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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 Indelicato Property Subdivision Project Initial Study/Mitigated Negative Declaration (IS/MND). CEQA statutes do not require a formal response to comment for an IS/MND; however, the City has chosen to provide formal responses to all comment letters for informational purposes. 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 Richard and Marilyn Armstrong Resident 4-12-23
B Group Letter with the following 43
Signatories from the Del Webb
Neighborhood/Woodbridge:
1. Nancy Behney
2. Deborah L. De La Cruz
3. Joy Hurlbut
4. Robert and Shirley Reynolds
5. Cheryl Grady
6. John Green
7. Robert and Marlyn Armstrong
8. Pat Wolfe
9. Donald Harris
10. Michael and Debra Machado
11. Cindy Jackson
12. Edwina and Michael Rich
13. Chalres and Nacy Pew
14. Bill and Linda Miller
15. Ed and Marietta Araya
16. Roger Gibson
17. Cynthia Thompson (2)
18. Patrick McDonald
19. Mariana Wilson
20. Anita Snyder
21. James Germaine
22. Jo Ann Germaine
23. Randall William
24. Maggie William
25. Ben and Margaret Kimura
26. Perry Gibson
27. Deanna Langworthy
28. Santi Afrolan
29. Mercedes Foote
30. Frank Lucerno
31. John and Diane Lennert
Del Webb Neighbors 4-26-23
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32. Julie Verduzco
33. Ronald and Nancy Berger
34. Jon and Deborah Ford
35. Rodger and Judith Goodnow
36. Irma Lewis
37. Andrew Edmanor
38. David and Carolyn Bray
39. Bob and LaVerne Onorato
40. Judith Legos
41. Mike and Sandra Raubenher
42. Yolanda Rodelander
43. Joseph Relks
C Mike Spence Resident 4-27-23
D Bill Barnhart Resident 4-30-23
E Mark Voss Resident 4-30-23
F Terry Voss Resident 4-30-23
G Zach Kearns California Dept. of Fish and Wildlife 5-3-23 H HJ Heaney Resident 5-5-23
I Phyllis McDonald Resident 5-7-23
J Phyllis McDonald Resident 5-8-23
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).
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Response to Letter A: Richard and Marilyn Armstrong
Response A-1: The commenter expresses concerns related to privacy and states that their biggest concern is the two-story homes proposed along the south perimeter of their community.
While the comment does not address the environmental concerns, adequacy of the IS/MND, or compliance with CEQA, this comment is noted for its design concerns and has been forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
It is noted that, in response to the design concerns of this commenter and other Woodbridge residents, the Project proponent met with various Woodbridge representatives to discuss their design concerns and to compromise on key issues. As part of this dialogue, Project proponent has agreed that all lots immediately adjacent to the existing Woodbridge development shall be restricted to single-story homes. This agreement was not warranted to mitigate a CEQA impact, but instead represents the Project proponent’s good faith effort to respond to design concerns of neighbors.
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Response to Letter B: Del Webb Neighbors
Response B-1: The commenter includes an introduction page to the attachment. The attachment includes a form letter which was duplicated and signed by the following members of the Del Webb community:
1. Nancy Behney
2. Deborah L. De La Cruz
3. Joy Hurlbut
4. Robert and Shirley Reynolds
5. Cheryl Grady
6. John Green
7. Robert and Marlyn Armstrong
8. Pat Wolfe
9. Donald Harris
10. Michael and Debra Machado
11. Cindy Jackson
12. Edwina and Michael Rich
13. Charles and Nacy Pew
14. Bill and Linda Miller
15. Ed and Marietta Araya
16. Roger Gibson
17. Cynthia Thompson (2)
18. Patrick McDonald
19. Mariana Wilson
20. Anita Snyder
21. James Germaine
22. Jo Ann Germaine
23. Randall William
24. Maggie William
25. Ben and Margaret Kimura
26. Perry Gibson
27. Deanna Langworthy
28. Santi Afrolan
29. Mercedes Foote
30. Frank Lucerno
31. John and Diane Lennert
32. Julie Verduzco
33. Ronald and Nancy Berger
34. Jon and Deborah Ford
35. Rodger and Judith Goodnow
36. Irma Lewis
37. Andrew Edmanor
38. David and Carolyn Bray
39. Bob and LaVerne Onorato
40. Judith Legos
41. Mike and Sandra Raubenher
42. Yolanda Rodelander
43. Joseph Relks
The responses to the listed concerns in the form letter are included in Responses B-2 through B-6.
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Response B-2: The commenter provides an introductory statement, questions if existing fences will be a common fence for the new residences, and questions if homes along the perimeter will be single-story.
While the comment does not address environmental concerns, adequacy of the IS/MND, or compliance with CEQA, this comment is noted for its design concerns and has been forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
It is noted that, in response to the design concerns of this commenter and other Woodbridge residents, the Project proponent met with various Woodbridge representatives to discuss their design concerns and to compromise on key issues. As part of this dialogue, Project proponent has agreed that all lots immediately adjacent to the existing Woodbridge development shall be restricted to single-story homes. This agreement was not warranted to mitigate a CEQA impact, but instead represents the Project proponent’s good faith effort to respond to design concerns of neighbors.
Response B-3: The commenter questions if grading and construction would be planned to avoid drainage flowing into their back yards and homes in adjacent communities.
