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HomeMy WebLinkAboutBonita Glen Response To CommentsResponses to Comments February 2019 RTC-1 Bonita Glen Project BONITA GLEN PROJECT RESPONSE TO COMMENTS Responses to Comments February 2019 RTC-2 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-3 Bonita Glen Project RTC. Bonita Glen Response to Comments RTC.1 Introduction This chapter of the Final Mitigated Negative Declaration (MND) includes a list of persons, organizations, and public agencies that provided written comments on the MND during or after the public review period, as well as a copy of the comments received by the City of Chula Vista (City) during (and after) the public review process for the MND and the City’s responses to these written comments. The MND for the proposed Bonita Glen Project (project) was prepared and circulated for public review from December 17, 2018 through January 23, 2019. During that time, the City received two agency comment letters, one organization comment letter, and 15 individual comment letters. The comments have been assigned an alphanumeric label, and the individual comments within each written comment letter are bracketed and numbered. For example, Comment Letter A contains one comment that is numbered A-1. The City’s responses to each comment of the MND represent a good-faith, reasoned effort to address the environmental issues identified by the comment. Under the State California Environmental Quality Act (CEQA) Guidelines, the City is not required to respond to all comments on the MND, but only those comments that raise environmental issues. In accordance with CEQA Guidelines Sections 15088 and 15204, the City has independently evaluated the comments and prepared the following written responses describing the disposition of any significant environmental issues raised. CEQA does not require the City to conduct every test or perform all research, study, or experimentation recommended or demanded by commenters. Rather, CEQA requires the City to provide a good faith, reasoned analysis supported by factual information. To fulfill these requirements, the City’s experts in planning and environmental sciences consulted with and independently reviewed analysis responding to the MND comments prepared by Dudek and other experts, each of whom has years of educational and field experience in their field of environmental sciences; is familiar with the project and the environmental conditions in the City; and is familiar with the federal, state, and local rules and regulations (including CEQA) applicable to the proposed project. Accordingly, the City staff’s final analysis provided in the responses to comments below are backed by substantial evidence. Likewise, the City prepared and/or independently reviewed legal analysis supplementing the responses to the MND comments. Revisions to the text of the Draft MND were not required, since no new significant information regarding the project or environmental setting was provided since the time of the Notice of Availability. Responses to Comments February 2019 RTC-4 Bonita Glen Project RTC.2 Response to Comments The following section includes a list of persons, organizations, and public agencies that provided written comments on the MND during, or after, the public review period, as well as a copy of the comments received by the City during (and after) the public review process for the MND and the City’s responses to these written comments. Table RTC-1 provides a list of all written comments received during the public comment period. Table RTC-1 List of Commenters on the Mitigated Negative Declaration Alphabetical Designator Category Commenter A Individual David Butler B Individual Claire Wachowiak C Individual Susan Wachowiak D Individual Suellen Butler E Individual Christine Malone F Individual Claire Wachowiak G Individual Kevin Malone H Individual Susan Wachowiak I Individual Scott Olsen J Individual Susan Wachowiak K Individual Kevin Malone L Individual John Salts M Individual Hector Vanegas N Organization Southwest Regional Council of Carpenters O Individual Scott Olsen P Individual Gloria and Mark Ramsey Q Agency Eric Lardy R Agency Scott Morgan Responses to Comments February 2019 RTC-5 Bonita Glen Project Responses to Comments February 2019 RTC-6 Bonita Glen Project Response to Comment Letter A David Butler December 21, 2018 A-1 The commenter expresses their concern regarding general traffic in the local roadway network, including narrow County of San Diego (County)-owned roads like Pepper Tree Road, resulting from the proposed Bonita Glen Project (project). As discussed in the Draft Mitigated Negative Declaration (MND) and the Traffic Impact Analysis (TIA) referenced in the Draft MND, following discussions with the City of Chula Vista (City), the following roadway segments were included in the TIA: 1. Bonita Road, between East Flower Street/Bonita Road and Bonita Glen Drive 2. Bonita Road, between Bonita Glen Drive and Interstate (I) 805 Southbound On- /Off-Ramps 3. Bonita Road, between I-805 Southbound On-/Off-Ramps and I-805 Northbound On-/Off-Ramps 4. Bonita Glen Drive, between Bonita Road and Adrienne Drive 5. Vista Drive, between Adrienne Drive and Ola Court 6. Pepper Tree Road, between Jacaranda Drive and Vista Drive Of the study roadway segments, Bonita Glen Drive, Vista Drive, and Pepper Tree Road were analyzed using County standards. For the purposes of this analysis, the TIA determines whether the proposed project would push the existing level of service (LOS) over the acceptable LOS threshold for each roadway, which is established by the County. Pepper Tree Road is classified as a Local Public Roadway under the County standards, and the project contributes no more than 100 trips to that roadway. As discussed in the Draft MND and the TIA referenced in the MND, all study segments are forecasted to operate at an acceptable LOS (D or better) under all assessed conditions, in regard to County roadway segments. Real or perceived existing roadway hazards are not subject to California Environmental Quality Act (CEQA) review as long as the proposed project does not exacerbate the issue, and the project does not. The County of San Diego General Plan Mobility Element and City of Chula Vista General Plan Mobility Element classify roadways based on the number of lanes of the roadway. These roadway classifications formed the basis of the TIA, therefore the City Responses to Comments February 2019 RTC-7 Bonita Glen Project has taken the study roadway widths into account. Since the proposed project would not result in a significant impact on these roadways, the CEQA requirements have been met. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. A-2 The commenter expresses their concern regarding parking insufficiencies along Bonita Glen Drive. As referenced in the Draft MND, a technical memorandum was prepared to document the current parking demand and determine whether the proposed project would provide sufficient parking to accommodate its future residents. The memorandum explains that State law requires the proposed project to provide a total of 212 parking spaces (one space/dwelling unit for the six studio and 122 one-bedroom apartments, and two spaces/dwelling unit for the 42 two-bedroom apartments). The proposed project exceeds these legal requirements, providing a total of 231 on-site parking spaces. This allows for a demand of 1.36 spaces per unit, or 1.09 spaces per bedroom. Based on observations performed at other properties within the area, and taking into account the unit mix which at the proposed project is 75% studio and one- bedroom units, the 231 spaces provided by the proposed project would be sufficient to accommodate its parking demand on site. The technical memorandum by the parking expert also looked at the existing on-street parking, and found that there were 97 on-street parking spaces on Bonita Glen Drive south of Bonita Road, and that the average occupancy at 10:00 p.m. on Bonita Glen Drive was 70 vehicles, which would leave approximately 27 available spaces on Bonita Glen Drive to accommodate any worst-case overflow parking from the proposed project. The experts in preparing the technical memorandum on parking looked at similar and surrounding developments and found the maximum parking demand per unit at any time being 1.46 spaces for the Bonita Court property on Sunday, April 15, 2018 at 10 p.m. However, 73% of the apartments at the Bonita Court development are two-bedroom units. The proposed project’s unit mix of 75% studio or one-bedroom is most similar to the Point Bonita project. Point Bonita generates a maximum parking demand of 1.15 spaces per unit. The City’s Transportation/Traffic threshold questions do not pertain to parking; however, the parking technical memorandum was provided in response to public comments. As such, this issue has been adequately addressed. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. It is also worth noting that there is a bus stop directly across the street, less than one-half mile from this infill project. Responses to Comments February 2019 RTC-8 Bonita Glen Project A-3 The commenter restates claims already addressed in Response A-2 and does not raise an environmental issue within the context of CEQA. The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary. Responses to Comments February 2019 RTC-9 Bonita Glen Project Responses to Comments February 2019 RTC-10 Bonita Glen Project Responses to Comments February 2019 RTC-11 Bonita Glen Project Response to Comment Letter B Claire Wachowiak December 28, 2018 B-1 The Draft Mitigated Negative Declaration (MND) references the Traffic Impact Analysis (TIA) prepared by Chen Ryan Associates in 2018 for the proposed Bonita Glen Project (project). The TIA identifies intersections and roadway segments that would be effected by the proposed project. Through discussion with City of Chula Vista (City) staff, the study area was determined to include the following roadway segments: 1. Bonita Road, between East Flower Street/Bonita Road and Bonita Glen Drive 2. Bonita Road, between Bonita Glen Drive and Interstate (I) 805 Southbound On- /Off-Ramps 3. Bonita Road, between I-805 Southbound On-/Off-Ramps and I-805 Northbound On-/Off-Ramps 4. Bonita Glen Drive, between Bonita Road and Adrienne Drive 5. Vista Drive, between Adrienne Drive and Ola Court 6. Pepper Tree Road, between Jacaranda Drive and Vista Drive These segments were analyzed using County of San Diego (County) and City standards, depending on which jurisdiction the roadway falls into. These roadway segments were analyzed using estimated trip generation for the proposed project under Existing Conditions, Existing plus Project Conditions, Future Year 2035 Base Conditions, and Future Year 2035 Base plus Project Conditions. As further relayed in the Initial Study, all study roadway segments are projected to operate at acceptable levels under all future conditions. Therefore, based on the City and County significance criteria, the proposed project would not result in a significant impact on these roadway segments. County Traffic Impact Guidelines require a proposed project to analyze the traffic impacts on a given roadway if the proposed project is projected to add 25 or more peak hour trips to the roadway. The TIA concluded that the proposed project would not add enough trips to Adrienne Drive, Ola Court, or Jacaranda Drive to require traffic impact analysis on these roadways. Therefore, they were not selected as study roadways in the TIA. As such, California Environmental Quality Act (CEQA) requirements have been met, and the comment has been adequately addressed. The City Responses to Comments February 2019 RTC-12 Bonita Glen Project is including this comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. B2 The commenter expresses concern regarding the existing roadways’ ability to sustain project traffic. As discussed in the TIA, the analysis of the study roadway segments uses the City and County level of service (LOS) standards and thresholds to determine whether the proposed project would have a negative impact on the roadways. Roadway segment LOS standards and thresholds provide the basis for analysis of arterial roadway segment performance. The analysis of roadway segment LOS is based on the functional classification of the roadway, the maximum capacity, roadway geometrics, and existing and forecast average daily traffic volumes. As discussed in Section 3.1, Existing Roadway Network, of the TIA, the width of Bonita Glen varies between 30 and 40 feet; Bonita Road is approximately 72 feet wide and widens to approximately 100 feet at the I-805 Southbound On-/Off-Ramp intersection; Vista Drive varies between 25 and 30 feet; and Pepper Tree Road varies between 25 and 30 feet. Under existing roadway width conditions, all study roadway segments are projected to operate at acceptable LOS under all future conditions. Therefore, based on the City and County significance criteria, the proposed project would not result in a significant project-related impact. The City is including this comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. B-3 Table 3.2 (County of San Diego) of the TIA classifies a segment of Bonita Glen Drive from Bonita Road to Adrienne Drive as a Two-Lane Minor Collector, and a segment of Vista Drive from Adrienne Drive to Ola Court as “Local Public Roadway.” That Table is referencing segments of Bonita Glen Drive and Vista Drive that start or end at Adrienne Drive, and is not classifying Adrienne Drive itself. The roads are correctly referenced in the TIA. The comment does not raise any specific issue regarding the analysis provided in the Draft MND; therefore, no more specific response can be provided or is required. The City is including this comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. B-4 The TIA did not look at the project traffic only from a general, regional level, but evaluated it on a project-specific level. As discussed in Responses A-1 and B-1, through discussion with City staff and based on well-founded City and County criteria as well as professional standards, the study area was determined to include Bonita Glen Drive, Responses to Comments February 2019 RTC-13 Bonita Glen Project Bonita Road, Vista Drive, and Pepper Tree Road. County Traffic Impact Guidelines require a proposed project to analyze the traffic impact on a given roadway if the proposed project is projected to add 25 or more peak hour trips to the roadway. The TIA determined that the proposed project would not add enough trips to Adrienne Drive, Ola Court, or Jacaranda Drive to require traffic impact analysis on these roadways under the established criteria. The roadway width and configurations are taken into account as part of the roadway classification by the City and/or County. Based on applicable standards, Adrienne Drive, Ola Court and Jacaranda Drive do not meet the threshold for inclusion as study roadways in the TIA. B-5 The project is consistent with the visions set forth in the City’s General Plan, including Chapter 4, as well as the Bonita Glen Specific Plan. With La Quinta Hotel to the north, the Point Bonita Apartments and Townhomes to the west, and single-family homes to the east, the project is consistent and harmonizes with the surrounding commercial land uses, and variety of housing densities in the vicinity. As discussed in the proposed project’s Draft MND and TIA, all study segments are forecasted to operate at an acceptable LOS (D or better) under all assessed conditions for County roadway segments. The proposed project would not result in a significant impact on the referenced roadways according to the TIA, which was prepared by traffic experts using established City and County criteria. Therefore, CEQA requirements have been met and this issue has been adequately addressed. The City is including this comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. Responses to Comments February 2019 RTC-14 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-15 Bonita Glen Project Responses to Comments February 2019 RTC-16 Bonita Glen Project Responses to Comments February 2019 RTC-17 Bonita Glen Project Response to Comment Letter C Susan Wachowiak January 7, 2019 C-1 The commenter restates information contained in the General Plan regarding the City of Chula Vista’s (City) community character. The City is including the comment as part of the Final Mitigated Negative Declaration (MND) for review and consideration by the decision makers prior to a final decision on the proposed Bonita Glen Project (project). No further response is required or necessary. C-2 The commenter alleges that the proposed project is in conflict with Chapter 4 of the City’s General Plan with respect to the character, safety, scale, or historic value of the City. Consistency with the City’s General Plan is discussed in Section X, Land Use and Planning, of the Initial Study. As explained in the Initial Study and as stated in the Bonita Glen Specific Plan (Specific Plan), residential development is permitted on the project site, following the process described therein. The proposed project has been designed to provide much-needed housing while also respecting the character of the surrounding neighborhood, which includes residential (including multi-family residential), and furthering the goals of the General Plan (see Initial Study Section XIII, Population and Housing). The Specific Plan envisions and allows adjustment to standards and regulations that are allowed by the State Density Bonus rules and regulations. The proposed project would not require a rezone or a Specific Plan Amendment. The proposed project complies with the General Plan and the Specific Plan, and all environmental impacts would be mitigated to less than significant. Therefore, this issue has been adequately addressed. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. Responses to Comments February 2019 RTC-18 Bonita Glen Project C-3 The commenter expresses their general opposition to the proposed project and its effect on the “already here” citizens. The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. The MND has concluded, based on expert studies and analysis, that the proposed project would not have any significant impact on the environment. In addition, as noted in Response C- 2, the project is consistent with the General Plan and Specific Plan. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary. Responses to Comments February 2019 RTC-19 Bonita Glen Project Responses to Comments February 2019 RTC-20 Bonita Glen Project Responses to Comments February 2019 RTC-21 Bonita Glen Project Responses to Comments February 2019 RTC-22 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-23 Bonita Glen Project Response to Comment Letter D Suellen Butler January 8, 2019 D-1 The commenter expresses their concern regarding street parking availability on Bonita Glen Drive. The City of Chula Vista (City) Transportation/Traffic threshold questions do not require analysis of parking; however, the City nonetheless had a parking technical memorandum prepared and provided in response to public comments. As referenced in the Draft Mitigated Negative Declaration (MND), that technical memorandum was prepared to document the current parking demand and determine whether the proposed Bonita Glen Project (project) will provide sufficient parking to accommodate its future residents. As the memorandum explains, State law requires the proposed project to provide a total of 212 parking spaces (one space/dwelling unit for the six studio and 122 one-bedroom apartments, and two spaces/dwelling unit for the 42 two-bedroom apartments). The proposed project exceeds these legal requirements, providing a total of 231 on-site parking spaces. This allows for a demand of 1.36 spaces per unit, or 1.09 spaces per bedroom. Based on observations performed at other properties within the area, and taking into account the unit mix which at the proposed project is 75% studio and one-bedroom units, the 231 spaces provided by the proposed project would be sufficient to accommodate its parking demand on site. The technical memorandum by the parking expert also looked at the existing on-street parking, and found that there were 97 on-street parking spaces on Bonita Glen Drive south of Bonita Road, and that the average occupancy at 10:00 p.m. on Bonita Glen Drive was 70 vehicles, which would leave approximately 27 available spaces on Bonita Glen Drive to accommodate any worst-case overflow parking from the proposed project. The experts in preparing the technical memorandum on parking looked at similar and surrounding developments and found the maximum parking demand per unit at any time being 1.46 spaces for the Bonita Court property on Sunday, April 15, 2018 at 10 p.m. However, 73% of the apartments at the Bonita Court development are two-bedroom units. The proposed project’s unit mix of 75% studio or one-bedroom is most similar to the Point Bonita project. Point Bonita generates a maximum parking demand of 1.15 spaces per unit. The City’s Transportation/Traffic threshold questions do not pertain to parking; however, the parking technical memorandum was provided in response to public comments. As such, this issue has been adequately addressed. The Responses to Comments February 2019 RTC-24 Bonita Glen Project City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. It is also worth noting that there is a bus stop directly across the street, less than one-half mile from this infill project. D2 The commenter expresses their concern regarding existing physical road conditions on Bonita Glen Drive. Bonita Glen Drive was included in the City’s Capital Improvement Program (CIP) Project STL0435, which identified a number of City streets to be rehabilitated. The City is currently in the process of selecting contractors and implementation planning. The estimated time of Bonita Glen’s rehabilitation will be established at a later date. In addition, the proposed project would pay development impact fees at the time of building permit issuance. Existing potholes are not subject to California Environmental Quality Act (CEQA) review as long as the proposed project does not exacerbate the issue, and the proposed project would not result in a significant impact on Bonita Glen Drive. Therefore, CEQA requirements have been met. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. D-3 The commenter expresses their concern regarding the increase in traffic as a result of the proposed project. The comment is specifically concerned with freeway on- and off- ramps and the on-street parking capacity on Vista Drive. As shown in Section XVI, Transportation/Traffic, of the Initial Study, the following on- and off-ramps were analyzed in the Traffic Impact Analysis: ● Interstate (I) 805 Southbound (SB) On-/Off-Ramps at Bonita Road ● I-805 Northbound (NB) On-/Off-Ramps at Bonita Road In addition, the follow ing roadway segments were analyzed under the Traffic Impact Analysis: ● Bonita Road, between Bonita Glen Drive and I-805 SB On-/Off-Ramps ● Bonita Road, between I-805 SB On-/Off-Ramps and I-805 NB On-/Off-Ramps The I-805 and Bonita Road intersections are expected to operate at an acceptable level of service (LOS) during the AM and PM peak hours under all analyzed conditions. Additionally, the roadway segments analyzed at the I-805 On-/Off-Ramps are forecasted to operate at an acceptable LOS (D or better) under all analyzed conditions. Responses to Comments February 2019 RTC-25 Bonita Glen Project As a result, there would not be any significant backup on the off -ramp as a result of the project. The concern regarding on-street parking was evaluated in the technical memorandum referenced in the Initial Study. The commenter may be erroneously referring to Bonita Glen Drive, not Vista Drive, as since the attached photo of street parking is of Bonita Glen Drive. Please see Response A-2 and Response D-1 regarding parking, and note that the parking technical memorandum prepared in response to public concerns regarding on-street parking capacity on Bonita Glen Drive found that there would be adequate parking even in a worst-case scenario. The memorandum explains that State law requires the proposed project to provide a total of 212 parking spaces (one space/dwelling unit for the six studio and 122 one-bedroom apartments, and two spaces/dwelling unit for the 42 two-bedroom apartments). The proposed project exceeds these legal requirements, providing a total of 231 on-site parking spaces. This allows for a demand of 1.36 spaces per unit, or 1.09 spaces per bedroom. Based on observations performed at other properties within the area, and taking into account the unit mix which at the proposed project is 75% studio and one-bedroom units, the 231 spaces provided by the proposed project would be sufficient to accommodate its parking demand on site. Even though the City’s Transportation/Traffic threshold questions do not require an analysis of parking, a parking technical memorandum was provided for the proposed project in response to public comments. In addition, please note that the Bonita Glen Specific Plan in place on this property since the 1970s assumed higher traffic volumes than would be generated by the proposed project response to public comments. As such, this issue has been adequately addressed. The commenter also expresses their general opposition to the proposed project, and does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. D-4 The photo of Bonita Glen Drive is referenced earlier in the comment letter. Please refer to Responses A-2 and D-1 regarding on-street parking on Bonita Glen Drive. Responses to Comments February 2019 RTC-26 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-27 Bonita Glen Project Responses to Comments February 2019 RTC-28 Bonita Glen Project Responses to Comments February 2019 RTC-29 Bonita Glen Project Responses to Comments February 2019 RTC-30 Bonita Glen Project Responses to Comments February 2019 RTC-31 Bonita Glen Project Responses to Comments February 2019 RTC-32 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-33 Bonita Glen Project Response to Comment Letter E Christine Malone January 12, 2019 E-1 The commenter expresses their general opposition to the proposed Bonita Glen Project (project), and does not raise an issue related to the adequacy of any specific section or analysis of the Draft Mitigated Negative Declaration (MND). The City of Chula Vista (City) is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. E-2 The City acknowledges the comment, which does not raise an issue related to the adequacy of any specific section or analysis; therefore, no more specific response can be provided or is required. Note, however, that the project area includes a mix of uses, including commercial and multi -family, and that the Bonita Glen Specific Plan also allows a mix of uses, including multi -family, on the project site. See Response C-2 regarding consistency with the General Plan and Specific Plan. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary. E-3 The City acknowledges the comment, which does not raise an issue related to the adequacy of any specific section or analysis. The commenter speculates about how much pride apartment dwellers take in their home, which is not a topic covered under the California Environmental Quality Act (CEQA). See Responses A -2 and D-1 regarding parking. The potential traffic impacts from the proposed project are addressed in the Draft MND and the proposed project’s Traffic Impact Analysis (TIA). The roadway segments of Bonita Glen Drive, Vista Drive, and Pepper Tree Road are County of San Diego (County) roads and thus were analyzed using County standards. For the purposes of this analysis, the TIA determines whether the proposed project would push the existing level of service (LOS) over the acceptable LOS threshold for each roadway analyzed, which is established by the County. As discussed in the Draft MND and the TIA, all study segments are forecasted to operate at an acceptable LOS (D or better) under all assessed conditions. For traffic, see also Responses A-1, B-1, B-2, B-4, B-5, and D-3. Since the proposed project would not result in a significant impact on these roadways and would provide an adequate Responses to Comments February 2019 RTC-34 Bonita Glen Project number of parking spaces on site, CEQA requirements have been met. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. E-4 The commenter references attached photos of litter along Bonita Glen Road. Street litter is not a topic covered under CEQA. Street litter is addressed through street sweeping, which occurs on Bonita Glen Road the first Monday of every 2 months (City of Chula Vista 2019). Moreover, as discussed in Responses A -2 and D-1, the parking memorandum concludes that the anticipated parking demand for the project would be met on site. E-5 The City acknowledges the comment and notes that it raises economic, social, or political issues that do not relate to any physical effect on the environment. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required because the comment does not raise an environmental issue. E-6 The commenter expresses their general opposition to the proposed project and support for a storage unit as a preferred alternative. The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. E-7 See Response C-2 regarding the project’s consistency with the City’s General Plan, as well as Section X, Land use and Planning, of the Initial Study. Responses to Comments February 2019 RTC-35 Bonita Glen Project Responses to Comments February 2019 RTC-36 Bonita Glen Project Responses to Comments February 2019 RTC-37 Bonita Glen Project Responses to Comments February 2019 RTC-38 Bonita Glen Project Responses to Comments February 2019 RTC-39 Bonita Glen Project Responses to Comments February 2019 RTC-40 Bonita Glen Project Responses to Comments February 2019 RTC-41 Bonita Glen Project Responses to Comments February 2019 RTC-42 Bonita Glen Project Responses to Comments February 2019 RTC-43 Bonita Glen Project Responses to Comments February 2019 RTC-44 Bonita Glen Project Responses to Comments February 2019 RTC-45 Bonita Glen Project Responses to Comments February 2019 RTC-46 Bonita Glen Project Responses to Comments February 2019 RTC-47 Bonita Glen Project Responses to Comments February 2019 RTC-48 Bonita Glen Project Responses to Comments February 2019 RTC-49 Bonita Glen Project Responses to Comments February 2019 RTC-50 Bonita Glen Project Responses to Comments February 2019 RTC-51 Bonita Glen Project Responses to Comments February 2019 RTC-52 Bonita Glen Project Responses to Comments February 2019 RTC-53 Bonita Glen Project Response to Comment Letter F Claire Wachowiak January 13, 2019 F-1 The City of Chula Vista (City) acknowledges the comment as an introduction to comments that follow. This comment is included in the Final Mitigated Negative Declaration (MND) for review and consideration by the decision makers prior to a final decision on the proposed Bonita Glen Project (project). The Initial Study (IS), MND and Traffic Impact Analysis (TIA) are accurate in regards to the referenced roads. See Response B-4 regarding Adrienne Drive, Ola Court and Pepper Tree Road. F-2 The commenter expresses their general concern regarding parking on Bonita Glen Drive and driving on Vista Road. The comment indicates that comments regarding this issue are included in the letter. Please see Responses A-2, D-1, F-10, F-11, and F-12 regarding parking. No further response is required. F-3 The comment references attached photos for context in following comments. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. F-4 The commenter has misinterpreted the road classifications provided in the Tables of the IS and the TIA. Please see Response B-3. Those classifications do not refer to Adrienne Drive. F-5 Please refer to Responses B-3 and F-4. The TIA, IS and MND were not referring to Adrienne Drive. Based on established standards and criteria, as discussed in the TIA, the proposed project would not add enough trips to Adrienne Drive to impact that roadway. Since the proposed project would not result in a significant impact on Adrienne Drive, the California Environmental Quality Act (CEQA) requirements have been met. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. F-6 The purpose of Figure 10, Project Study Traffic Areas, in the IS is to illustrate what roadways were analyzed in the TIA. The roadways shown in blue are study roadway segments that were assessed in the TIA, and the numbered intersections represent the intersections along Bonita Road assessed in the TIA. The comment indicates that Figure 10 erroneously labels part of Vista Drive as Bonita Glen Drive. The commenter Responses to Comments February 2019 RTC-54 Bonita Glen Project is correct in that the name of the road changes from Bonita Glen to Vista Drive when it extends south past Adrienne Drive. Although Figure 10 does not show the change in name on that roadway segment south of the Vista Drive and Bonita Glen Drive intersection as Vista Drive, the purpose of the figure was not compromised. The segment of Vista Drive from Bonita Glen Drive to Adrienne Drive was analyzed under the TIA, and no significant impacts to roadway segments or intersections were identified. As such, no revision to the Draft MND is required. F-7 As discussed in the TIA referenced in the Draft MND, Pepper Tree Road is classified as a Local Public Roadway with no on-street parking, based on roadway classifications established by the County of San Diego (County). The classification is not something established by the TIA, IS or MND; rather, the project’s traffic analysis must be based on already established classifications set by the appropriate jurisdiction. Roadway capacities and level-of-service (LOS) thresholds in the City were derived from the City’s General Plan Mobility Element. The comment disagrees with the County’s roadway designation, over which the City has no control. The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary. F-8 As discussed in the TIA referenced in the MND, the purpose of the TIA is to determine whether the project would push the existing LOS over the acceptable LOS threshold for each roadway analyzed, which for County roadways is established by the County. Pepper Tree Road is classified by the County as a Local Public Roadway under the County standards. As discussed in the Draft MND and the TIA referenced in the MND, all study segments are forecasted to operate at an acceptable LOS (D or better) under all assessed conditions on all County roadway segments. Moreover, the project adds very little traffic to Pepper Tree Road. Existing roadway hazards are not subject to CEQA review as long as the proposed project does not exacerbate the issue. Since the proposed project would not result in a significant impact on these roadways, the CEQA requirements have been met. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. Responses to Comments February 2019 RTC-55 Bonita Glen Project F-9 The commenter has misunderstood the references in Table 3.2, Roadway Segment Level of Service – Existing Conditions (County of San Diego), of the TIA, which classifies a segment of Vista Drive (not Ola Court) as a Local Public Roadway. As discussed in Response B-3, Table 3.2 (County of San Diego) of the TIA classifies a segment of Vista Drive from Adrienne Drive to Ola Court as “Local Public Roadway.” That Table is referencing a segment of Vista Drive that ends at Ola Court, and is not classifying Ola Court itself. The roads are correctly referenced in the TIA. Ola Court was not a roadway required to be further analyzed under the TIA. Adrienne Drive and Ola Court are included in Table 3.2 to identify where the studied segment of Vista Drive begins and ends. The comment does not raise any specific issue regarding the analysis provided in the Draft MND; therefore, no more specific response can be provided or is required. The City is including this comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. F-10 The commenter expresses their concern regarding parking insufficiencies along Bonita Glen Drive. As referenced in the MND, even though the City’s transportation/traffic threshold questions do not require analysis of parking, a parking technical memorandum was provided for the proposed project in response to public comments. That technical memorandum was prepared to document the current parking demand and determine whether the proposed project would provide sufficient parking to accommodate future residents. See also Responses A-2 and D-1. As noted there, the technical parking memorandum found that the 231 spaces provided by the proposed project would be sufficient to accommodate parking demand on site. As such, this issue has been adequately addressed. In addition, in response to public comments, the City’s Code Compliance is investigating whether the nearby apartment complex is complying with its permits regarding parking for its residents, and also is processing changes to the City’s Code to address concerns with charging residents for parking. The City is including this comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. F-11 The commenter expresses their concern about the existing conditions of parked cars on Bonita Glen Drive. The City allows public parking on public streets, and Bonita Glen is a public street. As discussed in Responses A-2 and D-1, the proposed project would be able to meet its parking demand on site, and even in a worse-case scenario overflow parking would be accommodated on Bonita Glen. A major transit stop is located across the street from the proposed infill project, further reducing the need for residents of the Responses to Comments February 2019 RTC-56 Bonita Glen Project project to drive and park. The parking supply was determined to be appropriate for the proposed use, and exceeds the legally required number of spaces. In addition, as discussed in the Draft MND and TIA, all study segments are forecasted to operate at an acceptable LOS under all assessed conditions. The decision to allow public parking on public streets is a City-wide issue not related to the proposed project, and the project has been designed to accommodate its reasonably anticipated parking demand on site. Existing roadway hazards are not subject to CEQA review as long as the proposed project does not exacerbate an existing issue. Since the proposed project would not result in a significant impact on these roadways, and would provide an adequate number of parking spaces on site, CEQA requirements have been met. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. F-12 The commenter expresses their concern regarding the width of Vista Drive. As discussed in in the Draft MND and TIA, all study segments are forecasted to operate at an acceptable LOS (D or better) under all assessed conditions, in regard to City and County roadway segments. Existing roadway hazards are not subject to CEQA review as long as the proposed project does not exacerbate the issue. Since the proposed project would not result in a significant impact on these roadways and would provide an adequate number of parking spaces on site, the CEQA requirements have been met. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. F-13 The comment misunderstands the road classification references in the TIA, IS and MND, as discussed in Responses B-3 and F-4. The road classification references are correct in the project studies. To the extent that the comment does not agree with the City and County street classifications themselves, those are City and County standard classifications not specific to the proposed project. The TIA prepared for the project accurately used the correct street classifications as they have been established by the City and County. The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary. Responses to Comments February 2019 RTC-57 Bonita Glen Project F-14 The City acknowledges the comment and notes that it expresses opposition to the proposed project and does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary. F-15 Please refer to Responses F-4 through F-6. F-16 Please refer to Responses F-4 through F-6. F-17 Please refer to Responses F-10 and F-11. F-18 Please refer to Responses F-10 and F-11. F-19 Please refer to Responses F-10 and F-11. F-20 Please refer to Response F-9. F-21 Please refer to Responses F-7 and F-8. F-22 Please refer to Responses F-7 and F-8. F-23 Please refer to Responses F-7 and F-8. F-24 Please refer to Responses F-7 and F-8. F-25 Please refer to Responses F-7 and F-8. F-26 Please refer to Response F-12. F-27 Please refer to Response F-12. F-28 Please refer to Response F-12. F-29 Please refer to Response F-12. Responses to Comments February 2019 RTC-58 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-59 Bonita Glen Project Responses to Comments February 2019 RTC-60 Bonita Glen Project Responses to Comments February 2019 RTC-61 Bonita Glen Project Response to Comment Letter G Kevin Malone January 13, 2019 G-1 The commenter expresses their general opposition to the proposed Bonita Glen Project (project), and speculates about the need for an Environmental Impact Report (EIR) due to the age of a prior EIR. The City of Chula Vista (City) is not relying on the previously prepared EIR, but, rather, prepared an Initial Study (IS) to evaluate whether or not an E IR was required. The IS determined, based on proper analysis under the California Environmental Quality Act (CEQA), that no EIR was required. The comment’s references to changes since 1984 ignore the recently completed analysis undertaken by the IS, which used current baseline conditions. The commenter also expresses general concern regarding unspecified noise, air pollution, and runoff water and flooding from Interstate (I) 805, which they believe have changed since 1984. Again, the City used current basel ine data to evaluate the project’s potentially significant impacts, and did not rely on baseline conditions from 1984. Also, CEQA does not require that the effects of environmental conditions on a project’s future residents or users be considered (California Building Industry Association v. Bay Area Air Quality Management District ). In addition, as referenced in the Draft Mitigation Negative Declaration (MND), the noise report prepared for the proposed project, which studied current conditions, concluded that the proposed project would not exacerbate traffic noise from I -805. A health risk assessment was performed to determine the risk to project residents from I-805. The results of the health risk assessment show that the cancer risk on site from emissions from I-805 would exceed the San Diego Air Pollution Control District’s threshold of 10 in 1 million and would result in a potentially significant impact. However, with mitigation, the cancer risk would be reduced to below the San Diego Air Pollution Contro l District’s significance threshold, and would therefore have a less -than-significant impact. Lastly, as discussed in the IS, the proposed project would include biofiltration basins that would direct runoff in multiple directions and eventually discharge i nto the existing drainage system. The proposed project density would not substantially alter the percolation patterns on the site once construction is complete. Therefore, the issues discussed in the comment were addressed in the Draft MND. Responses to Comments February 2019 RTC-62 Bonita Glen Project G-2 Please refer to Section IX, Hydrology and Water Quality, of the IS. A hydrologic and hydraulic analysis was prepared for Bonita Glen Creek, which demonstrated that the proposed ephemeral streambed within the proposed project can safely convey the 2- and 10-year design peak flow without overtopping or exceeding the allowed width buffer (Latitude 33 Planning and Engineering 2018a). Once constructed, on-site peak flows would be collected through the biofiltration basins and would discharge directly into the City storm drain infrastructure along Bonita Glen Drive. Outlet control would be provided in the biofiltration basins that would discharge directly into the City’s storm drain infrastructure along Bonita Glen Drive. The existing 33-inch public storm drain has a full flow capacity of 76.64 cubic feet per second based on the “as-built” slope of 2.1% (Latitude 33 Planning and Engineering 2018a). Water detention proposed in the 100-year floodplain will not affect the floodplain. In existing conditions, the floodplain area consists of dirt and shrubs, and during storm events, all runoff is directed into the existing ephemeral stream without any storage/outlet control. Additionally, as stated in the Preliminary Drainage Study, placing the infiltration basins in the 100-year floodplain will not affect the floodplain. Therefore, although the project site is within a floodplain, the project would not exacerbate any existing hazard associated with the floodplain. G-3 The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary. G-4 The density bonus law was enacted by the State to address the lack of adequate supply of affordable housing in California. The commenter expresses a general concern regarding increased traffic, parking problems, and congestion they fear will impact existing residents’ quality of life and property values if new housing is built in their neighborhood. Traffic and congestion from the proposed project were addressed in Section XVI, Transportation/ Traffic, of the IS. As discussed in the IS, all study area intersections are forecasted to operate at acceptable level of service (D or better) during the AM and PM peak hours under all analyzed conditions. In conclusion, the addition of proposed project traffic would not result in a significant impact to any study segment or intersection. The other issues discussed in the comment raise economic, social, or political issues that are not related to a physical effect on the environment. The City is including the comment as part of the Final Responses to Comments February 2019 RTC-63 Bonita Glen Project MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required. G-5 The commenter expresses their concern regarding the ability of the public to park along public streets such as Bonita Glen, which the commenter believes creates a hazardous roadway condition. The allowance of parking along the street is not associated with the project. See also Response F-11. Existing roadway hazards are not subject to CEQA review as long as the proposed project does not exacerbate the issue. Since the proposed project would not result in a significant impact on any of these roadways and would provide an adequate number of parking spaces on site, the CEQA requirements have been met. See Responses A-2, D-1, F-10 and F-11 regarding parking along Bonita Glen. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. G-6 See Responses A-2, D-1, F-10, F-11, and G-5. Even though the City’s transportation/traffic threshold questions do not require analysis of parking, a parking technical memorandum was prepared for the proposed project in response to public comments. That technical memorandum, referenced in the IS, explains that state law requires the proposed project to provide 212 parking spaces (one space per dwelling unit for the six studio and 122 one-bedroom apartments, and two spaces per dwelling unit for the 42 two-bedroom apartments). The proposed project exceeds these legal requirements, providing a total of 231 on-site parking spaces. This allows for a demand of 1.36 spaces per unit, or 1.09 spaces per bedroom. Based on observations performed at other properties within the area, and taking into account the unit mix which at the proposed project is 75% studio and one-bedroom units, the 231 spaces provided by the proposed project would be sufficient to accommodate its parking demand on site. Even though the City’s Transportation/Traffic threshold questions do not require an analysis of parking, a parking technical memorandum was provided for the proposed project in response to public comments. The parking technical memorandum surveyed Bonita Glen and confirmed that should the worst-case situation arise, there would be more than enough spaces along the street in which to park. CEQA does not consider even a parking deficit, by itself, to be an impact on the environment, and here the proposed project does not have a deficit but is in compliance with the parking legally required. While secondary impacts from a parking deficit should be analyzed to determine if there may be adverse environmental effects arising from it, here there is not a parking deficit, and yet the City nonetheless analyzed whether there would be any secondary Responses to Comments February 2019 RTC-64 Bonita Glen Project impacts from a worst-case scenario requiring parking on the street, and found that there were none As such, this issue has been adequately addressed. G-7 The commenter suggests the project property be purchased by the City and developed as a park or a commercial storage facility. Because the proposed project would not result in any significant and unavoidable environmental impacts, project alternatives were not required to be analyzed. In addition, note that the Bonita Glen Specific Plan (Specific Plan) has long planned for even more density on the site than is proposed by the project, and open space or park use would not be consistent with the Specific Plan. Developing the site as a park or commercial storage facility also would fail to help the City address its housing shortage, particularly its supply of affordable housing. The comment does not raise any specific issue regarding the analysis provided in the Draft MND; therefore, no more specific response can be provided or is required. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. G-8 The commenter claims that there are errors in the Notice of Intent figure. The figure was included in the Notice of Intent only to give the reader context for the location of the proposed project, which it did. The figure identifies Pepper Tree Road in the correct vicinity, even though the parcel map does not specifically show a street. As such, the purpose of the figure was not compromised and no revisions are necessary. The commenter also believes that the IS classifies Adrienne Drive as both a Two-Lane Minor Collector and a Local Public Roadway. See Responses B-3 and F-2 regarding the misunderstanding. G-9 The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. The Draft MND concludes that the project would not have a significant impact on the environment. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary. G-10 Please refer to Responses A-2, D-1, F-10, F-11, G-5, and G-6. Responses to Comments February 2019 RTC-65 Bonita Glen Project Responses to Comments February 2019 RTC-66 Bonita Glen Project Responses to Comments February 2019 RTC-67 Bonita Glen Project Responses to Comments February 2019 RTC-68 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-69 Bonita Glen Project Response to Comment Letter H Susan Wachowiak January 14, 2019 H-1 The commenter expresses a general concern regarding increased traffic and congestion. Traffic and congestion were addressed in Section XVI, Transportation/Traffic, of the Initial Study (IS). As discussed in the IS, all study area intersections are forecasted to operate at an acceptable level of service (LOS) (LOS D or better) during the AM and PM peak hours under all analyzed conditions. In conclusion, the addition of traffic associated with the proposed Bonita Glen Project (project) would not result in a significant impact to any study segment or intersection. See also Responses A-1 and B-2. H-2 The commenter expresses concern regarding general traffic in the local roadway network, and specifically with regard to the analysis of impacts to County of San Diego (County) roads. The commenter believes that the reports inaccurately classify certain roads; that apparently is based on a misinterpretation of the classifications provided in Tables 16 and 17 of the IS. Table 16 provides classifications and LOS for roadways within the City of Chula Vista (City), whereas Table 17 provides classifications and LOS for roadways within the County. The classifications column in Tables 16 and 17 relate to the roadway indicated in the first column; i.e., Bonita Glen Drive is classified as a Two-Lane Minor Collector and Vista Drive is classified as a Local Public Roadway under County standards (Table 17). The Draft Mitigated Negative Declaration (MND) correctly classifies and identifies the roadways. Also, as discussed in the IS and in the Traffic Impact Analysis (TIA) referenced in the Draft MND, all study segments are forecasted to operate at an acceptable LOS (D or better) under all assessed conditions, in regard to County roadway segments. See also Responses B-3 and F-4. Therefore, California Environmental Quality Act (CEQA) requirements have been met. H-3 The commenter expresses concern regarding general traffic in the local roadway network and believes that Pepper Tree Road was inaccurately classified in Section XVI, Transportation/Traffic, of the IS per City standards. However, Pepper Tree Road is a County road and therefore is not classified under City standards. Also, please note that Chula Vista’s e-zoning information relates to land use and is not a classification of roadways. Pepper Tree is classified as a Local Public Roadway under the County standards, as noted in Table 17 of the IS. For the purposes of this analysis, the TIA determines whether the proposed project would push the existing LOS over the LOS Responses to Comments February 2019 RTC-70 Bonita Glen Project threshold that the County has established for each roadway analyzed. As a Local Public Roadway, Pepper Tree Road has a capacity of 4,500 trips per day. Implementation of the proposed project with existing traffic would result in a total of 2,640 trips (average daily traffic), compared to Pepper Tree Road’s existing, without project condition, which has an average daily traffic of 2,538. Thus, Pepper Tree Road would remain under capacity and is forecasted to operate at an acceptable LOS (D or better) under all assessed conditions, in regard to County standards. Pepper Tree is not a “rural residential road,” and the comment confuses road classifications with zoning. The TIA does address potential impacts from Vista, noting that 104 of the 170 total dwelling units will access the site via Vista Drive, north of Bonita Glen Road. This segment of Vista Drive, between the Unnamed Cul-de-Sac and Bonita Glen Road, is currently constructed as a non-Mobility Element Local Public Roadway within the County of San Diego. The roadway currently provides access to three single-family dwelling units, which generate 10 trips per day for a total of 30 daily trips on the roadway. The roadway does not connect to any other roadways (other than the Unnamed Cul-de-Sac and Bonita Glen Road); therefore, there is minimal to no cut- through or cumulative traffic on the roadway. The proposed project is anticipated to add 624 additional daily trips to the roadway (104 units × 6 trips per multi-family unit), resulting in a total of 654 total trips along the roadway under proposed project conditions. This is well below the County’s daily design threshold for a Local Public Roadway, which is 4,500 trips per day. Since the segment of Vista Drive between the Unnamed Cul-de-Sac and Bonita Glen Road does not serve any cumulative or cut- through traffic and is projected to operate well below its design capacity with the implementation of the proposed project, the segment is not anticipated to be impacted by the proposed project under any scenario; therefore, no further analysis is required. H-4 The comment indicates that Table 16 of the IS erroneously refers to a portion of Vista Drive as Bonita Glen Drive. The commenter is correct in that Vista Drive extends north past Adrienne Drive. However, although mislabeled in the report, this segment was properly analyzed in the TIA, and this discrepancy does not change the outcome of any significance determination made in the Draft IS or the MND. See also Response F-6. The comment erroneously believes that the IS classifies Adrienne Drive as a Two-Lane Non-Circulation street. That is not the case. Table 16 of the IS classifies Bonita Glen Drive as Two-Lane Non-Circulation Element. Adrienne Drive is included in Table 16 Responses to Comments February 2019 RTC-71 Bonita Glen Project only to identify where the studied segment of Bonita Glen Drive ends. Adrienne Drive was not a roadway required to be further analyzed under the TIA. See also Responses B-3, B-4, and F-4 regarding Adrienne Drive. Lastly, the figure included in the Notice of Intent was to show the project location. The figure identifies Pepper Tree Road in the correct vicinity, even though the parcel map does not specifically show a street. The comment does not raise any specific issue regarding the analysis provided in the Draft MND; therefore, no more specific response can be provided or is required. H-5 The commenter asks if the City and County would “bring these roads to standards expected to handle the proposed traffic.” As discussed in the IS and the TIA, the proposed project would not result in a significant impact to any study segment or intersection. Further, all study segments are forecasted to operate at an acceptable LOS (D or better) under all assessed conditions, in regard to County roadway segments. The County of San Diego General Plan Mobility Element and City of Chula Vista General Plan Mobility Element classify roadways based on the number of lanes of the roadway. These roadway classifications formed the basis of the TIA, therefore the City has taken the study roadway widths into account. Therefore, current roadway conditions would be sufficient to meet the increased capacity demand resulting from the proposed project. The proposed project would include roadway improvements to the Vista Drive segment between the Unnamed Cul-de-Sac and Bonita Glen Road as project features. H-6 The commenter restates claims already addressed in Responses H-2 and H-3. The roads are correctly classified. See Responses B-3, F-4, and H-4. As such, the comment has been adequately addressed; no further response is necessary. H-7 The commenter expresses concern that the project would need to extend roadways or other infrastructure that is not taken into account in the population and housing section of the MND because of an alleged misidentification of the roadways. That is not the case. The roadways in the IS were correctly classified according to applicable City and County standards, and no road extensions are required as a result of the proposed project. See Responses B-3, F-4, and H-4 on the issue of road classification. As addressed in Response H-4, a portion of Vista Drive was erroneously referred to as Bonita Glen Drive. However, this segment was analyzed in the TIA and this discrepancy does not change the outcome of any significance determination made in the Draft IS or the MND. Therefore, transportation/traffic has been adequately addressed, and roadway improvements would not be required to accommodate the proposed project. As a result, no roadway extensions Responses to Comments February 2019 RTC-72 Bonita Glen Project would be required due to the project, and no change to the conclusions of the population and housing section would be required. Additionally, the commenter restates concerns already addressed in Response H-3 with regard to unanalyzed roadways. As such, the comment has been adequately addressed; no further response is necessary. Finally, the commenter expresses their concern regarding parking insufficiencies resulting from what the comment believes to be inaccuracies regarding road classifications. The roads were accurately classified, and for this and other reasons discussed in Responses A-2, D-1, F-10, F-11, G-5, and G-6 regarding parking, the project would not have a significant impact to parking. H-8 The commenter expresses concerns with potential impacts to intersections in the project vicinity, and specifically the East Flower Street/Bonita Road/E Street intersection and the Interstate 805 Southbound and Northbound On-/Off-Ramps on Bonita Road. The TIA identifies intersections that would be effected by the proposed project, and the intersections of concern were all analyzed. All study intersections, including the East Flower Street/Bonita Road/E Street intersection, are shown to operate at an acceptable LOS during the AM and PM peak hours under all analyzed conditions. Additionally, the roadway segments analyzed at the Interstate 805 On-/Off-Ramps are forecasted to operate at an acceptable LOS under all analyzed conditions. Further, existing intersection and roadway hazards are not subject to CEQA review as long as the proposed project does not exacerbate the issue. Since the proposed project would not result in a significant impact on these intersections and roadways, the CEQA requirements have been met. Responses to Comments February 2019 RTC-73 Bonita Glen Project Responses to Comments February 2019 RTC-74 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-75 Bonita Glen Project Response to Comment Letter I Scott Olsen January 14, 2019 I-1 The City of Chula Vista (City) acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft Mitigated Negative Declaration (MND). In addition, note that the proposed Bonita Glen Project (project) is consistent with the Bonita Glen Specific Plan. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary. I-2 As discussed in the Traffic Impact Analysis referenced in the Draft MND, the traffic experts have concluded after analysis based on professional standards that all study segments are forecasted to operate at an acceptable level of service (D or better) under all assessed conditions, on both the City and the County of San Diego roadway segments. Since the proposed project would not result in a significant impact on these roadways and would provide an adequate number of parking spaces on site, the California Environmental Quality Act (CEQA) requirements have been met. For more on traffic see Responses A-1, B-2, B-4, and D-3, among others; for more on parking see Responses A-2, D-1, F-10, F-11, G-5, and G-6. I-3 The commenter expresses their concern regarding parking insufficiencies resulting from implementation of the proposed project. As discussed in Responses A-2, D-1, F- 10, F-11, G-5, and G-6, a technical memorandum was prepared even though not required, in order to address residents’ concerns about existing parking along Bonita Glen. The parking memorandum explains that State law requires the proposed project to provide a total of 212 parking spaces (one space/dwelling unit for the six studio and 122 one-bedroom apartments, and two spaces/dwelling unit for the 42 two-bedroom apartments). The proposed project exceeds these legal requirements, providing a total of 231 on-site parking spaces. This allows for a demand of 1.36 spaces per unit, or 1.09 spaces per bedroom. Based on observations performed at other properties within the area, and taking into account the unit mix which at the proposed project is 75% studio and one-bedroom units, the 231 spaces provided by the proposed project would be sufficient to accommodate its parking demand on site. Responses to Comments February 2019 RTC-76 Bonita Glen Project I-4 The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary. Responses to Comments February 2019 RTC-77 Bonita Glen Project Responses to Comments February 2019 RTC-78 Bonita Glen Project Responses to Comments February 2019 RTC-79 Bonita Glen Project Responses to Comments February 2019 RTC-80 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-81 Bonita Glen Project Response to Comment Letter J Susan Wachowiak January 15, 2019 J-1 The commenter believes there is a discrepancy in the roadway classifications, and that under the County of San Diego’s (County’s) Mobility Element Pepper Tree Road and Vista Drive should be classified as Residential or Rural Residential instead of their current classification of Local Public Roads. However, the County has classified Pepper Tree Road and Vista Drive as Local Public Roadways with a capacity of 4,500 daily trips. The County General Plan Mobility Element (Chapter 4) does not include any mention of “non-mobility” or “Rural Residential” roads. As such, no further response can be provided regarding concerns for inconsistencies within the County General Plan Mobility Element. Any change of road classification would need to be processed through the County and is separate from the proposed Bonita Glen Project (project). The Initial Study (IS), Draft Mitigated Negative Declaration (MND) and Traffic Impact Analysis (TIA) must use current classifications for their analysis. J-2 Adrienne Road is not referred to as a “2 lane non CE” in the IS or MND. Table 16 of the IS accurately classifies a segment of Bonita Glen Drive that begins at Adrienne Drive as Two-Lane Non-Circulation Element. The commenter may have misinterpreted Table 16 as identifying Adrienne Drive as this classification. Adrienne Drive was included in Table 16 to identify where the studied segment of Bonita Glen Drive ends. Adrienne Drive was not a roadway required to be analyzed under the TIA. The County Traffic Impact Guidelines require a proposed project to analyze the traffic impact to a given roadway if the proposed project is projected to add 25 or more peak hour trips to the roadway. The TIA found that the proposed project would not add enough trips to Adrienne Drive to require traffic impact analysis on this roadway. See also Responses B-3, F-4 and H-4 regarding this misunderstanding of the Tables’ references to road classifications. The comment does not raise any specific issue regarding the analysis provided in the Draft MND; therefore, no more specific response can be provided or is required. J-3 Please refer to Response J-1. The IS, MND, and TIA used the correct road classifications. The roads are currently under capacity and have adequate capacity to handle the anticipated project traffic. Responses to Comments February 2019 RTC-82 Bonita Glen Project J-4 Please refer to Response J-1. The IS and MND used the correct road classifications. J-5 This comment is a copy of Comment Letter H. As such, this comment has been adequately addressed under Response to Comment Letter H; no further response is necessary. Responses to Comments February 2019 RTC-83 Bonita Glen Project Responses to Comments February 2019 RTC-84 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-85 Bonita Glen Project Response to Comment Letter K Kevin Malone January 15, 2019 K-1 The commenter raises concerns about the increase in water usage as a result of the proposed Bonita Glen Project (project). As discussed in Section XVII, Utilities and Service Systems, of the Initial Study, the proposed project would be serviced by the Sweetwater Authority. According to Sweetwater Authority records, water levels in production wells near National City have remained stable since about 1950. In addition, the Sweetwater Valley Groundwater Basin has not been identified in the California Department of Water Resources Bulletin 118 as in overdraft condition (Sweetwater Authority 2018). Sweetwater Authority receives a portion of its water from the Metropolitan Water District, whose supplies consist of Colorado River and State Water Project water from the Sacramento- San Joaquin Bay Delta. The Sweetwater Authority purchases approximately 21% of Metropolitan Water District’s total water deliveries. The Sweetwater Authority has 20 storage tanks that represent approximately 43.5 million gallons of treated water throughout its system, including a major buried reservoir with a capacity of 18 million gallons. The system has 23 pumping stations, with a total pumping capacity of approximately 36,000 gallons per minute from all distribution pumping sources. According to the Sweetwater Authority’s 2015 Urban Water Management Plan, water in this jurisdiction is projected to reach a potable water demand of 6,773 acre-feet per year for multi-family uses in 2020 (Sweetwater Authority 2016). The Sweetwater Authority has potable water available to meet that demand. The projected water demands are based on an assumed average water demand of 105 gallons per capita per day from 2020 to 2040, which is slightly higher than its current level (91 gallons per capita per day). The proposed 170 residential units, which are estimated to house up to 486 residents, would generate an insignificant portion of this demand for potable water of 57 acre-feet per year, which is equivalent to 0.84% of the total potable water demand for the Sweetwater Authority. The landscaped areas would not consist of water-intensive plant species, and anticipated water demand would remain less than 1% of the total demand for the Sweetwater Authority. As a result, impacts would be less than significant. Responses to Comments February 2019 RTC-86 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-87 Bonita Glen Project Responses to Comments February 2019 RTC-88 Bonita Glen Project Responses to Comments February 2019 RTC-89 Bonita Glen Project Responses to Comments February 2019 RTC-90 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-91 Bonita Glen Project Response to Comment Letter L John Salts January 15, 2019 L-1 The commenter expresses concerns with traffic and parking in the proposed Bonita Glen Project (project) vicinity. As discussed in the Initial Study (IS) and the Traffic Impact Analysis (TIA) referenced in the Draft Mitigated Negative Declaration (MND), all study segments are forecasted to operate at an acceptable level of service (LOS) (LOS D or better) under all assessed conditions, in regard to County of San Diego roadway segments. Since the proposed project would not result in a significant impact on these roadways and would provide an adequate number of parking spaces on site, the MND concluded based on expert review and analysis that there would be no significant impacts to either traffic or parking. For more on traffic, see Responses A-1, B-2, B-4, and D-3. For more on parking see Responses A-2, D-1, F10, F-11, G-5 and G-6. The traffic and parking issues has been adequately addressed in the IS, MND and technical studies and memoranda. The City of Chula Vista (City) is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. L-2 Please refer to Responses A-1, B-2, B-4, D-3 and L-1 regarding concerns about traffic along the Bonita Glen/Vista Way/Pepper Tree Drive corridor. L-3 The City acknowledges the comment and notes that it raises economic, social, or political issues that do not appear to relate to any physical effect on the environment. The City also notes that the Bonita Glen Specific Plan, which has been in place for decades, assumes development would result in more traffic than would be generated by the project proposed. See Responses A-1, B-2, B-4 and D-3 regarding traffic, and the fact that the project would not have any significant impact on traffic in the area. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. Additionally, the commenter restates issues addressed in Response L-1, so please refer to that Response as well. L-4 Soil sample results were included in the Geotechnical Report referenced in the IS. The Geotechnical Report stated that the project site is covered by a thin veneer of fill below which lies naturally occurring dense/stiff sands and clays. The subsurface soil units are Responses to Comments February 2019 RTC-92 Bonita Glen Project composed of alluvium underlain by silty and sandy soils of the Very Old Paralic Formation. The report concluded that the site is suitable for development of the planned structure on shallow foundations, provided that the geotechnical recommendations are followed. The comment refers to the area of soil that has been designated as critical coarse sediment yield area (CCYSA). To maintain sediment flows, a certain quota of land in the CCYSA must be preserved, as determined through hydraulic modeling. When neighbors asked for a sidewalk and street lights along Bonita Glen Drive, the developer had a hydrologist determine if those improvements could be provided without falling below the required threshold of CCYSA land. The hydrologist determined that the CCYSA could be reduced by the area needed for the sidewalk and street lights without going beneath the threshold. The developer then volunteered to provide the sidewalk and streetlights per the community’s request. L-5 Please refer to Responses A-2, D-1, F-10, F-11, G-5, G-6, and L-1 regarding parking. L-6 Please refer to Responses A-2, D-1, F-10, F-11, G-5, G-6, and L-1 regarding general parking and roadway concerns. The parking memorandum explains that State law requires the proposed project to provide a total of 212 parking spaces (one space/dwelling unit for the six studio and 122 one-bedroom apartments, and two spaces/dwelling unit for the 42 two-bedroom apartments). The proposed project exceeds these legal requirements, providing a total of 231 on-site parking spaces. This allows for a demand of 1.36 spaces per unit, or 1.09 spaces per bedroom. Based on observations performed at other properties within the area, and taking into account the unit mix which at the proposed project is 75% studio and one-bedroom units, the 231 spaces provided by the proposed project would be sufficient to accommodate its parking demand on site. The public is allowed to park on the public roadway, and that is unrelated to the project. The project does not have any significant impact to the roadway from either traffic or parking. Existing roadway hazards are not subject to California Environmental Quality Act (CEQA) review as long as the proposed project does not exacerbate the issue. Since the proposed project would not result in a significant impact on these roadways, the CEQA requirements have been met. L-7 Please refer to Responses A-2, D-1, F-10, F-11, G-5, G-6 and L-1 regarding parking. L-8 The commenter expresses concerns with potential impacts to the East Flower Street/ Bonita Road/E Street intersection. As discussed in the IS and the TIA, all study intersections, including the East Flower Street/Bonita Road/E Street intersection, were Responses to Comments February 2019 RTC-93 Bonita Glen Project studied and found based on expert analysis using generally accepted industry standards to operate at an acceptable LOS during the AM and PM peak hours under all analyzed conditions, without the need for widening. L-9 The commenter expresses concerns with potential impacts to the roadway segments from the East Flower Street/Bonita Road/E Street intersection to the Interstate 805 Southbound and Northbound On-/Off-Ramps on Bonita Road. As discussed in the IS and the TIA, all study roadways, including those mentioned above, were found based on study using generally accepted industry standards to operate at an acceptable LOS under all analyzed conditions. The proposed project would not result in a significant impact on these intersections and roadways. See also Response D-3 regarding Interstate 805 ramps. L-10 The comment expresses concerns with potential impacts along and to Pepper Tree Road, based on an assumption that the project will generate traffic that will have significant impacts to the intersection at Bonita Glen and E Street. The TIA demonstrates that the project would not have a significant impact on the Bonita Glen/E Street intersection, so would not cause vehicles to find alternate routes. To the extent there would be vehicles on Pepper Tree Road, Pepper Tree Road was included as a study roadway in the TIA. As mentioned, all study roadways, including Pepper Tree Road, were found to operate at an acceptable LOS under all analyzed conditions. See generally Responses A-1, B-1, B-4, B-5, D-3 and L-1 regarding traffic. L-11 The City acknowledges the comment as closing remarks to the comments that precede. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary because the comment does not raise an environmental issue. L-12 Please refer to Response L-1. Responses to Comments February 2019 RTC-94 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-95 Bonita Glen Project Responses to Comments February 2019 RTC-96 Bonita Glen Project Responses to Comments February 2019 RTC-97 Bonita Glen Project Response to Comment Letter M Hector Vanegas January 15, 2019 M-1 The City of Chula Vista (City) acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft Mitigated Negative Declaration (MND). The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed Bonita Glen Project (project). No further response is required or necessary. M-2 The commenter expresses concern about a change in land use. However, the project would not involve a rezone or change in land use, since the Bonita Glen Specific Plan allows multi-family residential use on this site, and no rezoning or re-designation of the land is required as part of the proposed project. See also Response C-2. In addition, the comment expresses concern about whether heavy-duty emergency vehicles could access the site, because the commenter believes Bonita Glen Drive is narrow and congested. The Traffic Impact Analysis (TIA) prepared for the project by a traffic engineer using well-established County of San Diego (County) and City criteria and professional standards concluded that the proposed project would not have a significant impact on traffic, and the technical memorandum on parking found that there would be no parking impact resulting from the project. See also Responses A-1, B-2, B-4, and D-3 regarding traffic, and A-2, D-1, F-10, F-11, G-5, and G-6, among others, regarding parking. Also, as discussed in Section XIV, Public Services, of the Initial Study (IS), the project site would be served by the Chula Vista Fire Department, which has nine fire stations and approximately 39 personnel, with approval for an additional 12 firefighters (City of Chula Vista 2017). The project site is within the service area of Fire Station 2, located at 80 East J Street, approximately 1 mile south of the project site. The proposed project would redevelop an underutilized site that has been long- planned for development with even more intensity than is proposed under the project. Additionally, the proposed project would require payment of development impact fees at the time of building permit issuance. The proposed project would not create additional congestion on the roadway, and would not adversely affect existing levels of fire protection services or create a significant new demand, and would not require the construction of a new or expansion of an existing facility. The project would not Responses to Comments February 2019 RTC-98 Bonita Glen Project impede access of heavy-duty emergency vehicles to the area. Therefore, impacts associated with fire protection would be less than significant. M-3 See Responses A-2, D-1, F-10, F-11, G-5, G-6, and L-1 regarding parking. M-4 The intersections of Bonita Road and the Interstate 805 On-/Off-Ramps were evaluated as study intersections in the TIA, including existing conditions regarding the proximity to an on and off ramp on Interstate 805 and the existing traffic signal system. As discussed in the IS and the TIA, all study intersections are expected to operate at an acceptable level of service (LOS) during the AM and PM peak hours under all analyzed conditions. See also Responses D-3 and L-8. M-5 Please refer to Response M-4 regarding evaluation of Interstate 805 On-/Off-Ramps. M-6 The commenter expresses concern with the project site’s proximity to Sweetwater River. Biological and hydrological resources were analyzed in the IS. As discussed in Section IV, Biological Resources, of the IS, the proposed project site is located within the Development Area of the City Planning Component as identified in the Subarea Plan (City of Chula Vista 2003). While the project site is close to the Sweetwater River, the project site is not a strategic preserve area within the City nor is it located within a designated conservation area. In addition, the project’s infill site has been planned for dense development since the 1970s. Furthermore, as discussed in Section IX, Hydrology and Water Quality, of the IS, runoff from the site would be conveyed via the internal on-site storm drain toward the southern boundary of the proposed project site. The proposed project footprint would result in an approximately 47% impervious area. In order to mitigate the impervious area, the proposed project would include three biofiltration basins that are projected to treat 84% of the runoff. Stormwater quality measures required by the Chula Vista Municipal Code would be implemented during construction phases of the proposed project. As such, the proposed project would not result in an increase in pollutant discharges to receiving waters. M-7 The commenter expresses concern with the population increase that would stem from implementation of the proposed project. As discussed in Section XIII, Population and Housing, of the IS, the proposed project would directly induce population growth to the area through the development of 170 apartments, and would help meet the City’s Responses to Comments February 2019 RTC-99 Bonita Glen Project housing needs, including its need for affordable housing. The City’s General Plan Housing Element identifies the need to maintain an inventory of both vacant and redevelopable land in order to achieve its regional share goal as allocated in the Regional Housing Needs Statement issued by the San Diego Association of Governments (SANDAG). As discussed in the Chula Vista Housing Element, between 2000 and 2010 the City experienced a 40% increase in population. The number of households is growing nearly as fast as the population, with a 31% increase in the number of households from 2000 to 2010. The U.S. Census Bureau reports 79,416 housing units in the City in 2010, an increase of 25% from 2000. Of the 79,416 housing units in the City, 2010 U.S. Census data shows 4.9% were vacant in 2010, and of the total vacant units, 39% were for rent. The Regional Housing Needs Assessment prepared by SANDAG for the years 2010–2020 identified Chula Vista’s housing production goal of 12,861 more homes in this time span. While the 2013 Housing Element site inventory for housing indicated that there was an overall inventory planned and zoned for residential use, implementation of the proposed project would assist the City in reaching their regional housing goal, in combination with the identified housing inventory. Furthermore, as the project site is currently underutilized as vacant land and is in conformance with the Bonita Glen Specific Plan, the proposed project would aid the City in meeting its housing needs for future and planned growth. Thus, impacts associated with population growth inducement would be less than significant. M-8 The commenter expresses concern with the potential impacts to traffic conditions on E Street and nearby arteries. E Street was not a roadway required to be analyzed under the TIA, because the project would not generate enough traffic on that roadway to trigger a need for analysis. The County Traffic Impact Guidelines require a proposed project to analyze the traffic impact to a given roadway if the proposed project is projected to add 25 or more peak hour trips to the roadway. The TIA concluded that the proposed project would add fewer than 25 peak hour trips to E Street and thus did not require a traffic impact analysis on E Street. With regard to other roadways in the project vicinity, all study segments are forecasted to operate at an acceptable LOS (D or better) under all assessed conditions, in regard to County roadway segments. Since the proposed project would not result in a significant impact on roadways and would provide an adequate number of parking spaces on site, California Environmental Quality Act requirements have been met with regard to traffic/transportation. See also Responses A-1, B-2, B-4, and D-3 regarding traffic. Responses to Comments February 2019 RTC-100 Bonita Glen Project M-9 The commenter expresses concern with the hydrology and flood conditions on the project site. As discussed in Section IX, Hydrology and Water Quality, of the IS, the northwestern portion of the site contains areas in either a special flood hazard area titled Zone AE, or in other areas of flood hazards, with 0.2% annual chance flood hazard, according to the Federal Emergency Management Agency Flood Map 06073C1914G. Zone AE areas have a 1% probability of flooding every year, which is also known as the “100-year floodplain.” The ephemeral stream located within the proposed project area is determined to have a 100-year peak flow rate of 51 cubic feet per second (REC Consultants 2018). Based on the calculations contained in the Hydrologic and Hydraulic Analysis Technical Memo, under proposed project conditions, the 10-year storm stays within the boundaries of the stream and a 5-foot buffer on either side (REC Consultants 2018). Based on the calculations contained in the Preliminary Geotechnical Investigation and Infiltration Study, it is anticipated that the proposed project would result in an increase in peak flow for the 50-year and 100-year storm frequencies. This volume would be detained through surface ponding and rock storage layers located in the proposed biofiltration basins. To minimize the increase in 100-year flood flows within the existing ephemeral stream, the stream banks would be graded up to create a larger open channel capable of handling the required flows. Increasing the stream banks would attenuate these peak flows below the existing condition amounts and would also offset the increase by detaining runoff to acceptable amounts. Additionally, the downstream existing 33-inch reinforced-concrete pipe public storm drain would be able to handle the mitigated 100-year flowrate of 55.11 cubic feet per second. Thus, impacts with regard to flood hazards would be less than significant. M-10 The commenter claims that the technical studies referenced in the Draft MND and the IS were not provided to the public. The technical studies were in fact included with the Draft MND and the IS in hardcopy format at the City of Chula Vista during the full 30- day public review period. The technical studies were also digitally available upon request. As such, the public had access to all technical studies referenced in the Draft MND and the IS during the public review period. M-11 The commenter expresses concern for the historic preservation of the area. As discussed in Section V, Cultural Resources, of the IS, the project site is currently vacant with no structures present on the property. The site has been previously graded and Responses to Comments February 2019 RTC-101 Bonita Glen Project disturbed. No impact to historical resources would occur. In addition, the Bonita Glen Specific Plan has planned for dense development of the property for decades. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. M-12 Please refer to Response M-7 regarding regional housing. The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required because the comment does not raise an environmental issue. M-13 Please refer to Response M-7 regarding the need for regional housing and Responses C-2 and M-2 regarding the fact that no change in zoning is required for the project. M-14 The City acknowledges the comment as closing remarks to the comments that precede. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary because the comment does not raise an environmental issue. 