HomeMy WebLinkAboutSR_99_Hosking_Final_EIR_October 2015Chapter 7
Response to Comments
SCH #2007101067
SR 99/Hosking
Commercial Center Project (GPA/ZC 13-0417)
By the City of Bakersfield
City of Bakersfield
Community Development Department
Planning Division
Bakersfield, California
October 2015
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B A K E R S F I E L D
October 1, 2015 File: GPA/ZC 13-0417
Addressee (see Distribution List)
RE: Response to Comments on Draft Environmental Impact Report: SR 99/Hosking Commercial
Center Project (GPA/ZC 13-0417) by the City of Bakersfield
Ladies and Gentlemen:
Enclosed is a document titled Chapter 7, Response to Comments, for the above-referenced project.
Section 15088 of the California Environmental Quality Act Guidelines requires the Lead Agency to
evaluate comments on environmental issues received from persons who reviewed the Draft
Environmental Impact Report (EIR) and prepare a written response addressing each comment. This
document is Chapter 7 of the Final EIR.
A public hearing has been scheduled with the City of Bakersfield Planning Commission to consider this
request on October 15, 2015, at 5:30 p.m., in the Council Chambers of City Hall, 1501 Truxtun Avenue,
Bakersfield, California, 93301.
Thank you for your participation in the environmental process for this project. If you have any questions
regarding this letter, please contact Cecelia Griego, Associate Planner II, at (661) 326-3733.
Very truly yours,
Cecelia Griego, Associate Planner II
Planning Division
Community Development Department
COMMENTING AGENCIES AND INTERESTED PERSONS: State Clearinghouse; California Highway
Patrol; California Department of Transportation; Kern County Public Works Department; San Joaquin
Valley Air Pollution Control District; Kern High School District Superintendent of Schools; Tejon Indian
Tribe; Betty Stephens; Public Hearing Comment by Phil Rudnick
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Chapter 7
Response to Comments
SCH #2007101067
SR 99/Hosking
Commercial Center Project (GPA/ZC 13-0417)
By the City of Bakersfield
City of Bakersfield
Community Development Department
Planning Division
Attn: Cecelia Griego, Associate Planner II, or
Jacquelyn Kitchen, Planning Director
1715 Chester Avenue
Bakersfield, CA 93301-2370
(661) 326-3733
Technical Assistance by:
ICF International
525 B Street Suite 1700
San Diego, CA 92101
(858) 444-3911
October 2015
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Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
i
October 2015
Contents
Page
Chapter 7 Response to Comments ......................................................................................... 7-1
7.1 Introduction ......................................................................................................... 7-1
7.1.1 Purpose .............................................................................................................. 7-1
7.1.2 Environmental Review Process .......................................................................... 7-1
7.2 Revisions to the Project Draft EIR ...................................................................... 7-2
Page 1-22, Table 1-7, Air Quality Impact AQ-2 .............................................................. 7-3
Page 1-29, Table 1-7, Cultural Resources Impact CR-2 ................................................ 7-5
Page 4.2-14, Last Paragraph ......................................................................................... 7-7
Page 4.2-32, First Paragraph ......................................................................................... 7-7
Pages 4.2-39 and 4.2-40, Cumulative Impacts .............................................................. 7-8
Page 4.4-11, Third Paragraph ........................................................................................ 7-8
Page 4.4-11, Fourth Paragraph ..................................................................................... 7-8
Page 4.6-17, Cumulative Impacts .................................................................................. 7-9
Page 4.12-42, First Paragraph ....................................................................................... 7-9
Page 4.12-19, Table 4.12-7 ......................................................................................... 7-10
7.3 Response to Comments ................................................................................... 7-11
Comment Letter 1. Governor’s Office of Planning and Research, State
Clearinghouse (August 6, 2015) .................................................................................. 7-12
Comment Letter 2. Governor’s Office of Planning and Research, State
Clearinghouse (August 7, 2015) .................................................................................. 7-15
Comment Letter 3. California Highway Patrol (July 16, 2015) ..................................... 7-17
Comment Letter 4. California Department of Transportation, District 6 (July
30, 2015) ...................................................................................................................... 7-22
Comment Letter 5. Kern County Public Works Department (August 12, 2015) ........... 7-33
Comment Letter 6. San Joaquin Valley Air Pollution Control District (August
10, 2015) ...................................................................................................................... 7-36
Comment Letter 7. Kern County Superintendent of Schools (August 10, 2015) .......... 7-44
Comment Letter 8. Tejon Indian Tribe (June 18, 2015) ............................................... 7-46
Comment 9. Betty Stephens (July 17, 2015) ............................................................... 7-49
Comment 10. Public Hearing Transcripts, July 16, 2015 ............................................. 7-51