Impacts associated with stormwater and drainage are discussed in Section X, Hydrology and Water Quality, on pages 64 and 65 of the IS/MND. As discussed, drainage improvements associated with the Project site would be located on the Project site, and the proposed Project would not alter or adversely impact offsite drainage facilities. The proposed Project would increase impervious surfaces throughout the Project site from new concrete and paved surfaces, as well as the residences. The proposed Project would require the installation of storm drainage infrastructure to ensure that storm waters properly drain from the Project site. The proposed storm drainage plan includes an engineered network of storm drain lines, manholes, inlets, and a water quality basin. The storm drainage plan was designed and engineered to ensure proper construction of storm drainage infrastructure to control runoff and prevent flooding, erosion, and sedimentation. The City Engineer reviews all storm drainage plans, including the calculations that are generated as part of the engineering of the planned infrastructure, as part of the improvement plan submittal to ensure that all facilities are designed to the City’s standards and specifications. The City Engineer also reviews all storm drainage plans to ensure that post-project runoff does not exceed pre-project runoff. The City Engineer’s review of pre- and post-project runoff is intended to ensure that the capacity of the existing storm drainage system is not exceeded. This determination is ultimately made by the City Engineer during the improvement plan review and approval. The City Engineer has been involved in the review of all project plans and calculations from project inception.
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and controls to protect and safeguard the general health, safety and welfare of the public residing in watersheds within the city of Manteca”. These requirements are intended to assist in the protection and enhancement of the water quality of watercourses, water bodies, and wetlands in a manner pursuant to and consistent with the Federal Water Pollution Control Act (Clean Water Act, 33 USC Section 1251 et seq.), Porter- Cologne Water Quality Control Act (California Water Code Section 13000 et seq.) and National Pollutant Discharge Elimination System (“NPDES”) Permit No. CAS000004, as such permit is amended and/or renewed.
Stormwater infrastructure is also discussed in Section XIX, Utilities and Service Systems, on pages 109 and 110 of the IS/MND. As discussed, because the Project site could increase runoff significantly, and create downstream drainage problems, Project impacts to stormwater were considered potentially significant. Mitigation Measures UTIL-1 was developed to address this potentially significant impact. This measure requires the Project applicant to submit a drainage plan to the City of Manteca for review and approval. The plan must include an engineered storm drainage plan that demonstrates attainment of pre-Project runoff requirements prior to release at the storm drainage outlet and describes the volume reduction measures and treatment controls used to reach attainment consistent with the Manteca Storm Drain Master Plan. With the implementation of a storm drainage that meets all city standards as outlined in the measure, the impact would be reduced to an insignificant level.
Response B-4: The commenter questions what the rules and regulations will be for landscaping. The commenter also discusses tree planting methods to ensure concrete and underground infrastructure is maintained.
As discussed in the IS/MND, landscaping would be provided as part of the Project. The Project would be subject to the City’s Landscaping Ordinance (Chapter 17.48 of the Municipal Code). Section 17.48.040 of the Code outlines planting size, spacing, and widths, including provisions for trees which abut residential property. This ordinance as designed to regulate landscaping in the city and effectively addresses concerns raised by the commenter.
Response B-5: The commenter questions if the property will be watered down during construction to limit dust and dirt.
As discussed in Section III, Air Quality, of the IS/MND, construction would result in numerous activities that would generate dust. The fine, silty soils in the project area and often strong afternoon winds exacerbate the potential for dust, particularly in the summer months. Impacts would be localized and variable. Construction impacts would last for a period of several months to several years. The initial phase of project construction would involve grading and site preparation activities, followed by building construction. Construction activities that could generate dust and vehicle emissions are primarily related to grading, soil excavation, and other ground-preparation activities, as well as building construction.
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Control measures are required and enforced by the SJVAPCD under Regulation VIII. The SJVAPCD considers construction-related emissions from all projects in this region to be mitigated to a less than significant level if SJVAPCD-recommended PM10 fugitive dust rules and equipment exhaust emissions controls are implemented. The proposed Project would be required to comply with all applicable measures from SJVAPCD Rule VIII. This rule includes measures that may include watering the soils, and other soil stabilizing methods. Watering the soil is the most common and economically feasible soil stabilizing method used by contractors in Manteca and is the method anticipated for the proposed Project.
Response B-6: This comment serves as a conclusion to the letter and does not warrant a response.
This comment is noted. No further response is necessary.
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Response to Letter C: Mike Spence
Response C-1: The commentor states background information regarding the design of the Project and discussions between the nearby neighbors, the Project applicant, and the City. The commenter also discusses the Union Ranch Specific Plan design. The commenter concludes by requesting mitigation of vision trespass from second stories vantages by either (or combinations of) requiring only single-story homes, insertion of an open-space corridor along the Woodbridge boundary, installation of an eight-foot concrete masonry unit (CMU) wall along project’s permitter with Woodbridge, if two-story homes are allowed and adjacent to Woodbridge, minimize the quantity and size, as well as, maximizing the floor to bottom edge of the window distance.
The comment does not address the adequacy of the IS/MND, or compliance with CEQA.
Instead, this comment expresses design concerns from the potential visibility of new residents in second stories having visibility into the existing resident’s yards/homes.
These concerns along with the recommendations for ameliorating the concerns are noted and have been forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
It is noted that, in response to the design concerns of this commenter and other Woodbridge residents, the Project proponent met with various Woodbridge representatives to discuss their design concerns and to compromise on key issues. As part of this dialogue, Project proponent has agreed that all lots immediately adjacent to the existing Woodbridge development shall be restricted to single-story homes. This agreement was not warranted to mitigate a CEQA impact, but instead represents the Project proponent’s good faith effort to respond to design concerns of neighbors.
