Comment 1.1.1 USFWS is sending its standard list of endangered and threatened species that may live in or near the project area, dated August 19, 2004.

Response: This information is acknowledged and no further action is required.

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Comment 2.1.1 The State Clearinghouse confirms that its 30-day comment window has closed and no state agencies submitted comments through it.

Response: This information is acknowledged and no further action is required.

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Comment 2.2.1 Fish and Game has reviewed the project and thinks it could affect fish and wildlife, so the project doesn't qualify as "minimal impact"—meaning the developer has to pay the standard environmental filing fee.

Response: This comment is acknowledged and necessary fees will be paid at the appropriate time.

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Comment 2.2.2 If any work would divert flow or change the bed/channel/bank of a stream or river, the developer needs a Streambed Alteration Agreement from Fish and Game. The CEQA document should fully spell out impacts to streams and riparian areas and how they'll be avoided or mitigated.

Response: The Department's comment is noted. A Streambed Alteration Agreement will be obtained if required.

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Comment 2.3.1 The project is 267 acres next to Cloverdale Municipal Airport and would include a mixed-use resort, golf course, shopping center, and housing.

Response: Comment noted. The comment includes a recitation of uses included in the proposed project and contains no comment on the environmental aspects of the proposed project.

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Comment 2.3.2 Parts of the project sit inside several airport safety zones—including the Runway Protection Zone (RPZ), the most restrictive zone, which is supposed to be off-limits to almost all structures and gathering places. Caltrans is worried about golf holes proposed inside the RPZ, particularly the trajectory of golf balls. The two ways to manage risk in these zones are limiting the number of people present and limiting the building footprint.

Response: In response to comments made by the Sonoma County Airport Land Use Commission (ALUC), the portion of the golf course adjacent to Cloverdale Airport has been redesigned and the redesign had been approved by the ALUC including issues regarding golf ball trajectory.

See also Revised Mitigation Measure 5.2-1 contained in the RDEIR that requires Sonoma County ALUC review and consistency determination with the most recent Alexander Valley Resort Specific Plan.

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Comment 2.3.3 The Airport Master Plan calls for extending Runway 14 to the north someday. If that happens, the RPZ also extends—over part of the project site. Caltrans recommends extending the existing avigation easement to match.

Response: The Cloverdale Airport Master Plan has been approved by the City of Cloverdale and, pursuant to Revised Mitigation Measure 5.2-1, the Sonoma County ALUC must make a determination of consistency between the most current Project and the CALUP.

Revised Mitigation Measure 5.2-1(h) requires the Project developer to dedicate an avigation easement for new development in the ALUC referral area for the Cloverdale Municipal Airport.

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Comment 2.3.4 Caltrans's records show the runway is 3,155 feet long, not the 3,145 feet in the EIR.

Response: The measured length of Runway 14-32 is 3,146 feet per the Airport's consultant, Bob Waddell.

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Comment 2.3.5 No structure should poke up into the airport's "imaginary approach surface" (the 3D safety envelope around the runway). If anything might, the developer needs to file a Notice of Proposed Construction with the FAA.

Response: The RDEIR notes that the FAA issued a "Determination of No Hazard to Air Navigation," with conditions, for three project components, the Resort Hotel, estate residential uses and a proposed on-site water reservoir. Copies of these Determinations are included in the Appendix of the RDEIR.

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Comment 2.3.6 Figure 3-4 shows wetland marshes inside the RPZ and a large artificial pond inside the Outer Safety Zone. Water bodies attract birds, and birds and aircraft don't mix—the FAA recommends restricting wetlands and similar wildlife-attracting uses near airports.

Response: The low wetland marshes shown within the RPZ in the original Site Plan are no longer being proposed. However, a large manmade pond will be located in the OSZ. Based on Comment 2.3.6 above, the current Specific Plan contains Policy NRC7.1 to discourage wildlife use of on-site water bodies.

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Comment 2.3.7 AB 2776 (a recent state law) requires anyone selling land within an "airport influence area" to disclose that fact to buyers.

Response: Information regarding buyer notification of nearby airport influence zones has been transmitted to the project applicant who intends to sell property. The requirements of AB 2776 will be met.

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Comment 2.3.8 State law requires general plans and specific plans to be consistent with adopted airport land-use plans, and the project must go to the Sonoma County ALUC for a consistency determination. The DEIR says it was submitted in February 2001. Caltrans agrees with ALUC about single-sided traffic patterns but is still concerned about uses inside the RPZ.

Response: The commenter is directed to Revised Mitigation Measure 5.2-1, contained in the RDEIR, that requires additional ALUC review and a consistency determination between the current Project and the CALUP.

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Comment 2.3.9 Under CEQA, the EIR has to use Caltrans's Airport Land Use Planning Handbook as a reference for projects in airport-compatibility areas.

Response: The Department's latest Handbook has been used by the EIR consultant in the preparation of this DEIR as evidenced on page 6-6 of the DEIR, References. The RDEIR incorporates this information by reference into the RDEIR.

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Comment 2.3.10 Beyond resubmitting to the ALUC, the developer should coordinate directly with airport staff to make sure the project is compatible with both current and future airport operations.

Response: Planning for the proposed Alexander Valley Resort project as well as the DEIR has been coordinated closely with the City of Cloverdale, owner and operator of Cloverdale Municipal Airport. Revised Mitigation Measure 5.2-1 requires additional ALUC review of the Project to determine consistency between the Project and the CALUP.

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Comment 2.3.11 General statement on the importance of aviation: Cloverdale Municipal has 21 based aircraft and ~10,900 annual operations, and protecting airports from incompatible neighbors is important to the state. Good airport-area planning prevents future conflicts.

Response: The Department's opinion on the value of airports to the state economy is noted.

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Comment 2.4.1 Caltrans agrees mitigation is needed at the South Cloverdale Boulevard/US 101 ramp intersections, but isn't sold on roundabouts there—they're uncommon in the Bay Area, drivers may not know how to use them, and Caltrans wants proof a roundabout would actually improve traffic flow at the northbound off-ramp.

Response: The Caltrans comment is noted. Either roundabouts or standard traffic signals will be employed to improve the operation of local intersections. If the City proposes the use of roundabouts, preliminary designs will be submitted to Caltrans staff, as requested by the commenter.

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Comment 2.4.2 Caltrans is also worried about pedestrian and bike safety in a roundabout under the freeway bridge. If those issues get resolved, roundabouts are acceptable. Before any approval, Caltrans wants to see roundabout operations modeled in Synchro (a standard traffic-modeling program).

Response: See Response to Comment 3.4.1.

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Comment 2.4.3 Mitigation Measures 4.10-1 through 4.10-3 should be required as conditions of approval, and the City should collect fair-share fees from the developer for the future widening of the freeway overpass.

Response: The comment is acknowledged and will be considered by the Planning Commission and City Council in reviewing the proposed project. The commenter is directed to Section 5.10 of the RDEIR that analyzes traffic and circulation impacts from the current Project,

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Comment 2.4.4 Is the existing westbound left-turn pocket onto the US 101 on-ramp long enough to handle existing plus project traffic?

Response: The commenter is directed to Section 5.10 of the RDEIR, which includes a comprehensive update of the Transportation and Circulation section for the currently proposed Project.

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Comment 2.4.5 What kind of fencing (and how tall) is going on along Asti Road by holes 15 and 16 to keep golf balls off the highway? The City has to ensure errant golf shots don't hit US 101 motorists.

Response: Hole 16 (formerly Hole 15) would not impact Asti Road or Highway 101. Hole 17 (formerly Hole 16) is a short par 3 aimed away from Asti Road and Highway 101. Golf ball trajectories would not typically result in hitting either road at these angles. Applicant has agreed to install a safety fence at the tee box of Hole 17 (formerly Hole 16).

There is a very limited possibility that a really bad golf drive could hook a shot left into the rough, then, attempting to correct this, a second shot could also hook left onto Asti Road. The golf hole has been designed so that there is a 205-foot separation from the centerline of Asti Road to the landing area. This distance is equal to or greater than industry design standards. The applicant has agreed to planting of trees along the project property line which will further limit the potential occurrence of golf balls reaching Asti Road.

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Comment 2.4.6 The Specific Plan lists movie theaters as a possible use, but the traffic study didn't analyze them. Caltrans wants the impact of a theater analyzed since theaters generate a lot of traffic and the Specific Plan permits them.

Response: Movie theaters are no longer proposed uses in the most current version of the Specific Plan. Refer to Section 3.0,Project Description, in the RDEIR.

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Comment 2.4.7 The traffic study analyzed the three S. Cloverdale Blvd. interchange intersections separately, like they're independent. They need to be modeled as a coordinated system. Caltrans asked for this back in the Notice of Preparation phase and it should already be in the DEIR.

Response: The commenter is directed to Section 5.10 of the RDEIR, which includes a comprehensive update of the Transportation and Circulation section for the currently proposed Project.

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Comment 2.4.8 Caltrans has twice asked the City to analyze the project's impact on US 101 mainline traffic, and it's still not in the DEIR. As lead agency, the City has to identify and mitigate every significant impact. Provide that analysis so Caltrans can determine whether the project significantly affects US 101 operations.

Response: The commenter is directed to Section 5.10 of the RDEIR, which includes a comprehensive update of the Transportation and Circulation section for the currently proposed Project.

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Comment 2.4.9 Several proposed traffic mitigations require work in Caltrans's right-of-way at the US 101 ramps, which means an encroachment permit is needed. The DEIR should mention this in Section 3.5.

Response: All necessary permits for work within a state right-of-way will be obtained from Caltrans prior to the commencement of work.

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Comment 2.5.1 Summary of the project: 267 acres between Asti Road and the Russian River, south of Santana Drive. Includes a 15-acre parcel of Prime Farmland under a Williamson Act contract. The project would cancel the contract before its non-renewal expires, then annex into the City. Mitigation proposed: an open-space easement on similar farmland elsewhere, plus fencing to protect adjacent vineyards.

Response: The Project Description has changed from the Original DEIR. The commenter is directed to the most current Project Description found in Chapter 3 of the RDEIR.

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Comment 2.5.2 The DEIR says LAFCO won't accept an annexation that includes Williamson Act land unless certain protest conditions were met when the contract was created. The DEIR also notes Sonoma County has, in the past, allowed early Williamson Act cancellation for terrace mining if the parcel goes into perpetual open space. The City seems to think early cancellation plus a new open-space easement would let development proceed; the Department of Conservation thinks it wouldn't. Department asks the FEIR to clarify the legal path forward, complying with both the Williamson Act and local rules.

Response: The issues of prime agricultural soils and the status of the Williamson Act is analyzed in Section 5.3 of the RDEIR. The RDEIR concludes that, with adherence to Revised Mitigation Measures 5.3-1 and 5.3-2, impacts regarding loss of prime agricultural soils and impacts to the existing Williamson Act contract will be less than significant. Revised Mitigation Measure 5.3-1 requires the Project developer to replace lost agricultural lands and Revised Mitigation Measure 5.3-2 requires the Project developer apply to the County for rescission or cancellation of the Contract; however, the Williamson Act contract has been non-renewed and will expire in 2013.

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Comment 2.5.3 Department asks the Final EIR to clarify the contract-termination plan for the parcel.

Response: The commenter is directed to Section 3, Project Description, in the RDEIR as well as Section 5.3. These sections provided updated information regarding the Williamson Act contract.

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Comment 2.5.4 As a general rule, you can only get out of a Williamson Act contract through the 9-year non-renewal process. Immediate cancellation is reserved for unusual cases and requires findings consistent with the Sierra Club v. City of Hayward (1981) case.

Response: These comments are acknowledged.

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Comment 2.5.5 If the developer applies for cancellation, the city/county must notify the Department when the application is accepted and consider the Department's comments before approving even a tentative cancellation.

Response: The comments regarding the statutory notification requirements are noted. No further response is required.

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Comment 2.5.6 If the developer wants to do an easement exchange (swap one parcel out for another open-space easement), they should contact the Department in advance—the exchange has its own approval process and ultimately needs sign-off from the Secretary of Resources.

Response: The comments regarding the process by which an easement exchange must be approved are noted.

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Comment 2.5.7 When a city annexes Williamson Act land, it generally has to inherit all the contract obligations from the county (with limited exceptions in Government Code §51243.5). LAFCO must notify the Department within 10 days of any such annexation proposal and can only approve it under specific conditions.

Response: The comments regarding the statutory requirements that govern lands under contract that are annexed are noted. No further response is required.

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Comment 2.6.1 The Regional Board lays out the various stormwater-related permits that may apply: 401 water quality certifications, Waste Discharge Requirements (WDRs), the General Construction Storm Water Permit, and rules for post-construction runoff.

Response: The general comments about Water Quality (401) Certification permits, Waste Discharge Requirements, General Construction Activity Storm water permits, and post construction impacts are noted. No further response is required.

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Comment 2.6.2 Several parts of the site are contaminated—the former Masonite wood-treatment facility, the former Louisiana-Pacific sawmill, the former Hot Rocks gravel facility, and various contaminated soil and fill. It looks like some of this material may get reused in the project. The EIR has to be explicit about what happens to those soils. Contaminated material left in place from the Masonite site can't simply be moved around during grading. The EIR needs to address what happens to the contaminated soils from the L-P truck shop, the construction soils on the log deck, and other on-site soils.

Response: The comment expresses concern that contaminated soils at the former Masonite facility, the former L-P sawmill, and the former Hot Rocks Facility may be improperly reused during grading operations. Contaminated materials on these sites, which are under RWQCB oversight, cannot be reused without RWQCB approval. The Construction Hazardous Materials Management Plan (CHMMP), required in Mitigation Measure 4.6-2(b), requires provisions to ensure that contaminated soils are stored, managed, and disposed of safely, and in accordance of applicable regulations. Mitigation Measure 4.6-2(b) requires coordination with RWQCB for construction in areas under RWQCB oversight. The CHMMP and coordination with RWQCB would reduce potential impacts from reuse of contaminated soils to a less-than-significant level.

The commenter is directed to Sections 2.5 and 5.6 of the RDEIR that updates information on the status of contamination on the Project site. Also see Comment and Response R1.2 from the Regional Water Quality Control Board that addresses the above comments.

In addition, since the circulation of the Original DEIR, the applicant has applied for and received permits from Sonoma County to remediate wood waste on the site to acceptable levels. This permitting process was subject to the California Environmental Quality Act and a Mitigated Negative Declaration was certified by Sonoma County. Wood waste remediation operations has been completed.

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Comment 2.6.3 The Regional Board is the lead agency for landfill regulation under Title 27 of the California Code of Regulations. The site's landfill is regulated under Order 84-064. The project would completely remove two waste-management units, screen and sort materials for reuse or disposal, and clean up groundwater. The developer needs to submit a Report of Waste Discharge so the Board can evaluate the landfill's clean closure and the reuse of any reclaimed material as soil amendment, and so it can draft Closure WDRs to consider at a public meeting.

Response: The comment regarding regulatory requirements for clean closure of the former wood waste landfill is noted. Waste Discharge Requirements for the closure of the wood waste landfill have been issued by the RWQCB. No further response is required.

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Comment 2.6.4 The DEIR says the project will be annexed for City water and sewer, and that the developer plans to mix on-site well water with tertiary-treated wastewater for golf-course irrigation. The on-site irrigation wells should be identified—including depths and pumping rates—and existing well info should be compared against projected water needs.

Response: Section 5.13 of the RDEIR describes the water supply for the proposed Project.

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Comment 2.6.5 The Regional Board strongly supports using recycled water for the golf course and landscaping, but the developer may need to get/comply with WDRs for recycled water use, or the City may need to renew the WDR for its wastewater treatment plant.

Response: The applicant will be required to comply with all requirements associated with the use of recycled water.