Attachment 1 Revised Signed Copy of Appendix C, Traffic Study of Draft
EIR
Attachment 2 Response Letter from Insight Environmental to San Joaquin
Valley Air Pollution Control District
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
ii
October 2015
Attachment 3 Response Letters from Ruettgers & Schuler to Caltrans and
Kern County Public Works Department
Attachment 4 Supplements to Appendix D, First Amendment to the Urban
Customer Service Agreement – Kern Delta Water District and
Greenfield County Water District; and Greenfield County
Water District Water Demand Factors and Calculation of
Projected Water Demands of Appendix D of Draft EIR
Table
Table on page
7-1 Public Comments Received on the Draft EIR ................................................................ 7-2
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
iii
October 2015
Acronyms and Abbreviations
AAQA Ambient Air Quality Analysis
Caltrans California Department of Transportation
CEQA California Environmental Quality Act
DPM diesel particulate matter
EIR Environmental Impact Report
HARP Hot Spots Analysis and Reporting Program
HRA Health Risk Assessment
ISR Indirect Source Review
NOP/IS notice of preparation/initial study
NOX nitrogen oxides
project State Route 99/Hosking Commercial Center Project
ROG Reactive Organic Gas
RTIF Regional Transportation Impact Fee
SCH State Clearinghouse
SJVAPCD San Joaquin Valley Air Pollution Control District
SR State Route
TAC toxic air contaminant
VERA Voluntary Emission Reduction Agreement,
VOC volatile organic compound
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
iv
October 2015
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Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-1
October 2015
Chapter 7
Response to Comments
7.1 Introduction
7.1.1 Purpose
As defined by Section 15050 of the California Environmental Quality Act
(CEQA) Guidelines, the City of Bakersfield is serving as Lead Agency for
preparation of the Environmental Impact Report (EIR) for the State Route (SR)
99/Hosking Commercial Center Project (project). The Final EIR presents the
environmental information and analyses that have been prepared for the project,
including comments received addressing the adequacy of the Draft EIR and
responses to those comments. In addition to the responses to comments,
clarifications, corrections, or minor revisions have been made to the Draft EIR.
The Final EIR—which includes the responses to comments, the Draft EIR, and
the Mitigation Monitoring Program—will be used by the Planning Commission,
and ultimately the City Council, in the decision-making process for the project.
7.1.2 Environmental Review Process
A Notice of Preparation/Initial Study (NOP/IS) (State Clearinghouse No.
2007101067) was circulated for a 30-day public review period beginning on
November 5, 2014, and ending on December 4, 2014. A scoping meeting was
noticed and held on November 18, 2014. Eleven comment letters were received
and used in preparation of the Draft EIR. The Draft EIR for the project was
circulated for a 45-day public review period beginning on June 22, 2015, and
ending on August 6, 2015. A total of nine written comment letters were received
on the Draft EIR, and public testimony was taken during the Draft EIR Adequacy
Hearing held by the Planning Commission on July 16, 2015.
Section 15088 of the State CEQA Guidelines requires that the lead agency
evaluate comments on environmental issues received from persons and agencies
that reviewed the Draft EIR and prepare a written response addressing each of
the comments received. The response to comments is contained in this Volume 3,
Chapter 7 of the Draft EIR. Volumes 1 through 3 together compose the Final
EIR. A list of agencies, organizations, and interested parties who have
commented on the Draft EIR is provided below. A copy of each numbered
comment letter and a lettered response to each comment are provided in Section
7.3, Response to Comments, of this chapter.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-2
October 2015
Table 7-1. Public Comments Received on the Draft EIR
Letter
No. Commenter
Commenter
Type
1 California Governor’s Office of Planning and Research, State
Clearinghouse (August 06, 2015)
State
2 California Governor’s Office of Planning and Research, State
Clearinghouse (August 07, 2015)
State
3 California Highway Patrol (July 16, 2015) State
4 California Department of Transportation, District 6 (July 30, 2015) State
5 Kern County Public Works Department (August 12, 2015) Local
6 San Joaquin Valley Air Pollution Control District (August 10, 2015) Local
7 Kern County Superintendent of Schools (August 10, 2015) Local
8 Tejon Indian Tribe (June 18, 2015) Local
9 Betty Stephens (July 17, 2015) Resident
10 Public Hearing Transcripts on July 16, 2015, Planning Commission
(Phil Rudnick) (July 16, 2015)
Resident
7.2 Revisions to the Project Draft EIR
The following revisions were made to the text of the SR 99/Hosking Commercial
Center Draft EIR. Amended text is identified by page number. Clarifications to
the Draft EIR text are shown with underlining and text removed from the Draft
EIR is shown with strikethrough.
The project revisions fall within the scope of the original project analysis
included in the Draft EIR and do not result in an increase in impacts or any new
impacts. No new significant environmental impacts would result from the project
changes or from a revised or new mitigation measure proposed to be
implemented. Therefore, no significant revisions have been made that would
require recirculation of the Draft EIR pursuant to State CEQA Guidelines Section
15088.5 (Recirculation of an EIR Prior to Certification).
The Lead Agency is of the opinion that no new significant environmental impacts
would result from the clarified and revised proposed mitigation measures shown
below.
