Loading...
HomeMy WebLinkAboutJPR 22-03-11-01_Comments_Tracking Table_22.07.14 ResponsesJPR 22-03-11-01 – Comments/Responses Tracking Table PROJECT IDENTIFIER – LEAP 2022-02/Rome Hill Commercial REVIEWER – Sarah Greely DOCUMENTATION REC’D – JPR submittal materials provided by the Permittee included a JPR submittal materials provided by the Permittee included an RCA Joint Project Review (JPR) Application (June 3, 2022); a Rome Hill General Biological Assessment (Assessment) prepared by Hernandez Environmental Services (July 8, 2022); an MSHCP Consistency Findings (Findings) prepared by the City of Lake Elsinore (July 1, 2022), and GIS shapefiles (June 2022). The Permittee/Applicant must provide a summary response to each comment in the Table below, including the document name and section/page# where the revised information relative to the response can be found. If the Permittee/Applicant chooses to do so, responses may be provided in the Table only in advance of revising the JPR supporting documents. However, without the revised documentation accompanying the Table as a way of providing context, this may add time to the review. When revised documents are submitted, they should be provided in tracked changes that clearly reflect the summary response below. If revised documents (with tracked changes) are submitted in Word, revised Figures should also be provided separately. The intent of this Table is to provide a forum for the Permittee/Applicant to address comments up front, if needed, particularly if the Permittee/Applicant would like to further discuss any of the comments in advance of revising the supporting documents. Note that each time responses and/or revised JPR supporting documents are sent back to RCA, the 14-day review clock begins again. We also strongly encourage the Permittee/Applicant to reach out to the RCA reviewer or arrange a meeting early on if there are any questions regarding the comments or any complex issues related to the JPR. The Permittee/Applicant must also fill out (whether new or update to existing code) the column for Response Codes using one of the following: A=Comment Addressed; B=Comment Partially Addressed; C=Comment Not Addressed. If a response was not provided or was only partially provided, please provide a justification regarding why the comment was not fully addressed. Shading = Comment completed. Additional Notes for the Permittee /Applicant: It is recommended that a tracked changes version of resubmitted documentation be provided along with this Table in order to facilitate reviews. The dates on any revised documents should be updated with each submittal to reflect most recent submittals and to avoid version control issues. Please also note that additional comments may be provided after review of the requested/revised information. The Table and revised JPR documentation, OR the Table-only (if the Permittee/Applicant chooses this latter approach), should be sent back to the RCA reviewer via email. Please also copy Leslie Levy (llevy@rctc.org), Betsy Dionne (bdionne@rctc.org), Tricia Campbell (tcampbell@rctc.org), and Britney Strittmater (bstrittmater@dudek.com) on the email. Round 1 – RCA Reviewer Comments (submitted 03-24-22) Response Codes  Round 1 – Permittee/Applicant Responses Summary (submitted back to the RCA on 06-03-22) Round 2 – RCA Reviewer Comments (submitted 06-14-22)  Round 2 – Permittee/Applicant Responses Summary (Please include date submitted back to the RCA) Response Codes  Round 3 – RCA Reviewer Comments (submitted 07-01-22)  Response Codes  Round 3 – Permittee/Applicant Responses Summary (submitted back to the RCA on 07-01-22)  Round 4 – RCA Reviewer Comments (submitted 07-14-22)  Response Codes  Round 4 – Permittee/Applicant Responses Summary (Please include date submitted back to the RCA)  General (GEN)             GEN-1. The JPR Application and the Findings list the project site acreage as 6.83 acres; however, the Assessment lists the project site acreage as 6.85 acres. Note that all APN acreages should use the geographic acreage listed in the MSHCP Information Tool. This acreage should be clearly and consistently reported among all JPR documents (i.e., JPR Application, Findings, and Assessment) and all applicable figures and GIS shapefiles also need to be consistent for the record. The RCA can provide the GIS files for the two parcels, if needed. A The acreage has been changed throughout the Assessment to reflect the geographic acreages listed in the MSHCP Information tool. APN 37115001 is 4.51 acres and APN 37115002 is 2.25 acres. The two parcels of the project site add up to 6.76 acres. Comment Partially Addressed GEN-1. While the JPR Application, and Assessment have been revised with the geographic acreage of 6.76 acres, the Findings still list the project site as 6.8 acres. Please update the Findings to reflect the revised 