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Comment 2.6.6 Mitigation Measure 4.5-2 only requires a 10-foot vegetative buffer between creek banks and irrigated turf. That's narrow and may need to be wider to comply with the Regional Board's WDRs. The mitigation also says stormwater will drain through vegetated swales. The Board may require monitoring and reporting on impacts to surface and groundwater from golf-course fertilizers, pesticides, and other chemicals.

Response: This comment is acknowledged. The Project developer will be required to prepare one or more Stormwater Pollution Prevention Plan(s) as part of future Precise Development Plans for each Project component that will include details regarding water quality methods.

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Comment 2.6.7 Mitigation Measure 4-13.3 says a groundwater hydraulic report will be reviewed by the City before the golf course is built. Additional monitoring wells will be needed to track impacts of golf-course irrigation on the existing groundwater contamination at the Masonite site.

Response: Based on additional information included in the RDEIR, including an SB 610 Water Supply Analysis, Mitigation Measure 4.13-3 included in the Original DEIR is no longer applicable to the current Project.

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Comment 2.6.8 The DEIR mentions ENSR International (acting for International Paper) submitted a work plan to speed up in-place groundwater treatment. Note that the Regional Board did not approve the IP proposal and is requiring ongoing groundwater monitoring to confirm the in-situ cleanup is actually working.

Response: This comment is acknowledged. The status of clean up efforts on the site is summarized in Section 2.5 of the RDEIR.

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Comment 2.6.9 PES (Tyris's environmental consultant) thinks more water infiltration into the ground wouldn't significantly affect groundwater. But recent sampling of the L-P domestic well found pentachlorophenol at 71 and 41 parts per billion. The Regional Board doesn't think the existing data supports PES's conclusion—more investigation is needed.

Response: This comment is acknowledged. The status of clean up efforts on the site is summarized in Section 2.5 of the RDEIR.

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Comment 2.6.10 Soils excavated from the Cloverdale Truck Stop are stockpiled on the former sawmill site, awaiting a regulatory decision on removal or reuse. The Regional Board has previously stated the requirements for soil reuse and is waiting on the developer to submit the necessary information so it can issue or waive WDRs.

Response: This comment is acknowledged. The status of clean up efforts on the site is summarized in Section 2.5 of the RDEIR.

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Comment 2.6.11 The DEIR says no hazardous releases were identified at the former Hot Rocks gravel facility. But during drilling of monitoring well MW-22, petroleum odors came up and a follow-up investigation found minor soil contamination—so contaminated soils in that area exist and have to be handled accordingly.

Response: This comment is acknowledged. The status of clean up efforts on the site is summarized in Section 2.5 of the RDEIR.

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Comment 2.6.12 "Fill of Unknown Origin" on page 4.6-10 contains diesel and motor-oil hydrocarbons (below regulatory thresholds) plus arsenic (which exceeds them). The EIR should explain what happens to this fill—is it reused on site, and where? Submit a reuse proposal along with a Report of Waste Discharge.

Response: The commenter is advised that this material has been removed, and no precise map of the former location of this material is available.

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Comment 2.6.13 Improperly stored cans of paints and stains were found at the site. Their locations should be plotted on a map and their origin stated in the EIR.

Response: The Project developer notes that the paint cans were removed by August 2002. No additional information regarding the origin of the cans was available. Provisions in the CHMMP, required in Original Mitigation Measure 4.6-2(b), address the potential for previously unknown contamination to be encountered at the site. After mitigation, no significant public health and safety impacts from the paint and stain storage is anticipated.

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Comment 2.6.14 The EIR's section on hazardous-materials sites within a mile mentions MGM Brakes and a Superfund site, but misses another MGM facility at the northeast corner of Santana Lane and S. Cloverdale Boulevard. That site has had releases of volatile organic compounds (VOCs) into surface and groundwater, with cleanup ongoing.

Response: This comment is acknowledged. The status of clean up efforts on the site is summarized in Section 2.5 of the RDEIR.

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Comment 2.6.15 Pumping groundwater could change the natural flow direction and pull contaminated groundwater toward the project's wells. Be aware: if groundwater pumping affects the contamination plume in a way that complicates cleanup, the project could be added as a "responsible party" for plume investigation and cleanup.

Response: The commenter states that the project applicant could be considered a responsible party for contamination at the site if the applicant's actions complicate or cause changes in the ongoing groundwater remedial efforts. The commenter is directed to Sections 2.5 and 5.6 of the RDEIR that updates the status of contamination and clean up on the site as well as Comment Letter R1.2 and responses to this comment. Based on Revised Mitigation Measure 5.6-2, the impact of extraction of groundwater near contaminated portions of the site would be less than significant.

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Comment 2.6.16 Contaminated soils at the former Masonite and sawmill sites can't be excavated or reused without first testing contaminant levels and leachability and getting Board approval—or hauling them to an approved facility. They cannot be moved on-site without Regional Board approval.

Response: The commenter describes the requirements for excavation and reuse of contaminated soils from sites under RWQCB oversight. Contaminated soils will stored, managed, and disposed of safely, and in accordance of applicable Regional Board regulations.

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Comment 2.6.17 The EIR doesn't mention the chemical breakdown products from the pentachlorophenol contamination. Dioxins and furans are persistent in the environment and should be evaluated. Some limited soil sampling for these has been done as part of the Masonite investigation.

Response: The comment describes the likely presence of dioxins and furans in soils at the Masonite site as a result of pentachlorophenol releases, and states that these contaminants should be addressed and evaluated in the EIR. See Revised Mitigation Measure 5.6-3 (a) contained in the RDEIR.

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Comment 2.6.18 Impact 4.6-4's mitigation requires a human health risk assessment and a risk management plan. These need to be reviewed by a regulatory agency like the Office of Environmental Health Hazard Assessment (OEHHA) or the Department of Toxic Substances Control (DTSC).

Response: The commenter states that the HHRA and RMP required by Revised Mitigation Measure 5.6-3(a) will require review by a regulatory agency such as OEHHA or DTSC. The mitigation measure requires review and approval of these documents by RWQCB, the regulatory agency that has overseen all previous investigation and remedial action at the project site. It may be appropriate for RWQCB, at their discretion, to obtain guidance and technical assistance for the review from OEHHA and/or DTSC. This comment is noted. No further response is required.

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Comment 2.6.19 The Mitigation Measure for Impact 4.6-4 says water from the L-P domestic well must meet Regional Board water-quality criteria. The cleanup criteria for well reuse have to achieve non-detectable levels for all contaminants found, and detection limits must be specified. Before any contaminated well is used on the project, the nature and extent of contamination must be characterized—pumping a contaminated well without that understanding could complicate the investigation or cleanup.

Response: The commenter will adhere to all requirements of the Regional Water Board regarding pumping of contaminated groundwater. Also see Revised Mitigation Measures 5.6-2 and 5.6-3, as modified by this Final EIR.

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Comment 3.1.1 The DEIR says Cloverdale has researched its historical water rights and has enough—dating back to the late 1800s—to serve full General Plan buildout. But several things are unclear: which specific water rights apply, what changes (if any) would be needed for the project, what the impact on streamflow would be, and what the cumulative effect on other water-rights holders would be.

Response: The commenter refers to a statement at page 4.13-1 of the Original DEIR, which was provided for background information only. A discussion of the City's water rights for full buildout of the City's General Plan is beyond the scope of the EIR for this Project.

The RDEIR document includes and SB 610 Water Supply Analysis that demonstrates that an adequate long-term water supply can be provided to serve the proposed Project even under drought conditions.

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Comment 3.1.2 The Agency has done extensive hydrogeology studies in the middle Russian River. The DEIR claims groundwater usually flows from the aquifer into the river (recharging it). The Agency's observations show this isn't true in summer and fall. Either provide data backing the claim or clarify when it does and doesn't hold.

Response: The commenter states that the DEIR text on page 4.5-4 that "Most of the time, groundwater flows from the aquifer, recharging the river" should be clarified. The text in the Groundwater section of the Original DEIR is hereby modified as follows and incorporated by reference into the text of the Original DEIR:

"On a regional basis, groundwater in the upper aquifer flows from the valley foothills toward the Russian River. Most Some of the time, groundwater flows from the aquifer, recharging the river. However, during periods of depressed groundwater levels (i.e. during the summer and fall seasons) or elevated river stage, the river water may move into the aquifer; this type of bank recharge is likely to be temporary and subsequently flow back into the river."

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Comment 3.1.3 Mitigation Measure 4.5-4 just points to Mitigation Measure 4.13-2. But Impact 4.5-4 talks about reduced base flow, habitat impacts, and downstream water-rights effects, while the linked mitigation only covers using reclaimed water for the golf course. The mitigation doesn't actually address base flow, habitat, or downstream water rights.

Response: The commenter states that Mitigation Measure 4.5-4 does not adequately address impacts to base flows, habitat and water rights downstream. Original Mitigation Measure 4.5-4 is revised as follows, because it refers to the wrong measure in Section 4.13: "Implement Mitigation Measure 4.13-2 and 4.13-3."

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Comment 3.1.4 The DEIR itself says water supply may be tight in summer. The Water Conservation Plan and Golf Course Landscape Plan should maximize conservation and reclaimed water use.

Response: The commenter states that Mitigation Measure 4.5-4 does not adequately address impacts to base flows, habitat and water rights downstream.

Impact 4.5-4 is no longer applicable since the Project now proposes the use of secondarily treated wastewater for golf course irrigation. Additional pumping of well water, as allowed by existing water rights, is proposed only as needed.

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Comment 3.1.5 The Agency strongly recommends mitigation include funding (or partial funding) to upgrade Cloverdale's wastewater treatment plant so it can produce reclaimed water for the landscaping and golf course.

Response: As stated in Chapter 3 and Section of 5.13 of the RDEIR, tertiary treated water is no longer proposed for golf course irrigation. Instead, the golf course and other major open space portions of the proposed Project would be irrigated by secondarily treated water as provided by the City.

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Comment 3.2.1 The project meets the noise compatibility standards in Section 8.3 of the Sonoma County CALUP.

Response: The commenter states that the project is consistent with the noise compatibility standards of the Comprehensive Airport Land Use Plan (CALUP). The comment is noted. No further response is required

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Comment 3.2.2 The project meets the safety compatibility standards in Section 8.4 of the CALUP, including the RPZ rules: no water features (other than stormwater detention), no golf tees/fairways/greens/cart paths, and breakable fencing to prevent trespass into the airport from the RPZ.

Response: This comment is acknowledged. On December 13, 2004, (after the date of this comment letter), the ALUC found the proposed Development Plan consistent with the current CALUP. Comment 3.2.4, submitted by the Sonoma County ALUC states that if the runway from Cloverdale Municipal Airport is extended north and the ITZ is similarly displaced, the density of clubhouse occupancy and related facilities shall meet the population density requirements of the CALUP for the ITZ.

Revised Mitigation Measure 5.2-1 requires a further determination of consistency between the current Project and the CALUP. See also the February 13, 2009 letter from the ALUC (Letter No. R2.2 in Section IV of this FEIR) which contains a confirmation of the project's continued consistency with the current CALUP.

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Comment 3.2.3 No more than 8 estate homes (as shown in the Draft Specific Plan) may be built in the Inner Turning Zone.

Response: This comment is noted. See Revised Mitigation Measure 5.2-1 in the RDEIR that requires additional review of the current Project by the ALUC.

See also the February 13, 2009 letter from the ALUC (Letter No. R2.2 in Section IV of this FEIR) which contains a confirmation of the project's continued consistency with the current CALUP.

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Comment 3.2.4 If the runway is extended north and the Inner Turning Zone shifts so the clubhouse falls outside the ITZ, the clubhouse occupancy still has to meet CALUP population-density limits.

Response: If the runway is extended, the maximum occupancy of the clubhouse shall meet the population densities of the CALUP. This will be ensured by the required consistency review of the current Project as required by Revised Mitigation Measure 5.2-1.

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Comment 3.2.5 The project meets the airspace protection standards (CALUP Section 8.5) if an avigation easement is granted, and if the FAA finds the hotel and water tank are not hazards (or they are properly marked and lighted).

Response: The commenter states that the project is consistent with the airspace protection standards of the CALUP if an avigation easement is granted to the City and the hotel and water tank are determined by the FAA to either not be a hazard or to be properly marked and lighted. Revised Mitigation Measure 5.2-1 contained in the RDEIR requires dedication of an avigation easement for new development. Also, the RDEIR contained current FAA determinations for the Resort Hotel, Estate Residential and water tank uses.

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Comment 3.3.1 The Department of Health Services is the County's certified Local Enforcement Agency for solid-waste inspection, permitting, and enforcement.

Response: This comment is noted and no further discussion is required.

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Comment 3.3.2 The DEIR estimates 400,000–600,000 cubic yards of wood waste on the site. The plan is to mix it 1:1 with borrow materials and use it as on-site soil amendment or landscape fill.

Response: Wood waste clean up on the Project site has been completed based on a permit granted by Sonoma County.

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Comment 3.3.3 The wood-waste cleanup isn't subject to CIWMB Compostable Materials Handling rules or related requirements.

Response: The comment is noted and no further action is required.

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Comment 3.3.4 Under state regulations (14 CCR 17850(e)), nothing prevents the Enforcement Agency or the board from inspecting any activity, operation, or facility to determine whether the standards apply.

Response: The comment about board inspection of activities on the site is noted. No further response is required.

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Comment 3.3.5 Once the wood-waste site is officially closed under Regional Board rules, the landowner is advised to send a letter to DHS voluntarily surrendering the Solid Waste Facility Permit and asking to archive the Cloverdale II Wood Waste Disposal Site file.

Response: Clean up of wood waste on the site has been completed and a Clean Closure Certification Report was submitted to the RWQCB in February of 2009. When the RWQCB rescinds the Waste Discharge Requirements for the site, the Sonoma County Department of Health Services will be notified.

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Comment 4.1.1 Reuser annexed land near the project site. At the time, Louisiana-Pacific wasn't going to develop industrial land, which was a concern. Infrastructure costs have gone up since then.

Response: The comments regarding the costs of infrastructure to develop the Reuser industrial area are noted. No further response is required.

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Comment 4.1.2 Reuser has reviewed the DEIR and it covers a lot. His main concerns are dust, traffic, and noise—his industrial operation generates noise and dust, and he'll have zero tolerance for complaints about that.

Response: The commenter is concerned that noise and truck traffic impacts generated by his industrial landscaping and recycling business may affect the project adjacent to his property. The proposed Project has been revised so that a golf driving range is currently proposed on the north side of the Project site to buffer other on-site uses from on-going light industrial uses to the north. The extent of the buffer is such as to minimize dust and noise issues for proposed residential uses on the Project site.

In addition, the Specific Plan contains policies and standards to provide buffers and screening to protect future project residences from adjacent windblown dust. Existing industrial operations are also controlled by permits issued by the North Coast Air Quality Management District to control dust and other air emissions.

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Comment 4.1.3 Reuser thinks the project is good but wants real measures in place to head off chronic complaints from new residents against existing and future businesses.

Response: The comment regarding the need to mitigate for future complaints against existing and future industrial uses is noted. The current configuration of the proposed Project would include a wide buffer between noise and dust sensitive uses on the Project site and light industrial uses to the north.

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Comment 4.2.1 The Runway Protection Zones and other safety zones in DEIR Figure 4.2-5 appear to be drawn centered on the edge of the runway, not the centerline.

Response: The Runway Protection Zone (RPZ) and other Safety Zones delineated in Figure 4.2-5 have been redrawn, taking into account the 254-foot runway extension proposed in the Cloverdale Municipal Airport Master Plan 2025, and included as Exhibit 5.2-1 in the RDEIR document.

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Comment 4.2.2 Moving the runway north (per the Airport Master Plan) will require an easement or fee acquisition of about 1.5 acres, which will need to be graded and fenced from the golf course. A 6-foot fence is typical; the minimum is a 4-foot wire mesh with barbed strands and breakaway posts. The fenced area would extend 280–320 feet past the future runway end. This will force relocation of golf hole #7.