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City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-7
October 2015
Page 4.2-14, Last Paragraph
SJVAPCD has adopted attainment plans to address O3, PM, and CO emissions in
the SJVAB. The 2007 Ozone Plan contains a comprehensive list of regulatory
and incentive-based measures to reduce VOC and NOX emissions within the
SJVAB. In particular, the plan proposes a 75% reduction in NOX and a 25%
reduction in VOC by 2023. SJVAPCD’s 2007 PM10 Maintenance Plan and 2008
PM2.5 Plan likewise include strategies to reduce PM emissions throughout the
air basin. The 2013 Plan for the Revoked 1-hour Zone Standard was prepared for
the EPA’s revoked 1-hour ozone standard. Although EPA approved the 2004
plan for the 1-hour ozone standard in 2010, EPA withdrew this approval as a
result of litigation. The 2013 Plan indicates the SJVAB will attain the revoked 1-
hour ozone standard by 2017. The 2012 PM2.5 Plan addresses EPA’s 24-hour
PM2.5 standard and indicates the SJVAB will meet the 24-hour PM2.5 standard
by the 2019 deadline, with most areas seeing attainment well before then. The
2015 Plan for the 1997 PM2.5 Standard addresses EPA’s annual PM2.5 standard
and requires attainment no later than December 31, 2020. Finally, the 2004
California State Implementation Plan for Carbon Monoxide addresses CO
emissions throughout the state. SJVAPCD’s air quality plans are evolving
documents that are updated to reflect changing population and economic, land
use, and transportation conditions. Local transportation planning agencies (in this
area, Kern Council of Governments) and ARB provide the information needed to
predict future on-road mobile source emissions that are used in the air quality
planning process.
Page 4.2-32, First Paragraph
(a) Reduction of Reactive Organic Gas (ROG) and NOX Emissions. The project
proponent shall submit evidence, verified by SJVAPCD, that demonstrates that
the project’s construction and operational-related PM10, ROG, and NOX
emissions will be reduced to below SJVAPCD’s numeric threshold of 15 and 10
tons per year by reducing ROG emissions by 7.17 tons and NOX emissions by
2.84 tons, respectively. These reductions can be achieved by any combination of
project design, compliance with the ISR, and/or via the project proponent
entering into a development mitigation contract (i.e., Voluntary Emission
Reduction Agreement, or VERA), with SJVAPCD.
If a VERA is utilized, a copy of the executed agreement and implementing
reports will be provided to the City to demonstrate compliance. Additionally, the
project proponent shall supply updated documents if the requirements change as
the VERA is reassessed by SJVAPCD at each phase of project development.
This requirement will be enforced and verified by SJVAPCD. The current VERA
payment fee for construction emissions is $9,350 $93,500 per ton of NOX;
payment fees vary by year (i.e., future year payment fees for NOX could be more
than the current price of $9,350 $93,500) and are sensitive to the number of
projects requiring emission reductions within the same air basin. At the time of
issuance for building permits for each phase of the project, associated fees will be
calculated and collected by SJVAPCD and will depend on the emissions required
to be mitigated after all selected emission reduction projects are completed. The
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-8
October 2015
VERA shall identify the amount of emissions to be reduced, in addition to the
amount of funds to be paid to SJVAPCD by the project proponent to implement
emission reduction projects required for the project.
Pages 4.2-39 and 4.2-40, Cumulative Impacts
The SJVAPCD has identified project-level thresholds to evaluate impacts to air
quality (see Section 4.2.4.2). In developing these thresholds, the air district
considered levels at which project emissions would be cumulatively
considerable. As noted in the SJVAPCD’s 2002 GAMAQI:
“Any proposed project that would individually have a significant air quality
impact (see Section 4.3.2 – Thresholds of Significance for Impacts from Project
Operations) [Table 3.2-6 of the DEIR] would also be considered to have a
significant cumulative air quality impact. Impacts of local pollutants (CO, HAPs)
are cumulatively significant when modeling shows that the combined emissions
from the project and other existing and planned projects will exceed air quality
standards.”
The criteria pollutant thresholds presented in Section 4.2.4.2, therefore, represent
the maximum emissions the project may generate before contributing to a
cumulative impact on regional air quality as determined by the SJVAPCD.
Therefore, exceedances of the project-level thresholds would be cumulatively
considerable. As discussed in Impact AQ-2, construction and operational
emissions associated with the project are not expected to exceed the SJVAPCD’s
quantitative thresholds with implementation of Mitigation Measures MM-AQ-1
and MM-AQ-2, while Impact AQ-3 indicates predicted ambient pollutant
concentrations and health risks would not exceed SJVAPCD thresholds.
Consequently, the project’s incremental contribution is not cumulatively
considerable.
Page 4.4-11, Third Paragraph
MM CR-1. (b) Provide Notice if Cultural Resources Are Encountered. If buried cultural
resources are discovered that may have relevance to Native Americans, the
project proponent shall provide written notice to the City of Bakersfield, Tejon
Indian Tribe, and to the Native American Heritage Commission, and any other
appropriate individuals, agencies, and/or groups as determined by the qualified
archaeologist in consultation with the City of Bakersfield.
Page 4.4-11, Fourth Paragraph
MM CR-1. (c) Cultural Resources Training. Prior to ground disturbance activities associated
with this project, personnel associates with the grading effort shall be informed
of the importance of the potential cultural and archaeological resources (e.g.,
archaeological sites, artifacts, features, burials, human remains) that may be
encountered during site preparation activities, how to identify those resources in
the field, and of the regulatory protections afforded to those resources. This
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-9
October 2015
training shall be conducted by representatives from the Tejon Indian Tribe or
qualified archaeologist. The personnel shall be informed of procedures relating to
the discovery of archaeological remains during grading activities and cautioned
to avoid archaeological finds with equipment and not collect artifacts. The
applicant/developer of the project site shall submit documentation to the Planning
Department that they have met this requirement prior to commencement of
ground disturbance activities. This documentation should include information on
the date(s) of training activities, the individual(s) that conducted the training, a
description of the training, and a list of names of those who were trained. Should
cultural remains be uncovered, the on-site supervisor shall immediately notify a
qualified archaeologist and the Tejon Indian Tribe. The developer shall provide
the Tejon Indian Tribe information on excavation depth of the construction of the
site.
