Loading...
HomeMy WebLinkAboutChapter 2_RTC_West Ming Specific Plan - Recirculated Draft EIR Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\Recirculated DEIR\02160029_ Recirculated DEIR.doc Chapter 2: Response to Comments and Supporting Technical Information Response to Comments to Environmental Impact Report for West Ming Specific Plan Prepared for: City of Bakersfield Development Services Department 1715 Chester Avenue Bakersfield, CA 93301 661.326.3733 Contact: Ms. Jennie Eng, Principal Planner Prepared by: Michael Brandman Associates 220 Commerce, Suite 200 Irvine, CA 92602 714.508.4100 Contact: Michael E. Houlihan, AICP, Project Director December 8, 2006 West Ming Specific Plan - Draft EIR Response to Comments Table of Contents Michael Brandman Associates iii H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec00-TOC with fields.doc TABLE OF CONTENTS Section 1: Purpose.............................................................................................................1-1 Section 2: Project Description..........................................................................................2-1 Section 3: List of Commentors.........................................................................................3-1 Section 4: Response to Comments on the Draft EIR (September 2006).......................4-1 4.1 - Introduction......................................................................................................4-1 4.2 - Comment Letters and Responses....................................................................4-1 4.3 - State Agencies.................................................................................................4-7 4.4 - Regional Agencies.........................................................................................4-29 4.5 - County Agencies............................................................................................4-33 4.6 - Private Organizations and Persons................................................................4-59 4.7 - Planning Commission Hearing - October 5, 2006..........................................4-83 Section 5: Project Description..........................................................................................5-1 5.1 - Revisions to Draft EIR and Appendices...........................................................5-1 5.2 - Summary of Technical Studies and Other Information Prepared after the Release of the Draft EIR................................................................................5-16 ATTACHMENTS1 Attachment 1: Revised Traffic Report Attachment 2: Updated Natural Resources Impact Report Attachment 3: Revised Flood Study Attachment 4: Revised Lake Report Attachment 5: Revised Water Supply Assessment Attachment 6: Housing Needs Analysis Attachment 7: Urban Decay Study Attachment 8: Fiscal Impact Analysis 1 attachments are on the CD located inside the back cover of this Response to Comments document. West Ming Specific Plan - Draft EIR Response to Comments Purpose Michael Brandman Associates 1-1 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec01-Purpose.doc SECTION 1: PURPOSE The Draft Environmental Impact Report (EIR) (State Clearinghouse No. 2005051055) for the West Ming Specific Plan project was circulated for public review and comment beginning on August 31, 2006 and ending on October 14, 2006. In accordance with Section 15088 of the State of California Environmental Quality Act (CEQA) Guidelines, the City of Bakersfield, as the lead agency, has evaluated the comments received on the Draft EIR for the West Ming Specific Plan project and has prepared written responses to the comments received. The responses to the comments and other documents, including technical appendices and other information contained within the environmental record, together with the Draft EIR, constitute the final EIR for use by the Bakersfield City Council and other decision makers in their review of the West Ming Specific Plan project. This Response to Comments document is organized as follows: • Section 1 - Purpose • Section 2 - Project Description • Section 3 - List of Commentors. Provides a list of the agencies, organizations, and individuals that commented on the Draft EIR. • Section 4 - Response to Comments. Includes a copy of all of the letters received. This section also provides Response to Comments on environmental issues describing the disposition of the issues, explaining the EIR analysis, supporting the EIR conclusions, and/or providing information or corrections as appropriate. This section is organized with the responses to each comment letter following the corresponding letter. • Section 5 - Errata. Includes a list of all the revisions to the Draft EIR and new information to be included as part of the administrative record. West Ming Specific Plan - Draft EIR Response to Comments Project Description Michael Brandman Associates 2-1 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec02-Project Description.doc SECTION 2: PROJECT DESCRIPTION The project site is located in and adjacent to the southwestern portion of the City of Bakersfield. It encompasses approximately 2,182 acres generally located west of Buena Vista Road, north of Pacheco Road, south of Ming Avenue, and east of the proposed West Beltway alignment. Approximately 640 acres of the project site are located within the Bakersfield city limits and the remainder of the project site (1,542 acres) is located in unincorporated Kern County. The proposed project includes the development of a new community with residential, commercial, recreational, schools, and light industrial uses. The project includes a maximum of 7,450 residential units, 478,880 square feet of commercial (including office, service, and retail), 331,200 square feet of town center commercial and mixed use (including office, service, and retail), 1,135,000 square feet of special uses (light industrial, mineral and petroleum, public facilities, open space, parks, public transportation, office, and other uses permitted by the Specific Plan.). The proposed schools will be located within the residential neighborhoods of the project site. The proposed project includes a phasing plan that will be implemented over a 20-year time frame. The development will be phased so that adequate utilities are provided for each area of development. The existing agriculture and oil production activities will continue and be located adjacent to new developed areas of the Specific Plan until each area of the project site is developed. The project will require approval of annexation, General Plan amendments, specific plan, zone changes, development agreement, Federal Emergency Management Agency conditional and final letters of map revisions, and State Reclamation Board encroachment permit. In addition to these approvals, the project will require approval of parcel maps, tentative and final tract maps, conditional use permits, permits related to oil wells, and approvals for the proposed elementary and middle schools. The project sponsor has identified the following objectives for the proposed project: • Provide a master planned community with residential, commercial, and industrial development of sufficient scale to permit master-planning of infrastructure, parks, open space, and public services to achieve the greatest possible efficiencies and synergies; • Establish a new mixed use center as defined in the Metropolitan Bakersfield General Plan; • Provide a development in southwest Bakersfield that is a focal point of activity and includes a mix of land uses as identified in the Metropolitan Bakersfield General Plan; • Provide a full mix of land uses to support the project’s population; • Provide employment opportunities to assist in meeting the Kern COG employment growth projections for the City; West Ming Specific Plan - Draft EIR Project Description Response to Comments 2-2 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec02-Project Description.doc • Provide residential uses to meet the housing demand specified in the Metropolitan Bakersfield General Plan Land Use Element; • Provide development similar to and consistent with existing or approved development in southwest Bakersfield to maintain and enhance property values and enhance compatibility of neighborhood character; • Provide a range of housing types on the project site; • Provide a master plan development so that land uses are phased in a programmed manner coordinated with the provision of infrastructure and public improvements necessary to accommodate such growth; • Locate development to meet anticipated growth in areas of relatively lesser environmental sensitivity, accommodating growth while balancing environmental conditions; • Provide parks which satisfy park dedication requirements and meet recreational needs of local residents including both active and passive recreational facilities; • Locate a master planned community adjacent to major highway arterials to better promote efficient traffic flows and minimize traffic demand on local and collector streets; • Cluster as much housing as possible near major traffic arterials to minimize congestion, air quality, noise, and safety impact on collector and neighborhood streets; and • Promote growth in areas directed by the Metropolitan Bakersfield General Plan. West Ming Specific Plan - Draft EIR Response to Comments List of Commentors Michael Brandman Associates 3-1 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec03-List of Commentors.doc SECTION 3: LIST OF COMMENTORS A list of public agencies, organizations, and individuals that provided comments on the Draft EIR is presented below. Each comment letter has been assigned an alphabetical designation. Each comment within each letter has been assigned a numerical designation so that each comment could be crossed- referenced with an individual response. Responses follow each comment letter. A list of individuals that provided comments on the Draft EIR during the City of Bakersfield Planning Commission public hearing held on October 5, 2006, is also provided below. Commentor Author Code State Agencies State of California, Governor’s Office of Planning and Research, State Clearing House and Planning Unit - October 17, 2006 OPR State of California, Department of Water Resources - September 20, 2006 DWR State of California, Department of Transportation - October 10, 2006 CALTRANS-1 State of California, Department of Transportation - October 25, 2006 CALTRANS-2 State of California, Department of Conservation - October 16, 2006 CDC Regional Agencies San Joaquin Valley Air Pollution Control District - October 17, 2006 SJVAPCD County Agencies Kern County Roads Department, Resource Management Agency - September 21, 2006 RMA-1 Kern County Roads Department, Resource Management Agency - October 9, 2006 RMA-2 Kern County Water Agency - October 16, 2006 KCWA Kern County Superintendent of Schools - October 11, 2006 KCSS City Agencies City of Bakersfield, Development Services Department - September 19, 2006 DS Private Organizations and Persons Crimson Resource Management - October 5, 2006 CRM-1 Foothill Energy - October 16, 2006 FH Tejon Indian Tribe - September 27, 2006 TT Sierra Club, Gordon Nipp - October 5, 2006 SC-1 West Ming Specific Plan - Draft EIR List of Commentors Response to Comments 3-2 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec03-List of Commentors.doc Planning Commission Hearing - October 5, 2006 Sierra Club, Gordon Nipp - October 5, 2006 SC-2 Crimson Resource Management - October 5, 2006 CRM-2 Phillip Ryle - October 5, 2006 PR Commissioner McGinnis - October 5, 2006 CM Commissioner Tragish - October 5, 2006 CT West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-1 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc SECTION 4: RESPONSE TO COMMENTS ON THE DRAFT EIR (SEPTEMBER 2006) 4.1 - Introduction In accordance with Section 15088 of the California Environmental Quality Act (CEQA) Guidelines, the City of Bakersfield as the lead agency evaluated the comments received on the Draft EIR (State Clearinghouse No. 2005051055) for the West Ming Specific Plan Project and the comments received during the public hearing held on October 5, 2006 at the City of Bakersfield Planning Commission meeting and has prepared the following responses to the comments received. This Response to Comments document is part of the Final EIR for the project in accordance with Section 15132 of the CEQA Guidelines. 4.2 - Comment Letters and Responses The comment letters and responses are provided on the following pages. The letters follow the same organization as used in Section 3.0, List of Commentors. OPR-1 OPR PAGE1OF4 OPR PAGE2OF4 OPR PAGE3OF4 OPR PAGE4OF4 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-7 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc 4.3 - State Agencies State of California, Governor’s Office of Planning and Research, State Clearing House and Planning Unit - October 17, 2006 (OPR) Response to Comment OPR-1 Comment is noted, and it is acknowledged that the Draft EIR was distributed to selected state agencies for review. No specific comments on the Draft EIR were provided; therefore, no further response is necessary. DWR-1 DWR PAGE1OF4 DWR PAGE2OF4 DWR PAGE3OF4 DWR PAGE4OF4 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-13 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc State of California, Department of Water Resources - September 20, 2006 (DWR) Response to Comment DWR-1 As discussed on page 5.7-2 of the Draft EIR, a portion of the project site is located within a designated Federal Emergency Management Agency (FEMA) 100-year flood zone. The portion of the site immediately adjacent to the Kern River is located within the Kern River Designated Floodway (i.e., State of California Adopted Plan of Flood Control) which was established by the Department of Water Resources and adopted by the Reclamation Board. This portion of the site encompasses approximately 3.7 acres. It is noted that an encroachment permit from the Reclamation Board will be required with the construction of the proposed levee as well as any other improvements south of the levee and within the 3.7 acres area. The following is added to the end of Page 3-39 of the Draft EIR. State Reclamation Board Encroachment Permit The project will require an encroachment permit for the proposed extension of the existing levee as well as any other improvements within the existing Kern River Designated Floodway. The effects of implementing the proposed levee have been addressed in the Draft EIR, and the addition of the above action does not alter the conclusions of the Draft EIR. CALTRANS-1 PAGE1OF1 CALTRANS-1-1 CALTRANS-1-2 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-17 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc State of California, Department of Transportation - October 10, 2006 (CALTRANS-1) Response to Comment CALTRANS-1-1 A Draft EIR was provided to CALTRANS via distribution from the State Clearinghouse (please see the letter received from the California’s Governor’s Office of Planning and Research dated, October 17, 2006). As part of the Draft EIR, the Traffic Impact Study was included as Appendix L of the Draft EIR and was available for public review during the review period that began August 31, 2006 and ended on October 14, 2006. In accordance with CALTRANS request, McIntosh & Associates forwarded a copy of the revised Traffic Impact Study to CALTRANS District 6 on October 10, 2006. Please see Response to Comments on CALTRANS-2-1. Response to Comment CALTRANS-1-2 It is noted that CALTRANS has requested a response to their comments prior to staff’s recommendation to the Planning Commission and City Council. As is required by the California Public Resources Code Section 21092.5(a), the lead agency must provide any responses to public agency comments at least 10 days prior to certifying the EIR. CALTRANS-2 PAGE1OF1 CALTRANS-2-1 CALTRANS-2-2 CALTRANS-2-3 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-21 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc State of California, Department of Transportation - October 25, 2006 (CALTRANS-2) Response to Comment CALTRANS-2-1 Project generated traffic volumes utilized in the Traffic Report (Traffic Impact Study [TIS]) are based upon the KernCOG cumulative projects traffic model. Project volumes are approximated by comparing relative volumes contained in the With Project model and the Without Project model for each intersection within the project study area. The Traffic Impact Study that is in Appendix L of the Draft EIR has been modified to include the appendices that were