Response: The DEIR text discusses this issue in Section 4.2 Land Use and Aviation Compatibility, and in Section 5.2 of the RDEIR. Golf hole #7 has been relocated. The Project applicant is aware of the requirement to provide an easement to the City for the proposed extension of the runway.

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Comment 4.2.3 The issue of golf balls being played across the RPZ—flagged as a potential problem in the DEIR—needs more analysis by the City. Coordinate with the FAA.

Response: Revised Mitigation Measure 5.2-1(c)(3) states that "no golf ball trajectories shall be located in the RPZ."

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Comment 4.2.4 Table 4.2-2 says only 0.7 acres would fall in the Runway Safety Area when the runway is extended, but ~1.5 acres would actually need to be fenced off (see comment 4.2.2).

Response: The commenter notes that the DEIR Table 4.2-2 estimates that 0.7 acres of the project would be in the new Runway Safety Area if the runway is extended, but 1.5 acres would need to be fenced off. This information is noted. Also see Table 5.2-1 contained in the RDEIR.

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Comment 4.2.5 The DEIR (page 4.2-9) says Runway 32's threshold is displaced 510 feet because of a boiler stack that's no longer there. But the displacement is also needed because of trees penetrating the close-in approach near the creek.

Response: Based on the comment, page 4.2-9 of the DEIR text has been clarified to read as follows and is incorporated by reference into the Original DEIR: "The landing threshold for Runway 14-32 is displaced 510 feet. This displacement is was originally intended to ensure adequate clearance over a boiler stack that was previously in the approach to Runway 14-32, but is no longer a problem. Based on more recent information supplied by the City of Cloverdale, the 510-foot displacement is no longer required (personal conversation with John Wanger, City Engineer, 9/21/05)."

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Comment 4.2.6 The DEIR says there's no instrument approach at the airport, but in 2003 an RNAV GPS approach to Runway 32 was published—with 2-mile visibility minimums, and circle-to-land not authorized east of the runway.

Response: Based on the comment, page 4.2-9 of the Original DEIR text has been corrected to read as follows: "Medium intensity runway edge lights are installed, which enable use of the airport during the night. Taxiway edge reflectors are provided to assist taxiing. No rotating beacon is present. No instrument approach procedures have been established for the airport. In 2003 a RNAV GPS approach to runway 32 was published with a two mile visibility minimums and circle to land is not authorized east of the runway, i.e., circle to land must be on the west side."

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Comment 4.2.7 The DEIR (page 4.2-10) says extending the runway northwest would require crossing a drainage channel and could affect wetlands—but a culvert could solve that. The drainage channel itself probably doesn't actually contain wetlands.

Response: The text on page 4.2-10 of the Original DEIR states that "Moving the runway to the north would involve crossing a drainage channel and could affect wetlands." The statement is supported by the biological assessment of the drainage channel, which indicated that it is an "isolated water" (see Figure 4.9-3 of the Original DEIR), which could come under the jurisdiction of the California Regional Water Quality Control Board.

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Comment 4.2.8 The DEIR says terrain west of US 101 and east of the river makes it hard to develop an instrument approach. As noted earlier, an approach has actually been published, with circle-to-land on the west side only—even though the visual traffic pattern is on the east.

Response: Based on the comment, page 4.2-11 of the Original DEIR text has been corrected to read: "Areas west of U.S. Highway 101 and east of the Russian River are places where the terrain penetrates the FAA air space surfaces. These terrain penetrations limit the ability to develop an instrument approach procedure procedures for the airport with low ceiling and visibility minimums."

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Comment 4.2.9 The avigation easement language on page 4.2-11 needs revision.

Response: Revised Mitigation Measures 5-2-1(h) and 5.12-1 require an avigation easement for proposed development on the Project site.

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Comment 4.2.10 Re-do the CALUP and density analyses, since the current graphics don't put safety surfaces centered on the runway centerline.

Response: On December 13, 2004, the Sonoma County ALUC found the proposed Development Plan to be consistent with the CALUP. If the City of Cloverdale extends the existing runway to the north, the ALUC determined that the Alexander Valley Resort would need to be brought into compliance with the CALUP.

Also see Revised Mitigation Measure 5.2-1 contained in the RDEIR that requires a final consistency determination by the Sonoma County ALUC to ensure that the current Project is consistent with the CALUP.

Also see the February 13, 2009 letter from the ALUC (Letter No. R2.2 in Section IV of this FEIR) which contains a confirmation of the project's continued consistency with the current CALUP.

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Comment 4.2.11 The DEIR (page 4.2-25) says the western part of the site isn't affected by CALUP safety zones because the traffic pattern is on the west side. But as noted above, traffic does turn west in a circle-to-land during instrument operations.

Response: Based on the comment, page 4.2-25 of the Original DEIR text has been corrected:

"The ALUC letter indicates that there is no Traffic Pattern Zone designated on the west side of the Cloverdale Municipal Airport, although CALUP does designate one. However, the western TPZ may be deleted as part of a pending update of CALUP. The normal flight pattern used by pilots, including the circle-to-land approach to Runway 14, does not use the western TPZ and ITZ because of the high hills on the project site. The applicant has indicated that elimination of the western TPZ and ITZ will be requested in the updated master plan for the airport (McCarthy, 2004)."

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Comment 4.2.12 The mitigation measures starting on page 4.2-25 address most of the comments in this letter, except for the incorrectly drawn safety surfaces and the west-side circle-to-land maneuver during instrument operations. The circle-to-land is published, but the commenter doesn't expect a significant number of those operations annually.

Response: This comment is noted.

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Comment 4.3.1 The commenter recently lived outside Healdsburg and watched vineyards go in with fences that blocked wildlife from reaching the creek and river. Don't let that happen here. A large pond would be great. Also: no poisons or toxic fertilizers, everything should be solar-powered, water wheels and wind power should be required, and alternative-energy business cars should be mandated.

Response: The resident has a number of specific suggestions for the proposed project, several of which are related to operational details that have not been addressed in the Original DEIR because they are not required through adopted City of Cloverdale building and development regulations. For example, the commenter states golf carts, homes, buildings and lights should be solar powered, and alternative energy business cars, water-wheel and wind power should be mandated for the project. The City has not adopted ordinances that require these types of alternative energy uses in approved development projects.

The design of fencing for the project could address the issue of fences obstructing the movement of animals to Porterfield Creek and the Russian River.

The issue of impacts related to the use of "poisons or toxic fertilizers" is addressed in Section 4.5, Hydrology and Water Quality of the Original DEIR that requires preparation of an Integrated Pest Management Plan that controls fertilizer use and minimizes pesticide use.

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Comment 4.3.2 Healdsburg's restaurants got pricey and shops turned into gift shops that locals don't visit anymore.

Response: The comment regarding "pricey" restaurants and gift shops is noted. The DEIR only addresses environmental issues, not economic issues.

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Comment 4.4.1 Riverkeeper only recently learned about the DEIR and couldn't find a copy at the Cloverdale Library. They support cleaning up the L-P mill site and putting it to new use, but have concerns about: soil and groundwater contamination from the former mill, the plan to bury wood waste under the golf course, construction and post-construction impacts on the Russian River, the source of project water, where and how wastewater would be treated, the potential for using recycled water for irrigation, impacts to on-site wetlands, and riparian setbacks for development and the golf course.

Response: Comments regarding the availability of the Original DEIR at the City library, are noted. The commenter also lists concerns approximately eight issues, all of which are addressed in the Original DEIR, as noted below:

- soils and groundwater contamination (see Original DEIR Section 4.6 Public Health and Safety, pages 4.6-1 through 4.6-11 and pages 4.6-17 through 4.6-23 as well as Section 2.5 and 5.8 of the RDEIR) - proposal to bury wood waste under the golf course (see Original DEIR Section 4.6 Public Health and Safety, pages 4.6-6 through 4.6-9 and Original DEIR Section 4.4 Geology, Soils, and Seismicity pages 4.4-13 through 4.4-14) - storm water impacts to Russian River (see Original DEIR Section 4.5 Hydrology and Water Quality, pages 4.5-9 through 4.5-18) - water supply for project (see Original DEIR Section 4.13 Public Services, pages 4.13-5 through 4.13-7 and pages 4.13-15 through 4.13-23, also see the SB 610 Water Supply Analysis appended to the RDEIR, Revised Impact and Revised Mitigation Measure 5.13-1 and Revised Impact and Revised Mitigation Measure 5.13-2) - wastewater treatment (see Original DEIR Section 4.12 Public Services, pages 4.13-9 through 4.13-11 and pages 4.13-23 through 4.13-25) - potential for recycled water re-use for irrigation (see Original DEIR Section 4.12 Public Services, page 4.13-11 and pages 4.13-18 through 4.13-19, also see RDEIR Sections 5.6, Public Health and Safety, and Section 5.13, Public Services) - impacts to wetlands (see Original DEIR Section 4.9 Biological Resources, pages 4.9-24 through 4.9-26) - riparian setback issues (see Original DEIR Section 4.9 Biological Resources, pages 4.9-11 through 4.9-12 and page 4.9-27).

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Comment 4.5.1 Corkill owns and runs Clover Cinemas downtown—built with City financial assistance. He urges the City to deny inclusion of a movie theater in this project.

Response: The proposed Project has been revised to remove the commercial component where any future theater may have located. See Section 3.0 of the RDEIR that describes the current Project.

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Comment 4.6.1 Have the EIR look at what would happen if the airport were closed, and what would happen if the runway is not lengthened.

Response: Analyzing the closure of the Cloverdale airport is beyond the scope of this EIR because it is not proposed by the applicant or the City. However, the City of Cloverdale has adopted an Airport Master Plan that does include an expanded runway to the north.

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Comment 4.6.2 Provide details on how many local private pilots use the airport for personal flights vs. visitors and commercial users. Compare the airport's economic costs and benefits to those of the resort project.

Response: The commenter asks for data regarding local private pilots versus visitors or commercial operations. This data is beyond the scope of this EIR. The commenter also asks for a comparison of the economic benefits and costs of airport versus the project. Economic analysis is not addressed in EIRs, which analyze only physical environmental impacts, not economic or social impacts. However, an economic study analyzing the costs and benefits of the project has been prepared as a separate report from the EIR.

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Comment 4.6.3 How many pilots will be affected if the airport is closed or the runway isn't extended?

Response: An analysis of the potential effects of the project on pilots is beyond the scope of this EIR.

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Comment 4.6.4 What does it cost to maintain the airport, and what does it contribute to the local economy?

Response: Data and analysis regarding maintenance costs of the Cloverdale Airport and contribution to the local economy is beyond the scope of this EIR.

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Comment 4.6.5 How many jobs will the resort create, and what will it contribute to the local tax base and infrastructure (property tax, sales tax, occupancy tax, schools, water treatment)?

Response: The number of permanent jobs anticipated to be created by the revised project is unknown, but could be significant due to anticipated employment from hotel and commercial components of the Project. Fiscal information on a proposed project is not required to be included in an EIR, but is included in a separate fiscal report regarding the Project.

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Comment 4.6.6 It would be great if the City could have both an airport and a resort, but airport approach patterns and air clearances may limit or jeopardize the resort. The commenter understands that significantly cutting the housing component might make the project unfeasible.

Response: The commenter's opinions about the relationship of the project and the airport are noted. The closure of the Cloverdale airport is not proposed by the applicant or the City. No further response is required.

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Comment 4.7.1 Corzilius represents the Palomino Lakes Mutual Water Company. Their only water source is the Russian River.

Response: This comment is noted and no further response is needed.

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Comment 4.7.2 Corzilius agrees with the proposed mitigation for surface-water-quality impacts (Mitigation Measures 4.5-1 and 4.5-2). He disputes that Mitigation Measure 4.5-4 actually reduces the water-supply impact to less-than-significant. The mitigation puts much of the burden on the City to build a tertiary water system and accept recycled water, and the document itself doubts whether recycled water can even be used on golf greens. The DEIR also makes clear that both the City and the resort will need new wells.

Response: See Section 5.13 of the RDEIR document as well as the SB 610 Water Supply Analysis for the proposed Project that is included as an appendix to the RDEIR.

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Comment 4.7.3 From newspaper comments by Tyris, the on-site wells could pump 250,000 to 1.5 million gallons per day. These wells draw from the Russian River underflow, which depends on releases from Lake Mendocino.

Response: The Project has been revised to include the use of existing secondarily treated wastewater as provided by the City for golf course and major landscaping irrigation. This is described in Section 3.0 of the RDEIR. Secondarily treated water would be used as the primary source of irrigation water for the golf course and major landscaped areas on the site; secondly, recycled water would be supplemented by groundwater pumped from existing wells on the site, as allowed by the land owner's water rights; and thirdly, municipal water would be used for the Resort Hotel, residential dwellings and other similar land uses.

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Comment 4.7.4 With the Sonoma County Water Agency on a reduced river-flow schedule, that volume of pumping is roughly 1/15th of all releases from Lake Mendocino. That's an enormous amount of water—and lots of other cities, smaller communities, and private parties also use river water.

Response: Extraction of groundwater from the Russian River would be minimized for use on the Project site through the use of secondary treated wastewater for golf course and major landscaping irrigation. There would be some pumping of groundwater to supplement treated wastewater, which is permitted under the landowner's existing water rights. The commenter is directed to the SB 610 Water Supply Analysis that is included in the RDEIR to demonstrate that an adequate long-term water supply can be provided to serve the Project.

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Comment 4.7.5 With wells 135 feet deep, sustained heavy pumping will create a "cone of depression"—the porous gravels around the wells will compress and lose permeability. That will reduce river underflow through the area, potentially blocking some neighboring wells and reducing flow to others. The lower underflow permeability could also cause more erosion of the riverbanks at the surface, hurting downstream homeowners.

Response: The commenter is directed to Section 5.13 of the RDEIR that describes use of treated secondary water for irrigation of golf course and major landscaped areas. This would reduce the need for additional groundwater pumping as originally proposed.

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Comment 4.7.6 Cloverdale's economic benefits are understood, but in this agricultural area the project will hurt private homeowners and farms to the south. Mitigation Measure 4.5-4 should be reworked to address these concerns.

Response: See Response to Comment 4.7.5.

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Comment 4.8.1 The DEIR doesn't say how it will prevent cross-connections between the City's drinking-water system and any alternative water sources. Of particular concern is river water and tertiary-treated water—a cross-connection could be devastating to public health.

Response: The current Project proposes to use secondary treated water for irrigation of the golf course and major landscaped areas. Necessary safeguards will be put in place by the City of Cloverdale prior to instituting a secondary source of water as required by the California Building Code.

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Comment 4.8.2 Review the state regulations for backflow and back-siphonage controls—the 2001 California Plumbing Code and Title 17 of the California Code of Regulations, 7th edition.

Response: The commenter notes that mixed flow systems are required to install mandatory backflow protection devices by the 2001 California Plumbing Code and Section 7583 through 7605 of the California Code of Regulations. Any construction for the project would be required to comply with all applicable building and plumbing codes as enforced by the City of Cloverdale.

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Comment 4.9.1 Greenbelt Alliance asks for an extension of the DEIR comment period beyond August 27, 2004.

Response: The comments regarding the comment period for the Original DEIR and the request for lengthening the period are noted. In a specific response to this request, the DEIR comment period was extended to September 3, 2004 by the City of Cloverdale.

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Comment 4.10.1 The applicant talks about using recycled water from the City's plant, but Cloverdale has no plans to upgrade treatment to make that possible. Given the project's huge water use, the upgrade has to happen before the golf course opens. Smith also wants to know how deep the project's wells will be so impacts on neighboring wells can be assessed.