Page 4.6-17, Cumulative Impacts
In accordance with scientific consensus regarding the cumulative nature of
GHGs, the analysis provides a cumulative evaluation of GHG emissions. Unlike
traditional cumulative impact assessments, this analysis is still project-specific in
that it only evaluates direct emissions generated by the project; given the global
nature of climate change, the analysis does not include emissions from past,
present, and reasonably foreseeable projects in the Project Area.
As discussed in Section 4.6.4.2, GHG impacts are inherently cumulative.
Accordingly, because implementation of the project would not exceed the San
Joaquin Valley Air Pollution Control District’s GHG threshold, it would not
result in a cumulatively considerable impact on GHGs or climate change. This
impact would be less than significant.
Page 4.12-42, First Paragraph
The proposed project would cause an increase in traffic that would have a
significant impact on area roadways and intersections in the future. As shown in
Table 4.12-7, the completed project is expected to generate 26,337 23,775 daily
trips on an average weekday and 668 611 weekday AM peak hour trips, 2,410
2,176 weekday PM peak hour trips, and 2,918 3,088 Saturday peak hour trips.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-10
October 2015
Page 4.12-19, Table 4.12-7
Table 4.12-7. Project Trip Generation Summary
Daily
Trips
Peak Hour Trips
AM PM Saturday
In Out In Out In Out
Phase I (2017)
Hotel (120 rooms) 701 38
(59%)
26
(41%)
37
(51%)
35
(49%)
95 49
0 (56%)
75 38
0 (44%)
Shopping Center
(300,000 sf)
15,045 204
(62%)
125
(38%)
653
(48%)
707
(52%)
1,007
(52%)
930
(48%)
Anchor1
(100,000 sf)
1,333 41
(61%)
26
(39%)
64
(48%)
69
(52%)
128
(48%)
139
(52%)
Pass-by2 -305
-2,562
-12
-42
-8
-27
-15
-113
-16
-122
-170
-178
-160
-166
Capture3 -752
-67
-10
-2
-6
-1
-33
-3
-35
-3
-57
-6
-53
-7
Phase I New Trips 16,022
14,450
261
239
163
149
706
638
760
686
908
1,000
856
934
Phase II (2020)
Hotel (240 rooms) 1,775 75
(59%)
52
(41%)
73
(51%)
71
(49%)
95
(56%)
75
(44%)
Shopping Center
(700,000 sf)
24,942 328
(62%)
201
(38%)
1,099
(48%)
1,191
(52%)
1,670
(52%)
1,541
(48%)
Anchor1
(100,000 sf)
1,333 41
(61%)
26
(39%)
64
(48%)
69
(52%)
128
(48%)
139
(52%)
Pass-by2 -466
-4,208
-17
-67
-12
-42
-21
-185
-21
-200
-284 -263
Capture3 -1,247
-67
-16
-2
-10
-1
-55
-3
-60
-3
-95
-6
-88
-7
Phases I & II New
Trips
26,337
23,775
411
375
257
236
1,160
1,048
1,250
1,128
1,514
1,603
1,404
1,485
1 Anchor Trip Rates determined from actual site surveys. 2 Applied to entire project. 3 Applied to anchor for dual trip purposes.
sf = square feet.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-11
October 2015
7.3 Response to Comments
The comment letters received on the Draft EIR are addressed in their entirety in
this section. Each comment contained in the letter has been assigned a reference
code. The responses to reference code comments follow each letter.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-12
October 2015
Comment Letter 1. Governor’s Office of Planning and
Research, State Clearinghouse (August 6, 2015)
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-13
October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-14
October 2015
Response to Comment Letter 1. Governor’s Office of Planning
and Research, State Clearinghouse (August 6, 2015)
1-A. Thank you for your comments. The participation of the State Clearinghouse
(SCH) in the public review of this document is appreciated. The SCH coordinates
the state-level review of environmental documents that are prepared pursuant to
CEQA. The commenter states that the SCH submitted the Draft EIR to selected
state agencies for review and comment in compliance with SCH review
requirements for draft environmental documents and pursuant to CEQA.
No state agencies submitted comments by the close of the public comment
period.
The commenter also states that the Lead Agency has complied with the SCH
review requirements for draft environmental documents pursuant to CEQA.
These comments have been noted for the record and have been provided to the
City of Bakersfield for consideration.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-15
October 2015
Comment Letter 2. Governor’s Office of Planning and
Research, State Clearinghouse (August 7, 2015)
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-16
October 2015
Response to Comment Letter 2. Governor’s Office of Planning
and Research, State Clearinghouse (August 7, 2015)
2-A. The commenter forwarded comments that were received after the public
comment period. These comments were recommended to be incorporated into the
Final EIR and to be considered before taking final action on the proposed project.
