a concern regarding the conversion of prime agricultural lands to urban uses, and possible future conflicts associated with this situation. 350
98 See Master Response #3, Agricultural Land, and Response to Comment A3-2. The conversion of agricultural land to urban uses would be prohibited by the Urban Growth Boundary provisions. Public utilities would be extended to areas adjoining those agricultural lands to provide service to well-defined exception areas, but those utilities would not be available to agricultural lands for urban uses for the twenty year period of the UGB.

Response to Comment A3-4:

The commenter recommends that specific properties under Williamson Act contract be identified.

The City will include a map as part of the FEIR which will identify contracted lands, and provide an acreage summary. Impacts are not anticipated to change, see Master Response #3, Agricultural Land, which addresses potential agricultural land conversion issues in detail and response A4-5, which details the Williamson Act parcels within the proposed UGB.

Letter A4. Sonoma County PRMD
Response to Comment A4-1:

ThecommenternotesthatreferencesintheCloverdaleGPUDEIRtothe“DraftSonoma CountyGeneralPlan”shouldbechangedto“GP2020”astheCountyGeneralPlanhas been adopted
Commented noted and the City concurs.

Response to Comment A4-2:

Commenter notes that the City of Windsor was omitted from the DEIR Section 4.1.1.

Commented noted and the City concurs.

Response to Comment A4-3:

The commenter expresses concern that the proposed UGB is not contiguous to the City limits.

See Master Response #4, Urban Growth Boundary. Also, the UGB includes lands within the General Planning area, not just the City limits. The General Plan is a 20-year document and anticipates changes within that 20-year period. It should be noted that the General Plan does not anticipate annexation of non-contiguous properties (see response A3-2).

Response to Comment A4-4:
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99 The commenter expresses concern regarding the potential for agricultural land conversions.

See Master Response #3, Agricultural Land and response A3-2 Response to Comment A4-5:

The commenter expresses concern over the location of Williamson Act properties and potential future extension of public facilities/services through areas designated as Conservation Features. The commenter recommends adding policy to the GPU which states that the extension of public water and sewer service would only be allowed in conjunction with the resolution of a public health hazard or the provision of affordable housing.

There are three Williamson Act Properties within the UGB, a 29.0 acre parcel north of the existing City limits and 10.8 and 16.8 acre parcels south of the City wastewater treatment plant. The 10.8 acre parcel has a cancellation request. The other two are in Conservation Features designation and are not anticipated for urban development in the General Plan time frame.

Response to Comment A4-6:

The commenter makes recommendations for Transportation Policies The City acknowledges this comment. It relates to policy issues, rather than environmental issues. The City may take action in concert with the County and other Sonoma County Cities, but those potential policies have not been analyzed in sufficient depth to place them in the General Plan.

Letter A5. California Regional Water Quality Control Board –North Coast Region Response to Comment A5-1:

The commenter expresses concern that there are not enough enforceable mitigation measures built into the General Plan Update or provided in the DEIR to address potential impacts to surface and ground water quality, loss of riparian habitats and wetlands, and storm water pollution. The commenter notes that the RWQCB has regulatory/permitting authority over individual storm water and waste water discharges, but the Agency prefers local jurisdictions to incorporate mitigation addressing these items at a local level. The RWQCB recommends more clear and enforceable mitigations be developed as part of this planning process.

In response , the City notes as explained in the Regulatory Framework section of the DEIR that industrial activities in Cloverdale which discharge storm water are subject to a 352
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NPDES General Industrial Permit for such discharges (Water Quality Order No. 97-03- DWQ). This permit requires the implementation of management measures that will achieve the performance standard of best available technology (BAT) economically achievable and best conventional pollutant control technology (BCT). The General Industrial Permit also requires the preparation of a Storm Water Pollution Prevention Plan (SWPPP), a monitoring plan and an annual report.

As described above, the NPDES program includes a permitting process for construction work. Under the NPDES General Construction Permit (NPDES No. CAS000002, Order No. 99-08-DWQ) process, projects that disturb one or more acres of lands are required to obtain a permit before the start of construction work. Typically, the permit attaches conditions that include the preparation of a SWPPP. The SWPPP describes the best management practices (BMPs) that would be employed to prevent loosened soils carried by storm water runoff from entering local streams and other water bodies.

Certain actions within the General Plan Study Area may need to conform to a General Permit for dewatering and other low threat discharges to surface waters (Water Quality Order No. 5-00-175). This General Permit allows such discharges provided that they do not contain significant quantities of pollutants and are either (1) four months or less in duration, or (2) the average dry weather discharge does not exceed 0.25 million gallons per day (mgd). Activities that may require the acquisition of this permit include well development water, construction dewatering, pump/well testing, pipeline/tank pressure testing, pipeline/tank flushing or dewatering, condensate discharges, water supply system discharges, and other miscellaneous dewatering/low threat discharges. “WatersoftheState”aredefinedbythePorter-CologneActas“anysurfacewateror groundwater,includingsalinewaters,withintheboundariesofthestate.”TheRWQCB protects all waters in its regulatory scope, but has special responsibility for wetlands, riparian areas, and headwaters. These water bodies have high resource value, are vulnerable to filling, and are not systematically protected by other programs. RWQCB jurisdictionincludes“isolated”wetlandsandwaters that may not be regulated by the CorpsunderSection404.“WatersoftheState”areregulatedbytheRWQCBunderthe State Water Quality Certification Program which regulates discharges of fill and dredged material under Section 401 of the Clean Water Act and the Porter-Cologne Water Quality Control Act.

Streams and lakes, as habitat for fish and wildlife species, are subject to jurisdiction by the California Department of Fish and Game under Sections 1600-1616 of the State Fish and Game Code. Alterations to or work within or adjacent to streambeds or lakes generally require a 1602 Lake and Streambed Alteration Agreement.

GPU policies and implementing actions LU 3-2, LU 3-2.a, LU 3-2.b, CDO 7-1, CDO 7-

1.a, CDO 7-1.b, and CDO 7-1.c would reduce the amount of sediments that enter streams and other water bodies through the use of best management practices to control soil erosion and to trap sediments, the incorporation of other measures deemed necessary by 353
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the City to reduce generation of sediments, and enforcement of provisions of a grading and erosion control ordinance. Implementation of the proposed GPU policies and action items, in conjunction with adherence to the provisions of the NPDES General Construction Permit requirements, when applicable, adequately address the concerns regarding this issue as expressed by the RWQCB.

The following mitigation measures are part of the DEIR and contain enforceable and direct language regarding project mitigation:

MM 4.9.1 The City will adopt and implement a Storm Drainage Master Plan.

Development projects will be evaluated for consistency with this plan.

The plan will identify drainage facilities that will be constructed to eliminate drainage problems in the City and describe the means for financing the improvements. The Storm Drainage Master Plan will address Regional Water Quality Control Board water quality standards, including Best Management Practices for storm drainage management.

MM 4.9.2 At the discretion of the City Engineer, new development may be required to provide documentation to the satisfaction of the City engineer that the cumulative rate of peak runoff does not exceed pre-development levels. New development and redevelopment of existing sites maybe required to provide storm water detention or retention facilities (on- or off-site), if necessary, to prevent flooding due to runoff or where existing storm drainage facilities are unable to accommodate increased storm water drainage.

MM 4.9.3 The City will review and revise its Subdivision Ordinance as needed to incorporate specific data and design requirements related to storm water drainage that are contained in this General Plan update.