Response: The proposed Project has been modified to use secondary treated water as supplied by the City. There is therefore no need to upgrade the City's wastewater treatment plant to provide tertiary treatment. See Section 3.0 of the RDEIR that describes use of secondary treated water.

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Comment 4.10.2 Smith thinks pilots should turn east after takeoff if heading south. Either east or west turns are fine off the southbound takeoff, but planes should never fly over this project or Cloverdale.

Response: This comment is noted and no further response is required.

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Comment 4.10.3 Anyone buying a home or lot in the project should get written notice of the "right to farm" law. A lot of farm work happens early in the morning, which residents typically don't appreciate.

Response: This comment is noted. This impact is not noted as a potentially significant impact in the Original DEIR so no mitigation is required.

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Comment 4.11.1 The Planning Commission asked to revisit the conclusion that the on-site alternative is the environmentally superior alternative. A 1,000-unit residential development on the site could have more impacts than the proposed project, not fewer. The DEIR's reasoning is based on the golf course's water demand vs. residential—but the on-site alternative would use domestic water, while the mitigated project might use recycled water. The on-site alternative would also push Cloverdale's population to ~10,700, near the limit of the City's water supply. So the on-site alternative looks like a bigger impact, not a smaller one.

Response: Pages 5-2 through 5-3 of the Original DEIR describe the On-Site alternative: "The 18-hole golf course would be reduced to a nine-hole course. In place of the nine golf holes that are removed, additional single family housing and recreational uses oriented to the Russian River would be substituted. The 125 acres of single family homes would be sited around the resort and recreational uses in locations that would conform with the land use restrictions of the Cloverdale Municipal Airport safety zones. Assuming an overall density of six to eight units per acre, a total of 750 to 1,000 homes would be accommodated in the Reconfigured On-site Alternative. Under this alternative, the uses would receive the same City services as in the proposed project, and the same remediation of hazardous materials would occur. It is further assumed that the access road locations and other improvements would be similar to the proposed project."

The current Project includes use of secondary treated water to irrigate the proposed 18-hole golf course and major landscaped areas. Since the On-Site Alternative would reduce the size of the golf course that would be served by treated wastewater, and replace golf holes with residences that would use domestic water, the proposed project would represent an environmentally superior alternative in terms of estimated water use.

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Comment 4.11.2 The DEIR has several long-term maintenance requirements built into mitigation measures. The mitigation measures should also identify long-term financing programs to fund that maintenance.

Response: The commenter notes that the financing programs to cover the cost of several long-term maintenance programs required in the DEIR should be identified. The California Environmental Quality Act does not require that the costs or funding sources for recommended mitigation measures must be identified. However, measures often contain text that requires the applicant to pay the partial or full cost of specific improvements and programs, such as transportation or other infrastructure improvements needed to serve the project. Two programs are identified by the commenter: the Water Quality Management Plan and Slope Maintenance Program have been amended as follows:

Original Mitigation Measure 4.5-2 contains the requirement for the Water Quality Management Plan. Subsection (i) of the measure requires a monitoring component to ensure that the provisions of the plan are implemented successfully over time. The measure states that "The monitoring component of the plan shall be prepared by the applicant and submitted to the city of Cloverdale for review and approval prior to issuance of grading permits." Thus, most of the ongoing maintenance cost of monitoring would be borne by the applicant. The only costs that would be required of the city staff is the cost associated with the review and approval of the plan. Theoretically, these staff costs could be covered through permit (such as grading permit) fees.

Original Mitigation Measure 4.4-2(d) contains the requirement for the slope maintenance program. The measure states: "A self-perpetuating slope maintenance program (i.e., a program that has an ongoing funding mechanism) shall be established (to be managed by a project site business and/or homeowners association or similar entity that includes annual inspection of slopes, debris benches, and v-ditches. An annual report documenting the inspection and any remedial action conducted shall be submitted to the Cloverdale Community Development Department for review." Again, the only costs that would be required of the city staff is the cost associated with the review of the annual report. Theoretically, these staff costs could be covered through permit fees charged to the Project. It is possible that recovery of City costs may be addressed in the proposed Development Agreement as well.

Revised Mitigation Measures 5.10-1 through 5.10-3 discuss the Project's contribution to assist in funding circulation improvements.

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Comment 4.12.1 Has anyone assessed whether this huge project plus other City projects can actually be served by the supplies in the Urban Water Management Plan?

Response: A Water Supply Analysis prepared pursuant to SB 610 is included as an appendix in the RDEIR to demonstrate that a long-term water supply is or will be available to serve the proposed Project.

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Comment 4.12.2 Has the City established Total Maximum Daily Loads (TMDLs) to maintain or improve water quality? Pesticides, fertilizers, and other chemicals applied to the golf course could be discharges of pollutants into U.S. waters. Who is responsible for monitoring this?

Response: The City has not adopted TMDLs; this is the responsibility of the Regional Water Quality Control Board. The RWQCB has listed the Russian River as impaired for excess sediment and temperature.

Project developer(s) are required to prepare and implement a number of measures to protect water quality. These include Storm water Pollution Prevention Plans, a Water Quality Management Plan, a Health and Safety Plan and an Integrated Pest Management Plan.

Also, if recycled water is used to irrigate the golf course, as proposed, nutrients contained in the recycled water would reduce the need for fertilizer application on golf course turf.

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Comment 4.12.3 On sewage: what's the current volume, the plant's capacity, and the projected volume after the project? What will the tertiary treatment facility actually cost the City? Will the project pay for the treated water, or will ratepayers indirectly pay for the plant and pipelines?

Response: Based on discussions with the Cloverdale City Engineer, the dry weather capacity of Cloverdale's wastewater treatment plant is 1.0 million gallons per day (mgd). The average daily dry weather flow into the plant in the year 2004 was 0.28 mgd. Average daily dry weather flows are anticipated to increase since City crews are repairing leaky sewer lines and manholes, which is anticipated to increase flows into the plant.

The current Project now includes use of existing secondary treated water for golf course and landscaping irrigation. Since the City's wastewater treatment plant currently produces secondary treated water, no upgrades to the plant are required.

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Comment 4.12.4 Seasonal wetlands need protection even if they're no longer under Army Corps jurisdiction. Unclear how the Migratory Bird Treaty Act handles wetland loss.

Response: Potential impacts to the seasonal wetlands on the project site are analyzed in Section 4.9, Biological Resources of the Original DEIR. Original Mitigation Measure 4.9-4(a) requires preparation of a Conceptual Wetland Protection, Replacement, and Restoration Plan that identifies wetland and jurisdictional area, and provides for protection and enhancement where feasible. If wetland habitat is to be created, the displaced wetland shall be replaced at a 1:1 ratio, and any small isolated wetlands shall be preferably consolidated. The wetland plan must specify performance criteria and long-term management responsibilities. Regarding discharges to wetlands, Original Mitigation Measure 4.5-1 requires preparation of a detailed Storm Water Pollution Prevention Plan that will control erosion of stockpiled earth and other measures to reduce discharges.

The Migratory Bird Treaty Act is discussed on page 4.9-10 of the Original DEIR.

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Comment 4.12.5 How does the project fit with the City's Growth Management Program?

Response: The Cloverdale growth management program is an infrastructure review ordinance, not a numerical growth control ordinance. Whenever it is projected that the city will have more than 200 housing units built in a single year, the city must prepare an infrastructure audit to determine if the infrastructure is adequate for the projected development. An infrastructure audit was triggered by growth projections in 2000, 2001, and 2002. The 2002 audit concluded that the City has adequate infrastructure, either in place or funded by impact fees, to serve a population of 11,000–12,000 people. Levels of development have been less than 200 units and have not triggered infrastructure audits in 2003 and 2004. If the proposed Project, in conjunction with other development, amounted to more than 200 housing units in a single year, an infrastructure audit would be required.

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Comment 4.12.6 The cumulative effect of water diverted from the Russian River and tributaries is subject to CDFG and NOAA Fisheries guidelines. The State Water Resources Control Board has 100+ pending applications in the Russian River watershed—many factors could compromise capacity.

Response: This comment is noted.

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Comment 4.13.1 This letter was sent to the Department of Conservation about cancelling the Williamson Act contract on the parcel. The lawyer called Department staff and offers further explanation of the proposed action.

Response: This comment is noted. See Revised Mitigation Measure 5.3-2.

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Comment 4.14.1 Contaminated soils at the former Masonite site and others aren't Tyris's problem. International Paper (IP) is operating under a Regional Board order to clean up and monitor the former wood-treatment area at the former Hot Rocks site. Louisiana-Pacific is responsible for cleanup of its stockpiled material on the site.

Response: The commenter states that IP and Louisiana-Pacific are the responsible parties for the former Masonite facility, Hot Rocks facility, and stockpiled soils at the site. The comment is noted. No further response is required.

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Comment 4.14.2 The project is designed to put as much of the contaminated area as possible under paved surfaces or the golf course, with no residential use in those areas. Mitigation Measure 4.6-2(b) covers any remaining concerns.

Response: The commenter states that the project has been designed to cover the Masonite and Hot Rocks facilities with impervious surfaces and a golf course, and that residential land uses at these areas is not proposed. The comment is noted. No further response is required.

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Comment 4.14.3 IP has submitted a work plan to investigate the pentachlorophenol contamination found on the site—the same contaminant tied to the former Masonite facility, which is IP's responsibility.

Response: The commenter states that IP is investigating the discovery of pentachlorophenol in a domestic well at the site. The comment is noted. No further response is required.

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Comment 4.14.4 Tyris will use reclaimed water to the maximum extent feasible and will work with the City toward that goal.

Response: The commenter states that the applicant intends to use reclaimed water to every extent feasible. The comment is noted. No further response is required.

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Comment 4.14.5 On Mitigation Measure 4-13.3: International Paper has groundwater monitoring wells downgradient of the former Masonite and Hot Rocks facilities. Whether these are sufficient or more are needed will be decided later.

Response: The commenter states that a series of groundwater wells are present down gradient of the Masonite and Hot Rocks facilities. The comment is noted. No further response is required.

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Comment 4.14.6 When PES did its infiltration study (referenced on page 4.6-5), the domestic well contamination hadn't been discovered yet. IP is investigating it now and will determine whether infiltration is the cause. Since the contamination was found at 135 feet below grade, surface infiltration is unlikely to be the issue.

Response: The commenter states that surface water infiltration is unlikely to have caused PCP contamination in the domestic water well. This contamination is currently under investigation; no cause has yet been identified. The comment is noted. No further response is required.

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Comment 4.14.7 Stockpiled soil materials are L-P's responsibility. Within about two weeks, L-P will submit the documentation needed for Regional Board approval to address the soils issue. If reuse turns out to be unfeasible, L-P is required to remove the soils.

Response: The commenter states that Louisiana Pacific is responsible for the soil stockpiles on the site, and is obligated to remove the soils if reuse is unfeasible. The comment is noted. No further response is required.

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Comment 4.14.8 Those soils will be mixed with wood waste and placed under the golf course, in compliance with Regional Board requirements.

Response: The commenter states that stockpiled soils are proposed to be mixed with wood waste and used for construction of the golf course. This operation has been completed based on a Use Permit granted by Sonoma County and with necessary CEQA clearances.

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Comment 4.14.9 The cans of paints and stains have been removed; no map exists of their precise locations. A general-location map can be provided if requested.

Response: The commenter states that paint and stain cans described on page 4.6-10 of the DEIR have been removed, and no precise map of their previous location is available. The comment is noted. No further response is required.

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Comment 4.14.10 None of the contaminated material left on the site will be excavated or moved around. It will all stay either under paved areas or under the golf course.

Response: The commenter states that contaminated materials proposed to be left in place are not proposed to be excavated or reused at the site. The comment is noted. No further response is required.

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Comment 4.14.11 Water from the contaminated well isn't currently being used and won't be without Regional Board approval.

Response: The commenter states that water from the contaminated domestic well at the site is not currently being used, and will not be used without RWQCB approval. The comment is noted. No further response is required.

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Comment 4.15.1 Anselmo did a thorough analysis of Keith Howard's September 14, 2004 letter (Letter 4.14). He has no further comments on the DEIR or Howard's letter regarding the Regional Water Board.

Response: Comments are noted and no further response is required.

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Comment 4.16.1 On page 2.8.6c, please verify the wording with reference to FAR 77.25(c) and (d).

Response: See Revised Mitigation Measure 5.2-1 contained in the RDEIR.

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Comment 4.16.2 On page 4.2-11, "Runway 142" should be "Runway 14."

Response: Based on the committee's comment, the reference on page 4.2-11 of the RDEIR to Runway 142 is revised to "Runway 14."

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Comment 4.16.3 On page 4.2-11, please verify the language about "must be free of obstructions below the clear zone glide path."

Response: Based on the committee's comment, the Original DEIR text on page 4.2-11 is revised to: "No structures can be built within the runway protection zone. In addition, there is a requirement that the land within the avigation easement must be free of obstructions below the clear zone glide path clear zone approach surface must be free from obstructions."

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Comment 4.16.4 On page 4.2-15, Policy G-3, the end of the sentence appears to be cut off in the reference to the State Division of Aeronautics.

Response: The six General Plan land use policies relating to aviation cited on page 4.2-15 of the DEIR have been re-lettered as "F-1" through "F-6." Policy F-3 is cited as written in the General Plan.

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Comment 4.16.5 On page 4.2-25, third bullet: the committee isn't aware of any federal regulation that automatically allows a 35-foot structure on ground that penetrates the horizontal surface. What's the source?

Response: The reference is from a letter of the Sonoma County ALUC staff. The reference is in the ALUC's Comprehensive Airport Land Use Plan, Section 8.5.1(3).

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Comment 4.16.6 On page 4.2-26, clarify the statement "20:1 imaginary plane starting at the end of the existing or extended runway." Per FAR 77.25(c) and (d), it should read "starting 200 feet from the extended runway."

Response: Refer to the Original DEIR revision as noted in Response to Comment 4.16.1.

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Comment 4.16.7 On page 4.2-10, clarify the statement that no instrument approach procedure has been established for the airport—Cloverdale has a GPS instrument approach.

Response: This comment is noted.

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Comment 4.16.8 On page 4.2-18, no mitigation measures are listed for the noted impact about disclosing airport noise.

Response: See Revised Mitigation Measure 5.12-1 contained in the RDEIR that provides mitigation for airport noise.

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Comment 4.16.9 The turning zone protections need to stay in place. The FAA instrument procedure has circle-to-land on the west side only—east is unsafe.

Response: The committee's comment that "turning zone protections need to stay in place" is noted. The reference to the "terrain penetration" text on page 4.2-11 has been revised. See Response to Comment 4.3.8.

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Comment 4.16.10 The committee supports the proposed runway expansion.

Response: This comment is noted and no further action is required.

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Comment 4.16.11 It would be helpful to extend water and sewer out to the airport while this project is being built.

Response: This comment is noted but the proposed action is outside the scope of this EIR.

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Comment 4.16.12 Recommend a walking/bike path continuing from First Street out to the airport—would be a wonderful addition.

Response: The committee's support for a walking/bicycle path connection to the airport is noted. Potential trail connections are discussed in Section 4.10, Transportation and Circulation contained in the Original DEIR.

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Comment 4.17.1 Tyris provides an overview and history of the project and its environmental cleanup efforts.

Response: These comments are noted and no response is required.

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Comment 4.17.2 The developer believes the DEIR doesn't credit the applicant for cleaning up and remediating the site, and instead makes the project look like it's harming wetlands, habitat, and adjacent properties.