However, noted in the letter is the statement that CEQA does not require lead
agencies to respond to late comments.
These comments are incorporated in the Final EIR as comment Letter 3, from the
California Highway Patrol. Responses are provided separately following this
letter.
These comments have been noted for the record and have been provided to the
City of Bakersfield for consideration.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-17
October 2015
Comment Letter 3. California Highway Patrol (July 16,
2015)
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-18
October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-19
October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-20
October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-21
October 2015
Response to Comment Letter 3. California Highway Patrol
(July 16, 2015)
3-A. Thank you for your comments. The California Highway Patrol’s participation in
the public review of this document is appreciated. Comment 3-A notes receipt of
the Notice of Completion and summarizes the proposed project, noting the
project and location. The commenter states that the project will not have a
significant impact on statewide departmental operations. No further response or
changes to the Draft EIR are necessary.
3-B. The commenter states that from preliminary review, the project will not have a
significant impact on statewide departmental operations. However, due to the
project proponent’s geographical proximity, the commenter requests a review of
transportation-related impacts and suggests the Highway Patrol Manual 41.1
Transportation Planning Manual, Chapter 6, Environmental Impact Documents,
as a guideline for such review.
This request is addressed with Section 4.12, Transportation and Traffic, of the
Draft EIR. The analysis concludes that implementation of Mitigation Measures
MM TR-1 though MM TR-3 would reduce impacts to less-than-significant levels
for their respective locations, with the exception of one unsignalized intersection,
seven signalized intersections, and one roadway segment.
The comments have been noted for the record and will be provided to the City of
Bakersfield for consideration. The Lead Agency thanks the commenter for taking
the time to comment on the EIR and to provide expertise, guidance, and
recommendations regarding transportation and traffic.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-22
October 2015
Comment Letter 4. California Department of
Transportation, District 6 (July 30, 2015)
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-23
October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-24
October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-25
October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-26
October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-27
October 2015
Response to Comment Letter 4. California Department of
Transportation, District 6 (July 30, 2015)
4-A. Thank you for your comment. The participation of the California Department of
Transportation (Caltrans), District 6 in the public review of this document is
appreciated. Caltrans indicated that the comments provided in its previous letter
from December 4, 2014, continue to be valid, with the exception of the first
bullet requesting a traffic impact study.
Commenter references a letter sent to the City related to the Notice of
Preparation of the EIR. The letter indicates that the applicant should prepare a
traffic impact study referencing the Caltrans Guide for the Preparation of Traffic
Impact Studies; advises on two current Caltrans projects along SR99; notes that
the project site is adjacent to an access control right of way; notes that an
encroachment permit is required for activities that would occur with the State
right-of-way and provides specific guidance on development within the right of
way; and recommends that the project contribute to the City of Bakersfield
Metropolitan Transportation Impact Fee Program.
The City appreciates Caltrans comments provided during the EIR scoping period.
Caltrans comments were reviewed and considered during the preparation of the
EIR. Please see the Traffic Study (Attachment 1) and related Section 4.12,
Transportation, of the EIR. In addition, responses and revisions are provided in
the Final EIR based on comments received from Caltrans in the July 21, 2015
letter that addressed specific comments related to the analysis presented in the
Draft EIR.
The City appreciates Caltrans interest in the project and your agencies expertise
in transportation planning and related issues. These comments and the
corresponding responses will be provided to the City of Bakersfield for
consideration.
4-B. Table 3 shows general assumptions for the distribution percentages. While 33%
is listed for northern trips, a number of the east and west trips may be considered
north of the project, but generally also traveled east or west. Additionally, the trip
distribution was based on a select link analysis by the Kern Council of
Governments’ model and therefore includes a future year build in which the
prevailing direction of development is to the south. The Kern Council of
Governments is the regional transportation agency for the project area; hence,
Kern Council of Governments maintains the transportation model for the City of
Bakersfield and surrounding area.
4-C. Queuing analysis was prepared for the state intersections, and intersections
adjacent to state facilities, which a queue could affect. The results are shown in
the table below). It was determined that there are no project impacts that are not
mitigated through improvements listed in Table 8 of the Traffic Study.
Additionally, there are no queue lengths on the ramps that would affect through
traffic on SR 99.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-28
October 2015
4-D. Pursuant to the project’s Traffic Engineer’s (Mr. Ian J. Parks) phone call with
Caltrans (Mr. Alec Kimmel) on August 26, 2015, and subsequent
correspondence, the comment is a general clarification of Caltrans’
understanding of the City of Bakersfield’s 5-second rule, and its application.
Table 8 of the Traffic Study shows percent share calculations for facilities that
are not included in the facilities list in the Regional Transportation Impact Fee
(RTIF) Program. It was confirmed with Caltrans that facilities included in the
RTIF Program do not need a fair share calculation due to the developer paying
into the RTIF Program.
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October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-33
October 2015
Comment Letter 5. Kern County Public Works Department
(August 12, 2015)
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-34
October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-35
October 2015
Response to Comment Letter 5. Kern County Public Works
Department (August 12, 2015)
5-A. Thank you for your comment. The participation of the Kern County Public
Works Department in the public review of this document is appreciated. The
Lead Agency acknowledges that the commenter reviewed DEIR Section 4.12,
Transportation and Traffic, and the Traffic Study for the proposed project and
concurs with Mitigation Measures MM TR-1, MM TR-2, and MM TR-3; and
that the commenter provided further Comments 5-B through 5-G.
