Corona City Council
July 1, 2026

December 2015 5.0 Alternatives
City of Corona Skyline Heights Project
PCR Services Corporation/SCH No. 2014021003 5-17
services including circulation improvements, drainage facilities, water, reclaimed water and sewer facilities are available to serve the project and meet or exceed applicable City standards and requirements prior to, or concurrent with development; (7) provide strategic improvements within the project to assist the City with Master Plan improvements to existing water and sewer system; (8) provide water reservoirs and infrastructure to improve service and reliability for other parts of the City; (9) provide a system of open space which combines natural and man-made areas to maintain a scenic and fire safe living environment for residents; (10) implement a comprehensive landscape program which provides visual continuity throughout the project area and the natural areas of the Cleveland National Forest; or (11) help meet the high market demand for high quality housing in western Riverside County and to meet the City’s housing needs to support forecasted population growth as discussed in the City’s General Plan (2004). b. Alternative 2 – Reduced Density Alternative
(1) Description of Alternative
Alternative 2, the Reduced Density Alternative, would result in the annexation of the proposed annexation area into the City of Corona as well as the development of a single-family residential neighborhood within the 270.9-acre project site, but at a density consistent with the existing Rural Residential I land use designation prescribed in the City of Corona General Plan for this portion of the City’s Sphere of Influence, which allows for single-family residential uses between 0.2 and 0.5 dwelling units per acre. Thus, this Alterative would allow for development of up to 136 single-family dwelling units on the 270.9-acre project site, or an overall density of approximately 0.5 dwelling units per acre, with residential lots clustered throughout the project site (as under the proposed project) in order to minimize site disturbance. It is anticipated that given the topography of the project site, substantial grading would still be required to accommodate the development, which would include grading for residential lots, building pads, graded slopes, roadways, water tank(s), and other improvements, but the physical extent and intensity of earthmoving operations would be incrementally reduced under this Alternative. This Alternative is intended to decrease the overall development footprint of the proposed project, which would result in reduced landform alteration and urban development that is visible from surrounding viewpoints, including public trails and designated scenic roadways. Although reduced in terms of overall intensity, this Alternative would result in a similar suite of roadway and other related infrastructure improvements, though the size and capacity of such facilities could be incrementally reduced relative to the proposed project. (2) Environmental Impact Categories
(a) Aesthetics
This Alternative would result in a similar development as the proposed project, with comparable singlefamily buildings, massing, and structural heights, but with an overall reduction in development intensity and associated grading and site disturbance. Given the fact that the development footprint would be reduced relative to the proposed project, it is anticipated that the potential for view obstructions and impacts to scenic vistas and scenic resources would be incrementally reduced under this Alternative, but impacts in this regard would remain significant and unavoidable based on the extent of grading that would still be required to construct a residential subdivision and related improvements. Therefore, despite the incremental reduction in grading and development intensity, impacts would be considered significant given that the development would be visible from several public vantage points, but would be reduced compared to the proposed project. Impacts related to aesthetics and visual character would also be reduced compared to the proposed project, as this Alternative would provide the same type of land uses and other improvements such

5.0 Alternatives December 2015
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as landscaping to improve the visual character of the project site, but at a lower overall intensity. Since the development footprint under this Alternative would be smaller than under the proposed project, but would also provide features to reduce visual character effects, impacts in this regard would be considered less than under the project. Nonetheless, given the conversion of the project site from undeveloped vacant land to an urbanized residential neighborhood, impacts would remain significant and unavoidable. Impacts related to light and glare and shade/shadow would likewise be incrementally reduced compared to the proposed project based on the overall reduction in density and associated need for lighting and presence of reflective surfaces. As such, impacts in this regard would remain less than significant and would be less than under the proposed project.
(b) Air Quality
In terms of air quality, the Reduced Density Alternative would reduce the amount of urban development on the project site, and thus would also be consistent with the AQMP, but impacts would be reduced compared to the proposed project given the reduction in on-site residential units and associated air pollutant emissions. Similarly, impacts related to violation of air quality standards during both construction and operations would be less than significant since the extent of grading and construction would be substantially reduced, and long-term operations from stationary sources (i.e., new homes) and vehicular mobile sources would also be proportionately reduced compared to the project, and thus would be less than significant without the need for mitigation measures. In addition, based on the overall reduction in development intensity on-site, impacts related to cumulatively considerable pollutant increases, exposure to substantial pollutant concentrations, odors, and regulatory consistency would be less than significant and reduced relative to the proposed project.
(c) Biological Resources
The Reduced Density Alternative, overall, would reduce the development footprint of the project and thus would also reduce the extent of site disturbance and associated impacts on biological resources. Impacts related to special status species and habitats on-site would be incrementally reduced compared to the project, although mitigation measures would still be required to reduce such impacts to less than significant.

Impacts to riparian habitat, sensitive natural communities, and wetlands/jurisdictional features would be less than significant without the need for mitigation measures, but would also be reduced relative to the proposed project given the reduced grading and site disturbance under this Alternative. Impacts to wildlife corridors and migratory bird species would still require mitigation to reduce them to less than significant, but such impacts would be less than under the proposed project. Lastly, similar to the proposed project, this Alternative would result in less than significant impacts regarding conflicts with plans, policies, or ordinances protecting biological resources.
(d) Cultural Resources
This Alternative would not result in any adverse impacts to historic resources, as no such resources are located on-site, as is the case under the proposed project. While impacts related to archaeological resources, paleontological resources, and human remains would still require mitigation to ensure they are less than significant, the potential for such impacts to occur would be incrementally reduced compared to the project based on the reduction in grading and site disturbance under this Alternative. Similar to the proposed project, impacts related to regulatory consistency would be less than significant, as this Alternative would comply with all applicable policies and regulations related to cultural resources.

December 2015 5.0 Alternatives
City of Corona Skyline Heights Project
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(e) Geology and Soils
The Reduced Density Alternative would reduce the development intensity of proposed residential uses on- site, which would also result in a sizeable reduction in the extent of grading activities necessary to construct the proposed subdivision. Nonetheless, with a reduction in on-site population, and assuming implementation of geotechnical recommendations similar to those contained in the project Geotechnical Report, impacts related to earthquake fault rupture, seismic ground shaking, ground failure, and landslides would be less than significant and would be incrementally reduced compared to the proposed project since fewer people would be exposed to such geologic hazards. Soil erosion impacts would be reduced under this Alternative given the reduction in soil disturbance and potential for erosive effects, and would be less than significant without the need for mitigation. Impacts associated with seismic ground failure, including liquefaction, and expansive soils would be less than significant with implementation of applicable mitigation measures, but would be reduced compared to the proposed project based on the overall reduction in development intensity. Similar to the proposed project, impacts related to septic tanks and alternative wastewater disposal systems would be less than significant, as the project site would be served by the City’s sewer system, and thus no such systems would be required on-site. Finally, impacts related to regulatory consistency would be similar to the proposed project, as all on-site development (irrespective of density) would be required to comply with applicable seismic safety, water quality, and building code requirements, and thus impacts would be less than significant with mitigation. (f) Greenhouse Gas Emissions
The Reduced Density Alternative would require substantially less grading and construction activity than the proposed project, and would also result in a sizeable reduction in long-term air pollutant emissions from operation of the proposed residential units. Given the reduction in short-term grading and construction activities and long-term stationary and mobile-source GHG emissions under this Alternative in comparison to the proposed project, impacts would remain less than significant and would be incrementally reduced. As construction and operation of residential development under Alternative 2 would result in less than significant GHG emissions impacts and would also implement sustainability features that are supportive local and State GHG reduction goals, impacts related to consistency with GHG reduction plans would be less than significant and similar to the proposed project.
(g) Hazards and Hazardous Materials
The Reduced Density Alternative would result in the development of a single-family residential community but with fewer residential units and an overall reduction in site disturbance compared to the proposed project. Therefore, the proposed on-site development under this Alternative would have an incrementally reduced potential to result in hazards associated with hazardous materials operations and releases and hazardous materials emissions near schools, though impacts would remain less than significant. Impacts related to listed hazardous materials sites, as is the case under the proposed project, would be less than significant since no listed hazardous materials sites are located within the project boundaries or in the immediate area such that potential hazards to on-site residents could occur. No airport-related impacts would occur under this Alternative, similar to under the proposed project, based on the distance of the project site from the nearest airport (Corona Municipal Airport). Impacts regarding regulatory consistency and emergency response and evacuation plans would be less than significant under Alternative 2 based on the similarity of uses and reduction in overall development intensity on-site, and would be reduced compared to the proposed project. Given the reduction in on-site residential uses and associated reduction

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in development footprint, impacts related to wildland fire hazards would be less than under the proposed project, though mitigation would still be required to reduce impacts to less than significant. (h) Hydrology and Water Quality
This Alternative would result in the same type of single-family residential development as the proposed project, but the intensity of grading, construction, and long-term operation of proposed residential uses would be incrementally reduced. Therefore, this Alternative would have a reduced potential to result in adverse impacts related to water quality degradation and wastewater discharge requirements as the extent of soil disturbance, increase in impervious surface area, and modification of natural drainage courses would be lower than under the proposed project, and as such impacts would remain less than significant. Based on a reduced development footprint and associated reduction in impervious surfaces that could restrict groundwater recharge, as well as a reduced demand for domestic water supplies (which are based in part of groundwater supplies), indirect impacts to groundwater resources would be less than under the project, but would also be less than significant. Impacts related to hydrology and drainage would still require mitigation to reduce them to less than significant, but given the reduced development intensity and extent of site disturbance, such impacts would be less than under the proposed project. Similarly, based on the reduced development footprint under this Alternative, impacts related to flood hazards would be less than under the proposed project and less than significant since less impervious surfaces would be introduced to the project site and fewer residential uses would be exposed to potential flooding effects once constructed. Lastly, as this Alternative would be required to comply with applicable policies and regulations related to hydrology and water quality, as is the case with the proposed project, impacts related to regulatory consistency would also be less than significant.
(i) Land Use and Planning
The Reduced Density Alternative would result in a similar development pattern on the project site, but at a lower overall intensity compared to the proposed project. Since the existing site is currently undeveloped and is located just outside the City’s corporate boundary adjacent to the Cleveland National Forest, there is little potential for this Alternative, as is the case for the proposed project, to result in the division of an established community and thus impacts in this regard would be less than significant. As under the proposed project, the proposed annexation area would be annexed into the City of Corona from unincorporated Riverside County, but the allowable single-family residential density would be consistent with the existing City General Plan designation of Rural Residential I for this portion of the City’s Sphere of Influence. This Alternative, therefore, would allow for a density of up to 0.5 dwelling units per acre, or up to 136 single-family homes on the 270.9-acre project site, compared to 292 residential units under the proposed project. As discussed in Section 4.I, Land Use, of this Draft EIR, the proposed project would be consistent with the applicable goals and policies of the Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 (CKH Act), the City’s General Plan, Corona Municipal Code (CMC), and SCAG regional plans. While this Alternative would result in a residential development at a lower density, it would still require annexation into the City and Metropolitan Water District of Southern California (Metropolitan) service area, as well as General Plan map and text amendments, a Zoning map amendment, and other approvals, as is the case with the proposed project. As such, despite the reduction in on-site development intensity under this Alternative, impacts related to consistency with applicable plans and policies would be less than significant and similar to the proposed project. As also discussed in Section 4.I, although the project site is located within the Temescal Canyon Area Plan of the WRC MSHCP, the proposed project would not conflict with any applicable habitat conservation plan or natural community conservation plan given

December 2015 5.0 Alternatives
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payment of mitigation fees. As such, given the reduced intensity of residential development under Alternative 2 within the same project boundaries, impacts would also be less than significant with payment of requisite mitigation fees, but would be reduced relative to the proposed project. (j) Noise
This Alternative would result in a similar single-family residential development pattern on the project site, but at a lower overall intensity. As such, construction activities and associated impacts related to noise generation and compliance with noise standards would be incrementally reduced compared to the proposed project, but mitigation would still be required to reduce such impacts to less than significant. Operational noise impacts under the proposed project would be less than significant without the need for mitigation measure, and therefore based on the reduction in on-site development intensity, operational noise impacts of this Alternative would also be less than significant and less than under the project. Similarly, impacts related to groundborne noise and vibration would be incrementally reduced under Alternative 2, and would be less than significant. Impacts associated with aircraft, airport noise, and regulatory consistency would also be less than significant without the need for mitigation measures, and would be similar to under the proposed project.
(k) Population, Housing, and Employment
The Reduced Density Alternative would result in the construction and operation of up to 136 single-family dwelling units on the project site, which would translate to a direct population growth of 479 people on the project site (3.52 persons per household x 136 dwelling units = 478.7), compared to 1,028 people under the proposed project. Given that this Alternative would result in less than half of the direct population growth of the proposed project, impacts to population growth would be less than the proposed project and would be less than significant. Conversely, this Alternative would result in the provision of less than half of the housing units of the proposed project, and therefore although the housing growth under Alternative 2 would be well within the SCAG growth projections for the City, subregion, and entire SCAG region, it would not help the City meet its State-mandated housing goals to the extent the proposed project would. As such, housing impacts under Alternative 2 are considered to be greater than those of the proposed project, though such impacts would remain less than significant. Lastly, with regard to employment growth, neither the proposed project nor Alternative 2 provide any on-site employment opportunities, and therefore impacts under this Alternative would be comparable to the proposed project and would be less than significant. (l) Public Services
This Alternative would result in the same type of residential uses within the project site, but the intensity of development would be substantially reduced. As such, the associated demands on public services and facilities such as fire protection and emergency medical services, police protection, parks and recreational facilities, schools, and libraries would be incrementally reduced within each respective service area. Impacts under Alternative 2, therefore, would be reduced compared to the proposed project, though mitigation measures would still be required to reduce such impacts to less than significant. In addition, impacts regarding regulatory consistency would also be less than significant and would be similar to the proposed project.

5.0 Alternatives December 2015
City of Corona Skyline Heights Project
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(m) Transportation/Traffic
This Alternative would require considerably less grading and construction activities than the proposed project, and thus would generate fewer construction-related vehicle trips. Since the project would result in less than significant construction-related traffic system impacts given implementation of a project-specific Construction Management Plan, which would also be required under this Alternative, impacts would also be less than significant and less than under the proposed project. Operational traffic impacts would also be incrementally reduced given the reduced overall development intensity on-site. Specifically, impacts to intersections under Existing With Project, Year 2020, and Year 2035 conditions would be less than significant with implementation of applicable mitigation measures, if necessary given the reduced traffic volumes, and impacts overall would be less than under the proposed project. Similarly, impacts to roadway segments would be reduced compared to the proposed project given the reduction in vehicle trip generation, and impacts would be less than significant without the need for mitigation measures, though specific project design features would still be implemented, as appropriate. In addition, impacts related to hazardous design features, emergency access, and parking would be less than significant and reduced compared to the proposed project. Lastly, similar to the project, Alternative 2 would result in less than significant impacts regarding alternative transportation and regulatory consistency with implementation of applicable mitigation measures.
(n) Utilities and Service Systems
This Alternative would result in the same type of single-family residential development as the proposed project, but at a lower overall intensity. Since the proposed project was determined to result in less than significant impacts to water, wastewater, and solid waste facilities and services with implementation of applicable mitigation measures, and this Alternative would result in reduced demands within the same service area boundaries of affected utilities and service providers, impacts would also be less than significant under this Alternative, though mitigation measures would still be required. As relates to stormwater drainage facilities, impacts under the project were determined to be less than significant given compliance with applicable regulations and implementation of site-specific BMPs related to water quality. As such, given the reduced development footprint and associated impervious surface area under this Alternative, impacts would also be less than significant and reduced compared to the proposed project. Impacts regarding regulatory consistency would be comparable to those under the proposed project, and would be considered less than significant.
(o) Agriculture and Forestry Resources
Under the Reduced Density Alternative, the project site would be graded and developed with a new singlefamily residential community, but at a lower overall intensity than the proposed project. As summarized in Section 4.O, Agriculture and Forestry Resources, of this Draft EIR, the project was determined to result in less than significant impacts related to farmland and forest land conversion, and impacts regarding conflicts with zoning for agriculture or forestry uses or Williamson Act contracts. As such, based on the similarity of residential land uses and the overall reduction in development intensity, impacts under Alternative 2 would be less than significant and less than under the proposed project. (3) Impact Summary
As summarized above in Table 5-1, the Reduced Density Alternative would result in reduced impacts to aesthetics (views/scenic vistas, scenic resources, aesthetics/visual character, light and glare, and

December 2015 5.0 Alternatives
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shade/shadow), air quality (AQMP consistency, violation of air quality standards, cumulatively considerable pollutant increases, exposure to substantial pollutant concentrations, and odors), biological resources (special status species/habitats, riparian habitat/sensitive natural communities, wetlands/jurisdictional features, and wildlife corridors/migratory species), cultural resources (archaeological resources, paleontological resources, and human remains), geology and soils (earthquake fault rupture, ground shaking, ground failure, landslides, soil erosion, liquefaction, and expansive soils), greenhouse gas emissions (greenhouse gas emissions), hazards and hazardous materials (hazardous materials operations and releases, hazardous materials emissions near schools, regulatory consistency and emergency response and evacuation plans, and wildland fire hazards), hydrology and water quality (water quality degradation/wastewater discharge requirements, groundwater resources, hydrology and drainage, and flood hazards), land use and planning (conflicts with habitat conservation plans), noise (noise generation and compliance with noise standards and groundborne noise and vibration), population/housing/employment (population growth), public services (fire protection, police protection, parks and recreation, schools, and libraries), transportation (intersection impacts and roadway segment impacts), utilities and service systems (water supply and infrastructure, wastewater conveyance and treatment, stormwater drainage facilities, and solid waste disposal), and agriculture and forestry resources (farmland and forest land conversion and conflicts with zoning or Williamson Act contracts). This Alternative would result in similar impacts to the proposed project with regard to aesthetics (regulatory consistency), air quality (regulatory consistency), biological resources (conflicts with plans, policies, or ordinances protecting biological resources), cultural resources (historic resources and regulatory consistency), geology and soils (septic tanks/alternative wastewater disposal systems and regulatory consistency), greenhouse gas emissions (consistency with GHG reduction plans), hazards and hazardous materials (listed hazardous materials sites and airport-related hazards), hydrology and water quality (regulatory consistency), land use and planning (division of established communities and consistency with plans, policies, and regulations), noise (aircraft/airport noise and regulatory consistency), population/housing/employment (employment growth and regulatory consistency), public services (regulatory consistency), transportation (hazardous design features, emergency access, parking, and alternative transportation/regulatory consistency), and utilities and service systems (regulatory consistency). This Alternative would result in greater impacts associated with population/housing/employment (housing growth), as it would provide fewer housing units on the project site. Although this Alternative would, overall, result in a reduction in the severity of impacts for nearly all environmental issues, it would not eliminate the proposed project’s significant unavoidable impacts to views/scenic vistas, scenic resources, and aesthetics/visual character. (4) Relationship of the Alternative to Project Objectives The Reduced Density Alternative would develop a single-family residential community on the project site, but at a substantially reduced intensity, which would provide less than half of the residential units than the proposed project on the property. Therefore, the Reduced Density Alternative would fully meet the following project objectives: (Objective 1) provide high quality residential development consistent with adjacent neighborhoods; (Objective 2) build residential housing which is in compliance with proposed zoning and Corona General Plan land use designations consistent with surrounding area; (Objective 3) facilitate the annexation of the project development and adjacent lands into the City of Corona; (Objective 4) provide efficient and safe movement of vehicles and pedestrians with minimum intrusion on adjacent residential neighborhoods; (Objective 5) dedicate land and contribute fees for the construction of Foothill Parkway; (Objective 6) ensure that all community facilities and services including circulation improvements, drainage facilities, water, reclaimed water and sewer facilities are available to serve the project and meet or exceed applicable City standards and requirements prior to, or concurrent with development; (Objective 9)

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provide a system of open space which combines natural and man-made areas to maintain a scenic and fire safe living environment for residents; and (Objective 10) implement a comprehensive landscape program which provides visual continuity throughout the project area and the natural areas of the Cleveland National Forest. Given the reduction in residential development and associated infrastructure improvements, Alternative 2 would only partially achieve the following project objectives: (Objective 7) provide strategic improvements within the project to assist the City with Master Plan improvements to existing water and sewer system; (Objective 8) provide water reservoirs and infrastructure to improve service and reliability for other parts of the City; and (Objective 11) help meet the high market demand for high quality housing in western Riverside County and to meet the City’s housing needs to support forecasted population growth as discussed in the City’s General Plan (2004).
c. Alternative 3 – Phase III Only Alternative
(1) Description of Alternative
The Phase III Only Alternative is being proposed in order to address the significant unavoidable impacts to views/scenic vistas, scenic resources, and aesthetics/visual character that would occur under the proposed project. The Phase III Only Alternative involves the development of single-family residential uses with a 7,200-square-foot minimum lot size, as under the proposed project, but only within the portion of the project site located north of Mabey Canyon. This development pattern is identical to Phase III improvements under the proposed project, and would only require infrastructure improvements to serve that portion of the project site, with the remaining property south of Mabey Canyon being left in its current undeveloped condition. Therefore, Alternative 3 would result in the development of up to 45 single-family residential units and associated infrastructure including streets, water and sewer facilities, storm drains and water quality BMPs, landscaping, lighting, and other improvements. It should be noted that given the existing topography within the Phase III portion of the project site, extensive soil excavation and removal would be required to prepare the site for urban development, which would substantially increase the number and frequency of haul truck trips to and from the site. By comparison, under the proposed project the cut soil material from the Phase III area would be utilized as fill material elsewhere within the project site, as no off- site soil import or export would be required. Under this Alternative, it is assumed that the entire proposed annexation area is annexed into the City of Corona, but only the Phase III potion of the 270.9-acre project site would be developed with urban uses.
(2) Environmental Impact Categories
(a) Aesthetics
This Alternative would result in a similar development as the proposed project, with comparable singlefamily buildings, massing, and structural heights, but with a substantial reduction in development intensity and associated grading and site disturbance with development only occurring at the lower project site elevations north of Mabey Canyon. Given the location of the Phase III portion of the project site relative to public viewpoints (including scenic roadways), the lower elevation and presence of intervening topography, vegetation, and urban development, it is anticipated that the potential for view obstructions and impacts to scenic vistas and scenic resources would be substantially reduced under this Alternative, and impacts in this regard would be less than significant, thereby avoiding a significant impact under the proposed project.

Impacts related to aesthetics and visual character would also be reduced compared to the proposed project, as this Alternative would provide the same type of land uses and other improvements such as landscaping to improve the visual character of the project site, but at a much lower overall intensity. Since the development

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footprint under this Alternative would be much smaller than under the proposed project and development would be limited to the area north of Mabey Canyon, and the development would also provide features to reduce visual character effects, impacts in this regard would be considered less than under the project. As such, despite the conversion of this portion of the project site from undeveloped vacant land to an urbanized residential neighborhood, impacts would be considered less than significant since the extent of landform alteration and visibility of the site from the surrounding area would be considerably reduced. Impacts related to light and glare and shade/shadow would likewise be substantially reduced compared to the proposed project based on the overall reduction in density and associated need for lighting and presence of reflective surfaces. As such, impacts in this regard would remain less than significant and would be less than under the proposed project.
(b) Air Quality
In terms of air quality, the Phase III Only Alternative would greatly reduce the amount of urban development on the project site, and thus would also be consistent with the AQMP, but impacts would be reduced compared to the proposed project given the reduction in on-site residential units and associated air pollutant emissions. Similarly, impacts related to violation of air quality standards during both construction and operations would be less than significant since the extent of grading and construction would be substantially reduced, and long-term operations from stationary sources (i.e., new homes) and vehicular mobile sources (i.e., worker vehicles and material and equipment deliveries) would also be proportionately reduced compared to the project, and thus would be less than significant without the need for mitigation measures. However, off-site construction-related truck trips for soil export would be substantially increased relative to the proposed project, since this Alternative would require off-site export and disposal of cut soils necessary to prepare the site for development of residential uses. No off-site soil transport is required for the proposed project, as all earthwork would be balanced on-site, and therefore the additional truck haul trips associated with this Alternative would represent an additional mobile emissions source during construction activities. However, based on the overall reduction in development intensity on-site, impacts related to cumulatively considerable pollutant increases, exposure to substantial pollutant concentrations, odors, and regulatory consistency would be less than significant and reduced relative to the proposed project.
(c) Biological Resources
The Phase III Only Alternative, overall, would greatly reduce the development footprint of the project and thus would also reduce the extent of site disturbance and associated impacts on biological resources.

Impacts related to special status species and habitats on-site would be substantially reduced compared to the project, as the entire portion of the project site south of Mabey Canyon would be left in its current state, although mitigation measures would still be required to reduce impacts to resources north of Mabey Canyon to less than significant. Impacts to riparian habitat, sensitive natural communities, and wetlands/ jurisdictional features would also be less than significant without the need for mitigation measures, but would also be substantially reduced relative to the proposed project given the reduced grading and site disturbance under this Alternative. Impacts to wildlife corridors and migratory bird species would still require mitigation to reduce them to less than significant, but such impacts would be much less than under the proposed project. Lastly, similar to the proposed project, this Alternative would result in less than significant impacts regarding conflicts with plans, policies, or ordinances protecting biological resources.

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(d) Cultural Resources
This Alternative would not result in any adverse impacts to historic resources, as no such resources are located on-site, as is the case under the proposed project. While impacts related to archaeological resources, paleontological resources, and human remains would still require mitigation to ensure they are less than significant, the potential for such impacts to occur would be substantially reduced compared to the project based on the reduction in grading and site disturbance under this Alternative. Similar to the proposed project, impacts related to regulatory consistency would be less than significant, as this Alternative would comply with all applicable policies and regulations related to cultural resources. (e) Geology and Soils
The Phase III Only Alternative would reduce the development intensity of proposed residential uses on-site, which would also result in a sizeable reduction in the extent of grading activities necessary to construct the proposed subdivision. Nonetheless, with a reduction in on-site population, and assuming implementation of geotechnical recommendations similar to those contained in the project Geotechnical Report, impacts related to earthquake fault rupture, seismic ground shaking, ground failure, and landslides would be less than significant and would be incrementally reduced compared to the proposed project since fewer people would be exposed to such geologic hazards. Soil erosion impacts would be reduced under this Alternative given the reduction in soil disturbance and potential for erosive effects, and would be less than significant without the need for mitigation. Impacts associated with seismic ground failure, including liquefaction, and expansive soils would be less than significant with implementation of applicable mitigation measures, but would be reduced compared to the proposed project based on the overall reduction in development intensity. Similar to the proposed project, impacts related to septic tanks and alternative wastewater disposal systems would be less than significant, as the project site would be served by the City’s sewer system, and thus no such systems would be required on-site. Finally, impacts related to regulatory consistency would be similar to the proposed project, as all on-site development would be required to comply with applicable seismic safety, water quality, and building code requirements, and thus impacts would be less than significant with mitigation.
(f) Greenhouse Gas Emissions
The Phase III Only Alternative would require substantially less grading and construction activity than the proposed project, and would also result in a sizeable reduction in long-term air pollutant emissions from operation of the proposed residential units. Given the reduction in short-term grading and construction activities and long-term stationary and mobile-source GHG emissions under this Alternative in comparison to the proposed project, impacts would remain less than significant and would be substantially reduced. As construction and operation of residential development under Alternative 3 would result in less than significant GHG emissions impacts and would also implement sustainability features that are supportive local and State GHG reduction goals, impacts related to consistency with GHG reduction plans would be less than significant and similar to the proposed project.
(g) Hazards and Hazardous Materials
The Phase III Only Alternative would result in the development of a single-family residential community but with much fewer residential units and a considerable overall reduction in site disturbance compared to the proposed project, with only the portion of the project site north of Mabey Canyon subject to urban development. Therefore, the proposed on-site development under this Alternative would have a

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substantially reduced potential to result in hazards associated with hazardous materials operations and releases and hazardous materials emissions near schools, and impacts would remain less than significant.