Response: The California Environmental Quality Act stresses the identification of changes to the natural environment caused by a development project. The law does not specifically require that the beneficial impacts of a project must be documented in an EIR unless the impact is "significant." Significant impacts related to the remediation of the site, including removal of hazardous materials, are discussed in Section 4.6 Public Health and Safety. Section 15126.2(a) of the CEQA Guidelines states:

"An EIR shall identify and focus on the significant environmental effects of the proposed project. In assessing the impact of a proposed project on the environment, the lead agency should normally limit its examination to changes in the existing physical conditions in the affected area as they exist at the time the notice of preparation is published, or where no notice of preparation is published, at the time environmental analysis is commenced. Direct and indirect significant effects of the project on the environment shall be clearly identified and described, giving due consideration to both the short-term and long-term effects. The discussion should include relevant specifics of the area, the resources involved, physical changes, alterations to ecological systems, and changes induced in population distribution, population concentration, the human use of the land (including commercial and residential development), health and safety problems caused by the physical changes, and other aspects of the resource base such as water, historical resources, scenic quality, and public services. The EIR shall also analyze any significant environmental effects the project might cause by bringing development and people into the area affected."

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Comment 4.17.3 Tyris's planners and engineers worked to design components around the site's sensitive environmental areas.

Response: Section 4.9 Biological Resources of the DEIR analyzes the consistency of the proposed design plan with the identified biological features on the site and recommends mitigation to retain or replace biotic values as needed. Also refer to Section 5.9 of the RDEIR.

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Comment 4.17.4 Background on the proposed golf course—design criteria, project economics, etc.

Response: The comments regarding the changing economics of golf courses in development projects and the economic differences between 9-hole and 18-hole golf courses are noted. No further response is needed.

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Comment 4.17.5 Tyris opposes any new airport projects that hurt the AVR project—especially ones proposed after AVR's plans were submitted. The result is two competing master plans, and the DEIR forces the City to choose between airport expansion and the resort. The mitigation requiring AVR to meet current CALUP standards with a 250-foot runway extension would force elimination of three golf holes and relocation of the clubhouse—a significant redesign for an extension that may or may not happen. The current runway already accommodates every fixed-wing single-engine aircraft built in the U.S.

Response: The commenter offers extensive comments regarding existing and planned operations at the Cloverdale Municipal Airport. Following submittal of this comment letter, the City of Cloverdale approved the Airport Master Plan with a northerly runway extension.

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Comment 4.17.6 Tyris provides a long justification for eliminating or modifying the existing Inner Turning Zone and Traffic Pattern Zone west of the airport.

Response: This comment is noted, but changes and modifications to Airport Safety Zones are not part of the Project and are not under the purview of the City of Cloverdale.

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Comment 4.17.7 The boiler stack at the south end of the runway is gone, so the runway could be extended 300 feet south instead of north.

Response: This comment is noted, however, the City's Airport Master Plan includes a northerly extension of the runway.

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Comment 4.17.8 Placing fill near hole 7 won't raise the elevation and so won't conflict with the avigation easement's 272-foot elevation cap.

Response: The comment is noted. A conceptual grading plan for the property east of the railroad tracks was not supplied by the applicant for use with the EIR analysis, so a worst-case assessment assumed that the placement of fill could raise the existing elevation.

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Comment 4.17.9 An economic feasibility study is being done. While not part of the EIR, it'll be important for weighing the project against airport expansion. AVR will bring significant revenue during construction and long-term. The DEIR's claim that airport operations will triple in 5 years is suspect—AVR will help the airport grow, but not that much. The City should weigh both projects' economic benefits.

Response: An economic study for the earlier version of the proposed Project is available for review at the Cloverdale Community Development Department. No further response is needed.

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Comment 4.17.10 The FAA has told Tyris they'll issue a "Determination of No Hazard to Air Navigation" for the estate residential subdivision, the resort hotel, and the water tank.

Response: Such Notices are included in the appendix of the RDEIR.

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Comment 4.17.11 The golf course needs a lot of water and is designed for maximum conservation. Existing wells will be used to the maximum, but recycled water from a City tertiary plant is essential during summer. A long-term water agreement between developer and City is needed before the project even starts.

Response: These comments are noted.

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Comment 4.17.12 The DEIR's biological analysis would force redesign of the Estate Residential portion to avoid at least part of the native grasslands. Tyris argues they should be allowed to transplant the native grasses elsewhere on the site instead.

Response: The analysis under Impact 4.9-2 on page 4.9-22 of the Original DEIR states that the native grasslands are the one sensitive natural community not addressed under policies of the draft Specific Plan, and that the two large stands of native grasslands would both be entirely eliminated as a result of proposed development according to the preliminary grading concept. Policy NRC 4.1 contained in the Specific Plan does call for developing new native grassland in the natural and designated landscape. However, re-establishing native grasslands is a difficult task, requiring intensive monitoring and management, and the commenter's suggestion that the grasses simply be transplanted into open space areas would not serve to adequately protect or replace this sensitive natural community.

Mitigation measure 4.9-2(a), (b), and (c) were recommended in the Original DEIR and modified by Revised Mitigation Measure 5.9-1 of the RDEIR to provide at least partial avoidance of the native grasslands on the site, and to require that any grasslands lost as a result of development be replaced at a minimum 1:1 ratio. The measures do not require complete avoidance of native grasslands, as suggested by the commenter, but do require that a detailed Native Grassland Protection, Replacement and Restoration Plan be prepared to provide adequate mitigation. The replacement and restoration component of the Plan should preferably include salvage and transplant of clumps of grass to be lost, but simply transplanting individual plants into open space areas with no site preparation, maintenance, or monitoring, would be inadequate. No modifications to the DEIR are considered necessary in response to this comment.

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Comment 4.17.13 SMART (the rail agency) may not build bike/walking paths along the railroad right-of-way. To create a trail link between the resort and the planned Russian River levee trail, a new public railroad crossing would be needed—very hard to get because of CEQA and regulatory hurdles. The applicant is negotiating three private crossings (including the existing under-grade crossing as a golf-cart route). Tyris is willing to work with the City to create public paths from the resort to the SMART right-of-way and levee trail if the City can secure public crossing rights down the road.

Response: The Project Description section of the RDEIR identifies proposed railroad track crossings. Revised Mitigation Measure 5.10-5 in the RDEIR requires the Project developer to dedicate proposed trails.

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Comment 4.17.14 Tyris is concerned about the recommended construction of two roundabouts. The eastern roundabout would take valuable applicant property and could destroy a stand of native oaks.

Response: Installation of roundabouts is not mandated by the RDEIR; however, Mitigation Measure 5.10-4 contained in the RDEIR provides that future traffic control devices could include either roundabouts or standard traffic signals at the South Cloverdale Interchange Overcrossing. Potential impacts to native oaks are noted.

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Comment 4.17.15 The Williamson Act analysis in the DEIR is outdated—see Keith Howard's separate letter (Comment 4.13).

Response: This analysis has been updated in Section 5.3 of the RDEIR.

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Comment 4.17.16 A Water Code reference on page 1-3 is incorrect.

Response: The text is a direct quotation from a letter from the California Department of Fish and Game. No change has therefore been made.

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Comment 4.17.17 Chapter 3.1's project description should describe the property as an unsightly abandoned industrial site with piles of demolition wood, miscellaneous debris, abandoned concrete foundations, etc. The project would clean all this up—but won't go forward unless approved.

Response: The Original DEIR text describes the site as a former sawmill and wood treatment plant on page 3-1. The cleanup proposed for the site is described on page 3-12. The applicant's expansion on existing site conditions is noted. The applicant has completed wood waste site cleanup.

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Comment 4.17.18 Page 3.12, second full paragraph should read: "The applicant intends to irrigate the golf course with tertiary-treated reclaimed water from the City, if this is available, and, if not, proposes to use existing wells to irrigate the golf course."

Response: The applicant now proposes to use secondarily treated water, as documented in Section 3.0 of the RDEIR.

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Comment 4.17.19 Page 3.12, third full paragraph should add "or rescission" when discussing Williamson Act actions.

Response: The commenter is directed to Revised Mitigation Measure 5.3-2 contained in the RDEIR.

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Comment 4.17.20 Not used.

Comment 4.17.21 On page 3.11, paragraph 2, replace "extensive grading and processing" with "recontour the land."

Response: Based on the comment, the text on page 3-11 is modified as follows: "where grading and recontouring would be required."

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Comment 4.17.22 On page 3-12, paragraph 3: the project may require importing 140,000 cubic yards of clean fill, not 25,000 as stated.

Response: Refer to the updated Project Description section contained in Section 3.0 of the RDEIR.

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Comment 4.17.23 Insert "or rescission" after "cancellation" before "of an existing."

Response: This comment is superseded by the wording of the RDEIR.

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Comment 4.17.24 Change "NWP railroad" to "NWP railroad tracks."

Response: Based on the comment, the text on page 3-12 of the Original DEIR is modified as follows: "...immediately north of the former sawmill site and east of the NWP railroad tracks."

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Comment 4.17.25 Replace "smaller shops" with "complimentary retail."

Response: This wording is superseded by wording in the RDEIR.

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Comment 4.17.26 Mitigation Measure 4.1-4 needs clarification—Cloverdale's R-1 zoning doesn't allow lots smaller than 6,000 sq ft and 60 ft wide.

Response: Based on Section 4.0 of the RDEIR, Mitigation Measure 4.1-4 contained in the Original DEIR no longer applies to the current Project.

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Comment 4.17.27 On page 4.1-1, the 15-acre former vineyard parcel Tyris purchased is within the Area II Destination Commercial boundary.

Response: Based on the comment, the text on page 4.1-1 is clarified as follows: "Other properties that are within the Area II Destination Commercial boundary on the City General Plan map include the vineyards and rural residential lots south of the project site and west of the Cloverdale Airport (Figure 4.1-1)."

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Comment 4.17.28 On page 4.1-8: it's the Sonoma County LAFCO Policies and Guidelines that prohibit annexation of Williamson Act land unless certain conditions are met. The project may not meet those conditions, but the Policies allow the applicant to submit written justification for any inconsistency.

Response: See Section 5.3 of the RDEIR, Agricultural Resources, that updated the analysis of this topic.

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Comment 4.17.29 On page 4.1-14, Mitigation Measure 4.1-4 should clarify that preparing Precise Development Plans won't trigger new CEQA review.

Response: Based on the RDEIR, this Original Mitigation Measure is no longer applicable to the current Project.

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Comment 4.17.30 On page 4.2-3: Shamrock Materials' mining approvals went through independent Sonoma County environmental review and aren't related to the project. Mining agreements predated Tyris's purchase of the property.

Response: In response to the comments about the mining operations, the following text on page 4.2-3 is clarified: "A small portion of the project site that is within the Russian River channel, east of the existing levee, has been subject to gravel mining. The mining activities are unrelated to the proposed project. The applicant has not entered into any mining agreements, but rather the mining agreements were negotiated with previous property owners and are binding on all future owners."

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Comment 4.17.31 On page 4.2-7: should the Cloverdale Rancheria (Pomo Indian) project be included in the cumulative CEQA analysis as a probable future project? There's no pending application for the gaming facility and the project has been abandoned.

Response: Although there has been discussion of an Indian gaming casino north of the Project site, no approvals have been granted by federal agencies. Impacts caused as a result of any casino will need to be mitigated by the operator or owner of any casino.

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Comment 4.17.32 On page 4.2-25: Mitigation Measure 4.2-1 effectively chooses future airport runway expansion over construction of the golf course. The two are incompatible—both can't happen. Suggested revised mitigation language follows.

Response: The City of Cloverdale has subsequently approved an Airport Master Plan that includes the northerly extension of the runway.

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Comment 4.17.33 On page 4.2-25: Mitigation Measure 4.2-1(d) suggests at least 6 estate units need to be eliminated because they're in the ITZ. But the text also says the ITZ may be modified to exclude its western side (which would obviate the cuts). And even at proposed densities, the ITZ-wide density is below the required 0.2 units/acre—so why use only part of the ITZ for density math?

Response: The project was found consistent with the CALUP by the Sonoma County Airport Land Use Commission on December 13, 2004. An additional finding of consistency by the County ALUC is required by Revised Mitigation Measure 5.2-1 in the RDEIR.

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Comment 4.17.34 Mitigation Measure 4.2-1(f) is not only unreasonable, it's not even FAA's job to review precise development plans.

Response: Necessary FAA determinations have been received by the Applicant and are included as an appendix of the RDEIR.

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Comment 4.17.35 The DEIR should just apply FAA, CALUP, and ALUC rules—not interpret them. Mitigation Measure 4.2-1 should simply require the project to comply with those documents.

Response: See Comment Letter R2.2 from the Sonoma County ALUC, indicating that the current Project is generally consistent with CALUP requirements. Revised Mitigation Measure 5.2-1 requires a final determination of consistency for the current Project by the ALUC.

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Comment 4.17.36 The zones in Figure 4.2-5 aren't centered on the runway centerline. Unclear what's being shown.

Response: See Response to 4.2.1 and 4.2.10.

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Comment 4.17.37 Per the County ALUC and Caltrans Handbook, there shouldn't be an Inner Turning Zone west of the runway because the VFR pattern is on the east.

Response: See Response to Comments 4.2.6, 4.2.8 and 4.2.11.

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Comment 4.17.38 There's a published non-precision instrument approach to Cloverdale Airport that's not authorized at night.

Response: The comment about the non-precision approach is noted.

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Comment 4.17.39 That instrument approach has a circle-to-land option that has to be flown west of the airport. Minimums: 1,440 ft altitude (1,168 ft above ground), 2-mile visibility.

Response: The comment about the non-precision approach is noted. See Response to Comment 4.17.38.

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Comment 4.17.40 [The missed-approach procedure for the non-precision instrument approach...] Tyris argues the property would never be overflown.

Response: The comment is noted. However, it does not appear that sufficient data exists to unequivocally state that the property would never be overflown. The circle-to-land maneuver requires the pilot to maintain visual contact with the runway during the approach. This typically results in flight paths being flown tighter than usual. Pilots flying this approach may use Highway 101 as a landmark during the approach. This could bring pilots over the western edge of the project during a circle-to-land approach.

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Comment 4.17.41 Critical issue: the runway extension. One option would be to provide a Runway Safety Area at the south end by shortening the runway—that would require redefining all the zones and renegotiating the existing RPZ easement.

Response: Regarding the option of extending the runway to the south, the City has recently approved a Master Plan for the Airport that will eventually result in a northerly extension of the runway.

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Comment 4.17.42 Various issues with technical terminology and factual details.

Response: Regarding runway length, runway numbering, and non-precision approach, see Responses to Comments 2.3.4 and 4.2.6 respectively. Regarding change in slope, the text on page 4.2-18 states "The current avigation easement that restricts uses within the Runway 14 protection zone extends 1,000 feet into the project site and requires that the land in the easement be kept clear of obstructions within the clear zone approach surface defined by a 20:1 plane with an elevation of 272.6 to 312.6 feet." If the definition of the 20:1 plane and elevation is wrong, it is embodied in the adopted avigation easement and cannot be changed until the easement is renegotiated.

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Comment 4.17.43 Tyris attaches a memo exploring shortening the runway instead of extending it.

Response: The technical comments are noted. See Response to Comment 4.17.41.

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Comment 4.17.44 The DEIR is wrong about Impact 4.2-1—the FAA-set Runway Safety Area is a 200-foot area immediately adjoining the runway and is on airport property, not the project site.

Response: Based on the comment, the text on page 4.2-18 is revised: "In addition, the U.S. Federal Aviation Administration sets the boundary for a Runway Safety Area, which also falls is located 240 feet from the end of the runway and is not within the site." Runway Safety Areas for this class of runway extend 240 feet beyond the runway end.

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Comment 4.17.45 The DEIR says "approximately one-half of the Estate Residential component is within the ITZ." Wrong—about 2.5 of the 6.4 estate-residential acres are in the ITZ, ~39%.

Response: This comment is noted and included by reference in the Original DEIR. Also see Section 5.2 contained in the RDEIR that updates issues regarding airport compatibility.