5-B. The referenced traffic counts describing the time frame of activity are referenced
on page 16, second paragraph, of the Traffic Study, which was reviewed by the
commenter per Comment 5-A. The reference traffic count data has been added to
the appendix of the Traffic Study; which has been attached to this document as
Attachment 1.
5-C. The Phase I Trip Generation table has been revised for the Saturday peak hour
Hotel trips. (See Attachment 1)
5-D. The pass-by rate has been corrected to apply to all land use types for the tables
listed. The result was a reduction in trips. (See Attachment 1)
5-E. Footnote 2 for Table 2a and Table 2b has been corrected to read, “Applied to
entire project.” (See Attachment 1)
5-F. The percent share calculation was applied correctly in the mitigation table and
there were no changes made to the fair share percentages. The equation in the
report text on page 66 has been corrected to read “Existing Traffic” instead of
“2010.” (See Attachment 1)
5-G. A finalized and signed report is included as part of this response letter. The
revised Traffic Study is provided in its entirety as a revised appendix to this Final
EIR. (See Attachment 1)
The comments have been noted for the record and will be provided to the City of
Bakersfield for consideration. The Lead Agency thanks the commenter for taking
the time to comment on the EIR and to provide expertise, guidance, and
recommendations regarding transportation and traffic.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-36
October 2015
Comment Letter 6. San Joaquin Valley Air Pollution
Control District (August 10, 2015)
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-37
October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-38
October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-39
October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-40
October 2015
Response to Comment Letter 6. San Joaquin Valley Air Pollution
Control District (August 10, 2015)
6-A. Thank you for your comment. The commenter recommends additional language be
included to discuss attainment plans not discussed in the Draft EIR. Text has been added
to Chapter 4.2, Air Quality, to include attainment plans not discussed in the Draft EIR.
6-B. Thank you for your comment. The commenter acknowledges that Mitigation Measure
MM AQ-1(c) requires a Voluntary Emission Reduction Agreement (VERA) to reduce
project-related construction and operation ROG, NOX, and PM10 emissions to below the
District’s threshold of significance; and the commenter recommends that the MM be
revised as follows:
a. Commenter recommends specification of the level of mitigation or amount tons to be
reduced.
b. Commenter notes that the EIR finds that the level of PM10 emissions will not exceed
District thresholds for significance and recommends clarification if PM10 emissions
still need to be mitigated or need to be quantified at a later date and mitigated.
c. Commenter notes that the EIR finds that the level of construction emissions will not
exceed District thresholds for significance and recommends clarification if
construction emissions still need to be mitigated or need to be quantified at a later
date and mitigated.
d. Commenter recommends removing Rule 9510 and project design language from
Mitigation Measure MM AQ-1(c) since it is already imposed as Mitigation Measure
MM AQ-1(a)(ii) and to eliminate confusion.
e. Commenter clarifies that the project emissions would not be reassessed at each phase
of project development if mitigating only project operational emissions. The
emissions to be mitigated under the VERA would be based on the required estimated
operational emissions identified to be reduced in the EIR.
f. Commenter notes that the current estimated cost for operational emissions is $93,500
per ton of NOX/ROG emissions. The cost per-ton is not a guarantee and only an
estimate.
g. Commenter notes that Rule 9510 (ISR) is a regulatory requirement while a VERA is
a potentially feasible mitigation measure for projects subject to CEQA requirements.
Rule 9510 may substantially reduce project-specific impacts on air quality; however,
it may not be sufficient to reduce project specific emissions to less-than-significant
levels under CEQA. VERAs provide emission reductions that can be used to satisfy
both ISR and CEQA requirements. Entering into a VERA does not exempt a project
from ISR requirements, but the emission reductions achieved under a VERA can be
applied towards satisfying ISR emission reduction requirements.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-41
October 2015
The following responses have been prepared in response to the comments above:
a. Mitigation Measure MM AQ-1(c) indicates the following regarding the level of
mitigation that is required:
“…the project’s operational-related ROG and NOX emissions will be reduced to
below SJVAPCD’s numeric threshold of 10 tons per year by reducing ROG
emissions by 7.17 tons and NOX emissions by 2.84 tons.”
b. Text has been revised in Chapter 4.2, Air Quality, and in the MM, to remove the
PM10 requirement from Mitigation Measure MM AQ-1(c).
c. Text has been revised in Chapter 4.2, Air Quality, and in the MM, to remove the
construction requirement from Mitigation Measure MM AQ-1(c).
d. Text has been revised in Chapter 4.2, Air Quality, and in the MM, to remove the
Rule 9510 (ISR) discussion from Mitigation Measure MM AQ-1(c). However, as
the mitigation requirement in Mitigation Measure MM AQ-1(c) is to reduce
ROG and NOX emissions, rather than just incorporate a VERA, the project
design language has not been removed.
e. Text has been revised in Chapter 4.2, Air Quality, and in the MM, to remove the
language indicating that emissions are reassessed at each phase of the project
development.
f. Text has been revised in Chapter 4.2, Air Quality, and in the MM, to update the
operational offset fee from $9,350 to $93,500 per ton.
g. Thank you for your comment. As indicted in Table 4.2-10 of the Draft EIR, Rule
9510 (ISR) is not sufficient to reduce impacts to a less-than-significant level.
