RESPONSE TO COMMENTS
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LIST OF COMMENTERS
Table 1 lists the comments on the Draft IS/MND that were submitted to the City of Manteca (City) during the public review period for the proposed Mitigated Negative Declaration. The assigned comment letter or number, letter date, letter author, and affiliation, if presented in the comment letter or if representing a public agency, are also listed. Letters received are coded with letters (A, B, etc.).
TABLE 1 LIST OF COMMENTERS ON DRAFT IS/MND
RESPONSE
LETTER
INDIVIDUAL OR SIGNATORY AFFILIATION DATE
A Tom Dumas Caltrans 7/27/22
B Peter Minkel Central Valley Regional Water Quality Control Board 8/8/22 C Zach Kerns California Department of Wildlife 8/8/22
COMMENTS AND RESPONSES
The lead agency is evaluating and responding to all comments on the that regard an environmental issue.
The written response addresses the environmental issue raised and provides a detailed response. The written response is a good faith and reasoned analysis. It is noted that lead agencies need only to respond to significant environmental issues associated with the proposed Project and do not need to provide all the information requested by the commenter, as long as a good faith effort at full disclosure.
RESPONSES TO COMMENT LETTERS
Written comments on the CEQA document are reproduced on the following pages, along with responses to those comments. To assist in referencing comments and responses, the following coding system is used:
• Each letter is lettered or numbered (i.e., Letter A) and each comment within each letter is numbered (i.e., comment A-1, comment A-2).
Exhibit A- Response to Comments
Exhibit "A" ATTACHMENT 2
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A-1
A-2
A-3
A-4
A-5
Exhibit "A" ATTACHMENT 2
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A-6
A-5 Cont’d
A-7
A-8
A-9
A-10
A-11
A-12
A-13
Exhibit "A" ATTACHMENT 2
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A-13 Cont’d
A-14
A-15
Exhibit "A" ATTACHMENT 2
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Response to Letter A: Caltrans
Response A-1: The commenter states: “Please make the following revisions to the Transportation Impact Analysis (TIA) and submit to Caltrans for review and comment prior to project approval.” This comment is noted.
Response A-2: The commenter states: “The TIA needs to include the scenario “Existing Year Plus Proposed Project Plus Any Approved/Pending Projects.”
Analysis of future development within the City is addressed via the Cumulative Conditions analysis as the local travel demand model was used in the volume forecasts and is consistent with the City's latest approved general plan. No changes are recommended.
Response A-3: The commenter states: “The TIA needs to include queueing analysis for the following conditions
• Existing Conditions without Project
• Existing Plus Project Conditions
• Existing Year Plus Proposed Project Plus Any Approved/Pending Projects • Cumulative (2040) Conditions without Project
• Cumulative (2040) Plus Project Conditions”
This information is provided in the updated TIA (attached) as requested and will be consistent with comment #13 request.
Response A-4: The commenter states: “The TIA needs to include the following study intersections:
• Airport Way & Daniels Street
• Airport Way & Atherton Drive”
The traffic scope was established early in the process. The scoping of study intersections and roadway segments was coordinated with the City of Manteca Engineering Department and Kittelson Associates. The City is comfortable that the project was properly scoped to evaluate the roadway network for their engineering considerations.
The CEQA document appropriately evaluated VMT per the requirements of SB 375.
Response A-5: The commenter states: “Using the Existing Turning Movement Counts the Appendix, we could not verify the Existing Traffic Volumes in Figure 3 of the TIA. Please review and revise the Existing Turning Movement Counts section within the Appendix and provide Caltrans with Existing Turning Movement Counts that can be used to verify the Existing Traffic Volumes in Figure 3.”
The existing turning movement volumes shown in Figure 3 represent balanced existing AM and PM peak hour volumes. Raw peak hour existing count data for each individual study intersection provided in Appendix B were evaluated and adjusted (upwards/increasing only) where necessary to arrive at the balanced existing AM and PM Exhibit "A" ATTACHMENT 2
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peak hour analysis volumes. Text on page 8 of the TIA has been updated to document this detail.
Response A-6: The commenter states: “Figure 3 (Existing Traffic Volumes) shows that at the intersection of Airport Way & SR 120 WB on/offramp during PM peak hour, the northbound through movements for Airport Way shows 703 vehicles. However, this seems to contradict data in other parts of the TIA. Please indicate where the TIA gets the 703 vehicles from and ensure that similar errors do not appear with other turning movements/intersections as well.
• In the Appendix, the northbound through movements for Airport Way shows 802 vehicles based on the turning movement diagram.