referenced in the Traffic Impact Study as well as some modifications and clarifications of the information in the Traffic Impact Study (see Attachment 1 in this Response to Comments Document). The modifications and clarifications are specified in Section 5, Errata, of this Response to Comments and do not substantially alter the conclusions that are presented in the Traffic Impact Study. The revised Traffic Impact Study is the version that was sent to CALTRANS for review on October 10, 2006 and is currently available for public review at the City of Bakersfield Planning Department at 1715 Chester Avenue, Bakersfield, CA 93301. In comparing the model volumes at the intersection of White Lane and Old River Road, the difference in daily volumes between the two models equates to 6,000 vehicles average annual daily traffic (AADT). Assuming that the PM peak hour volumes are approximately one-tenth of the total AADT, this would equate to approximately 600 project-related trips during the PM peak hour. For the intersection of White Lane and Buena Vista Road, the comparison of the model volumes results in 21,600 AADT project vehicles and thus 2,160 project related PM peak hour trips. The TIS analyzed these intersections with 683 project-related trips at White Lane and Old River Road for the PM peak hour and 3,093 project-related trips at the intersection of White Land and Buena Vista Road. Therefore, the TIS conservatively analyzed project-related trips at these two intersections. In addition McIntosh & Associates, Inc. prepared a manual distribution analysis of the project related traffic for the traffic facilities immediately adjacent to the project vicinity so that the traffic volumes at the project-created intersections and entrances coincide with the total project trip generation volumes presented in the TIS. For traffic facilities not immediately adjacent to the project site, traffic generated by the project is approximated based on the KernCOG model runs as detailed above and in the TIS. Because the KernCOG model results provide only segment volumes and not individual turning movement volumes, this can result in unbalanced volumes when comparing intersections immediately to the project with those intersections not immediately adjacent to the project. Although these discrepancies can occur when comparing adjacent intersections’ turning movement volumes, the total project added volumes at the intersections not immediately adjacent to the proposed project are accurate based on the use of the KernCOG model results. These total project added volumes at individual intersections are adequate when determining the overall impact at the intersections at future year scenarios for calculation of the project’s share of vehicles utilizing those future year scenarios. West Ming Specific Plan - Draft EIR Response to Comments Response to Comments 4-22 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc Response to Comment CALTRANS-2-2 In addition to paying into the traffic fee program, as identified in the TIS, analysis was performed based on future cumulative traffic volumes at Year 2015 to identify required improvements at an assumed Opening Day scenario. It is the policy of the City of Bakersfield that all development projects must construct collector and arterial frontages of their respective projects to full half width improvements. Consistent with this policy, the West Ming Specific Plan’s various projects will be required to construct their frontage improvements as they develop regardless of whether or not these improvements are beyond minimum mitigation measures that are identified in the TIS. In addition to the half width improvements required for the frontage roadways, all collector and arterial roadways within the project will be required to be constructed by the development to full width standards regardless of whether or not those full width improvements are required to accommodate future project and non-project traffic. Improvements are required for adjacent intersections, including signalization, will also be constructed by the various portions of the project as they develop. Response to Comment CALTRANS-2-3 The KernCOG traffic model volumes indicate that State Route 99/Ming Avenue interchange meet the criteria identified in the traffic impact study for detailed analysis. The following information is provided regarding the With Project and Without Project volumes. For the intersection of Ming Avenue at State Route 99 Northbound Ramps/Valley Plaza Entrance, the traffic model indicates a total of 48,700 vehicles AADT for the Without Project scenario and 48,900 vehicles for the With Project scenario. This equates to only a 20 vehicle increase at PM Peak attributable to the project. Approximating volumes from the model for the southbound ramps results in the project attributing 30 vehicle increase for the off ramp and a 30 vehicle increase for the on ramp at the PM peak hour. These PM peak hour traffic volumes are not considered substantial and are expected to result in a less than significant impact on the operation of the northbound and southbound ramps. CDC-1 CDC PAGE1OF2 CDC PAGE2OF2 CDC-1 CONT. CDC-2 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-25 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc State of California, Department of Conservation - October 16, 2006 (CDC) Response to Comment CDC-1 This comment regarding the feasibility of purchasing agricultural conservation easements to reduce the potential significant impact of the loss of agricultural land from project implementation is noted. Based on a discussion with the Central Valley Farmland Trust, there are no entities in Kern County to implement or manage agricultural land conservation easements. A governmental entity or land trust is needed to assume responsibility for holding and managing agricultural conservation easements to prohibit practices which would interfere with agricultural use of lands covered by easements. As a result, the purchasing of agricultural conservation easements to reduce significant impacts from the loss of agricultural land is not considered feasible at this time. Although agricultural conservation easements are not considered feasible, the following mitigation measure is added to reduce project impacts due to the conversion of agricultural land. With the implementation of the mitigation measure below, the project’s impact on agricultural land is reduced to the maximum extent feasible and will be substantially lessen; however, the level of impact due to the conversion of agricultural land would still be considered significant and unavoidable. The following mitigation is added to pages 5.1-12 and 6-2 under Mitigation Measures in the Draft EIR as well as pages 2-3 and 2-30 under the Mitigation Measures column for Impact 5.1.A and Impact 6.3.1.A in the Draft EIR: 5.1.A.1 Prior to recordation of a final subdivision map for urban development, or approval of a Site Plan Review by the City of Bakersfield, whichever occurs first, the applicant shall mitigate loss of 2,182 acres of agricultural lands by selecting one or more of the items described below. Agricultural land shall meet the definition of Prime Farmland or Farmland of Statewide importance established by the State Department of Conservation. In addition, as indicated at the same time described above, the applicant shall submit written verification of the applicant’s compliance of this mitigation to the Planning Director’s satisfaction. Completion of the selected mitigation measure, or with the Planning Director’s approval, a combination of the selected mitigation measures, can be on qualifying agricultural land within the San Joaquin Valley (San Joaquin, Stanislaus, Merced, Fresno, Madera, Kings, Tulare, Kern) or outside the San Joaquin Valley with written evidence that the same or equivalent crops can be produced on the mitigation land. • Funding and purchase of agricultural conservation easements. Such easements shall be managed and maintained by an appropriate entity. • Purchase of credits from an established agricultural farmland mitigation bank. • Contribution of agricultural land or equivalent funding to an organization that provides for the preservation of farmland in California. West Ming Specific Plan - Draft EIR Response to Comments Response to Comments 4-26 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc • During the life of the project, if the City of Bakersfield or other responsible agency adopts an agricultural land mitigation program that provides equal or more effective mitigation than measures listed above, the applicant may choose to participate in that alternate program to mitigate loss of agricultural land impacts. Prior to participation in the alternate program, the applicant shall obtain written approval from the City of Bakersfield agreeing to the participation, and the applicant shall submit written verification of compliance with the alternate program at the same time described above in the first paragraph. The mitigation provided above shall be completed as lands within the project are developed such that mitigation will occur at least contemporaneously with the development of such lands. Response to Comment CDC-2 As identified on page 3-28 in the Draft EIR, the project will be developed in phases over an approximate 20-year period. Grading within the Specific Plan area would occur as development is proposed and implemented. Therefore, the existing agricultural activities will continue and be located adjacent to new developed areas of the Specific Plan until each area of the project site is developed. This will allow the continuance of the existing agricultural activities until there is a demand for the proposed project land uses. SJVAPCD-1 SJVAPCD-2 SJVAPCD PAGE1OF2 SJVAPCD-3 SJVAPCD-4 SJVAPCD-4 CONT. SJVAPCD PAGE2OF2 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-29 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc 4.4 - Regional Agencies San Joaquin Valley Air Pollution Control District - October 17, 2006 (SJVAPCD) Response to Comment SJVAPCD-1 With respect to separating out the annual emissions from each land use category listed in Table 5.2-1, the approach utilized in the air study of individual URBEMIS model runs for each year of construction and operation using the current templates was prepared based on SJVUAPCD discussions and guidance. As stated in the approved protocol, the analysis was performed in accordance with Guide to Assessing Air Quality Impacts (GAMAQI), where the sum of all project- related area and indirect source emissions were compared to ROG and NOx significance thresholds. The individual URBEMIS runs that show the separation by land use are provided as an appendix to Appendix C of the EIR. Response to Comment SJVAPCD-2 The comment is noted. There is a discrepancy between Table 5.2-5 of the Air Quality Assessment and Table 1 of Appendix VI of Appendix C of the EIR. The data in Appendix VI of Appendix C of the EIR reflect higher agricultural related emissions that the numbers provided in the Air Quality Assessment text (and utilized in the total emissions tables). Table 5.2-5 of the EIR is correct. Response to Comment SJVAPCD-3 As noted in Response to Comment SJVAPCD-1 and as in the approved protocol, the Air Quality Assessment was performed in accordance with SJVAPCD GAMAQI. GAMAQI states that project operations should be evaluated for area source, indirect source, and stationary sources impacts at the time at which construction is complete and the project is occupied with its intended use. For the West Ming Specific Plan project, it is estimated that the site will be occupied with its intended use at 2027. The Air Quality Assessment provides emission totals from the entire intermediate period (from start of construction until buildout) in Appendix C. Emission totals at buildout (and for each year throughout buildout) exceed District significance thresholds of 10 tons per year of reactive organic gases (ROG) and oxides of nitrogen (NOx), which is the purpose of the additional mitigation measures that are proposed to reduce impacts to less than significant. The area source, stationary source, indirect source, and the construction phase emissions were summed annually to determine the maximum impact year for which complete (ROG), (NOx), and PM10 mitigation is proposed to reduce these emissions to zero. Response to Comment SJVAPCD-4 The applicant has entered into an agreement with SJVAPCD and has funded the agreement to allow the mitigation to be realized this year. RMA-1 PAGE1OF1 RMA-1-1 RMA-1-2 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-33 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc 4.5 - County Agencies Kern County Roads Department, Resource Management Agency - September 21, 2006 (RMA-1) Response to Comment RMA-1-1 The version of the Traffic Report in Appendix L is a previous version of the report, and there were modifications that were made in an updated Traffic Report. This updated Traffic Report is provided in Attachment 1 in this Response to Comments document. The modifications that were provided in the updated Traffic Report included (1) revised fee summaries on Page 36 and Tables 6 and 10 of the Traffic Report, (2) the appendices to the Traffic Report, and (3) clarifications of when improvements are required. The modifications and clarifications are specified in Section 5, Errata, of this Response to Comments and do not substantially alter the conclusions that are presented in the Traffic Impact Study. Response to Comment RMA-1-2 The revised Traffic Report was sent to the County Roads Department for review on September 26, 2006 and is currently available for public review at the City of Bakersfield Planning Department at 1715 Chester Avenue, Bakersfield, CA 93301. As stated in Response to Comment RMA-1-1 and in Section 5, Errata, the modifications and clarifications that were included in the revised Traffic Report did not substantially alter the conclusions that were presented in the Traffic Report in Appendix L of the Draft EIR. RMA-2 PAGE1OF2 RMA-2-1 RMA-2-2 RMA-2-3 RMA-2-4 RMA-2-5 RMA-2-6 RMA-2 PAGE2OF2 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-37 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc Kern County Roads Department, Resource Management Agency - October 9, 2006 (RMA 2) Response to Comment RMA-2-1 The Traffic Impact Study does not assume full buildout will occur of Westside Parkway and West Beltway by the year 2015. These facilities are indicated on KernCOG’s cumulative model year run for the year 2030, which was utilized to analyze the project impact at full buildout of the project. An additional analysis year scenario was performed for the year 2015 to identify required improvements at year 2015. With respect to these facilities, this additional analysis scenario merely identifies the minimum improvements that would be required at their interchanges with existing roadways at the time of the construction of the interchanges. Response to Comment RMA-2-2 In accordance with the City of Bakersfield’s ordinance regarding the Regional Traffic Impact Fee (RTIF) program, the project’s share of the RTIF shall be the fixed rate unless the project produces trips equivalent to or greater than that of what is considered a Major Retail Project, as defined in the current Methodology for Independent Assessment of Regional Impacts. Per City ordinance, the project share for the West Ming Specific Plan project is to be calculated in accordance with the current methodology for fee calculation of a Major Retail Project. The required fee calculation is provided in Table 10 of the revised Traffic Impact Study and included in the revised Appendix L and attached to this Response to Comments document. In addition to the fee calculation which is based on the KernCOG 2020 model as required, impact analysis is performed at year 2030. If the improvements identified in the RTIF are not sufficient to mitigate project impacts at year 2030, than additional mitigation measures are identified. Those additional mitigation measures along with the project’s pro rata share of the cost of those additional measures are identified in Table 6 of the revised Appendix L attached to this Response to Comments document. The total impact fees of page 36 of the TIS are combination of both the calculated regional fee and the project’s pro rata share of the costs to provide the additional improvements required to mitigate both the project and the cumulative project impacts at year 2030. Response to Comment RMA-2-3 The comment is noted in regard to the Institute of Engineers (ITE) Trip Generation’s Manual