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This comment is included in the Final Mitigated Negative Declaration (MND) for review and consideration by the decision makers prior to a final decision on the proposed Bonita Glen Project (project). No further response is required or necessary because the comment does not raise an environmental issue. N-2 The City acknowledges the comment as an introduction to comments that follow. This comment is included in the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary because the comment does not raise an environmental issue. N-3 The City notes that the comment provides factual background information and does not raise an environmental issue within the meaning of the California Environmental Quality Act (CEQA). The City will include the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required because the comment does not raise an environmental issue. N-4 The commenter claims the MND does not describe any discretionary approvals the proposed project will require. The required contents for an MND are set forth in State CEQA Guidelines Section 15071, and do not include a requirement to provide a list of discretionary approvals. However, as noted on the Notice of Intent to Adopt Proposed Mitigated Negative Declaration IS18-0001, the proposed project is a permitted use by the Bonita Glen Specific Plan and may be approved through processing a Design Review Permit subject to review and approval by the Planning Commission of the City of Chula Vista. In addition, the project would receive approvals from the U.S. Army Corps of Engineers, California Department of Fish and Wildlife, and the Regional Water Quality Control Board. N-5 The MND sufficiently describes the baseline conditions for the project site. As discussed in Section I, Aesthetics, of the Initial Study (IS), there are no scenic vistas Responses to Comments February 2019 RTC-122 Bonita Glen Project on the project site. The proposed project site, long-planned for development, is characterized as substantially disturbed, undeveloped, and bifurcated by an existing natural stream. The site was previously graded, therefore it is relatively flat, with overall gradual sloping east to west. Elevations range from approximately 45 feet above mean sea level in the northwestern portion, up to approximately 91 feet above mean sea level in the southern portion of the site. There is a concrete brow ditch in the northern portion of the property that appears to be associated with the parking lot of the La Quinta Inn located immediately north of the site. Trash and litter have been observed throughout the site, during field surveys, along with several large pieces/piles of broken concrete debris in the western portion of the site. No structures exist on the property other than two corrugated-steel-pipe culverts associated with an ephemeral drainage. Regarding the comment’s claim that the MND does not fully describe project- related aesthetic impacts, please refer to Response N-6, below. N-6 As stated in Section I, Aesthetics, of the IS, the height limit applied to the project site is 38 feet beyond 100 feet from Vista Drive, and 30 feet within 100 feet of Vista Drive. Because a portion of the proposed project would exceed the current maximum permitted height of 30 feet within 100 feet of Vista Drive, a waiver of development standards would be obtained through the State Density Bonus Law to allow for additional height. As the MND appropriately found, there are no aesthetic impacts that would arise from the additional height proposed. In addition, the Bonita Glen Specific Plan (Specific Plan) anticipates that changes and refinements to its standards, regulations, and conceptual plan will be proposed by the project developer, and specifically intends that its standards not be inflexible. The Specific Plan also states that, “The Planning Commission, upon the recommendation of the Zoning Administrator, may adjust said standards and regulations upon finding that said adjustment will not adversely affect the nature, character, design, order, amenity, or intent of the proposed project or Specific Plan.” Regarding the assertion that there are “severe” aesthetic impacts because there will be development on currently undeveloped land, any development on currently undeveloped land changes the baseline aesthetics of a site; a change from an undeveloped property to developed property does not in and of itself create a significant aesthetic impact. The development must substantially damage scenic resources, degrade the existing visual character of the site, or create a new source of substantial Responses to Comments February 2019 RTC-123 Bonita Glen Project light or glare. Change in the status quo is most related to what was analyzed in Section I(c). As stated in the IS, the proposed structure would be similar in scale and height to the existing surrounding developments. Exterior finishes would generally use earth- tones colors, which would not substantially contrast with the surround visual character. All buildings would be setback 25 feet from Bonita Glen Drive and 100 feet along the eastern boundary of the site from Vista Drive. Lighting fixtures would be shielded downward and away from adjacent residential land uses. The proposed project would not include large walls or expanses of glass or other highly reflective materials. As such, impacts related to visual character/aesthetics would be less than significant. Lastly, the proposed project site is not designated as a scenic overlay identified in the General Plan, and Vista Drive has no scenic designation. Please refer to Response N-7 regarding the visual quality under proposed conditions in comparison to the existing conditions. N-7 As stated in the IS, the significance criteria used to identify visual impacts under construction and operations of a project is whether the project would “substantially degrade the existing visual character or quality of the site and its surroundings.” As stated in Response N-5, the project site—long planned for development—is characterized as previously graded, substantially disturbed, undeveloped, and bifurcated by an existing natural stream. Trash and litter have been observed throughout the site, during field surveys, along with several large pieces/piles of broken concrete debris in the western portion of the site. The referenced surveys include the biological surveys conducted by Dudek biologists on April 22, 2016, and April 21, 2017. The project site is not within any scenic overlays by the City, nor identified to have scenic or historic value. Based on the City’s General Plan, the project site is intended to be developed according to the Specific Plan as a two-story mixed-use complex with parking surrounding the building. As discussed in Section I of the IS, the proposed project would result in six three-story garden-style buildings and one four-story, podium-style building. The proposed project design would allow for development of wood-framed residential units (Type V-A) atop a reinforced concrete podium (Type 1-A). The proposed building façades would consist of vinyl frame windows, fabric awnings on painted metal frames, sand finish stucco, and French doors at all unit entries. Balconies would have a metal guardrail with a wood trellis. Building 7’s façade would consist of pre-finished metal siding and cement fiber horizontal siding, French doors, and fabric awnings over balconies with composite Responses to Comments February 2019 RTC-124 Bonita Glen Project railings (see Figures 6a, Buildings 1–6 Elevations, and 6b, Building 7 Elevations, in the IS). The proposed structure would be similar in scale and height to the existing surrounding developments. Exterior finishes would generally use earth-tone colors, which would not substantially contrast with the surround visual character. All buildings would be set back 25 feet from Bonita Glen Drive and 100 feet along the eastern boundary of the site from Vista Drive. There will be a 10-foot interior side yard setback along the north boundary of the site, where the project boundary abuts the La Quinta Hotel to the north. The proposed project shall be reviewed for consistency with the City of Chula Vista Design Guidelines and findings shall be made by the City Planning Commission with regard to consistency with City Design Guidelines. Conformance with the City’s Design Guidelines would avoid adverse aesthetic impacts. The comment’s assertion that a view of trees will be lost forever with the project is untrue, as new trees and other landscaping would be planted around the proposed structures to provide visual relief and softening. The proposed landscape, architectural design, and building scale would be consistent with the existing visual character of the site and surrounding area. As such, the proposed project would not substantially degrade the existing visual character or quality of the site and its surroundings. The MND and IS analyzed the existing conditions as the baseline, but it’s important nonetheless to note that the property already has been graded, and its development and grading have been analyzed and anticipated since the adoption of the Environmental Impact Report and Specific Plan in 1977. In sum, CEQA requirements have been adequately addressed, the MND’s analysis adequately and accurately evaluates the baseline project conditions and project impacts, and no further response is necessary. N-8 As stated in the Project Description of the MND, construction would be temporary, lasting approximately 19 months, with construction equipment being used five days a week for no more than eight hours a day. As the MND explains, temporary construction changes would not rise to the level of a change that would substantially degrade the existing visual character. As discussed in Section I of the IS, construction of the proposed project would introduce the potential use of heavy machinery, such as large trucks, cranes, bulldozers, and other equipment needed for grading and construction activities. The presence of this equipment and the grading and construction activities associated with the proposed project would alter the visual character and quality of the site during construction, and would be visible from surrounding areas, but would not “forever remove” the ephemeral stream, which remains on the property with the Responses to Comments February 2019 RTC-125 Bonita Glen Project project. The Tier III, non-native grasslands that will be graded, as has been anticipated since adoption of the Specific Plan and its certified Environmental Impact Report in 1977, will be fully mitigated. Impacts to existing visual character resulting from construction activities would not be considered substantial due to the relatively short- term and temporary nature of construction. Therefore, the focus of this analysis pertains to the long-term permanent physical changes anticipated to occur as a result of implementation of the proposed project. The City regulations referred to in the comment and the IS refers to the City Municipal Code Title 15 Building and Construction, which requires land development activities to install fencing or barricades where necessary to eliminate any hazards to the public. Consistent with City standards, a construction fence would be installed during construction activities, which would create a visual buffer from the construction activities. The fence itself will be installed only temporarily, during construction, and there are no significant impacts associated with temporary use of a construction fence used to shield views that otherwise would be of an active construction site. As such, CEQA requirements have been adequately addressed, and no further response is necessary. N-9 As stated in Section I of the IS, and as discussed in Response N-7, the proposed residential development would be visually consistent with surrounding land uses, as the surrounding area is nearly completely built out with residential communities, commercial land uses, and roadway infrastructure. As such, operational activities would have a less-than-significant impact on visual resources. The CEQA requirements for the aesthetics analysis have been met. N-10 The comment reiterates previous comments and does not raise new or additional environmental issues concerning the adequacy of the Draft MND. As discussed above, the City’s discussion of aesthetic impacts accurately and fully describes the project’s potential for impacts to aesthetics consistent with CEQA. For that reason, the City provides no further response to this comment. N-11 As discussed in the MND, Dudek prepared an Air Quality and Greenhouse Gas Technical Report (AQ/GHG Report) that identified air pollution as a largely cumulative impact. In analyzing cumulative impacts from a project, the analysis must specifically evaluate the project’s contribution to the cumulative increase in pollutants for which the San Diego Air Basin is designated as nonattainment. As stated in the AQ/GHG Report for the Bonita Glen Project, if the project does not exceed thresholds and is determined to have less-than-significant project-specific impacts, it may still contribute Responses to Comments February 2019 RTC-126 Bonita Glen Project to a significant cumulative impact on air quality if the emissions from the project, in combination with the emissions from other proposed or reasonably foreseeable future projects, are in excess of established thresholds. However, a project would only be considered to have a significant cumulative impact if the project’s contribution accounts for a significant proportion of the cumulative total emissions (i.e., it represents a “cumulatively considerable contribution” to the cumulative air quality impact). The proposed project would have a less-than-significant impact for short-term construction and long-term operations. As previously discussed, the project would not exceed significance thresholds during construction or operation. Additionally, the project would be consistent with the existing zoning and land use designation and the Specific Plan for the site, would help the City meet its housing goals including for low-income housing, and would not result in significant regional growth that is not accounted for within the Regional Air Quality Strategy. The City’s Housing Element reiterates the City’s need for more housing, including for low-income housing, and this project will simply help avoid an even larger housing crisis. This project would still leave the City 637 homes short of the number of homes projected to be built in 2019 alone by the San Diego Association of Governments (SANDAG). The comment provides no evidence indicating any foreseeable exceedance of SANDAG’s growth forecast. As a result, the proposed project would not result in a cumulatively considerable contribution to regional ozone concentrations or other criteria pollutant emissions. Cumulative impacts would be less than significant during operation. Cumulative air quality impacts have been accurately analyzed and portrayed in the MND. As a result, the project would not result in a cumulatively considerable contribution to regional O3 concentrations or other criteria pollutant emissions. N-12 Please refer to Response N-11. As noted there, the method of analysis used in the AQ/GHG Report took into consideration San Diego’s non-attainment status for certain pollutants and considered not only project emissions but cumulative emissions as well. As explained in the MND and the AQ/GHG Report, the Regional Air Quality Strategy states that where a project, such as the proposed project, does not exceed SANDAG’s growth projects for the City, it does not conflict with the Regional Air Quality Strategy, a strategy that takes into account cumulative projects, and is also consistent with the State Implementation Plan. N-13 The air quality mitigation measures included in the MND were identified in the AQ/GHG Report referenced in the MND. As stated in the AQ/GHG Report, the closest Responses to Comments February 2019 RTC-127 Bonita Glen Project sensitive receptors to the proposed project are residences adjacent to the western and eastern property boundaries. The Technical Study and MND studied and discussed whether or not there were any significant impacts of the proposed project on the environment, finding that there were not. Because the project does not have any potentially significant air quality impacts on the environment, no mitigation measures were required. The proposed project would, however, introduce new on-site sensitive receptors to the area. Construction activities would not generate emissions in excess of the City’s site-specific mass daily thresholds; therefore, site-specific construction impacts during construction of the proposed project would be less than significant. In addition, diesel equipment would also be subject to the California Air Resources Board Airborne Toxic Control Measures for in-use off-road diesel fleets, which would minimize diesel particulate matter emissions. Therefore, the exposure of proximate sensitive receptors to project-generated toxic air contaminant emissions and associated health risk impacts would be less than significant. Health impacts associated with exposure to nitrogen dioxide and oxides of nitrogen include respiratory irritation, which may be experienced by nearby receptors during the periods of heaviest use of off-road construction equipment. However, these operations would be relatively short term. Additionally, off-road construction equipment would operate at various locations on site and would not be concentrated in one portion of the site at any one time. Construction of the proposed project would not require any stationary emission sources that would create substantial, localized impacts associated with oxides of nitrogen. Therefore, health impacts would be less than significant. The measures directed at reducing potential impacts of the project on future residents were required to be consistent with San Diego Air Pollution Control District (SDAPCD) guidance. In accordance with that guidance, mitigation measures were evaluated to identify ways to ensure that residents of the proposed project would not be exposed to health risks that exceed SDAPCD significance thresholds, and to ensure that impacts related to community risk and hazards from placement of sensitive receptors proximate to major sources of air pollution would be less than significant. Moreover, the purpose of the mitigation included in the MND is to reduce the significant impacts associated with cancer risk levels below the SDAPCD thresholds. As such, the air quality analysis included in the IS and technical report referenced in the IS addresses impacts to both on- and off-site receptors. The MND’s conclusions are supported by the evidence in the record, including that found in the AQ/GHG Report. Responses to Comments February 2019 RTC-128 Bonita Glen Project N-14 As stated in the biological technical report referenced in the IS, Dudek biologists conducted biological surveys on April 22, 2016, and a second time on April 21, 2017. Surveys were done during the appropriate flowering season for special-status species. Any potentially sensitive biological resources were identified and mapped directly in the field. Only one vegetation community was identified within the project site: non- native grassland, which is considered a sensitive vegetation community; impacts to this community require mitigation, which is addressed in MM-BIO-1 in the IS. As such, the comment has been addressed, and no further response is required. N-15 The comment refers to images of the proposed project and claims the project will alter the ephemeral stream’s natural flow direction. This topic is addressed in Section IX, Hydrology and Water Quality, of the IS. As stated in Section IX, in developed conditions, the existing ephemeral stream would remain in a natural state with graded embankments to the east and west of the delineated existing ephemeral stream. The proposed project does not re-route the stream itself, but only proposes to reroute the existing man-made drainage system so that it flows into treatable areas, biofiltration basins, and outlet through an existing