Mitigation Measure MM 4.9.1 requires preparation of a Storm Drainage Master Plan that identifies drainage facilities needed to reduce or eliminate drainage problems as well as require the use of Best Management Practices that will eliminate or reduce the discharge of pollutants from construction sites to waters of the state and implement stormwater pollution prevention plans that document the selection and implementation of Best Management Practices for a particular construction project. Mitigation Measure MM

4.9.2 sets a City standard for future development related to storm water runoff –the cumulative rate of peak runoff must not exceed pre-development levels. This will limit the generation of higher peak runoff flows resulting from development, which could produce higher velocities for flow, which in turn increase erosion and sediment discharge. Best Management Practices, energy dissipation measures, stabilization measures, and onsite detention ponds can be applied to and incorporated into proposed development to limit the concentrations of these constituents in any site runoff that is discharged into downstream facilities. Mitigation Measure MM 4.9.3 requires that storm waterdataandrequirementsbeincludedintheCity’sSubdivisionOrdinance. 354
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Response to Comment A5-2
The commenter states that the DEIR only considers three creeks, and the Russian River, to be significant within the Study Area.

As stated in the DEIR, the water types consist of potential jurisdictional waters of the U.S. including seasonal wetlands, ponds, ephemeral drainages, and intermittent to perennial streams/rivers that occur within the study area. DEIR Figure 4.10-2 illustrates the known wetlands and streams present within the study area and vicinity. This figure is not meant to be a comprehensive account of all waters, including wetlands, within the study area. Additional wetland features are likely to exist in the study area. Wetlands and waterways were identified using the online National Wetlands Inventory (USFWS 2007b). Waters of the U.S. identified in the Cloverdale Alexander Valley Resort Specific Plan DEIR (Baseline Environmental Consulting 2004) and the Clover Springs Phase 3B Environmental Constraints Study (ESA 2004) were also incorporated into this figure.

The City notes the comment by RWQCB and will revise the Draft EIR to include a clarifying statement that there are other creeks, drainages, etc in the Study Area in addition to the four listed in the current DEIR. (See underlined text below).

DEIR Section 4.9.1 - Existing Setting: Local Surface Water Features The City of Cloverdale is located in the Alexander Valley Groundwater Basin. The Study Area includes one (1) major river, the Russian River, and three (3) significant creeks, Cloverdale Creek to the north, Porterfield Creek to the south, and Cherry Creek near central Cloverdale. There are also other creeks and drainages existing within the Study Area which carry varying degrees of water and support a range and variety of wildlife habitat.

Response to Comment A5-3
ThecommenterstatesthattheRussianRiverislistedontheRegionalWaterBoard’s 303(d) list as impaired due to excess sediment and elevated temperature. The commenter also notes that the proposed General Plan Update would allow for an increase in urban development, which in turn would generate increased storm water runoff carrying various pollutants to waterways.

TheCity’sDEIRaddressesthisissueinseveralsectionsofthedocumentashighlighted below:

DEIR Section 4.9.1 –Existing Setting: Surface Water Quality. The primary surface water body that passes through Cloverdale is the Russian River. The entire length of the Russian River is listed by the State Water Resources Control Board (SWRCB) as impaired by sediment and temperature. These impacts are related to the sources as described below, and are not necessarily related to any specific land-use activities within the City of Cloverdale. The City of Cloverdale does not currently have an individual permit for discharge of storm water, but it is a member of the Russian River Watershed 355
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Association, which is an association of nine cities, counties and special districts in the Russian River Watershed that coordinates regional programs for clean water, fisheries restoration and watershed enhancement.

Sediment impacts in the Russian River and its tributaries prompted listing the entire Russian River watershed with sediment issues stemming from the following probable sources:

Agriculture Disturbed Sites (Land
Develop.)
Flow Regulation/Modification Channel Erosion
Agriculture-storm runoff Hydromodification Habitat Modification Erosion/Siltation Logging Road
Construction/Maintenance
Channelization Removal of Riparian Vegetation Nonpoint Source Construction/Land
Development
Dam Construction Streambank
Modification/Destabilization
Highway/Road/Bridge
Construction
Upstream
Impoundment
Drainage/Filling Of Wetlands
Temperature impacts in the Russian River and its tributaries prompted listing the entire Russian River watershed with temperature issues stemming from the following probable sources:

Hydromodification Flow
Regulation/Modification
Removal of Riparian Vegetation Nonpoint
Source
Upstream
Impoundment
Habitat Modification Streambank
Modification/Destabilization
Additionally, it is important to note that development potential under the proposed General Plan Update is less than the current development potential under the existing General Plan. The General Plan Update in and of itself will not lead to an increase of urbandevelopmentascomparedtotheexistingGeneralPlan,the“noproject”as analyzed in the DEIR.

Several other responses included within this FEIR address this item, including:

Master Response #2; and Individual Reponses A1-1; A1-3; A1-4; A3-1; and A5-1.

Response to Comment A5-4
The commenter states that creek maintenance for flood control should recognize the need tokeepsufficientshadecanopyoverthecreek.Thecommenternotesthat“encouraging cooperation”withotheragenciesisaninadequateapproachtomeetingobjectivesset forth in the General Plan.

The City emphasizes that as mentioned above in severalinstances,theCity’sDEIRand General Plan Update document recognizes the importance of waterways which may be impacted by the project. The land area subject to inundation by the base flood is referred to as the "100 year floodplain." Typically, the 100-year floodplain is delineated on the 356
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Flood Insurance Rate Maps prepared by the Federal Emergency Management Agency (FEMA) for regulatory purposes concerning flood insurance.

As described in the DEIR, FEMA maps indicate that portions of the Study Area are potentially vulnerable to flooding. The City of Cloverdale has adopted a Flood Damage Prevention Ordinance (Chapter 15.20 of the Municipal Code) and a "Primary Floodplain (FP) Overlay District" in its Zoning Ordinance, contained within Chapter 18.07 (Special Districts). The Flood Prevention Ordinance (Ordinance 507-96, adopted in 1996) was adopted in response to the Flood Insurance Study performed by the Federal Emergency management Agency (FEMA) in July of 1996. The purpose of the Ordinance is to protect human life and health; minimize public expenditures; minimize prolonged business interruptions; minimize damage to public facilities; maintain a stable tax base; ensure disclosure to potential purchasers of property; and ensure that those occupying structures within the special flood hazard areas assure responsibility for their actions.

The overlay zone established pursuant to Chapter 18.07 of the Zoning Ordinance establishes development standards within the floodplain areas delineated on the Flood Insurance Rate Map (Community Panel No. 060376-0001 C, revised July 1996) prepared by FEMA in its 1996 report titled The Flood Insurance Study for the City of Cloverdale, California, Sonoma County.

According to Chapter 18.07 of the City's Zoning Ordinance, the purpose of the "Primary Floodplain FP District" is to provide land use regulations for properties situated in floodways, and along creeks and streams to ensure an adequate open corridor to safeguard against the effects of bank erosion, channel shifts, increased runoff or other threats to life and property. The Primary Floodplain Overlay District can be combined with other districts contained within the Zoning Ordinance.

The areas within the City most prone to flooding are generally described below:
 Those areas along Cloverdale Creek from the northwest portion of the City south toward Cloverdale Boulevard, and easterly crossing University Street, Vista View Drive, Third Street, Second Street; Oakbrook Lane.
 The area between First Street and the Frontage Road to the Russian River.  The area on both sides of the Russian River, extending approximately 500 feet east of the former Northwestern Pacific Rail Road track bed and easterly to the City Limits, and along the easterly limits of the City.  Along Cherry Creek from the western City Limits running easterly to an area between Clark Avenue and the railroad tracks east of Highway 101.  Along Porterfield creek from a distance approximately 600-feet west of Cloverdale Boulevard and easterly to Highway 101.
 The low-lying areas between Highway 101 and the Russian River, where the City's water treatment plant is located.