Impacts related to listed hazardous materials sites, as is the case under the proposed project, would be less than significant since no listed hazardous materials sites are located within the project boundaries or in the immediate area such that potential hazards to on-site residents could occur. No airport-related impacts would occur under this Alternative, similar to under the proposed project, based on the distance of the project site from the nearest airport (Corona Municipal Airport). Impacts regarding regulatory consistency and emergency response and evacuation plans would be less than significant under Alternative 3 based on the similarity of uses and sizeable reduction in overall development intensity on-site, and would be substantially reduced compared to the proposed project. Given the reduction in on-site residential uses and associated reduction in development footprint, impacts related to wildland fire hazards would be less than under the proposed project, though mitigation would still be required to reduce impacts to less than significant.
(h) Hydrology and Water Quality
This Alternative would result in the same type of single-family residential development as the proposed project, but the intensity of grading, construction, and long-term operation of proposed residential uses would be substantially reduced. Therefore, this Alternative would have a reduced potential to result in adverse impacts related to water quality degradation and wastewater discharge requirements as the extent of soil disturbance, increase in impervious surface area, and modification of natural drainage courses would be much lower than under the proposed project, and as such impacts would remain less than significant.

Based on a reduced development footprint and associated reduction in impervious surfaces that could restrict groundwater recharge, as well as a reduced demand for domestic water supplies (which are based in part of groundwater supplies), indirect impacts to groundwater resources would be less than under the project, but would also be less than significant. Impacts related to hydrology and drainage would still require mitigation to reduce them to less than significant, but given the substantially reduced development intensity and extent of site disturbance, such impacts would be less than under the proposed project.

Similarly, based on the reduced development footprint under this Alternative, impacts related to flood hazards would be less than under the proposed project and less than significant since less impervious surfaces would be introduced to the project site and fewer residential uses would be exposed to potential flooding effects once constructed. Lastly, as this Alternative would be required to comply with applicable policies and regulations related to hydrology and water quality, as is the case with the proposed project, impacts related to regulatory consistency would also be less than significant. (i) Land Use and Planning
The Phase III Only Alternative would result in a similar development pattern on the project site, but at a lower overall intensity compared to the proposed project. Since the existing site is currently undeveloped and is located just outside the City’s corporate boundary adjacent to the Cleveland National Forest, there is little potential for this Alternative, as is the case for the proposed project, to result in the division of an established community and thus impacts in this regard would be less than significant. As under the proposed project, the proposed annexation area would be annexed into the City of Corona from unincorporated Riverside County, and the entire 270.9-acre project site would be designated for Low Density Residential uses and zoned R1-7.2 per the City’s Zoning Code, though only the Phase III portion of the site would be developed with urban uses. This Alternative, therefore, would allow for a density of up to 6 dwelling units per acre, but would only provide 45 single-family homes on the approximately 39-acre Phase

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III portion of the project site, compared to 292 residential units under the proposed project. As discussed in Section 4.I, Land Use, of this Draft EIR, the proposed project would be consistent with the applicable goals and policies of the Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 (CKH Act), the City’s General Plan, Corona Municipal Code (CMC), and SCAG regional plans. While this Alternative would result in a residential development at a much lower intensity, it would still require annexation into the City and Metropolitan Water District of Southern California (Metropolitan) service area, as well as General Plan map and text amendments, a Zoning map amendment, and other approvals, as is the case with the proposed project. As such, despite the reduction in on-site development intensity under this Alternative, impacts related to consistency with applicable plans and policies would be less than significant and similar to the proposed project. As also discussed in Section 4.I, although the project site is located within the Temescal Canyon Area Plan of the WRC MSHCP, the proposed project would not conflict with any applicable habitat conservation plan or natural community conservation plan given payment of mitigation fees. As such, given the reduced intensity of residential development under Alternative 3 within the same project boundaries, impacts would also be less than significant with payment of requisite mitigation fees, but would be reduced relative to the proposed project.
(j) Noise
This Alternative would result in a similar single-family residential development pattern on the project site, but at a much lower overall intensity. As such, construction activities and associated impacts related to noise generation and compliance with noise standards would be substantially reduced compared to the proposed project, but mitigation would still be required to reduce such impacts to less than significant. Operational noise impacts under the proposed project would be less than significant without the need for mitigation measure, and therefore based on the reduction in on-site development intensity, operational noise impacts of this Alternative would also be less than significant and less than under the project. Similarly, impacts related to groundborne noise and vibration would be incrementally reduced under Alternative 3, and would be less than significant. Impacts associated with aircraft, airport noise, and regulatory consistency would also be less than significant without the need for mitigation measures, and would be similar to under the proposed project.
(k) Population, Housing, and Employment
The Phase III Only Alternative would result in the construction and operation of up to 45 single-family dwelling units on the portion of the project site located north of Mabey Canyon, which would translate to a direct population growth of 158 people on the project site (3.52 persons per household x 45 dwelling units = 158.4), compared to 1,028 people under the proposed project. Given that this Alternative would result in approximately 15 percent of the direct population growth of the proposed project, impacts to population growth would be much less than the proposed project and would be less than significant. Conversely, this Alternative would result in the provision of less than one-fifth of the housing units of the proposed project, and therefore although the housing growth under Alternative 3 would be well within the SCAG growth projections for the City, subregion, and entire SCAG region, it would not help the City meet its State- mandated housing goals to the extent the proposed project would. As such, housing impacts under Alternative 3 are considered to be greater than those of the proposed project, though such impacts would remain less than significant. Lastly, with regard to employment growth, neither the proposed project nor Alternative 3 provide any on-site employment opportunities, and therefore impacts under this Alternative would be comparable to the proposed project and would be less than significant.

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(l) Public Services
This Alternative would result in the same type of residential uses within the project site, but the intensity of development would be substantially reduced and limited to the portion of the project site located north of Mabey Canyon. As such, the associated demands on public services and facilities such as fire protection and emergency medical services, police protection, parks and recreational facilities, schools, and libraries would be substantially reduced within each respective service area. Impacts under Alternative 3, therefore, would be greatly reduced compared to the proposed project, though mitigation measures would still be required to reduce such impacts to less than significant. In addition, impacts regarding regulatory consistency would also be less than significant and would be similar to the proposed project. (m) Transportation/Traffic
Overall, this Alternative would require considerably less grading and construction activities than the proposed project, and thus would generate fewer construction-related vehicle trips. Since the project would result in less than significant construction-related traffic system impacts given implementation of a project- specific Construction Management Plan, which would also be required under this Alternative, impacts would also be less than significant and less than under the proposed project. It should be noted, however, that implementation of this Alternative would require off-site transport and disposal of excavated/cut soil materials from the site, as it would not be possible to balance all earthwork on-site as would occur under the proposed project. The addition of off-site soil haul truck trips would be expected to substantially increase the number and frequency of construction-related truck traffic on a given construction day relative to the proposed project, though the overall duration and intensity of construction activities would be reduced under this Alternative. Operational traffic impacts would also be substantially reduced given the reduced overall development intensity on-site (approximately 15 percent of the residential units as under the proposed project). Specifically, impacts to intersections under Existing With Project, Year 2020, and Year 2035 conditions would be less than significant with implementation of applicable mitigation measures, if necessary given the reduced traffic volumes, and impacts overall would be much less than under the proposed project. Similarly, impacts to roadway segments would be considerably reduced compared to the proposed project given the reduction in vehicle trip generation, and impacts would be less than significant without the need for mitigation measures, though specific project design features would still be implemented, as appropriate. In addition, impacts related to hazardous design features, emergency access, and parking would be less than significant and reduced compared to the proposed project. Lastly, similar to the project, Alternative 3 would result in less than significant impacts regarding alternative transportation and regulatory consistency with implementation of applicable mitigation measures (if necessary). (n) Utilities and Service Systems This Alternative would result in the same type of single-family residential development as the proposed project, but at a lower overall intensity. Since the proposed project was determined to result in less than significant impacts to water, wastewater, and solid waste facilities and services with implementation of applicable mitigation measures, and this Alternative would result in considerably reduced demands within the same service area boundaries of affected utilities and service providers, impacts would also be less than significant under this Alternative, though mitigation measures would still be required. As relates to stormwater drainage facilities, impacts under the project were determined to be less than significant given compliance with applicable regulations and implementation of site-specific BMPs related to water quality.

As such, given the reduced development footprint and associated impervious surface area under this Alternative, impacts would also be less than significant and reduced compared to the proposed project.

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Impacts regarding regulatory consistency would be comparable to those under the proposed project, and would be considered less than significant.
(o) Agriculture and Forestry Resources
Under the Phase III Only Alternative, only the portion of the project site located north of Mabey Canyon would be graded and developed with a new single-family residential community at the same density proposed under the project for this part of the site. As summarized in Section 4.O, Agriculture and Forestry Resources, of this Draft EIR, the project was determined to result in less than significant impacts related to farmland and forest land conversion, and impacts regarding conflicts with zoning for agriculture or forestry uses or Williamson Act contracts. As such, based on the similarity of residential land uses and the overall reduction in development intensity, impacts under Alternative 3 would be less than significant and less than under the proposed project.
(3) Impact Summary
As summarized above in Table 5-1, the Phase III Only Alternative would result in reduced impacts to aesthetics (views/scenic vistas, scenic resources, aesthetics/visual character, light and glare, and shade/shadow), air quality (AQMP consistency, violation of air quality standards, cumulatively considerable pollutant increases, exposure to substantial pollutant concentrations, and odors), biological resources (special status species/habitats, riparian habitat/sensitive natural communities, wetlands/jurisdictional features, and wildlife corridors/migratory species), cultural resources (archaeological resources, paleontological resources, and human remains), geology and soils (earthquake fault rupture, ground shaking, ground failure, landslides, soil erosion, liquefaction, and expansive soils), greenhouse gas emissions (greenhouse gas emissions), hazards and hazardous materials (hazardous materials operations and releases, hazardous materials emissions near schools, regulatory consistency and emergency response and evacuation plans, and wildland fire hazards), hydrology and water quality (water quality degradation/wastewater discharge requirements, groundwater resources, hydrology and drainage, and flood hazards), land use and planning (conflicts with habitat conservation plans), noise (noise generation and compliance with noise standards and groundborne noise and vibration), population/housing/employment (population growth), public services (fire protection, police protection, parks and recreation, schools, and libraries), transportation (intersection impacts and roadway segment impacts), utilities and service systems (water supply and infrastructure, wastewater conveyance and treatment, stormwater drainage facilities, and solid waste disposal), and agriculture and forestry resources (farmland and forest land conversion and conflicts with zoning or Williamson Act contracts). This Alternative would result in similar impacts to the proposed project with regard to aesthetics (regulatory consistency), air quality (regulatory consistency), biological resources (conflicts with plans, policies, or ordinances protecting biological resources), cultural resources (historic resources and regulatory consistency), geology and soils (septic tanks/alternative wastewater disposal systems and regulatory consistency), greenhouse gas emissions (consistency with GHG reduction plans), hazards and hazardous materials (listed hazardous materials sites and airport-related hazards), hydrology and water quality (regulatory consistency), land use and planning (division of established communities and consistency with plans, policies, and regulations), noise (aircraft/airport noise and regulatory consistency), population/housing/employment (employment growth and regulatory consistency), public services (regulatory consistency), transportation (hazardous design features, emergency access, parking, and alternative transportation/regulatory consistency), and utilities and service systems (regulatory consistency). This Alternative would result in greater impacts associated with population/housing/employment (housing growth), as it would provide fewer housing units on the project

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site. Overall, this Alternative would result in a substantial reduction in the severity of impacts for nearly all environmental issues, and more importantly, would also avoid the proposed project’s significant unavoidable impacts to views/scenic vistas, scenic resources, and aesthetics/visual character. (4) Relationship of the Alternative to Project Objectives The Phase III Only Alternative would develop a single-family residential community on the portion of the project site located north of Mabey Canyon, but at a substantially reduced intensity, which would provide just over 15 percent of the residential units as the proposed project. Therefore, the Phase III Only Alternative would fully meet the following project objectives: (Objective 1) provide high quality residential development consistent with adjacent neighborhoods; (Objective 2) build residential housing which is in compliance with proposed zoning and Corona General Plan land use designations consistent with surrounding area; (Objective 3) facilitate the annexation of the project development and adjacent lands into the City of Corona; (Objective 4) provide efficient and safe movement of vehicles and pedestrians with minimum intrusion on adjacent residential neighborhoods; (Objective 6) ensure that all community facilities and services including circulation improvements, drainage facilities, water, reclaimed water and sewer facilities are available to serve the project and meet or exceed applicable City standards and requirements prior to, or concurrent with development; and (Objective 10) implement a comprehensive landscape program which provides visual continuity throughout the project area and the natural areas of the Cleveland National Forest. Given the reduction in residential development and associated infrastructure improvements, and limited area for usable open space north of Mabey Canyon, Alternative 3 would only partially achieve the following project objectives: (Objective 5) dedicate land and contribute fees for the construction of Foothill Parkway; (Objective 7) provide strategic improvements within the project to assist the City with Master Plan improvements to existing water and sewer system; (Objective 8) provide water reservoirs and infrastructure to improve service and reliability for other parts of the City; (Objective 9) provide a system of open space which combines natural and man-made areas to maintain a scenic and fire safe living environment for residents; and (Objective 11) help meet the high market demand for high quality housing in western Riverside County and to meet the City’s housing needs to support forecasted population growth as discussed in the City’s General Plan (2004).
d. Environmentally Superior Alternative
As identified above in Table 5-1, Alternatives 1, 2, and 3 all reduce the severity of the majority of projectrelated impacts. However, only Alternatives 1 and 3 would fully eliminate the significant unavoidable aesthetics impacts of the proposed project, including impacts to views/scenic vistas, scenic resources, and aesthetics/visual character. Furthermore, Alternative 1 would reduce or eliminate impacts associated with all but three remaining environmental topics (historic resources, housing growth and employment growth), as no development would occur under this Alternative.

CEQA requires that the Environmentally Superior Alternative be identified in the EIR. Based on the analysis in this chapter and the summary contained in Table 5-1, the No Project Alternative is determined to be the Environmentally Superior Alternative. Although Alternative 1 is considered the Environmental Superior Alternative, this Alternative would not satisfy any of the identified project objectives, as shown below in Table 5-2, as it would not provide any new housing opportunities or related infrastructure improvements or achieve any of the other project objectives.

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However, Alternative 3, the Phase III Only Alternative, would at least partially achieve all of the 11 stated project objectives, as shown below in Table 5-2, but would only fully achieve six of them. Although this Alternative would not provide nearly as much housing, infrastructure, open space, and other improvements on-site as under the proposed project, it would still provide additional single-family housing stock within the City which would be contiguous with existing single-family residential development and future development along the Foothill Parkway Westerly Extension. Therefore, Alternative 3 has been determined to be the Environmentally Superior Alternative. However, Alternative 3 would not dedicate as much land or contribute as many fees for the construction of Foothill Parkway based on the substantial reduction in development intensity and lack of physical development south of Mabey Canyon along the proposed Foothill Parkway Extension corridor. Alternative 3 would also not provide as many strategic improvements within the project to assist the City with Master Plan improvements to existing water and sewer system, provide as many water reservoirs and infrastructure to improve service and reliability for other parts of the City, or provide a system of open space which combines natural and man-made areas to maintain a scenic and fire safe living environment for residents within areas south of Mabey Canyon. Lastly, the Phase III Only Alternative would not help meet the high market demand for high quality housing in western Riverside County or meet the City’s housing needs to support forecasted population growth as discussed in the City’s General Plan to the extent the proposed project would, as it would only provide approximately 15 percent of the residential units on the project site.

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Alternatives’ Ability to Meet Project Objectives
Project Objective
Alternative 1
No Project Alternative
Alternative 2
Reduced Density Alternative
Alternative 3
Phase III Only Alternative
Objective 1: Provide high quality residential development consistent with adjacent neighborhoods. Does Not Meet Objective Fully Meets Objective Fully Meets Objective Objective 2: Build residential housing which is in compliance with proposed zoning and Corona General Plan land use
designations consistent with surrounding area.

Does Not Meet Objective Fully Meets Objective Fully Meets Objective Objective 3: Facilitate the annexation of the project
development and adjacent lands into the City of Corona. Does Not Meet Objective Fully Meets Objective Fully Meets Objective Objective 4: Provide efficient and safe movement of vehicles and pedestrians with minimum intrusion on adjacent residential neighborhoods.

Does Not Meet Objective Fully Meets Objective Fully Meets Objective Objective 5: Dedicate land and contribute fees for the
construction of Foothill Parkway. Does Not Meet Objective Fully Meets Objective Partially Meets Objective Objective 6: Ensure that all community facilities and services including circulation improvements, drainage facilities, water, reclaimed water and sewer facilities are available to serve the project and meet or exceed applicable City standards and requirements prior to, or concurrent with development.

Does Not Meet Objective Fully Meets Objective Fully Meets Objective Objective 7: Provide strategic improvements within the project to assist the City with Master Plan improvements to existing water and sewer system.

Does Not Meet Objective Partially Meets Objective Partially Meets Objective Objective 8: Provide water reservoirs and infrastructure to improve service and reliability for other parts of the City. Does Not Meet Objective Partially Meets Objective Partially Meets Objective Objective 9: Provide a system of open space which combines natural and man-made areas to maintain a scenic and fire safe living environment for residents.

Does Not Meet Objective Fully Meets Objective Partially Meets Objective

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Alternatives’ Ability to Meet Project Goals and Objectives City of Corona Skyline Heights Project PCR Services Corporation/SCH No. 2014021003 5-34 Project Objective
Alternative 1
No Project Alternative
Alternative 2
Reduced Density Alternative
Alternative 3
Phase III Only Alternative
Objective 10: Implement a comprehensive landscape program which provides visual continuity throughout the project area and the natural areas of the Cleveland National Forest.

Does Not Meet Objective Fully Meets Objective Fully Meets Objective Objective 11: Help meet the high market demand for high quality housing in western Riverside County and to meet the City’s housing needs to support forecasted population growth as discussed in the City’s General Plan (2004).

Does Not Meet Objective Partially Meets Objective Partially Meets Objective Source: PCR Services Corporation, 2015

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6. OTHER MANDATORY CEQA CONSIDERATIONS

INTRODUCTION
This section summarizes the findings with respect to significant, unavoidable environmental impacts; irreversible environmental changes; growth inducing impacts; potential secondary effects; and less than significant impacts of the proposed project. 1. SIGNIFICANT UNAVOIDABLE IMPACTS Section 15126.2(b) of the CEQA Guidelines requires that an EIR describe significant environmental impacts that cannot be avoided, including those effects that can be mitigated but not reduced to a less than significant level. Following is a summary of the impacts associated with the proposed project that were concluded to be significant and unavoidable. These impacts are also described in detail in Chapter 4, Environmental Impact Analysis, of this Draft EIR.

Aesthetics: Given the substantial landform alteration of the project site required to implement the proposed project, impacts related to views/scenic vistas, visual resources, and visual character would be significant and unavoidable, as no mitigation measures are available to reduce the significance of these impacts.

2. REASONS WHY THE PROJECT IS BEING PROPOSED, NOTWITHSTANDING

SIGNIFICANT UNAVOIDABLE IMPACTS
In addition to identification of the project’s significant unavoidable impacts, Section 15126.2(b) of the CEQA Guidelines also requires a description of the reasons why the project is being proposed, notwithstanding significant unavoidable impacts associated with the project. As described further below, the proposed project is being proposed, notwithstanding its significant unavoidable impacts, because: 1) the proposed project would achieve a considerable number of City-related project objectives; and 2) the significant unavoidable impacts are based on landform alteration and in two cases, typical of those that would occur with any construction at the project site.

The reasons why this particular project has been proposed are identified in the Project Objectives subsection in Chapter 2, Project Description, of this Draft EIR. The underlying purpose of the proposed project is to provide high quality residential development consistent with adjacent neighborhoods. However, the proposed project’s individual objectives include the following:

Objective 1: Provide high quality residential development consistent with adjacent neighborhoods.

Objective 2: Build residential housing which is in compliance with proposed zoning and Corona General Plan land use designations consistent with surrounding area.

Objective 3: Facilitate the annexation of the project development and adjacent lands into the City of Corona.

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Objective 4: Provide efficient and safe movement of vehicles and pedestrians with minimum intrusion on adjacent residential neighborhoods.

Objective 5: Dedicate land and contribute fees for the construction of Foothill Parkway.

Objective 6: Ensure that all community facilities and services including circulation improvements, drainage facilities, water, reclaimed water and sewer facilities are available to serve the project and meet or exceed applicable City standards and requirements prior to, or concurrent with development.

Objective 7: Provide strategic improvements within the project to assist the City with Master Plan improvements to existing water and sewer system.

Objective 8: Provide water reservoirs and infrastructure to improve service and reliability for other parts of the City.

Objective 9: Provide a system of open space which combines natural and man-made areas to maintain a scenic and fire safe living environment for residents.

Objective 10: Implement a comprehensive landscape program which provides visual continuity throughout the project area and the natural areas of the Cleveland National Forest.

Objective 11: Help meet the high market demand for high quality housing in western Riverside County and to meet the City’s housing needs to support forecasted population growth as discussed in the City’s General Plan (2004).

Two of the proposed project’s significant unavoidable impacts are limited to nature and are typical of impacts occurring during construction activities at development projects. Construction of the proposed project would result in a significant impact to views/scenic vistas, as well as aesthetics/visual character since it would: (1) alter the existing natural viewshed, including changes in natural terrain; (2) alter the existing visual quality of the region or eliminate visual resources (e.g., natural topography and vegetation on the project site); (3) obstruct or permanently reduce visually important features (e.g., on-site natural terrain; and (4) result in long-term adverse visual changes or contrasts to the existing landscape as viewed from areas with high visual sensitivity (e.g., designated scenic roadways such as Chase Avenue and publicly accessible trails such as the Skyline Drive Trail). Overall, the proposed development would replace the views of the existing undeveloped foothills with views of a residential subdivision and associated graded slopes, structures, and landscaping. While the project would grade the slopes so as to appear natural and the project would include extensive landscaping, the change in the natural environmental would be considered a significant change to the existing views/scenic vistas, visual character and quality of the site and its surroundings.

Alternatives to the proposed project were considered in Chapter 5, Alternatives, of this Draft EIR. Among those alternatives, only one feasible alternative other than the No Project Alternative (Alternative 3, the Phase III Only Alternative) is identified that would reduce the significant unavoidable effects of the proposed project. However, none of the Alternatives would achieve the objectives to the extent the proposed project would. Given the substantial landform alteration of the project site required to implement the proposed project, impacts related to views/scenic vistas, visual resources, and visual character would be significant

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and unavoidable. Finally, since the No Project Alternative would not meet the underlying purpose of the project, it is not considered a feasible project Alternative. 3. SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES According to Sections 15126(c) and 15126.2(c) of the CEQA Guidelines, an EIR is required to address any significant irreversible environmental changes that would occur should the proposed project be implemented. As stated in CEQA Guidelines Section 15126.2(c):
“[u]ses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter likely. Primary impacts and, particularly, secondary impacts (such as highway improvement which provides access to a previously inaccessible area) generally commit future generations to similar uses. Also, irreversible damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.”
The future implementation of the proposed project would necessarily consume limited, slowly renewable, and non-renewable resources. This consumption would occur during the construction of future project phases and would continue throughout the operational lifetime of the proposed project. Project development would require a commitment of resources that would include: (1) building materials, (2) fuel and operational materials/resources, and (3) the transportation of goods and people to and from the project site. Future construction would also require the consumption of resources that are non-replenishable or may renew so slowly as to be considered non-renewable. These resources would include the following construction supplies: certain types of lumber and other forest products; aggregate materials used in concrete and asphalt such as sand, gravel and stone; metals such as steel, copper, and lead; petrochemical construction materials such as plastics; and water. Furthermore, nonrenewable fossil fuels such as gasoline and oil would also be consumed in the use of construction vehicles and equipment, as well as the transportation of goods and people to and from the project site.

Project operation would continue to expend nonrenewable resources that are currently consumed within the City of Corona. These include energy resources such as electricity and natural gas, petroleum-based fuels required for vehicle-trips, fossil fuels, and water. Fossil fuels would represent the primary energy source associated with both construction and ongoing operation of the project, and the existing, finite supplies of these natural resources would be incrementally reduced. Project operation would occur in accordance with Title 24, Part 6 of the California Code of Regulations, as wells as numerous local regulations and proposed project design features which establish conservation practices that would limit the amount of energy consumed by the project. However, the energy requirements associated with the project would still represent a long-term commitment of essentially nonrenewable resources.

Limited use of potentially hazardous materials typical of residential uses, including household and vehicle maintenance materials (i.e., cleaning supplies, paints, fertilizers, oil, and grease) would be used and stored within the project area. The use of these materials would be in small quantities and used, handled, stored, and disposed of in accordance with the manufacturer’s instructions and applicable government regulations and standards.

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In summary, project construction and operation would result in the irretrievable commitment of limited, slowly renewable, and nonrenewable resources, which would incrementally limit the availability of these particular resource quantities for future generations or for other uses during the life of the proposed project.

However, continued use of such resources would be on a very small scale and consistent with regional and local growth forecasts in the area, as well as state and local goals for reductions in the consumption of such resources. Further, the project would not affect access to existing resources, nor interfere with the production or delivery of such resources. As such, although irreversible environmental changes would result from the Project, such changes would not be considered significant.

4. GROWTH-INDUCING IMPACTS
Section 15126.2(d) of the CEQA Guidelines requires an EIR to discuss the ways the proposed project could foster economic or population growth or the construction of additional housing, directly or indirectly, in the surrounding environment. Growth-inducing impacts include the removal of obstacles to population growth (e.g., the expansion of a wastewater treatment plant allowing more development in a service area) and the development and construction of new service facilities that could significantly affect the environment individually or cumulatively. In addition, growth must not be assumed as beneficial, detrimental, or of little significance to the environment.

The proposed project includes the development of 292 single-family residences on an approximately 270.9- acre site within an undeveloped hillside area to the south/southwest of the Foothill Parkway Westerly Extension. The project site is currently located within the City of Corona sphere of influence in unincorporated Riverside County. In order to facilitate the residential development and the completion of the Foothill Parkway Westerly Extension, the Applicant proposes the annexation of the project site and surrounding parcels totaling approximately 394.8 acres to the City of Corona. Of the approximately 270.9- acre project site, approximately 21.38 acres would be used as right-of-way for the construction of the Foothill Parkway Westerly Extension. The City of Corona is currently implementing a Capital Improvement Project for the Foothill Parkway Westerly Extension between Green River Road and Trudy Way. This roadway would provide primary access to the project site at “P” Street, “B” Street (aligned with Border Avenue) and Trudy Way. As indicated in Section 4.K, Population, Housing, and Employment, of this Draft EIR, the proposed project includes the construction of 292 single-family homes that would generate a population of approximately 1,028 residents. The increase of 1,028 residents to the City would represent a total of 6.193 percent, 0.086 percent, and 0.024 percent of the population growth projected by SCAG for the local, subregional, and regional areas, respectively, between the years of 2008 and 2035. These percent increases do not exceed the forecasted growth set forth by SCAG. In addition, the project population growth would not substantially alter the location or growth rate of the population projected and forecasted for the City, the Western Riverside subregion, and SCAG region. By adding new housing units to the general housing supply, the Project would support applicable housing policies of the City’s General Plan, SCAG’s RTP/SCS, and housing allocation goals of the RHNA, and would substantially help meet the housing demands of the growing population of the City by contributing to housing availability and opportunity in the project area. The proposed project would represent 6.952 percent, 0.071 percent, and 0.019 percent of household growth projected by SCAG for the local, subregional, and regional areas between the years of 2008 and 2035, respectively. The demand of additional housing units is well within the SCAG housing growth projections for the City, the Western Riverside subregion, and the SCAG region. By creating new housing units within the

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project area, the proposed project would support applicable housing policies of SCAG’s RTP/SCS and housing allocation goals of the RHNA, and would substantially help meet the housing demands of the growing population of the City. Project implementation would not directly generate new job opportunities to the City. The local area, subregional area, and regional area would be considered “job rich” with a housing deficit that would not meet the ideal 1.25 job/housing ratio. As population continues to increase in the City, the Western Riverside subregion, and the SCAG region, employment demands would be met as there would be a job surplus, but new homes would need to be built to meet the future housing demands and meet the ideal average job/housing ratio of 1.25 as identified by SCAG. The proposed would introduce up to 292 residential units, which would be able to provide housing for residents and help make up for the high job/housing ratio within the City.