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Response to Letter D: Bill Barnhart
Response D-1: This comment is noted. This comment is an email with an attached letter. It serves as an introduction to the letter and does not warrant a response. No further response is necessary.
Response D-2: This comment is noted. This comment serves as an introduction to the letter. See Responses D-3 through D-7.
Response D-3: The commenter states that Pulte was required to place 8-foot to 12-foot block walls around most of Woodbridge and place greenbelts along the various site boundaries. The commenter states that the proposed Project does not include greenbelts, and concludes by requesting that the same fencing/wall requirements be levied on abutting developments that were required of the Woodbridge development, and that residential heights for homes backing their residential area be considered.
While the comment does not address environmental concerns, adequacy of the IS/MND, or compliance with CEQA, this comment is noted for its design concerns and has been forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
It is noted that, in response to the design concerns of this commenter and other Woodbridge residents, the Project proponent met with various Woodbridge representatives to discuss their design concerns and to compromise on key issues. As part of this dialogue, Project proponent has agreed that all lots immediately adjacent to the existing Woodbridge development shall be restricted to single-story homes. This agreement was not warranted to mitigate a CEQA impact, but instead represents the Project proponent’s good faith effort to respond to design concerns of neighbors. Upon receipt of Developer’s letter, the commenter withdrew the statements made in Response D-3.
Response D-4: The commenter states that bus pullout areas are included for Woodbridge and a development on Airport Way between Louise and the railroad tracks. The commenter concludes by stating that a safety impact could occur if a pullout is not provided.
As noted on page 84 of the IS/MND, the Project would generate approximately 57 K-6 students, 16 7-8 students, and 35 9-12 students (for a total of 108 students). It is anticipated that between five to ten percent of the students would utilize public transportation, and that the school transit would establish several pickup/drop-off locations within the subdivision, as opposed to on Airport Way. Additionally, school kids walking or riding a bike to school would be anticipated to utilize the sidewalk improvements that would be constructed along the project frontage, travel south on the already developed sidewalk along Airport Way, and then utilize the walking path/trail along the southside of Woodbridge to ultimately connect to Lathrop Road near the London Road intersection. This intersection has an existing signal and crosswalk to ATTACHMENT 14
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facilitate safe travel. From that intersection there is existing sidewalk and crosswalks to George McParland Elementary School. Alternatively, from Lathrop Road kids could travel eastbound along the existing sidewalks to Union Road, then south to East Union High School. This path has existing signals, crosswalk, and sidewalks to facilitate safe travel.
Any need for a bus turnout along Airport Way would be specifically identified by Manteca Transit. The closest bus stop to the Project site is served by Manteca Transit Route 3 and located at Chadwick Park approximately 1 and ¼ miles away. The traffic report addresses existing transit on page 10 of the traffic report. Generally, curbside transit stops in the study area are identified with posted signs and do not include passenger amenities such as a shelter, seating, landscaping, bicycle parking, or pedestrian-scale lighting. The Manteca Transit does not currently have plans for a route along Airport Way north of Northgate (Route 4). As Manteca Transit considers expanding their current routes, or adding new routes, the existing and planned residences along Airport Road north of Lathrop Road would benefit from a transit route, however, there is not currently any plans.
Response D-5: The commenter states that the nearest recreational area will be Woodbridge parks and that the students generated by the Project will need recreational areas immediately. The commenter concludes by stating that the proposed park needs to be completed before the first home sales to help mitigate what they feel would be a very significant impact on our private parks here in Woodbridge.
Impacts associated with recreational facilities are discussed in Section XVI, Recreation, on page 87 of the IS/MND. As discussed, the proposed Project would result in the construction of up to 173 single-family residential homes, which would result in up to an estimated 513 individuals. The City of Manteca General Plan Policy PF-P-49 calls for city park acquisition efforts to be based on the goal of 5 acres of developed neighborhood and community parkland per 1,000 residents within the City parks. Therefore, the estimated new demand for parks generated by the proposed Project is approximately
2.69 acres of new parks. The proposed Project includes the construction of 3.03 acres of new parks, which satisfies the City of Manteca General Plan Policy PF-P-49. However, the City reviews each proposed Project and assigns park credit based on its function and design (i.e. dual use basins do not receive full credit). Park in-lieu fees ultimately fund the construction of new park land to offset the increased demand for these facilities, as required by Mitigation Measure PUBLIC-1.
It is noted that, in response to the design concerns of this commenter and other Woodbridge residents, the Project proponent met with various Woodbridge representatives to discuss their design concerns and to compromise on key issues. As part of this dialogue, Project proponent has agreed that all lots immediately adjacent to the existing Woodbridge development shall be restricted to single-story homes. This agreement was not warranted to mitigate a CEQA impact, but instead represents the Project proponent’s good faith effort to respond to design concerns of neighbors. Upon ATTACHMENT 14
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receipt of Developer’s letter, the commenter withdrew the statement made in Response D-5.
Response D-6: The commenter states that the main entrance/exit of the proposed Project should have both right and left access to avoid traveling north to make a U-turn at Lovelace Road/Airport Way.