Section 8.20.070 of the City of Cloverdale Municipal Code requires a permit from the City for work that could impact natural watercourses within a defined buffer area along natural watercourses. Activities potentially requiring a permit include the placement of 357
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structures, grading, fill, and planting of vegetation. The buffer area under this ordinance includes the toe of the bank at a slope of 2.5:1 to the maximum high water elevation plus thirty feet, or thirty feet from the top of the bank, whichever is greater. In addition, no permanent structures shall be built within a buffer area defined as the toe of the bank at a slope of 2.5:1 to the maximum high water elevation plus fifteen feet, or fifteen feet from the top of bank, whichever is less. As part of the permitting process, project applicants must provide a creek study analyzing project impacts to watercourse structure and flow and detailing bank stabilization, erosion control, and other watercourse protection measures included in the project.

Section17.20.130oftheCityofCloverdaleMunicipalCodestatesthat“project development shall not affect the natural course or riparian habitat of any stream.

Mitigation measures shall be required where development may result in impacts in such areas.”Section17.20.170oftheCityofCloverdalemunicipalcodestatesthat“whenever there is reason to suspect significant sensitive plant sites are located within the project site, an appropriate survey by qualified professionals approved by the planning director shallberequiredaspartofanyenvironmentalreview.”
General Plan policies PS 2-1, PS 2-2, PS 2-3, PS 2-4, PS 2-5, PS 2-6, PS 2-7, PS 2-8, PS 2-9, PS 2-10, PS 2-11, PS 2-12, PS 2-13, PS 2-14, PS 2-15, PS 2-16, PS 2-17, and PS 5-1 willadequatelyaddressfloodingconcernswithintheCity’sStudyAreaand would reduce potential the impacts related to this issue.

Response to Comment A5-5
The commenter notes that the Regional Water Board could provide the City with a GIS database which can be utilized for mapping sensitive areas, including wetlands. The commenter recommends that the FEIR contain policies and implementation measures aimed at enhancing water features.

While the City agrees with RWQCB that enhancing natural water systems within the city's sphere of influence is desirable, the City's responsibility in the CEQA EIR process is to identify and analyze the impacts of development envisioned under the General Plan Update, and to evaluate and adopt feasible mitigation for those impacts." The General Plan Update contains many policies and implementation measures related to this comment, including:

Implementation CDO 7-2.b - Preserve wetlands, habitat corridors, sensitive natural communities, and other essential habitat areas that may be adversely affected by public or private development projects where special-status plant and animal species are known to be present or potentially occurring based on City biological resource mapping or other technical material. Require biological resources assessment for development projects in areas identified or with potential to special status plant and animal species. 358
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Implementation CDO 7-2.c - Protect sensitive biological resources and habitat corridors in CEQA review and participation in comprehensive habitat management programs, including continued acquisition and permanent protection of important natural habitats.

Response to Comment A5-6
The commenter recommends that the City adopt an Urban Growth Boundary, a Hillside Ordinance, and a Grading Ordinance as soon as possible.

TheCity’sGeneralPlanUpdatecontainspolicesandimplementationinagreementwith this comment.

Response to Comment A5-7
The commenter recommends that a clear explanation of jurisdictional regulations related to wetlands and waters of the State be included in the DEIR.

TheCity’sDEIRcontainslengthydiscussionsoftheregulatoryframeworksurrounding this issue. See Individual Responses A1-3; A1-4; A5-1; A5-2; and A5-3.

The General Plan Update EIR serves as a program EIR and does not approve specific development projects. As future development is proposed, the impacts of each individual future project on waters of the State, including wetland areas, will be fully evaluated and mitigated as part of the development application process. For unavoidable impacts to waters of the State, submittal of applications for 401 Water Quality Certification and/or Waste Discharge Requirements (Dredge/Fill) permits from the Regional Water Quality Control Board will be necessary. United States Army Corps of Engineers Clean Water Act Section 404 permits and Department of Fish and Game stream alteration permits may also be needed.

Response to Comment A5-8
The commenter discusses several issues related to the topic of storm water runoff associated with impervious surfaces, and the resulting potential impacts upon the watershed. For example, the commenter recommends the disconnection of impervious surface areas from storm drain systems and routing to vegetated areas prior to entering a waterway.

TheCity’sDEIRandGeneralPlanUpdatedocumentaddresstheissueofstormwater management in several instances. The DEIR recognizes that new development under the proposedGeneralPlanUpdate(oranyoftheAlternativesconsidered,includingthe“no project”Alternative)couldintroduceconstituentsintostormwaterthataretypically associated with urban runoff. These constituents include sediments, petroleum hydrocarbons, pesticides, fertilizers, and heavy metals such as lead, zinc, and copper.

These constituents would result in water quality impacts to onsite and offsite drainage flows to area waterways. The Russian River is included in the Section 303(d) list of impaired water bodies. Discharges of urban runoff into this river may contribute to the 359
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existing impairment. The entire length of the Russian River within the GPU Study Area is listed by the State Water Resources Control Board (SWRCB) as impaired by sediment and temperature.

As previously mentioned, the City is not subject to the NPDES Phase II program with respect to storm water management. Where/when required, Storm Water Management Plans (SWMP) must include the following six minimum control measures:
 Public Education and Outreach on Storm Water Impacts
 Public Involvement/Participation
 Illicit Discharge Detection and Elimination
 Construction Site Storm Water Runoff Control
 Post-Construction Storm Water Management in New Development  Redevelopment and Pollution Prevention/Good Housekeeping for Municipal Operations
Mitigation Measure MM 4.9.1 requires preparation of a Storm Drainage Master Plan that identifies drainage facilities needed to reduce or eliminate drainage problems as well as require the use of Best Management Practices that will eliminate or reduce the discharge of pollutants from construction sites to waters of the state and implement stormwater pollution prevention plans that document the selection and implementation of Best Management Practices for a particular construction project. Mitigation Measure MM

4.9.2 sets a City standard for future development related to storm water runoff –the cumulative rate of peak runoff must not exceed pre-development levels. This would limit the generation of higher peak runoff flows resulting from development, which could produce higher velocities for flow, which in turn increase erosion and sediment discharge. Best Management Practices, energy dissipation measures, stabilization measures, and onsite detention ponds can be applied to and incorporated into proposed development to limit the concentrations of these constituents in any site runoff that is discharged into downstream facilities. Mitigation Measure MM 4.9.3 requires that storm waterdataandrequirementsbeincludedintheCity’sSubdivisionOrdinance.

In addition, General Plan policies and implementation measures CDO 7-1, CDO 7-1.a, CDO 7-1.b, CDO 7-1.c, PS 2-3, and PS 2-4 are designed to ensure minimal surface water quality impacts related to development.

Also see Individual Response A5-1.

Response to Comment A5-9
The commenter provides two comments related to the subject of wastewater. First, the commenter recommends adoption of a water recycling program. Secondly, the commenter states that in their opinion, in order to implement GPU Policy LU 6-3, that the City needs to adopt an Urban Growth Boundary.
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Policy LU 6-3 reads as follows: Discourage development beyond areas with planned expansions of sewer, water, and road systems. Develop a growth phasing plan that addresses location and timing of development and infrastructure.

In response, the City supports water recycling and conservation as reflected in the implementation policies listed below. It is also noted that the City anticipates upgrading its WWTP to provide an advanced (tertiary) level of treatment at some point in the future.

However, a target date or schedule has not yet been set. It is not a condition of the City's current WWTP five-year NPDES Permit (issued by the State Water Resource Control Board). The City will be including an estimated cost for the upgrade in its Wastewater Master Plan Update to be completed in late 2008.