storm drain on the western side of the project site, along Bonita Glen Drive. Proposed biofiltration basins would collect runoff from the undeveloped areas connecting to the proposed storm drain system (downstream of the basin). There would be no proposed hydromodification due to runoff discharging at the Sweetwater River through existing conveyances (Latitude 33 Planning and Engineering 2018b). Additionally, increasing the stream banks would attenuate these peak flows below the existing condition amounts, and would also offset the increase by detaining runoff to acceptable amounts. This is discussed in the MND and in the IS. N-16 MM-CUL-2 states that a paleontological monitor shall be on site at all times during the original cutting of previously undisturbed sediments of highly sensitive geologic formations (i.e., San Diego Formation) to inspect cuts for contained fossils. Then in the following sentences, MM-CUL-2 states the monitor shall be on site on at least a half- time basis during the original cutting of previously undisturbed sediments of moderately sensitive geologic formations (e.g., Lindavista Formation) to inspect cuts for contained fossils. Therefore, depending on the sensitivity of the geologic formation, the paleontological monitor shall be on site for either a half-time or full-time basis for original cutting. Revisions to this mitigation measure are not necessary as this comment was taken out of context. Responses to Comments February 2019 RTC-129 Bonita Glen Project N-17 The comment is incorrect in its assertion that the City relies exclusively on the City’s Climate Action Plan (CAP) to determine that quantitative greenhouse gas emissions are less than significant. As stated in the IS, Dudek prepared an AQ/GHG Report for the proposed project in July 2018. As the AQ/GHG Report explains: To develop an efficiency threshold that would satisfy the requirements of Center for Biological Diversity vs. California Department of Fish and Wildlife and EO B- 30-15, the City’s 1990 emissions inventory, less 40%, must be divided by the City’s 2030 population. Project level emissions can then be directly evaluated against a threshold based on local emission reduction goals and local population densities in accordance with the Court’s decision on Center for Biological Diversity vs. California Department of Fish and Wildlife. … Dividing the City’s 1990 GHG emissions of 847,166 MT CO2E by the 1990 SP gives an efficiency metric of 3.60 MT CO2E per SP. … In order to develop an efficiency metric for the Project’s buildout year of 2021, it is necessary to interpolate between the efficiency metrics in 1990 and 2030. … As shown in Table 16, the calculated efficiency metric for 2021 based on the City’s emissions inventory in 2012 and GHG emissions reduction goal for 2030 was 1.78 MT CO2E per SP. … If the Project achieves the 2021 efficiency metric, it would not interfere with attainment of the 2030 and 2050 statewide emission reduction targets, and therefore not interfere with the State’s and the City’s ability to achieve the mid-term and long- term GHG reduction targets in the City’s CAP. As such, the proposed project used an efficiency metric as the threshold of significance, which considers the mid-term and long-term GHG reduction targets in the City’s climate action plan. While the CAP is applicable and up-to-date, the City does not exclusively rely on the City’s CAP to determine quantitative GHG emissions, but rather also developed the efficiency metric. The efficiency metric is a valid threshold under CEQA. N-18 The commenter claims that the technical studies referenced in the MND and IS were never made available for public review. That is not accurate. The technical studies were in fact included with the MND and IS in hard copy form at the City of Chula Vista during the full 30-day public review period, available upon request both in hard copy and digitally. As such, the public had access to all technical studies referenced in the MND and IS during the public review period. See also Response M-10. Responses to Comments February 2019 RTC-130 Bonita Glen Project N-19 Refer to Response N-17 regarding the validity of thresholds used in the IS, and refer to Response N-18 for discussion on the availability of the technical studies referenced in the IS and MND. N-20 Refer to Response N-18 for discussion on the availability of the technical studies referenced in the IS and MND. As stated in the Phase I Environmental Site Assessment, prepared by Construction Testing and Engineering and referenced in the IS, no recognized environmental conditions were noted to be present on the project site. Because no recognized environmental conditions were revealed, there was no basis or reason to conduct soil sampling. In addition, the subject site was not listed in the Environmental Data Resources report and the report found no up-gradient groundwater or topographic gradient properties that would provide a significant environmental concern to the proposed project site. The Phase I investigated the current and past history and uses of the property, looking at what was previously on the site, what past usage could have done, whether any usage could potentially have contaminated the soil or groundwater underlying the site, etc. It was an investigation to determine if there were any conditions that were indicative of releases of petroleum or hazardous materials or chemicals at the site, now or in the past. If the experts who conducted the Phase I report had determined there was a potential for hazards or hazardous materials on the site that had the potential for a significant impact, they would have recommended conducting further testing such as soil sampling. The experts concluded no such additional testing was required. N-21 The Spectrum Preschool at Spectrum Church is not within 0.25 miles from the proposed project; it is only the far edge of the western parking lot that touches that boundary, and not the school itself. In addition, the Spectrum Preschool is located only approximately 237 feet east of Interstate (I) 805, where hazardous materials are frequently transported. Therefore, even if the Spectrum Preschool were within 0.25- mile radius of the project site, which it is not, with compliance with federal, state, and local regulations, any hazardous material transported to and from the project site would be similar to the types of hazardous materials already transported on the I-805, and would not substantially increase the hazards exposed to the school. N-22 The comment expresses concern for project usage of groundwater resources that was not explicitly identified in the IS. The significance criteria for impacts to groundwater the comment is referring to is whether the proposed project would substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that Responses to Comments February 2019 RTC-131 Bonita Glen Project there would be a net deficit in aquifer volume or a lowering of the local groundwater table level. As stated in Section XVII, Utilities and Service Systems, of the IS, the proposed 170 residential units, which are estimated to house up to 486 residents, would generate an insignificant demand for potable water—57 acre-feet per year—which is equivalent to 0.84% of the total potable water demand for the Sweetwater Authority. The Sweetwater Authority procures water from the following four sources: (1) deep freshwater wells in National City, (2) local runoff in the Sweetwater River with subsequent storage at the Loveland Reservoir and Sweetwater Reservoir, (3) San Diego Formation Wells in the lower Sweetwater River basin, and (4) purchase of imported water delivered by the San Diego Water Authority and Metropolitan Water District (Sweetwater Authority 2018). Considering the Sweetwater Authority draws from a variety of water sources, and the proposed project would account for an insignificant amount of water demand, the project would not have a significant impact on groundwater resources. The Sweetwater Authority states that it is considered to have the most reliable water resources of any district in the San Diego region, with resources including imported raw water, imported treated water, four freshwater wells, 17 pump stations, two dams, 25 storage tanks, a groundwater desalination facility and a water treatment facility. The Water Authority has estimated a total groundwater storage capacity of 973,000 acre-feet for this basin. According to Sweetwater Authority records, water levels in production wells near National City have remained stable since about 1950. In addition, the Sweetwater Valley Groundwater Basin has not been identified in California Department of Water Resources Bulletin 118 as in overdraft condition (Sweetwater Authority 2018). Sweetwater Authority receives a portion of their water from the Metropolitan Water District, in which supplies consist of both Colorado River and State Water Project supplies from the Sacramento-San Joaquin Bay Delta. The Sweetwater Authority purchases approximately 21% of Metropolitan Water District’s total water deliveries. As such, the Sweetwater Authority is not using groundwater beyond the basin’s sustainable yield. Thus the project’s water demand would not have a substantial effect on groundwater. N-23 As stated in Section IX of the IS, according to the Federal Emergency Management Agency Flood Map 06073C1914G, the northwestern portion of the site contains areas in either a special flood hazard area titled Zone AE, or in other areas of flood hazards, with 0.2% annual chance flood hazard. Zone AE areas have a 1% probability of flooding every year, which is also known as the “100-year floodplain.” The ephemeral stream located within the proposed project area is determined to have a 100-year peak Responses to Comments February 2019 RTC-132 Bonita Glen Project flow rate of 51 cubic feet per second (cfs) (REC Consultants 2018). As discussed in the Hydrologic and Hydraulic Analysis referenced in the IS, which examined the conveyance capacity of the ephemeral creek on site, a depth analysis was taken at the southernmost structure (the proposed southern parking lot) adjacent to Bonita Glen Road. It was determined that a 100-year flood would require a flow width of 15.61 feet, which is greater than the maximum flow width available of 11.5 feet. As stated in the Preliminary Drainage Study referenced in the IS, to mitigate the increase in 100-year flood flows within the creek, the creek banks will be graded up to create a larger open channel, capable of handling the required flows. Increasing the creek banks will ensure that surface flows will not overtop the banks and flood onto the adjacent developments, or worsen flooding downstream. As such, the potential for on-site residents to experience flooding during a 100-year storm event would be less than significant. This comment has been adequately addressed and no further response is required. N-24 The City did evaluate project noise impacts compared to baseline conditions. The comment erroneously asserts that the City assumes that a sound wall is being installed as a project feature in order to mitigate noise impacts. That is not the case. The “acoustical shielding provided by the project to roadways” discussed in Section XII, Noise, of the IS, is not mitigation and is not a sound wall. Rather, the MND is describing the fact that the project itself, which includes apartment buildings nearest to Bonita Glen Drive, and the walls of those units function not only as the exterior of the homes but also naturally acts as acoustical shielding. No sound walls are proposed or required. N-25 As stated in the MND, the Acoustical Assessment Report presented the locations of modeled off-site noise receivers to analyze off-site traffic noise. As stated in the report, the City does not have a specific noise criterion for evaluation of off-site noise impacts to residences or noise-sensitive areas from project-related traffic. For the purposes of the noise analysis, such impacts are considered significant when they cause an increase of 3 decibels (dB) from existing noise levels or exceed the 65 A-weighted decibel community noise equivalent level noise threshold. Based on the findings of the analysis, the maximum noise level increase would be 0 dB (i.e., less than 1 dB when rounded to whole decibels). A change in noise level of 1 dB or less is not an audible change, in the context of community noise, and is therefore less than significant. There is no information in the MND that indicates the project will have significant impacts on off-site receptors during operation of the project, and there is no significant noise impact that needs to be mitigated. Therefore, CEQA requirements have been met and no further response is necessary. Responses to Comments February 2019 RTC-133 Bonita Glen Project N-26 For the same reasons specified in Response N-25, the City does not have off-site indoor noise impact criteria. The Acoustical Assessment Report analyzed off-site traffic noise impacts and determined that, based on the modeled receptors, off-site traffic noise impacts would be less than significant. Therefore, CEQA requirements have been met and no further response is necessary. N-27 As stated in Section XIV, Public Services, of the IS, the proposed project would develop an underutilized infill site served by the Chula Vista Fire Department and the Chula Vista Police Department and would not adversely impact existing levels of fire or police protection or create a significant new demand. The same is true for other public services, as discussed in the IS and MND. The project would be required to pay the development impact fees at the time of building permit issuance. The development impact fees shall be calculated to ensure that the fees are assessed proportional to the impact created by the proposed project, and the proceeds from the fees can only be spent on expanding or upgrading infrastructure that can be used by the occupants of the project in the development impact fees’ area of benefit. All projects in the area would be required to pay development impact fees proportional to the impacts created by those projects. The City designed the development fee system to require all projects in the area to pay these fees, in order to ensure that public services have the funds to expand services, if necessary. As such, impacts would be less than significant and CEQA requirements have been met. N-28 According to the City’s Growth Management Oversight Committee Fiscal Year 2017 Annual Report, the City had 3.99 park acres per 1,000 residents in eastern Chula Vista in 2017, exceeding the threshold standard requiring 3 acres per 1,000. There is no parks-to- residents deficiency. The Growth Management Oversight Committee had projected the City to have 3.92 acres of parks per 1,000 people in 2018, and 3.94 acres per 1,000 by 2022 in eastern Chula Vista. As stated in Section XV, Recreation, of the IS, the proposed project would include a swimming pool, clubhouse, and dog run, and would pay required development impact fees for the provision of public services, including parks and recreational facilities. Therefore, impacts would be less than significant. N-29 The commenter claims a significant impact was overlooked in Table 19, Roadway Segment Level of Service – Year 2035 Base Plus Project Conditions (City of Chula Vista), of the IS. Although Table 19 identifies Bonita Road from I-805 southbound ramps to I-805 northbound ramps at Level of Service (LOS) E under Year 2035 Base Plus Project conditions, the roadway was projected to operate at LOS E under Year 2035 Base Conditions. However, as shown in Table 21, Peak Hour Intersection Level Responses to Comments February 2019 RTC-134 Bonita Glen Project of Service – Year 2035 Base Plus Project Conditions, of the IS, the study intersections along Bonita Road all operate at LOS D or better. Based on the City’s significance thresholds, roadway segments operating at LOS E are not considered impacted if the intersections on either side of the segment operate at LOS D or better. As such, there would not be a significant impact along Bonita Road from the I-805 Southbound On- /Off-Ramps to I-805 Northbound On-/Off-Ramps. Therefore, CEQA requirements have been met and no further response is necessary. N-30 The City requires that all development projects within the City, including the proposed project, prepare a Traffic Control Plan that ensures impacts on surrounding roadways and intersections are minimized during construction. Furthermore, the proposed project would be required to comply with Chula Vista Fire Department requirements and standards to ensure that adequate access is provided. The proposed project would not involve the permanent closure of any surface streets that would increase the response time for emergency services. Additionally, the project will comply with all fire codes, and emergency access will be maintained by foot and by truck. Therefore, with compliance with local regulations, impacts to emergency access would be less than significant. N-31 The comment expresses concern for the project’s effect on peak wet weather flows and its effect on the City’s wastewater treatment facilities. However, the commenter has mixed up wastewater facilities with stormwater facilities, as stormwater facilities handle peak wet weather flows, not wastewater treatment or sewer facilities. The project’s effect on the City’s stormwater facilities is addressed in Section IX of the IS. As stated in Section IX, once constructed, on-site peak flows would be collected through the biofiltration basins and would discharge directly into the City’s storm drain infrastructure along Bonita Glen Drive. Proposed biofiltration basins would collect runoff from the undeveloped areas connecting to the proposed storm drain system (downstream of the basin). Runoff from the site would be conveyed via the internal on-site storm drain toward the southern boundary of the proposed project. The proposed project footprint