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Comment 4.17.46 Figure 4.2-5 doesn't show the RPZ and other safety zones in their accurate locations (centered on the extended runway centerline). They're shifted west, which makes it look like more Estate Residential land is in the ITZ than actually is.

Response: See Exhibit 5.2-1 contained in the RDEIR that updates airport safety zones for Cloverdale Airport.

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Comment 4.17.46a The second half of the first paragraph on page 4.2-23 conflates the Runway Safety Area (RSA) with the Runway Protection Zone (RPZ). Also, there's no requirement that the 20:1 approach surface be kept clear on the ground—only that no obstructions penetrate it.

Response: Based on this comment, it should be noted that the Runway Safety Area (RSA) is different from the Runway Protection Zone. The intent of the City is to require a low fence along the property line between the project and the airport property that would not penetrate into the 20:1 conical surface.

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Comment 4.17.47 The DEIR (page 4.2-23, second paragraph) says the CALUP prohibits structures and obstructions in the RPZ and requires zero population density. That's an interpretation not supported by CALUP Table 8B—the relevant footnote 4 only applies to structures.

Response: The commenter's opinion is noted and no further action is needed.

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Comment 4.17.48 Mitigation Measure 4.2-1(a) should be deleted—it deals with an assumed 250-foot runway extension that isn't part of the Specific Plan.

Response: The significance criteria for the measures is discussed on page 4.2-17. Based on the Environmental Checklist in Appendix G of the CEQA Guidelines, a proposed project could be considered to have significant land use impacts if it would "conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project." Additionally, "for a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport," the project's impacts could be significant if "the project would result in a safety hazard for people residing or working in the project area" or if "the project would expose people residing or working in the project area to excessive noise levels." The adopted CALUP is based on the Airport Master Plan, which has been updated to provide for the northerly extension of the runway. It is therefore appropriate for an EIR to document impacts for the existing plan, as well as future plans that are under discussion.

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Comment 4.17.49 Mitigation Measure 4.2-1(b) should be deleted—it relates to runway expansion, not the Specific Plan.

Response: The requirement that the project conforms with CALUP standards for the RSA applies to the existing and future runway. Based on the comments, no changes in the DEIR have been made.

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Comment 4.17.50 Mitigation Measure 4.2-1(c) prohibits golf holes in the RPZ—that's not a CALUP requirement and would seriously hurt the golf course's viability. Delete it.

Response: The commenter is directed to Revised Mitigation Measure 5.2-1 in the RDEIR that prohibits golf holes within the RPZ.

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Comment 4.17.51 Mitigation Measure 4.2-1(c)(3) (no golf-ball trajectories in the RPZ) should be deleted—it's not consistent with CALUP standards.

Response: The commenter is directed Revised Mitigation Measure 5.2-1 in the RDEIR that prohibits golf ball trajectories within the RPZ.

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Comment 4.17.52 Mitigation Measure 4.2-1(c)(4) (golf cart paths with stopping/congregation points) should be deleted—CALUP doesn't regulate that.

Response: Mitigation Measure 4.2-1 c(4) has been superseded by Revised Mitigation Measure 5.2-1 contained in the RDEIR.

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Comment 4.17.53 Mitigation Measure 4.2-1(c)(5) (RPZ fencing) isn't required by CALUP.

Response: See Revised Mitigation 5.2-1 in the RDEIR that deals with fencing in the RPZ.

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Comment 4.17.54 Delete Mitigation Measure 4.2-1(e).

Response: See Revised Mitigation 5.2-1 in the RDEIR.

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Comment 4.17.55 Mitigation Measure 4.2-1(h) should be clarified—the avigation easement shouldn't have to be more restrictive than CALUP requires.

Response: Revised Mitigation Measure 5.12-1 requires dedication of an avigation easement, but does not require that this easement will be more restrictive than required by the CALUP.

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Comment 4.17.56 On page 4.2-1, paragraph 5: include the "log bin ramp" in the list of structures at the sawmill complex.

Response: The "log bin ramp" is already included on page 4.2-1 in the list of structures at the sawmill. No further response is needed.

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Comment 4.17.57 On page 4.2-2, paragraph 5: insert "and clean up" in the last sentence.

Response: The responsibility of International Paper to clean up groundwater contamination is summarized in Section 2.5 of the RDEIR.

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Comment 4.17.58 Insert APN 117-050-014 and 117-050-017 after "lumber mill property" before "was first approved."

Response: Based on the comment, the text on page 4.2-2 is revised: "Mining of the river gravel bar within the river channel portion of the former Louisiana-Pacific lumber mill property (APN 117-050-014 and 117-050-017) was first approved by Sonoma County in 1986 (Figure 3-2)."

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Comment 4.17.59 Shamrock did use public roads to haul gravel during the 2003 mining season. Haul roads are "primarily" in the river channel, not "entirely."

Response: Based on the comment, the text on page 4.2-2 of the Original DEIR is revised: "Haul and access roads to and from the gravel bars are entirely primarily within the river channel; no public roads are used to haul gravel to the Shamrock processing plant. Shamrock did use public roads to haul gravel to its processing plant during the 2003 mining season when they were unable to install bridges in the river channel."

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Comment 4.17.60 On page 4.2-9, paragraph 2: there's only one vacant property accessed off the Santana Drive cul-de-sac, not two.

Response: Based on the comment, the text on page 4.2-9 is revised: "In addition to the Rancheria gaming complex, future development that would be anticipated in the immediate area of the project site would be industrial development of the two one vacant properties property accessed off the cul-de-sac at the end of Santana Drive."

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Comment 4.17.61 On page 4.2-9, paragraph 4: Airport Road accesses the airport from Asti Road, not Highway 101.

Response: See Section 5.10 of the RDEIR that updated Transportation and Circulation issues.

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Comment 4.17.62 On page 4.2-9, paragraph 6: delete the sentence saying the runway should be 3,160 feet long for Cloverdale's temperatures—or justify it.

Response: Based on the comment, the text on page 4.2-9 of the Original DEIR is revised: "For temperatures at Cloverdale, the runway should be 3,160 feet long, according to FAA standards 365 days per year in order to accommodate 100% of the general aviation fleet."

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Comment 4.17.63 It's Runway 32 (not Runway 14-32) whose threshold is displaced 510 feet.

Response: Regarding runway number, all references on page 4.2-9 of the Original DEIR to Runway 14-32 are revised to "Runway 32." Based on the comment, the text on page 4.2-9 is revised: "With the displaced threshold, 2,645 2,636 feet are available for landings on Runway 14-32."

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Comment 4.17.64 The boiler stack was in the approach to Runway 32, not 14-32.

Response: This comment is noted.

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Comment 4.17.65 The math on landing distance is wrong. With a runway length of 3,146 feet and a 510-foot displacement, that leaves 2,636 feet for landing on Runway 32—but the DEIR says 2,645 feet for Runway 14-32. The displacement only applies to Runway 32, not 14-32.

Response: This comment is noted.

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Comment 4.17.66 Delete the last sentence on page 4.2-10 paragraph 1—there is a published GPS approach to Runway 32.

Response: As requested by the commenter, this last sentence is deleted by reference.

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Comment 4.17.67 The DEIR (page 4.2-10) says south runway expansion isn't feasible due to environmental constraints. Note that extending 254 feet northeast would destroy wetlands identified elsewhere in the DEIR. Any feasibility analysis should include economics.

Response: Subsequent to this comment, the current Airport Master Plan calls for a northerly extension of the runway.

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Comment 4.17.68 On page 4.2-10, paragraph 5: the drainage channel is actually a wetland under Regional Board jurisdiction. Moving it "will" affect wetlands, not "could."

Response: This comment is noted.

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Comment 4.17.69 On page 4.2-11, paragraph 4: there's a published RNAV approach. The terrain penetrations limit minimums on the existing RNAV procedure.

Response: This comment is noted and no further action is required.

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Comment 4.17.70 Page 4.2-11, paragraph 6: the reference should be to "Runway 14," not "Runway 142."

Response: See Response to Comment 4.17.63.

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Comment 4.17.71 On page 4.2-18, paragraph 2: the existing Runway Safety Area is on airport property, not the project site.

Response: This comment is noted. See Exhibit 5.2-1 contained in the RDEIR that updates safety zones for Cloverdale Airport.

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Comment 4.17.72 On page 4.2-23, paragraph 1: the 1988 Airport Layout Plan called for extending the runway 3,200 feet to the southeast, not northeast into the project site.

Response: This is superseded by the most recent Airport Master Plan for Cloverdale Airport.

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Comment 4.17.73 On Impact 4.2-1: the most recent Caltrans Land Use Planning Handbook generally reduces the size and criteria of safety zones at smaller airports.

Response: Based on the comment, the text on page 4.2-11 is revised: "The California Division of Aeronautics defines specific safety zone boundaries based on accident probability and common flight tracks in the California Airport Land Use Planning Handbook (State of California, 2002a). These zones extend beyond the immediate vicinity of runways. The most recent version of the Handbook generally reduces the size and criteria of safety zones at small airports."

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Comment 4.17.76 Mitigation Measure 4.3-2 should end after the first sentence (which requires LAFCO compliance). The next two sentences are the EIR authors' legal interpretation, based on outdated information.

Response: See Revised Mitigation Measure 5.3-2 contained in the RDEIR that updates Mitigation Measure 4.3-1 contained in the Original DEIR.

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Comment 4.17.77 On page 4.3-5: even if the annexation isn't consistent with LAFCO policy, the applicant can submit written justification for annexing the Williamson Act parcel.

Response: This comment is noted.

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Comment 4.17.78 On page 4.3-9: the APN for the Silverado Premium Properties parcel north of the site is 116-310-005, not -05.

Response: This comment is noted.

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Comment 4.17.79 On page 4.3-12: there's only one Williamson Act contract covering three properties—not multiple contracts.

Response: This is updated in Section 5.3 of the RDEIR.

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Comment 4.17.80 Mitigation Measure 4.4-3, second sentence—delete it. The EIR shouldn't substitute its opinion for the geotechnical engineer's. The compaction rates from the wood-waste landfill pilot study are very high and may be suitable for access roads or utility corridors.

Response: Based on the comment, Mitigation Measure 4.4-3 on page 4.4-13 is revised:

"(a) The site specific geotechnical report shall specifically address the potential hazards associated with use of on site wood waste materials as fill. Fill containing wood waste shall not be placed under any proposed habitable structures, access roadways, or major utility corridors, such as water and wastewater lines, unless the geotechnical report finds that the specific use of the fill is not hazardous."

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Comment 4.17.81 Mitigation Measure 4.4-4(b) (specific requirements for expansive soils) should be deleted. Limited irrigation actually helps because expansive-soil problems come from differential moisture in the soil. Areas under building foundations are typically dry; the area around the building should be kept dry with positive drainage and low irrigation volumes.

Response: The commenter acknowledges that the measure is often appropriate but prefers to leave the specific mitigation selection to the geotechnical engineer. It is the professional opinion of the EIR preparer that the requirement for low water-need plantings and irrigation in common areas, particularly around buildings, is needed in addition to the recommendations of the geotechnical report to mitigate the impact to a less-than-significant level. It should be noted that the use of low water-need plantings is also consistent with the water conservation plan requirements of Mitigation Measure 4.13-1. Based on the comment, no change in the DEIR has been made.

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Comment 4.17.82 Not used.

Comment 4.17.83 On page 4.4-1, paragraph 4: change both references to "piles" to "wood waste landfill."

Response: These changes are made by reference throughout the DEIR.

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Comment 4.17.84 In Impact and Mitigation Measure 4.4-3: change all references to "on-site materials" to "wood waste material."

Response: These changes are made by reference throughout the DEIR.

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Comment 4.17.85 On page 4.4-14: insert "low to" after "project site have" and before "moderate." Delete "to high" after "moderate" before "shrink-swell potential."

Response: The commenter requests that the term "low to" be used as a modifier for the moderate shrink-swell potential soils. However, the commenter does not provide a reason that this term should be added and no explanation of its meaning. In the opinion of the preparers of the DEIR, adding this term would not provide additional clarification. Based on the comment, no change in the DEIR has been made.

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Comment 4.17.86 Mitigation Measure 4.5-2(c) should be deleted, except for the first sentence.

Response: It is the profession opinion of the EIR preparer, that the additional requirement in the measure is needed to mitigate the identified impact to a less-than-significant level. Based on the comment, no change in the DEIR has been made.

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Comment 4.17.87 Use "IPMP" (not "IPM") as the abbreviation for Integrated Pest Management Program throughout Mitigation Measure 4.5-2.

Response: These changes are made by reference throughout the DEIR.

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Comment 4.17.88 In Mitigation Measure 4.5-2(g), delete "preventative chemical use shall not be employed."

Response: Based on the comment, Mitigation Measure 4.5-2(g) should be modified to read "preventative chemical use shall only be employed in limited situations where other methods will not be successful and by a licensed technician."

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Comment 4.17.89 Delete the last sentence of Mitigation Measure 4.5-2(h).

Response: It is the professional opinion of the EIR preparer, that the additional requirement in the measure is needed to mitigate the identified impact to a less-than-significant level. Based on the comment, no change in the DEIR has been made.

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Comment 4.17.90 Delete all of Impact and Mitigation Measure 4.5-4—the analysis belongs in Section 4.13.

Response: See Section 5.13 of the RDEIR that updates the water supply analysis for the Project.

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Comment 4.17.91 Delete all of Impact and Mitigation Measure 4.5-5—the remote chance of a levee breach and flooding isn't a significant impact.

Response: See Revised Mitigation Measure 5.5-1 of the RDEIR.

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Comment 4.17.92 Updated information on groundwater remediation at the Masonite Facility.

Response: This information is noted. Additional updated information is provided in Section 2.5 of the RDEIR as well.

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Comment 4.17.93 No justification for the human-health risk assessment (HHRA) and risk management plan (RMP) required by Mitigation Measure 4.6-4(a).

Response: The commenter is correct that past cleanups at the site were completed under regulatory oversight, but much of the work, such as that performed at the Masonite facility, was cleaned up to commercial/industrial land use standards, and did not anticipate the proposed recreational and residential land uses at the property. The presence of arsenic and PCP at the project site above residential land use screening thresholds warrants the development of the HHRA and RMP.

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Comment 4.17.94 Clarification on soil cleanup criteria at the former sawmill site.

Response: This information is noted.

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Comment 4.17.95 Page 4.6-5: groundwater monitoring is and continues to be performed semi-annually for the former Masonite facility by International Paper. The DEIR's claim that no reports have been filed with RWQCB is wrong.

Response: This information is superseded by information provided in Section 2.5 of the RDEIR.

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Comment 4.17.96 Delete the last sentences of Mitigation Measure 4.9-1(a), (b), and (c)—speculating about what other agencies may require.

Response: See Revised Mitigation Measures contained in Section 5.6 of the RDEIR.

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Comment 4.17.97 On page 4.6-10, paragraph 2: delete "of Unknown Origin"—the fill came from the Del Webb project.

Response: Based on the comment, the title on page 4.7-10 is revised: "Fill Material of Unknown Origin."

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Comment 4.17.98 On page 4.6-11, paragraph 2: title should be "Off-Site Environmental Issues," not "Concerns."

Response: Based on the comment, the title on page 4.7-11 is revised: "Off-Site Environmental Concerns Issues."

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Comment 4.17.99a On page 4.6-11, paragraph 3: the third lot with the 5-acre-foot detention pond is east of the L-shaped parcel, not west.

Response: Based on the comment, the text on page 4.7-11 is revised: "A third lot to the west east includes a five acre-foot detention pond used to contain drainage from the business."

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Comment 4.17.99b On page 4.6-13, paragraph 3: insert "wood waste" after "Masonite facility" before "landfill."

Response: Based on the comment, the text on page 4.7-13 is revised: "At the project site, RWQCB has conducted oversight over remedial activities at the former sawmill complex, former Masonite facility, and wood waste landfill."