The following GPU implementation measures address the comments received regarding this issue:

Implementation LU 6-1.b. Upgrade the City Wastewater Treatment Plan to provide tertiary treatment. Provide plumbing in new development so that tertiary treated water can be distributed for new development, open space, parks, and other uses.

Implementation LU 6-1.c. Promote water conservation and encourage water conserving landscaping. Adopt water conservation ordinances and mandatory landscaping ordinances if needed to respond to water supply issues.

Implementation LU 6-1.d. Maintain a Water Master Plan for evaluate adequacy of water supplies and to provide a framework for timed capital improvements, financing of improvements, and facility expansion.

With respect to the comment regarding an Urban Growth Boundary, please see Master Response # 4.

Response to Comment A5-10
The commenter speaks to four issues related to groundwater as follows:

1. Section 4.4, DEIR page 4.4-2 should include information regarding the Cortese List;

2. The former Masonite site is inaccuratelymappedonDTSC’sEnviroStor;

3. Correction of text on DEIR page 4.4-4asfollows:“SonomaCounty,with oversight from the North Coast Regional Water Board, administers a cleanup programtoaddressdischargesfromundergroundstoragetanksystems”.

4. It is recommended that the GPU contain mitigation measures to require soil and/or groundwater management plans for closed and active cleanup sites if development is proposed in the vicinity.

In response, the City concurs with the commenter and will make the necessary corrections to the DEIR text. The City notes that regarding Item #1, information regarding the Cortese List is included in the DEIR, Section 4.4.1, Existing Setting.

With respect to Item #4, the DEIR contains the following information:
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Table 4.4-4 lists federal, state, and local regulatory agencies that oversee hazardous materials handling and hazardous waste management, and the statutes and regulations that they administer. Other applicable state and local hazardous materials laws and policies are provided in Table 4.4-5.

Implementation of the proposed General Plan Update may result in known and unknown hazardous material being discovered or encountered at subsequent development sites.

Known hazardous waste sites are identified in Table 4.4-1. Most of these sites involve issues of leaking underground storage tanks typically associated with past automobilerelated activities located in proximity to U.S. Highway 101. Within the Study Area, there are 12 SLIC (Spills, Leaks, Investigations, and Cleanups) sites and 22 LUFT (Leaking Underground Fuel Tanks) sites with open files.

A GPU Policy and/or implementation measure requiring soil and/or groundwater management plans for closed and active cleanup sites if development is proposed in the vicinity is proposed as an addition to the GPU.

Response to Comment A5-11
The commenter reiterates information regarding existing regulatory standards and requirements.
[See comments regarding Response A5-7; The City agrees that this is pertinent information and as such, this information has been included in the DEIR. See Individual Response A5-1.

Response to Comment A5-12
The commenter summarizes by reiterating their recommendation to include more detailed mitigation measures to support polices. They also recommend public outreach and education programs.

The City emphasizes that they have prepared a program level DEIR which is appropriate for a project such as General Plan Update pursuant to CEQA. The City is confident that they have proposed adoption of adequate GPU policies and implementation measures which will effectively carry out the existing regulatory framework on the local, State, and Federal levels. Early in the process, the City made the decision to prepare a selfmitigating document thusly avoiding the need and possible ineffectiveness of a lengthy list of mitigation measures and associated monitoring requirements. The draft General Plan was formulated to minimize environmental impacts, with the goal that adoption of the General Plan would be the primary mitigation of impacts identified in the Environmental Impact Report. During the DEIR process, the General Plan Update document was modified to address environmental concerns which became apparent but have now been mitigated through effective policy and implementation programs. (See Revised GPU, September 2008)
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TheCity’sGPUcontainsseveralpoliciesandimplementationmeasuresdirectedatpublic education and outreach in a variety of areas, including historical and cultural resources, proper use of storm drains, wildlife conservation, housing, and emergency services.

Responses –Organizations
Letter O1. Citizens for a UGB (Urban Growth Boundary)
Response to Comment O1-1:

The commenter recommends that a) the City adopt language into the General Plan specifying uses allowed within and outside of the proposed UBG, b) include an UGB map in the General Plan, and c) adopt language to protect hillside areas above 20% slope.

In response, the City has included a map showing the approximate location of the proposed UGB (see General Plan Update Exhibit 2.5). Implementation Policy LU 3-2.b requires the development of a hillside ordinance for any areas over 20 % slope that are within the UGB. (See Master Response #4 for more information related to the UGB).

Much of the discussion of the UGB and associated issues are outside the purview of the EIR and are strictly General Plan policy issues. (See Master Response #1).

Letter O2. Citizens for a UGB (Urban Growth Boundary)
Response to Comment O1-2:

The commenter indicates that adoption of an UGB by voter approval is more effective than adoption by ordinance.

In response, the City General Plan Update Implementation Policy LU 3-1.a requires the adoption of an UGB Ordinance within 6 months of General Plan adoption, followed by the placement of the ordinance on the ballot of the first election following ordinance adoption. Much of the discussion of the UGB and associated issues are outside the purview of the EIR and are strictly General Plan policy issues. (See Master Response #1). (See Master Response #4 for more information related to the UGB).

Letter O2. Greenbelt Alliance
Response to Comment O2-1:

ThecommenteracknowledgesthattheCity’sself-mitigating General Plan and associated DEIR are well thought out documents; however, it is recommended that more mitigation measures should be adopted as policies.

The writer's general comment above is elaborated on in the more specific comments in the writer's letter, which are responded to below.

Response to Comment O2-2:
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The commenter expresses concerns regarding the proposed UGB.

In response, the City has prepared Master Response #4 which focuses upon the issue of the proposed UGB.

Response to Comment O2-3:

The commenter raises several issues related to adoption of an UGB as follows: a) the General Plan Update should include policy language directing that an UGB ordinance be adopted, followed by voter adoption; b) uses allowed within and outside of the UGB should be included in the General Plan Update; and c) the General Plan update should include an UGB map.

In response, the City concurs with Items (a) and (c) above, and has included policy language addressing these items. See Response OA 1-2, and Master Response #4. Any future proposed ballot measure will both adopt a UGB ordinance and amend the General Plan, so that the future ordinance becomes a part of the city's General Plan upon approval by the voters.

With respect to Item (c), the UGB boundaries are mapped (exhibit 2.5). That map will be revisedtoremove“illustrative”fromthetitle.

Response to Comment O2-4:

The commenter is concerned about an increase of acreage designated Conservation Features in the proposed General Plan Update document and questions adequate analysis of this in the DEIR. The commenter continues to recommend that mitigation for this concern may be accomplished through the adoption of an UGB.

The City concurs with the commenter and has included adoption of an UGB as part of the proposed GPU. This is explained in several of the preceding comments, as well as Master Response #4. The Conservation Features land use designation reads as follows:

The purpose of this designation is to manage and preserve valuable biological, visual, and agricultural resources in the Cloverdale Planning Area. Primary uses include river/stream-related recreation, open space buffers, and agricultural production.

Setbacks of 50 feet from tributaries are encouraged, and between 300 feet to 1,000 feet around the Russian River.

The City’sDEIRhasanalyzedthepotentialprogramlevelimpactsassociatedwith potential development within the Study Area over the life of the Plan. See Response #4 for a complete discussion of issues associated with the proposed UGB.

Response to Comment O2-5:
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The commenter expresses concerns regarding the potential conversion of agricultural lands given adoption of the proposed General Plan Update. The commenter recommends excluding the Asti area and adjacent vineyards from the proposed Sphere of Influence.

The commenter recommends the following revised language be adopted by the City as policy:

City Proposed Policy LU 6-3: Discourage development beyond areas with planned expansions of sewer, water, and road systems. Develop a growth phasing plan that addresses location and timing of development and infrastructure.