6.76 acreage. Furthermore, updated GIS shapefiles need to be submitted reflecting the revised 6.76-acre project site. The Findings have been revised to change the acreage from “approximately 6.8 acres” to 6.76 acres, as requested. The requested shapefile has been provided to RCA. A Comment Addressed -  -  -   GEN-1. The JPR Application and the Findings list the project site acreage as 6.83 acres; however, the Assessment lists the project site acreage as 6.85 acres. Note that all APN acreages should use the geographic acreage listed in the MSHCP Information Tool. This acreage should be clearly and consistently reported among all JPR documents (i.e., JPR Application, Findings, and Assessment) and all applicable figures and GIS shapefiles also need to be consistent for the record. The RCA can provide the GIS files for the two parcels, if needed. A The acreage has been changed throughout the Assessment to reflect the geographic acreages listed in the MSHCP Information tool. APN 37115001 is 4.51 acres and APN 37115002 is 2.25 acres. The two parcels of the project site add up to 6.76 acres. Comment Partially Addressed GEN-1. While the JPR Application, and Assessment have been revised with the geographic acreage of 6.76 acres, the Findings still list the project site as 6.8 acres. Please update the Findings to reflect the revised 6.76 acreage. Furthermore, updated GIS shapefiles need to be submitted reflecting the revised 6.76-acre project site. The Findings have been revised to change the acreage from “approximately 6.8 acres” to 6.76 acres, as requested. The requested shapefile has been provided to RCA. A Comment Addressed -  -  -  GEN-2. The JPR Application and the Findings list the total acreage occurring within the Criteria Cell (i.e., Cell 5038); however, the Assessment does not separate this acreage out. Given that this review only covers the portion of the project that is located within the Criteria Cell, the Assessment also needs to be revised to list the total geographic acreage that occurs within the Criteria Cell (i.e., Cell 5038). Furthermore, all figures need to clearly depict development areas inside and outside the Criteria Cell. Please revise the Assessment accordingly. A The Assessment now separates the acreage of the 4.31 acres of the site that is within Criteria Cell 5038. It is addressed in Section 2.1.2 Project Relationship to the Western Riverside County MSHCP, and Section 3.3 Plant and Habitat Communities. An additional map, Figure 5, has been included that shows the habitats on the portion of the site within the Criteria Cell only. Comment Partially Addressed GEN-2. While the JPR Application and the Assessment have been revised to separate the acreages inside and outside of the Criteria Cell (i.e., Cell 5038), the Findings, page 7, Criteria Area Species Section incorrectly states that 4.17 acres of the project site are within the survey area for Criteria Area Species. The entire 4.31 acres inside the Criteria Cell are within this survey area. Revise accordingly. The Findings were corrected to show that the entire 4.31 acre portion of the site within the Criteria Cell is within the survey area for Criteria Area Species. A Comment Partially Addressed GEN-2. While the JPR Application, Assessment and Findings all have been updated to match the original GIS shapefiles which show that the portions of the project within the Criteria Cell total 4.31 acres; the revised GIS shapefiles now reflect that 4.28 acres of the project are within the Criteria Cell. Please note that the GIS shapefiles need to reflect the same acreage that is listed in the supporting documentation. While we understand this discrepancy is minor, please revise such that the acreage within the Criteria Cell is consistently reported among all supporting documentation and GIS shapefiles.   Comment Addressed  -  GEN-3. All project APNs need to be consistently reported across all JPR supporting documentation. The APNs listed in the Findings, page 3, incorrectly identifies the project APNs as 377-150-001 and -002, whereas all other JPR supporting documentation lists 371-150-001 and 371-150-002. Additionally, the Findings state that a portion of APN 371-150-016 will be utilized for parking and drive aisle purposes; however, APN 371-150-016 is not being reflected as part of the project in the JPR Application, Assessment, or GIS shapefiles provided. Furthermore, per e-mail correspondences between the Permittee and the RCA on March 3, 2022, APN 371-150-016 is not a part of the proposed project. Please confirm whether or not the project includes APN 371-150-016. If this APN is not a part of the project, please remove this APN from the Findings. If this APN is part of the proposed project, then this needs to be included in all supporting documentation, including the JPR Application, the Assessment, and GIS shapefiles. A