The project site is located in an area surrounded by urbanized land, and is served by current infrastructure (e.g., roads and utilities), and community service facilities (e.g., police, fire, schools, and libraries). The project’s only infrastructure improvements would consist of tie-ins to, and extensions of, the existing utility main-lines already serving the project area.

Therefore, the project would not spur additional growth in Corona other than that already anticipated in the SCAG growth forecasts, and would not eliminate impediments to growth. Therefore, the proposed project would not foster growth inducing impacts.

5. POTENTIAL SECONDARY EFFECTS
Section 15126.4(a)(1)(D) of the CEQA Guidelines requires mitigation measures to be discussed in less detail than the significant effects of the project if the mitigation measure(s) would cause one or more significant effects in addition to those that would be caused by the project as proposed. With regard to this section of the CEQA Guidelines, the project’s proposed mitigation measures that could cause potential impacts were evaluated. The following provides a discussion of the potential secondary effects that could occur as a result of the implementation of the project mitigation measures, listed by environmental issue area. a. Air Quality
Impacts regarding air quality are less than significant and no mitigation measures are required. Therefore, no secondary impacts would occur due to the implementation of mitigation measures for this environmental topic.
b. Biological Resources
Mitigation Measure BIO-1 requires vegetation and general wildlife impact areas and avoidance areas to be flagged or fenced prior to grubbing of any vegetation or jurisdictional drainage features to prevent incursion into unsurveyed or avoided areas. Mitigation Measure BIO-2 prevents impacts to sensitive wildlife by avoiding clearing or other work in native habitats during critical nesting periods. Mitigation Measure BIO-3 requires surveys for the burrowing owl. Mitigation Measures BIO-4 and BIO-5 requires all heavy equipment to be washed prior to entering the project site from other construction sites to prevent the spread of weedy species and for staging areas to be placed in areas that have been previously disturbed. Mitigation Measures BIO-6, BIO-7, and BIO-8 provide mitigation for loss of non-wetland federal jurisdictional drainage features and streambed and riparian vegetation. Mitigation Measure BIO-9 requires the employment of standard best management practices (BMPs) to prevent discharged from entering avoided waters of the U.S. and

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streambed with associated riparian vegetation during construction. Mitigation Measure BIO-10 requires replacement of oak trees at no less than 1:1 ratio in landscaped areas. Mitigation Measure BIO-11 requires preservation of the ten acres of natural habitat identified as a compensation parcel adjacent to Forest Service land. Mitigation Measure BIO-12 requires mitigation for the 6.17 acres of Riparian/Riverine impacts. These mitigation measures would minimize or avoid overall losses of sensitive resources and would not result in any significant secondary effects.
c. Cultural Resources
Mitigation Measures CR-1 through CR-4 requires monitoring, recovery, and documentation of any recovered archaeological or paleontological resources. These measures are intended to preserve on-site cultural resources and would not have any secondary adverse effects either on- or off-site. d. Geology and Soils
Mitigation Measures GEO-1 through GEO-23 require implementation of all applicable recommendations contained in Section 9.0, Earthwork Conclusions and Recommendations, of the project Geotechnical Report, which would address site-specific geologic hazards to future on-site development. Therefore, no secondary impacts would occur due to the implementation of the mitigation measure for this environmental topic. e. Greenhouse Gas Emissions
Impacts regarding greenhouse gas emissions are less than significant and no mitigation measures are required. Therefore, no secondary impacts would occur due to the implementation of mitigation measures for this environmental topic.
f. Hazards and Hazardous Materials
Impacts regarding hazards and hazardous materials are less than significant. To ensure that impacts remain below the threshold, Mitigation Measures PS-1 and PS-2 from Section 4.I, Public Services, are recommended.

Mitigation Measure PS-1 requires the project Applicant to obtain CFD review and approval prior to issuance of building permits. Mitigation Measure PS-2 requires the project Applicant to pay the required service and development fees. Therefore, no secondary impacts would occur due to the implementation of mitigation measures for this environmental topic.
g. Hydrology and Water Quality
Mitigation Measure HYD-1 requires review and approval by the City of the engineering plans for the Drainage Management Area C. Therefore, no secondary impacts would occur due to the implementation of the mitigation measure for this environmental topic.
h. Land Use and Planning
Impacts regarding land use and planning are less than significant and no mitigation measures are required.

Therefore, no secondary impacts would occur due to the implementation of mitigation measures for this environmental topic.

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i. Noise
Mitigation Measure NS-1 requires restricted hours for construction and demolition. Mitigation Measure NS- 2 requires noise and groundborne vibration construction activities whose specific location on the project site may be flexible to be conducted as far as possible from nearest noise-and vibration-sensitive land use.

Mitigation Measure NS-3 requires construction and demolition activities to be scheduled so as to avoid operating several pieces of equipment simultaneously. Mitigation Measure NS-4 requires the use of construction equipment or construction methods with the greatest peak noise generation to be minimized.

Mitigation Measure NS-5 requires the project contractor to use power construction equipment with state-ofthe-art noise shielding and muffling devices. Mitigation Measure NS-6 requires barriers to minimize the amount of noise to the maximum extent feasible during construction. Mitigation Measure NS-7 requires all construction truck traffic to be restricted to truck routes approved by the City of Corona Public Works Department. Mitigation Measure NS-8 requires notification about estimated duration and hours of construction activities to all adjacent land uses within 300 feet. Therefore, no secondary impacts would occur due to the implementation of mitigation measures for this environmental topic. j. Population, Housing, and Employment
Impacts regarding population, housing, and employment are less than significant and no mitigation measures are required. Therefore, no secondary impacts would occur due to the implementation of mitigation measures for this environmental topic.
k. Public Services
(1) Fire
Mitigation Measure PS-1 requires the project Applicant to obtain CFD review and approval prior to issuance of building permits. Mitigation Measure PS-2 requires the project Applicant to pay the required service and development fees. Therefore, no secondary impacts would occur due to the implementation of mitigation measures for this environmental topic.
(2) Police
Mitigation Measure PS-3 requires the project Applicant to reserve a portion of the project site for a future radio facility site. Mitigation Measure PS-4 requires the project Applicant to pay the required service and development fees. Therefore, no secondary impacts would occur due to the implementation of mitigation measures for this environmental topic.
(3) Parks/Recreation
Mitigation Measure PS-5 requires the project Applicant to comply with the City of Corona Municipal Code (Chapter 16.35, Park Dedication and In Lieu Fees). Therefore, no secondary impacts would occur due to the implementation of the mitigation measure for this environmental topic.

6. Other Mandatory CEQA Considerations December 2015
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(4) Schools
Mitigation Measure PS-6 requires the project Applicant to pay the required SB 50 mitigation fees to the CNUSD. Therefore, no secondary impacts would occur due to the implementation of the mitigation measure for this environmental topic.
(5) Libraries
Mitigation Measure PS-7 requires payment of service and development fees pursuant to Section 16.23.080 of the CMC and the City’s Library Facility and Collection section of the Master Facility Plan to the City of Corona for the public improvements and facilities associated with the CPL. Therefore, no secondary impacts would occur due to the implementation of the mitigation measure for this environmental topic. l. Transportation
Mitigation Measure TR-1 requires the project Applicant to install at a traffic signal and design for two-phase operation at Intersection 3 – Paseo Grande at Ontario Avenue if the project is developed prior to the construction of the Foothill Parkway Extension. Mitigation Measure TR-2 requires the project Applicant to install at a traffic signal and design for two-phase operation at Intersection 4 – Border Avenue and Ontario Avenue. Mitigation Measure TR-3 requires the project Applicant to install at a traffic signal and design for five-phase operation at Intersection 10 – Elysia Street at Foothill Parkway. Mitigation Measure TR-4 requires the project Applicant to install at a traffic signal and design for three-phase operation at Intersection 11 – Trudy Way at Foothill Parkway. Mitigation Measure TR-5 requires the project Applicant to improve Roadway Segment 2 – Paseo Grande between Ontario Avenue and Green River Road to a 4-lane Secondary Roadway if the project is developed prior to the construction of the Foothill Parkway Extension.

While these improvements would require temporary construction activities at their respective locations, they would be carried out concurrent with project-related construction activities in the immediate area, such that their construction would not result in a substantial increase in the overall construction-related impacts of the proposed project. Furthermore, once constructed, these improvements would serve to reduce operational traffic impacts at the affected locations. Therefore, no measureable secondary impacts would occur due to the implementation of mitigation measures for this environmental topic. m. Utilities and Service Systems
(1) Water Supply and Water Infrastructure
Mitigation Measure UTIL-1 requires payment of water service connection fees to the Corona Department of Water and Power. Therefore, no secondary impacts would occur due to the implementation of the mitigation measure for this environmental topic.
(2) Wastewater
Mitigation Measure UTIL-2 requires payment of sewer connection fees to the Corona Department of Public Works. Therefore, no secondary impacts would occur due to the implementation of the mitigation measure for this environmental topic.

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(3) Solid Waste
Mitigation Measure UTIL-3 requires that contract specifications dictate that the construction contractors utilize the services of City’s exclusive franchise contract hauler, while Mitigation Measure UTIL-4 requires on-site separation and recycling of construction related wastes. Mitigation Measure UTIL-5 requires the project Applicant to demonstrate a plan to ensure adherence to the City of Corona Waste Diversion Program, which diverts 75 percent of all waste away from landfills. Therefore, no secondary impacts would occur due to the implementation of mitigation measures for this environmental topic. n. Agriculture and Forestry Resources
Impacts regarding agriculture and forestry resources are less than significant and no mitigation measures are required. Therefore, no secondary impacts would occur due to the implementation of mitigation measures for this environmental topic.

6. LESS THAN SIGNIFICANT IMPACTS
Section 15128 of the CEQA Guidelines states that an EIR shall contain a brief statement indicating reasons that various possible significant effects of a project were determined not to be significant and not discussed in detail in the Draft EIR. An Initial Study was not prepared for the project and therefore all substantive issues with any potential adverse impacts were addressed in this Draft EIR. However, given the development nature of the project site and its location within a highly urbanized area, the City of Corona determined that the project would not result in any potential impacts related to Mineral Resources. The basis for these conclusions is discussed below.

Mineral Resources
According to the Preliminary Geotechnical Investigation and Grading Plan, prepared by Ginter and Associates, Inc. in April 2014 (Appendix F of this Draft EIR), no active oil or gas wells exist and no mining of the gravels and/or sand has occurred to date. No other mineable resources are known to exist at the site. Aggregate companies have explored on-site conglomerates, but found no evidence of mining development for sand or gravel. Further, implementation of the project would not impede the potential for direct use or future exploration of mineral resources. Therefore, the project would result in no impacts regarding mineral resources.

6. Other Mandatory CEQA Considerations December 2015
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City of Corona Skyline Heights Project
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7.0 DOCUMENT PREPARATION AND REFERENCES
A. DOCUMENT PREPARATION

1. Lead Agency – City of Corona
City of Corona
400 S. Vicentia Avenue
Corona, California 92882
Jason Moquin, Senior Planner
Terri Manuel, AICP, Planning Manager
Joanne Coletta, Community Development Director

2. EIR Preparation
PCR Services Corporation
2121 Alton Parkway, Suite 100
Irvine, CA 92606
David Crook, AICP, Principal Planner (Project Manager)
Jay Ziff, Vice President/Director of Environmental Planning and Documentation Mike Harden, Principal Planner
Heidi Rous, CPP, Vice President/Director of Air Quality, Climate and Acoustics Alan Sako, Senior Air Quality Scientist
Kyle Kim, Ph.D., Senior Acoustic Engineer
Luci Hise-Fisher, Associate Principal
Lorena Christman, Senior Planner
Brian Allee, Senior Planner
Denise Kaneshiro, Graphics Specialist
Terry Keelan, Publications Director

3. Technical Consultants
(1) Traffic Impact Analysis
Linscott Law & Greenspan Engineers
2 Executive Circle, Suite 250
Irvine, CA 92614
Keil D. Maberry, P.E., Principal
Zawwar Saiyed, P.E., Senior Transportation Engineer

7.0 Document Preparation and References December 2015
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(2) Geotechnical Evaluation
Ginter & Associates, Inc. 27631 Durazno
Mission Viejo, CA 92692
Dave Ginter, R.G., C.E.G., President
Vela Ganeshwara, P.E., G.E., Consulting Geotechnical Engineer Mike Mills, R.G., C.E.G., Consulting Engineering Geologist (3) Hydrology and Water Quality
KWC Engineers
1880 Compton Avenue, Suite 100
Corona, CA 92881
Victor Elia, P.E. Mike Taing, P.E.
(4) Air Quality and Greenhouse Gas Emissions
FirstCarbon Solutions | Michael Brandman Associates
220 Commerce, Suite 200
Irvine, CA 92602
Charles Holcombe, Project Manager
Chryss Meier, Air Quality Analyst
(5) Biological Resources
L&L Environmental, Inc.
5455 Morgan Ave
Riverside, CA 92509
Leslie Irish, CEO, Wetland Delineator
Ann Lopez, Delineator & Regulatory Analyst
Julia Fox, Technical Editor
Jeff Sonnentag, Technical Editor
Gonzales Environmental Consulting, LLC
51-842 Avenida Diaz
La Quinta, CA 92253
Teresa Gonzales
Paul Gonzales
(6) Cultural Resources
LSA Associates, Inc.
1500 Iowa Avenue, Suite 200
Riverside, California 92507

December 2015 7.0 Document Preparation and References
City of Corona Skyline Heights Project
PCR Services Corporation/SCH No. 2014021003 7-3
Riordan Goodwin, Senior Cultural Resources Manager/Archaeologist Robert E. Reynolds, Senior Paleontologist
Jodi L. Dalton, M.A.
(7) Fuel Modification
BMLA Landscape Architecture
310 North Joy Street
Corona, CA 92879
Baxter Miller, RLA, ASLA President
(8) Agricultural Resources
FirstCarbon Solutions | Michael Brandman Associates
621 E. Carnegie Drive, Suite 100
San Bernardino, CA 92408
Charles Holcombe, Project Manager
(9) Noise
FirstCarbon Solutions | Michael Brandman Associates
621 E. Carnegie Drive, Suite 100
San Bernardino, CA 92408
Charles Holcombe, Project Manager
Katie Wilson, Air Quality/Noise Analysis Project Manager (10) Hazardous Materials
Hillman Consulting, Inc.
1745 W. Orangewood Avenue, Suite 110
Orange, CA 92868
Kenneth A. Thornburgh, Ph.D., Project Manager
David Rutherford, Director of Due Diligence
(11) Radio Communications
Wavepoint Research, Inc.

P.O. Box 96
Crane, IN 47522
Eric Wandel, P.E.
(12) Utilities
KWC Engineers
1880 Compton Avenue, Suite 100
Corona, CA 92881
Mike Taing, P.E.

7.0 Document Preparation and References December 2015
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PCR Services Corporation/SCH No. 2014021003 7-4
B. REFERENCES
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Bay Area Air Quality Management District, Recommended Methods for Screening and Modeling Local Risks and Hazards. 2012. Available: <http://www.baaqmd.gov/~/media/Files/Planning%20and %20Research/CEQA/Risk%20Modeling%20Approach%20May%202012.ashx?la=en>.

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California Air Resources Board. 1998. Proposed Identification of Diesel Exhaust as a Toxic Air Contaminant.

Available: <http://www.arb.ca.gov/regact/diesltac/diesltac.htm>. Accessed: January 25, 2010.

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California Climate Action Registry, Climate Action Leaders. http://www.climateregistry.org/about/members/climate-action-leaders.html. Accessed April 26, 2011.

California Climate Change Center. 2006. Our Changing Climate, Assessing the Risks to California: A Summary Report from the California Climate Change Center, CEC-500-2006-077, July 2006, http://www.scc.ca.gov/webmaster/ftp/pdf/climate_change/ assessing_risks.pdf. Accessed May 2012.

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California Department of Water Resources Website, CASGEM Groundwater Basin Prioritization, Casgem Basin Summary, Upper Santa Ana Valley, dated May 30, 2014, http://www.water.ca.gov/ groundwater/casgem/pdfs/basin_prioritization/SRO%20206.pdf, accessed June 2015.

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California Department of Water Resources, “Climate Change Characterization and Analysis in California Water Resources Planning Studies - Final Report,” December 2010 California Department of Water Resources, “Progress on Incorporating Climate Change into Management of California’s Water Resources,” July 2006
California Department of Water Resources, “Using Future Climate Projections to Support Water Resources Decision Making in California,” May 2009
California Department of Water Resources, Memorandum to All DWR Employees, “Sustainability Targets,” September 20, 2010. http://www.water.ca.gov/climatechange/docs/Sustainability_Policy.pdf.

California Department of Water Resources,Memorandum to All DWR Employees, “Sustainability Workgroup,” April 22, 2009. http://www.water.ca.gov/limatechange/docs/Sustainability_Policy.pdf. California Division of Mines and Geology (CDMG),Gray 1961; CDMG 1965;Weber, 1977, Gray et al, 2002; CDMG, 1980, cited in Ginter and Associates, Inc., Preliminary Geotechnical Investigation and Grading Plan, April 2014.

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CalRecycle Website,, http://www.calrecycle.ca.gov/WasteChar/WasteGenRates/Institution.htm, accessed November 2013).

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Caltrans, California Scenic Highway Program. http://www.dot.ca.gov/hq/LandArch/scenic_highways/ index.htm Accessed May 6, 2013.

Captain Jerry Rodriguez, Investigative Services Commander, Email correspondence, dated March 3, 2014 CEQA Guidelines Section 15126.6(b).

CEQA Guidelines Section 15130(b)(1)(A) and (B)
Chang & Adams Consulting. “Assessing the Economic and Market Trends Affecting Agriculture in the Western Inland Empire”. September 2011.

Cindi Schmitz, Corona Fire Department, Email correspondence, dated March 17, 2014.

Cindi Schmitz, Corona Fire Department, Email correspondence, dated February 27, 2014.

City of Corona Bicycle Master Plan and Existing and Proposed Bicycle Facilities Map, prepared by Alta Transportation Consulting and Ryan Snyder Associates, dated May 31, 2001.

City of Corona Final 2010 Urban Water Management Plan, Carollo, April 2012.

City of Corona Foothill Parkway Westerly Extension Draft EIR, Executive Summary, pages 2-1 and 2-2, August 2008.

City of Corona General Plan Technical Background Report, prepared by EIP Associates, adopted March 2004.

City of Corona General Plan, adopted March 17, 2004
City of Corona Library and Recreation Services Website, Recently Completed, Current & Planned Projects, http://www.coronadwp.com/parkmaint/projects.shtml, accessed May 2014.

City of Corona Municipal Code, Chapter 13.16.

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City of Corona website; available: http://discovercorona.com/About-Corona.aspx, accessed September 2014.

City of Corona, Climate Action Plan, 2012.

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December 2015 7.0 Document Preparation and References
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City of Corona, General Plan, Chapter 4, Infrastructure and Public Services. EIP Associates, March 2004.

City of Corona, General Plan, Technical Background Report, EIP Associates, March 2004.

City of Corona. www.InnerCircleCorona.com, “Green River Road Widening Project”, posted March 22, 2015.

Available at: http://www.innercirclecorona.com/green-river-road-widening-project/. Accessed July 2015.

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Corona-Norco Unified School District School Facilities Needs Analysis, December 2012.

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Effective 07/31/14.
http://planning.rctlma.org/Portals/0/zoning/ordnance/Ord.%20348.4773_clean_version.pdf.

Accessed November 2014.

Department of Water Resources, Climate Change Adaptation Strategies for California’s Water: Managing an Uncertain Future, California October 2008. http://www.water.ca.gov/climatechange/docs/ ClimateChangeWhitePaper.pdf.

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Fire Hazard Severity Zones in SRA, Western Riverside County, adopted by CAL FIRE on November 7, 2007.

First Carbon Solutions|Michael Brandman Associates, Noise Impact Analysis, Skyline Heights Project, City of Corona, California, Table 6, April 2014.

Ginter and Associates, Inc., Infiltration Opportunities, Constraints and Recommendations for Water Quality Treatment Purposes, for Skyline Heights Tentative Tract Map No. 36544, City of Corona,, California, January 2014.

Ginter and Associates, Inc., Preliminary Geotechnical Investigation and Grading Plan for Tentative Tract Map No. 36544, April 2014.

Highway Design Manual, Chapter 1000, Bikeway Planning and Design, Topic 1001 – General Criteria, Section 1001.4 Definitions, June 26, 2006.

7.0 Document Preparation and References December 2015
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http://www.discovercorona.com/City-Departments/Public-Works/Foothill-Parkway-WesterlyExtension.aspx, accessed June 16, 2104. http://www.lafco.org/opencms/faq.html, accessed June 16, 2014.

ICF International, Final Corona Regional Medical Center Expansion Project Archaeological and Paleontological Resources Report, prepared by April 2013.

Integrated Water Resources Plan, Report No. 1373, Updated October 12, 2010. The Metropolitan Water District of Southern California. http://www.mwdh2o.com/mwdh2o/pages/yourwater/ irp/IRP2010Report.pdf.

Jones, G. R., J. Jones, B. A. Gray, B. Parker, J. C. Coe, J. B. Burnham, and N. M. Geitner. 1975. A Method for the Quantification of Aesthetic Values for Environmental Decision Making. Nuclear Technology 25(4):
682–713.

Katherine Backus, Management Analyst, Corona Public Library, Letter Correspondence, dated February 27, 2014.

KWC Engineers, Preliminary Drainage Report for Skyline Heights, January 2014.

KWC Engineers, Preliminary Drainage Report, January 21, 2013 KWC Engineers, Preliminary Reclaimed Water Report for the Skyline Heights Project, January 16, 2014.

KWC Engineers, Preliminary Water Report for the Skyline Heights Project, February 10, 2014.

KWC Engineers, Project Specific Water Quality Management Plan, January 2014.

KWC Engineers. Skyline Heights – Tentative Tract Map No. 36544. 2014.

Martin and Lew (1999) cited in Ginter & Associates, Inc., April 25, 2014, page 35.

Metropolitan Water District of Southern California, Report for Metropolitan Water District of Southern California Board Meeting September 11, 2007 Agenda Item 8-4.

Metropolitan Water District of Southern California. The Regional Urban Water Management Plan, November 2010. http://www.mwdh2o.com/mwdh2o/pages/yourwater/RUWMP/RUWMP_2010.pdf.

Nancy Baker, Facilities Supervisor, Corona-Norco Unified School District, Letter Correspondence, dated March 13, 2014.

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Office of Environmental Health Hazard Assessment. 2000. Health Effects of Diesel Exhaust Fact Sheet.

August. Available: <http://oehha.ca.gov/air/pdf/dieselfact2.pdf>. Accessed: April 26, 2010.

Pacific Soils Engineering, Inc. (2004 and 2005) cited in Ginter & Associates, April 25, 2014, page 36.

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http://www.rivcoag.org/opencms/publications/. 2012. Accessed April 2013.

San Bernardino, County of. Department of Agriculture/Weights and Measures. “2009 Crops and Livestock Report”. Website: http://ucanr.org/sites/Farm_Management/files/132158.pdf. 2010. Accessed April 2013. Santa Ana River Trail Master Plan, Corona-Eastvale-Norco Segment State Route 71 to Hidden Valley Wildlife Area, prepared by The Dangermond Group, WRC Consulting, Inc., Michael Brandman Associates, and Kammeyer and Associates, dated June 2011 and the City of Corona Online Services Website, Santa Ana River Trail Documents, http://www.discovercorona.com/City-Departments/Parks--- Community-Services/Park-Development-(1)/Trail-Projects.aspx, accessed May 2014.

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Smardon, R. C., J. F. Palmer, and J. P. Felleman. 1986. Foundations for Visual Project Analysis. NY: John Wiley & Sons, Inc.

South Coast Air Quality Management District, 2012 Air Quality Management Plan, http://www.aqmd.gov/home/library/clean-air-plans/air-quality-mgt-plan/final-2012-aqmp-carbepa-sip-submittal. Accessed December 11, 2012.

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South Coast Air Quality Management District, CEQA Air Quality Handbook, (1993), 12-3.

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South Coast Air Quality Management District, Fact Sheet for Applying CalEEMod to Localized Significance Thresholds, http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significancethresholds/caleemod-guidance.pdf?sfvrsn=2. Accessed March 21, 2012.

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South Coast Air Quality Management District, Final Localized Significance Threshold Methodology, Appendix C, Revised October 21, 2009, http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysishandbook/localized-significance-thresholds. Accessed May 7, 2012.

South Coast Air Quality Management District, Final Report, Multiple Air Toxics Exposure Study, MATES-III, (2008).

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Accessed October 2014.

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Southern California Air Quality Management District (SCAQMD) Risk Assessment Procedures for Rules 1401 and 212, November 1998.

Southern California Air Quality Management District (SCAQMD), CEQA Air Quality Handbook, Chapter 6 (Determining the Air Quality Significance of a Project).

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Southern California Association of Governments website: http://www.scag.ca.gov/Documents/ 5thCyclePFinalRHNAplan.pdf. Accessed May 2014.

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Steve Wilkson, City of Corona Public Works – Waste Management/Recycling, email correspondence, dated February, 28, 2014.

The Regional Urban Water Management Plan, November 2010. The Metropolitan Water District of Southern California. http://www.mwdh2o.com/mwdh2o/pages/yourwater/RUWMP/RUWMP_2010.pdf.

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U.S. Census Bureau, http://quickfacts.census.gov/qfd/states/06/0616350.html, accessed March 2014.

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U.S. Soil Conservation Service. 1978. Procedure to Establish Priorities in Landscape Architecture (Technical Release No. 65). Washington, DC. U.S.D.A. Forest Service. 1995. Landscape Aesthetics: A Handbook for Scenery Management. (Agriculture Handbook Number 701).

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PCR
January 2017

FINAL ENVIRONMENTAL IMPACT REPORT
Skyline Heights Project
City of Corona, California

January 2017
Prepared For:

CITY OF CORONA
400 S. Vicentia Avenue
Corona, California 92882
Contact: Jason Moquin, Senior Planner
Prepared By:

PCR SERVICES CORPORATION
2121 Alton Parkway, Suite 100
Irvine, California 92606
Skyline Heights Project
City of Corona, California

FINAL ENVIRONMENTAL IMPACT REPORT

Table of Contents
Page

1. INTRODUCTION...............................................................................................................................................................1-1

1.1 CONTENT AND FORMAT............................................................................................................................................... 1-1

1.2 PUBLIC REVIEW OF THE DRAFT EIR.......................................................................................................................1-1

1.3 POINT OF CONTACT........................................................................................................................................................ 1-2

1.4 PROJECT SUMMARY ........................................................................................................................................................ 1-2

2. RESPONSES TO COMMENTS ........................................................................................................................................2-1

2.1 LIST OF PERSONS, ORGANIZATIONS, AND PUBLIC AGENCIES COMMENTING ON THE DEIR........2-2

2.2 FORMAT OF RESPONSES TO COMMENTS..............................................................................................................2-2

2.3 COMMENTS AND RESPONSES.....................................................................................................................................2-3

3. CORRECTIONS AND ADDITIONS TO THE DRAFT EIR AND RDEIR .................................................................3-1

3.1 INTRODUCTION.................................................................................................................................................................3-1

3.2 CORRECTIONS AND ADDITIONS................................................................................................................................3-2

4. MITIGATION MONITORING AND REPORTING PROGRAM ................................................................................4-1

4.1 INTRODUCTION.................................................................................................................................................................4-1

4.2 MITIGATION MONITORING AND RESPONSIBILITIES.......................................................................................4-1

4.3 MMRP PROGRAM CHECKLIST.....................................................................................................................................4-2 List of Tables
Page
Table 2-1 Summary of Comments on the Skyline Heights Project Draft EIR........................................................ 4 Table 2-2 Summary of Comments on the Skyline Heights Project RDEIR .......................................................... 14 City of Corona Skyline Heights Project
PCR Services Corporation/SCH No. 2014021003 i

1. Introduction

1. INTRODUCTION
The Final Environmental Impact Report (“EIR”) for the proposed Skyline Heights Project (“proposed project”) is composed of the Draft EIR State Clearinghouse No. 2014021003 and Appendices; the Response to Comments; the Findings, Statement of Overriding Considerations, Staff Reports, and Resolutions.