Commenter Proposed Policy LU 6-3: Plan expansion of sewer, water, and road systems to support development within the Urban Growth Boundary. Any expansion of sewer or water service to the UGB Exception Areas shall be provided with pipes sized at the minimum diameter necessary to serve the Exception Areas at buildout.

In response, the City concurs that agricultural land is an important resource which needs protection. The City has placed a growth cap within the Plan in order to mange growth in the Cloverdale area and to help minimize impacts associated with growth. The proposed UGB recognizes existing uses and developed areas, and as such, provides the opportunity to comprehensively plan for continued development of these areas with minimal impact upon the surrounding agricultural lands. The City may consider a revision to proposed Policy LU 6-3 as suggested by the commenter in order to further define infrastructure expansions in these areas. Also, see Master Response #4 regarding UGB and Master Response #3 pertaining to Agricultural Lands.

Response to Comment O2-6:

The commenter expresses concerns related to potential impacts to riparian corridors. The commenter suggests adopting language whichissimilartoSonomaCounty’sGeneral Plan as follows:

Sonoma County Policy OSRC-8b: Establish streamside conservation areas along both sides of designated Riparian Corridors as follows, measured from the top of the higher bank on each side of the stream as determined by PRMD:
(1) RussianRiverRiparianCorridor:200’
(2) FlatlandRiparianCorridors:100’
(3) OtherRiparianCorridors:50’*
TheCity’sGPUandDEIRcontainspolicylanguageandanalysisaddressingthisissueas described in portions of Master Responses #1, #2, and #4. Additionally, information related to riparian corridor protection has been included in the following individual specific responses: A1-1, A1-3, A1-4, A5-2, and A5-4.

Response to Comment O2-7:

The commenter recommends that the GPU designate future school sites. 365
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In response, the City has included several GPU policies and implementation measures related to this item. The school district was consulted during the preparation of the GPU regarding the need for additional school facilities at this time and into the future.

Implementation policies and measures LU 5-1, LU 5-1a, LU 5-1b, LU 5-1c, LU 5-1d, and LU 5-1e have been included in the proposed GPU and are considered adequate to address any potential issues associated with school facilities.

Response to Comment O2-8:

Thecommenterhasexpressedaconcernthatthe“baseofhill’linehasnotbeen delineated. They suggest that a) the General Plan contain policy requiring that a survey be prepared for projects located near the UGB line, and b) require landowners to donate conservation easements to the Open Space District on lands above 20% slope in exchange for the right to develop on the flat portion of the property. The following policies and implementation measures are taken from the GPU and address the commenter’sconcerns:

Policy LU 3-1: Develop an Urban Growth Boundary that allows urban development within the boundaries and does not allow urban development outside the boundaries.

Urban development should be within the GeneralPlanStudyAreaandbelowthe“Base ofHill”asdefinedinExhibit2.2exceptfortheareatothesouthofSandholmLane extended and north of Bluxom Creek, where development may be allowed above the base of hill but behind the hill if the primary access road visible to the City is below the base of hill, and houses, night lighting, street lighting, and roadways above the base of hill are not visible from the balance of the City.

Policy LU 3-2: Expansion into hillside areas shall be consistent with the Conservation, Design, and Open Space Element, to eliminate or minimize visual, access or lighting impacts in hillside areas, particularly in the western hillsides.

Implementation LU 3-2.a. Amend the Zoning Ordinance to include provisions of Exhibit

2.2, including the provision for Base of Hill, net acreage, environmentally sensitive lands.

Implementation LU 3-2.b. Develop a hillside ordinance prior to any construction above base of hill if the Urban Growth Boundary allows hillside development.

Implementation LU 3-2.c. Coordinate with Sonoma County to assure that City hillside view policies are communicated and implemented in any County approvals.

Policy CDO 1-1: Urban development in the City will be on the valley floor, defined generally as the land below the Base of Hill. Development will be framed by and contained within agricultural lands to the north and south, the Russian River to the east, and below the Base of Hill (defined as the location where the valley floor transitions to a 20% slope or greater using 5 foot slope contours or less) on hillside areas). 366
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Policy CDO 2-1: Adopt a hillside ordinance or a hillside provisions within the Zoning Ordinance to implement hillside development provisions.

Policy CDO 2-2: Where a parcel has land both below and above the Base of Hill, development rights to the hillside areas shall be transferred to the area below Base of Hill, and hillside areas will remain as visual open space with easements or other legal guarantees that include the City as a participant. Any hillside areas shall provide for trails as outlined in the Parks and Recreation Element.

Policy CDO 2-3: Where a property within the City as of the date this General Plan is adopted does not have lands below the Base of Hill, residential development above the Base of Hill may be allowed if:
 The development conforms to General Plan densities
 The residential use, including grading for roadways and lighting, will not be visible from the valley floor within the City because it is positively screened by topographic features.
 The residential use provides guarantees that the hillside areas will remain as visual open space with easements or other legal guarantees that include the City as a participant.

The open space areas provide for trails as outlined in the Parks and Recreation Element.

Responses –Individuals
Letter I1. Roz Katz
Response to Comment I1-1:

The commenter expresses concern regarding the proposed designation of Foothill Boulevard as an Arterial.

In response, the City notes that Foothill Boulevard has characteristics which could justify either arterial or collector status, but not residential street status. Although it does not carry large volumes of traffic indicative of an arterial street, it does serve a long distance.

The traffic volume and function may be more in line with a collector street designation.

However, given that Foothill Boulevard is the only continuous parallel facility to Cloverdale Boulevard, its designation as an arterial street may be more prudent because of public safety functions.

Letter I2. James Wagele
Response to Comment I2-1:

The commenter expresses concern regarding future development west of Foothill Boulevard.
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In response, the City notes that the General Plan traffic analysis assumes development of all undeveloped properties which are zoned in the General Plan land use element. Traffic assignments of these undeveloped properties utilized Foothill Boulevard to gain access to Cloverdale Boulevard and US 101 interchanges as well as for longer trips to/from Treadway Drive. Therefore, impacts of these properties on the local circulation system were addressed in the traffic analysis. For local circulation, Foothill Boulevard is positioned as the only continuous link parallel to Cloverdale Boulevard. Therefore, its function in public safety issues also should be considered in addition to traffic volumes.

Letter I3. John MacKie, Esq for Pacific States Industries, Inc Response to Comment I3-1:

The Comment notes that Policy LU 1-4 states that there should be a buffer between industrial and residential uses, that there is a concern that the buffer between industrial uses west of the freeway and the proposed residential area east of the freeway in the McCray Road Area is not sufficient, and that notices and/or deed restrictions should be recorded on residential properties adjoining industrial uses informing of the right to industrial use.

In response, the EIR analyzed noise impacts related to industrial use in the mentioned area and found no significant impact. Other potential impacts would be speculative. It is noted that there is a minimum separation of 350 feet between the industrial area and the designated residential area, and that separation is a freeway and a rail line.

Implementation LU 1-4a is performance based, requiring subsequent development to mitigate for the existing development (in this case, the residential development must analyze and mitigate for the existing industrial impacts). No further mitigation would be necessary in the General Plan, but will be analyzed and proposed in subsequent development review.

Response to Comment 13.2.

The comment notes that Implementation LU 1-4b may allow transfer of industrial designation from the west of the freeway to the east of the freeway, that Pacific States Industries would not want its land use to become non-conforming because of changes in land use outside of its control, and that the property owner would like flexibility in land uses in the future. This comment relates to General Plan policy rather than to the Draft EIR.

However, the land use policies for the Pacific States Industries Redwood Empire Asti Property would be General Industrial under the Urban Growth Boundary industrial exception area. The UGB will not allow changes in that designation during the UGB time frame (20 years). The General Industrial designation under the UGB industrial exception area is not controlled by property owner decisions on the west of the freeway.