APN 371-150-016 is not a part of the project. Comment Partially Addressed GEN-3. One typo remains in the Findings, page 3, Section 1.2, and incorrectly identifies APN 371-150-016 as 71-150-016. All project APNs need to be consistently reported across all JPR supporting documentation. Revise accordingly. This error was not in the Findings document, it was in the Assessment document. The typo was corrected. A Comment Partially Addressed GEN-3. One typo remains in the Findings, page 3, Development Project Description Section, which incorrectly identifies the project APNs as 377-150-001 and 002. Please revise this APN reference to 371-150-001 and 002. All project APNs need to be consistently reported across all JPR supporting documentation.   Comment Addressed  -   GEN-3. All project APNs need to be consistently reported across all JPR supporting documentation. The APNs listed in the Findings, page 3, incorrectly identifies the project APNs as 377-150-001 and -002, whereas all other JPR supporting documentation lists 371-150-001 and 371-150-002. Additionally, the Findings state that a portion of APN 371-150-016 will be utilized for parking and drive aisle purposes; however, APN 371-150-016 is not being reflected as part of the project in the JPR Application, Assessment, or GIS shapefiles provided. Furthermore, per e-mail correspondences between the Permittee and the RCA on March 3, 2022, APN 371-150-016 is not a part of the proposed project. Please confirm whether or not the project includes APN 371-150-016. If this APN is not a part of the project, please remove this APN from the Findings. If this APN is part of the proposed project, then this needs to be included in all supporting documentation, including the JPR Application, the Assessment, and GIS shapefiles. A APN 371-150-016 is not a part of the project. Comment Partially Addressed GEN-3. One typo remains in the Findings, page 3, Section 1.2, and incorrectly identifies APN 371-150-016 as 71-150-016. All project APNs need to be consistently reported across all JPR supporting documentation. Revise accordingly. This error was not in the Findings document, it was in the Assessment document. The typo was corrected. A Comment Partially Addressed GEN-3. One typo remains in the Findings, page 3, Development Project Description Section, which incorrectly identifies the project APNs as 377-150-001 and 002. Please revise this APN reference to 371-150-001 and 002. All project APNs need to be consistently reported across all JPR supporting documentation.   Comment Addressed  -  GEN-4. Related to comment GEN-3 above, it is unclear which APNs are being impacted by the proposed project, and the GIS shapefiles appear to conflict with the site plan (refer to Assessment, Figure 2). Please include the APNs on all applicable figures in the Assessment, including the site plan provided in Figure 2. A The correct APNs, 371-150-001 and 371-150-002, have been added to all figures in the Assessment. Comment Addressed - - - -  -  -  Project Description (PD)             PD-1. The Assessment states, “The development of the proposed project will impact the entire 6.85-acre project site.” While it is assumed that this would be permanently impacted, this needs to be clearly stated and needs to separate out impact acreages that occur within and outside of the Criteria Cell (refer to comment GEN-2 above). Furthermore, Assessment, Section 1.2, does state no temporary impacts to onsite or offsite areas will occur. This statement is misleading. Please clearly state if the proposed project includes any off-site improvements and staging areas. Please also update the Findings with this information, as applicable, as all JPR supporting documentation needs to present consistent information for the record. A Section 1.2 Project Description within the Assessment has been updated to detail the proposed development that will occur within and outside of the criteria cell on site. The Impacts Map, Figure 6, now outlines the portion of the site within the Criteria Cell also. The entire 6.76-acre site will be permanently impacted. No offsite construction or staging areas are proposed as part of the project.  