Specifically, this document portion of the EIR includes the Comments and Responses volume of the Final EIR, EIR modifications or errata, and the Mitigation Monitoring Reporting Program (“MMRP”). The purpose of this document is to respond to all comments received by the City of Corona (“City”) regarding the environmental information and analyses contained in the Draft EIR. Additionally, any corrections to the text and figures of the Draft EIR generated either from responses to comments or independently by the City, are stated in this volume of the Final EIR. The Draft EIR text itself has not been modified to reflect these clarifications.

1.1 CONTENT AND FORMAT
Subsequent to this introductory section, Chapter 2 contains copies of each comment letter received on the Draft EIR, along with annotated responses to each comment contained within the letters. Chapter 3 of this document contains corrections and errata to the Draft EIR. Chapter 4 contains the MMRP, which includes additional measures developed as a part of this Final EIR.

1.2 PUBLIC REVIEW OF THE DRAFT EIR
As required by the California Environmental Quality Act (“CEQA”) Guidelines Section 15087, a Notice of Completion (“NOC”) of the Draft EIR State Clearinghouse No. 2014021003 for the Skyline Heights Project was filed with the State Clearinghouse on December 4, 2015 and the Notice of Availability (“NOA”) of the Draft EIR was filed with the Riverside County Clerk on December 4, 2015.

The Draft EIR was submitted to the State Clearinghouse and circulated for public review for a period of 45 days, from December 4, 2015 to January 19, 2016. On March 16, 2016, the City publicly noticed the availability of the Draft EIR in the Sentinel Weekly, on the city website at www.discovercorona.com, mailed individual public notices to property owners within a 500 foot radius of the project boundary and posted a sign on Foothill Parkway in the general proximity of the project site. The City accepted all public comments on the Draft EIR through May 9, 2016. Copies of the Draft EIR were distributed to all Responsible Agencies and to the State Clearinghouse in addition to various public agencies, organizations, and interested individuals. Copies of the Draft EIR were also made available for public review at the City Community Development Department at City Hall, at the City Public Library, and on the City’s website.

Based in part on comments received on the Draft EIR, the City decided to recirculate the Biological Resources section of the EIR and supporting revised technical studies. The Recirculated DEIR was circulated for a period of 45 days which began on November 16, 2016 and ended on December 30, 2016, though the City accepted comments submitted on the RDEIR through January 9, 2017.

A total of 83 comment letters, including 66 emails were received during the public comment period.

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Comment letters and emails were received from state agencies, regional agencies, cultural organizations and the general public. In addition, a total of six (6) comment letters were subsequently received on the Recirculated Draft EIR (RDEIR) during the 45-day public review period. These included comments from three (3) public agencies, one organization, and two (2) private individuals.

In addition to the written comments, relevant issues raised in oral comments received at two of the City’s regularly scheduled Planning and Housing Commission meetings on April 11 and May 9, 2016 have also been considered. Comments that address environmental issues are thoroughly responded to in Chapter 2.

1.3 POINT OF CONTACT
The Lead Agency for this Project is the City of Corona. Any questions or comments regarding the preparation of this document, its assumptions, or its conclusions, should be referred to:

Jason Moquin, Senior Planner
Community Development Department
Planning Division
400 South Vicentia Avenue
Corona, California 92882
Phone: (951) 736-2262

1.4 PROJECT SUMMARY
The following information is summarized from the Chapter 2, Project Description, in the Draft EIR. For additional detail in regard to project characteristics and project-related improvements, along with analyses of the project’s potential environmental impacts, please refer to Draft EIR Chapter 4, Environmental Impact Analysis.

1.4.1 Project Location and Surrounding Uses
The project site is located in unincorporated Riverside County, approximately three miles south of State Route 71 (SR-71, Chino Valley Freeway) and SR-91 (Riverside Freeway) and approximately four miles west of Interstate 15 (I-15, Temecula Valley Freeway) along the southwestern boundary of the City of Corona.

The 270.9-acre project site is located adjacent to, and southwest of, the proposed Foothill Parkway Westerly Extension.

The project site is vacant; however, one single-family home is located within the larger 394.8-acre annexation area surrounding the site, which is located to the north of the project site (Assessor’s Parcel Number [APN] 102-320-010). Access to the single-family residence is provided via Green River Road.

Miscellaneous vacated buildings, used in conjunction with a former horse stable enterprise, are located within APN 102-320-009, adjacent to and east of the existing residence. Other uses within the surrounding annexation area, but not within the 270.9-acre project site include a nursery (APN 275-080-021) to the north of Browning Circle and four open space parcels owned by the U.S. Wildlife Service in the southeasterly sector of the larger annexation area. The project site is generally bounded on the north and east by single-family City of Corona Skyline Heights Project
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January 2017 1. Introduction
residences and on the south and west by the Cleveland National Forest and large privately owned parcels.

No commercial land uses are located within the immediately surrounding area.

The nearest development (Tract Map 31955) is located adjacent to and southeast of the project site, south of Foothill Parkway, with access provided by Trudy Way, Rawley Street, Elker Road, and Corbett Street. Tract 31955 consists of an approximately 154-lot, residential subdivision within the R1-7.2 zone, which corresponds to low-density single-family and a 7,200-square-foot minimum lot area. The edges of the subdivision are zoned R1-AD/HD, which corresponds to agricultural/hillside uses in a residential zone. The purpose for the latter zone is to maintain common open spaces on the periphery of the residential development.

The area to the south of Tract 31955 is zoned R1-9.6 (single-family residential, with a 9,600-square-foot minimum lot size) and OS (open space) and vacant. This area is accessed by, and to the south of, Skyline Drive.

Existing single-family neighborhoods are also located to the northeast of the project site and Foothill Parkway Westerly Extension. These neighborhoods are generally zoned low density residential (R1-7.2, R1-

8.4, and R1-9.6). Large, undeveloped parcels within the OS zone are interspersed among the residential areas. All of the adjacent developed areas are located within the City of Corona.

The Cleveland National Forest is located to the west and south of the annexation area and project site. The National Forest is accessed via Skyline Drive, a graded forest service access road to the south of the project site. This road provides recreational hiking and mountain biking opportunities to residents on a local and regional level.

1.4.2 Proposed Project
The project involves the approval of Tentative Tract Map 36544 for the development of 292 single-family homes. In order to facilitate the development of the residential subdivision, an annexation of the project site and surrounding annexation area is required. As such, the primary facets of the project are the following:
 Annexation of 394.8 acres from unincorporated Riverside County in the City of Corona’s SOI to the City of Corona.
 General Plan Amendment to Corona’s General Plan Sphere of Influence Land Use Plan (West Sphere) to amend 394.8 acres from Rural Residential 1 (0.2 – 0.5 dwelling units/acre) to Low Density Residential (3-6 dwelling units/acre) on 357.14 acres and Open Space on 37.61 acres.  Application to rezone 37.61 acres to Open Space, 86.23 acres to Agriculture, and 270.9 acres to R-1-

7.2 (single-family residential, 7,200 square-foot minimum lot size located in the city’s SOI (westerly sphere) to facilitate the annexation of property into the City of Corona.  Approval of Tentative Tract Map 36544.

Tentative Tract 36544 includes numerous lettered lots to be set aside for open space, slope landscaping, streets, and utilities. Of these lots, 45 lots would be developed to the north of Mabey Canyon and 247 lots would be developed to the south of Mabey Canyon. The residential development would occur in three City of Corona Skyline Heights Project
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1. Introduction January 2017
phases. Phase I would consist of 157 homes to be located in the central and south sectors of the site, to the south of Mabey Canyon and along the future Trudy Way alignment. Phase II would consist of 90 homes to be constructed in the central sector of the site, south of Mabey Canyon and west of the Trudy Way alignment.

Phase III would consist of 45 homes to be constructed in the north sector of the project site, north of Mabey Canyon. It is anticipated that the three phases would be completed by 2020.

1.4.3 Project Objectives
Section 15124(b) of the CEQA Guidelines states that a project description shall contain “a statement of the objectives sought by the proposed project.” In addition, Section 15124(b) of the CEQA Guidelines further states that “the statement of objectives should include the underlying purpose of the project.” As set forth by the CEQA Guidelines, the list of objectives that the project Applicant seeks to achieve for the project is provided below.

Objective 1: Provide high quality residential development consistent with adjacent neighborhoods.

Objective 2: Build residential housing which is in compliance with proposed zoning and Corona General Plan land use designations consistent with surrounding area.

Objective 3: Facilitate the annexation of the project development and adjacent lands into the City of Corona.

Objective 4: Provide efficient and safe movement of vehicles and pedestrians with minimum intrusion on adjacent residential neighborhoods.

Objective 5: Dedicate land and contribute fees for the construction of Foothill Parkway.

Objective 6: Ensure that all community facilities and services including circulation improvements, drainage facilities, water, reclaimed water and sewer facilities are available to serve the project and meet or exceed applicable City standards and requirements prior to, or concurrent with development.

Objective 7: Provide strategic improvements within the project to assist the City with Master Plan improvements to existing water and sewer system.

Objective 8: Provide water reservoirs and infrastructure to improve service and reliability for other parts of the City.

Objective 9: Provide a system of open space which combines natural and man-made areas to maintain a scenic and fire safe living environment for residents.

Objective 10: Implement a comprehensive landscape program which provides visual continuity throughout the project area and the natural areas of the Cleveland National Forest.

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January 2017 1. Introduction
Objective 11: Help meet the high market demand for high quality housing in western Riverside County and to meet the City’s housing needs to support forecasted population growth as discussed in the City’s General Plan (2004).

1.4.4 Required Permits and Discretionary Actions
Approvals required for implementation of the proposed project include, but are not limited to, the following:

1. City of Corona
 City Council approval of project and certification of Environmental Impact Report  General Plan Amendment 13-003 (GPA13-003) to amend Corona’s General Plan Sphere of Influence Land Use Plan (westerly sphere) to amend 394.8 acres from Rural Residential I (0.2 - 0.5 dwelling units per acre) to Low Density Residential (3-6 dwelling units per acre) on 357.14 acres and Open Space on 37.61 acres.
 Change of zone 13-002 (CZ13 002) to rezone 37.61 acres to Open Space, 86.23 acres to Agriculture, and 270.9 acres to R-1-7.2 (single-family residential, 7,200 square-foot minimum lot size) located in the City’s SOI (westerly sphere) to facilitate the annexation of property into the City of Corona.  Annexation 117 to annex 394.8 acres from unincorporated Riverside County in the City of Corona’s SOI to the City of Corona.
 Approval of Tentative Tract Map 36544 (TTM 36544) to provide for the subdivision of 270.9 acres into 292 single family residential lots, including numerous lettered lots to be set aside for open space, slope landscaping, streets and utilities in the R-1-7.2 zone being proposed by CZ13-002.  Approval of a Radio Study (for Corona Police Department communications), as well as haul route, demolition, grading, and building permits.

2. Riverside LAFCO
 Review and approval of the annexation of 394.8 acres located within the City of Corona SOI from unincorporated Riverside County to the City of Corona

3. South Coast Air Quality Management District (SCAQMD)  Construction and operation permits pursuant to SCAQMD Regulation II

4. Regional Water Quality Control Board (RWQCB)
 National Pollution Discharge Elimination System (NPDES) Permits

5. Metropolitan Water District of Southern California (Metropolitan)  Annexation of the project site into the Metropolitan service area

6. State Water Resources Control Board (SWRCB)
 General Construction Stormwater Permit
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1. Introduction January 2017

7. Federal
 Clean Water Act (CWA) Section 404 Permit
 Clean Water Act (CWA) Section 401 Water Quality Certification  California Fish and Game Code Section 1602 Streambed Alteration Agreement for impacts to jurisdictional features regulated by the USACE, RWQCB, and/or CDFW.

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2. Responses to Comments

2. RESPONSES TO COMMENTS
A total of 83 comment letters were received on the Skyline Heights Draft EIR. The Draft EIR was initially made available to the public through the State Clearinghouse on December 4, 2015 for a period of 45 days with the public comment period ending on January 20, 2016. The comment period on the Draft EIR was extended by City and the notice of availability was made available to the public on March 16, 2016 through May 2, 2016. The Notice of Availability of the Draft EIR was published in the Sentinel Weekly, published on the City’s website, posted on a sign on Foothill Parkway in general proximity to the project site, and mailed public notices were sent to property owners within a 500-foot radius of the project site. The City accepted all public comments submitted on the Draft EIR through May 9, 2016, the date of the second Planning and Housing Commission meeting on the Skyline Heights project. These include comment letters from five public agencies, three organizations, and 75 private individuals and businesses. In addition, a total of six (6) comment letters were subsequently received on the Recirculated Draft EIR (RDEIR) during the 45-day public review period which began on November 16, 2016 and ended on December 30, 2016, though the City accepted comments submitted on the RDEIR through January 9, 2017. These included comments from three (3) public agencies, one organization, and two (2) private individuals.

Section 15088 of the State CEQA Guidelines, Evaluation of and Response to Comments, states:
a) The lead agency shall evaluate comments on environmental issues received from persons who reviewed the draft EIR and shall prepare a written response. The lead agency shall respond to comments received during the noticed comment period and any extensions and may respond to late comments.
b) The lead agency shall provide a written response to a public agency on comments made by that public agency at least 10 days prior to certifying an environmental impact report. c) The written response shall describe the disposition of significant environmental issues raised (e.g., revisions to the proposed project to mitigate anticipated impacts or objections). In particular, major environmental issues raised when the lead agency’s position is at variance with recommendations and objections raised in the comments must be addressed in detail, giving the reasons that specific comments and suggestions were not accepted. There must be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information will not suffice. d) The response to comments may take the form of a revision to the draft EIR or may be a separate section in the final EIR. Where the response to comments make important changes in the information contained in the text of the draft EIR, the lead agency should either:

1. Revise the text in the body of the EIR; or

2. Include marginal notes showing that the information is revised in the responses to comments.

In accordance with CEQA Guidelines Section 15088(a), written responses to the comments received regarding the adequacy and completeness of the Draft EIR, substantive environmental issues associated with the Project, and/or the incorporation of additional environmental information relevant to environmental City of Corona Skyline Heights Project
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2. RESPONSES TO COMMENTS January 2017
analysis, are included in this chapter. In accordance with CEQA Section 15088(a), comments received that do not address one or more of these issues are not responded to further in this chapter.

In addition, in accordance with CEQA Guidelines Section 15088(d), a set of corrections and additions to the EIR has been prepared in accordance with CEQA that make minor corrections and clarifications to the Draft EIR and RDEIR as a result of City review and comments received during the respective public review periods for these documents. Therefore, this Response to Comments document, along with these corrections and additions, are included as part of the Final EIR for consideration by the City Council prior to a vote to certify the Final EIR. These corrections and additions are included in Chapter 3, Corrections and Additions to the Draft EIR and RDEIR, of this Final EIR. These corrections and additional clarify, amplify, or make minor modifications to the Draft EIR and RDEIR. It should be noted that a number of comments received on the Draft EIR warranted additional analysis regarding impacts to biological resources, and therefore the City prepared an updated Biological Resources section, which was circulated for public review as part of the RDEIR, as noted above. None of the comments, responses, or associated corrections and additions subsequent to the release of the RDEIR constitutes “significant new information” (CEQA Guidelines Section 15088.5) that would require recirculation of the EIR because:
 No new significant environmental impact would result from the project or from a new mitigation measure;
 There is no substantial increase in the severity of an environmental impact that would result unless mitigation measures are adopted that reduce the identified significant impacts to a level of insignificance;
 No feasible project alternative or mitigation measure considerably different from others previously analyzed has been proposed or identified that would clearly lessen the significant environmental impacts of the project; and
 The Draft EIR, inclusive of the RDEIR, is not fundamentally or basically inadequate or conclusory in nature such that meaningful public review and comment were precluded.

2.1 LIST OF PERSONS, ORGANIZATIONS, AND PUBLIC AGENCIES COMMENTING ON THE DEIR
The public agencies, organizations, and private individuals and businesses that submitted written comments on the Draft EIR through May 9, 2016, and on the RDEIR through January 9, 2017, as well as the environmental and CEQA process issues raised in these comments, are identified in Table 2-1, Summary of Comments on the Skyline Heights Project Draft EIR, and Table 2-2, Summary of Comments on the Skyline Heights Project RDEIR.

2.2 FORMAT OF RESPONSES TO COMMENTS
Courtesy statements, introductions, closings, and individual comments within the body of each letter have been identified and numbered. A copy of each comment letter and the City’s responses are included in this section. Brackets delineating the individual comments and an alphanumeric identifier have been added to the right margin of the letter. Responses to each comment identified are included on the page(s) following each comment letter. Responses to comments were sent to the agencies that provided comments at least 10 days prior to the City Council’s consideration of certification of the Final EIR (CEQA Guidelines Section 15088(b).

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January 2017 2. RESPONSES TO COMMENTS

2.3 COMMENTS AND RESPONSES
The bracketed comment letters, and the written responses to the comments in these letters, are provided after Tables 2-1 and 2-2 below.

City of Corona Skyline Heights Project
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2. RESPONSES TO COMMENTS January 2017
Table 2-1
Summary of Comments on the Skyline Heights Project Draft EIR

LETTER
NO. COMMENTER PROJECT

DESCRIPTION

AESTHETICS AND
VIEWS

AIR QUALITYBIOLOGICAL
RESOURCESa

CULTURAL

RESOURCES

GEOLOGY AND SOILSGREENHOUSE
GAS

EMISSIONS

HAZARDS AND

HAZARDOUS
MAT

HYDROLOGY AND
WATER

QUALITY

LAND USE AND

PLANNING

NOISEPOPULATION, HOUSING,EMPLOYMENTPUBLIC SERVICES (INCLUDING PARKS AND RECREATION)b
TRANSPORTATIONcUTILITIES AND SERVICE SYSTEMSAGRICULTURE AND FORESTRY RESOURCESALTERNATIVESOTHER CEQA CONSIDERATIONSOTHER COMMENTS

EXPLANATION OF OTHER

PUBLIC AGENCIES
1 United States Forest Service
Cleveland National Forest
Trabuco Ranger District
Darrel Vance, District Manager
1147 E 6th Street
Corona, CA 92879-1616
x x x x
2 State of California
Governor’s Office of Pln. and Res.

Scott Morgan, Director
State Clearinghouse and Plan. Unit
1400 Tenth Street
P.O. Box 3044
Sacramento, CA 95812-3044
x x CEQA process
3 State of California
Natural Resources Agency
Department of Fish and Wildlife
Inland Deserts Region
Leslie MacNair, Regional Manager
3602 Inland Empire Boulevard
Suite C-220
Ontario, CA 91764
x x
City of Corona Skyline Heights Project
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2. RESPONSES TO COMMENTS January 2017
LETTER
NO. COMMENTER PROJECT

DESCRIPTION

AESTHETICS AND
VIEWS

AIR QUALITYBIOLOGICAL
RESOURCESa

CULTURAL

RESOURCES

GEOLOGY AND SOILSGREENHOUSE
GAS

EMISSIONS

HAZARDS AND

HAZARDOUS
MAT

HYDROLOGY AND
WATER

QUALITY

LAND USE AND

PLANNING

NOISEPOPULATION, HOUSING,EMPLOYMENTPUBLIC SERVICES (INCLUDING PARKS AND RECREATION)b
TRANSPORTATIONcUTILITIES AND SERVICE SYSTEMSAGRICULTURE AND FORESTRY RESOURCESALTERNATIVESOTHER CEQA CONSIDERATIONSOTHER COMMENTS

EXPLANATION OF OTHER
4 County of Riverside
Transportation and Land
Management Department
Russell Williams, Development
Review Manager
4080 Lemon Street, 8th floor
Riverside, CA 92501
x x x
5 Riverside County
Regional Park and Open-Space
District
Paul Rull, Parks Planner
4600 Crestmore Road
Jurupa Valley, CA 92509
x x x

ORGANIZATIONS
6 California Native Plant Society
Riverside-San Bernardino Chapter
4477 Picacho Drive
Riverside, CA 92507
x x x
7 Soboba Band of Luiseno Indians
Joseph Ontiveros, Director of
Cultural Resources
P.O. Box 487
San Jacinot, CA 92581
x
8 Soboba Band of Luiseno Indians
Joseph Ontiveros, Director of
Cultural Resources
P.O. Box 487
San Jacinot, CA 92581
x
City of Corona Skyline Heights Project
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January 2017 2. RESPONSES TO COMMENTS
LETTER
NO. COMMENTER PROJECT

DESCRIPTION

AESTHETICS AND
VIEWS

AIR QUALITYBIOLOGICAL
RESOURCESa

CULTURAL

RESOURCES

GEOLOGY AND SOILSGREENHOUSE
GAS

EMISSIONS

HAZARDS AND

HAZARDOUS
MAT

HYDROLOGY AND
WATER

QUALITY

LAND USE AND

PLANNING

NOISEPOPULATION, HOUSING,EMPLOYMENTPUBLIC SERVICES (INCLUDING PARKS AND RECREATION)b
TRANSPORTATIONcUTILITIES AND SERVICE SYSTEMSAGRICULTURE AND FORESTRY RESOURCESALTERNATIVESOTHER CEQA CONSIDERATIONSOTHER COMMENTS

EXPLANATION OF OTHER

INDIVIDUALS AND BUSINESSES
9 Petition-Moratorium
iPetitions.com x x x X General opposition to project
10 Nicole Krenzin
2627 Falcon Circle
Corona, CA 92882
[email protected]
x x x X
11 Dwight Woodward x x x x x
12 DeAnna Murdock
Signage Solutions
2231 S. Dupont Drive
Anaheim, CA 92806
[email protected]
x x
13 Ann and Donald Long
1460 W. Chase Drive
Corona, CA 92882
x x x x x
14 Alexis Demeo
[email protected] x x
15 David Wright
1359 Williamsburg Ln.

Corona, CA 92882
[email protected]
x x x x X
CEQA process (public
noticing), general
opposition to project
16 Dalia Terriquez
[email protected] x x X General opposition to project
17 Jeff Nelson
[email protected] x x x X General opposition to project City of Corona Skyline Heights Project
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2. RESPONSES TO COMMENTS January 2017
LETTER
NO. COMMENTER PROJECT

DESCRIPTION

AESTHETICS AND
VIEWS

AIR QUALITYBIOLOGICAL
RESOURCESa

CULTURAL

RESOURCES

GEOLOGY AND SOILSGREENHOUSE
GAS

EMISSIONS

HAZARDS AND

HAZARDOUS
MAT

HYDROLOGY AND
WATER

QUALITY

LAND USE AND

PLANNING

NOISEPOPULATION, HOUSING,EMPLOYMENTPUBLIC SERVICES (INCLUDING PARKS AND RECREATION)b
TRANSPORTATIONcUTILITIES AND SERVICE SYSTEMSAGRICULTURE AND FORESTRY RESOURCESALTERNATIVESOTHER CEQA CONSIDERATIONSOTHER COMMENTS

EXPLANATION OF OTHER
18 Kyle Ericson
3244 Mountain Pass Drive
Corona, CA 92882
[email protected]
x x X
19 Rudy Realo
[email protected] x x X General opposition to project
20 Georganna Hemingway
[email protected] x x X General opposition to project
21 Justin Henderson x x x X General opposition to
project
22 Courtney Kasey
[email protected] x x X General opposition to project 23 Justin Henderson
[email protected] x x X General opposition to project
24 Branton Lachman
[email protected] x x X General opposition to project 25 Stephanie Lomani
[email protected] x x X
General opposition to
project
26 Branton Lachman
[email protected] x x x X General opposition to project 27 Patricia (Realo) Anderson
[email protected] x x x X X
Development rights,
general opposition to
project
28 David Wright
1359 Williamsburg Ln.

Corona, CA 92882
[email protected]
x x X
CEQA process (public
noticing), general
opposition to project
29 Courtney Kasey
[email protected] x x X General opposition to project City of Corona Skyline Heights Project
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January 2017 2. RESPONSES TO COMMENTS
LETTER
NO. COMMENTER PROJECT

DESCRIPTION

AESTHETICS AND
VIEWS

AIR QUALITYBIOLOGICAL
RESOURCESa

CULTURAL

RESOURCES

GEOLOGY AND SOILSGREENHOUSE
GAS

EMISSIONS

HAZARDS AND

HAZARDOUS
MAT

HYDROLOGY AND
WATER

QUALITY

LAND USE AND

PLANNING

NOISEPOPULATION, HOUSING,EMPLOYMENTPUBLIC SERVICES (INCLUDING PARKS AND RECREATION)b
TRANSPORTATIONcUTILITIES AND SERVICE SYSTEMSAGRICULTURE AND FORESTRY RESOURCESALTERNATIVESOTHER CEQA CONSIDERATIONSOTHER COMMENTS

EXPLANATION OF OTHER
30 Khoa Vu x x X General opposition to
project
31 Christy Parker
Emotional Ethics
[email protected]
[email protected]
x
32 K. Zimmerman x x
33 Carol Lazar
1763 Gleason
Corona, CA 92882
[email protected]
X Open space
34 [email protected] X Open space
35 Kate Panepinto
[email protected] X General opposition to project
36 Jorge Loutzenhiser
Quality Assurance/IT Dept.