Fitted Curve Equation and the Average Rate; however, this should have no significant affect on the results presented in the TIS. The ITE Trip Generation Handbook, A Recommended Practice, recommends to choose between the regression equation (fitted curve) or the weighted average rate based on which plot line tests fits the data points at the size of the independent variable for this project. This choice is to be made when other criteria for choosing one method over the other method does not result in a clear preference. Upon inspection of the data plots for ITE Code 210, the data points at the size of the independent variable for the various groups of residential products within the project are scattered on both side of both plot line plots representing the fitted curve and the average rate. Since this dispersion of the representative data points also does not result in a clear preference, the proposed trip West Ming Specific Plan - Draft EIR Response to Comments Response to Comments 4-38 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc generation for the project was approximated taking the average of the traffic volumes calculated by the two different methods. This methodology is also consistent with the remaining ITE codes used in the TIS analysis. Response to Comment RMA-2-4 The comment is noted regarding the volume to capacity (V/C) ratios; however, this should have no significant affect on the results presented in the TIS. The mitigation measures identified for project impacts at year 2030 do not include any two lane undivided roadways. Therefore, the V/C ratio calculations used to determine the resulting levels of service (LOS) after the proposed mitigation required to reduce the project’s impacts to less than significant are consistent with the comment. It should also be noted that although there are two lane roadways identified in Table 9 of the TIS for non-project impacts; the City of Bakersfield’s policy that all development projects construct collector and arterial frontages of the respective project to full half-width improvements. Therefore, all other projects contributing to the cumulative future impacts will be required to build their respective frontages as they develop, which will contribute to the mitigation of the cumulative impacts. Consistent with the City’s policy, the West Ming Specific Plan project will be required to construct the frontage roadways; collector and arterial roadways within the project will be required to be constructed by the development to a full width standards regardless of whether or not those full width improvements are required to accommodate future project and non-project traffic. It should also be noted that the majority of arterials in the vicinity are included in the RTIF program to provide for two additional lanes. Because of these factors and policies, it is unlikely that any two land roadway will remain beyond its requirement for expansion. Response to Comment RMA-2-5 The comment is noted. The TIS scope for facilities requiring LOS impact analysis was developed in accordance with City policy. The comment incorrectly implies that the calculation of the RTIF was prepared for only facilities that serve 50 or more project trips. Please refer to Table 10 of the revised TIS (Appendix L as attached to this Response to Comments document) in which the Regional Impact Fees are calculated for all facilities currently included in the current RTIF list regardless of the magnitude of trips. This has to be accomplished in order to ensure that the project pays its pro rata share into the RTIF program. Detailed analysis is identified for facilities in accordance with the thresholds identified in the TIS and EIR so as to identify any additional mitigation required above and beyond that included in the RTIF program due to project impacts. The minimum thresholds that were identified are those that would be required to actually affect the analysis at those particular service levels. Additionally, the fee calculations provided in the RTIF were calculated in accordance with the City’s ordinance. West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-39 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc Response to Comment RMA-2-6 Please refer to Response to Comments RMA-2-2 and RMA-2-5 regarding the project’s fee contribution to the RTIF program. KCWA PAGE1OF4 KCWA-1 KCWA-2 KCWA PAGE2OF4 KCWA-2 CONT. KCWA-3 KCWA-4 KCWA-5 KCWA-6 KCWA-7 KCWA-8 KCWA PAGE3OF4 KCWA-8 CONT. KCWA-9 KCWA-10 KCWA-11 KCWA PAGE4OF4 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-45 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc Kern County Water Agency - October 16, 2006 (KCWA) Response to Comment KCWA-1 The comment is noted that the applicant, Castle &Cooke, has entered into an agreement (dated June 7, 2006) with the Kern County Water Agency to exchange land from south of the Kern River for land north of the Kern River, which will assist in buffering open space areas, groundwater recharge, and water production. Response to Comment KCWA-2 The comment is noted that the comments provided in the letter submitted by the Kern County Water Agency on the West Ming Specific Plan Draft EIR are based upon their understanding of the City’s water balance. Response to Comment KCWA-3 This comment regarding the City of Bakersfield’s estimated annual water consumption is noted, and the first sentence on page 3 of the Water Supply Assessment (WSA) in Appendix M of the Draft EIR is revised as follows: Without specific information as to the different service entities, a mass water balance within the City of Bakersfield area consists of the following: population 295,893 (KernCOG); assuming 325 gallons per capita per day, an estimated annual water consumption of 107, 700 acre-feet per year (afy); average annual surface water supplies that are treated and directly delivered to municipal users total approximately 30,000 afy with the remaining 77,700 afy being supplies by groundwater pumping. Response to Comment KCWA-4 The comment regarding ID4 water supply from the State Water Project is noted. Section VI (B) on page 11 is revised as follows: Kern River is not the only surface water source available to the City of Bakersfield; water is also obtained from the Improvement District (ID) #4. ID #4 was formed by resolution adopted by the Board of Directors of the KCWA on December 21, 1971 to provide supplemental water supply for portions of the Bakersfield metropolitan area through implementation of water from the State Water Project (SWP). Approximately 65 percent of the district is within the limits of the City of Bakersfield. The City service area covers about 20 percent to 30 percent of ID #4. Waters made available to the City of Bakersfield from ID #4 are only permitted for use within the actual boundaries of the District. Currently, ID #4 has an annual entitlement of 93,546 acre feet. Actual allocations from the SWP in any year are subject to hydrologic variability of the State Project. Response to Comment KCWA-5 This comment regarding the use of Kern River water supply is noted. The first paragraph in Section VI (A) is revised as follows: West Ming Specific Plan - Draft EIR Response to Comments Response to Comments 4-46 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc Unlike groundwater supplies, river flows have a high degree of variability. In order to account for the hydrologic variability of the Kern River, statistical analysis of flow data typically includes probability of occurrence graph along with a bar chart based on annual volume. Historic Kern River flow data was obtained from the California Department of Water Resource (DWR) Division of Flood Management Data Exchange Center website and the Kern County Watermaster. The flow measuring point of DWR is downstream of Lake Isabella and the site ID for this location is KRB. The Kern River Watermaster records flow diversions at a site known as the First Point of Measurement, rebuilt in 1981. Response to Comment KCWA-6 TH following footnote is added to Table 5 of the Water Supply Assessment: 4. If Kern River supplies are reduced by 70,000 af, the total amount of surplus water supply decreases to 31,000 af. Response to Comment KCWA-7 To clarify the information in the WSA, when excess Kern River water is available of use by the City of Bakersfield, this source may be redirected to the 2,800 acres located along the banks of the Kern River where the water is allowed to percolate back into the ground through old river channels and spreading basin. The City’s current operational philosophy for the area is expected to continue into the future and will be modified as needed so that the City can continue to provide reliable water to its users. Response to Comment KCWA-8 To clarify the information in the WSA, the Kern River water supply (140,000 af) identified on page 5 of the WSA is intended to show how this source could be used to meet future demands of the City. The City recognizes that recharge operations at the Kern River Channel and the 2,800 acres are governed by infiltration rates and contractual recharge agreements with other agencies. Since this volume of water is less than the maximum recharge capability of the Kern River Channel and the 2,800 acres, it is conceivable that this entire entitlement could be used to replenish the groundwater bank if storage space is available Response to Comment KCWA-9 This comment regarding recharge and recovery operations for the 2,800-Acres is noted. The following is added after the second paragraph in Section V (C) of the WSA in Appendix M. West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-47 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc 2800 Acres Recharge Facility Operations Calendar Year Spreading (AF) Losses (AF) Recovery (AF) Groundwater Storage (AF) 1999 0 0 6,741 205,632 2000 0 0 3,426 202,206 2001 64 0 9,227 193,043 2002 156 0 14,084 179,115 2003 89 0 8,416 170,788 2004 144 0 14,092 156,840 2005 32,573 1,953 2,860 184,600 Notes: 1. Source: 2005 City of Bakersfield Urban Water Management Plan 2. Spreading and loss data sets area current through 7/31/2006 with recovery data current through 6/30/2006. Response to Comment KCWA-10 To clarify the information in the WSA, the reclaimed water volume specified on page 9 of the WSA documents the amount of water that is typically generated from this source on average and does not imply that the City is dependent on complete utilization of this resource. In all water balance investigations included within the WSA, reclaimed water utilization is limited to 50 percent of the total wastewater generation, which is less than the current reclaimed water utilization. Use of this resource to meet irrigation needs of cropped farmland is consistent with the City’s existing disposal practice for this water source and does not qualify as double counting because the groundwater wells that are typically used for irrigating are turned off. Response to Comment KCWA-11 In accordance with CEQA Guidelines Section 15130(1)(B), the WSA evaluated the cumulative impacts utilizing a summary of growth projections contained in the KernCOG regional growth forecast adopted in April 2002. These adopted KernCOG projections described and evaluated regional and area-wide conditions contributing to cumulative impacts. The population projections account for all estimated growth that is to occur within the Metropolitan Bakersfield area, irrespective of where within the Metropolitan Bakersfield area that this growth is to occur. As stated on page 33 of the WSA, the growth projections utilized and incorporated all existing, planned, and reasonably foreseeable future projects within the Metropolitan Bakersfield area including but not limited to the specific projects identified on the list attached as Appendix D of Appendix M of the Draft EIR. Thus, the growth projections included growth from all projects referenced in the KCWA letter. KCSS PAGE1OF2 KCSS-1 KCSS PAGE2OF2 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-51 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc Kern County Superintendent of Schools - October 11, 2006 (KCSS) Response to Comment KCSS-1 This comment regarding the provision of child care is noted. According to the West Ming Specific Plan, there are specific uses allowed within the proposed zoning designations on the project site. Day care facilities are a permitted use in a few of the proposed zones on the project site. The specific uses that will be constructed in the proposed zones on the project site is not known at this time. CRM-1 PAGE1OF6 CRM-1-1 CRM-1-1 CONT. CRM-1 PAGE2OF6 CRM-1-1 CONT. CRM-1 PAGE3OF6 CRM-1-1 CONT. CRM-1 PAGE4OF6 CRM-1 PAGE5OF6 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-59 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc 4.6 - Private Organizations and Persons Crimson Resource Management - October 5, 2006 (CRM-1) Response to Comment CRM-1-1 An updated Natural Resources Report was prepared by WZI, Inc. on October 26, 2006, and is included in Attachment 2 of this Response to Comments document. As part of the updated report, WZI, Inc., reviewed the report prepared by Ryder Scott Company, which was submitted by CRM. WZI concurs that in light of current conditions the valuation conclusions included in the Ryder Scott Company report are reasonable and as of January 1, 2006 the value of well 52X-10 is $1,685,000. To ensure that the proposed project does not impact the known resources in the area of Crimson 52X- 10 well, the project applicant is proposing to revise the Zoning Districts map (Exhibit 3-4) in the Draft EIR by including a 2.5-acre (330 feet by 330 feet) in the northwestern portion of the project site to West Ming Drill Island District (WM - DI) zone from the proposed West Ming One Family Dwelling Zone (WM-R1). The WM-DI zone is proposed to have a westernmost boundary located 115 feet, a northernmost boundary located 165 feet, a southernmost boundary located 165 feet, and an easternmost boundary located 215 feet from the center of Crimson 52X-10 well. To reflect this change in the proposed project, the following is added on page 3-12 in the Draft EIR above Table 3-3. West Ming-Drill Island (WM-DI). This zone allows for oil or gas exploration and development, production, storage, transmission, and treatment, and any accessory or ancillary equipment structure or facilities thereto, In addition, Table 3-3 on page 3-12 of the Draft EIR is revised so that WM-R1 is 445.5 acres and WM-DI is added as 2.5 acres. Furthermore, Exhibit 3-4 in the Draft EIR is hereby revised to reflect the proposed WM-DI zone. According to the project applicant, CRM and Castle & Cooke have entered into an agreement in relation to the continuing operation of well 52X-10. The terms of the agreement in principle are as follows: • Castle & Cooke will provide CRM with an exclusive easement over a 2.5 acre site (330 feet x 330 feet) and Castle & Cooke have the right to reconfigure the 2.5 acre site as development occurs within the area of well 52X-10 as long as CRM’s operations are not adversely affected; • Castle & Cooke will provide CRM with permanent access to the site; • Castle & Cooke has the right to relocate roadways to the site as the area around well 52X-10 develops; • Castle & Cooke will apply to rezone the 2.5 acre site as DI, Drilling Island; • The easement will terminate upon abandonment and plugging of the well; West Ming Specific Plan - Draft EIR Response to Comments Response to Comments 4-60 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc • CRM will provide a surface waiver over the balance of the 20 acre site; • Where feasible, Castle & Cooke have the right to relocate pipelines which fall outside of the 2.5 acre site. Where feasible, pipelines will be re-routed into the public right-of-way; • Castle & Cooke will stub utilities to the site when utilities become available; and • Castle & Cooke will construct a masonry wall around the 2.5-acre site as the area is developed. The addition of the WM-DI zone will not result in new environmental impacts that we not previously discussed in the Draft EIR. The potential effects on mineral resources and a mitigation measure were previously provided on page 1-6 in the Draft EIR. The mitigation measure will reduce potential impacts on Crimson 52X-10 well from future land uses developed in the adjoining WM-R1 zone. FH PAGE1OF3 FH-1 FH-2 FH PAGE2OF3 FH-2 CONT. FH-3 FH-4 FH PAGE3OF3 FH-4 CONT. FH-5 FH-6 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-65 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc Foothill Energy - October 16, 2006 (FH) Response to Comment FH-1 The comment is noted that