No offsite impacts will result from project implementation. Comment Partially Addressed PD-1. While the response to comment PD-1 does indeed indicate the entire site would be permanently impacted, this also needs to be clearly stated in the Assessment and Findings. Also include a statement that the project does not include any proposed temporary impacts. Revise accordingly. Section 1.2 Project Description within the Assessment was amended to clearly state that the entire 6.76-acre site will be permanently impacted and that there are no temporary impacts. The Development Project Description on page 3 of the Findings was amended to add “The project will result in permanent impacts to the entire 6.76-acre project site and will not result in any temporary impacts.” A Comment Addressed -  -  -   PD-1. The Assessment states, “The development of the proposed project will impact the entire 6.85-acre project site.” While it is assumed that this would be permanently impacted, this needs to be clearly stated and needs to separate out impact acreages that occur within and outside of the Criteria Cell (refer to comment GEN-2 above). Furthermore, Assessment, Section 1.2, does state no temporary impacts to onsite or offsite areas will occur. This statement is misleading. Please clearly state if the proposed project includes any off-site improvements and staging areas. Please also update the Findings with this information, as applicable, as all JPR supporting documentation needs to present consistent information for the record. A Section 1.2 Project Description within the Assessment has been updated to detail the proposed development that will occur within and outside of the criteria cell on site. The Impacts Map, Figure 6, now outlines the portion of the site within the Criteria Cell also. The entire 6.76-acre site will be permanently impacted. No offsite construction or staging areas are proposed as part of the project.  No offsite impacts will result from project implementation. Comment Partially Addressed PD-1. While the response to comment PD-1 does indeed indicate the entire site would be permanently impacted, this also needs to be clearly stated in the Assessment and Findings. Also include a statement that the project does not include any proposed temporary impacts. Revise accordingly. Section 1.2 Project Description within the Assessment was amended to clearly state that the entire 6.76-acre site will be permanently impacted and that there are no temporary impacts. The Development Project Description on page 3 of the Findings was amended to add “The project will result in permanent impacts to the entire 6.76-acre project site and will not result in any temporary impacts.” A Comment Addressed -  -  -  PD-2. According to the site plan provided in the Findings and the Assessment, the proposed project does not include any detention basins or other water quality features; however, this needs to be clearly stated and addressed. A Implementation of the proposed project would include lid infiltration basins that will run southwest to northeast along the eastern boundary of the site. These features are addressed within Section 1.2 Project Description of the Assessment. Comment Addressed - -  -  -  -  - - - - - - - -  PD-3. Using the updated GIS shapefiles for the project, and according to the soils map generated by the RCA, a small area of Traver and Ramona soils occur within the northern corner of the project site. However, these soils are not acknowledged within the Assessment. In addition, Assessment, Appendix D, Soil Map, lists the total Area of Interest as 6.4 acres, which does not include the total area of the project site (i.e., 6.76 acres). Please revise the Assessment to discuss these soils (Traver and Ramona) in all applicable Sections, and revise Appendix D, Soil Map, to include the entire project site (i.e., 6.76 acres) which would include these two soil types. Also refer to comment RIP/RIV-1 and Plant-2 below. A The Assessment was revised to identify the Traver and Ramona soils (page 6). Appendix D was revised to list the acreages of these soil types.  - - - - - - - -  6.1.2 Riparian/Riverine (RIP/RIV)             RIP/RIV-1. According to the Assessment, Section 3.3, the project site contains 0.05 acre of tamarisk dominant ruderal habitat; however, this community is not discussed in the Assessment, Section 6.1, with respect to Section 6.1.2 Riparian/Riverine resources. Note that tamarisk can be associated with riparian habitats and is a facultative species under the USACE wetland indicator list, meaning this species is equally likely to occur in wetland (34%-66%) and non-wetlands. In addition, this 0.05-acre of tamarisk overlaps the Traver soil series which is known to retain moisture. Therefore, further justification (e.g., presence/absence of hydrology indicators in this area, etc.) is needed to verify why this area is not considered a Section 6.1.2 riparian/riverine resource. A Section 6.1 (page 15) discusses the Traver soil and notes that “Although the northern corner of the project site is vegetated with tamarisk, which is a facultative species that is equally likely to occur in wetlands and non-wetlands, and is mapped as containing Traver soil series, which is known to retain moisture, this area of the site is located on a slope containing artificial fill and debris (Appendix C). Therefore, the project site does not contain habitat that may be considered riparian/riverine areas as defined in Section 6.1.2 of the Western Riverside County MSHCP.”           