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Comment 4.17.100 On Mitigation Measure 4.6-1: applicant's construction in the Masonite area shouldn't require RWQCB approval.

Response: Project construction has the potential to affect existing contamination at the site, and therefore it is appropriate to coordinate with the overseeing agency. Even surface construction activities could complicate investigation and remedial activities or affect precipitation infiltration patterns. In addition, the Regional Water Quality Control Board is a separate agency from the City of Cloverdale and the applicant should deal directly with Regional Board staff to determine the type of coordination that would be required regarding this issue.

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Comment 4.17.101a Delete the last sentences of Mitigation Measure 4.6-1(a), (b), and (c)—speculative about what RWQCB may require.

Response: Refer to Response to Comment 4.17.96.

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Comment 4.17.101b In Impact 4.6-4: insert "wood waste" after "sawmill complex" before "landfill," and after "contaminated soil" before "and groundwater."

Response: This change is made by reference in the DEIR.

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Comment 4.17.102 Insert "wood waste" after "clean closure of the" before "disposal facility."

Response: See revised mitigation measures set forth in Section 5.6 of the RDEIR.

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Comment 4.17.103 Mitigation Measure 4.6-4 should be limited to potable water.

Response: See revised mitigation measures set forth in Section 5.6 of the RDEIR.

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Comment 4.17.104 Use "IPMP," not "IPM," for Integrated Pest Management Program.

Response: Based on the comment, all references to "(IPM)" on page 4.65-23 are revised to "(IPMP)."

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Comment 4.17.105 In Section 4.7 (Visual Resources): the DEIR keeps referring to a "natural hill" by US 101 with a serpentine outcropping. Clarify that only the top is natural—the western side has been graded multiple times for roadways. Tyris shares the City's view that this is a high-quality gateway and intends to enhance the hill by regrading scarred portions and establishing a golf landscape along this frontage. The southerly access road will also be enhanced.

Response: Based on the comment, multiple text revisions are made on pages 4.7-1, 4.7-9, 4.7-18, 4.7-19, and 4.7-21 to refer to "the existing prominent hill" with a "rock outcropping" rather than "natural hill," and to acknowledge that "the top and east finger of this hill is natural contours and includes an oak tree grove, while the west facing slope of the hill has been graded numerous times to accommodate various alignments of a former access road into the site." Other revisions describe the future water reservoir, Hole 16 grading on the western slope, recontouring for Hole 17 along the northern slope (resulting in elimination of part of a native grassland stand), and the southerly access road cutting through the serpentine outcropping. The most dramatic topographic change will be removal of the two large wood-waste piles south-central of the site.

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Comment 4.17.106 Revise Mitigation Measure 4.8-1(c), (d), and (e).

Response: See revised mitigation measures included in Section 5.8 of the RDEIR.

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Comment 4.17.107 Is the reference to "CA-Son-2323H" correct?

Response: The reference to "CA-Son-2322H" is correct.

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Comment 4.17.108 Delete "apparently" from the last sentence of Impact 4.8-3.

Response: Based on the comment, the text on page 4.8-18 is revised: "However, the cemetery is apparently more than 1,000 feet from the project site, so no impacts are anticipated."

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Comment 4.17.109 On Mitigation Measure 4.9-1: the Specific Plan designates wetlands, riparian, and woodland areas as Natural Resource Preserves. Some tree/resource loss is unavoidable but can be mitigated through replacement plantings and restoration. Healthy trees will be preserved.

Response: The commenter states that the applicant intends to incorporate the requirements of Mitigation Measure 4.9-1 into the project. The comments are noted. No further response is needed.

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Comment 4.17.110 Tyris will incorporate Mitigation Measure 4.9-2 into the project.

Response: No response is required for the above comment.

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Comment 4.17.111 Revise the statement of Impact 4.9-3.

Response: Based on the comment, Impact 4.9-3 on page 4.9-23 is revised: "Development of the site would generally not have a substantial adverse effect on habitat for special-status species. However, preconstruction surveys would be necessary to confirm absence of could potentially affect raptor nests and red-legged frogs if they are found on the site prior to construction. This is a potentially significant impact."

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Comment 4.17.112 Tyris will incorporate Mitigation Measure 4.9-3 into the project.

Response: The comments are noted. No further response is needed.

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Comment 4.17.113 Tyris will incorporate Mitigation Measure 4.9-4 into the project.

Response: The comments are noted. No further response is needed.

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Comment 4.17.114 Tyris will incorporate Mitigation Measure 4.9-5 into the project.

Response: The comments are noted. No further response is needed.

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Comment 4.17.115 Figures 4.9-1 and 4.9-3 should be revised—they underestimate the proposed Natural Resource Preserve areas and overestimate the oak woodlands.

Response: The commenter states that Figures 4.9-1 and 4.9-3 should be revised to more accurately reflect the extent of proposed Natural Resource Preserve areas, which they believe are underestimated, and the extent of oak woodland areas, which they believe are overestimated. The concerns of the commenter over the information shown in Figures 4.9-1 and 4.9-3 are noted, but these graphics are provided for illustrative purposes only. Comparison of the mapped extent of woodlands in the two figures to aerial photographs does show one area between the fairway to Hole 13 and the Estate Residential use to the southwest that appears to be larger than it actually is in the aerial. However, further comparison also shows that the extent of mapped tree canopy in the Preliminary Grading Concept and Natural Resource Preserves don't include the open woodland directly south of the green to Hole 13 either.

Review of the extent of Natural Resource Preserves shown in Figure 4.9-3 to that shown in Exhibit 2-5 of the Specific Plan shows no appreciable differences. Most of the oak woodlands would be preserved, as acknowledged on page 4.9-16 of the DEIR, but further refinement of the plans is still necessary to protect additional trees. Mitigation Measure 4.9-1 would ensure that tree resources are accurately identified by engineered survey, that plans are refined to protect specimen valley oaks and other native deciduous oaks to the maximum extent feasible, and that a Tree Preservation and Replacement Plan be prepared to ensure adequate protection of trees to be preserved and replacement of trees lost as a result of development. Because tree resources would be accurately mapped as part of implementation of Mitigation Measure 4.9-1, revisions to Figures 4.9-1 and 4.9-3 are not necessary.

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Comment 4.17.116 Delete the first bullet under Mitigation Measure 4.9-1(a)—concern that all oak woodlands would become Natural Resource Preserves.

Response: The first bullet point of Mitigation Measure 4.9-1 only requires "important stands" of oak woodlands to be located in Natural Resource Preserves, not all oak stands. The City of Cloverdale will work with the applicant to agree on what constitutes important stands of oak woodlands. Therefore, this mitigation measure has not been revised.

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Comment 4.17.117 Delete the first bullet under Mitigation Measure 4.9-2(a)—concern that all native grasslands would become Natural Resource Preserves.

Response: See revised mitigation measures contained in Section 5.9 of the RDEIR.

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Comment 4.17.118 The DEIR should acknowledge that the two native-grassland stands on the western slope of the western hill were created by road cuts.

Response: This comment is noted.

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Comment 4.17.119 Delete the first bullet under Mitigation Measure 4.9-4(a)—concern that all wetlands would become Natural Resource Preserves.

Response: No change to Mitigation Measure 4.9-4 contained in the RDEIR is recommended. As noted in the DEIR, treatment of wetland areas are subject to regulations and issuance of permits from the California Department of Fish and Game, Regional Water Board and the Army Corps of Engineers.

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Comment 4.17.120 On page 4.9-10, paragraph 3: delete the sentence about recent genetic research on the red-legged frog.

Response: The discussion on page 4.9-10 of the DEIR provides an accurate summary of genetic research conducted by Rana Resources. In response to the comment, the DEIR text has not been revised.

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Comment 4.17.121 On page 4.9-11, paragraph 1: replace "diked former flood plain of the river" with the more recent "former log ponds used by Louisiana Pacific."

Response: Based on the comment, the text on page 4.9-11 is revised: "However, the Corps has determined that the scattered seasonal wetlands in the diked former flood plain of the river (the former Louisiana-Pacific log ponds), the ephemeral drainage and manmade ponds through the center of the site, and the active spring (Figure 4.9-2) are not jurisdictional because they are hydrologically isolated features."

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Comment 4.17.122 On page 4.9-19, paragraph 3: delete the sentence about "highly invasive" species and the second sentence about "a detailed management report."

Response: The discussion on page 4.9-19 provides an accurate summary of the potential for establishment and spread of invasive species on the site, and the need for a detailed management plan to control highly invasive species. Implementation of Mitigation Measure 4.9-1(c) would ensure that inappropriate invasive species are not planted as part of landscaping, and would include a program to prevent the establishment and spread of broom on the site. In response to the comment, the DEIR text has not been revised.

Regarding "a detailed management plan," research indicates it is difficult to create or restore native grasslands unless substrate conditions such as serpentine soils limit the potential for invasion and dominance by non-native species. In response to the comment, the DEIR text has not been revised.

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Comment 4.17.123 On page 4.9-22, paragraph 1: change the last sentence to "However, re-establishing native grasslands can be a difficult task."

Response: The change is made by reference into the DEIR.

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Comment 4.17.124 Cloverdale's General Plan and Zoning Ordinance limit activities within 30 feet of the top of bank of waterways to protect natural conditions, but allow some uses if they don't endanger water flow or create flood/property hazards.

Response: The comments about the creek setback buffers that are required by the Cloverdale General Plan and Creek Ordinance are noted. No further response is needed.

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Comment 4.17.125 Mitigation Measure 4.9-5 should be revised to require consistency with the City's Creek Setback Ordinance.

Response: This comment is noted, but since it is currently a City requirement is not a true mitigation measure no change to the DEIR is needed.

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Comment 4.17.126 General Plan buildout traffic projections on Asti Road (1,000 peak-hour vehicles north of the south overpass) seem too high—especially since they don't include the casino.

Response: See updated Traffic and Circulation analysis on the current Project in Section 5.10 of the RDEIR.

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Comment 4.17.127 On page 4.10-11: project traffic is added to a base that already includes casino-generated traffic, implying the casino is more likely to be built than the resort.

Response: Based on Section 5.10 of the RDEIR, cumulative traffic assumptions have not included a gaming casino near the Project site.

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Comment 4.17.128 On page 4.10-16: Saturday mid-day trip generation is overstated for the hotel and restaurant categories.

Response: See Section 5.10 of the RDEIR, which analyzes the current Project that includes hotel and restaurant uses.

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Comment 4.17.129 Unlikely that 40 of 48 daily construction truck trips would happen during peak commute hours—they'd more likely be spread over an 8–9 hour day (~6/hr).

Response: The commenter questions the assumption that 40 of the 48 daily construction trips would occur during peak hours. This assumption is a worst-case scenario that was used in the analysis.

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Comment 4.17.130 Mitigation Measure 4.10-9 (requiring a trail connection to a planned SMART trail along the railroad) is too speculative.

Response: Based on a recent conversation with John Nemeth of SMART, SMART is planning a multi-use trail on the east side of the existing railroad tracks. Information is not available from SMART over the timing of trail construction however. Most recently, Sonoma and Marin County voters have approved a sales tax increase to assist in funding SMART improvements.

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Comment 4.17.131 Mitigation measures shouldn't be based on maximum General Plan buildout plus the casino.

Response: See Response to Comment 4.17.3.

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Comment 4.17.132 There are two driveways on Santana Drive.

Response: The project has been revised to eliminate full public access to the project from Santana Drive. There will continue to be an EVA road for the project off Santana Drive.

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Comment 4.17.133 Mitigation Measure 4.10-1 shouldn't require widening of the US 101/S. Cloverdale interchange overpass. Acceptable LOS and queuing can be achieved without widening. Caltrans approval is uncertain (could jeopardize the project), the project alone doesn't justify widening, and any need is 10 years out, if ever.

Response: Mitigation Measure 4.10-1 has been superseded by Section 5.10 of the RDEIR.

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Comment 4.17.134 Mitigation Measure 4.10-2 shouldn't require overpass widening either, and would force a roundabout that could destroy a small oak grove at the project entrance.

Response: Mitigation Measure 4.10-2 has been superseded by Section 5.10 of the RDEIR.

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Comment 4.17.135 On Impact 4.10-6: delete the last sentence of the paragraph beginning "However, if the truck trips...". Fill hauling will be done before residential construction begins.

Response: Impact 4.10-6 has been superseded by Section 5.10 of the RDEIR.

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Comment 4.17.136 Mitigation Measure 4.10-8 should reference the City's eminent domain power for trail/path easements.

Response: Mitigation Measure 4.10-8 has been revised by Section 5.10 of the RDEIR.

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Comment 4.17.137 In Impact 4.10-11: replace "dos not" with "does not."

Response: Impact 4.10-11 has been superseded by Section 5.10 of the RDEIR.

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Comment 4.17.138 Modify Mitigation Measure 4.11-1—revise subsection (e), delete (c), (d), (f), and (g). Wind and vehicle speed don't necessarily affect PM-10 emissions.

Response: Mitigation Measure 4.10-11 has been superseded by Section 5.11 of the RDEIR.

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Comment 4.17.139 The vineyard-to-home buffer (Mitigation Measure 4.11-6(a)) should be 150 feet, not 300.

Response: A County agricultural setback ordinance calls for 100 to 200 foot setbacks. Based on the comment, Mitigation Measure 4.11-6(a) on page 4.11-17 is revised: "(a) A 300 100-foot setback or buffer between any vineyards and nearby residences so long as landscaping or fencing is also provided between residences and vineyards."

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Comment 4.17.140 Mitigation Measure 4.11-5 (limiting fireplaces to gas-burning) is overly restrictive, especially for the hotel.

Response: The City of Cloverdale does not allow wood burning fireplaces on a city-wide basis. Therefore, this mitigation measure has not been changed.

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Comment 4.17.141 On page 4.12-5, paragraph 1: insert "seasonal" before "gravel mining."

Response: Based on the comment, the text on page 4.10-5 is revised: "The project site is bordered on the west by U.S. Highway 101 and seasonal gravel mining occurs in the Russian River on the east side of the site."

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Comment 4.17.142 On page 4.12-10, paragraph 3: redraft the first sentence and delete the rest.

Response: Based on information supplied by the City of Cloverdale, there is a possibility that freight service could be resumed in the future on the railroad tracks adjacent to the project site. Therefore, the first sentence of the third paragraph on page 4.12-10 of the Original DEIR is amended: "However Although all freight train service has been discontinued along the NWP line, and it is highly unlikely that freight service would be reestablished in the future there is a possibility that freight service could be resumed in the future."

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Comment 4.17.143 On page 4.12-10, paragraph 4: redraft the last sentence.

Response: Based on the comment, the text on page 4.10-10 of the Original DEIR is revised: "The rail line right-of-way that runs through the project site is owned by the North Coast Railroad Authority and is 80 feet wide."

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Comment 4.17.144 On page 4.12-11, paragraph 1: replace "and within the Louisiana Pacific lumber mill plant property" with "the project site."

Response: Based on the comment, the text on page 4.10-11 is revised: "As noted above in Section 4.2, Land Use and Aviation Consistency, Shamrock Materials has a ten-year use permit (2001 to 2011) to skim gravel from the gravel bars in the Russian River immediately adjacent and within the Louisiana Pacific lumber mill plant property to the project site."

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Comment 4.17.145 On page 4.13-9, paragraph 5: a second alternative for connecting to the city water system is a private water line on the project site.

Response: Although a second routing for water does exist, the City of Cloverdale does not encourage the construction of private water lines.

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Comment 4.17.146 On page 4.13-9, paragraph 6: add "if such service is necessary" at the start of the second sentence.

Response: The commenter states that a sentence related to the need for a future pump for the lower portion of the property should be revised. The sentence is part of a quote from the City Engineer and his comments cannot be revised.

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Comment 4.17.147 On page 4.13-11, paragraph 1: the project site is 267 acres.