in the Initial Study prepared for the proposed project, it was determined that with the implementation of the proposed project impacts to mineral resources would be less than significant with mitigation. As the commentor notes, the City of Bakersfield Planning Department determined that there is the potential for mineral resources; specifically the East Gosford Area of the Canfield Ranch Oil Field could be impacted by project implementation. The proposed project does include a Special Use District that would all continued oil well production either by right or by a conditional use permit, depending on the distance of the facilities to project related structures. Response to Comment FH-2 The comment is noted that the proposed project includes Mitigation Measure MR-1, which reduces impacts to mineral resources to less than significant. Response to Comment FH-3 Please see Response to Comments CRM1-1 regarding the update to the Natural Resources Report prepared by WZI, Inc. According to the revised Natural Resources Report located as revised Appendix H in this Response to Comments document, Foothill Energy LLC’s well may have remaining productive lives of between 6 and 35 years. According to WZI, the proposed project would not result in the loss of availability of known mineral resources nor in the loss of availability of a locally important mineral resource recovery site with the implementation of a petroleum integration plan as referenced in a mitigation measure on page 1-6 of the Draft EIR. The petroleum integration plan is anticipated to include (1) reservation of presently existing well sites, (2) provision for future drill sites on development maps, (3) provide for continued access and drilling rights to the sites, and (4) design the subdivisions in such a manner to ensure regulatory compliance with local, regional, and state setback and siting requirements regarding development of oil and gas producing property. Response to Comment FH-4 The comment is noted that through the EIR process it was determined that there is the potential for hazards and hazardous materials impacts to occur in relation to the transportation, use, storage, and disposal of hazardous materials associated with the oil field activities. As the commentor notes, mitigation measures have been incorporated into the proposed project to reduce these potential impacts to less than significant (see Mitigation Measures 5.6.G.1 through 5.6.G.7 of Section 5.6, Hazards and Hazardous Materials of the EIR) IT is noted that Foothill Energy complies with all federal, state, and local laws and that as an operator of the Canfield Ranch Oil Field facility since 2004, Foothill Energy has not had a spill or related environmental incident. It is noted that Foothill Energy fully supports the mitigation measures proposed in the EIR except for 5.6.G.1 because this measure should not refer to idle wells because an operator could leave a well idle and re-enter in the future. Therefore, Mitigation Measure 5.6.G.1 is revised as follows: West Ming Specific Plan - Draft EIR Response to Comments Response to Comments 4-66 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc 5.6.G.1 Prior to recordation of a final map, any abandoned wells within the grading envelope shall have the surface area returned to its natural condition including but not limited to cleaning all oil, oil residues, drilling fluids, mud and other substances; leveling, grading or filling of sumps, ditches, and cellars including removal of all lining material to the satisfaction of the Department of Oil, Gas and Geothermal Resources. Response to Comment FH-5 The comment is noted that Foothill Energy is currently evaluating the idle wells on the project site and that any wells that are to be abandoned will be abandoned in accordance with the standards set forth by the Department of Oil, Gas, and Geothermal Resources (DOGGR) and the wells that continue to operate on the site will be subject to DOGGR’s program for monitoring and managing idle wells. TT PAGE1OF2 TT-1 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-69 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc Tejon Indian Tribe - September 27, 2006 (TT) Response to Comment TT-1 The comment is noted that the Tejon Indian Tribe would like to be on the project site during any future archeological survey and any surface disturbance. In accordance with Mitigation Measure 5.4.A.1, a Native American monitor will be onsite during construction activities at the location of the 10 cultural sites and 26 isolates that were previously recorded on the site. SC-1 PAGE1OF4 SC-1-1 SC-1-2 SC-1 PAGE2OF4 SC-1-2 CONT. SC-1-3 SC-1-4 SC-1-5 SC-1 PAGE3OF4 SC-1-5 CONT. SC-1-6 SC-1-7 SC-1-8 SC-1-9 SC-1 PAGE4OF4 SC-1-10 SC-1-11 SC-1-12 SC-1-13 SC-1-14 West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-75 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc Sierra Club - October 5, 2006 (SC-1) Response to Comment SC-1-1 The potential to mitigate project-related agricultural resources impacts by identifying a government entity or land trust to manage a conservation easement (i.e., designed to prohibit practices that would interfere with agricultural activities) was considered. However, this mitigation was rejected as it was deemed not feasible. Specifically, to date, no government entity or private land trust has created any program in Kern County to implement the acquisition or management of conservation easements or any other vehicle by which mitigation of farmland impacts can be achieved. Without such a program, such mitigation is not feasible. Please see response to comment CDC-1 regarding conservation easements for agricultural land and a mitigation measure that has been included to reduce impacts on agricultural land to the maximum extent feasible and substantially lessen the impact. However, the impact due to the conversion of agricultural land would still be considered significant and unavoidable. Response to Comment SC-1-2 The proposed project includes the establishment of land uses within a Specific Plan. The detailed design of the proposed structures as well as the lighting associated with the structures has not been prepared because the project applicant is not requesting approval of site-specific development plans. The site-specific development plans will be part of future requested approvals. Lighting is discussed in the Initial Study/Notice of Preparation (IS/NOP) prepared for the West Ming Specific Plan (Appendix A of the Draft EIR). As discussed in the IS/NOP, the proposed project would be required to comply with the mandatory obligations relating to lighting and glare contained in the City’s Municipal Code. Compliance with the Municipal Code is expected to result in less than significant light and glare impacts. Response to Comment SC-1-3 The primary lighting sources associated with the proposed project will be from the proposed commercial and industrial uses that are located in the vicinity of South Allen Road and Buena Vista Road. Habitat in the vicinity of the West Ming Specific Plan is located north of Ming Avenue, west of the project site and west of West Beltway, and south of the Union Pacific Railroad. Ming Avenue will have a lighting system that provides adequate night lighting in accordance with the City of Bakersfield Municipal Code for vehicles. The proposed onsite uses adjacent to Ming Avenue will be low density residential, and these uses are not associated with substantial amount of lighting. Furthermore, a levee is proposed along the northern side of the future alignment of Ming Avenue to eliminate potential flooding on the project site from a 100-year frequency flood. The proposed levee will also provide an additional buffer between the project site and habitat north of the project site. The portion of the project site along the eastern boundary of the project site is planned for low- medium density residential and low density residential. Lighting systems associated with these uses will be required to comply with the City’s Municipal Code and would not cause significant lighting West Ming Specific Plan - Draft EIR Response to Comments Response to Comments 4-76 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc impacts west of the project site. The area south of the project site is currently in agriculture and planned to be developed with a master planned community. The proposed onsite uses which include low-medium residential, high-medium residential, special use district, and office-commercial are separated from the area south of the project site by the existing Union Pacific Railroad as well as the future extension of Pacheco Road. The areas east of the project site are currently developing or have been developed with residential uses; therefore, the project would not affect habitat in these areas. Since the project site is proposed to be separated from nearby habitat by existing and planned barriers such as roadways, levees, and railroads, the implementation of the proposed project would result in less than significant lighting impacts on habitat in the vicinity of the project site. Response to Comment SC-1-4 This comment regarding the documentation of measures to reduce air emissions is noted. As discussed on page 5.2-36, the project applicant has entered into an Air Quality Mitigation Agreement with the San Joaquin Valley Air Pollution Control District (SJVAPCD) to participate in a voluntary emission reduction program (see Mitigation Measure 5.2.C.2 and Appendix C of the Draft EIR). The applicant’s compliance with the Air Quality Mitigation Agreement will result in a reduction of ROG, NOx, and PM10 net emissions to net zero or in quantities to sufficient to fully mitigate the project’s air quality impacts to the extent that the development of the project will result in no net increase in criteria pollutant emissions which would otherwise exist without the development of the project, as verified by the SJVAPCD. Additionally, as noted on page 5.2-37 of the Draft EIR, the program provides for implementation of all feasible mitigation measures through smart growth design of the development. This could include the installation of turnouts and park and ride facilities if it is considered feasible and if Golden Empire Transit will service the project site. The agreement includes emission reduction design features such as: • Utilization of land use designs, which create walkable communities and encourage pedestrian travel; • Utilization of interconnecting sidewalks, walking paths, and/or bike paths in order to encourage travel by other means other than motor vehicle; • Utilization of appropriate landscaping to create reasonable shade canopies for streets, parkways, and parking areas; • Utilization of roadway designs, which enhance pedestrian safety by appropriate signaling, signage, and separation from traffic; • Design requirements, which incorporate natural gas hookups and electrical outlets on patios; and West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-77 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc • Design requirements, which prohibit the installation and use of wood burning stoves and wood burning fireplaces. Response to Comment SC-1-5 As provided in Section 5.2 of the Draft EIR, implementation of mitigation measure 5.2.C.2 will reduce ROG, NOx, and PM10 emissions to net zero. Annual construction phase, area source, indirect source, and existing agricultural emissions were summed form the project commencement to buildout to determine the year of maximum project emissions for the purpose of mitigation. Year 2026 represents the year in which maximum project-related emissions occur. Real, quantifiable, and verifiable mitigation at 2026 levels (inclusive of construction phase emissions) will be in place prior to the commencement of construction. Response to Comment SC-1-6 The proposed project will result in significant unavoidable impacts to three roadway segments and the project will cumulatively contribute to significant unavoidable impacts to two additional roadway segments (as reflected in Section 5, Errata, of this Response to Comments document). As outlined in Mitigation Measure 5.11.A.1 and Mitigation Measure 6.3.11.A.1, the project applicant will be required to participate in the Regional Transportation Impact Fee (RTIF) program and pay a proportional share for local mitigation improvements (those not covered by the RTIF). As discussed in Sections 5.11 and 6.3.11 of the Draft EIR, no additional measures to reduce potential impacts to less than significant along the roadway segments is feasible. A Transit-oriented Alternative is suggested by the commentor to reduce potential project and cumulative traffic congestion impacts. The transit that is suggested includes an area-wide light rail system. Currently, the public transportation that involves rail in the City of Bakersfield includes the Union Pacific and Burlington Northern/Santa Fe Railroad line that accommodates Amtrak service among cities within the Central Valley. No Metropolitan Bakersfield-wide light-rail system is provided, and the provision of a system for the proposed project is not feasible for the project applicant to implement. Furthermore, the west side of Bakersfield has been planned to include a substantial amount of low density residential which is not conducive for the implementation of a light-rail system because such a system accommodates areas with high densities. However, if the City and/or the County determines that a light-rail system is feasible to implement in the future, the project applicant has included a Special Use District in the Specific Plan that allows a future light-rail station adjacent to the existing railroad tracks on the southern boundary of the project site. The potential future light-rail location is illustrated on Exhibit 3-6 in the Draft EIR. Response to Comment SC-I-7 The Institute of Transportation Engineers’ (ITE) “Trip Generation Handbook, An ITE Recommended Practice” recommends to choose between use of the regression equation (fitted curve) or the weighted average rate based on which line plot best fits the data points at the size of the independent variable West Ming Specific Plan - Draft EIR Response to Comments Response to Comments 4-78 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc for the project. This choice is to be made when other criteria used for choosing one method over the other does not result in a clear preference. Upon inspection of the data plots for ITE Code 210, the data points at the size of the independent variable for the various groups of residential products within the project are scattered on both sides of both line plots representing the fitted curve and the average rate. Since this dispersion of the respective data points also does not result in a clear preference, the proposed trip generation for the project was approximated by taking the average of the traffic volumes calculated by the two different methods. The Trip Generation Handbook states, “When the Trip Generation data plot contains more than 20 data points and a regression curve and equation are provided, use of the regression equation is recommended. A regression equation with an R2 of at least 0.75 is preferred because it indicates the desired level of correlation between the trips generated by a site and the value measured for an independent variable.” For this ITE code (i.e. ITE code 210), there are approximately 350 data points, and the value of R2 is 0.96. Use of the fitted curve equation alone for calculating the Average Vehicle Trip Ends for the Single Family Residential land use, as recommended by the above excerpt, would result in a reduction to the trip generation volume of approximately 3,700 vehicle trip ends from the volume used in the study. This would result in a reduction of approximately 9 percent from the volumes used in the Traffic Report. The review comment questions the use of the fitted curve equation because the statistics on which it is based do not cover a project of this size.” However, both the Average Rate of 9.57 Trip Ends per Dwelling Unit and the fitted curve equation are based on the same statistics. It is not necessarily appropriate to use a method that may calculate a higher rate just because it results in a higher traffic volume. In fact for larger projects (greater than 500+/- units), the graph of the data points for this land use actually shows that the fitted curve line better represents the data points than does the average rate line. Additionally it should be noted that the Traffic Report did not apply a reduction to any of the trip generation volumes to account for