MillworkX Precision Machining,
Inc.
[email protected]
x x x X
37 Khris Gaines
[email protected] x x X General opposition to project
38 Eric Budinko
[email protected] x x X General opposition to project
39 Stephanie Lomani
[email protected] x x x X General opposition to project 40 Imdad Yusufaly
[email protected] x x X General opposition to project City of Corona Skyline Heights Project
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2. RESPONSES TO COMMENTS January 2017
LETTER
NO. COMMENTER PROJECT

DESCRIPTION

AESTHETICS AND
VIEWS

AIR QUALITYBIOLOGICAL
RESOURCESa

CULTURAL

RESOURCES

GEOLOGY AND SOILSGREENHOUSE
GAS

EMISSIONS

HAZARDS AND

HAZARDOUS
MAT

HYDROLOGY AND
WATER

QUALITY

LAND USE AND

PLANNING

NOISEPOPULATION, HOUSING,EMPLOYMENTPUBLIC SERVICES (INCLUDING PARKS AND RECREATION)b
TRANSPORTATIONcUTILITIES AND SERVICE SYSTEMSAGRICULTURE AND FORESTRY RESOURCESALTERNATIVESOTHER CEQA CONSIDERATIONSOTHER COMMENTS

EXPLANATION OF OTHER
41 Craig Johnson
1400 W. Chase Drive
Corona, CA 92882
[email protected]
x x X X Maintenance of facilities
42 Khoa Vu x x X General opposition to
project
43 Erika Hernandez
[email protected] x x X General opposition to project 44 Michelle Phillips
[email protected] x x X General opposition to project 45 Patricia (Realo) Anderson
[email protected] x x x x x X X CEQA process (public noticing) 46 David (James) Armenta
[email protected] x x X
General opposition to
project
47 Brendan McGeown
[email protected] x x X
48 Laura Brennan-Mayhugh
[email protected] x x x X
49 Aaron Cox
[email protected] x x x X
50 Wendie Stevens-Rodriguez
[email protected] x x X General opposition to project 51 Nicole Krenzin
2627 Falcon Circule
Corona, CA 92882
[email protected]
x x x x x X
City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 Page 2660 of 3613 2-9
January 2017 2. RESPONSES TO COMMENTS
LETTER
NO. COMMENTER PROJECT

DESCRIPTION

AESTHETICS AND
VIEWS

AIR QUALITYBIOLOGICAL
RESOURCESa

CULTURAL

RESOURCES

GEOLOGY AND SOILSGREENHOUSE
GAS

EMISSIONS

HAZARDS AND

HAZARDOUS
MAT

HYDROLOGY AND
WATER

QUALITY

LAND USE AND

PLANNING

NOISEPOPULATION, HOUSING,EMPLOYMENTPUBLIC SERVICES (INCLUDING PARKS AND RECREATION)b
TRANSPORTATIONcUTILITIES AND SERVICE SYSTEMSAGRICULTURE AND FORESTRY RESOURCESALTERNATIVESOTHER CEQA CONSIDERATIONSOTHER COMMENTS

EXPLANATION OF OTHER
52 Nicole Krenzin
2627 Falcon Circule
Corona, CA 92882
[email protected]
x x X General opposition to
project
53 Ann and Donald Long
1460 W. Chase Drive
Corona, CA 92882
[email protected]
x x x x X Property values
54 Rachel DosSantos
[email protected] x
55 Jennifer Daughaday
[email protected] x
56 Sean Soto
[email protected] x
57 Elsa Yoshida
[email protected] x x X X General opposition to project, open space 58 Malinda Vance
[email protected] x x x
59 Sylvia Sparks
[email protected] x
60 Brittney Pecore
[email protected] x x X General opposition to project
61 Lolly Janoski
[email protected] x x x x X
62 Elaine Harris
[email protected] x x x X Open space
City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 2-10

2. RESPONSES TO COMMENTS January 2017
LETTER
NO. COMMENTER PROJECT

DESCRIPTION

AESTHETICS AND
VIEWS

AIR QUALITYBIOLOGICAL
RESOURCESa

CULTURAL

RESOURCES

GEOLOGY AND SOILSGREENHOUSE
GAS

EMISSIONS

HAZARDS AND

HAZARDOUS
MAT

HYDROLOGY AND
WATER

QUALITY

LAND USE AND

PLANNING

NOISEPOPULATION, HOUSING,EMPLOYMENTPUBLIC SERVICES (INCLUDING PARKS AND RECREATION)b
TRANSPORTATIONcUTILITIES AND SERVICE SYSTEMSAGRICULTURE AND FORESTRY RESOURCESALTERNATIVESOTHER CEQA CONSIDERATIONSOTHER COMMENTS

EXPLANATION OF OTHER
63 Linda Terry
Corona, CA 92879
[email protected]
x x
64 Ann and Donald Long
1460 W. Chase Drive
Corona, CA 92882
[email protected]
x x x x X Property values
65 Dwight Woodward
2272 Adrienne Drive x x x
66 David (James) Armenta
Corona, CA
[email protected]
x x X General opposition to
project
67 Courtney Kasey
[email protected] x x x x X X X X CEQA process (public noticing), fiscal 68 Courtney Kasey
[email protected] x x x x X X X X CEQA process (public noticing), fiscal 69 Courtney Kasey
[email protected] x x x x X X X CEQA process, cumulative, fiscal 70 Courtney Kasey
[email protected] x x x x x x X X X
Mitigation, open space,
general opposition to
project
71 Courtney Kasey
[email protected] x x x x x x X X X
Mitigation, open space,
general opposition to
project
72 Carlos Quintero
[email protected] x x X Open space
73 James Brooks
[email protected] x x x X General opposition to project, open space City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 Page 2662 of 3613 2-11
January 2017 2. RESPONSES TO COMMENTS
LETTER
NO. COMMENTER PROJECT

DESCRIPTION

AESTHETICS AND
VIEWS

AIR QUALITYBIOLOGICAL
RESOURCESa

CULTURAL

RESOURCES

GEOLOGY AND SOILSGREENHOUSE
GAS

EMISSIONS

HAZARDS AND

HAZARDOUS
MAT

HYDROLOGY AND
WATER

QUALITY

LAND USE AND

PLANNING

NOISEPOPULATION, HOUSING,EMPLOYMENTPUBLIC SERVICES (INCLUDING PARKS AND RECREATION)b
TRANSPORTATIONcUTILITIES AND SERVICE SYSTEMSAGRICULTURE AND FORESTRY RESOURCESALTERNATIVESOTHER CEQA CONSIDERATIONSOTHER COMMENTS

EXPLANATION OF OTHER
74 Elaine Harris
[email protected] x x x X Open space
75 Didier Trevizo
Trevizo Chiropractic
Corona, CA
[email protected]
x x x General opposition to
project, open space
76 Tariq Shamma
TMS Consortium
807 E. Chase Drive
Corona, CA 92881
x x x x
77 Wilson Tsing
[email protected] x x x x X X
General opposition to
project, CEQA process
(public noticing)
78 Roger Conard
Conard Photo
[email protected]
x x x x X General opposition to
project
79 Stephanie Morales
[email protected] x x x x X General opposition to project, open space 80 Lydia Castillo
[email protected] x X Open space
81 Wes Bemis
898 Big Spring Court
Corona, CA 92880
[email protected]
x x X Open space
82 Eveline Zadeh
[email protected] x x X General opposition to project 83 Wes Bemis
[email protected] x
City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 2-12

2. RESPONSES TO COMMENTS January 2017
LETTER
NO. COMMENTER PROJECT

DESCRIPTION

AESTHETICS AND
VIEWS

AIR QUALITYBIOLOGICAL
RESOURCESa

CULTURAL

RESOURCES

GEOLOGY AND SOILSGREENHOUSE
GAS

EMISSIONS

HAZARDS AND

HAZARDOUS
MAT

HYDROLOGY AND
WATER

QUALITY

LAND USE AND

PLANNING

NOISEPOPULATION, HOUSING,EMPLOYMENTPUBLIC SERVICES (INCLUDING PARKS AND RECREATION)b
TRANSPORTATIONcUTILITIES AND SERVICE SYSTEMSAGRICULTURE AND FORESTRY RESOURCESALTERNATIVESOTHER CEQA CONSIDERATIONSOTHER COMMENTS

EXPLANATION OF OTHER
a Biological resources include, but are not limited to, sensitive plant and animal species, sensitive habitat (riparian, wetlands) wetland, streambed alteration, and watersheds. b Public services include fire protection and emergency medical services, police protection and law enforcement services, parks and recreational services, schools, and library services. c Transportation includes traffic, parking, circulation, (vehicular, pedestrian, bicycle), and safety.

Source: ESA PCR, January 2017.

City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 Page 2664 of 3613 2-13
January 2017 2. RESPONSES TO COMMENTS
Table 2-2
Summary of Comments on the Skyline Heights Project RDEIR

LETTER
NO.

COMMENTER PROJECT

DESCRIPTIO
N

AESTHETICS AND
VIEWS

AIR QUALITYBIOLOGICAL
RESOURCESa

CULTURAL

RESOURCES

GEOLOGY AND SOILSGREENHOUSE
GAS

EMISSIONS

HAZARDS AND

HAZARDOUS
MAT

HYDROLOGY AND
WATER

QUALITY

LAND USE AND

PLANNING

NOISEPOPULATION, HOUSING,EMPLOYMENTPUBLIC SERVICES (INCLUDING PARKS AND RECREATION)b
TRANSPORTATIONcUTILITIES AND SERVICE SYSTEMSAGRICULTURE AND FORESTRY RESOURCESALTERNATIVESOTHER CEQA CONSIDERATIONSOTHER COMMENTS

EXPLANATION OF OTHER

PUBLIC AGENCIES
84 State of California
Natural Resources Agency
Department of Fish and Wildlife
Inland Deserts Region
Leslie MacNair, Regional Manager
3602 Inland Empire Boulevard
Suite C-220
Ontario, CA 91764
x x
85 State of California
Department of Transportation
District 8
Mark Roberts, Office Chief
Intergovernmental Review,
Community and Regional Planning
MS 722
464 West 4th Street, 6th Floor
San Bernardino, CA 92401-1400
x
86 Riverside County Flood Control
and Water Conservation District
Edwin Quinonez
Engineering Project Manager
1995 Market Street
Riverside, CA 92501
x x x

ORGANIZATIONS
City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 2-14

2. RESPONSES TO COMMENTS January 2017
LETTER
NO.

COMMENTER PROJECT

DESCRIPTIO
N

AESTHETICS AND
VIEWS

AIR QUALITYBIOLOGICAL
RESOURCESa

CULTURAL

RESOURCES

GEOLOGY AND SOILSGREENHOUSE
GAS

EMISSIONS

HAZARDS AND

HAZARDOUS
MAT

HYDROLOGY AND
WATER

QUALITY

LAND USE AND

PLANNING

NOISEPOPULATION, HOUSING,EMPLOYMENTPUBLIC SERVICES (INCLUDING PARKS AND RECREATION)b
TRANSPORTATIONcUTILITIES AND SERVICE SYSTEMSAGRICULTURE AND FORESTRY RESOURCESALTERNATIVESOTHER CEQA CONSIDERATIONSOTHER COMMENTS

EXPLANATION OF OTHER
87 Pechanga Tribal Historic
Preservation Office
Temecula Band of Luiseno Mission
Indians
Anna Hoover, Deputy THPO,
Cultural Analyst
Post Office. Box 2183 • Temecula,
CA 92593
x

INDIVIDUALS
88 Joyce Malle
[email protected] x X
89 Patrick Aggabao
[email protected] x
a Biological resources include, but are not limited to, sensitive plant and animal species, sensitive habitat (riparian, wetlands) wetland, streambed alteration, and watersheds. b Public services include fire protection and emergency medical services, police protection and law enforcement services, parks and recreational services, schools, and library services. c Transportation includes traffic, parking, circulation, (vehicular, pedestrian, bicycle), and safety.

Source: ESA PCR, January 2017.

City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 Page 2666 of 3613 2-15
1 David Crook
From: Joanne Coletta <[email protected]>
Sent: Monday, May 02, 2016 6:23 PM
To: David Crook; Mike Byer ([email protected]) Subject: FW: Skyline Heights DEIR Comments - Forest Service Attachments: Corona SKYLINE DEIR comments CNF 050216.pdf Importance: High
From: Vance, Darrell W -FS [mailto:[email protected]]
Sent: Monday, May 02, 2016 12:57 PM
To: Terri Manuel
Cc: Heys, Jeffrey A -FS; Rodriguez, Jacob F -FS
Subject: Skyline Heights DEIR Comments - Forest Service Importance: High
Good Afternoon Ms. Manuel,
Please find attached our written comments regarding the Skyline Heights DEIR.   Feel free to contact us with any comments or questions.

Thank You, and have a great day!
D
Darrell Vance
District Ranger
Forest Service
Cleveland National Forest
Trabuco Ranger District
p: 951-736-1811 x3236
[email protected]
1147 E. 6th St.

Corona, CA 92879-1616
www.fs.fed.us
Caring for the land and serving people
This electronic message contains information generated by the USDA solely for the intended recipients. Any unauthorized interception of this message or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please notify the sender and delete the email immediately.

LETTER 1
1

2 3
4 5

5 (cont.)
6 7
8

8 (cont.)
9

9 (cont.)
10 Page 2671 of 3613
January 2017 2. RESPONSES TO COMMENTS
Comment Letter 1
United States Forest Service
Cleveland National Forest
Trabuco Ranger District
Darrel Vance, District Manager
1147 E 6th Street
Corona, CA 92879-1616
Response to Letter 1
Response to Comment 1-1. This comment provides a general introduction regarding the comments raised in this letter. Responses to the comments contained in this letter are provided below in Responses to Comments 1-2 through 1-10 below.

Response to Comment 1-2. This comment expressing thanks for the opportunity to comment, and commending the detail provided in the analysis which eliminated many of the Forest Services’ concerns regarding development in close proximity to the Cleveland National Forest (CNF), is noted and will be provided to the decision makers for their consideration. However, as this comment does not raise a substantive issue on the content of the Draft EIR, no further response is warranted.

Response to Comment 1-3.

Consistency with CNF LMP
The Draft EIR addressed the location of the project site in multiple chapters and sections, including but not limited to Chapter 1.0, Introduction, Chapter 2.0, Project Description, and Section 4.I, Land Use and Planning, and evaluates the consistency of the project with applicable regulations in multiple sections, including the consistency of the project will applicable land use plans in Section 4.I. While the Draft EIR correctly indicates that the CNF lies to the west and south of the project site (for example, on pages ES-4, 1-5, 2-2, 2-5, 2-11 and

4.I-2), it is acknowledged that the Draft EIR does not make clear that the project site is located entirely within the boundaries of the CNF as indicated in the comment. In response, the Draft EIR has been revised to: (1) indicate that the project site is located entirely within the boundaries of the CNF; and (2) include the requested consistency analysis with the CNF’s 2005 Land Management Plan (LMP). These corrections and additions have been incorporated into Chapter 3, Corrections and Additions to the Draft EIR and RDEIR, in this Final EIR. As indicated in the added consistency analysis, the project would be generally consistent with applicable land use goals and requirements of the LMP, and thus project land use impacts regarding consistency with the LMP would be less than significant.

Development at the Urban-Rural Interface
With regards to the comment that the increase in population density under the project would accelerate certain ongoing challenges that the LMP directs the Forest Service to remedy, while the project site is located within the CNF, the portion of the site proposed for development: (1) is private land within Riverside County’s land use jurisdiction and the City of Corona’s Sphere of Influence (SOI); (2) both the County and the City currently designate the proposed development portion of the site for rural residential development; (3) City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 2-21

2. RESPONSES TO COMMENTS January 2017
as indicated on page 37 of the LMP, the Elsinore portion of the CNF in which the project site is located is at the urban-rural interface; and (4) LMP’s Land-Use Zones map identifies the proposed development portion of the site as “Non-Forest System Land” rather than “Forest Land” and does not identify the site as being within one of the designated Land-Use Zone in which the LMP regulates land uses. Furthermore, the project would not include the construction of urban support systems (e.g., roads, utility lines, etc.) on public land or on private land not already designated for urban development, and would not block existing vehicular and trail access to the CNF. Finally, as indicated under the “Consistency with CNF LMP” discussion above, the project would be generally consistent with the applicable land use goals and requirements of the LMP.

Therefore, the project would not substantially accelerate certain ongoing challenges that the LMP directs the Forest Service to remedy related to population density. Please see the LMP consistency analysis in Chapter 3 of this Final EIR, and Response to Comments 1-5 and 1-6 below, for further discussion.

Response to Comment 1-4.

Development in Proximity to the CNF
With regard to the general issues of development in close proximity to NFS lands and increasing population density within/adjacent to the CNF, please see Response to Comment 1-3 above. As indicated therein, the proposed development portion of the project site is already designated for urban development, the project would not include development on public land or the extension of roads or infrastructure on public lands, and the project would not block existing vehicular and trail access to the CNF. Furthermore, as indicated on page 4.I-15 of the Draft EIR, while project residents would likely utility the existing trails in the area, this increase in trail use is expected to be nominal relative to the existing trail usage and would not result in substantial degradation of the trails
Water Extraction
With regard to water extraction, this issue is addressed in Section 4.H, Hydrology and Water Quality, of the Draft EIR. As indicated on page 4.H-27 of the Draft EIR, the project would not involve any groundwater extraction or other activities that could result in direct withdrawal or depletion of groundwater supplies. As further indicated, while the project would obtain its water from the City of Corona’s municipal water system, which relies in part on water supplies from local aquifers, the project would not result in any adverse impacts to the City’s water supplies, including groundwater resources. Therefore, the project would not significantly impact groundwater levels or supply within the CNF.

Habitat/Habitat Fragmentation
With regard to loss of habitat and habitat fragmentation, these issues are addressed in Section 4.C, Biological Resources, of the Draft EIR. As indicated on pages 4.C-23 through 4.C-30 and page 4.C-50 of the Draft EIR, and on pages 4.C-49 through 4.C-50 of the RDEIR, the project would result in less than significant impacts to sensitive species habitat, riparian habitat and wetlands, and less than significant habitat fragmentation impacts, with the proposed provision of approximately 36 percent of the annexation area as permanent open space (including most of Maybey Canyon and the drainages), adherence to applicable regulations, and implementation of the Project Design Features and mitigation measures identified in the section. Please see Response to Comment 1-7 below for further discussion.

Land Use and Open Space
City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 2-22

January 2017 2. RESPONSES TO COMMENTS
With regard to loss of open space, this issue is addressed in Section 4.I, Land Use and Planning, of the Draft EIR. As indicated on page 4.I-15 through 4.I-25, the project would be consistent with the: (1) open space factors (e.g., requirements) for annexation set forth in the Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000; (2) objectives to focus growth in existing and emerging centers and along major transportation corridors, and to preserve existing open space, as set forth in the Southern California Association of Governments Regional Transportation Plan/Sustainable Communities Strategy and other SCAG regional plans; and (3) open space goals, policies and requirements of the City of Corona General Plan.

As indicated on pages 4.I-15 through 4.I-25, the above conclusions were reached, in part, because: the project site is located immediately adjacent to existing development and a major arterial, within an urban service area designated by LAFCO, within the City of Corona’s sphere of influence (SOI), and within an area designated by both the County and the City for urban development; approximately 36 percent of the greater annexation area would be retained as agricultural and permanent open space land; the project would largely preserve Mabey Canon and other surrounding open space features, and conserve habitat in drainages; the project would preserve vehicular and trail access to the CNF; and the project would provide open space features within the proposed subdivision that provide for recreation and natural resource value. As indicated on page 4.I-26 of the Draft EIR, with approval of the proposed General Plan Map Amendment, Zoning Map and Text Amendment, Tentative Tract Map, and project design features identified in the Draft EIR, the project would not conflict with relevant land use plans, policies and regulations, and thus impacts related to land use and planning (including impacts to open space) would be less than significant. Please see the CNF LMP consistency analysis in Chapter 3, Corrections and Additions to the Draft EIR and RDEIR, of this Final EIR, for analysis of project consistency with applicable CNF LMP open space goals, policies and requirements. As indicated therein, the project would be consistent with applicable CNF LMP open space goals, policies and objectives.

Scenic Integrity
With regard to loss of scenic integrity, this issue is addressed in Section 4.A, Aesthetics, of the Draft EIR. As indicated on pages 4.A-15 and 4.A-4.A-26 of the Draft EIR, given the substantial landform alteration of the project site required to implement the proposed projects, impacts related to views/scenic vistas, visual resources, and visual character would be significant and unavoidable, and no mitigation measures are available to reduce the significance of these impacts. Still, as indicated on page 4.A-26, all feasible mitigation measures, including clustering and compliance with state and local development codes, have been incorporated into the project. In addition, the project would preserve approximately 36% of the proposed annexation area in agricultural and permanent open space use. Finally, the project would represent lowdensity residential development with landscape and open space amenities which would soften the aesthetic impacts of the project. Please see Response to Comment 1-9 below under “Visual Sensitivity of Project Site” for additional mitigating factors.

Response to Comment 1-5.

Occupancy Trespass
The Draft EIR addresses occupancy trespass on page 4.C-27 in Section 4.C, Biological Resources, which is also addressed on page 4.C-41 of the RDEIR. As indicated on page 4.C-27 of the Draft EIR and 4.C-41 of the RDEIR, the project would incorporate barriers to prevent human and pet encroachment into the natural areas outside the proposed subdivision. Specifically, Project Design Feature BIO-6 on Draft EIR page 4.C-22 (RDEIR page 4.C-41) will include walls, exclusionary fencing, and special edge treatments in accordance with City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 2-23

2. RESPONSES TO COMMENTS January 2017
Western Riverside County Multiple Species Habitat Conservation Plan requirements to separate developed areas from open space areas and minimize unauthorized public access, domestic animals predation, and illegal trespass and dumping. Furthermore, per Project Design Features BIO-7 and BIO-8 provided on Draft EIR page 4.C-22 and RDEIR page 4.C-42), access points between native habitat and project development will be posted with signage requesting project residents to stay on the trails, not disturb habitat, and keep pets leashed and educational pamphlets will be provided to project residents educating them on the potential adverse impacts to biological resources and native habitats should these requests be ignored. Project Design Feature BIO-8 also prohibits back gates in the required private yard fencing. Therefore, significant occupancy trespass into open space areas adjacent to the proposed project would not occur.

Use of Public Lands for Urban Support
With regard to the concern that there may be an expectation on the part of the project applicant for use of public lands to provide urban support (e.g., accommodation of roads, water tanks/water transmission lines, etc.) and/or wildfire defensible space for the proposed project: (1) as indicated in Figures 2-6, 2-7, 4.G-1A and 4.G-1B of the Draft EIR, the 270.9-acre project site occurs wholly on private property, and would not include the construction of urban support systems or the provision of required wildfire defensible space on public land; (2) as indicated on page 2-15 of the Draft EIR, the four U.S. Fish and Wildlife Service parcels within the greater 394.8-acre annexation area, as well as the open space parcel at the south edge of the annexation area, would be maintained as permanent open space; (3) as indicated on page 2-15 of the Draft EIR, vehicle access to the project would be from the Foothill Parkway Westerly Extension and Trudy Way; and (4) as indicated on page 2-21 of the Draft EIR, all project water, wastewater, and storm drainage infrastructure improvements would be constructed wholly within the project site or within City rights-ofway, and as indicated on page 4.I-24, natural gas and electrical lines are currently located in the surrounding streets. Therefore, the project and associated infrastructure and wildfire defensible space would be developed wholly on private and not public land.

Response to Comment 1-6.

Access to the CNF
Public and administrative access to the CNF is addressed in Section 4.I, Land Use and Planning, of the Draft EIR. As indicated on pages 4.I-9 and 4.I-15, the four U.S. Fish and Wildlife Service parcels within the annexation area, and the open space parcel at the south edge of the annexation area, would be maintained as permanent open space which would allow continued access to Skyline Drive which serves as trail access to the CNF as well as the trails within the CNF themselves. As indicated in Figure 2-7, Tentative Tract Map 36544, in Chapter 2, Project Description, the portion of Skyline Drive within the annexation area would be preserved. As indicated on page 4.I-12 and in Figures 4.I-1 and 4.I-2, the project would not alter Skyline Trail or the access point to that trail along Foothill Parkway. As indicated in Figure 2-7 in Chapter 2, Project Description, of the Draft EIR, the existing unimproved road leading from Maybey Canyon Road through the project site into Mabey Canyon within the CNF would be retained. Therefore, existing publically accessible trails would be preserved, and existing access to the CNF preserved, under the project.

Unplanned Roads/Trails
With regard to unplanned roads and trails directly out of the subdivision, and unauthorized motorized vehicle use, please see Response to Comment 1-5 “Occupancy Trespass”. As indicated therein, project design City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 2-24

January 2017 2. RESPONSES TO COMMENTS
features (e.g., walls, exclusionary fencing, a prohibition on back gates in private yard fencing) are proposed which would eliminate substantial occupancy trespass and avoid unplanned roads and trails into adjacent CNF open space areas.

Survey/Post of Private Property Boundary Line
With regard to the request for the project to survey and post the private property boundary line, within the project area, where it abuts NFS lands, this has been added as a project design feature in Chapter 3, Corrections and Additions to the Draft EIR and RDEIR, in this Final EIR.

Response to Comment 1-7. This comment references a 40-acre Cleveland National Forest parcel, which does not correspond to the development portion of the Skyline Heights project site. However, the project site does surround a 10-acre USFS parcel (APN 275-040-010), which is designated as “NOT A PART” (NAP) on the project tentative tract map. The proponent proposes to mitigate both potential direct and indirect impacts to the 10-acre NAP parcel via the avoidance and the deed restricting of an equal size parcel of land, which is located immediately adjacent to land owned by the USFS in the western portion of the project site.

The Exchanged or Compensation parcel (currently part of APN 275-040-006), which is also 10 acres, is immediately adjacent to the CNF and Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) Core B. This 10-acre property would add to the total acreage of contiguous land within the Core that would remain undeveloped in perpetuity. In addition to the 10 acres, those areas not impacted by the proposed project will also be deed restricted to prevent future development. The avoided land to the west of the proposed development will also add to the total acreage of contiguous land with the Core that would remain undeveloped in perpetuity.

The 10-acre parcel proposed for compensation is in the far west portion of the project site, in proximity to the NAP parcel and within the Santa Ana foothills. The compensation parcel supports 2.5 acres of coastal sage scrub, 0.79 acre of coastal sage scrub-chaparral intergrade, 6.54 acres of chaparral, 0.17 acre of coast live oak woodland, and two (2) jurisdictional features. In addition, the compensation parcel supports approximately ±1,396 chaparral nolina (Nolina cismontana) and 116 intermediate mariposa lilies (Calochortus weedii var. intermedius). There are no access roads on the property. The proposed development is adjacent to the compensation parcel, but only a narrow east/west band comes close to the parcel. Another ±7 acres of natural land will be avoided by the development immediately east of the 10-acre parcel and will remain undeveloped.

Although the land surrounding the 10-acre NAP parcel is currently undeveloped, the NAP parcel is not contiguous with CNF land since it is surrounded by private property. In an effort to not isolate the NAP parcel, the project design includes approximately 22 acres to the east and south that would be avoided and deed restricted around the 10-acre NAP parcel. This area is contiguous with another large area of currently undeveloped land to the south, which would allow for some opportunities for sensitive plants and animals to disperse. Urban and Wildlands interface measures would also be utilized to minimize edge effects to the area surrounding the 10-acre NAP as well as to the avoided habitat west of the development.

Please see Response to Comment 1-5 above regarding encroachment and enforcement issues.

Response to Comment 1-8. The Draft EIR addressed the widland fire hazards associated with the project in Section 4.G, Hazards and Hazardous Materials, with supporting data provided in Appendix G, Phase I City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 2-25

2. RESPONSES TO COMMENTS January 2017
Environmental Site Assessment and Fuel Modification Report. As indicated on pages 4.G-15 and 4.G-16, while the project site is located within a Very High Fire Hazard Severity Zone (VHFHSZ), the project would replace highly flammable vegetation with plants on the City’s approved list of fire-resistant species, and would implement a fuel modification plan, which would decrease rather than increase the wildland fire potential in the area. As such, the project would result in a less than significant wildland fire hazards with:
adherence to applicable requirements (including with CBC Chapter 7A, Materials and Construction Methods for Exterior Wildfire Exposure, and requirements related to fire access, fire flows, and number of hydrants); implementation of the proposed project design features (including the fuel modification plan); and implementation of the prescribed mitigation measures (including CFD review and approval of the site plan, fuel modification plan, and project design features, and payment of the required “Fire Facilities Fund” fees).

With regard to the comment that the project would increase the potential for human-caused wildfires, and that the Draft EIR does not adequately evaluate this increased potential, as indicated above, the project would replace highly flammable vegetation with fire-resistant species, and would implement a fuel modification plan, which together would reduce rather than increase the wildland fire hazard on-site. Also, the project would include roadway development that would increase rather than decrease fire fighting vehicle access to the area, and would include the extension of water infrastructure, including for firefighting purposes, where no such infrastructure currently exists. Furthermore, the area already includes an existing urban-rural interface, so the potential for human-cause wildfires in the area already exists; the project would merely move the existing urban-rural interface line. City of Corona Fire would assume responsibility of the area once annexed into the City. However, the City has an automatic aid contract with the U. S. Forest Service and participates in the Master Mutual Aid Plan with Cal Fire. Both documents provide the Corona Fire Department with cooperative assistance from these two agencies in wildland fires. Lastly, it is noted that the significance threshold used in the wildland fire hazard analysis in the Draft EIR is verbatim from Appendix G of the State CEQA Guidelines, and states that a significant wildland fire hazard would occur if the project would “Expose people or structures to a significant risk of loss, injury or death involving wildland fires…”, not expose wildlands to an increased potential for wildland fires.