However, with implementation of the VERA through Mitigation Measure MM
AQ-1(c), this impact is considered less than significant.
6-C. The commenter acknowledges that a Health Risk Assessment (HRA) and Ambient Air
Quality Analysis (AAQA) were performed for the project and states that the District was
unable to determine if the cancer risk will exceed the District’s significance threshold or
if there will be a violation of an ambient air quality standard. The Commenter
recommends revisions to the Draft EIR as follows:
a. The commenter states that, if a new HRA is prepared, the latest threshold of
significance of 20 in a million for cancer risk be used along with the latest
methodology.
b. The commenter states that current versions of the AERMOD model and San
Joaquin meteorological data were not used in the analyses and recommends that
the current version of the AERMOD model and San Joaquin Valley
meteorological data be used in the analyses.
c. The commenter states that pathways other than inhalation were not enabled in the
Hot Spots Analysis and Reporting Program (HARP). This is not a problem if
only diesel particulate matter (DPM) is modeled. However, there is space in the
development for a considerable number of restaurants. Had the restaurants been
included in the HRA, toxins other than DPM would have been modeled. For
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-42
October 2015
those pollutants, enabling other pathways would have been important. The
District recommends establishing the travel paths for each store with deliveries
and the number of trucks per store.
d. The commenter states that DPM emissions were not properly calculated. An
assumption was made that all trucks would travel the entire length of a roadway
that encircled the entire development. There was no differentiation between the
large anchor stores and other sites that would have fewer deliveries. The same
assumption was made for idling. Therefore, the emissions were overestimated.
e. The commenter states that toxic air contaminant (TAC) emissions from
restaurants were not modeled in the HRA although there are 10 spaces in the
development for restaurants. Therefore, the District recommends that TAC
emissions from restaurants be modeled in the HRA.
f. The commenter states that in the AAQA, all emissions were modeled using a
single large area source that encompassed the entire 80-acre site. Using such a
large area source would dilute the emissions and reduce predicted impacts.
Therefore, the District recommends that the criteria pollutants should be modeled
using the same sources that is used for toxins.
Thank you for your comments. The following responses have been prepared in response
to the comments above:
a. It is the City’s position that it is unnecessary to re-run the AAQA or HRA
models. See response to comment 6-C-b. Therefore, the most current significance
thresholds and methodology for estimating cancer risk at the time the original
dispersion modeling was completed shall remain in use.
b. At the time of preparation of the Air Quality Study, the most recent versions of
AERMOD and meteorological data were used. The dispersion modeling was
based on the most recent available meteorological and modeling data at the time
of analysis. The District has since updated the meteorological data for more
recent years (2009-2013) and the EPA has since updated the AERMOD
dispersion model to include bug fixes, enhancements, and one miscellaneous
modification regarding assignment of ambient temperature at stacks. While these
updates to the meteorological data and modeling software may result in a small
change to the modeled concentrations and risk calculations, it is the City’s belief
that these changes would be minor. Furthermore, given that the cancer and
chronic hazard risk calculations shown in Table 4.2-14 of DEIR are so far below
thresholds, any changes would not result in a significant health risk impact.
Therefore, given that existing risk values are so low and that a re-model would
likely only result in minor changes, it is the City’s position that it is unnecessary
to re-run the AAQA or HRA models.
c. As the District states, the pathways enabled in HARP are correct since only DPM
is modeled, as DPM is estimated through the inhalation pathway only. Risk
associated with restaurants was determined to be negligible and far below any
contribution associated with diesel activity, thus restaurants were not modeled.
Therefore, enabling additional exposure pathways is not necessary.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-43
October 2015
d. Based on discussions with the project applicant, the Air Quality expert concludes
that the original assumption that all trucks would travel the entire length of the
roadway encircling the project would be the most conservative, and most
accurate methodology for calculating DPM. It is implausible for diesel delivery
trucks to maneuver U-turns or reverse after making deliveries behind shops. It
would be inappropriate to calculate DPM for truck travel or idling using a
different, less conservative methodology. As such, the original modeling and
emissions estimations for DPM is appropriate and no changes are warranted.
e. While there are spaces for restaurants included in the proposed project, any risk
associated with these restaurants would be low. The District’s screening tool for
many emission source types (mall.xls), which includes fast food restaurants,
shows that risk from a typical fast food restaurant to be low even at 25 meters,
with risk decreasing appreciably with distance. As noted in comment 6-C-b and
6-C-c, the risk levels from diesel-related activity are well-below thresholds and
any risk associated with any restaurant activity would be minor. Therefore, given
the development specifics provided by the project applicant, the low risk levels
from diesel-related activity, and the small risk associated with typical restaurant
activities, the inclusion of restaurant-generated TACs is not necessary to make a
determination of less-than-significant.
f. It is common practice to use an area source to model emissions where the
modeler does not know specifically where the emissions will be occurring within
the source, particularly when the area being modeled is flat. Volume source
requires specific locations as the emissions release point is essentially within the
center of the volume source. ARB has performed numerous HRAs at railyards
throughout the state and uses area sources to model emissions from mobile
equipment and vehicles operating over large areas. Therefore, given that using an
area source is standard practice and the exact location of activity is unknown, it is
the City’s position that it is unnecessary to re-run the AAQA or HRA models.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-44
October 2015
Comment Letter 7. Kern County Superintendent of
Schools (August 10, 2015)
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-45
October 2015
Response to Comment Letter 7. Kern County Superintendent of
Schools (August 10, 2015)
Thank you for your comments. The participation of the Kern County
Superintendent of Schools in the public review of this document is appreciated.