The UGB as proposed would not allow flexibility in land uses because of the nature of the UGB industrial exception areas. \
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Response to Comment 13.3.

The comment notes that Policy LU 3-1 would allow continued industrial use under the UGB industrial exception area. It also requests that there be flexibility of uses with alternative to industrial use and that infrastructure, if installed to the site, be made available to alternative non-industrial uses. This comment relates to General Plan policy, rather than to the Draft EIR.

However, as noted in response to Comment 13.2, the nature of UGB exception areas as presently proposed would not allow alternative uses or infrastructure for alternative uses.

Letter I4. Robert Sexton for Tyris Corporation
Response to Comment I4-1 through I4-14:

Comments 14.1 –14-4, 14.11, 14-13, and 14-14.

The comments are related to General Plan policies and not to the EIR. They are appropriate for review in the General Plan public hearings. Comments are noted.

Comments 14-5 –14-9 These comments generally ask that EIR text, charts, and maps be corrected for the Alexander Valley Resort project. Changes will be made, as shown in Section 4, "Minor Changes and Edits to the Draft EIR."
Comment 14.12.

The comment requests that the noise contours for aircraft use and policies for aircraft noise be modified to allow alternate noise standards if approved by the Airport Land Use Commission.

The request would allow ALUC to approve noise standards in conflict with the noise studies done for the General Plan. This could result in noise levels in excess of those evaluated in the Draft EIR, with a potential unmitigated adverse impact. The requested change is not consistent with the Draft EIR or General Plan policy and will not be made.

Individual Oral Comments I5; John Doble –11/5/08 PC Meeting Response to Comment I5-1:

The commenter stated that the proposed UGB should use parcel lines as the boundary and that the UGB should be the same as the Sphere of Influence.

This comment relates to General Plan policy, rather than to the Draft EIR. However, the City will consider both comments in conjunction with development of the proposed UGB ordinance. See Master Response #1 and Master Response #4. 369
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Individual Oral Comments I6; Diane Bartleson –11/5/08 PC Meeting Response to Comment I6-1:

The commenter recommends more language be added to the GPU related to the UGB in order to ensure that the UGB ordinance is adopted and wants a guarantee that the line would not be amended in the future.

The City Council has already adopted a resolution approving an UGB, and directed that the approximate location be included in the GPU. The proposed ballot measure will both adopt a UGB ordinance and amend the General Plan, so that the future ordinance becomes a part of the city's General Plan upon adoption by the voters. Although the General Plan can be further amended, that would require a separate public hearing and approval process, and a voter-adopted amendment could not be changed except by another vote of the people. Also, see Master Responses #1 and #4.

Individual Oral Comments I7; Dick Schwartz –11/5/08 PC Meeting Response to Comment I7-1:

The commenter recommends that the City consider pre-zoning parcels within the Sphere of Influence and the UGB. Also, the City should consider provision of infrastructure to these areas.

Inresponse,itisnotedthattheCity’sGPUproposeslandusedesignationsfortheentire Study Area, which includes the SOI and the UGB. Additionally, the GPU addresses the provision of infrastructure to expansion areas, as well as the timing of said infrastructure development.

Individual Oral Comments I8; Melanie Bagby –11/5/08 PC Meeting Response to Comment I8-1:

The commenter supports the UGB as proposed by the City, and points out the importance of concentrating growth and protecting water supplies.

In response, it is noted that the City concurs with these points and has addressed these items in the GPU.

Individual Oral Comments I9; Russ Peihl –11/5/08 PC Meeting Response to Comment I9-1:

The commenter had questions related to the adoption process associated with the UGB.

In response, the City has outlined the procedure for adoption of the proposed UGB. The City Council has adopted a resolution in support of an UGB, and the GPU calls for approval of an ordinance, which will then be placed on the ballot for voter adoption. The proposed ballot measure will both adopt a UGB ordinance and amend the General Plan, so that the future ordinance becomes a part of the city's General Plan if adopted by the voters.
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CHAPTER 4
Minor Changes and Edits to the Draft EIR
Introduction and Project Description
This chapter will provide any revisions that are made to the text of the Draft EIR.

Modifications will be organized by chapter and a page number (referring to the original text’slocationintheDraftEIR)willalsobeprovided.Textadditionswillbeshownin underline and text deletions will be shown in strikeout.

Revise second paragraph on page 2.0, Section 2.5 to include the following text.

Because policies have been incorporated into the General Plan to avoid or reduce environmental impacts, the Plan itself is self-mitigating to the greatest extent possible.

Many Plan policies therefore act as mitigation for impacts that would otherwise occur or be more severe. Where needed and feasible, additional mitigation measures (MM) have been proposed. The self-mitigating General Plan policies are included in the lists of MM in the following sections.

Revise fourth paragraph on page 3.0-2 to read:

The City Council received the recommendations of the Planning Commission and held public input meetings on the draft plan. The council considered land use changes related toissues.OnMay9,2007,theCityCouncilreleasedadraft“project”forEIR consideration.

Revise first bullet of paragraph 4, page 3.0-33 as follows:
 Revisions to the Municipal Code, including the Subdivision and Zoning Ordinances to update existing resolutions regulations ensuring consistency with the General Plan.

Revise parkland acreage table 4.1.4 as follows:

Park type Existing City Parks Total
acres
Needed for
12,000
population
Additional
acreage needed
by 2025
Neighborhood Park.s Tarman Park 0.5 ac
Vintage Meadows 3.5 ac.

Brookside Mini Park0.2 ac.

4.2 Community Parks City Park 7.4 ac.

Furber Park 6.0 ac.

13.4 Active Open Space River Park 10.3 ac.

Porterfield Ck 10.0 ac.

Clover Springs 5.6 ac.

25.9 Community
Center/Administrative

0.3 acres/1,000
Downtown Plaza 0.4 ac
Senior Center 0.4 ac.

0.8 372
120
Total 5 acres per 1,000
population

44.3 60 acres 15.7 acres
Open Space Recreation

1.5 acres/1,000
population
River Park 58.2 passive ac.
(includes County land)

58.2 No standard
established
Revise second and third paragraphs, page 5.0-42 as follows:

This EIR identifies policies and local implementing actions which can assist in the reduction of GHG emissions. Mitigation Measure 5.0.1 requires the preparation of a Climate Action Plan with specific requirements for quantification of emissions data and targets for reduction. However, as noted above, the regulatory climate is presently evolving, and no air district in California has adopted a quantified threshold of significance for local GHG emissions. Not all anticipated State reduction measures have been adopted at this time, and there is a substantial level of uncertainty about their effectiveness and how they will apply to local governments. It is also difficult, if not impossible, to presently determine to what extent local reduction measures will affect statewide, national or global climate change. AB 32 commits the State of California to reducing its GHG emissions to 1990 levels by 2020. Buildout of the General Plan Planning Area, without accounting for State and federal GHG reduction measures and the potential benefits of new technology, would most likely result in local GHG emission levels which exceed 1990 levels. However, it is also probable that State and federal measures coupled with local GHG reduction programs and new technology will have a beneficial effect on GHG emission levels at General Plan Buildout.

TheCity’sGeneralPlanpoliciesandimplementingactionslistedabove,Stateandfederal reductionmeasuresapplicableinCloverdaleandtheCity’sClimateActionProgram required by Mitigation Measure 5.0.1 can effectively reduce GHG emissions. However, because of the technical and regulatory uncertainties noted above, it cannot presently be determined to a reasonable degree of certainty that Buildout under the General Plan Update will not result in a substantial increase in GHG emissions compared to existing conditions. Because it is therefore not possible to conclude that Buildout will not result in a cumulatively considerable incremental contribution to the significant cumulative impact of global climate change, this impact is considered significant and unavoidable.