Impacts associated with traffic hazards are discussed on pages 103 and 104 of the IS/MND. No traffic hazards were identified. This comment is noted and will be forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
Response D-7: The commenter urges the City to have a master plan for developing the area near Woodbridge. This comment serves as a conclusion to the letter.
While the comment does not address the adequacy of the IS/MND, or compliance with CEQA, this comment is noted and will be forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
It is noted that, in response to the concerns of this commenter and other Woodbridge residents, the Project proponent met with various Woodbridge representatives to discuss their concerns and to compromise on key issues. As part of this dialogue, Project proponent has agreed that all lots immediately adjacent to the existing Woodbridge development shall be restricted to single-story homes. This agreement was not warranted to mitigate a CEQA impact, but instead represents the Project proponent’s good faith effort to respond to design concerns of neighbors. Upon receipt of Project proponent’s response letter, the commenter withdrew the statements made in Response D-7.
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Response to Letter E: Mark Voss
Response E-1: The commenter expresses general concerns regarding children walking to and from school through the community relating to litter, loiter, smoke, and noise.
Noise impacts are discussed in Section XIII, Noise, of the IS/MND. The noise levels will not exceed noise levels established by the City’s Noise Ordinance. The other concerns presented (loitering, smoking, etc.) are not environmental concerns addressed under CEQA and do not address the adequacy of the IS/MND, or compliance with CEQA.
Nevertheless, this comment is noted and will be forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
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Response to Letter F: Terry Voss
Response F-1: The commenter provides background information regarding why they chose to move to the Del Webb Community and concerns regarding homes built north of Del Webb.
While the comment does not address environmental concerns, adequacy of the IS/MND, or compliance with CEQA, this comment is noted for its concerns and has been forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
It is noted that, in response to the concerns of this commenter and other Woodbridge residents, the Project proponent met with various Woodbridge representatives to discuss their concerns and to compromise on key issues. As part of this dialogue, Project proponent has agreed that all lots immediately adjacent to the existing Woodbridge development shall be restricted to single-story homes. This agreement was not warranted to mitigate a CEQA impact, but instead represents the Project proponent’s good faith effort to respond to design concerns of neighbors.
Response F-2: The commenter discusses traffic concerns near Chick-Fil-A and states that they would not like to see the traffic or children in Del Webb, at their parks, or passing through.
Traffic is addressed within the Traffic Report, as well as the traffic section of the IS/MND.
The traffic does not exceed thresholds of significance established for the City. The other concerns presented (kids) are not environmental concerns addressed under CEQA and do not address the adequacy of the IS/MND, or compliance with CEQA. Nevertheless, this comment is noted and will be forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
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Response to Letter G: California Department of Fish and Wildlife Response G-1: The commenter summarizes the responsibilities of the California Department of Fish and Wildlife (CDFW) and summarizes the proposed Project details.
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 G-2: The commenter states that white-tailed kite (Elanus leucurus) has the potential to occur within or adjacent to the Project area. The commenter also states that Project activities should be designed to completely avoid any fully protected species that have the potential to occur within or adjacent to the Project site.
Impacts associated with special-status species, including white-tailed kite, are discussed in Section IV, Biological Resources, of the IS/MND. As stated on pages 30 and 38 of the IS/MND, white-tailed kite is a commonly observed raptor species in the region and is protected from take pursuant to the Fish and Game Code of California Section 3503.5, and the federal Migratory Bird Treaty Act, among other federal and State regulations.
According to the California Natural Diversity Database (CNDDB), there is one documented occurrence of this species within 15 miles of the Project site. The occurrence is located approximately 6.55 miles north of the site and was documented in 2002. This species, however, is very common and the one occurrence does not represent the abundance of this species throughout the region.
White-tailed kite is a covered species under the San Joaquin County Multi-Species Habitat Conservation and Open Space Plan (SJMSCP). As required by Mitigation Measure BIO-1, the Project would be required seek coverage under the SJMSCP, which involves compensation for habitat impacts on covered species through implementation of incidental take and minimization Measures (ITMMs) and payment of fees for conversion of lands that may provide habitat for covered special status species.
The Project site is in the SJMSCP Central Zone. Chapter 5 of the SJMSCP includes ITMMs for Project Proponents to implement. ITMMs shall be completed prior to Site Disturbance (normally prior to grading) as indicated in the conditions of project approval. Some ITMMs will be carried out during project construction. The cost of implementing ITMMs is the responsibility of the Project Proponent. The SJMSCP Joint Powers Authority (JPA) is responsible for costs and implementation of relocation efforts as approved by the Permitting Agencies and as determined necessary through preconstruction surveys.
It is noted that, in response to Comment G-3, white-tailed kite was added to the specialstatus wildlife species table (Table BIO-2) of the Final IS/MND.
Response G-3: The commenter states that Table BIO-2 should be updated and verified, and lists three species (tricolored blackbird, California tiger salamander, and American peregrine falcon) that need updating.
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To address this comment, the Initial Study was revised to update and verify the species listed in this comment as well as other species documented in the region. See the Final IS/MND for the changes to the table.
Response G-4: The commenter discusses and summarizes Sections 3503, 3503.5, and 3513 of the Fish and Game Code. The commenter then recommends that a pre-construction nesting bird survey if vegetation removal or earthwork is scheduled during the nesting season, typically February 1 through August 31. Additionally, the commenter states that CDFW typically recommends surveying a minimum of a 500-foot radius for migrating birds, and a ½-mile radius for nesting raptors.