• The 15-minutes count period from 4:00 PM to 5:00 PM shows that there are 712 (199+180+164+169 = 712) vehicles for the northbound through movement.” There appears to be some confusion and a mistake from the commenter. There is an error in the commenter's calculation "199+180+164+169". As shown in the Appendix, the 4:00pm-5:00pm NBT volume is 199+170+164+169=702.
Figure 3 shows 702 NB vehicles at the Airport Way/SR 120 WB ramps during the PM peak hour, the Synchro Existing PM peak hour analysis work sheet shown in the Existing Conditions Analysis Appendix show 703 vehicles, and Figure 3 shows 703 PM peak hour vehicles. The additional 1 vehicle was due to volume balancing. No changes are recommended.
Response A-7: The commenter states: “How was the Peak Hour Factor (PHF) inputted into Synchro calculated? Where does the PHF came from in the existing traffic counts?” The peak hour factor (PHF) data was determined based upon existing peak hour volumes and was applied at each individual intersection. Existing PHF data is presented in the Existing Turning Movement Counts Appendix of the Report along with existing peak hour turning movement volumes, heavy vehicle percentages, and pedestrian/bike counts. No changes are recommended.
Response A-8: The commenter states: “How was the truck percentage for each turning movement that was inputted into Synchro calculated? Each turning movement should have its own truck percentage based upon the number of vehicles and trucks for each turning movement.” Heavy vehicle truck volumes were collected along with passenger vehicle, pedestrian, and bike data and is presented in the Existing Turning Movement Counts section of the Appendix. Heavy vehicle % was coded by approach, but will be revised and coded by movement as requested.
Response A-9: The commenter states: “The default link speed within Synchro is 30 mph. Please review the link speed used in the Synchro and change it to the posted speed limit.” Exhibit "A" ATTACHMENT 2
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Link speeds have been updated in the TIA as requested.
Response A-10: The commenter states: “The segment of Airport Way between Peregrine St. and Woodward Ave has one lane for northbound traffic. However, the Synchro files show that the segment has two lanes for northbound traffic. Please correct this and check the Synchro model to ensure it accurately represents the existing field conditions for all study years unless it is part of a mitigation.”
The existing synchro files has been revised as requested. Airport Way is planned to be widened to 4 lanes per the PFIP.
Response A-11: The commenter states: “Please balance the volume of traffics within Synchro for all roadway segments.”
As noted in response #5 above, inconsistencies between Figure 3 (Existing Peak Hour Volumes) and the raw existing volume summaries in the appendix are due to peak hour balancing where appropriate. Text will be added to the report to describe the balancing process. Balancing will only be applied where applicable, for example between interchange ramps.
Response A-12: The commenter states: “Provide the output from the travel model developed for the City of Manteca General Plan Update and any calculations for the established baseline VMT per single family residential household of 103.8 and the 2040 with Project VMT per single family residential household of 63.6 to the Appendix.”
VMT output summaries are provided in the Appendix to the TIA.
Response A-13: The commenter states: “It is expected that the TIA’s queue analysis results be shown in SimTraffic instead of Synchro to measure the full impact of queueing and blocking since SimTraffic is designed to model networks of signalized and unsignalized intersections, closely spaced intersections with blocking problems, and the effects of signals on nearby unsignalized intersections and driveways. To determine if studied intersections operate in coordination (especially queue distances between signalized intersections, between signalized and unsignalized intersections), they need to be coded as actuated coordinated. Additionally, SimTraffic should include 10-minute seed time and 60-minute record time of 15-minute interval, and the model should be recorded with 5 to 10 simulation runs. Please use Synchro/SimTraffic V11 for the analysis.” Queue results have been added to the report using SimTraffic as requested.
Response A-14: The commenter states: “Caltrans recommends a Complete Streets approach to planning this development and the surrounding area that promotes bicycle and pedestrian connectivity between the residence and neighboring schools, parks, businesses, and other nearby destinations. This would include facilities such as crosswalks, sidewalks, and bicycle lanes.”
Exhibit "A" ATTACHMENT 2
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As documented in Figure 2 and on page 46 of the TIA, the project will provide sidewalk along both sides of all internal site roadways as well as sidewalk along the project frontages along Oleander Avenue and Peach Road.
Response A-15: The commenter states: “Caltrans recommends that nearby destinations include the facilities necessary to accommodate alternate modes of transportation such as bus stops, bike racks, and solar charging stations for electric vehicles.” Noted.
Exhibit "A" ATTACHMENT 2
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B-1
Exhibit "A" ATTACHMENT 2
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Exhibit "A" ATTACHMENT 2
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Response to Letter B: California Department of Fish and Wildlife Response B-1: This commenter provides an introduction, outlines their regulatory authorities, and provides a comment regarding tree impacts. The comment includes CDFW’s recommendation for tree replacement at a ratio of 3:1 rather then the 1:1 specified in Mitigation Measure Bio-2.