internal capture rates within the project vicinity. From the Trip Generation Handbook “An internal capture rate can generally be defined as a percentage reduction that can be applied to the trip generation estimates for individual land uses to account for trips internal to the site.” Use of this reduction is appropriate for this type of multi-use development. Further as stated in the Trip Generation Handbook,”...a multi-use development is typically a single real-estate project that consists of two or more ITE land use classifications between which trips can be made without using the off-site road system. Because of the nature of these land uses, the trip-making characteristics are interrelated, and some trips are made among the on-site uses. This capture of trips internal to the site has the net effect of reducing vehicle trip generation between the overall development site and the external street system (compared to the total number of trips generated by comparable, stand-alone sites)”. These overall capture rates can be significant. Since the Traffic Report did not utilize these reductions, the actual rates used are even more conservative. West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-79 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc The trip generation rates used from the “Institute of Transportation Engineers - Trip Generation Manual” are based on studies of single-family detached housing only and do not include any reductions for proximity to commercial properties. An excerpt from the description contained in the ITE manual for this land use further details the basis of the trip generation in the Traffic Report. “Single-family detached units had the highest trip generation rate per dwelling unit of all residential uses, because they were the largest units in size and had more residents and more vehicles per unit than other residential land uses; they were generally located farther away from shopping centers, employment areas and other trip attractors than other residential land uses; and they generally had fewer alternate modes of transportation available, because they were typically not as concentrated as other residential land uses.” There is also no validation that these rates should be adjusted due to “very high summer temperatures” as the review comment claims. The ITE manual’s rate is based on 350 different studies performed throughout the United States and Canada. There are no suggested adjustments due to climate, whether they be hot summer temperatures in California or sub-zero temperatures in the northern states or Canada. As further supported by the information provided above, the trip generation average rate and fitted curve equation contained in the ITE manual for this land use, and utilized in the Traffic Report are appropriate. Furthermore, use of the KernCOG model is required by the local agencies for predicting future traffic volumes. This model is maintained by KernCOG using current projections of socio-economic data for the entire Metropolitan Bakersfield Sphere of Influence. Both data input and model results are reviewed and approved by the city and county. The cumulative projects model run prepared by KernCOG is mandated to be used by development projects requiring Traffic Impact Studies to help ensure consistent results between the studies with respect to future traffic projections. The KernCOG model prepared for the Metropolitan Bakersfield Regional Transportation Impact Fee Program is used by all the projects as well to help ensure that all proposed projects pay their fair share of transportation impact fees. Response to Comment SC-1-8 A housing needs analysis for the proposed project has been prepared to determine the need for the proposed 7,450 housing units in Metropolitan Bakersfield. In addition, the analysis evaluates the cumulative need of other housing projects and proposed project. The Housing Needs Analysis is summarized in Section 5, Errata, of this Response to Comments document and is located in its entirety in Attachment 6. The findings of this analysis are that the housing demand within Metropolitan Bakersfield based on officially adopted forecasts from Kern COG through 2030 and The Natelson Dale Group, Inc. 2040 projection based on countywide West Ming Specific Plan - Draft EIR Response to Comments Response to Comments 4-80 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc population growth rates forecasted by the California State Department of Finance show an over supply of 733 housing units in 2030 based on the number of housing units proposed within cumulative projects. This projected over supply represents approximately 0.7 percent of the growth, which is considered not significant. The 2040 housing demand projections show a substantial under supply (unmet demand) of 13,001 housing units, which represents 9.7 percent of the growth. Response to Comment SC-1-9 Electrical services to the proposed project will be provided by Pacific Gas & Electric’s (PG&E). Based on a discussion with Matt Coleman, PG&E’s land technician, PG&E has an adequate supply of electricity for the West Ming Specific Plan subdivision(s) on Buena Vista Road. PG&E will utilize proposed and existing road easements when installing electrical facilities for the project. Since the Specific Plan site is in the vicinity of PG&E’s existing substation, no new substations is expected to be required. In addition, no new power plants are proposed as PG&E has included this area in long- term plans for development. Response to Comment SC-1-10 The EIR was prepared in accordance with the CEQA Guidelines and examined air quality impacts in relation to the thresholds established by the City of Bakersfield and those presented in Appendix G of the CEQA Guidelines. In addition, please see Response to Comment SC-1-4. In addition, the project applicant, Castle & Cooke, currently builds all of its homes to meet the Comfortwise/Green standards. Specifically, this means that Castle & Cooke builds homes that are twenty percent more energy-efficient than the current California Title 24 mandatory requirements (as of October 2005) and utilize green building practices. The commentor identified the need for the proposed project to include solar photovoltaic panels for water heating. The use of these panels would reduce the amount of electricity used as well as reduce the amount of air emissions generated from the use of electricity. Please see response to comment SC-1-4 regarding the proposed mitigation measure to reduce air emissions to net zero. Please also see response to comment SC-1-9 regarding the availability of electricity in the project vicinity. Response to Comment SC-1-11 As discussed in Appendix C, Air Quality Assessment, of the Draft EIR, California’s agricultural ecosystem is centered in the San Joaquin Valley and covers 11 percent of its landscape. Farm products produced within this area include almonds, grapes, lettuce, cotton, grains, and vegetables. Most crop species respond positively to growth with increased atmospheric carbon dioxide. Over much of the United States, a number of crop models identify beneficial effects of elevated carbon dioxide. As stated in response to comment SC-1-9, a new power plant to serve the proposed project would not be required. PG&E has included the project area in their long-term plans for development. West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-81 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc Response to Comment SC-1-12 Please see Response to Comment SC-1-10 regarding the building practices of the project applicant. According to Castle & Cooke, homes built by them are 20 percent more energy-efficient than is required in California. Providing this higher level of energy-efficiency adds approximately $1,500 to $2,000 of additional direct construction costs. Solar photovoltaic systems at their current cost structure of approximately $20,000 are not considered to be affordable to many homebuyers even after considering the $2,000 federal tax credit that goes to buyers of the photovoltaic systems. Response to Comment SC-1-13 The West Ming Specific Plan includes a variety of residential uses. These uses include low density, low-medium density, high density, and high-medium density residential, The City of Bakersfield Housing Element includes various goals, objectives, and policies. The Housing Element includes five broad goals with objectives and policies that support each of the goals. Two of the housing goals are applicable to the proposed project. Goal 1 is to provide housing opportunities and accessibility for all economic segments of the City. This goal as well as the supporting objectives and policies discuss the availability of permanent housing for all social and economic segments of the community. As discussed above, the proposed project includes residential uses with various densities. These various uses could provide housing for a variety of social and economic segments of the City. Goal 2 is to provide and maintain an adequate supply of sites for the development of affordable new housing. This goal as well as the supporting objectives and policies discuss the provision of housing sites. The project is proposed on land that primarily has a current General Plan designation of Intensive Agriculture, 20-acre minimum, and the site does not include housing. Therefore, implementation of the proposed project could provide additional opportunities for the City to provide affordable new housing. Response to Comment SC-1-14 A Higher Density Alternative is suggested by the commentor to concentrate more land uses on less land and provide the opportunity to reduce the amount of development on prime farmland. The proposed project has been designed with high and medium density housing within several villages on the project site. Two of the villages are designed to accommodate densities exceeding 20.0 dwelling units per acre. Project design would accommodate medium densities in several other villages ranging from 5.75 dwelling units per acre and 12.0 dwelling units per acre. These proposed uses would concentrate residents on less land than the residential developments that exist east of the project site. One of the commentor’s suggested benefits of the High Density Alternative is to increase the feasibility of a public transportation system (i.e., light-rail). As discussed in Response to Comment SC-1-6, the west side of Bakersfield has been planned by the City to include a substantial amount of low density residential which is not conducive for the implementation of a light-rail system because such a system accommodates areas with high densities. West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-83 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc 4.7 - Planning Commission Hearing - October 5, 2006 Sierra Club, Gordon Nipp - October 5, 2006 (SC-2) Comment SC-2-1 Mr. Nipp requested that the conversion of 2,182 acres of agricultural land to urban land needs to be addressed and believes that there are feasible measures to reduce conversion impacts. Response to Comment SC-2-1 Please see Response to Comment SC-1-1 regarding the feasibility of reduce farmland conversion impacts. Comment SC-2-2 Mr. Nipp identified that a number of intersections and roadway segments would be lower than level of service C. He believes that it is unacceptable to lower the LOS to D or worse. The EIR should consider a transit-oriented development as an alternative. Response to Comment SC-2-2 Please see Response to Comment SC-1-6 regarding the transit-oriented alternative. Comment SC-2-3 Mr. Nipp believes that the EIR should address the “need” for the project. He refers to the Agricultural Conservation Policy No. 14 of the Metropolitan Bakersfield General Plan which requires evaluation of “demonstrated project need” when converting agricultural lands to a non-agricultural use. How many projects have been approved and not yet built? Is there a need for the project? Response to Comment SC-2-3 Please see Response to Comment SC-1-8 regarding the need of the proposed residential uses. Comment SC-2-4 The EIR should discuss the need to construct upgraded electric facilities and determine if there is a need to install solar photovoltaic panels to reduce impacts. Response to Comment SC-2-4 Please see Response to Comments SC-1-9 and SC-1-10 regarding electric facilities and solar photovoltaic panels, respectively. Crimson Resource Management - October 5, 2006 (CRM-2) Comment CRM-2-1 Crimson Resource Management (CRM) is concerned that the proposed project includes a change in zoning designation from Agriculture to Residential. This zone change would require additional West Ming Specific Plan - Draft EIR Response to Comments Response to Comments 4-84 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc measures for the oil operator if modifications to the existing well or if an additional oil well is installed. Response to Comment CRM-2-1 Please see Response to Comment CRM-1-1 regarding the proposed zoning district surrounding Crimson well 52X-10. Comment CRM-2-2 CRM would like to request a drilling island to accommodate the existing oil well as well as a potential for a second well. CRM would like public access to the well site(s) as development is proposed adjacent to the well sites. Response to Comment CRM-2-2 Please see Response to Comment CRM-1-1 regarding the proposed zoning district surrounding Crimson well 52X-10. Comment CRM 2-3 CRM is concerned that if single lot drilling islands are established, the permit status for drilling would change from Class 3 (no conditional use permit and special conditions) to Class 1 (conditional use and potentially special conditions). This change in permit status would result in extra costs as well as potentially environmental impacts on nearby residences. Response to CRM 2-3 Please see Response to Comment CRM-1-1 regarding the proposed zoning district surrounding Crimson well 52X-10. Comment CRM 2-3 CRM requests that a Drill Island designation be provided in the area around their existing zone and request that setbacks of future residential structures from the Drill Island designation be 500 feet. Response to CRM 2-3 Please see Response to Comment CRM-1-1 regarding the proposed zoning district surrounding Crimson well 52X-10. Phillip Ryle - October 5, 2006 (PR) Comment PR-1 Mr. Ryle recommends that the City prepare a plan to protect future oil and gas resources. Response to PR-1 The comment regarding a City-wide plan is noted and will be forwarded to the Planning Commission and City Council for their review. West Ming Specific Plan - Draft EIR Response to Comments Response to Comments Michael Brandman Associates 4-85 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec04-Responses to Comments12506.doc Commissioner McGinnis - October 5, 2006 (CM) Comment CM-1 Commission McGinnis asked if the preparer of the Natural Resources Impact Report talked to Crimson Resources Management regarding the valuation of oil resources. Response to CM-1 The Natural Resources Impact Report was prepared in November 2003 and oil prices have substantially changed since that time. Please see Response to Comment CRM-1-1 regarding an updated Natural Resources Impact Report prepared by WZI, Inc. in October 2006. The updated report, which is in Attachment 2 of this Response to Comments document confirms that the valuation estimates conducted by Ryder Scott Company in December 2005 was reasonable. Commissioner Tragish - October 5, 2006 (CT) Comment CT-1 Commission Tagish requested additional information on the liquefaction issue in the northwestern portion of the Specific Plan. Response to CT-1 Page 5.5-5 in the Draft EIR referenced a liquefaction analysis that was prepared by Soils Engineering, Inc. in April 2005. The liquefaction study confirmed that implementation of the proposed land uses in the northwestern portion of the project site could be significantly affected by liquefaction. In Appendix F, Geotechnical Feasibility Study/Geological Hazard Study, of the Draft EIR and mitigation measure 5.5.A.1 on page 5.5-6 in the Draft EIR, additional liquefaction studies are recommended to be conducted in the northwestern portion of the project site concurrently with submittal of a tentative subdivision map application or other development plan. This mitigation measure is appropriate for a Program EIR because more detailed liquefaction studies will be prepared as more detailed site planning with structure locations are provided. Comment CT-2 Commissioner Tragish requested that the economic impact of the proposed project be discussed. Response to Comment CT-2 An Urban Decay Study was prepared for the proposed project, summarized in Section 5, and included in Attachment 7 of this Response to Comments document. As discussed, the proposed West Ming Specific Plan project would not result in a significant impact in relation to urban decay. In addition, cumulative development within the Regional Trade Area would not result in significant impacts to existing or reasonably foreseeable retail development within the Primary Market Area. West Ming Specific Plan - Draft EIR Response to Comments Errata Michael Brandman Associates 5-1 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc SECTION 5:PROJECT DESCRIPTION The following are revisions to the Draft EIR for the West Ming Specific Plan and where a specific comment was submitted on a technical study, if warranted, the specific revision to the technical report is included as well. These revisions are minor modifications and clarifications to the Draft EIR and the technical reports, and the revisions do not change the significance of any of the environmental findings within the Draft EIR. The revisions are listed by page number. This Errata is separated into two sections: (1) revisions to the Draft EIR and Appendices based on comments received on the Draft EIR, and (2) summary of technical studies and other information that were prepared subsequent to the release of the Draft EIR. The new information provided in this Errata does not alter the conclusions contained within the Draft EIR, but provides additional explanations and clarifications of the impacts associated with the proposed project. 