As discussed in Chapter 5 of the SJMSCP, there are four categories of preconstruction surveys necessary to the implementation of the SJMSCP:
A. Preconstruction surveys to verify vegetation types affected by the project and to determine if SJMSCP Covered Species are present and, if present, attaching Incidental Take Minimization Measures as conditions of project approval for individual projects (see Section 5.2.2.5 [of the SJMSCP] for survey methodologies and Section 5.2.2.4 [of the SJMSCP] for special provisions for conducting plant surveys). These preconstruction surveys shall be conducted in the field when a project is located on suitable habitat for one or more of the SJMSCP Covered Species;
B. Preconstruction surveys conducted prior to (or, for some Incidental Take Minimization Measures, during) ground-disturbing activities to determine if SJMSCP Covered Species have been successfully relocated and/or to determine if other Incidental Take Minimization Measures have been implemented, as specified in the conditions of project approval; and
C. Preconstruction surveys, conducted in compliance with current U.S. Fish and Wildlife Service protocols, to determine the presence or absence of Conservancy and/or longhorn fairy shrimp within vernal pools or other wetlands located southwest of I-580 in the Southwest Zone unless complete avoidance of vernal pools and/or wetlands is achieved in compliance with SJMSCP Section 5.5.9.
D. Preconstruction surveys conducted pursuant to the protocol established in Section 5.2.2.5(AC) of the SJMSCP for:
• Large-flowered fiddleneck southwest of the 900 foot contour line in the Southwest Zone southwest of I-580;
• Showy madia in the Southwest Zone;
• Hospital canyon larkspur in the Southwest Zone;
• Diamond-petaled poppy in the Southwest Zone;
• Greene's tuctoria in the Vernal Pool Zone;
• Succulent owl's clover in the Vernal Pool Zone;
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• Legenere in the Vernal Pool Zone;
• Delta button celery in the Central Zone in S(Scrub) vegetation types; • Sanford’s arrowhead in the Central Zone in W3, W4 and all I and R vegetation types; and
• Slough thistle in the Central and Central/Southwest Transition Zones in W4, R, R2, R3, R4 or R5 vegetation types–in particular where R touches or transitions to W.
The costs of conducting preconstruction surveys described in paragraphs A, B, and D, above, are calculated in the administrative costs for the SJMSCP and are included in funding estimates. The JPA shall conduct preconstruction surveys described in the paragraphs A, B, and D, above, at no additional cost to the Project Proponent. Preconstruction surveys required pursuant to paragraph C, above, are the responsibility of the Project Proponent.
The proposed Project would be subject to the preconstruction survey requirements in paragraph A above.
Response G-5: The commenter state that the proposed project is anticipated to result in disturbances to natural habitats that support native species. The commenter suggests that a qualified biologist who is approved by CDFW to handle special-status species should be retained to be onsite prior to and during all project-related activities. The commenter further states that movement of wildlife out of harm’s way should be limited to only those individuals that would otherwise be injured or killed, and individuals should be moved only as far a necessary to ensure their safety. The commenter concludes by describing the incidental take permit (ITP) requirements as they relate to the California Endangered Species Act (CESA) and associated listed species.
Please see Response G-2.
Response G-6: The commenter states that the trees on the Project site may provide habitat for tree roosting bats, and includes recommendations for tree removal to avoid potential impacts stated by the commenter to such species. The commenter further states that, if bats must be captured or relocated, a qualified biologist should capture injured bats by handcapture or other methods approved by CDFW. The commenter concludes by stating that CDFW does not authorize the use of mist nets or harp traps as capture techniques.
As discussed on pages 38 and 39 of the IS/MND, the Project site provides potential habitat for several special-status bats, including: Greater western mastiff bat (Eumops perotis californicus), western red bat (Lasiurus blossevillii), small-footed myotis/bat (Myotis ciliolabrum), long-eared myotis/bat (Myotis evotis), fringed myotis/bat (Myotis thysanodes), long-legged myotis/bat (Myotis volans), and Yuma myotis/bat (Myotis yumanensis). These species are not federal, or state listed; however, they are tracked by the CNDDB. Greater western mastiff bat (Eumops perotis californicus) has been documented in the 12-quadrangle radius for the Project site. The nearest occurrence to ATTACHMENT 14
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the site is located approximately 18.6 miles southwest of the site near the Carnegie State Vehicular Area in the hills west of Interstate 580. Western red bat (Lasiurus blossevillii), small-footed myotis/bat (Myotis ciliolabrum), long-eared myotis/bat (Myotis evotis), fringed myotis/bat (Myotis thysanodes), long-legged myotis/bat (Myotis volans), and Yuma myotis/bat (Myotis yumanensis) have not been documented in the 12-quadrangle radius of the Project site.
As discussed on page 39 of the IS/MND, development of the Project site would eliminate foraging habitat for special status bats by removing the agricultural areas. Additionally, special status bats can establish roosts within the structures and/or trees located on the Project site. Bats can establish roosts even when absent in prior years. There has been no evidence of bat roosts on the project site (i.e. guano, bat sounds, etc.). These special status bat species are covered by the SJMSCP.
The following bat species are covered by the SJMSCP: Greater western mastiff bat aka California mastiff bat (Eumops perotis californicus), red Bat (Lasiurus blossevilli), smallfooted myotis/bat (Myotis ciliolabrum), long-eared myotis/bat (Myotis evotis, fringed myotis/bat (Myotis thysanodes),long-legged myotis/bat (Myotis volans), Yuma myotis/bat (Myotis yumanensis), and Pale big-eared bat (Plecotus townsendii pallescens aka Corynorhinus townsendii pallescens) aka Pacific western big-eared bat (Plecotus townsendii townsendii aka Corynorhinus townsendii townsendii).