Based on the above, the project would reduce the wildland fire hazard both on and adjacent to the project site, and the wildland fire hazard impact would be less than significant. Additional support for this conclusion is provided in the Fuel Modification Report as set forth below. • Pages 4 and 5 of the Fuel Modification Report address the nature and relationship that the home owner, HOA and City Fire Department has to minimize the potential for human caused fires. This includes, but is not limited, to inspections and additional Fuel Modification Plan approval at the time of building site layout and permit approval.
• This issue is addressed in the Calculations and approach that the BEHAVE PLUS FIRE MODELING SYSTEM SOFTWARE, which was utilized for the Fuel Modification Report. With the development information at hand at the time of the writing of the report, the recommendations are conservative and will be reviewed and modified as required by the City of Corona as the development plans proceed. Refer to Fuel Modification Report pages 8 thru 16. • As indicated on page 5, Section 8, of the Fuel Modification Report, the Fuel Modification plan does provide prudent and restrictive solutions to the interface between the CNF and the proposed development in accordance with the state, county and local requirements for fuel modification and City of Corona Skyline Heights Project
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January 2017 2. RESPONSES TO COMMENTS
wild land fire protection.
• As indicated on page 3, Section 5, of the Fuel Modification Report, the minimum distance from the limits of the maintained fuel modification zone includes an additional 30’ of defensible area for all structure setbacks.
• As indicated on page 4, Section, 6, of the Fuel Modification Report, the Fuel Modification Plan places the responsibility for maintaining of the fuel modification zones directly on the shoulders of the HOA and the property owner not the CNF.
• As indicated on pages 112 through 118 of the Fuel Modification Report, the species identified in the plant palette includes native species that are compatible with fuel modification activities and the habitat in which we are proposing to develop.

The slopes where trees are located within the fuel modification zones will be planted under the restrictions and guidelines for defensible space. The planting of invasive species is not proposed. The only reason that the trees are limited to the intersection of property lines at the top of slopes; is to provide some screening of the residential units while providing views.

Response to Comment 1-9.

Visual/Aesthetic Impacts
The comment that the project’s visual impacts would directly affect the area’s aesthetics to a significant and unavoidable level is noted. Please see Responses to Comments 1-4 under “Scenic Integrity” and 1-9 under “Visual Sensitivity of Project Site”.

Visual Sensitivity of Project Site
With regard to the comment that the project area is one of the most visible landscapes on the CNF, and is maintained as an undeveloped island and natural-appearing backdrop to the I-15 and CA-91 corridors, it is acknowledged that CNF’s 2005 LMP says this with respect to the Elsinore Place portion of the CNF, which appears by the LMP’s Scenic Integrity Objectives Map to cover most of the Corona Hills (e.g., the east-facing slopes of the CNF). However, the project site is located along the bottom-most (e.g., eastern most) portion of the Corona Hills, and directly adjacent to existing residential tracts. Furthermore, the LMP’s Scenic Integrity Objectives Map doesn’t even assign a Scenic Integrity Objective (e.g., moderate, high, very high) to the project site and greater annexation area. These factors suggest that the project site is located within one of the less visibly-sensitive portions of the Elsinore Place area. Furthermore, as discussed in Response to Comment 1-3, the project site is located on private land within Riverside County’s land use jurisdiction and the City of Corona’s Sphere of Influence (SOI) rather than on public land within the Forest Service’s land use jurisdiction, and is designated by the County and City for urban development. Therefore, the project site is not located within one of the most visible landscapes in the CNF, and is not to be maintained as an undeveloped island. However, the Draft EIR discloses the fact the project would alter the natural setting of the site and will result in a significant and unavoidable impact on aesthetics.

Maintenance of Skyline Silhouette
With regard to the comment that among the desired conditions and landscape attributes on the CNF is City of Corona Skyline Heights Project
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2. RESPONSES TO COMMENTS January 2017
maintenance of the skyline silhouette of the Santa Ana Mountains, as indicated on pages 4.A-14 and 4.A-15 of the Draft EIR: “While the project would permanently alter the foreground views of the foothills of the Santa Monica Mountains, the background views to the Santa Ana Mountains would remain following project implementation.” This is apparent from Figures 2-1 and 2-2 of the Draft EIR which show that the project site is located near the foot rather than ridge tops of the Santa Ana Mountains, and thus would not affect the skyline silhouette of the Santa Ana Mountains.

Impact on “Forest Experience”
With regard to the comment that the impacts of the project (e.g., noise, increased demand for NFS lands, parking, need for sanitation) on the Forest experience have not been adequately evaluated, the Draft EIR:
addressed the biological resources impacts of the project in Section 4.C, Biological Resources, with supporting data provided in Appendix D, Biological Resources Assessment, Surveys, and Jurisdictional Delineation; addressed the noise impacts of the project in Section 4.J, Noise, with supporting data provided in Appendix I, Noise Impact Analysis; addressed the park and recreational impacts of the project in Section

4.L, Public Services; addressed the parking impacts of the project in Section 4.M, Transportation, with supporting data provided in Appendix K, Traffic Impact Analysis; and addressed the sanitation (e.g., solid waste) impacts of the project in Section 4.N, Utilities and Service Systems. In addition, additional analysis of biological resources impacts was subsequently provided in Section 4.C, Biological Resources, in the RDEIR, with supporting documentation and analysis provided in Appendix A of the RDEIR. Furthermore, an analysis of project consistency with applicable goals and objectives of the 2005 CNF LMP has been added in Chapter 3, Corrections and Additions to the Draft EIR and RDEIR, in this Final EIR. However, CEQA and applicable federal, State, County and local regulations do not require analysis of impacts on the “Forest experience” in an EIR.

Proposed On-Site Park and Recreational Facilities
With regard to the comment “Nor does there appear to be much alternative on the proposed developed private land for similar opportunities”, it is unclear exactly what the commenter intended by this comment.

If the comment intends to indicate that the project does not provide sufficient on-site park and recreational facilities required to meet project demand, the parks and recreation impacts of the Project are evaluated in Section 4.L, Public Services, of the Draft EIR. As indicated on page 4.L-17, the project is not proposing new on-site park or recreational facilities (although, as indicated on pages 2-15 through 2-19 of the Draft EIR, the project is proposing on-site open space and landscape features). However, as indicated therein (pages 4.L17 and 4.L-18), the project would result in less than significant parks and recreation impacts with implementation of the proposed project design features and implementation of Mitigation Measure PS-5 which requires compliance with City of Corona Municipal Code Chapter 16.35 (Park Dedication and In Lieu Fees). Compliance with Mitigation Measure PS-5, in particular, would ensure park and recreation facilities are being accounted for with this project as the proponent would be required to dedicate land for a park or pay an in-lieu fee for such facility to be developed elsewhere.

Vantage Points/Visual Simulations
With regard to the choice of visual simulations included in the aesthetics analysis in the Draft EIR, as indicated on page 4.A-10 of the Draft EIR, the focus of the visual analysis is on the potential for the project to adversely affect views from publically accessible vantage points (i.e., views from public roads, trails, towns, parks, or bridges instead of from private viewing locations). The four viewpoints selected for analysis, as indicated in Figures 4.A-3 through 4.A-6, were selected because they meet this definition, are frequented by a City of Corona Skyline Heights Project
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January 2017 2. RESPONSES TO COMMENTS
large number of people, and are relatively close to the project site and thus provide a worst-case or near worst-cast analysis. While it is acknowledged that the CNF is bisected by public trails which are publically accessible, the project site is visible from only a small number of these trails, these trails are not accessed by large numbers of people (at least compared to the number of people that frequent the four vantage points selected for analysis), and are not all close to the project site. Furthermore, because most of the trails within the CNF from which the site may be visible are located to the west with generally higher elevations than the project site, easterly views from these vantage points include not only the small foreground area that includes the project site, but also the larger background area that includes the valley with the San Bernardino and San Jacinto Mountains in the background. Thus, the project site represents a relatively small portion of the total field of view from these vantage points, so that the project would have less impact on views and visual character from these vantage points than from the four vantage points selected for analysis.

Finally, as discussed in Response to Comment 1-9, the LMP’s Scenic Integrity Objectives Map doesn’t even assign a Scenic Integrity Objective (e.g., moderate, high, very high) to the project site and greater annexation area which suggests that the project site is located within one of the less visibly-sensitive portions of the Elsinore Place area. For all these reasons, the vantage points included in the analysis are adequate, and no additional vantage points from the CNF are required.

Response to Comment 1-10.

Support for Reduced Density Alternative, and Opposition to General Plan Amendment The NFS’s support for the Reduced Density Alternative, its opposition to the proposed General Plan Amendment from Rural Residential to Low Density Residential, and its willingness to work together with the City of Corona to address the impacts of the project on the CNF, is noted and will be provided to the decision makers for their consideration. However, as this comment does not raise a substantive issue on the content of the Draft EIR, no further response is warranted.

Wildland Urban Interface
With respect to the comment that it is far more appropriate to maintain a lower density of residential units in the Wildland Urban Interface, we could find no evidence that the project site is located in the Wildland Urban Interface. According to p.6 of the 2005 CNF LMP, most Wildland/Urban Interface Zones are anticipated to be located within the Developed Area Interface (e.g., DAI), with such areas intended to have a broad range of higher intensity uses but be managed to limit development to a slow increase of carefully designed facilities to help direct use into the most suitable areas. However, according to the LMP’s Land-Use Zones Map, the project site is located on Non-Forest System Land rather than within the DAI or any other LMP-designated Land-Use Zone. As discussed in Response to Comment 1-3, the project site is located on private land within Riverside County’s land use jurisdiction and the City of Corona’s Sphere of Influence (SOI), and is designated by the County and City for urban development.

With regard to the request for adherence to all provisions that maintain development solely on private lands, and neither provide nor imply a reliance on NFS lands for infrastructure or vegetation management, please see Response to Comment 1-5.

Impacts on the CNF
With regard to the request that the impacts of the project on the CNF be given more intensive analysis, City of Corona Skyline Heights Project
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2. RESPONSES TO COMMENTS January 2017
please see Response to Comments 1-3 and 1-6. As indicated therein: (1) the project would not substantially accelerate certain ongoing challenges that the LMP directs the Forest Service to remedy related to population density; (2) the project would retain access to the CNF; and (3) an analysis has been added to the Draft EIR in Chapter 3, Corrections and Additions to the Draft EIR and RDEIR, in this Final EIR, which evaluates project consistency with the 2005 CNF LMP.

City of Corona Skyline Heights Project
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1 LETTER 2

2. RESPONSES TO COMMENTS January 2017
Comment Letter 2
State of California
Governor’s Office of Planning and Research
Scott Morgan, Director
State Clearinghouse and Plan. Unit
1400 Tenth Street
P.O. Box 3044
Sacramento, CA 95812-3044
Response to Letter 2
Response to Comment 2-1. The State Clearinghouse identifies the CEQA-required 45-day review period for the Draft EIR, acknowledges compliance with agency review requirements, identifies the state agency that reviewed the Draft EIR, and attaches the comments from that State agencies. As this comment does not raise a substantive issue on the content of the Draft EIR, no further response is warranted.

One comment letter from State agencies was attached to the State Clearinghouse letter, a letter dated January 19, 2016 from the California Department of Fish and Wildlife (DFW). The DFW letter is included as Comment Letter 3 in this Final EIR. Written responses to the comments made in the DFW letter are included as Responses to Comments 3-1 through 3-8 in this Final EIR.

City of Corona Skyline Heights Project
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State of California - Natural Resources Agency

DEPARTMENT OF FISH AND WILDLIFE
Inland Deserts Region
3602 Inland Empire Blvd., Suite C-220
Ontario, CA 91764
(909) 484-0459
www.wildlife.ca.gov
January 19, 2016
Jason Moquin
Senior Planner
City of Corona
400 S. Vicentia Avenue
Corona, CA 92882
Subject: Draft Environmental Impact Report
Skyline Heights Development Project
State Clearinghouse No. 2014021003
Dear Mr. Moquin:

EDMUND G. BROWN, Jr., Governor
CHARLTON H. BONHAM, Director
The Department of Fish and Wildlife (Department) appreciates the opportunity to comment on the Draft Environmental Impact Report (DEIR) for the Skyline Heights Development Project (project) [State Clearinghouse No. 2014021003]. The Department is responding to the DEIR as a Trustee Agency for fish and wildlife resources (California Fish and Game Code Sections 711 .7 and 1802, and the California Environmental Quality Act [CEQA] Guidelines Section 15386), and as a Responsible Agency regarding any discretionary actions (CEQA Guidelines Section 15381 ), such as the issuance of a Lake or Streambed Alteration Agreement (California Fish and Game Code Sections 1600 et seq.) and/or a California Endangered Species Act (CESA) Permit for Incidental Take of Endangered, Threatened, and/or Candidate species (California Fish and Game Code Sections 2080 and 2080.1 ).

The proposed project is located within the City of Corona (City) Sphere of Influence in unincorporated Riverside County. Specifically, the site is located west of the City's western boundary, south of Avenida Del Vista, north of Skyline Drive and latitude 33°50'28.45", and west of the Cleveland National Forest and longitude -11 r37'02.25".

Richland Developers, the project Applicant, is proposing the development of approximately 292 single-family residences on approximately 270.9 acres. To facilitate the development, the Applicant proposes the annexation of the project site and surrounding parcels totaling approximately 394.8 acres into the City of Corona. Of the approximately 270.9 acre project site, approximately 21.38 acres would be reserved as right-of-way for construction of the City's Foothill Parkway Westerly Extension between Green River Road and Trudy Way.

Conserving Ca{ijornia's WiUCife Since 1870
LETTER 3
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Of the proposed 292 single-family residences, 45 would be developed north of Mabey Canyon and 247 would be developed to the south. The development would occur in three phases. Phase I would consist of 157 homes to be constructed in the central and south sectors of the site, to the south of Mabey Canyon and along the future Trudy Way alignment. Phase II would consist of 90 homes to be constructed in the center of the site, south of Mabey Canyon and to the west of the future Trudy Way alignment.

Phase Ill would consist of 45 homes to be constructed to the north of Mabey Canyon.

Comments and Recommendations
Following review of the DEIR, the Department offers the comments and recommendations presented below to assist the City of Corona (City; the CEQA lead agency) in adequately identifying and/or mitigating the project's significant, or potentially significant, impacts on biological resources:

Focused Botanical Surveys: Focused botanical surveys were conducted from March through July, 2013. The Department is concerned that these surveys may have been inadequate to form a complete inventory of the plant species present on the site for the following reasons:
a) The surveys are over two years old. It is possible that some species that were not observed during the 2013 surveys may have since spread to the project site; b) At least one of the sensitive species judged to have a moderate to high potential to inhabit the site -white rabbit tobacco - has a blooming period outside of the period during which focused surveys took place and may have been overlooked or misidentified; and
c) Conditions have changed since the surveys occurred. The surveys took place during an unusually dry year. Due to the ongoing drought, some sensitive plant species potentially present on the site may have failed to bloom. Other species may have been present in the seed bank or in bulb form. Annual and short-lived perennial plant species and plants with persistent long-lived seed banks may not germinate every year. In addition, the phenological development of some plants may be altered because of the drought. Because of these conditions, the failure to locate a plant during the floristic surveys of one field season does not constitute evidence that the plant is absent from the surveyed location. With the expected El Nino event in 2016, it is reasonable to expect changes in the observable species assemblage.

In order to provide a more complete description of the baseline conditions of the site, the Department recommends that focused surveys following the Department's 2009 Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Communities be conducted during the appropriate times of year, and that the results be included in the final EIR. If additional special-status plant populations are observed, the final EIR should include appropriate avoidance, minimization, and/or mitigation measures to address additional impacts. 1 (cont.)
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Impacts to Coulter's Matilija Poppy and Intermediate Mariposa Lily: The Department encourages the City to avoid and preserve populations of Coulter's matilija poppy and intermediate mariposa lily to the greatest extent feasible. If any populations exist in or near natural open space, the Department recommends that they be connected to existing conserved lands via a corridor of undisturbed land, and protected by placement of a conservation easement over the population and corridor.

Mountain Lion Safety: The list of species observed in the DEIR's Biological Resources Assessment (Appendix D) includes mountain lion (Puma concolor). Based on this, the project's construction may encroach into at least one lion's current home range. The Department is concerned about potential safety issues (both for future residents and for mountain lions) that may arise from human-lion conflicts. In a study investigating the causes of death in 36 southern California mountain lions, over half were killed by human-lion interactions, including 10 vehicle strikes, 6 killed legally with depredation permits, 4 killed illegally, and 1 killed in a public safety incident (Vickers 2015).

In order to reduce the likelihood of human-lion conflicts, the Department recommends that the City revise the DEIR to require implementation of a Homeowner Education Program containing guidelines for safe and responsible living in mountain lion country.

Guidelines should include recommendations for safe driving practices on roads that mountain lions may cross; warnings against letting pets outside unsupervised or leaving dogs in back yards over night, as unsupervised pets may attract mountain lions; recommendation to keep pet food inside and/or inaccessible to wildlife; and instructions on how to stay safe if a mountain lion is spotted. If a Homeowners' Association is planned for the development, we recommend that these guidelines be included in the Association's codes, covenants, and restrictions.

The Department also recommends that signage warning of potential mountain lion presence be placed throughout the development, particularly in areas adjacent to open space.

Impacts to Species Not Adequately Conserved under the MSHCP: The DEIR's Biological Resources Assessment lists several special-status species that occur, or have the potential to occur, on the project site, and are not covered by the Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP). Section 15380 of the CEQA Guidelines indicates that State Species of Special Concern, plant species ranked as rare and endangered by the California Native Plant Society (CNPS), and other sensitive and special status species should be included in an analysis of project impacts if they can be shown to meet the criteria of sensitivity outlined therein.

Sections 15063 and 15065 of the CEQA Guidelines, which address how an impact is identified as significant, are particularly relevant to sensitive species. Project-level impacts to listed (rare, threatened, or endangered) species are generally considered significant thus requiring lead agencies to prepare an Environmental Impact Report to fully analyze and evaluate the impacts. In assigning "impact significance" to populations of non-listed species, analysts usually consider factors such as population3 4 5

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level effects, proportion of the taxon's range affected by a project, regional effects, and impacts to habitat features.

The Department is particularly concerned with the project's potential impacts to chaparral nolina, white rabbit tobacco, California silvery legless lizard, San Bernardino/San Diego ringneck snake, coast patch-nosed snake, pallid bat, and Dulzura pocket mouse. These species have all been designated either 18.2/28.2 ("moderately threatened in California") by the CNPS, or state rank S3, S2, or S1 ("vulnerable to extirpation", "very vulnerable to extirpation", or "especially vulnerable to extirpation") by the State. The Department considers impacts to these species to be potentially significant. Therefore, the Department recommends that the following measures be added to the final EIR to further reduce the potential direct impact to these species:

A qualified biologist shall inspect debris piles, pipes, burrows, vegetation, leaf litter piles, and other potential refugia for sensitive wildlife species prior to initiation of clearing, grubbing, grading, or any other project activity that may injure or kill sensitive wildlife species. If wildlife is discovered, the qualified biologist shall move it out of harm's way or allow it to move safely out of the work area prior to initiation of project activities.

Potential day roosts for pallid bat (e.g., caves, crevices, mines, hollow trees, buildings, etc.) shall be inspected by a qualified bat biologist prior to impacts. If bats are roosting, a bat exclusion plan shall be prepared and submitted to CDFW for review prior to impacts. If a colony is discovered during the maternity season (March - October), the bat biologist shall determine appropriate avoidance measures, including, but not limited to sound walls, buffers, and project phasing/timing, to prevent disturbance to the colony until all young are weaned and capable of foraging independently.

These measures will not completely preclude direct impacts to all of the above mentioned species, and they do not address the project impacts to habitat. The Department recommends that the remaining potential for direct impact and the habitat impacts be mitigated by preserving the natural open space areas in perpetuity via a conservation easement and providing a non-wasting endowment to fund their longterm management by an appropriate conservation entity.

Impacts to Riparian and Riverine Habitat: The DEIR estimates that the project will result in impacts to 6.17 acres of riparian and streambed habitat, and proposes to mitigate the impacts "at no less than a 1:1 ratio" or more, as specified by the Department in a Streambed Alteration Agreement. Please note that, due to potential factors such as net loss of streambed habitat, uncertainty of mitigation success, distance between the impacted area and the mitigation site, differences in habitat type 5 (cont.)
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between the impacted area and the mitigation site, and temporal lag between impacts and establishment of replacement habitat, a 1:1 mitigation ratio is unlikely to be sufficient to reduce the project impacts to a less than significant effect. While the Department is unable to provide a specific ratio without knowing the location and type of mitigation proposed, it is likely that providing sufficient mitigation for the proposed impacts will be extremely costly, and locating in-kind mitigation opportunities may be difficult.

The Department encourages the City and the project Proponent to consider revising the project design to avoid ravines and streambeds to the greatest possible extent, and to build spanning bridges rather than placing roadways directly on top of existing streambed. This could significantly reduce project impacts to streambed and the cost of mitigation, and may also reduce the potential for impacts to sensitive wildlife species and to wildlife movement.

Updated DBESP: A Determination of Biologically Equivalent or Superior Preservation (DBESP) was submitted to the Department and United States Fish and Wildlife Service (collectively, the Wildlife Agencies) in May 2014. The DEIR includes an updated DBESP dated March 2015. At the time of writing this letter, the Department has been unable to confirm receipt of the updated DB ESP. Therefore, in order to finalize the MSHCP consistency review process, the Department requests that the City submit a hard copy of the updated DB ESP to the Wildlife Agencies for review prior to approving . the project.

Further Coordination
The Department appreciates the opportunity to comment on the Skyline Heights Development Project (SCH No. 2014021003), and requests that the City address the Department's comments and concerns prior to circulating the final EIR. If you should have any questions pertaining to these comments, please contact Gabriele Quillman at (909) 980-3818 or [email protected].

Sincerely,
cc: State-Clearinghouse, Sacramento
6 (cont.)
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Literature Cited
Vickers TW, Sanchez JN, Johnson CK, Morrison SA, Botta R, Smith T, et al. (2015) Survival and Mortality of Pumas (Puma concolor) in a Fragmented, Urbanizing Landscape. PLoS ONE 10(7): e0131490.
doi:1 0.1371 /journal.pone.0131490

January 2017 2. RESPONSES TO COMMENTS
Comment Letter 3
State of California
Natural Resources Agency
Department of Fish and Wildlife
Inland Deserts Region
Leslie MacNair, Regional Manager
3602 Inland Empire Boulevard, Suite C-220
Ontario, CA 91764
Response to Letter 3
Response to Comment 3-1. This comment provides a general introduction regarding the comments raised in this letter. Responses to the comments contained in this letter are provided below in Responses to Comments 3-2 through 3-8.

Response to Comment 3-2. In addition to the original 2013 surveys, L&L Environmental, Inc. performed updated focused botanical surveys between April and August 2016. All species observed during the surveys were documented and the site was assessed for appropriate botanical species during the specific flowering periods when the species may reasonably be observed and properly identified at the site.

White rabbit tobacco (Pseudognaphalium leucocephalum), which is also known as white cudweed, is included in the CNPS Inventory of Rare and Endangered Plants as a Rank 2B.2 (rare, threatened, or endangered in CA).

Our analysis indicated this species had a moderate probability of occurrence within suitable habitat. This plant has a blooming period between August and November during conditions suitable to the species.

Focused plant surveys were conducted in August 2016, which is within this species’ blooming period.

Additionally, L&L Environmental, Inc. identified a reference site near the project site, which confirmed this species was in bloom at the offsite location at the time the August 2016 surveys were conducted on the project site. White rabbit tobacco was not observed within the project site during the August 2016 focused surveys, at which time it should have been detected had it been present because it was documented nearby as in bloom, or during any of the other previously conducted surveys. It can be confidently concluded that this species does not current occur on the project site.

Updated focused botanical surveys were conducted between April and August 2016. Although rainfall varied throughout southern California, records for the Corona Airport and the nearby Corona weather station KCACORON19 documented rainfall from September 1, 2015 through August 23, 2016 as 7.72 and 10 inches, respectively. Rainfall during the 2015-2016 season continued to be lower than the average of 12 inches, but this total is significantly higher than the 2012-2013 survey season, which was recorded as 4.9 and 5.92, respectively. Field biologists reported a good blooming season on the project site and documented 145 additional botanical species during the 2016 focused surveys, thereby reducing the probability that species were overlooked during surveys.

Updated botanical surveys were completed between April and August 2016, which were conducted pursuant to the CDFW 2009 protocol. A list of all species observed during the 2016 focused botanical surveys and revised habitat mapping is provided in the “Updated Biological Resources Assessment for TTM 36544; City of Corona Skyline Heights Project
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2. RESPONSES TO COMMENTS January 2017
Skyline Heights Project, City of Corona, Riverside County, California” (Appendix A of the RDEIR). The comprehensive 2016 surveys did confirm the presence of additoinal special-status plant species populations, for which appropriate mitigation has been recommended. Impacts to all special status plant species were also evaluated and avoidance, minimization and mitigation measures were included in the Updated Biological Resources Assessment.

Response to Comment 3-3. The project design will avoid some populations of Coulter’s matilija poppy (Romneya coulteri) and intermediate mariposa lily. Revised mitigation measures below, including Mitigation Measures BIO-MM2, BIO-MM3, and BIO-MM4 contained in the RDEIR (and subsequently modified per CDFW input), as well as Mitigation Measure BIO-MM5 contained in the RDEIR, will reduce impacts to Coulter’s matilija poppy, chaparral nolina and intermediate mariposa lily.

Mitigation Measure BIO-MM2. Mitigation shall be provided for impacts to Coulter’s matilija poppy, intermediate mariposa lily, and chaparral nolina.
• Impacts shall be minimized and avoided to the extent feasible. Coulter’s matilija poppy and intermediate mariposa lily plants within the development footprint shall be salvaged for use in the project area, avoidance area, or reuse in local restoration projects. In addition, a qualified botanist shall collect seeds from plants within the grading impact area during the spring or summer before grading commencement.
• Impacts to chaparral nolina shall be mitigated through translocation and seed collection with propagation to an on-site or off‐site preserved property acceptable to the City. The property shall be composed of habitat characteristics suitable to support chaparral nolina, including but not limited to: appropriate soils, elevation, and supporting chaparral or coastal sage scrub (or a combination thereof) habitat. The property shall be conserved via recordation of a conservation easement or deed restriction in favor of a California Department of Fish and Wildlife (CDFW)-due diligence approved local conservation entity to protect chaparral nolina on the property in perpetuity. Alternatively, the land may be transferred in fee title to a CDFW-approved local conservation entity. A management fund shall be established by the Applicant and will consist of an interest-bearing account with the amount of capital necessary to generate sufficient interest and/or income to fund all monitoring, management, and protection of the conservation area(s), including but not limited to, reasonable administrative overhead, biological monitoring, invasive species and trash removal, signage replacement and repair, law enforcement measures, long-term management reporting (as described below), and other actions designed to maintain and improve the habitat of the conserved land(s), in perpetuity. A Property Analysis Record, or substantially equivalent analysis, shall be conducted by the Applicant and approved by the City to determine the management needs and costs described above, which then will be used to calculate the capital needed for the management of the fund. This management fund shall be held and managed by a CDFW-approved local conservation entity. To protect the mitigation area(s), the Applicant shall place appropriate signage around the perimeter of each site. Except for uses appropriate to a habitat conservation area, the public shall not have access to the mitigation area(s), and no activities shall be permitted within the site, except maintenance of habitat, including the removal of nonnative plant species, trash, and debris, and the installation of native plant materials.

Prior to any ground disturbance, the Applicant shall prepare a Chaparral Nolina Planting Plan (Plan) for chaparral nolina. The Plan shall require a replacement ratio of 1:1 by area, and ensure a City of Corona Skyline Heights Project
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January 2017 2. RESPONSES TO COMMENTS
minimum 90 percent survivorship at the end of a five-year monitoring period, which shall be verified by the monitoring biologist (minimum qualifications of the monitoring biologist are specified below). At a minimum, the five-year plan shall include the following information:

1. a description of the existing conditions of the receiver site(s) characterizing the suitability of the site(s) for chaparral nolina, and documenting the acreage of the site,

2. a description of how the site will be preserved in perpetuity, e.g., conservation easement, deed restriction, etc., and the name of the CDFW-approved due diligence entity that will hold the easement/deed restriction, etc.,

3. qualifications of the monitoring biologist. At a minimum the monitoring biologist will possess a minimum of five-year's experience conducting habitat restoration projects in coastal sage scrub and/or chaparral habitat in Riverside County, California,

4. receiver site preparation for transplanting,

5. goals for success,

6. schedule,

7. propagation techniques,

8. transplant and seedling installation methods,

9. plant spacing,

10. performance criteria for success, including provision for control of non-native and invasive species,

11. monitoring and reporting procedures for each of the five years of the monitoring period,

12. adaptive management strategies, including a contingency plan should the site fail to meet the specified success criteria, and maintenance requirements that will be reviewed and approved by the City. The Plan shall also ensure a mixture of both male and female plants.