5.1 - Revisions to Draft EIR and Appendices Following are revisions to Draft EIR based on comments received during the public review period. In addition to revisions based on comments received during the public review period, Sections 2, 3, 5.11, 6.3.11, and 8.1 of the Draft EIR are provided to ensure consistency within the Draft EIR as well as the Traffic Report. The revisions to the traffic sections of the draft EIR are due to an oversight of not including the impacts and mitigation measures resulting from the project into the cumulative discussion. All of the revisions are minor modifications and clarifications to the Draft EIR and its associated appendices and do not change the significance of any of the environmental issue findings within the Draft EIR. The revisions are listed by page number. All additions to the text are underline (underlined) and all deletions from the text are stricken (stricken). Draft EIR Page 2-5 of the Draft EIR The determination at the end of the discussion for Impact 5.3.A is revised as follows. The level of significance was correctly addressed in Section 5.3 in the Draft EIR. Impact 5.3.A: The proposed project has a potential to result in a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service. (LTS) (S) West Ming Specific Plan - Draft EIR Errata Response to Comments 5-2 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc Page 2-10 of the Draft EIR The determination at the end of the discussion for Impact 5.5.A is revised as follows. The level of significance was correctly addressed in Section 5.5 in the Draft EIR. Impact 5.5.A: The proposed project could expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault; Strong seismic ground shaking; seismic- related ground failure including liquefaction; and landslides. (LTS) (S) Page 2-17 of the Draft EIR The determination at the end of the discussion for Impact 5.7.C is revised as follows. The level of significance was correctly addressed in Section 5.7 in the Draft EIR. Impact 5.7.C: The proposed project could alter the existing drainage pattern of the site or area in a manner which would result in erosion or siltation on- or off-site. (LTS) (S) Page 2-19 of the Draft EIR The following is added as the level of significance after mitigation for Impact 5.8.A. The level of significance after mitigation was correctly addressed in Section 5.8 in the Draft EIR. Less than significant. Page 2-19 of the Draft EIR The following is added as the level of significance after mitigation for Impact 5.8.B. The level of significance after mitigation was correctly addressed in Section 5.8 in the Draft EIR. Less than significant. Page 2-21 of the Draft EIR The determination at the end of the discussion for Impact 5.8.F is revised as follows. The level of significance was correctly addressed in Section 5.8 in the Draft EIR. Impact 5.8.F: Land uses outside the project site would be exposed to noise levels that result in a substantial permanent increase in ambient noise levels. (S) (LTS) West Ming Specific Plan - Draft EIR Response to Comments Errata Michael Brandman Associates 5-3 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc Page 2-22 of the Draft EIR The determination at the end of the discussion for Impact 5.9.C is revised as follows. The level of significance was correctly addressed in Section 5.9 in the Draft EIR. Impact 5.9.C: The project may potentially result in substantial adverse physical impacts associated with the provision or need of new or physically altered school facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives. (LTS) (S) Page 2-32 of the Draft EIR The determination at the end of the discussion for Impact 6.3.9.B is revised as follows. The level of significance was correctly addressed in Section 6.3.9 in the Draft EIR. Impact 6.3.9.A: The proposed project will increase the need for fire and police protection facilities; however, the project’s contribution to cumulative impacts would not be cumulatively considerable. (S) (LTS) Page 3-12 of the Draft EIR Table 3-3 is revised as follows: Zoning District Acreage WM - R1 44844.5 WM - R2 1,358 WM - R3 43 WM - CO 41 WM - GC 9 WM - TC 63 WM - DI 2.5 WM - SU 220 Source: West Ming Specific Plan 2006. Page 3-39 of the Draft EIR The following is added to the end of the page: State Reclamation Board Encroachment Permit The project will require an encroachment permit for the proposed extension of the existing levee as well as any other improvements within the existing Kern River Designated Floodway. West Ming Specific Plan - Draft EIR Errata Response to Comments 5-4 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc Page 5.1-12 and 2-3 of the Draft EIR The following mitigation measure is added to reduce project impacts due to the conversion of agricultural land. With the implementation of the mitigation measure below, the project’s impact on agricultural land is reduced to the maximum extent feasible and will be substantially lessen; however, the level of impact due to the conversion of agricultural land would still be considered significant and unavoidable: 5.1.A.1 Prior to recordation of a final subdivision map for urban development, or approval of a Site Plan Review by the City of Bakersfield, whichever occurs first, the applicant shall mitigate loss of 2,182 acres of agricultural lands by selecting one or more of the items described below. Agricultural land shall meet the definition of Prime Farmland or Farmland of Statewide importance established by the State Department of Conservation. In addition, as indicated at the same time described above, the applicant shall submit written verification of the applicant’s compliance of this mitigation to the Planning Director’s satisfaction. Completion of the selected mitigation measure, or with the Planning Director’s approval, a combination of the selected mitigation measures, can be on qualifying agricultural land within the San Joaquin Valley (San Joaquin, Stanislaus, Merced, Fresno, Madera, Kings, Tulare, Kern) or outside the San Joaquin Valley with written evidence that the same or equivalent crops can be produced on the mitigation land. • Funding and purchase of agricultural conservation easements. Such easements shall be managed and maintained by an appropriate entity. • Purchase of credits from an established agricultural farmland mitigation bank. • Contribution of agricultural land or equivalent funding to an organization that provides for the preservation of farmland in California. • During the life of the project, if the City of Bakersfield or other responsible agency adopts an agricultural land mitigation program that provides equal or more effective mitigation than measures listed above, the applicant may choose to participate in that alternate program to mitigate loss of agricultural land impacts. Prior to participation in the alternate program, the applicant shall obtain written approval from the City of Bakersfield agreeing to the participation, and the applicant shall submit written verification of compliance with the alternate program at the same time described above in the first paragraph. The mitigation provided above shall be completed as lands within the project are developed such that mitigation will occur at least contemporaneously with the development of such lands. West Ming Specific Plan - Draft EIR Response to Comments Errata Michael Brandman Associates 5-5 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc Page 5.6-9 of the Draft EIR Mitigation Measure 5.6.G.1 is revised as follows: 5.6.G.1 Prior to recordation of a final map, any abandoned and idle wells within the grading envelope shall have the surface area returned to its natural condition including but not limited to cleaning all oil, oil residues, drilling fluids, mud and other substances; leveling, grading or filling of sumps, ditches, and cellars including removal of all lining material to the satisfaction of the Department of Oil, Gas and Geothermal Resources. Page 5.12-2 of the Draft EIR The first sentence of the first full paragraph is revised as follows: Furthermore, the City has acquired water rights for Kern River flows for approximately 140,000 160,000 acre-feet per year. Page 3-38 of the Draft EIR The first bullet under General Plan Circulation Element Amendment is revised to reflect the correct portion of Renfro Road as follows: Extension of Ming Avenue as an arterial east west of Renfro Road to the proposed West Beltway. Page 5.11-6 of the Draft EIR The following intersection under the subheading “Roadway Network,” 1st bullet-point under Westside Parkway is revised as follows: Allen Road and Westside Parkway Eastbound Ramps - To provide an unsignalized intersection and the construction of one eastbound shared left turn and right turn lane, one northbound shared through and right turn lane, two southbound left turn lanes, one northbound through lane, and two southbound through lanes. Page 5.11-16 of the Draft EIR The following roadway segment is added under the heading “Year 2030 - Roadway Segment Analysis” after the third bullet: Ming Avenue - Old River Road to Gosford Road. Page 5.11-16 of the Draft EIR The following roadway segment is added under the heading “Year 2030 - Roadway Segment Analysis” after the fifth bullet: West Ming Specific Plan - Draft EIR Errata Response to Comments 5-6 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc Ming Avenue - New Stine Road to Old Stine Road. Page 5.11-17 and Page 2-23 of the Draft EIR The following required improvement is added to the mitigation measure “5.11.A.1,” within “Year 2015 - Intersections” in Table 2-1 on page 2-23 (2nd bullet) and on page 5.11-17 (2nd bullet) and is amended as follows (This improvement was previously identified as laneage “required to comply with City Ordinance at construction of the off-ramp.” However, this additional improvement is the laneage required to operate at an acceptable LOS when the signal is warranted): Allen Road and Westside Parkway Eastbound Ramps - Install signal and construct two southbound left turn lanes. Page 6-29 and 2-33 of the Draft EIR The following introductory paragraph under the mitigation measure “6.3.11.A.1” in Table 2-1 on page 2-33 and on page 6-29 under the heading, “Mitigation Measures” for “6.3.11.A.1” is revised as follows: Prior to the issuance of building permits, the project applicant shall participate in the Regional Transportation Impact Fee (RTIF) program as well as paying the proportional share for local mitigation improvements (those not covered by the RTIF). The intersection and roadway improvements that are required with cumulative development (i.e., the cumulative growth of “background-related” traffic with the addition and contribution of project-generated traffic) in the years 2015 and 2030 are as follows (Note: All project-generated impacts and corresponding mitigation measures/improvements are included in both Section 5.11 and Section 6.3.11). Page 6-24 of the Draft EIR The following intersection is listed twice under the heading “Year 2015 - Intersections,” therefore the reference to improvements required at AM Peak (third bullet from bottom of page) is removed as the required improvements at PM Peak (first bullet) govern as follows: Allen Roadway and Westside Parkway Westbound Ramps (AM Peak) Page 6-25 of the Draft EIR The following intersection is added under the heading “Year 2015 - Intersections,” and therefore, it is added after 2nd bullet on page, as follows: Coffee Road and Westside Parkway Eastbound Ramps (AM and PM Peak) Page 6-26 of the Draft EIR The following roadway segment is added under the heading “Year 2015 - Roadway Segments” after the 15th bullet on page, as follows: West Ming Specific Plan - Draft EIR Response to Comments Errata Michael Brandman Associates 5-7 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc Allen Road - Westside Parkway Westbound Ramps to Westside Parkway Eastbound Ramps. Page 6-27 of the Draft EIR The following intersection is added under the heading “Year 2030 - Intersections” after the fourth bullet on page, as follows: Ming Avenue and New Stine Road (PM Peak). Page 6-28 of the Draft EIR The following intersection is added under the heading “Year 2030 - Intersections” after the 14th bullet on page, as follows: McCutchen Road and Gosford Road (PM Peak). Page 6-29 of the Draft EIR The following roadway segment is added under the heading “Year 2030 - Roadway Segments” after the 13th bullet on page, as follows: Gosford Road - McCutchen Road to Taft Highway. Page 6-29 of the Draft EIR The following roadway segment under the heading “Year 2030 - Roadway Segments” (23rd bullet on page), is revised as follows: Panama Lane - Wible Road to NB SB 99 Ramps. Page 6-30 and 2-34 of the Draft EIR The following required improvement under the mitigation measure “6.3.11.A.1,” within “Year 2015 - Intersections” in Table 2-1 on page 2-34 (16th bullet on page) and on page 6-30 (19th bullet on page) is revised as follows: Panama Lane and West Beltway Southbound Ramps - Install signal and construct one westbound left turn lane, two southbound right turn lanes, and one eastbound through lane. Page 6-30 and 2-34 of the Draft EIR The following required improvement under the mitigation measure “6.3.11.A.1,” within “Year 2015 - Intersections” in Table 2-1 on page 2-34 (17th bullet on page) and on page 6-30 (20th bullet on page) is revised as follows: West Ming Specific Plan - Draft EIR Errata Response to Comments 5-8 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc Panama Lane and West Beltway Northbound Ramps - Install signal and construct two eastbound left turn lanes, one westbound right turn lane, one northbound right turn lane, and one westbound through lane. Page 6-30 and 2-34 of the Draft EIR The following required improvement is added to the mitigation measure “6.3.11.A.1,” within “Year 2015 - Roadway Segments” in Table 2-1 on page 2-35 (after 5th bullet) and on page 6-31 (after 5th bullet) as follows: Coffee Road - Westside Parkway Westbound Ramps to Westside Parkway Eastbound Ramps - Add two lanes. Page 6-32 and 2-36 of the Draft EIR The following required improvement is added to the mitigation measure “6.3.11.A.1,” within “Year 2015 - Roadway Segments” in Table 2-1 on page 2-36 (after 17th bullet on page) and on page 6-32 (after 13th bullet on page) as follows: Allen Road - Westside Parkway Westbound Ramps to Westside Parkway Eastbound Ramps - Add two lanes. Page 6-33 and 2-38 of the Draft EIR The following required improvement under the mitigation measure “6.3.11.A.1,” within “Year 2030 - Intersections” in Table 2-1 on page 2-38 (8th bullet on page) and on page 6-33 (16th bullet) is revised as follows: Stockdale Highway and New Stine Road - Construct one eastbound right turn lane, one eastbound left turn lane, one northbound right turn lane, and one southbound through lane. Page 6-33 and 2-38 of the Draft EIR The following required improvement under the mitigation measure “6.3.11.A.1,” within “Year 2030 - Intersections” in Table 2-1 on page 2-38 (9th bullet on page) and on page 6-33 (17th bullet) is revised as