As discussed in the SJMSCP, prior to the nursery seasons indicated in Table 5.2-2 of the SJMSCP for bat species discussed above, nursery sites shall be sealed. Sealing of the hibernation sites shall occur prior to the hibernation season (November through March) when hibernation sites are identified on the project site. Alternatively, grating may be installed as described in 5.5.9(E)(1) of the SJMSCP. Additionally, when colonial roosting sites which are located in trees or structures must be removed, removal shall occur outside of the nursery and/or hibernation seasons and shall occur during dusk and/or evening hours after bats have left the roosting site unless otherwise approved pursuant to Section 5.2.3.2 of the SJMSCP.
Response G-7: The commenter states that occurrences of Swainson’s hawk (Bueto swainsoni) have been documented within five miles of the Project site, and the site may have suitable nesting and foraging habitat. The commenter suggests that, if participation in the SJMSCP is not feasible, an ITP should be obtained if the Project would result in a “take”. The commenter also recommends a qualified biologist conduct a SWHA survey within a minimum ½-mile radius around the project area. Further, if an occupied nest is found and may be impacted by project activities, the commenter suggests that the project proponent should consult with CDFW and demonstrate compliance with CESA.
It is noted that Swainson’s hawk is well documented in the region. The site survey did not reveal any active or remnant nest site. The open land would be foraging habitat for Swainson’s hawk. Participation in the SJMSCP is required by Mitigation Measure BIO-1 of the IS/MND. The City of Manteca is a permit holder and plan participant for the SJMSCP.
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As stated previously, Mitigation Measure BIO-1 of the IS/MND requires the Project proponent to seek coverage under the SJMSCP to mitigate for habitat impacts to covered special status species. Coverage involves compensation for habitat impacts on covered species through implementation of incidental take and minimization measures (ITMMs) and payment of fees for conversion of lands that may provide habitat for covered special status species. These fees are used to preserve and/or create habitat in preserves to be managed in perpetuity. Obtaining coverage for a Project includes incidental take authorization (permits) under the Endangered Species Act Section 10(a), California Fish and Game Code Section 2081, and the MBTA. Coverage under the SJMSCP would fully mitigate all habitat impacts on covered special-status species.
Response G-8: The commenter states that occurrences of burrowing owl (Athene cunicularia) have been documented within five miles of the Project site, and suggests that a survey for this species be completed within one to two weeks prior to the start of construction. If burrowing owls are observed within 500 feet of the project area, the commenter suggests that the project proponent should develop an Impact Assessment consistent with the Staff Report on Burrowing Owl Mitigation and submit the Impact Assessment to CDFW prior to construction work.
As discussed in Chapter 5 of the SJMSCP, the presence of ground squirrels and squirrel burrows are attractive to burrowing owls. There was no evidence of active or remnant burrows on the project site, although there is a potential for foraging. The SJMSCP requires a Project Proponent to prevent ground squirrels from occupying the project site early in the planning process by employing one of the following practices:
A. The Project Proponent may plant new vegetation or retain existing vegetation entirely covering the site at a height of approximately 36" above the ground.
Vegetation should be retained until construction begins. Vegetation will discourage both ground squirrel and owl use of the site.
B. Alternatively, if burrowing owls are not known or suspected on a project site and the area is an unlikely occupation site for red-legged frogs, San Joaquin kit fox, or tiger salamanders:
The Project Proponent may disc or plow the entire project site to destroy any ground squirrel burrows. At the same time burrows are destroyed, ground squirrels should be removed through one of the following approved methods to prevent reoccupation of the project site. Detailed descriptions of these methods are included in Appendix A, Protecting Endangered Species, Interim Measures for Use of Pesticides in San Joaquin County, dated March, 2000:
1. Anticoagulants. Establish bait stations using the approved rodenticide anticoagulants Chlorophacinone or Diphacinone. Rodenticides shall be used in compliance with U.S. Environmental Protection Agency label standards and as directed by the San Joaquin County Agricultural Commissioner.
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2. Zinc Phosphide. Establish bait stations with non-treated grain 5-7 calendar days in advance of rodenticide application, then apply Zinc Phosphide to bait stations. Rodenticides shall be used in compliance with U.S. Environmental Protection Agency label standards and as directed by the San Joaquin County Agricultural Commissioner.
3. Fumigants. Use below-ground gas cartridges or pellets and seal burrows.
Approved fumigants include Aluminum Phosphide (Fumitoxin, Phostoxin) and gas cartridges sold by the local Agricultural Commissioner's office. NOTE: Crumpled newspaper covered with soil is often an effective seal for burrows when fumigants are used. Fumigants shall be used in compliance with U.S.
Environmental Protection Agency label standards and as directed by the San Joaquin County Agricultural Commissioner.
4. Traps. For areas with minimal rodent populations, traps may be effective for eliminating rodents. If trapping activities are required, the use of, shall be consistent with all applicable laws and regulations.