Mitigation Measure BIO-MM3. Prior to issuance of a grading permit, the project Applicant shall preserve a minimum of 10 acres (a 1:1 ratio) of natural habitat, biologically equivalent or superior to the PQP land the project site surrounds, adjacent to USFS land. The compensation parcel shall either be:

1. Deeded in fee title to the USFS or RCA to ensure appropriate protection and permanent habitat management in perpetuity, or

2. Conserved via recordation of a conservation easement or deed restriction in favor of a CDFW-due diligence approved local conservation entity.

Mitigation Measure BIO-MM4. Those areas of the project site not impacted by the project footprint, including Riparian/Riverine and excluding the minimum 10-acre preservation area identified in BIOMM3, shall be conserved in perpetuity via the recordation of a conservation easement or deed restriction in favor of a CDFW-approved local conservation entity; or transferred in fee title to a CDFW-approved local conservation entity. The avoided Riparian/Riverine areas shall be conserved prior to issuance of a grading permit. The CDFW-approved local conservation entity shall manage the conservation areas to protect the long-term conservation, functions and values in-perpetuity.

With the implementation of BIO-MM3 and BIO-MM4, a portion of these species’ on-site populations will be avoided and preserved in perpetuity. The proposed project design will avoid 139 of the 455 (31%) observed City of Corona Skyline Heights Project
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2. RESPONSES TO COMMENTS January 2017
intermediate mariposa lily, 386 of the 691 (56%) Coulter’s matilija poppy, and ±2,667 of the estimated 5,343 (50%) chaparral nolina.

Mitigation Measure BIO-MM5. The project Applicant shall add more common cultivar forms of Coulter’s matilija poppy to the list of plants to be avoided in site landscaping, including White Cloud matilija poppy. Additional non-native plants to be avoided in any onsite mitigation or landscaping include coyote brush (Baccharis pilularis) and fourwing saltbush (Atriplex canescens). To ensure these non-native plants are not used in landscaping within the project site, the project Applicant shall include a list of plant species to avoid within the CC&Rs for the development. The project applicant shall also develop and distribute a suitable homeowner education package to residents / new owners covering the species to avoid.

In addition, all the avoided populations, with the exception of the east-central portion of the site, are connected to land within the Cleveland National Forest. All avoided populations are contiguous with large tracts of mostly undisturbed native habitats.

Avoided populations within the east-central portion of the project site will be conserved within an approximately 22-acre area, which is adjacent to the 10-acre NAP USFS parcel. This area is contiguous with another large area of currently undeveloped land to the south. Creation of a corridor to USFS land to the west is infeasible as it would require a corridor of a minimum of 1,800 feet long through the center of the project area. The corridor would need both drainage features and hillsides to provide potential habitat for the avoided species. The requirement of a drainage feature would necessitate the corridor to be along drainage Feature 3.

Avoidance of Feature 3 is infeasible since it would require the complete removal of the secondary access point. Without contiguous access providing an efficient looped water system within the project site, risk in fire situations would be increased. In addition, constructing the project without impacting the drainage would result in effectively eliminating the lower two-thirds of the project site, which would not generate enough revenue to pay for the needed infrastructure and other improvements.

Creation of a bridge over Feature 3 results in similar difficulties as those discussed in the ‘Reduced Lot Count Alternative’ in the Updated Biological Assessment (Appendix A of the RDEIR), which discusses creation of a bridge over Feature 1. The expense of constructing a bridge in combination with the resulting reduced lot count would create a financially infeasible project. Without the filling of the un-named stream of Feature 3, the project design will need to export 3 to 4 million cubic yards of material or radically adjust the development footprint to reduce cut. Since this site requires hillside grading, export of that much material would have a significant impact on existing residents and roads, would be extremely expensive, and redesigning the site and streets to reduce cut while maintaining a comparable lot count is not feasible.

Inability to fill the un-named stream reduces the developable footprint and would reduce lot count significantly from the 292 lots shown on TTM 36544. This alternative would be financially infeasible due to increased costs and reduced lot yield. In addition, alternative land plans require that additional water, sewer, and roadway infrastructure facilities be constructed in a less efficient manner and, therefore, would substantially increase the cost of development.

Response to Comment 3-4. The Updated Biological Assessment and RDEIR included the following City of Corona Skyline Heights Project
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January 2017 2. RESPONSES TO COMMENTS
mitigation measure:

Mitigation Measure BIO-MM5. A mountain lion (Puma concolor) program shall be developed by the project Applicant for City review and approval in an effort to reduce likelihood of human-lion conflicts.

The program shall include the following components:

1. A suitable homeowner education package for distribution to residents / new owners;

2. A suitable road sign program warning of the presence of mountain lions and the need for reduced speeds and increased caution;

3. A suitable CC&R provision limiting unsupervised outdoor pets and pet feeding practices that may encourage mountain lions to enter residential yards in search of food; and

4. A suitable mountain lion safety plan.

The City will review the mountain lion program and will include the requirement for mountain lion signage throughout the development and at adjacent to open spaces.

Response to Comment 3-5. The special-status species identified in this comment as having a moderate or high potential of occurring on the project site, but are not identified as ‘Covered Species’ under the MSHCP, were evaluated in more detail in the Updated Biological Assessment (Appendix A of the RDEIR) and RDEIR, and are briefly summarized below:

1. Chaparral nolina: This species was recorded on the project site during the 2016 focused plant surveys. Mitigation Measure BIO-MM2 included in the Updated Biological Assessment outlines mitigation for unavoidable impacts to chaparral nolina through translocation and seed collection with propagation to an on-site or off-site preserved property acceptable to the City. In addition, Mitigation Measure BIO-MM3 preserves 10 acres supporting chaparral nolina.

2. White rabbit tobacco: See Response to Comment 3-2, above. It can be confidently concluded that this species does not current occur on the project site.

3. California silvery legless lizard (Anniella pulchra pulchra), pallid bat (Antrozous pallidus), and Dulzura pocket mouse (Chaetodipus californicus femoralis): Although these three species are ranked on CNDDB as S3 species and are therefore not considered “imperiled” or “endangered”, the above measure recommended by the Department was included as Mitigation Measure BIO-MM14 in the Update Biological Assessment. The pre-construction surveys prior to vegetation clearing and grubbing will reduce potential impacts to these species, if present.

4. San Bernardino ringneck snake (Diadophis punctatus ssp. modestus and ssp. similis): This species is a CNDDB S2? species, which is considered more than vulnerable but not imperiled with certainty. This species, if present, would be expected to occur in the Riparian/Riverine areas of the project site.

Although approximately 55% of Riparian/Riverine areas would be impacted by the proposed project, City of Corona Skyline Heights Project
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2. RESPONSES TO COMMENTS January 2017
impacts to this species are not expected to appreciably affect overall population size or range of this species. Mitigation Measure BIO-MM14 would require a pre-construction survey to be conducted prior to clearing and grubbing of vegetation.

5. Coast patch-nosed snake (Salvadora hexalepis virgultea): This species is a CNDDB S2S3 species, which is considered between vulnerable and imperiled. This species, if present, would be expected to occupy the scrub and chaparral habitats on the project site. Although the project proposes impacts to suitable scrub and chaparral habitats, large tracts of suitable habitat will remain in the project vicinity and therefore impacts to this species are not expected to appreciably affect the overall population or range of this species. Mitigation Measure BIO-MM14 would require a preconstruction survey to be conducted prior to clearing and grubbing of vegetation.

The Updated Biological Assessment (Appendix A of the RDEIR) and RDEIR include Mitigation Measures BIOMM3 and BIO-MM4 (see above) to ensure avoided portions of the project site are not developed in the future.

Response to Comment 3-6. State and federal regulatory jurisdictional areas were reevaluated in 2016 and the results are detailed in the report, “An Updated Jurisdictional Delineation for TTM 36544, AKA Skyline Heights Project, City of Corona, Riverside County, California” (Appendix A of the RDEIR) and summarized in the “Updated Biological Assessment” (Appendix A of the RDEIR). The Updated Biological Assessment report and RDEIR include the following mitigation measure to reduce impacts to a less than significant level:

Mitigation Measure BIO-MM10. Prior to the issuance of a grading permit, to mitigate for the loss of

10.07 acres of streambed and wetlands due to project construction, project Applicant shall enter into an agreement with the California Department of Fish and Wildlife (via issuance and implementation of a Streambed Alteration Agreement, Section 1600) to replace affected streambed at not less than a 2:1 basis, as specified by the California Department of Fish and Wildlife, through a combination of offsite acquisition and preservation, participation in an approved mitigation bank, and/or on or offsite creation, enhancement, or reestablishment of the streambed. The exact ratio shall be based on a functions and values assessment.

The project design considered minimizing impacts to drainages, and Alternative designs are discussed in Section 8 of the Updated Biological Assessment. Impacts to both drainage Features 1 and 3 are required to create a secondary access point. Complete avoidance of these drainage features would remove the efficient looped water system within the Project and risk in fire situations would be increased. To avoid impacts to the features and still maintain two access points, development would be limited to the northern third of the project site. If this alternative is advanced, the project would not generate enough revenue to pay for the needed infrastructure and other improvements and it is likely that the southern two thirds of the project site would be subdivided and sold to produce revenue to offset development costs. See Response to Comment 3- 3 above for additional discussion.

Response to Comment 3-7. An initial DBESP was prepared for the project and is being revised based on previous comments received from the CDFW and USFWS and from the updated focused botanical surveys between April and August 2016. The DBESP is not required to be completed at the same time as the EIR, but City of Corona Skyline Heights Project
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January 2017 2. RESPONSES TO COMMENTS
is required prior to the issuance of any regulatory permits issued by CDFW and USFWS. . A revised DBESP has been prepared and this will be submitted by the City of Corona to CDFW and USFWS for processing.

Response to Comment 3-8. This comment provides a general conclusion regarding the comments raised in this letter. Responses to the comments contained in this letter are provided above in Responses to Comments 3-1 through 3-7.

City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 2-47

COUNTY OF RIVERSIDE
Juan C. Perez, P.E., T.E.

Director of Transportation and
Land Management
January 19, 2016
Jason Moquin
City of Corona

TRANSPORTATION AND

LAND MANAGEMENT AGENCY
Transportation Department
Community Development Department
400 South Vicentia Avenue
Corona, CA 92882-2187
RE: Notice of Availability of a Draft Environmental Impact Report for the Skyline Heights Project
Dear Mr. Moquin:

Patricia Romo, P.E.

Assistant Director of Transportation
Thank you for the opportunity to comment on the Notice of Availability (NOA) of a Draft Environmental Impact Report (DEIR) for the City of Corona's Skyline Heights Project. The proposed project is located south of the planned extension of Foothill Parkway, generally west of Trudy Way, and generally east of Paseo Grande. The project consists of a general plan amendment that will change the existing land use from rural residential designation to low density residential and open space designations. A tentative tract map is also proposed that will subdivide the area into 292 single family residential lots. The Riverside County Transportation Department (County) provides the following comment on the DEIR.

The DEIR and project traffic study indicate that the planned extension of Foothill Parkway from Trudy Way to Paseo Grande is expected to be completed by 2017, however, not a required improvement of the project. The project is located within a high fire area, therefore secondary access should be required for all lots.

In reviewing the tentative Tract Map 36544, lots 248 through 292 only have one access for ingress and egress via Foothill Parkway. The County recommends that City place a condition on the tentative tract map requiring Foothill Parkway to be extended to Paseo Grande before occupancy permits are issued for lots 248 through 292.
4080 Lemon Street, 8'h Floor · Riverside, CA 92501 · (951) 955-6740 P.O. Box I 090 · Riverside, CA 92502-1090 · FAX (951) 955-3198 LETTER 4
1

Jason Moquin
January 19, 2016

Thank you again for the opportunity to review the NOA. Please contact me at (951) 955-2016 with questions or comments.

Sincerely,
Russell Williams
Development Review Manager
RUW:KKT:rg
cc: Juan C. Perez, Director of Transportation and Land Management Patricia Ramo, Assistant Director of Transportation
4080 Lemon Street, 8'" Floor · Riverside, CA 9250 I · (951) 955-6740 P.O. Box I 090 · Riverside, CA 92502-I 090 · FAX (95I) 955-3I98 Page 2700 of 3613

2. RESPONSES TO COMMENTS January 2017
Comment Letter 4
County of Riverside
Transportation and Land Management Department
Russell Williams, Development Review Manager
4080 Lemon Street, 8th floor
Riverside, CA 92501
Response to Letter 4
Response to Comment 4-1. This first paragraph of this comment provides a general introduction regarding the comments raised in this letter. With regard to the second paragraph, specifically the comment that secondary access should be provided for all lots and the recommendation that the City place a condition on the tentative tract map requiring Foothill Parkway to be extended to Paseo Grande before occupancy permits are issued for project lots 248 and 292, this comment and recommendation are noted. As indicated on page

4.M-34 of the Draft EIR, it is anticipated that the Foothill Parkway Westerly Extension (a separate project already under construction which and anticipated for completion in late 2016 or in early 2017) would be completed prior to the initiation of project construction. It is worth mentioning that since the preparation of the Draft EIR, the construction of Foothill Parkway has been completed and the roadway is currently operational, ahead of the completion date anticipated in the Draft EIR. Furthermore, as indicated on page

4.L-21, as required by Mitigation Measure PS-1, the project shall comply with City of Corona Municipal Code and CFD requirements, including those related to emergency access, such that adequate emergency access would be provided. Finally, as indicated on page 4.M-35 of the Draft EIR, the project site plan would be subject to review and approval by the City’s Department of Public Works and Fire Department to ensure adequate emergency access such that the emergency access impact of the project would be less than significant.

City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 2-50

Date: December 9, 2015
City of Corona
Attention: Jason Moquin
Community Development Department
400 South Vicentia Avenue
Corona, CA 92882
RE: Skyline Heights Project Environmental Impact Report (GPA13-003, CZ13-002, Annexation 117; TTM36544)
To Mr. Jason Moquin,
Thank you for allowing the Riverside County Regional Park and Open-Space District to comment on the proposed Skyline Heights Project Environmental Impact Report (EIR). Staff has reviewed the document and has the following comment:
 The proposed project location is within the Cleveland National Forest. The Cleveland National Forest has several established hiking paths and trails located in or around the project area. The project should identify, analyze, and preserve these trails and its connections to the adjacent developed communities.

The Riverside County Regional Park and Open-Space District is available for any discussion or clarifications.

If you have any questions, please do not hesitate to contact me at (951) 955-6998 or email me at [email protected].

Sincerely,
Paul Rull
Parks Planner

LETTER 5
1

2. RESPONSES TO COMMENTS January 2017
Comment Letter 5
Riverside County
Regional Park and Open-Space District
Paul Rull, Parks Planner
4600 Crestmore Road
Jurupa Valley, CA 92509
Response to Letter 5
Response to Comment 5-1. The Draft EIR addressed project impacts on trails within the CNF in Section 4.I, Land Use and Planning. As indicated on pages 4.I-9 and 4.I-15, the four U.S. Fish and Wildlife Service parcels within the annexation area, and the open space parcel at the south edge of the annexation area, would be maintained as permanent open space which would allow continued access to Skyline Drive which serves as trail access to and within the CNF. As indicated on page 4.I-12 and in Figures 4.I-1 and 4.I-2, the project would not alter Skyline Trail, the only designated public trail within or adjacent to the annexation area, and would not alter the access point to that trail along Foothill Parkway. Several undesignated trails traverse the project site and would be impacted by the project; however, these trails occur on private property and are not dedicated for public access by any legal instrument such as a public access easement. As such, the Draft EIR identified and addressed project impacts to designated public trails within the CNF, and the project would result in a less than significant impact to these trails.

City of Corona Skyline Heights Project
ESA PCR/SCH No. 2014021003 2-52

1 David Crook
From: Joanne Coletta <[email protected]>
Sent: Monday, May 02, 2016 6:25 PM
To: David Crook; Mike Byer ([email protected]) Subject: FW: Comments on DEIR for Skyline Heights Project by Riverside-San Bernardi no CNPS
Attachments: 2016May1_SkylineHeightsDEIRcommentsFMR2.pdf ‐‐‐‐‐Original Message‐‐‐‐‐
From: [email protected] [mailto:[email protected]] Sent: Monday, May 02, 2016 5:08 PM
To: Terri Manuel
Cc: [email protected]; [email protected]; [email protected]; [email protected]; karin_cleary‐ [email protected]; [email protected]; [email protected]; [email protected] Subject: Comments on DEIR for Skyline Heights Project by Riverside‐San Bernardi no CNPS Dear Terri,
The Riverside‐San Bernardino Chapter of the California Native Plant Society hereby submits the attached comment letter on the Skyline Heights DEIR.  Thank you for the opportunity to provide comments.  Please send further notices to our chapter at the address at the top of the letter.

Please let us know that this email and document were received today.

Sincerely,
Kate Kramer
Fred Roberts
____________________________________________________________ Newsmax
What the Bible Says About Money (Fascinating)
http://thirdpartyoffers.juno.com/TGL3141/5727ec338261e6c32249dst04vuc LETTER 6
1 Page 2704 of 3613
1 Riverside-San Bernardino Chapter
www.riverside-sanbernardino.cnps.org
4477 Picacho Drive, Riverside, CA 92507
DATE: May 1, 2016
TO: Terri Manuel, Planning Manager ([email protected]) RE: DRAFT ENVIRONMENTAL IMPACT REPORT: SKYLINE HEIGHTS PROJECT The California Native Plant Society (CNPS) is a non-profit volunteer organization dedicated to the conservation and preservation of California’s native flora (www.CNPS.org). The Riverside/San Bernardino Counties Chapter of CNPS works to increase the public awareness of the significance of native plants and to preserve the native vegetation of Riverside and southwestern San Bernardino Counties. The following comments are submitted for the DRAFT ENVIRONMENTAL IMPACT REPORT for the SKYLINE HEIGHTS PROJECT alluded to in Public Notice for ANNEX-117-GP13-003-CZ13-002-TTM-36544-EIR.

In our review we have focused on Appendix D, the Biological Resources Assessment and other changes in the land form that would have severe consequences to sensitive native plant populations and sensitive plant communities. Our chapter has botanists and ecologists with many years of education and experience in examining rare plants, vegetation communities, and the flora of the Santa Ana Mountains. One of the authors of this letter has published checklists of the vascular plants for western Riverside and Orange counties (Roberts et al 2004, Roberts 2008) and is a co-author of the highly regarded Wildflowers of Orange County and the Santa Ana Mountains (Allen & Roberts 2013).

In general, we have found the surveys for sensitive plants and communities, the analysis of the projects impacts to them, and the findings to be inadequate. For example, it is possible that the consultants did not know the difference between the common Whipple’s yucca (Hesperoyucca whipplei) and the rare Chaparral nolina (Nolina cismontana), California Rare Plant Rank (CRPR) 1B.2) and therefore missed many hundreds of plants over at least a 10- acre portion of the project site. In addition, the document fails to recognize the presence of extensive Riversidean Alluvial Fan Scrub vegetation, also known as the Lepidospartum squamatum Alliance (rank S3G3). The EIR does not sufficiently map or estimate the presence of Quecus agrifolia or estimate the damage to its habitat contained within the 2 3 4 Page 2705 of 3613
2 Quercus agrifolia woodland alliance and Quercus berberidifolia or Quercus berberidifoliaAdenostoma fasciluatum shrubland alliances. Furthermore, their surveys for rare plants were inadequate. Some of their work may have been hampered by the clearing (blading?) of two of the major areas of clay substrate within the project site. The clay areas were scraped clean between 2005 and 2006. This can be seen by looking at the sequence of aerial photos available in Google Earth from before 2005 through 2016. These areas are now recovering from the damage.

Rare Vegetation and Plants that Occur on the Project Site:

The botanical surveys were conducted in 2013, overall a dry year throughout California and the second year of what would become one of the states more significant droughts. The document does not appear to take the impact of the drought on the vegetation and flora of of the project site under consideration. It should be plainly stated that due to the dry conditions, the list of species observed is almost certainly incomplete. The descriptions of the vegetation communities on site also appear to be either overly simplified or poor fits to the actual vegetation on site. For example, many important and frequently occurring species like toyon (Heteromeles arbutifolia), holly-leaved red berry (Rhamnus ilicifolia), holly-leaved cherry (Prunus ilicifolia), Ramona lilac (Ceanothus tomentosus), and California scrub oak (Quercus berberidifolia) are not mentioned while much less abundant plants like California coffee berry (Frangula californica) are, giving the reader a different impression of the site than the reality. One of the more significant omissions is nolina scrub, dominated by chaparral nolina. A plant community dominated by a CRPR ranked sensitive species is by default a sensitive community.

Chaparral Nolina, Nolina cismontana, Forest Service sensitive species and CRPR 1B.2 species: Chaparral nolina was included as part of the taxon Nolina parryii prior to 1995 (Hess & Dice 1995). Hess & Dice 1995 noted that the plant is threatened by development.

Its range extends from Ventura to San Diego County with the principal populations found in the northern Santa Ana Mountains. The authors of the Manual of California Vegetation, 2nd edition (MCV2, Sawyer et al. 2009) were not aware of this extensive population of N. cismontana in the Santa Ana Mountains and that it is often a dominant species, often referred to in neighboring Orange County as nolina scrub. Regardless of being identified in the manual or not, it is a true vegetation alliance and the abundance of chaparral nolina within it would make it difficult to accurately place this vegetation within other alliances.

Chaparral nolina appears to be co-dominant in the shrub layer in many areas with Adenostoma fasciculatum, Ceanothus tomentosus and Salvia mellifera, or with Ceanothus crassifolius, Cercocarpus betuloides, Fraxinus dipetala, Quercus berberidifolia, Heteromeles arbutifolia and other chaparral shrubs, depending on the slope aspect inside an approximately 10 acre area (see Appendix with map and photos). The extent of the population needs to be carefully surveyed because most of it is currently slated for grading. 4 (cont.)
5 6 Page 2706 of 3613
3 Chaparral nolina has only recently been found to occur in Riverside County and is overall scarce. It was not included in Roberts et al. (2004) due to a lack of a known population a decade ago and was not considered for the MSHCP. However, the population within the project site is possibly the largest in Riverside County. That in combination with its CRPR 1B.2 ranking makes this a significant conservation concern.

In the appendix to this letter, we include an aerial map of locations and photos to document the extensive population of the Chaparral Nolina within the project site.

With our knowledge of the general area, we find it unlikely that the only sensitive plant within the project site is Coulter’s matillija poppy (Romneya coulteri), as discussed in the document. We already know that chaparral nolina was missed and it is a fairly large and showy sensitive plant. It does not appear on the species list and is considered of “low potential” to occur by the preparers of the document. That alone calls in to question how many more obscure and difficult to locate sensitive species were not seen or addressed. At the very least, members have recently observed Fish’s milkwort (Polygala corunata ssp. fishae), a CRPR 4.3 plant, on the site without conducting extensive surveys. Intermediate mariposa lily (Calochortus weedii var. intermedius), CRPR 1B.2 is known from habitat adjacent to the site on three sides and there is suitable habitat over much of the project area. It almost certainly occurs within the project area. We recommend that additional rare plant surveys be conducted at the appropriate time of year. We also suggest adding a table to the document that allows reviewers to see just which species are being considered and a brief discussion of the habitat requirements and reasoning for potential occurrence estimates.

Riversidean Alluvial Fan Scrub (RAFS) also known as the Lepidospartum squamatum shrubland alliance, S3G3: Alluvial Scrub vegetation types occur on the site within outwash fans, stream terraces, and within the sandy, cobbly, rocky wash soils of the major drainages (primarily drainage 3, page 56 of Appendix D). Alluvial scrub occurs on the well-drained substrates of alluvial fans and riverine/stream deposits and is well adapted to occasional flood and scour events (Buck-Diaz et al. 2011, Hanes et al. 1989). The approximately 6 acres of the main, unnamed drainage 3 that flows toward the basin at Mangular Ave. and W.

Chase Drive supports a rare type of alluvial scrub vegetation known as Riversidean Alluvial Fan Scrub [see Western Riverside County MSHCP and vegetation mapping project (Evens & Klein 2006, Klein & Evens 2006)] and which is classified in the MCV2 within the Lepidospartum squamatum Alliance. The majority of this vegetation is on the project property, but a portion is on adjacent property to the south. On the site, the alliance contains Lepidospartum squamatum (>5% cover) in association with species such as Eriogonum fasciculatum var. foliolosum, Acmispon glaber var. glaber, Hesperoyucca whipplei, Salvia mellifera, Malosma laurina, Romneya coulteri, Artemisia californica, and scattered Platanus racemosa. This vegetation type intergrades Quercus agrifolia oak woodland and a variety of sage scrub and species rich chaparral alliances that occupy the adjacent slopes and upper terraces of the wash. Riversidean Alluvial Fan Scrub is underrepresented within conserved lands in western Riverside County. Additional 6 (cont.)
7 Page 2707 of 3613
4 Riversidean is needed to meet the goals of the plan. The document should provide a discussion for the level of conservation currently attained by the MSHCP and how loss or conservation of the Riversidean Alluvial Fan Scrub within the project area would impact the MSHCP conservation effort.

Alluvial Scrub vegetation in general is severely threatened by residential and other development, and by altered stream flows. There are many practical and conservation reasons to avoid developing over Lepidospartum squamatum scrub. The development would destroy the flows and disturbance regime in the upper drainage and pipe water toward the habitat at the eastern end of the site.

Recent climate change vulnerability assessments undertaken by the US Forest Service in collaboration partners (other agencies, practitioners, and academics), and facilitated by consultants from EcoAdapt, have shown that Alluvial Scrub plant communities are highly vulnerable to climate change, water diversions, and development ( see the January 2016 version of the assessment at:
http://ecoadapt.org/data/documents/SoCal_VASummary_AlluvialScrub_FINAL.pdf, http://ecoadapt.org/data/documents/EcoAdapt_SoCal_AdaptationStrategiesTable_AlluvialS crub.pdf, and
http://ecoadapt.org/data/documents/SoCal_VAASBrief_AlluvialScrub_January2016_smallre s.pdf). For more information about the Southern California Climate Adaptation Project and links to documents on the various stressors that may adversely affect Alluvial Scrub vegetation, see: http://ecoadapt.org/programs/adaptation-consultations/socal.

The vegetation map provided by the consultants and by others were far too generalized to reveal the existence of local alluvial scrub habitats that are dependent on natural fluvial processes for their continued existence. There is no analysis of how interruption of flows and piping of flows within the major unnamed drainage are expected to affect the downstream habitat that supports rare vegetation alliances such as Riversidean Alluvial Fan Scrub/Lepidospartum squamatum scrub and the particular chaparral alliances that occur on alluvial terraces, all of which support stands of the rare Culter’s Matillija Poppy (Romneya coulteri).

Clay Soils and Potential Rare Plant Habitat: The larger clay-soil areas that currently support grasslands with Stipa pulchra, Stipa lepida and associated forbs are not mapped or analyzed sufficiently as having potential to support rare plant species. These are precisely the areas that would likely support some of the rare plants missed in the most recent plant surveys (including the Intermediate mariposa lily) but which were found by other consultants in the past. The draught and slow recovery from the land scraping treatment on the clay soil areas may have resulted in few and harder to detect rare plants. 7 (cont.)
8 Page 2708 of 3613
5 Other Issues:

Mitigating oak removals by planting Quercus agrifolia at a rate of 1:1 in the landscaped areas does not come close to mitigating for the loss of wildlife habitat provided by this tree.

Natural oak populations are suffering from a host of diseases and this sort of destruction and ornamental planting is contrary to encouraging sustainable populations of oaks and their associated species.

The presentation of Project Alternatives is inadequate. The project alternatives presented are not sufficiently detailed. There needs to be a different project alternative that provides a larger buffer between the development and the National Forest and that avoids the Nolina cismontana area, direct and indirect impacts to Riversidean Alluvial Fan Scrub, and the major clay soil areas that are known to support rare plants and native grassland. A streamlined development alternative that avoids these habitats would also likely have more of a buffer between the National Forest lands and decrease the ignition sources from the new development compared to the alternatives provided. A different alternative that preserves drainage 3 and the clay ridge areas (see appendix) would also allow additional access to a recreational trail system up the unnamed drainage and beyond, linking to other important and well used trails.