This comment is noted, however, it is the City’s policy to impose the requirements of the Manteca Municipal Code for tree replacement. The Manteca Municipal Code calls for the avoidance of heritage trees as defined under section 17.61.030. Heritage trees are any natural woody plant rooted in the ground and having a diameter of 30 inches or more when measured two feet above the ground.
Section 17.19.060 calls for the protection of all existing trees having a diameter of six inches or more when measured 4½ feet above the ground. The City planning department must be notified of planned construction or grade changes within the proximity of existing mature trees. Existing trees must be protected from construction equipment, machinery, grade changes, and excavation for utilities, paving, and footers. Replacement of existing trees is subject to approval from the planning director and must be with a minimum 24- inch box tree of compatible species for the development site and be consistent with Section 17.19.030.
Section 12.08.070 of the municipal code prohibits cutting, pruning, removing, injuring, or interference with any tree, shrub, or plant upon or in any street tree area or other public place in the City without prior approval from the superintendent. The City is authorized to grant such permission at their discretion and where necessary. Except for utility companies, as provided in Section 12.08.080, no such permission shall be valid for a longer period than 30 days after its issuance.
As noted in the Initial Study, there are several ornamental trees associated with the existing residences within the Project site; however, none are heritage trees. While the City is not imposing a tree replacement above the 1:1 ratio, it is noted that there are 197 residential units and each unit will have a minimum of one tree planted in the front landscaping of the residence. It is also anticipated that additional trees will be planted in the backyards of the residences at the discretion of the new home owners. This number of trees planted would far exceed the commenters recommendation for a 3:1 replacement ratio.
Exhibit "A" ATTACHMENT 2
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C-1
C-2
Exhibit "A" ATTACHMENT 2
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C-2 Cont’d
C-3
C-4
Exhibit "A" ATTACHMENT 2
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C-5
C-6
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C-6 Cont’d
C-7
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C-8
C-7 Cont’d
Exhibit "A" ATTACHMENT 2
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Response to Letter C: Central Valley Regional Water Quality Control Board Response C-1: This comment is noted. This comment serves as an introduction to the letter and does not warrant a response. No further response is necessary.
Response C-2: The comment provides background information regarding the responsibilities of the Central Valley Regional Water Quality Control Board (RWQCB). This information further elaborates on regulatory information regarding the Water Quality Control Plan for the Central Valley Region (Basin Plan), which is the guiding document for water quality and sustainable groundwater management in the region. This comment is noted. No response is necessary.
Response C-3: The comment provides information regarding “Antidegradation Considerations,” including the Basin Plan’s policy and analysis requirements for National Pollutant Discharge Elimination System (NPDES) and Waste Discharge Requirement (WDR) permitting. The project is subject to the requirements of the NPDES and WDR, which are existing regulatory requirements. No response is necessary.
Response C-4: The comment identifies construction storm water permit requirements for projects that disturb one or more acres of soil or are part of a larger plan that in total disturbs one or more acres of soil. These are regulatory requirements that require the Project Applicant to obtain coverage under the General Permit for Storm Water Discharges Associated with Construction Activities (Construction General Permit), Construction General Permit Order No. 2009-009-DWQ. To do so, the applicant(s) must prepare a Project-specific Stormwater Pollution Prevention Plan (SWPPP), which would incorporate BMPs in order to prevent or reduce to the greatest extent feasible adverse impacts to water quality from erosion and sedimentation. The proposed Project would comply with the General Construction Stormwater Permit from the Central Valley RWQCB.
Response C-5: The comment identifies construction storm water permit requirements MS4 permit requirements. The City is classified as a Phase II city by the State Water Resources Control Board. As such, the City, and consequently new development, is required to comply with the State Board’s storm water National Pollutant Discharge Elimination System (NPDES) permit for Phase II cities.
Response C-6: This comment discusses requirements of Section 404 and 401 of the federal Clean Water Act, and discharges to Waters of the State. As discussed on page 42 of the Initial Study, the Project site does not have any jurisdictional waters and is not subject to these permit requirements.
Response C-7: This comment discusses dewater permit requirements. Dewatering is not anticipated to be required as a result of construction of the proposed Project. However, should groundwater be encountered during construction and dewatering become necessary, the applicant would be required to seek the proper NPDES permit for dewatering activities.
Exhibit "A" ATTACHMENT 2
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Response C-8: This comment discuses NPDES permits, and the preparation of Waste Discharge Reports.
These are regulatory requirements that require the Project Applicant operating under a NPDES permit to complete and submit a report of Waste Discharge to the Central Valley RWQCB. The proposed Project is required to comply with these requirements.
Exhibit "A" ATTACHMENT 2