Revise Impact 5.23, page 5.0-43 as follows:

Impact 5.23 The cumulative impacts of global climate change may result in decrease in water supply, increase in air pollutants, and increase in health hazards. This could create significant cumulative effects.

Revise second paragraph, page 5.0-44 as follows:

While the General Plan policies and implementing actions would reduce the potential GHG emissions in the City, the effects of global climate change on the City are partly the 373
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result of global GHG emissions. As noted in the discussion under Impact 5.22, technical and regulatory uncertainty surrounding GHG emission reduction efforts make it impossible to conclude that General Plan buildout in Cloverdale will not result in a substantial increase in GHG emissions over existing conditions in the City. However, it is probable that even the complete elimination of additional GHG emissions in the City through General Plan Buildout would not significantly alter climate change on a global scale because City emissions make up such a miniscule proportion of global GHG emissions. The CCCC report discussed above speaks of possible changes under a variety of scenarios by the end of the century, a time period far beyond the 2025 buildout horizon of the General Plan Update. For the purposes of evaluation under CEQA, specific impacts of global climate change within Cloverdale as of 2025 are incapable of determination with any degree of certainty based on available information. As is noted under Impact 5.22, it is also not possible to determine whether any increase in local GHG emissions resulting from buildout will make a cumulatively considerable incremental contribution to those effects. Because it is therefore not possible to conclude that buildout will not result in a cumulatively considerable incremental contribution to the potentially significant cumulative impacts of global climate change on the City, this impact is considered significant and unavoidable.

Minor Changes to the Environmental Analysis
I. Sonoma LAFCO - Response to Comment A3-4:

The commenter recommends that specific properties under Williamson Act contract be identified. The City will include a map as part of the FEIR which will identify contracted lands, and provide an acreage summary. Impacts are not anticipated to change, see Master Response #3, Agricultural Land, which addresses potential agricultural land conversion issues in detail.

Revision: New Figure 4.2-3 titled“WilliamsonActLand”willbeadded to the EIR and will appear on page 4.2-10.

II. Sonoma County PRMD - Response to Comment A4-1
ThecommenternotesthatreferencesintheCloverdaleGPUDEIRtothe“DraftSonoma CountyGeneralPlan”shouldbechangedto“GP2020”astheCountyGeneralPlan has been adopted. Commented noted and the City concurs and will revise the EIR as needed.

Revision:“DraftSonomaCountyGeneralPlan”replacedwith“GP2020”throughout EIR.

III. Sonoma County PRMD - Response to Comment A4-2:

Commenter notes that the City of Windsor was omitted from the DEIR Section 4.1.1.

Commented noted and the EIR will be revised accordingly. 374
122
Revision: The City of Windsor will be added to the list of cities found on DEIR page 4.1- 1, Section 4.1.1, Regional Setting.

IV. California Regional Water Quality Control Board, North Coast Region - Response to Comment A5-2:

The commenter states that the DEIR only considers three creeks, and the Russian River, to be significant within the Study Area. DEIR Figure 4.10-2 illustrates the known wetlands and streams present within the study area and vicinity. This figure is not meant to be a comprehensive account of all waters, including wetlands, within the study area.

The City notes the comment by RWQCB and will revise the Draft EIR to include a clarifying statement that there are other creeks, drainages, etc in the Study Area in addition to the four listed in the current DEIR.

Revision: DEIR Section 4.9.1 - Existing Setting: Local Surface Water Features, page

4.9-1. Underlined text will be added.

The City of Cloverdale is located in the Alexander Valley Groundwater Basin. The Study Area includes one (1) major river, the Russian River, and three (3) significant creeks, Cloverdale Creek to the north, Porterfield Creek to the south, and Cherry Creek near central Cloverdale. There are also other creeks and drainages existing within the Study Area which carry varying degrees of water and support a range and variety of wildlife habitat.

V. California Regional Water Quality Control Board, North Coast Region - Response to Comment A5-10: The commenter points out that the former Masonite site isinaccuratelymappedonDTSC’sEnviroStor.Also,acorrectionoftextonDEIRpage

4.4-4isneededasfollows:“SonomaCounty,withoversightfrom the North Coast Regional Water Board, administers a cleanup program to address discharges from undergroundstoragetanksystems”.ThesechangeswillbemadetotheEIR. 375
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CHAPTER 5
Report Preparation
City of Cloverdale
Director of Community Development ..........................................................................Bruce Kibby PMC
EIR Project Advisor...............................................................................................Chris Stabenfeldt EIR Project Director ............................................................................................. Ignacio Gonzalez EIR Project Manager.................................................................................................... Gary Pedroni Cultural Resources.......................................................................John Nadolski; Tina Pitsenberger Biological Services Director................................................................Joyce Hunting; Elaine Flock Fiscal Analysis...........................................................................................Derek Wong; Julia Light GIS Graphic Production..................................................................John DeMartino; Robert Noyes Air Quality Analysis............................................................................... Doug Kim; Jeremy Bailey Climate Change.......................................................................................Mike Martin; Seth Meyers Creative Services Document Production ...................................................................Roxanne Perry Environmental Planner.................................................................................................Terry Farmer Environmental Planner......................................................................................................Kim Voge W-Trans –Transportation Consultants
Transportation Engineers..............................................................Steve Weinberger; Chris Meyers Bollard - Noise Consultants
Vice President ...............................................................................................................Jason Mirise Tully & Young - Water Consultants
Principal ...............................................................................................................Gwyn-Mohr Tully Miller Pacific - Geologic Consultants
Geologist....................................................................................................................... Mike Dwyer 376
124
CHAPTER 5
Report Preparation
City of Cloverdale
Director of Community Development ..........................................................................Bruce Kibby PMC
EIR Project Advisor...............................................................................................Chris Stabenfeldt EIR Project Director ............................................................................................. Ignacio Gonzalez EIR Project Manager.................................................................................................... Gary Pedroni Cultural Resources.......................................................................John Nadolski; Tina Pitsenberger Biological Services Director................................................................Joyce Hunting; Elaine Flock Fiscal Analysis...........................................................................................Derek Wong; Julia Light GIS Graphic Production..................................................................John DeMartino; Robert Noyes Air Quality Analysis............................................................................... Doug Kim; Jeremy Bailey Climate Change.......................................................................................Mike Martin; Seth Meyers Creative Services Document Production ...................................................................Roxanne Perry Environmental Planner.................................................................................................Terry Farmer Environmental Planner......................................................................................................Kim Voge W-Trans –Transportation Consultants
Transportation Engineers..............................................................Steve Weinberger; Chris Meyers Bollard - Noise Consultants
Vice President ...............................................................................................................Jason Mirise Tully & Young - Water Consultants
Principal ...............................................................................................................Gwyn-Mohr Tully Miller Pacific - Geologic Consultants
Geologist....................................................................................................................... Mike Dwyer 1193576.1
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1 Comment From HCD (Dept. of Housing & Community Development) City Response A Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)
As part of the evaluation of programs in the past cycle (pages 32-44), the element must provide an explanation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female-headed households, farmworkers, and persons experiencing homelessness). Programs should be revised as appropriate to reflect the results of this evaluation.

Section 1.15 (Policy
Changes in 2023 Housing
Element) revised to reflect
the City-funded
construction of Cherry
Creek Village and
approval of Alexander
Valley Apartments.

B1 Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)
Disparities in Access to Opportunity: The element does not include comparison on a regional level for economic opportunity to adequately compare to the City.