RIP/RIV-1. According to the Assessment, Section 3.3, the project site contains 0.05 acre of tamarisk dominant ruderal habitat; however, this community is not discussed in the Assessment, Section 6.1, with respect to Section 6.1.2 Riparian/Riverine resources. Note that tamarisk can be associated with riparian habitats and is a facultative species under the USACE wetland indicator list, meaning this species is equally likely to occur in wetland (34%-66%) and non-wetlands. In addition, this 0.05-acre of tamarisk overlaps the Traver soil series which is known to retain moisture. Therefore, further justification (e.g., presence/absence of hydrology indicators in this area, etc.) is needed to verify why this area is not considered a Section 6.1.2 riparian/riverine resource. A Section 6.1 (page 15) discusses the Traver soil and notes that “Although the northern corner of the project site is vegetated with tamarisk, which is a facultative species that is equally likely to occur in wetlands and non-wetlands, and is mapped as containing Traver soil series, which is known to retain moisture, this area of the site is located on a slope containing artificial fill and debris (Appendix C). Therefore, the project site does not contain habitat that may be considered riparian/riverine areas as defined in Section 6.1.2 of the Western Riverside County MSHCP.”  6.1.3 Narrow Endemic Plant Species and Section 6.3.2 Criteria Area Plant Species (PLANT)             PLANT-1. According to Assessment, Appendix B, smooth tarplant’s microhabitat includes disturbed places; however, it is noted that no suitable habitat is present on site. As discussed in Assessment, Section 3.3, there are 6.8 acres of disturbed habitat present. Note that disturbance is not acceptable as the sole basis for ruling out suitable habitat in an area. A conclusion that no suitable habitat for Narrow Endemic Plant Species and Criteria Area Plant Species is present on site should be supported with solid evidence (e.g., soil types, topography, existing development). Therefore, please include adequate justification to rule out suitable habitat for Narrow Endemic Plant Species and Criteria Area Plant Species. A The Assessment has been updated with substantiation for the absence of Narrow Endemic Plant Species and Criteria Area Plant Species. It is specifically noted in Section 4.1.1 Sensitive Plant Species that “Smooth tarplant is restricted to clay and alkaline, silty clay soils. No clay or alkaline soils exist on site. None of the plants that smooth tarplant is generally associated with such as, California goldfields (Lasthenia californica), or Atriplex spp. were found on site. No habitat for this species is present on the project site.” Further, Tables 1 and 2 were added to Section 6.1 MSHCP Requirements of the Assessment and contain a thorough habitat assessment for Narrow Endemic and Criteria Area plants. Comment Addressed - - - -  -  -  - - - - - - - -  PLANT-2. As noted in comment PD-3 above, the Assessment is lacking a discussion on the Traver and Ramona soils. Note that several Criteria Area Plant Species (specifically Coulter’s goldfields, Davidson’s saltscale, Parish’s brittlescale, and San Jacinto Valley crownscale) are associated with Traver soils. Therefore, a conclusion that “no suitable habitat occurs” is not sufficient given the presence of Traver soils within a portion of the project site. Therefore, provide further justification to rule out suitable habitat for all applicable Criteria Area Plant Species and Narrow Endemic Plant Species. A Table 2 of the Assessment was revised (pages 19–21) to explain for each of the Criteria Area Plant Species that “Although Traver soils, which are known to retain moisture, are mapped within the northern portion of the site, this area consists of a slope containing artificial fill and debris. No wetlands or suitable habitat communities occur onsite.”   - - - - - - - -  PLANT-2. As noted in comment PD-3 above, the Assessment is lacking a discussion on the Traver and Ramona soils. Note that several Criteria Area Plant Species (specifically Coulter’s goldfields, Davidson’s saltscale, Parish’s brittlescale, and San Jacinto Valley crownscale) are associated with Traver soils. Therefore, a conclusion that “no suitable habitat occurs” is not sufficient given the presence of Traver soils within a portion of the project site. Therefore, provide further justification to rule out suitable habitat for all applicable Criteria Area Plant Species and Narrow Endemic Plant Species. A Table 2 of the Assessment was revised (pages 19–21) to explain for each of the Criteria Area Plant Species that “Although Traver soils, which are known to retain moisture, are mapped within the northern portion of the site, this area consists of a slope containing artificial fill and debris. No wetlands or suitable habitat communities occur onsite.”