follows: Ming Avenue and Buena Vista Road - Construct one westbound right turn lane, one northbound turnthrough lane, and one southbound through lane. Page 6-35 and 2-40 of the Draft EIR The following required improvement under the mitigation measure “6.3.11.A.1,” within “Year 2030 - Roadway Segments” in Table 2-1 on page 2-40 (7th bullet) and on page 6-35 (7th bullet) is revised as follows: West Ming Specific Plan - Draft EIR Response to Comments Errata Michael Brandman Associates 5-9 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc Calloway Drive - Westside Parkway Eastbound Ramps to Stockdale Highway - Add two lanes, construct as divided highway. Page 6-36 and 2-41 of the Draft EIR The following required improvement under the mitigation measure “6.3.11.A.1,” within “Year 2030 - Roadway Segments” in Table 2-1 on page 2-41 (13th bullet on page) and on page 6-36 (12th bullet on page) is revised as follows: Panama Lane - Gosford Road to Ashe Road - Add four two lanes. Page 6-36 and 2-41 of the Draft EIR The following required improvement under the mitigation measure “6.3.11.A.1,” within “Year 2030 - Roadway Segments” in Table 2-1 on page 2-41 (14th bullet on page) and on page 6-36 (13th bullet on page) is revised as follows: Panama Lane - Ashe Road to Stine Road - Add two four lanes. Page 6-33 and 2-37 of the Draft EIR The following required improvement is added to the mitigation measure “6.3.11.A.1,” within “Year 2030 - Intersections” in Table 2-1 on page 2-37 (after 7th bullet) and on page 6-33 (after 7th bullet) as follows: Brimhall Road and Calloway Drive - Construct one southbound through lane. Page 6-33 and 2-38 of the Draft EIR The following required improvement is added to the mitigation measure “6.3.11.A.1,” within “Year 2030 - Intersections” in Table 2-1 on page 2-38 (after 3rd bullet on page) and on page 6-33 (after 11th bullet) as follows: Coffee Road and Westside Parkway Westbound Ramps - Construct one northbound left turn lane, one southbound right turn lane, one westbound left turn lane, and one southbound through lane. Page 6-33 and 2-38 of the Draft EIR The following required improvement is added to the mitigation measure “6.3.11.A.1,” within “Year 2030 - Intersections” in Table 2-1 on page 2-38 (before 4th bullet on page) and on page 6-33 (before 12th bullet) as follows: Coffee Road and Westside Parkway Eastbound Ramps - Construct one eastbound right turn lane, one southbound through lane, one northbound through lane, one northbound right turn lane, and southbound left turn lane. West Ming Specific Plan - Draft EIR Errata Response to Comments 5-10 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc Page 6-34 and 2-38 of the Draft EIR The following required improvement is added to the mitigation measure “6.3.11.A.1,” within “Year 2030 - Intersections” in Table 2-1 on page 2-38 (after 9th bullet on page) and on page 6-34 (before 1st bullet on page) as follows: Ming Avenue and Gosford Road - Construct one eastbound through lane, one westbound through lane, one northbound through lane, and one southbound through lane. Page 6-35 and 2-40 of the Draft EIR The following required improvement is added to the mitigation measure “6.3.11.A.1,” within “Year 2030 - Intersections” in Table 2-1 on page 2-40 (before 1st bullet on page) and on page 6-35 (after 2nd bullet on page) as follows: Panama Lane and Gosford Road - Construct one eastbound left turn lane, two eastbound through lanes, one eastbound right turn lane, one westbound left turn lane, two westbound through lanes, one northbound left turn lane, one northbound through lane, one northbound right turn lane, one southbound left turn lane, two southbound through lanes, and provide overlapping phase for westbound right turn lane. Page 6-30 and 2-33 of the Draft EIR The following required improvement is added to the mitigation measure “6.3.11.A.1,” within “Year 2015 - Intersections” in Table 2-1 on page 2-33 (after 5th bullet on page) and on page 6-30 (after 2nd bullet on page) as follows: Allen Road and Westside Parkway Eastbound Ramps - Install signal. Page 6-37 of the Draft EIR The following roadway segment under the heading “Level of Significance After Mitigation” on page 6-37 (1st bullet on page) is revised as follows: Ming Avenue from Ashe Road to New Stine Road (LOS B C to LOS D). Page 6-37 of the Draft EIR The following roadway segment under the heading “Level of Significance After Mitigation” on page 6-37 (4th bullet on page) is incorrectly listed here and is hereby deleted as follows: Calloway Drive from Westside Parkway Westbound Ramps to Stockdale Highway (LOS A to LOS E). Page 6-37 of the Draft EIR The following roadway segment under the heading “Level of Significance After Mitigation” on page 6-37 (5th bullet on page) is revised as follows: West Ming Specific Plan - Draft EIR Response to Comments Errata Michael Brandman Associates 5-11 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc Coffee Road from Brimhall Road to Westside Parkway Westbound Ramps (LOS A B to LOS ED). Page 6-30 and 2-34 of the Draft EIR The following roadway segment under the heading “Level of Significance After Mitigation” on page 6-37 (6th bullet on page) is revised as follows: Coffee Road from Westside Parkway Westbound Ramps to Westside Parkway Eastbound Ramps (LOS A B to LOS E). Page 8-1 of the Draft EIR The following bullet-point includes roadway segments that result in significant unavoidable cumulative impacts. These impacts were identified in Section 6.3.11 in the Draft EIR; however, they were not included in Section 8.1 of the Draft EIR. Therefore, the following is added after the 1st bullet-point on page 8-1, as follows: With the addition of background-related traffic, intersections and roadway segments will exceed the established thresholds for the Years 2015 and 2030 without project even with the improvements that are required for the Years 2015 and 2030 with project. After implementation of the recommended mitigation measures, cumulative projects (including the proposed project) would result in the degradation of a level of service that began at or below LOS C for the following (roadway segments): Ming Avenue from Ashe Road to New Stine Road (LOS C to LOS D) Calloway Drive from Westside Parkway eastbound ramps to Stockdale Highway (LOS A to E) White Lane from Wible Road to Southbound 99 Ramps (LOS C to LOS D) Coffee Road from Brimhall Road to Westside Parkway Westbound Ramps (LOS B to LOS D) Coffee Road from Westside Parkway Westbound Ramps to Westside Parkway Eastbound Ramps (LOS B to LOS E) Therefore, cumulative projects would result in significant and unavoidable impacts to these roadway segments. Notably, impacts to intersections would be less than significant after implementation of the mitigation measures. West Ming Specific Plan - Draft EIR Errata Response to Comments 5-12 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc Appendices Traffic Report (Appendix L) The Draft EIR included a prior version of the Traffic Impact Study (TIS). The primary difference between the version included in the Draft EIR and the current version (April 3, 2006) is that the prior version included incorrect fee summaries. Accordingly, page 36 of the TIS and Tables 6 and 10 of the TIS that were included in the Draft EIR did not contain correct fee references. However, these fees were not directly referenced in the mitigation measures included in the Draft EIR, and therefore, the clarification of these fees will not result in a substantial change to the Draft EIR. The changes to the TIS (Appendix L of Draft EIR) are as follows: Page 36 Under the subheading Conclusions: “The summary of the impact fees including both ‘Local’ and ‘Regional’ impact fees as calculated herein on Tables 6, 8, and 10” are revised as follows: Single Family Residential: $2,117.25$1,067.14 per dwelling unit (4748 D.U.’s) Multi Family Residential: $1,404.80$779.05 per dwelling unit (2702 D.U.’s) General Commercial: $212.35$120.44 per daily trip (13,918 ADT) Office Commercial: $304.10$123.83 per daily trip (4,088 ADT) Light Industrial: $123.06$281.43 per daily trip (10,342 ADT) Page 60 Table 6: The “Project’s Pro-Rata Share Cost Summary” is revised as follows: Single Family Residential Multi Family Residential General Commercial Office Commercial Light Industrial Total Regional Transportation Impact Fee (See Table 10) Calculated in accordance with COB Methodology $9,182,779$4, 196,824 $3,443,542$ 1,752,768 $2,678,310$1, 404,709 $1,147,847$4 12,741 $2,678,310$ 1,040,253 $19,130,789 $8,807,295 Total Traffic Impact Fees: $10,052,715$5 ,066,761 $3,795,769$ 2,104,994 $2,955,478$1, 681,877 $1,243,177$5 08,071 $2,910,582$ 1,272,524 $20,957,722 $10,634,227 Per Dwelling Unit Cost / Per Average Daily Trip Cost $1,067.14$2,1 17.25 per D.U. $779.05$1,4 04.80 per D.U. $120.44$212. 35 per D.U. $123.83$304. 10 per D.U. $123.06$281 .43 per D.U. — Flood Study (Appendix I) The appendices to the Flood Study were inadvertently not included in Appendix I of the Draft EIR; therefore, these appendices are included in Attachment 3 of this Response to Comments document as a revised Flood Study. The revised Flood Study is hereby added to Appendix I of the EIR. Lake Report (Appendix I) The first paragraph of page 2-1 is revised as follows: West Ming Specific Plan - Draft EIR Response to Comments Errata Michael Brandman Associates 5-13 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc The two primary functions of the West Ming Specific Plan water features are to enhance aesthetics and provide recreation opportunities for the residents of the West Ming Specific Plan project and nearby area. The proposed project plans for the construction of one five-acre lake within the Village Center District. Although the lake will be private, it will be accessible to the public by means of the trail system. Final project design for the West Ming Specific Plan may determine that the water elements within the Specific Plan area will include a system of man-made lakes. A lake system including 10 lakes was analyzed in this report. Detention Basins may also be used within the project area, and may be incorporated within the water features of the project.1 1 Project water features may serve as "detention basins" for peak flows, with outfall to ultimate “retention basisns” and/or the Kern River Canal. Based on the above revision, a revised Lake Report was prepared and included in Attachment 4. This revised Lake Report hereby replaces the original Lake Report that is in Appendix I of the Draft EIR. Water Supply Assessment (Appendix M) Page 3 The first sentence of page 3 of the Water Supply Assessment (WSA) is revised as follows: Without specific information as to the different service entities, a mass water balance within the City of Bakersfield area consists of the following: population 295,893 (KernCOG); assuming 325 gallons per capita per day, an estimated annual water consumption of 89,946 107, 700 acre-feet per year (afy); average annual surface water supplies that are treated and directly delivered to municipal users total approximately 30,000 afy with the remaining 77,700 afy being supplies by groundwater pumping. Page 9 The following table is incorporated after the last paragraph in Section V(C): 2800 Acres Recharge Facility Operations Calendar Year Spreading (AF) Losses (AF) Recovery (AF) Groundwater Storage (AF) 1999 0 0 6,741 205,632 2000 0 0 3,426 202,206 2001 64 0 9,227 193,043 2002 156 0 14,084 179,115 West Ming Specific Plan - Draft EIR Errata Response to Comments 5-14 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc 2003 89 0 8,416 170,788 2004 144 0 14,092 156,840 2005 32,573 1,953 2,860 184,600 Notes: 1. Source: 2005 City of Bakersfield Urban Water Management Plan 2. Spreading and loss data sets area current through 7/31/2006 with recovery data current through 6/30/2006. All other tables have been subsequently renumbered throughout the WSA. Page 11 The first paragraph of Section VI(A) is revised as follows: Unlike groundwater supplies, river flows have a high degree of variability. In order to account for the hydrologic variability of the Kern River, statistical analysis of flow data typically includes probability of occurrence graph along with a bar chart based on annual volume. Historic Kern River flow data was obtained from the California Department of Water Resource (DWR) Division of Flood Management Data Exchange Center website and the Kern County Watermaster. The flow measuring point of DWR is downstream of Lake Isabella and the site ID for this location is KRB. The Kern River Watermaster records flow diversions at a site known as the First Point of Measurement, rebuilt in 1981. Page 11 Section VI(B) is revised as follows: Kern River is not the only surface water source available to the City of Bakersfield; water is also obtained from the Improvement District (ID) #4. ID #4 was formed by resolution adopted by the Board of Directors of the KCWA on December 21, 1971 to provide supplemental water supply for portions of the Bakersfield metropolitan area through implementation of water from the State Water Project (SWP). Approximately 65% of the district is within the limits of the City of Bakersfield. The City service area covers about 20% to 30% of ID #4. Waters made available to the City of Bakersfield from ID #4 are only permitted for use within the actual boundaries of the District. Currently, ID #4 has an annual entitlement of 93,546 acre feet. Actual allocations from the SWP in any year are subject to hydrologic variability of the State Project. Page 30 The following footnote is added to Table 5: If Kern River supplies are reduced by 70,000 af, the total amount of surplus water supply decreases to 31,000 af. West Ming Specific Plan - Draft EIR Response to Comments Errata Michael Brandman Associates 5-15 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc Based on the above revisions, a revised Water Supply Assessment was prepared by Provost & Prichard in October 2006 and included in Attachment 5 of this Response to Comments document. This revised Water Supply Assessment hereby replaces the original Water Supply Assessment that is in Appendix M of the Draft EIR. In addition to the above revisions, additional revisions were incorporated in the revised Water Supply Assessment as a result of comments submitted by City staff. The primary revision in the document relates to the City of Bakersfield’s Kern River water rights. According to the City of Bakersfield Water Resources Department, the August 2006 WSA had underestimated the City’s annual average Kern River water right at 140,000 acre feet per year (af/yr); the Water Resources Department citing the 2005 Water Balance Report, indicated that the City of Bakersfield’s annual average Kern River water right is actually 160,000 af/yr. The WSA was updated to reflect this new information. Additional language was added to further document and substantiate the City of Bakersfield’s Kern River water rights and the allocation of the water that is secured by those rights (see Section III of the Water Supply Assessment that is in Attachment 5 of this Response to Comments document). Given, that this clarification identifies that the City has 20,000 af/yr greater of Kern River water rights than was documented in the August 2006 WSA, there is no new significant impact in relation to the conclusions of the WSA analysis contained within the August 2006 document and the Final October 2006 document. Secondly, at the request of the City, Provost & Pritchard removed language in regards to the long- term contracts between the City of Bakersfield and certain irrigation districts. These contracts expire in 2012. Lastly, at the request of the City, Tables 7 and 8 in the document were revised for clarification. Provost & Pritchard revised both tables to identify the amount of recharged reclaimed water. These revisions did not alter the final calculations but rather these revisions were intended to provide further clarification of the City’s water supplies. All other revisions were either minor clarifications and/or the correction of typographical errors and did not impact the context or analysis of the document. As previously stated, none of the revisions altered the final conclusions in regards to the provision of water to the West Ming Specific Plan project site or the water demand of the proposed project. In accordance with CEQA, these revisions are minor modifications and clarifications to the technical studies and the revisions do not change the significance of any of the environmental issue findings within the Draft EIR. West Ming Specific Plan - Draft EIR Errata Response to Comments 