Disproportionate Housing Needs, Including Displacement: The element includes minimal information on trends and patterns on a regional level for homeless and displacement to adequately compare to the City.

Local Data, Knowledge, and Other Relevant Factors: The element must include local data, knowledge, and other relevant factors to discuss and analyze any unique attributes about the City related to fair housing issues. The element should complement federal, state, and regional data with local data and knowledge where appropriate to capture emerging trends and issues, including utilizing knowledge from local and regional advocates and service providers, City staff and related local and county planning documents and should include an analysis of the history of exclusionary zoning in the City.

Identification and Prioritization of Contributing Factors: The element must list and prioritize Analysis of regional trends
and jobs/housing ratio
added.

Regional analysis added.

Analysis of single-family
zoning patterns,
population over time, and
redlining added to
Section 4.5.3 (Segregation
and Integration Patterns
and Trends).

Analysis added to
378
2 contributing factors to fair housing issues. Contributing factors create, contribute to, perpetuate, or increase the severity of fair housing issues and are fundamental to adequate goals and actions. While the element includes some information on contributing factors, the City should include examples such as community opposition to affordable housing, housing discrimination, land use and zoning laws, lack of regional cooperation, location and type or lack of affordable housing and lack of public or private investment in areas of opportunity or affordable housing choices. The analysis shall result in strategic approaches to inform and connect goals and actions to mitigate contributing factors to affordable housing.

Contributing Factors
subsection, Section 4.5.7
(Summary of Fair Housing
Issues).

B2 An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Emergency Shelter: The element states that currently emergency shelters must go through a discretionary review process and that program IP 2.3.3 has been included to be consistent with state Law. However, the program commits to allow emergency shelters to be a by-right use in zones consistent with statutory requirements but does not specify the zones where emergency shelters will be allowed by right. Program IP 2.3.3 should be revised to include the zone where emergency shelters will be permitted.

Please note the element cannot be found in compliance until a zone or zones where emergency shelters are allowed as a permitted use without a conditional use or other discretionary permit (Government Code Section 65583(a)(4)). The identified zone or zones must include sufficient capacity to accommodate the need for emergency shelter and must accommodate at least one year-round shelter.

In addition, please be aware Chapter 654, Statutes of 2022 (AB 2339), adds additional specificity on how cities and counties plan for emergency shelters and ensure sufficient and suitable capacity. Future submittals of the housing element may need to address these statutory requirements. For additional information and timing requirements, please see HCD’s memo at https://www.hcd.ca.gov/sites/default/files/docs/planning-andcommunity/ab2339-notice.pdf.

IP-2.3.3 revised to allow
emergency shelters as a
by-right use in the TOD
zone.
379
3 Supportive Housing: The element should clarify if there are policies/procedures to accommodate AB 2162 or should include a program.

Subprogram added to IP2.3.3 (Code Changes) to
ensure compliance with
AB 2162 and provide a
written streamlined
application process.

B3 An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).) Processing and Permit Procedures: The element states that there are projects that require major and minor design review. The element must describe and analyze the design review guidelines and process, including approval procedures and decision-making criteria, for their impact as potential constraints on housing supply and affordability. For example, the analysis could describe required findings and discuss whether objective standards and guidelines improve development certainty and mitigate cost impacts. The element must demonstrate this process is not a constraint or it must include a program to address this permitting requirement, as appropriate.

Fees and Exactions: While the element includes estimated development impact fees for single family and multi-family housing, it should include estimates that include all other permitting fees for both single family and multi-family housing.

Inclusionary Housing: The element must specifically analyze locally adopted ordinances such as inclusionary ordinances that directly impact the cost and supply of residential development. The City appears to have an inclusionary ordinance, however no information was provided in the element. The element must describe and analyze the City’s inclusionary housing requirements, including its impacts as potential constraints on the development of housing for all income levels. The analysis must evaluate the inclusionary policy’s implementation framework, including levels of mandated affordability and the types of options and incentives offered to encourage and facilitate compliance with the inclusionary Subprogram included in
IP-2.3.3 (Code Changes)
to adopt objective design
and development
standards.

Building fees added to
Local Permitting and
Processing Fees section.

Inclusionary Housing
analysis added to the
Technical Background
Report (TBR) indicating
thresholds and in-lieu fee
applicability.
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4 requirements.

C1 To have a beneficial impact in the planning period and meet the goals and objectives of the housing element, programs must have specific commitment and timelines toward tangible outcomes. Programs to be revised with a metric and geographic targeting include Programs

1.1.1 (Rehabilitation/Preservation Program), 2.2.1 (Accessory Dwelling Units), 3.1.1 (Funding Affordable Housing), 3.1.2 (Housing Fund), 5.1.1 (Equitable Representation). In addition, Program 1.1.2 (Neighborhood Revitalization) should be revised to include a geographic targeting and Program 2.3.1 (Flexible Parking Options): should be revised to include a complete review and make recommendations.

Geography added to each
program listed.

Program 2.3.1 revised to
quantify outreach and
timeline for review of
shared parking program.

C2 As noted in Finding B2, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to encourage a variety of housing types.

A complete Sites
Inventory will be
transmitted to HCD with
the Adopted Housing
Element.

C3 The element must include a program(s) with specific actions and timelines to assist in the development of housing for extremely low-, very low-, low-, and moderate-income households. The program(s) could commit the City to adopting priority processing, granting fee waivers or deferrals, modifying development standards, granting concessions and incentives for housing developments that include units affordable to lower and moderateincome households; assisting, supporting or pursuing funding applications; and outreach and coordination with affordable housing developers.

IP 3.1.1 (Funding
Affordable Housing)
amended to include fee
deferrals, priority
processing,
concessions/incentives,
in-kind technical
assistance, and outreach
to affordable housing
developers.

C4 As noted in Finding B3, the element requires a complete analysis of potential governmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

No revisions to the
Housing Constraints
Analysis in the Adoption
Draft Housing Element
were found to necessitate
the addition or revision of
programs.

C5 As noted in Finding B1, the element must include a complete assessment of fair housing.

Based on the outcomes of that analysis, the element must add or modify programs. Goals and actions must specifically respond to the analysis and to the identified and prioritized All programs referenced
in the programmatic
381
5 contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, metrics, milestones, and geographic targeting as appropriate and must address housing mobility enhancement (more choices and affordability across geographies), new housing choices and affordability in higher opportunity and income areas (e.g., missing middle housing types), place-based strategies for community preservation and revitalization and displacement protection.
analysis of contributing
factors (TBR Table 30: Fair
Housing Issues,
Contributing Factors, and
Programs & Actions) have
been revised to reflect
program geography and
expanded metrics.
382
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
March 9, 2023
Kevin Thompson, Director
Community Development Department
City of Cloverdale
124 N Cloverdale Boulevard
Cloverdale, CA 95425
Dear Kevin Thompson:

RE: City of Cloverdale’s 6th Cycle (2023-2031) Draft Housing Element Thank you for submitting the City of Cloverdale’s (City) housing element received for review on December 9, 2022, along with revisions received on March 8, 2023.

Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a meeting on March 2, 2023, with City’s consultants Jane Riley, Elliott Pickett and Luke Lindenbusch. In addition, HCD considered comments from, YIMBY Law and Greenbelt Alliance, pursuant to Government Code section 65585, subdivision (c).

The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code). See enclosed Appendix.

As a reminder, the City’s 6th cycle housing element was due January 31, 2022.

As of today, the City has not completed the housing element process for the 6th cycle. The City’s 5th cycle housing element no longer satisfies statutory requirements. HCD encourages the City to revise the element as described above, adopt, and submit to HCD to regain housing element compliance.

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. During the housing element revision process, the City must continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available while considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.
383
Kevin Thompson, Director