There are National Forest lands in the zone of influence of this project. There is not sufficient analysis of the effects of the project to National Forest lands and natural resources. For example, it is well known that ignition frequency increases in the wildland urban interface and along roads. This project inserts development far into prime chaparral and riparian habitats. Analyses of the cumulative impacts on the value of the existing habitat and watershed protection on Federal lands are wanting. Furthermore, because the surveys did not recognize the existence of an extensive population of Nolina cismontana over at least 10 acres, at least 0.75 acres of native grassland habitat, and over 5 acres of Lepidospartum squamatum scrub, which indeed do exist, the findings regarding impact to sensitive plants and plant communities are mistaken, unsupported, and will need to be reevaluated.

Fuel Modification: Appendix G-2 Fuel Modification. Sec 1:5, Sec 1:6 figures. The 100 feet shown BEYOND property boundaries of pads to be managed by HOA. This will eliminate even more habitat than shown in the footprint of the grading. The fuel management area should not be considered part of open space. This creates issues. The fuel modification zones should be in the footprint of the development—part of properties.

The natural population of Romneya coulteri needs to be protected from the influx of genes from cultivated selections of the plant. This is a sensitive, rare plant. Cultivars of this plant (e.g. ‘White Could’) should not be used in the fuel modification zone or landscaping. Plants are bee pollinated and the bees travel far. Just use plants from local seed source as recommended for outer zones but elsewhere too. The best plants to be used in fuel mod zone are the species native to this area that have low fuel, green leaves, and low ignition 9 10 11 12 Page 2709 of 3613
6 potential such as Heteromeles arbutifolia, Quercus berberidifolia, Ceanothus tomentosus, Hesperoyucca whipplei, Rhus ovata, Rhamnus illicifolia, Prunus illicifolia, Quercus agrifolia, Platanus racemosa, Fraxinus dipetala, Cercocarpus betuloides. The low fuel, natural species from the adjacent habitat are the best to use in the dry fuel mod zone! These will look best and grow well.

AVOID Baccharis pilularis and Atriplex canescens, which will invade the site and become too dense.

The mitigation proposed for loss of 6.17 acres of streambed. Wetlands are becoming very difficult to find. There needs to be more avoidance of these areas. A 1:1 replacement basis is also not sustainable and a 3:1 basis should be adopted.

Sincerely,
Fred M. Roberts, Jr.

Rare Plant Chair, Riverside/San Bernardino Chapter, CNPS Kate Kramer
Conservation Co-chair, Riverside/San Bernardino Chapter, CNPS 12 (cont.)
13 Page 2710 of 3613
7 Bibliography
Allen, R. L., and F. M. Roberts, Jr. 2013. Wildflowers of Orange County and the Santa Ana Mountains.

Laguna Wilderness Press, Laguna, CA.

Baldwin, B. G., D. H. Goldman, D. J. Keil, R. Patterson, T. J. Rosatti, and D. H. Wilken, editors. 2012.

The Jepson Manual: Vascular Plants of California. 2nd edition. University of California Press, Berkeley, CA.

Buck-Diaz, J., J. M. Evens, and A. M. Montalvo. 2011. Alluvial Scrub Vegetation of Southern California, A Focus on the Santa Ana River Watershed In Orange, Riverside, and San Bernardino Counties, California. Report to USDA Forest Service, Grant Program, National Fire Plan Restoration/Rehabilitation of Burned Areas. Available online:
http://www.cnps.org/cnps/vegetation/pdf/alluvial_scrub-diaz_evans2011.pdf.

Evens, J. M., and A. N. Klein. 2006. A new model for conservation planning: vegetation mapping in western Riverside County. Madroño 34(2):11-18.

Hanes, T., R. Friesen, and K. Keane. 1989. Alluvial scrub vegetation in coastal southern California.

USDA Forest Service General Technical Report PSW-110:187-193.

Hess, W. J. and J. C. Dice. 1995. Nolina cismontana (Nolinaceae), a New Species Name for an Old Taxon. Novon 5(2): 162-164.

Klein, A., and J. Evens. 2006. Vegetation Alliances of Western Riverside County, California. Report prepared for California Department of Fish and Game. California Native Plant Society, Sacramento, CA. Available on line:
http://www.cnps.org/cnps/vegetation/pdf/WRIV_Vegetation_CNPSFinalReport_April2006.pdf.

Roberts, F. M., Jr. 2008. The Vascular Plants of Orange County, California: An Annotated Checklist. F.

M. Roberts Publications, San Luis Rey, CA.

Roberts, F. M., Jr., S. D. White, A. C. Sanders, D. E. Bramlet, and S. Boyd. 2004. The Vascular Plants of Western Riverside County, California: An Annotated Checklist. F. M. Roberts Publications, San Luis Rey, CA.

Sawyer, J. O., T. Keeler-Wolf, and J. M. Evens. 2009. A Manual of California Vegetation. 2nd edition.

California Native Plant Society Press, Sacramento, CA.

8 Appendix: Photos to document locations of rare plants and rare communities. There are also herbarium specimens of the rare plants at UCR Herbarium.

All photos taken on April 20-26, 2016.

The red shape on left is an approximately 10-acre area within which extensive stands of the Chaparral Nolina were found.

The red shape on the right is where there is over 6 acres of Riversidean Alluvial Fan Scrub.

The pink pin is one location of Polygala cornuta var. fishiae.

The yellow pins mark extensive areas of clay soil and where there are Stipa pulchra (at 2) or Stipa lepida (at 1) grasslands.
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9 Nolina cismontana
Photos from project of the 10 acres of habitat from top of Clay ridge 1 and from drainage to north.

Population of Chaparral Nolina along Clay ridge 1.
14 (cont.) Page 2713 of 3613
10 South facing slope along next ridge to north of Clay ridge 1-- the “north ridge” showing Nolina.

North facing slope on next ridge to south of Clay ridge 1 also has extensive patches of Nolina scatted over the very steep slopes of the canyon.
14 (cont.) Page 2714 of 3613
11 The Nolina population extends all along the “north ridge” to the canyon bottom. 14 (cont.) Page 2715 of 3613
12 Quercus agrifolia Woodland Alliance
Coast live oak woodland (woodland has > 10 % tree cover) Characteristic Species
Quercus agrifolia is dominant or co-dominant in the tree canopy with Fraxinus dipetala. Understory with Heteromeles arbutifolia, Quercus berberidifolia. Rhamnus illicifolia, Toxicodendron diversilobum and shrubs from the RAFS.

Membership Rules
• Quercus agrifolia > 50% relative cover in the tree canopy; if Umbellularia californica trees present, then < 33% relative cover in the tree canopy (Keeler-Wolf et al. 2003a, Evens and San. 2004, Keeler-Wolf and Evens 2006).
• Quercus agrifolia > 60% relative cover in the tree canopy (Evens and San 2005, Klein and Evens 2005).

Habitats
Alluvial terraces, canyon bottoms, stream banks, slopes, flats. Soils are deep, sandy or loamy with high organic matter. Quercus agrifolia Oak Woodland and Chaparral with abundant QUAG There is more oak woodland along the alluvial terraces than mapped by the consulting team, including the woodland in center of this photo along the drainage on the south side of Clay ridge 1 (see map at beginning of appendix). Many of the tributaries to Drainage 3 have oaks and would be impacted. The extent of damage to oaks needs to be reevaluated. 15 16 Page 2716 of 3613
13 Oak Woodland. Three is also Scrub oak chaparral (Quercus berberidifolia alliance), Scrub oak-chamise chaparral (Quercus berberidifolia-Adenostoma fasciculatum alliance) and toyon chaparral (Heteromeles argutifolia alliance) with scattered Quercus agrifolia along the north facing slopes of drainages between stands of oak woodland. 16 (cont.) Page 2717 of 3613
14 Lepidospartum squamatum Shrubland Alliance (> 6 acres) Scale broom scrub
Characteristic Species
Lepidospartum squamatum is dominant, co-dominant, or conspicuous in the shrub canopy with Artemisia californica, Eriodictyon crassifolium, Eriogonum fasciculatum var. foliolosum, Hesperoyucca whipplei, Acmispon glaber var. glaber, Malosma laurina, Rhus ovata, Rhus trilobata and Toxicodendron diversilobum. Emergent trees or tall shrubs are present at low cover, including Cercocarpus betuloides, Platanus racemosa and Sambucus nigra. Holland called this Riversidian alluvial fan sage scrub and alluvial fan chaparral.

Membership Rules (MCV2)
Lepidospartum squamatum > 1% cover in alluvial environments. Habitats intermittently or rarely flooded, low-gradient alluvial deposits along streams, washes and fans. The USFWS Wetland Inventory (1996 national list) recognizes Lepidospartum squamatum as a NI plant.

Scale broom scrub within unnamed drainage 3 within project site. Additional photos available upon request.
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15 Ridgeline – Clay area 1, approximately 1 acre (Clay area 2 is 0.75 acres and contains Stipa pulchra grassland).

There is over an acre of native needlegrass grassland dominated by Stipa lepida on clay soils especially along ridges that were previously scraped. Associated with Salvia mellifera, Ceanothus tomentosus, Adenostoma fasciculatum.

Nassella (Stipa) lepida Provisional Herbaceous Alliance (MCV2)
Foothill needle grass grassland
State rarity S3?, Global rarity G3?
Characteristic Species
Stipa (Nassella) lepida is dominant in the herbaceous layer Habitats
Soils with high clay content (when rolled, soil from this location forms stiff pencil), derived from mudstone, shale, sandstone substrates.

Holland: Valley needlegrass grassland
17 (cont.) Page 2719 of 3613
16 Polygala cornuta var. fishiae- photo at Polygala point on map at bottom of clay ridge 1. 17 (cont.) Page 2720 of 3613
17 Species missing from Plant Table that are significant at the site Native Plants Observed not on species list
Bloomeria crocea
Brickiella californica
Calistegia macrostegia
Ceanothus crassifolius
Ceanothus tomentosus
Cercocarpus betuloides
Encelia farinosa
Fraxinus dipetala
Helianthus gracilentus
Keckiella antirrhiniodes
Keckiella cordifolia
Lepidospartum squamatum
Nolina cismontana
Phacelia distans
Phacelia minor
Polygala cornuta var. fishiae
Pseudognaphalium californicum
Prunus illicifolia
Rhamnus illicifolia
Solanum xanti
Stipa pulchra
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January 2017 2. RESPONSES TO COMMENTS
Comment Letter 6
California Native Plant Society
Riverside-San Bernardino Chapter
4477 Picacho Drive
Riverside, CA 92507
Response to Letter 6
Response to Comment 6-1. This comment provides a general introduction regarding the comments raised in this letter. Responses to the comments contained in this letter are provided below in Responses to Comments 6-2 through 6-13.

Response to Comment 6-2. This comment provides a general introduction regarding the CNPS and the comments raised in this letter. Responses to the comments contained in this letter are provided below in Responses to Comments 6-3 through 6-13.

Response to Comment 6-3. The Draft EIR addressed project impacts on sensitive native plant populations and sensitive plant communities in Section 4.C, Biological Resources, with supporting data provided in Appendix D, Biological Resources Assessment, Surveys, and Jurisdictional Delineation, while the RDEIR addressed these resources in Section 4.C, with supporting analysis and documentation provided in the Updated Biological Resources Assessment included as Appendix A. As indicated on page 4.C-23 through 4-C28 of the Draft EIR, and of pages 4.C-43 through 4.C-46 of the RDEIR, the project would result in less than significant impacts on sensitive native plant species with implementation of the proposed project design features and prescribed mitigation measures. As indicated on Draft EIR pages 4.C-28 and 4.C-29, and on pages 4.C-50 through 4.C-55 of the RDEIR, the project would result in less than significant impacts on riparian habitat (including, plant communities in riparian and woodland habitats, upland, and unvegetated/altered habitats) with implementation of the prescribed mitigation measures. As indicated on Draft EIR pages 4.C-29 through 4.C-33, and on pages 4.C-56 through 4.C-59 of the RDEIR, the project would result in less than significant impacts to federally protected wetlands, and less than significant impacts to jurisdictional waters of the U.S. and riparian scrub and streambeds with compliance with applicable regulatory requirements and implementation of the prescribed mitigation measures. Therefore, the project would not have “severe consequences” to sensitive native plant populations and sensitive plant communities.

Response to Comment 6-4. Updated focused botanical surveys were conducted between April and August 2016, which followed adequate rainfall that provided favorable conditions for annual species that were not observed in past years. In addition to an updated botanical census, the vegetation communities on the project site were also remapped. Field biologists reported a good blooming season in the project site and documented 145 additional botanical species during surveys. The following special-status species were observed during the surveys: 20 Fish’s milkwort (Polygala cornuta var. fishiae), 261 paniculate tarplant (Deinandra paniculata), 455 intermediate mariposa lily, 691 Coulter’s matilija poppy, and ± 5,343 chaparral nolina. The process for determining the number of chaparral nolina on the project site is detailed in Section

4.5.2 of the Updated Biological Assessment (Appendix A of the RDEIR; Appendix D to this EIR).Remapping of habitat communities or assemblages was conducted to more fully address the entire list of species present City of Corona Skyline Heights Project
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and the classifications categorized down to the dominant and subdominant species where applicable.

Alluvial fan sage scrub (AFSS) was observed and has been included in updated figures. The Updated Biological Assessment (Appendix A of the RDEIR) identifies and analyzes the project related impacts to this community.

The location and extent of Quercus agrifolia woodland alliance (coast live oak woodland) and Quercus berberidifolia (scrub oak chaparral) or Quercus berberidifolia Adenostoma fasciculatum shrubland alliances (scrub oak – chamise chaparral) were identified and remapped in the Updated Biological Assessment (Appendix A of the RDEIR) and the Final EIR. Impacts are calculated at 7.59 acres of coast live oak woodland,

6.19 acres of scrub oak chaparral, and 11.71 aces of scrub oak-chamise chaparral (see Table 8 in the Updated Biological Resources Assessment). Tree count surveys and oak tree impacts will also be addressed at the local level with the City of Corona’s General Plan Policy 10.10.5, which requires conservation of oak tree resources in the City and where appropriate within the MSHCP Riparian/Riverine mitigation and CDFW streambed mitigation on a no net loss basis. The EIR and Updated Biological Assessment report includes the following mitigation measure to reduce impacts of oak trees to a no net loss:

Mitigation Measure BIO-MM6. The project Applicant shall replace oak trees impacted by the project at a ratio consistent with the City of Corona oak tree conservancy policy (General Plan Policy 10.10.5), at no less than a 2:1 ratio. Replacement trees shall be located in undeveloped natural areas suitable to support these trees or in onsite mitigation areas where possible. If spacing requirements limit the number of replacement trees in these areas additional plantings may be located in landscaped areas as close to open space as feasible. All replacement trees shall be planted prior to issuance of the Certificate of Occupancy.

Botanical surveys conducted between April and August in 2016 included three areas of clay substrate.

Additional time was spent in these areas to ensure they were adequately surveyed.

Response to Comment 6-5. Reported surveys, the results of which were included in the original Draft EIR, were conducted in drought years and it is likely that some species did not germinate or had a reduced blooming period, which would have affected the species observed and mapped. Additional focused botanical surveys were conducted in 2016 between April and August. Although rainfall continued to be lower than the average, rainfall for the 2015-2016 season was significantly higher than the 2012-2013 survey season. Field biologists reported a good blooming season in the project site and documented 145 additional plant species during surveys, thereby reducing the probability that species were overlooked during surveys.

The 2016 Protocol Botanical Survey conducted by L&L Environmental, Inc. and habitat remapping effort reevaluated the habitat communities and alliances in the project site and refined the designations to include dominant and sub-dominant species. The detailed habitat descriptions are found in Section 4.2 of the Updated Biological Assessment and in the recirculated Biological Resources section. While chaparral nolina was documented as occurring on the project site, the species was not considered to be sufficiently dominant in any location to be mapped as a separate vegetation community. Chaparral nolina was found as an associated species within the hoary-leaf ceanothus chaparral, scrub oak chaparral, and Eastwood manzanita chaparral communities.

Response to Comment 6-6. As stated above in Response to Comment 6-4, L&L Environmental, Inc.

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conducted an updated focused botanical survey during the 2016 survey season, between April and August, to supplement previous work and provide current data. Included in the observed species during the updated surveys were the following sensitive species: 20 Fish’s milkwort, 261 paniculate tarplant, 455 intermediate mariposa lily, 691 Coulter's matilija poppy, and ± 5,343 chaparral nolina. It is believed that the special-status plant species surveys have been adequately completed.

Table 14, Sensitive Species Probability Table, in the Updated Biological Assessment (Appendix A of the RDEIR; Appendix D to the Draft EIR) identifies all the special-status plant species considered during the focused botanical survey, their habitat description and distribution and the determination of probability to occur.

Response to Comment 6-7. On the project site, AFSS is located in and adjacent to drainage Features 3, 6, and 7. The project site supports approximately 10.25 acres of AFSS, of which, 3.35 acres are proposed for impacts under the proposed Project. The MSHCP proposes to conserve AFSS within Conservation and Criteria Areas, within which the project site is not located. AFSS is considered a Riparian/Riverine associated habitat.

The MSHCP baseline habitat map does not include AFSS habitat within the project site, although it is now documented from the site. Therefore, the Skyline Heights Project impacts to AFSS would not technically contribute to the loss of AFSS habitat inventory in the MSHCP Rough Step 7 analysis. Of the 10.25 acres of AFSS mapped by L&L Environmental, Inc., 6.9 acres will be preserved and will remain as open space that will be deed restricted from future development. In effect, 6.9 acres will be added to conserved AFSS within Rough Step 7 and will contribute additional acreage of AFSS in conservation not previously accounted in the total AFSS existing in the MSHCP Plan area. BIO-MM4 will conserve preserved habitat (including AFSS) and prevent additional impacts in the future. Project impacts to AFSS will be mitigated as Riparian/Riverine habitat.

Mitigation Measure BIO-MM4. Those areas of the project site not impacted by the project footprint, including Riparian/Riverine and excluding the minimum 10-acre preservation area identified in BIOMM3, shall be conserved in perpetuity via the recordation of a conservation easement or deed restriction in favor of a CDFW-approved local conservation entity; or transferred in fee title to a CDFW-approved local conservation entity. The avoided Riparian/Riverine areas shall be conserved prior to issuance of a grading permit. The CDFW-approved local conservation entity shall manage the conservation areas to protect the long-term conservation, functions and values in-perpetuity.

Mitigation Measure BIO-MM7. Prior to issuance of a grading permit, the project Applicant shall provide mitigation for 10.07 acres of Riparian/Riverine impacts at a 2:1 basis, as determined through consultation with the City of Corona and wildlife agencies based on an MSHCP evaluation of functions and values analysis. The project Applicant proposes mitigation in the form of offsite mitigation with the Riverside-Corona Resource Conservation District (RCRCD) or other suitable approved organization with available credits. Currently, mitigation in banks is favored to preserve large areas of habitat where it is needed to fulfill the conservation goals of the MSHCP. In the event mitigation with the RCRCD is not finalized for any reason, the project Applicant shall provide equal or greater value mitigation in one or more of the following forms: offsite acquisition and preservation, participation in an approved mitigation bank, onsite creation, offsite creation, enhancement, or reestablishment. If offsite mitigation is incorporated, the preferred choice shall be to find mitigation within or adjacent to the Santa Ana City of Corona Skyline Heights Project
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Watershed and in or adjacent to Corona if possible. In addition, some avoided resources shall be preserved in an open space area and deed restricted.

If onsite mitigation is proposed as an alternative, the project Applicant shall prepare a Habitat Mitigation and Monitoring Plan for review and approval by local and regulatory agencies, which shall include the following components:
• Quantitative success criteria (vegetation cover and species richness); • Recommendations for soil preparation;
• A plant palette to include native species occurring on the site, such as coast live oak and Coulter’s matilija poppy;
• Planting methods;
• Irrigation and maintenance requirements; and
• A long-term mitigation maintenance and monitoring plan with remedial measures.

Areas containing AFSS in the project site have been mapped and are addressed in the Updated Biological Assessment (Appendix A of the RDEIR), which was undertaken to provide more specific vegetation mapping details. For the AFSS occurring within Mabey Canyon, there will be little to no change to the existing fluvial processes because the proposed project does not alter that drainage in any appreciable way. The project development will have the greatest impacts to Drainage Feature 3; however, much of the hydrology flows to the lower areas of Feature 3 will receive sufficient volumes during storm events to allow for maintenance of the AFSS habitat.

Response to Comment 6-8. Clay soil areas and grasslands were surveyed in the field in 2016 and evaluated for vegetation habitats characterization onsite. L&L Environmental, Inc. mapped three new areas of needlegrass grasslands, which totaled 2.33 acres. Additional time was spent in clay soils areas during the updated 2016 focused botanical surveys to ensure these areas were adequately covered for observance of sensitive botanical species. All species observed during the field surveys were included in the list of plant species observed.

Response to Comment 6-9. Coast live oak woodlands located within drainages are considered jurisdictional components and as such are included in the mitigation requirements for jurisdictional impacts.

Those oaks located outside of drainages or as scattered individual oaks are mitigated in compliance with the lead agency ordinances. The project site supports 8.62 acres of coast live oak woodland in seven (7) locations and in addition to scattered individual oak trees. The proposed project will impact 7.59 acres of coast live oak woodlands (4.46 acres of riparian habitat and 3.13 acres of upland woodlands). Prior to construction, the actual number of individual oak trees proposed for impacts will be inventoried and mitigated at a ratio consistent with the City of Corona’s oak tree conservation policy (General Plan 10.10.5), at no less than 2:1, preferably within native, avoided habitats where naturally occurring water sources are present. This typically includes areas where rainfall is likely to accumulate, for example along benches adjacent to drainages or at the toe of slopes. Where the number of mitigation trees exceeds the number that can reasonably be planted in and supported by available water within native habitats, the remaining trees may be planted within landscaped areas where there is an opportunity for these species to survive on irrigation water. This may occur at the toe of constructed slopes, downstream from water quality basins, etc., as close to open space as is reasonably feasible. Replacement of coast live oak trees is included as BIO-MM6 in the Updated Biological Assessment report (see Response to Comment 6-4 above).

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The location of replacement oaks will be prioritized to the greatest extent possible along drainages or on the periphery of water features or basins created on the project site so as to maintain a more natural environment and encourage sustainable populations.

The Declaration of Covenants, Conditions, and Restrictions (CC&Rs) will be modified to prohibit the planting of species that might negatively impact existing and newly planted oak trees, and the final landscape plans will include a broader community of oak tree alliances to reduce the potential for broad scale species loss.

Response to Comment 6-10.

Level of Detail of Alternatives Evaluated
The Draft EIR presents and evaluates alternatives to the proposed project in Chapter 5, Alternatives. With respect to the level of detail of the alternatives addressed in the Draft EIR: (1) as required by CEQA Guidelines Section 15126(d), the descriptions of the three alternatives on pages 5-13, 5-17 and 5-24 are sufficiently detailed to provide an analysis of the alternatives; and (2) as required by CEQA Guidelines Section 15126(a), the analysis of the alternatives in Chapter 5 is sufficiently detailed to foster informed decision making and public participation; and (3) as permitted by CEQA Guidelines Section 15126(d), the discussion of the environmental effects of the alternatives may be in less detail than the discussion of the impacts of the proposed project.

Range of Alternatives Evaluated
CEQA Guidelines Section 15126.6(a) requires that an EIR describe a range of reasonable alternatives to a project which would feasibility attain most of the basic objectives of the project while avoiding or substantially lessening one or more of the significant effects of the project. Consistent with this requirement, three alternatives are evaluated in the Draft EIR, all of which include reductions in the amount of development proposed under the project. These include the No Project Alternative which is required by CEQA Guidelines Section 15126.6(e), and the Reduced Density Alternative and Phase III Only Alternative which are intended to address the significant unavoidable aesthetics and visual resources impacts of the project. An alternative site location alternative was also considered in the Draft EIR but was concluded to be infeasible and thus rejected from further consideration in accordance with CEQA Guidelines Section 15126.6(f)(1). As indicated in Sections 4.C, Biological Resources, of the Draft EIR and RDEIR, and 4.I, Land Use and Planning of the Draft EIR, the project would result in less than significant impacts to both biological resources and trails with compliance with applicable regulations, implementation of the proposed project design features, and/or implementation of the prescribed mitigation measures. Therefore, there is no basis under CEQA for requiring analysis of an additional alternative that would reduce or avoid the biological resources and trails impacts of the project.

Specific Biological Issues Raised
The project alternatives were identified by the lead agency and the biological studies considered the impacts of those alternatives in the Updated Biological Assessment (Appendix A of the RDEIR). The Updated Biological Assessment indicates that ±2,667 chaparral nolina and 6.9 acres of AFSS will be avoided. The impacted AFSS will be mitigated at a minimum ratio of 2:1 (BIO-MM7) and the loss of chaparral nolina shall be mitigated through translocation and seed collection (BIO-MM2).

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Complete avoidance of Feature 3 is infeasible since it would require the complete removal of the secondary access point, which would interfere with public safety. Without contiguous access providing an efficient looped water system within the project site, risk in fire situations would be increased. In addition, constructing the project without impacting the drainage would result in effectively eliminating the lower two-thirds of the project site, which would not generate enough revenue to pay for the needed infrastructure and other improvements, making the project infeasible.

The City believes that a reasonable range of alternatives have been provided to allow an informed decision by the City’s planning commission and the City Council.

Response to Comment 6-11.

Effects on National Forest Lands and Natural Resources (General) The Draft EIR addressed the potential impacts of the project on adjacent lands (including CFS lands) and associated resources throughout the document, including but not limited to: Section 4.A, Aesthetics; Section

4.C, Biological Resources, with supporting data provided in Appendix D, Biological Resources Assessment, Surveys, and Jurisdictional Delineation; Section 4.D, Cultural Resources, with supporting data provided in Appendix E, Cultural Resources Assessments; Section 4.J, Noise, with supporting data provided in Appendix I, Noise Impact Analysis; Section 4.G, Hazards and Hazardous Materials, with supporting data provided in Appendix G, Phase I Environmental Site Assessment and Fuel Modification Report; Section 4.H, Hydrology and Water Quality, with supporting data provided in Appendix H, Preliminary Drainage Report and Water Quality Management Plan; Section 4.L, Public Services (including police and fire); Section 4.M, Transportation, with supporting data provided in Appendix K, Traffic Impact Analysis; and Section 4.O, Agriculture and Forestry Resources. Furthermore, an analysis of project consistency with applicable goals and objectives of the 2005 CNF Land Management Plan (LMP) has been added in Chapter 3, Corrections and Additions to the Draft EIR and RDEIR, in this Final EIR. The Draft EIR provides an adequate analysis of project effects on CNF lands and associated resources.

Wildland Fire Hazard
The Draft EIR addressed the widland fire hazards associated with the project in Section 4.G, Hazards and Hazardous Materials, with supporting data provided in Appendix G, Phase I Environmental Site Assessment and Fuel Modification Report. As indicated on pages 4.G-15 and 4.G-16, while the project site is located within a Very High Fire Hazard Severity Zone (VHFHSZ), the project would replace highly flammable vegetation with plants on the City’s approved list of fire-resistant species, and would implement a fuel modification plan, which would decrease rather than increase the wildland fire potential in the area. As such, the project would result in a less than significant wildland fire hazards with: adherence to applicable requirements (including with CBC Chapter 7A, Materials and Construction Methods for Exterior Wildfire Exposure, and requirements related to fire access, fire flows, and number of hydrants); implementation of the proposed project design features (including the fuel modification plan); and implementation of the prescribed mitigation measures (including CFD review and approval of the site plan, fuel modification plan, and project design features, and payment of the required “Fire Facilities Fund” fees).

Effects on National Forest Lands and Resources (Biological) City of Corona Skyline Heights Project
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