5-16 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc 5.2 - Summary of Technical Studies and Other Information Prepared after the Release of the Draft EIR Housing Needs Analysis A Housing Needs Analysis was prepared by The Natelson Dale Group, Inc. in October 2006 for the West Ming Specific Plan project. Following is a brief summary of the analysis, and it is included in its entirety in Attachment 6 of this Response to Comments document. The West Ming Specific Plan project site is located in the Metro Southwest Regional Statistical Area (RSA) and is immediately adjacent to the Metro North of the River (NOA) RSA. Collectively, these two RSA’s represent the west Bakersfield housing market area and are the most relevant sub-area for the housing needs analysis. Housing projections for the study area for 2030 are based on the officially adopted forecasts from Kern Council of Governments (COG). The 2040 projection was developed by The Natelson Dale Group, Inc. based on countywide population growth forecasted by the California State Department of Finance. Between 2006 and 2030, the projected demand for new housing units in the overall Metropolitan Bakersfield area is 98,486. Of that total projected growth, 65,019 new housing units are projected to be added in the Metro Southwest/NOR RSAs between 2006 and 2030. Based on cumulative projects within Metropolitan Bakersfield as well as within the Metro Southwest/NOR RSAs, the projected supply of housing in Metropolitan Bakersfield is 99,219 housing units, of which 66,489 housing units are projected to be supplied in the Metro Southwest/NOR RSAs. The projected supply of housing does not have a projection year; therefore, the projects assumed to be completed by 2030 include all projects currently in the development process except those where Notices of Preparation were recently issued. Based on this assumption, the implementation of cumulative projects and the proposed project within the Metropolitan Bakersfield area will result in an over supply of housing of 733 housing units between 2006 and 2030 which represents approximately 0.7 percent of the projected growth. This projected over supply is considered not significant because the City of Bakersfield has experienced that many projects ultimately construct fewer units than the maximum approved. Between 2006 and 2040, the projected demand for new housing units was provided for the overall Metropolitan Bakersfield area. This projected demand is 146,434 housing units. The projected supply of housing based on the cumulative projects (including those projects where Notices of Preparation were recently issued) is 133,433 housing units. In comparing the demand with the supply between 2006 and 2040, there is a substantial under supply (unmet demand) of housing units of 13,001 housing units, which represents 9.7 percent of the projected growth. The proposed project includes 7,450 dwelling units to the overall Metropolitan Bakersfield area’s increasing demand for housing. Based on an approximate equal supply and demand for the period between 2006 and 2030 and a substantial unmet housing demand for the period between 2006 and West Ming Specific Plan - Draft EIR Response to Comments Errata Michael Brandman Associates 5-17 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc 2040, the proposed housing units that are part of the project has been determined to be needed to meet the projected demand. In addition to the quantitative need for the proposed project, there are also locational factors that make the West Ming Specific Plan project an important piece of the Metropolitan Bakersfield area's future housing development process. The proposed development site is immediately adjacent to the Seven Oaks community and other projects are developing south and west of the project site. Infrastructure (water lines, sewer lines, major roadways, etc.) available to the serve the project is located along the eastern project boundaries. Moreover, the master planning of an entire community, such as the West Ming Specific Plan, achieves a more comprehensive planning process and a higher level of coordination, which could not be accomplished if the project were developed on a piecemeal basis or with a short term planning approach. Urban Decay Study An Urban Decay Study was prepared by The Natelson Dale Group, Inc. in November 2006 for the West Ming Specific Plan project. Following is a brief summary of the analysis, and it is included in its entirety in Attachment 7 of this Response to Comments document. The Urban Decay Study evaluates the potential for the retail components of the West Ming Specific Plan to cause urban decay as a result of the retail component of the proposed project (both individually and cumulatively). Specifically, the study evaluates the extent to which the proposed project would have competitive impacts on the existing retail trade facilities in the trade area and consequently have the potential to result in urban decay. For purposes of this analysis, urban decay is defined as physical effects including, but not limited to, facilities that are poorly maintained and in disrepair, deterioration of buildings and improvements, visual and aesthetic impacts related to physical deterioration, increased instances of property crimes including graffiti, and increased demand for police and emergency response services, which result from individual or cumulative increases in retail closures and consequent long-term vacancies. The study is based in part on two assumptions, both of which resulted in a conservative analysis of the effects of the proposed project on urban decay. First, it was assumed that income levels will remain constant in real dollar terms and while it is generally accepted that incomes are underreported by 13 percent, there was not an attempt to adjust incomes. Second, the estimates of potential support for new retail space are based solely in resident/household demand. Thus, the demand estimates do not include visitors and businesses as potential sources of market support. It is generally accepted that a retail market analysis apply a factor of 5 to 10 percent to the total income of the trade area to account for these additional sources of market support. As stated, the Urban Decay Study evaluates impacts that occur individually with the development of project-related retail space and collectively with project-related retail space and all known pending West Ming Specific Plan - Draft EIR Errata Response to Comments 5-18 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc and reasonably foreseeable future retail development projects. For purposes of evaluating the individual project-related impacts, a Primary Market Area (PMA) was established that encompasses a 5-mile radius around the project site. The PMA is consistent with the International Council of Shopping Centers who has identified trade areas for community scale retail facilities as typically 3 to 6 miles. For purposes of evaluating cumulative impacts, the Regional Trade Area is defined by the PMA and the Regional Statistical Areas (RSA) of the Metro North of the River (NOR) RSA, Metro Southwest (SW) RSA, Greater Shaft RSA, and the Greater Taft/Maricopa RSA. As noted in the Draft EIR, the project includes a total of 1,945,080 square feet of commercial and industrial development, which includes both retail and commercial office land uses. Based upon additional information provided by the applicant, the project is anticipated to include the construction of 525,890 square feet of retail space and 1,419,190 square feet of non-retail space, that will be developed between the years 2010 and 2027. The cumulative retail projects in the Regional Trade Area is projected to include the construction of 3,776,739 square feet of retail space that will be developed between 2012 and 2027. However, it should be noted that the PMA will only capture a share of the retail demand from the greater external cumulative regional trade area, thus the study applied a discount to the planned retail space outside of the PMA. Therefore, for purposes of analysis, after the discount adjustment is applied, the study considers 3,171,835 square feet of cumulative retail space development between the years 2012 and 2027 (see Table II-2 and Section IV-E of the Urban Decay Study for further discussion of the discount calculation). Project-Related Urban Decay Impacts Currently within the West Ming PMA, there is approximately 2.1 million square feet of retail space, with a vacancy rate of 1.5 percent. This vacancy rate reflects a market where finding available retail space to occupy is difficult because a healthy retail market (i.e., markets where available retail space to occupy is not too difficult or where retail space is not too abundant) typically have an occupancy rate that ranges from 5 to 10 percent. The demand analysis concluded that there is the potential market support for $7.18 million in total retail sales in the West Ming PMA, which translates into approximately 2.5 million square feet of currently supportable retail space. Thus considering that there is presently 2.1 million square feet of retail space within the West Ming PMA, the PMA could currently support an additional 400,000 square feet of retail space. Growth projections for the West Ming PMA indicate that by the year 2020 there will be a demand for an additional 1.59 million square feet of retail space and by the year 2028 (one year after project buildout) there will be a demand for an additional 2.1 million square feet of retail space. Therefore, the project’s proposed net increase of 525,890 square feet of retail space development could be accommodated within the West Ming PMA by the year 2020, and by the year 2028, the proposed project would absorb less than 25 percent of the demand for new retail space. Based on these findings, the proposed project’s retail component would not result in economic impacts to exiting stores in the trade area. Moreover, retail stores would not be forced to close solely as a result West Ming Specific Plan - Draft EIR Response to Comments Errata Michael Brandman Associates 5-19 H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc of the proposed project. As indicated earlier, urban decay would result in a physical effect that would lead to an environmental impact if it would increase retail closures and consequent long-term vacancies. Therefore, individually, the West Ming Specific Plan project would result in a less than significant urban decay impact. Cumulative Urban Decay Impacts The Urban Decay Study examined the impacts of growth of retail space within the RTA upon the PMA. As noted above, when the discount calculations are applied to the actual projected growth in the RTA, the RTA is projected to have 3,171,835 square feet of retail space development (including 100 percent of the proposed development within the PMA) that could potentially have a cumulative impact on the PMA. If all planned and pending retail space development occurs according to development plans, the market would be slightly overbuilt in the year 2020. According to projections, development of all planned and pending projects would result in 3 million square feet of retail development; however, projections indicate that in the year 2020, there would be a demand for 2.6 million square feet of retail space. Thus, there would be a surplus of 400,000 square feet of retail space; yet this is a temporary impact as projections indicate that the supply and demand for retail space would be balanced by the year 2024. Moreover, it is likely that infrastructure constraints and retail market conditions would result in a more gradual buildout of planned retail development such that the pace of retail development would more closely follow the growth in retail demand. In the year 2028 (one- year after project buildout) demand for new retail space is forecasted to reach 3.44 million square feet, and projections indicate that in the year 2028 development of all planned and pending projects within the RTA, there would be a need for approximately 273,000 square feet of retail space in the PMA in addition to the 3.17 million square feet projected with cumulative projects. Under the cumulative scenario, cumulative retail development within the PMA would result in less than significant urban decay impacts. Fiscal Impact Analysis A Fiscal Impact Assessment (FIA) was prepared by Development Planning & Financial Group, Inc. in November 2006 for the West Ming Specific Plan project. Following is a brief summary of the analysis, and it is included in its entirety in Attachment 8 of this Response to Comments document. The FIA examines the fiscal impact of the West Ming Specific Plan project on the City of Bakersfield. It is acknowledged in the Draft EIR (see Section 5.9, Public Services) that the proposed project will increase the need for public services. However, while the proposed project will demand public services, it will also generate tax dollars that will support such services. Specifically, the West Ming Specific Plan project will generate additional income for the General Fund primarily through increased sales tax, property taxes, and franchise taxes. The findings of the FIA concluded that the proposed project will cost the City of Bakersfield $10,070243 while it will create $10,576,253 in West Ming Specific Plan - Draft EIR Errata Response to Comments 5-20 Michael Brandman Associates H:\Client (PN-JN)\0216\02160029\RTC\02160029_RTC Sec05-Responses to Comments.doc revenue; thereby, resulting in a surplus of $506,009 for the City, which is considered a beneficial impact. Other Information Agricultural Resources Page 5.1-1 of the Draft EIR includes a discussion regarding harvested land in Kern County. Kern County contains 866,226 acres of harvested land, according to the 2003 Agricultural Crop Report prepared by the Kern County Agricultural Commissioner’s Office. As of 2005, there were 873,005 acres of harvested land in Kern County according to the 2005 Agricultural Crop Report. The Agricultural Crop Report does not provide information regarding the total number of acres of prime farmland in Kern County. However, the California Land Conservation (Williamson) Act 2004 Status Report, a biennial report of statewide enrollment data for the Williamson Act provides prime farmland information for land under the Williamson Act and Farmland Security Zone program. The 2004 report provided data for 2003. As of 2003, there were 674,599 acres of prime farmland under the Land Conservation (Williamson) Act, and 139,639 acres enrolled in Farmland Security Zone program (a provision under the Williamson Act); for a total of 814,238 acres of prime farmland in Kern County enrolled in this agricultural land protection program. This information has not been updated since the preparation of the 2004 Status Report. Traffic For clarification, on page 5.11-11 of the Draft EIR, there is a discussion of improvements that are not dictated by project impacts. The improvements that are identified are either project created intersections or project created approaches at existing intersections. These are improvements that will be required to be built by the project at the time of development adjacent to these intersections. Therefore, they are not necessarily mitigation measures required at existing intersections due to project created impacts, but rather improvements that will be constructed by the project as the project develops. Many of these improvements would not be built if development of the proposed project does not occur. Improvements to existing facilities and construction of future facilities adjacent to the project will be required as development of the project occurs. These improvements will be tied to various portions of the project as those specific projects are submitted for approval. Timing of improvements to regional facilities not adjacent to the project will be based on the City of Bakersfield’s current Capital Improvement Plan. The “significance thresholds” referred to in the Draft EIR will be based on the service levels of the various facilities. As future traffic volumes increase and service levels of various facilities decrease, those improvements included in the Regional Transportation Impact Fee Program (RTIF) will be constructed as necessary to accommodate the increased traffic volumes. Those RTIF improvements will either be built by the City through implementation of the City’s current Capital Improvement Plan or built by various projects adjacent to those affected facilities through development agreements between the City and the various developers.