If the measures described above were not attempted or were attempted but failed, and burrowing owls are known to occupy the project site, then the following measures shall be implemented:
C. During the non-breeding season (September 1 through January 31) burrowing owls occupying the project site should be evicted from the project site by passive relocation as described in the California Department of Fish and Game’s Staff Report on Burrowing Owls (Oct., 1995)
D. During the breeding season (February 1 through August 31) occupied burrows shall not be disturbed and shall be provided with a 75 meter protective buffer until and unless the TAC, with the concurrence of the Permitting Agencies’ representatives on the TAC; or unless a qualified biologist approved by the Permitting Agencies verifies through non-invasive means that either: 1) the birds have not begun egg laying, or 2) juveniles from the occupied burrows are foraging independently and are capable of independent survival. Once the fledglings are capable of independent survival, the burrow can be destroyed.
These Incidental Take Minimization Measures are consistent with the provisions of the Migratory Bird Treaty Act as described in Section 5.2.3.1(G).
Response G-9: The commenter states that escape ramps for wildlife should be placed at each end of any open excavation at the end of each workday, and a qualified biologist or construction monitor should survey the project area to ensure wildlife incidentally trapped due to project activities are allowed to escape prior to project commencement.
Please see Response G-2.
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Response G-10:The commenter states that there may be drainage features on-site which appear to be hydrologically connected to other waterbodies. The commenter summarizes Section 1602 of the Fish and Game Code and defines “river, stream, or lake” as it pertains to this Section of the Code. The commenter also describes the Lake and Streambed Alteration (LSA) Agreement requirements and procedures.
As discussed on page 40 of the IS/MND, the Project site does not contain protected wetlands or other jurisdictional areas and there is no need for permitting associated with the federal or state Clean Water Acts. The irrigation ditches are man-made isolated facilities with the sole purpose of agricultural irrigation. These ditches are exempt from permitting and are not considered a river, stream, or lake.
Response G-11:The commenter states that, if participation in the SJMSCP is not approved for any reason, early consultation with CDFW is recommended to ensure CESA compliance and avoid project delays due to the permitting process.
As noted in Response G-7, the City of Manteca is a permit holder and plan participant for the SJMSCP. As stated previously, Mitigation Measure BIO-1 of the IS/MND requires the Project proponent to seek coverage under the SJMSCP to mitigate for habitat impacts to covered special status species. Coverage involves compensation for habitat impacts on covered species through implementation of incidental take and minimization measures (ITMMs) and payment of fees for conversion of lands that may provide habitat for covered special status species. These fees are used to preserve and/or create habitat in preserves to be managed in perpetuity. Obtaining coverage for a Project includes incidental take authorization (permits) under the Endangered Species Act Section 10(a), California Fish and Game Code Section 2081, and the MBTA. Coverage under the SJMSCP would fully mitigate all habitat impacts on covered special-status species.
Response G-12:The commenter requests written notification of proposed actions and pending decisions regarding the Project.
This comment is noted. The commenter has been included in the City’s notification list for this Project. This comment serves as a conclusion to the letter.
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Response to Letter H: HJ Heaney
Response H-1: The commenter provides an introductory statement, questions if the site is zoned residential, questions if existing fences will be a common fence for the new residences and who will be responsible for maintenance of the fences, and states that homes along the perimeter should be single-story.
As discussed on page 4 of the IS/MND, the Project site is designated LDR (Low Density Residential) by the Manteca General Plan land use map. There is also a small silver of Public Quasi Public (PQP) land use designated along the northern boundary of the Project site. Because the site is not located within the City of Manteca, the site does not have a City zoning designation. The current zoning for the site is Agriculture Urban Reserve (AU 20). As also discussed in the IS/MND, the San Joaquin County Local Agency Formation Commission (LAFCo) will require the project site to be pre-zoned by the City of Manteca in conjunction with the proposed annexation. The City’s pre-zoning for the entire site will be R-1 (One Family Dwelling), which is consistent with the LDR (Low Density Residential) land use designation of the Manteca General Plan.
Beyond the land use and zoning questions discussed above, this comment does not present environmental concerns, and does not address the adequacy of the IS/MND, or compliance with CEQA. Nevertheless, this comment is noted and has been forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
It is noted that, in response to the concerns of this commenter and other Woodbridge residents, the Project proponent met with various Woodbridge representatives to discuss their concerns and to compromise on key issues. As part of this dialogue, Project proponent has agreed that all lots immediately adjacent to the existing Woodbridge development shall be restricted to single-story homes. This agreement was not warranted to mitigate a CEQA impact, but instead represents the Project proponent’s good faith effort to respond to design concerns of neighbors.
Response H-2: The commenter questions who would be responsible for any damage done to existing grades and drainage in backyards during grading and construction.
Impacts associated with stormwater and drainage are discussion in Section X, Hydrology and Water Quality, on pages 64 and 65 of the IS/MND. As discussed, drainage improvements associated with the Project site would be located on the Project site, and the proposed Project would not alter or adversely impact offsite drainage facilities. The proposed Project would increase impervious surfaces throughout the Project site. The proposed Project would require the installation of storm drainage infrastructure to ensure that storm waters properly drain from the Project site. The proposed storm drainage plan includes an engineered network of storm drain lines, manholes, inlets, and a water quality basin. The storm drainage plan was designed and engineered to ensure proper construction of storm drainage infrastructure to control runoff and prevent flooding, erosion, and sedimentation. The City Engineer reviews all storm drainage plans ATTACHMENT 14
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as part of the improvement plan submittal to ensure that all facilities are designed to the City’s standards and specifications. The City Engineer also reviews all storm drainage plans to ensure that post-project runoff does not exceed pre-project runoff. The City Engineer’s review of pre- and post-project runoff is intended to ensure that the capacity of the existing storm drainage system is not exceeded. This determination is ultimately made by the City Engineer during the improvement plan review and approval.