would result in an approximately 47% impervious area. In order to mitigate the impervious area, the proposed project includes three biofiltration basins that are projected to treat 84% of the runoff. The other 16% would drain naturally into the stream in the middle of the site (Latitude 33 Planning and Engineering 2018a). As concluded in Section IX, the downstream existing 33-inch reinforced-concrete pipe public storm drain would be able to handle the mitigated 100-year flowrate of 55.11 cfs. The stormwater from the project site would not cause or contribute to sewer overflows, as the stormwater system is separate from the sewer system proposed onsite. As such, the project Responses to Comments February 2019 RTC-135 Bonita Glen Project will not have any significant impacts to wastewater treatment facilities. CEQA requirements have been met, and this comment has been adequately addressed. N-32 As discussed in Section XVII of the IS, the Sweetwater Authority is projected to reach a potable water demand of 6,773 acre-feet per year for multi-family uses in 2020 (Sweetwater Authority 2016). The proposed 170 residential units, which are estimated to house up to 486 residents, would generate an insignificant portion of this demand for potable water—57 acre-feet per year—which is equivalent to 0.84% of the total potable water demand for the Sweetwater Authority. The CEQA significance criteria the comment alludes to is whether the proposed project would have sufficient water supplies available to serve the project from existing entitlements and resources. By providing the Sweetwater Authority’s water demand in comparison to the proposed project’s water demand, the IS adequately provides justification that the Sweetwater Authority has capacity for the proposed project. Also see Response N-22, which cites the Sweetwater Authority as confirming it has adequate capacity. Therefore, CEQA requirements have been met, and this comment has been adequately addressed. N-33 The commenter refers to a “Thresholds” checklist at the end of the MND. The Thresholds checklist is a part of the City’s Initial Study checklist and provides additional information regarding the City’s thresholds for impacts to public services such as police and fire, traffic, parks and recreation, water, etc. These thresholds were taken into account in the relevant sections of the IS, which thoroughly went through the Appendix G checklist and provided both discussion and evidence for each issue area, providing support for its checklist determinations. That is why the IS in the Thresholds section refers the reader to the discussions above. No further response can be provided as the comment does not raise any specific issue regarding that analysis and, therefore, no more specific response can be provided or is required. The City will include the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. N-34 At the time of the Notice of Intent, the City’s MND checklist followed CEQA’s Appendix G checklist, which did not include the standard Energy checklist questions. Appendix G provides a recommended format, and jurisdictions such as the City may use the Appendix G checklist as a template for the preparation of their CEQA documents. Although the MND does not include specific energy checklist questions, the discussion of energy consumption is addressed in the AQ/GHG Report referenced in the MND. California Emissions Estimator Model (CalEEMod) default values for Responses to Comments February 2019 RTC-136 Bonita Glen Project energy consumption for each land use were applied for the project analysis. The energy use from residential land uses is calculated in CalEEMod based on the California Residential End-Use Survey database. The program uses data collected during the Residential Appliance Saturation Survey to develop energy intensity values (electricity and natural gas usage per square foot per year) for residential buildings. Energy use in buildings (both natural gas and electricity) is divided by the program into end use categories subject to Title 24 requirements (end uses associated with the building envelope, such as the water heating system, integrated lighting, and heating, ventilation, and air conditioning system) and those not subject to Title 24 requirements (such as appliances, electronics, and miscellaneous “plug-in” uses). Title 24 of the California Code of Regulations serves to enhance and regulate California’s building standards. The most recent amendments to Title 24, Part 6, referred to as the 2016 standards, became effective on January 1, 2017. The previous amendments were referred to as the 2013 standards. CalEEMod 2016.3.2 includes compliance with the 2016 Title 24 standards. The project applicant is committed to exceeding the 2016 Title 24 energy standards. The proposed project includes implementation of rooftop solar photovoltaic energy production, which will cover energy use for all common area lighting. The proposed project also will include the installation of electric vehicle charging stations, Energy Star appliances, and 100% of the lighting fixtures on site will be LED. The AQ/GHG Report evaluates energy consumption and energy conservation methods, and confirms that the proposed project would not result in a wasteful consumption of energy. N-35 The City acknowledges the comment and notes that it provides concluding remarks that do not raise new or additional environmental issues concerning the adequacy of the Draft MND. For that reason, the City provides no further response to this comment. N-36 The comment requests that the Southwest Regional Council of Carpenters receive a copy of the Notice of Determination for this project. This has been noted and the City will arrange to have a copy of the Notice of Determination sent to Nicholas Whipps of Wittwer Parkin LLP for the Southwest Regional Council of Carpenters. N-37 Please refer to Response N-7. N-38 Please refer to Response N-7. N-39 Please refer to Response N-21. Responses to Comments February 2019 RTC-137 Bonita Glen Project Responses to Comments February 2019 RTC-138 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-139 Bonita Glen Project Response to Comment Letter O Scott Olsen January 14, 2019 O-1 The City of Chula Vista (City) acknowledges the comment as introductory remarks to the comments that follow. The City is including the comment as part of the Final Mitigated Negative Declaration (MND) for review and consideration by the decision makers prior to a final decision on the proposed Bonita Glen Project (project). No further response is required or necessary because the comment does not raise an environmental issue. O-2 The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. Note that the Bonita Glen Specific Plan has long planned for development on this site of a density that would generate more traffic than is proposed with the project. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary. O-3 The commenter expresses concerns with hazardous roadways and parking in the project vicinity. As discussed in the Draft MND and the Traffic Impact Analysis referenced in the MND, all study segments are forecasted to operate at acceptable level of service (LOS) (LOS D or better) under all assessed conditions, in regard to County roadway segments. Existing roadway hazards are not subject to California Environmental Quality Act review as long as the proposed project does not exacerbate the issue. Note that as a project feature, the proposed project would include improvements to Vista Drive between the Unnamed Cul-de-Sac and Bonita Glen Road. For more on traffic see Responses A-1, B-2, B-4, D-3, and L-1. See Responses A-2, D-1, F-10, F-11, G-5, and G-6 regarding parking. O-4 Please refer to Response A-2, D-1, F-10, F-11, G-5, and G-6 regarding parking capacity. The anticipated parking demand would be met on site. Responses to Comments February 2019 RTC-140 Bonita Glen Project O-5 The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary. Responses to Comments February 2019 RTC-141 Bonita Glen Project Responses to Comments February 2019 RTC-142 Bonita Glen Project Responses to Comments February 2019 RTC-143 Bonita Glen Project Response to Comment Letter P Mark Ramsey January 18, 2019 P-1 The commenter expresses concerns with existing traffic, parking and roadways in the vicinity of the proposed Bonita Glen Project (project) site. As discussed in the Draft Mitigated Negative Declaration (MND) and the Traffic Impact Analysis (TIA) referenced in the Draft MND, all study segments are forecasted to operate at an acceptable level of service (LOS) (LOS D or better) under all assessed conditions, in regard to County of San Diego roadway segments. See Responses A-1, B-2, B-4, D-3, and L-1 regarding traffic, and Responses A-2, D-1, F-10, F-11, G-5, and G-6 regarding parking. In addition, note that the project would include sidewalks, and the project was found to have no significant impacts on the area roadways. P-2 The City acknowledges the comment and notes that it expresses the opinions of the commenter and does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary. P-3 The City acknowledges the comment is of attached images to coincide with preceding comments regarding traffic. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary because the comment does not raise an environmental issue. Responses to Comments February 2019 RTC-144 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-145 Bonita Glen Project Responses to Comments February 2019 RTC-146 Bonita Glen Project Responses to Comments February 2019 RTC-147 Bonita Glen Project Responses to Comments February 2019 RTC-148 Bonita Glen Project Responses to Comments February 2019 RTC-149 Bonita Glen Project Responses to Comments February 2019 RTC-150 Bonita Glen Project Responses to Comments February 2019 RTC-151 Bonita Glen Project Response to Comment Letter Q County of San Diego, Planning & Development Services Eric Lardy, AICP – Chief (Acting), Advance Planning Division January 18, 2019 Q-1 The City of Chula Vista (City) acknowledges the comment as introductory remarks to the comments that follow. The City is including the comment as part of the Final Mitigated Negative Declaration (MND) for review and consideration by the decision makers prior to a final decision on the proposed Bonita Glen Project (project). No further response is required or necessary because the comment does not raise an environmental issue. Q-2 The City acknowledges the comment as introductory remarks to the comments that follow. The City and the developer have worked to address concerns about the proposed project. See Responses A-1, B-2, B-4, D-3, L-1, and L-8 regarding traffic. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary because the comment does not raise an environmental issue. Q-3 The Traffic Impact Analysis establishes that the proposed project would generate 624 daily trips on the segment of Vista Drive between the Unnamed Cul-de-Sac and Bonita Glen Road. However, the referenced segment of Vista Drive does not serve any cumulative or cut-through traffic and is projected to operate well below its design capacity (Chen Ryan 2018). Therefore, the proposed project would not result in a significant impact to this roadway. Improvements would be included as project features, not mitigation measures, because there would be no significant impacts that require mitigation. In lieu of vacation or annexation, the proposed project would include roadway improvements to the roadway segment between the Unnamed Cul-de-Sac and Bonita Glen Road. As such, annexation or privatization of the roadway would not occur. Q-4 Please refer to Response Q-3 regarding the status of the segment of Vista Drive between the Unnamed Cul-de-Sac and Bonita Glen Road. Q-5 As indicated in the Priority Development Permit (PDP) Stormwater Quality Management Plan, the proposed project is exempt from PDP hydromodification management requirements, including a Vector Control Plan. Considering the Responses to Comments February 2019 RTC-152 Bonita Glen Project ephemeral nature of the on-site stream, the proposed project would not include standing water features capable of accumulating and holding the minimum 0.5 inches of water for more than 96 hours necessary to support mosquito breeding and development. Additionally, the proposed project is not located within 0.25 miles of an existing known vector breeding source. As a result, the project does not trigger a potentially significant impact under the County Guidelines for Determining Significance for Vectors referenced in the comment. In addition, the City’s California Environmental Quality Act threshold checklist does not require vector control examination; therefore, analysis was not included in the Initial Study. The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. Therefore, no further response is required. Q-6 As indicated in the PDP Stormwater Quality Management Plan, pollutant control and hydromodification management best management practices (BMPs) have been applied to the proposed project, in accordance with the City’s BMP Design Manual. The comment does not raise an issue related to the adequacy of any specific section or analysis of the Draft MND. Therefore, no further response is required. Q-7 The County of San Diego (County) has been provided with the updated project plans, showing that the sewer line will no longer cross the receiving water. No significant impacts would result from this change. Therefore, no recirculation of the MND is required. Q-8 As discussed in Sections XIII and XV of the Initial Study, the proposed project would require payment of development impact fees at the time of building permit issuance. Additionally, the proposed project would be providing recreational areas including a swimming pool, clubhouse, and dog run. With proximity to neighborhood parks, inclusion of on-site recreational facilities, and payment of impact fees, the proposed project would not adversely affect the provision of park and recreational facilities, and impacts would be less than significant. Because the County does not have jurisdiction over the proposed project area, improvement to County recreational facilities or payment of development impact fees to the County is not required. Q-9 The City acknowledges the comment as closing remarks to the comments that precede. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary because the comment does not raise an environmental issue. Responses to Comments February 2019 RTC-153 Bonita Glen Project Q-10 The City acknowledges the comment as introductory remarks to the comments that follow. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary because the comment does not raise an environmental issue. Q-11 Please refer to Response Q-3. Q-12 Please refer to Response Q-3. Q-13 Please refer to Response Q-3. Q-14 Please refer to Response Q-3. Q-15 Please refer to Response Q-5. Q-16 Please refer to Responses Q-6 and Q-7. Q-17 Please refer to Response Q-8. Q-18 The City acknowledges the comment as closing remarks to the comments that precede. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary because the comment does not raise an environmental issue. Responses to Comments February 2019 RTC-154 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-155 Bonita Glen Project Responses to Comments February 2019 RTC-156 Bonita Glen Project Responses to Comments February 2019 RTC-157 Bonita Glen Project Responses to Comments February 2019 RTC-158 Bonita Glen Project Responses to Comments February 2019 RTC-159 Bonita Glen Project Response to Comment Letter R Governor’s Office of Planning and Research State Clearinghouse and Planning Unit Scott Morgan – Director, State Clearinghouse January 16, 2019 R-1 The comment acknowledges that the State Clearinghouse submitted the Draft Mitigated Negative Declaration (MND) to state agencies for review through January 15, 2019. The City of Chula Vista (City) acknowledges the comment as introductory remarks to the comments that follow. The City is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed Bonita Glen Project (project). No further response is required or necessary because the comment does not raise an environmental issue. R-2 The City acknowledges the comment and is including the comment as part of the Final MND for review and consideration by the decision makers prior to a final decision on the proposed project. No further response is required or necessary because the comment does not raise an environmental issue. Responses to Comments February 2019 RTC-160 Bonita Glen Project INTENTIONALLY LEFT BLANK Responses to Comments February 2019 RTC-161 Bonita Glen Project References Chen Ryan. 2018. Traffic Impact Analysis: Bonita Glen. Draft. April 6, 2018. City of Chula Vista. 2003. City of Chula Vista MSCP Subarea Plan. Accessed July 2018. http://www.chulavistaca.gov/home/showdocument?id=7106. City of Chula Vista. 2013. 2012–2020 Housing Element. Accessed July 2018. http://www.chulavistaca.gov/home/showdocument?id=5503. City of Chula Vista. 2017. Public Safety Staffing Report. Accessed July 2018. https://www.chulavistaca.gov/home/showdocument?id=15604. City of Chula Vista. 2019. Street Sweeping. Accessed February 8, 2019. https://www.chulavistaca.gov/departments/public-works/services/street-sweeping. Latitude 33 Planning and Engineering. 2018a. Priority Development Project (PDP) Storm Water Quality Management Plan. June 2018. Latitude 33 Planning and Engineering. 2018b. Preliminary Drainage Study. Bonita Glen. REC Consultants. 2018. Technical Memorandum: Hydrologic and Hydraulic Analysis for Bonita Glen Creek. January 2018. Revised June 2018. Sweetwater Authority. 2016. 2015 Urban Water Management Plan. June 2016. Accessed July 2018. https://www.sweetwater.org/DocumentCenter/View/84/2015-Urban-Water- Management-Plan-PDF. Sweetwater Authority. 2018. “About Us.” Accessed July 2018. https://www.sweetwater.org/ 27/About-Us. Responses to Comments February 2019 RTC-162 Bonita Glen Project INTENTIONALLY LEFT BLANK