The commenter notes that the office has reviewed the Draft EIR for the
SR 99/Hosking Commercial Center Project and summarizes the proposed project.
The commenter requests that the project proponent contribute toward the
statutory fees authorized under Education Code Section 17620 and Government
Code Section 65995 et seq. (all as amended with an operative date of November
4, 1995) at the time that building permits are issued to mitigate project impacts
on public school facilities. No impacts on schools were identified in the Draft
EIR. However, payment of school fees is statutorily required, and such fees
would be collected from the applicant prior to issuance of building permits. Since
payment of school fees is statutorily required, no additional mitigation measures
of conditions to the project are necessary.
The comment has been noted for the record is and provided to the City of
Bakersfield for consideration.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-46
October 2015
Comment Letter 8. Tejon Indian Tribe (June 18, 2015)
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-47
October 2015
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-48
October 2015
Response to Comment Letter 8. Tejon Indian Tribe (June 18,
2015)
8-A. Mitigation Measure MM CR-1 (c) was added on page 4.4-11 of Section 4.4, Cultural
Resources of the EIR to address cultural resources training, prior to ground-
disturbing activities. This training shall be conducted by representatives from the
Tejon Indian Tribe or qualified archaeologist.
Specifically, Mitigation Measure MM CR-1 (c) states:
(c) Cultural Resources Training. Prior to ground-disturbance activities associated
with this project, personnel associates with the grading effort shall be informed
of the importance of the potential cultural and archaeological resources (i.e.
archaeological sites, artifacts, features, burials, human remains, etc.) that may be
encountered during site preparation activities, how to identify those resources in
the field, and of the regulatory protections afforded to those resources. This
training shall be conducted by representatives from the Tejon Indian Tribe or
qualified archaeologist. The personnel shall be informed of procedures relating to
the discovery of archaeological remains during grading activities and cautioned
to avoid archaeological finds with equipment and not collect artifacts. The
applicant/developer of the project site shall submit documentation to the Planning
Department that they have met this requirement prior to commencement of
ground disturbance activities. This documentation should include information on
the date(s) of training activities, the individual(s) that conducted the training, a
description of the training, and a list of names of those who were trained. Should
cultural remains be uncovered, the on–site supervisor shall immediately notify a
qualified archaeologist and the Tejon Indian Tribe. The developer shall provide
the Tejon Indian Tribe information on excavation depth of the construction of the
site.
The commenter also requests that a copy of the Project’s ND, MND, or EIR be
forwarded to the Tejon Tribe for review. A copy of the Project’s Draft EIR was
distributed to the Kathy Morgan, Chair of the Tejon Indian Tribe, at the start of the
public review period in compliance with the SB 18 (Chapter 905, Statutes of 2004)
consultation process.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-49
October 2015
Comment 9. Betty Stephens (July 17, 2015)
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-50
October 2015
Response to Comment 9. Betty Stephens (July 17, 2015)
9-A. Thank you for your comment. The commenter’s interest in the air quality impacts
of the proposed project have been noted for the record. Please refer to Section
4.2, Air Quality, and Section 4.6, Greenhouse Gas Emissions, for related
discussion of these concerns and for mitigation measures incorporated into
project design to reduce potential impacts from project operations. No comments
related to the adequacy of the analysis contained in the Draft EIR are provided.
Therefore, no further response is warranted.
9-B. Thank you for your comment. The commenter suggests that drought-tolerant
landscaping be used for the proposed project. Please refer to page 4.8-21 of the
Draft EIR for Mitigation Measure MM WQ-2(c), which addresses the use of
drought-tolerant landscaping and is subject to approval by the City of
Bakersfield. No comments related to the adequacy of the analysis contained in
the Draft EIR are provided. Therefore, no further response is warranted.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-51
October 2015
Comment 10. Public Hearing Transcripts, July 16, 2015
10-A. During the Draft EIR Adequacy Hearing before the City of Bakersfield on July
16, 2015, a public comment was made by Mr. Phil Rudnick about the project
being beneficial for the community by providing jobs and services.
Response to Comment 10. Public Hearing Transcripts, July 16,
2015
10-A. The commenter, who has lived in the community for 83 years within a half mile
of the project, expresses support for the project. Specifically, the commenter
states that the property has been in non-production for a long time and believes
that the project is beneficial for the community by providing jobs and services.
The comment does not relate to the adequacy of the Draft EIR and, therefore, no
further response is warranted.
Thank you for your comment. This comment has been noted for the record and
will be provided to the City of Bakersfield for consideration.
City of Bakersfield
Chapter 7. Response to Comments
Final Environmental Impact Report
SR 99/Hosking Commercial Center Project
7-52
October 2015
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