Additionally, the proposed Project is subject to the requirements of Chapter 13.28 of the Manteca Municipal Code – Stormwater Management and Discharge Control. The purpose of these requirements is to “establish minimum storm water management requirements and controls to protect and safeguard the general health, safety and welfare of the public residing in watersheds within the city of Manteca”. These requirements are intended to assist in the protection and enhancement of the water quality of watercourses, water bodies, and wetlands in a manner pursuant to and consistent with the Federal Water Pollution Control Act (Clean Water Act, 33 USC Section 1251 et seq.), Porter- Cologne Water Quality Control Act (California Water Code Section 13000 et seq.) and National Pollutant Discharge Elimination System (“NPDES”) Permit No. CAS000004, as such permit is amended and/or renewed.
Stormwater infrastructure is also discussed in Section XIX, Utilities and Service Systems, on pages 109 and 110 of the IS/MND. As discussed, because the Project site could increase runoff significantly, and create downstream drainage Problems, Project impacts to stormwater are considered potentially significant. Mitigation Measures UTIL-1 requires the Project applicant to submit a drainage plan to the City of Manteca for review and approval. The plan will include an engineered storm drainage plan that demonstrates attainment of pre-Project runoff requirements prior to release at the storm drainage outlet and describes the volume reduction measures and treatment controls used to reach attainment consistent with the Manteca Storm Drain Master Plan.
During construction, as discussed on page 57 of the IS/MND, a Storm Water Pollution Prevention Plan (SWPPP) with Best Management Practices (BMPs) related to prevention of soil erosion during construction would be required. As stated in Mitigation Measure GEO-2, the SWPPP shall be designed to control pollutant discharges utilizing Best Management Practices (BMPs) and technology to reduce erosion and sediments. BMPs may consist of a wide variety of measures taken to reduce pollutants in stormwater runoff from the Project site. Measures shall include temporary erosion control measures (such as silt fences, staked straw bales/wattles, silt/sediment basins and traps, check dams, geofabric, sandbag dikes, and temporary revegetation or other ground cover) that will be employed to control erosion from disturbed areas. Final selection of BMPs will be subject to approval by the City of Manteca and the RWQCB. The SWPPP will be kept on site during construction activity and will be made available upon request to representatives of the RWQCB.
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Response H-3: The commenter states that removing trees will generate significant dust and first, and questions how dust and dirt will be mitigated.
As discussed in Section III, Air Quality, of the IS/MND, construction would result in numerous activities that would generate dust. The fine, silty soils in the project area and often strong afternoon winds exacerbate the potential for dust, particularly in the summer months. Impacts would be localized and variable. Construction impacts would last for a period of several months to several years. The initial phase of project construction would involve grading and site preparation activities, followed by building construction. Construction activities that could generate dust and vehicle emissions are primarily related to grading, soil excavation, and other ground-preparation activities, as well as building construction.
Control measures are required and enforced by the SJVAPCD under Regulation VIII. The SJVAPCD considers construction-related emissions from all projects in this region to be mitigated to a less than significant level if SJVAPCD-recommended PM10 fugitive dust rules and equipment exhaust emissions controls are implemented. The proposed Project would be required to comply with all applicable measures from SJVAPCD Rule VIII.
Response H-4: The commenter questions what improvements to Airport Road will be contemplated.
As described on pages 3 and 4 of the IS/MND, residences would back on Airport Way, consistent with the existing residential orientation along the street. Access to the subdivision will occur from two locations on the west site of the subdivision along Airport Way. The internal circulation design includes roadway stubs to access the property to the north in accordance with the City’s requirements. These are the only proposed improvements to Airport Way.
Response H-5: This comment is noted. This comment serves as a conclusion to the letter and does not warrant a response. No further response is necessary.
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Response to Letter I: Phyllis McDonald
Response I-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 I-2: The commenter states that not having a school bus pullout is a safety issue for students and requests one be added.
As noted on page 84 of the IS/MND, the Project would generate approximately 57 K-6 students, 16 7-8 students, and 35 9-12 students (for a total of 108 students). It is unknown how many of those students would take public school buses. It is also noted that street safety issues were not identified in the IS/MND.
While the comment does not address the adequacy of the IS/MND, or compliance with CEQA, this comment is noted and will be forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
Response I-3: The commenter discusses the proposed access points and turning movements for the Project, and states that the main entrance/exit of the proposed Project should have both right and left access to avoid traveling north to make a U-turn at Lovelace Road/Airport Way.
Impacts associated with traffic hazards are discussed on pages 103 and 104 of the IS/MND. No traffic hazards were identified. This comment is noted and will be forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
Response I-4: The commenter urges the Planning Department to have a master plan for developing the area north of Woodbridge. This comment serves as a conclusion to the letter.
While the comment does not address the adequacy of the IS/MND, or compliance with CEQA, this comment is noted and will be forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
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Response to Letter J: Phyllis McDonald
Response J-1: The commenter provides concerns regarding Lovelace MRF and Transfer Station workers who drive along Lovelace Road.
While the comment does not address the adequacy of the IS/MND, or compliance with CEQA, this comment is noted and will be forwarded to the decision-makers for their consideration of topics beyond the adequacy of the IS/MND.
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