Response: The commenter states that a sentence referring to the size of the project area should be revised. The sentence is part of a quote from the City's Water Master Plan Update and the quote cannot be revised. The City report used a different assumption about the size of the project area.

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Comment 4.17.148 On page 4.13-16, paragraph 1: add "if it is available" at the end of the sentence.

Response: See Section 5.13 contained in the RDEIR for a discussion of the proposed water supply for the current Project.

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Comment 4.17.149 On page 4.13-18, Impact 4.13-2: Windsor's golf course uses a blend of reclaimed and freshwater. Delete the first paragraph of this impact.

Response: See Section 5.13 of the RDEIR for a discussion of the proposed water supply for the current Project.

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Comment 4.17.150 On pages 4.13-20 to -23: Tyris believes there's enough water from on-site wells to irrigate 9 holes; phasing of golf course construction may be needed.

Response: See Section 5.13 of the RDEIR for a discussion of the proposed water supply for the current Project.

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Comment 4.17.151 Revise Mitigation Measure 4.13-3.

Response: See Section 5.13 of the RDEIR for a discussion of the proposed water supply for the current Project.

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Comment 4.17.152 On Mitigation Measure 4.13-4: the City's treatment plant is more than adequate for projected wastewater flows. There's no connection between wastewater flows and tertiary treatment.

Response: The commenter states that there is no connection between wastewater flows and tertiary treatment at the City plant. The comment is noted. No further response is needed. The commenter states that Mitigation Measure 4.13-4 should be revised. Based on the comment, Mitigation Measure 4.13-4 on page 4.10-25 is revised:

"The Development Agreement to be negotiated between the developer and the City should address measures to ensure that the applicant pays a fair share of the cost of upgrading the City's wastewater treatment plant to a tertiary level of treatment. The applicant shall also be required to pay sewer impact fees and construct a pump station somewhere on the lower portion of the site to pump effluent to the existing force main that is stubbed to the site south of the cul-de-sac off Santana Drive, if needed."

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Comment 4.17.153 Mitigation Measure 4.13-5 is unreasonable—the development will have its own security (resort and golf-course personnel), minimizing police calls.

Response: See Revised Mitigation Measure 5.13-3 contained in the RDEIR.

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Comment 4.17.154 On page 5.1, Alternatives: there isn't enough land east of the railroad tracks to support a 9-hole golf course (as the "Reconfigured On-Site Alternative" assumes), given the aviation mitigation restrictions (no golf holes in the RPZ).

Response: For the purposes of the alternative analysis, it was assumed that there would be adequate land for a 9-hole course, since the proposed project is planning nine holes there. However, there is adequate room for only 8 golf holes east of the railroad tracks.

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Comment 4.17.155 On page 5.3, paragraph 1: the number of homes is less than shown in Table 5.1 and this paragraph. Other changes also requested.

Response: This alternative assumes that a 9-hole golf course could be built on approximately 75 acres east of the railroad tracks, and that 125 acres could be planned for single family homes at a similar density to what is being proposed by the project, six to eight units per acre. In addition, Table 5.1 shows a theoretical development summary only. Based on the comment, no changes have been made to the DEIR.

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Comment 4.17.156 On page 5.5, paragraph 5: change "150 to 200 acres" to "250 to 300 acres."

Response: The commenter states that the reference to "150 to 250" acres as one of the criterion for the "Off-Site Alternative" should be changed to "250 to 300" acres. The DEIR alternatives analysis took a more conservative view, and determined that if an off-site location with slightly smaller acreage could be identified, it could be a suitable location for the project as proposed. Based on the comment, no changes have been made to the DEIR.

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Comment 4.17.157 On page 5.8, paragraph 8: replace "750 to 1,000 homes" with "432 homes."

Response: Refer to Response 4.17.155.

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Comment 5.1.1 Wayne Smith (Icaria Creek Vineyards) was concerned about water impacts and asked the City to make sure the right amount of recycled water is available for the golf course.

Response: See Section 5.13 of the RDEIR regarding use of secondary treated wastewater for golf course and landscaping irrigation.

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Comment 5.1.2 Robin Anderson reported the Airport Committee supports the project but submitted a list of comments to the Commission.

Response: The comment is noted. See Responses to Comment Letter 4.16.

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Comment 5.1.3 Chairman Jordan disclosed he's a member of the Airport Committee but has not been part of their discussions on this project.

Response: This information is acknowledged and no further action is required.

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Comment 5.1.4 Troy Soiland submitted written comments (Exhibit 1) and recommended mitigation measures.

Response: Refer to Response 4.16.

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Comment 5.1.5 Howard Blake had concerns about water and airport-compatibility issues. He wanted clarification of the term "industrial," asked about impacts on the wells of a 112-home water district, and raised concerns about percolation runoff downstream. He encouraged on-site retention facilities.

Response: The commenter stated his concerns about water issues and compatibility issues related to the airport. See Section 5.13 of the Revised DEIR for a discussion of water impacts. The RDEIR addresses aviation compatibility issues for the project in Section 5.2, Land Use and Aviation Compatibility. Also see Responses to Comment Letters 2.3, 4.2, and 5.1.

The commenter requested clarification of a definition for "industrial" use. The Cloverdale General Plan defines "General Industrial" land use category as follows:

"This designation provides additional employment opportunities in Cloverdale. It is the intent of this designation that industrial uses (light and quasi-heavy) have little environmental effects as possible. The placement of this designation is located away from residential uses and sensitive habitats where possible. Primary uses include light-manufacturing, limited manufacturing, industrial parks, wineries, lumber mills, assembly, warehousing and distribution. Secondary uses include professional office and research and development. The maximum floor area ratio (FAR) is 0.35" (page 32).

The commenter discussed potential impacts of the project on the wells maintained by the 112-home Palomino Lakes Mutual Water District. See Section 13 of the RDEIR that discussed water supply issues.

The commenter asked about impacts of run-off from percolation downstream. The DEIR addresses run-off issues for the project in Section 4.5 Hydrology and Water Quality of the Original DEIR, specifically in Mitigation Measure 4.5-2(b), (c), and (d).

The commenter encourages the creation of on-site detention facilities. The comment is noted. The Original DEIR addresses detention basins on pages 4.5-17 through 4.5-18 and specifically in Mitigation Measure 4.5-3.

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Comment 5.1.6 Carolyn Marcinkowski asked that all new outdoor lights—both commercial and residential—be shielded so they don't add to light pollution.

Response: The commenter asked if outdoor lighting issues had been addressed in the DEIR and if new lighting will be shielded. The DEIR discusses lighting in Section 4.7 Visual Resources, under Impact 4.7-4 on page 4.7-23 of the Original DEIR. The text notes that "Commonly accepted industry standards for outdoor lighting, e.g., hood shields and industry designs to focus lighting, may reduce glare and the 'leakage' of excess light from parking lots and nighttime activity areas onto adjacent properties. The city has standard conditions of approval that require that lighting for new projects must reduce light spread."

The impact associated with the loss of some dark "night sky" for nearby rural residences is considered a less-than-significant impact. Thus, no mitigation is required. But Mitigation Measure 4.7-3 states "The following measure could be considered: Amend the draft Alexander Valley Resort Specific Plan to include the following policy: The applicant shall submit a lighting program with provisions to minimize light spread with each Precise Development Plan, for city review and approval."

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Comment 5.1.7 Lee Tolbert pushed for conservation and water reuse. He insisted the City help fund upgrading the wastewater treatment plant to tertiary treatment. He suggested cutting overall water use on the project (including landscape and golf-course irrigation), removing contaminated soils and wood waste from the site, and mitigating all storm and irrigation runoff so none reaches the river or blue-line streams.

Response: See Section 5.13 of the RDEIR that discussed use of secondary treated water for golf course and irrigation purposes.

The commenter requested removal of all contaminated soils and wood waste products according to Best Management Practices, and that all runoff from the site be mitigated by use of subsurface flow constructed wetlands. Wood waste materials on the site as a result of former L-P operations have been cleaned up. Mitigation Measure 4.6-2(b) on page 4.6-19 requires that a Construction Hazardous Materials Management Plan shall be prepared for the project to address the safe management and disposal of hazardous materials that may be encountered during project construction, including wood waste. The plan shall include procedures for managing soils and groundwater removed from the site to ensure that any excavated soils and/or dewatered groundwater with contaminants are stored, managed, and disposed of safely, in accordance with applicable regulations.

Regarding runoff, Mitigation Measure 4.5-2(b), (c), and (d) contained in the Original DEIR requires that to minimize golf course runoff into nearby creeks, a minimum of a ten-foot natural vegetated buffer shall be maintained between the edge of irrigated turfgrass and the top of the bank of drainages, including Porterfield Creek and the ephemeral drainages of the site. Drainage shall be directed to grassed swales, area drains, or sumps for percolation, and discharge pipes shall be directed to dense turfgrass areas that can act as a biotic filter and allow percolation.

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Comment 5.1.8 Chairman Jordan asked about the economic analysis.

Response: An economic study analyzing the costs and benefits of the project has been prepared as a separate report from the DEIR.

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Comment 5.1.9 A Commissioner said the DEIR should consider using reclaimed water for irrigation.

Response: See Response to Comment Letter 4.10.

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Comment 5.1.10 A Commissioner said the DEIR should study downstream water impacts of the project.

Response: See Responses to Comments 3.1.1 through 3.1.3, 4.7.3 and 4.7.4.

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Comment 5.1.11 A Commissioner said industry-standard lighting requirements may not be enough for this project.

Response: See Response to Comment 5.1.6.

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Comment 5.1.12 A Commissioner said the DEIR should consider low-water landscape alternatives.

Response: See Comment Letter 4.8.

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Comment 5.1.13 A Commissioner said the DEIR should consider potential conflicts between pedestrian/bike trails and the railroad.

Response: The DEIR discusses a potential impact related to the project and the pedestrian/bicycle path that is planned by SMART along the rail corridor under Impact and Mitigation Measure 4.10-9 on page 4.10-34. This has been modified by Revised Mitigation Measure 5.10-5 contained in the RDEIR.

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Comment 5.1.14 A Commissioner said the DEIR should address overflow and ensure no runoff reaches the Russian River.

Response: See Responses to Comment Letter 4.8 and Response 4.12.2.

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Comment 5.1.15 A Commissioner said the DEIR should compare irrigation demand against available recycled water.

Response: See Response to Comment 4.12.1.

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Comment 5.1.16 A Commissioner said state and federal aviation safety requirements shouldn't be compromised.

Response: The comment is noted. Aviation safety issues are addressed in Section 4.2 Land Use and Aviation Compatibility of the Original DEIR as modified by Section 5.2 of the RDEIR.

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Comment 5.1.17 A Commissioner said the DEIR should consider potential conflicts with nearby industrial uses and the airport.

Response: This comment is noted. The current Specific Plan provides a buffer of a golf driving range on the Project site.

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Comment 5.1.18 A Commissioner asked how traffic could be separated between Santana Drive and Asti Road—whether project access could be limited to Asti Road and Santana Drive closed off to project traffic.

Response: The current Project does not include access onto Santana Drive except for an Emergency Vehicle Access that would not be open to the public.

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Comment 5.1.19 A Commissioner asked whether the DEIR could include more analysis of shuttle service between the project, airport, and downtown—and maximize use of pedestrian/bike paths.

Response: The analysis in Section 4.10 Transportation and Circulation does not discuss the potential for future shuttle bus service since the City does not currently offer such service and shuttle service is not planned. It is the judgment of the EIR consultant that requiring the City or the applicant to fund a shuttle service is premature. If the City or another transit agency establishes a shuttle service in the future, the applicant could be asked to contribute to the capital and ongoing costs.

Section 3.0 of the RDEIR describes public trails that are proposed to be provided.

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Comment 5.1.20 A Commissioner asked the DEIR to analyze the precedent set by rescinding the Williamson Act contract on the Silverado portion of the project.

Response: See Section 5.3 of the RDEIR that addresses treatment of the Williamson Act.

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Comment 5.1.21 A Commissioner asked whether the project might block the rail link.

Response: The currently proposed Project has been designed in a manner so as not to block or obstruct the planned SMART rail operation.

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Comment 5.1.22 A Commissioner said the DEIR should analyze the project's commercial center and its effect on downtown Cloverdale's vitality.

Response: The project has been revised to remove almost all of the commercial component, so there should be minimal impact to downtown businesses.

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Comment 5.1.23 A Commissioner said the DEIR should analyze project water use and toxic generation.

Response: See Section 5.13 of the RDEIR for a discussion of water supply impacts and mitigation with the current Project. Regarding potential for toxic runoff, Mitigation Measure 4.5-2(b), (c), and (d) on page 4.5-15 of the Original DEIR requires measures to minimize golf course runoff into nearby creeks.

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Comment 5.1.24 A Commissioner said the impacts of 1,000 new homes in the Reconfigured On-site alternative look bigger than the proposed project—questioning whether that's really the "environmentally superior" alternative.

Response: See Response to Comment 4.11.1.

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Comment 5.1.25 A Commissioner said the DEIR should assess school impacts.

Response: The Original DEIR analyzes the project's potential impacts on local schools in Section 4.13 Public Services under Impact and Mitigation Measure 4.13-6 on page 4.13-30.

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Comment R1.1.1 Improvements identified in Mitigation Measures 5.10-1 and 5.10-3 should be done before the project opens. The developer should work with the City on a schedule.

Response: All project-specific transportation circulation improvements recommended as part of the proposed AVR project will be required to be completed or bonded for prior to Project occupancy as part of the final Specific Plan as well as future Precise Development Plans.

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Comment R1.1.2 The traffic analysis says the intersection doesn't meet warrants for a traffic signal, so signalization isn't appropriate mitigation. Please also analyze a 3-way stop as a possible mitigation, and submit that analysis along with a copy of the signal warrant.

Response: With baseline plus proposed Project traffic, the S. Cloverdale Interchange Overcrossing/US Highway 101 northbound ramp intersection would meet the minimum peak hour volumes for signalization (MUTCD #3). The text in the traffic analysis incorrectly states that the intersection does not qualify for signalization with proposed project traffic. The text has been corrected to reflect this revised condition. Consequently, the recommended mitigation measure to signalize the intersection would be appropriate under baseline plus project conditions. See signal warrant evaluation sheet (attached).

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Comment R1.1.3 Under Scenario 2 (all four S. Cloverdale interchange intersections signalized), was traffic-signal coordination simulated to improve flow and reduce queues? Would lane improvements or roadway widening help, and by how much?

Response: Intersection Level-of-Service (LOS) calculations for the four study intersections on the S. Cloverdale Interchange Overcrossing under Scenario #2 (signalization only) were taken directly from the transportation analysis performed for the City's General Plan Update. (No year 2030 cumulative intersection LOS calculations were performed by the AVR Project consultant). Based on a review of these intersection LOS calculations, no roadway widening and/or lane improvements were analyzed as part of their work. However, discussions with the City's traffic consultant indicate that there would be vehicle storage problems and/or vehicle queuing problems with signalization and widening due the short distances between the intersections with year 2030 cumulative traffic volumes (source: Steve Weinberger, W-Trans, June 2008). This condition is confirmed in the Impacts and Mitigation Measures section of the City's General Plan Update (Traffic and Circulation). Under Impact 4.5 the section states (in part with signalization), "queue lengths at intersections along the South Interchange corridor would extend through adjacent intersections causing blockages, additional delays, and safety concerns. For these reasons the installation of multiple traffic signals is not considered to be a viable mitigation measure for the South Interchange corridor. In order for traffic signals to operate acceptably into the future, the overpass structure would need to be widened at substantial cost." Hence, the City's transportation consultant is recommending roundabouts (east and west) as the ultimate year 2030 cumulative improvement for the interchange.

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Comment R1.1.4 Under Scenario 3 (two roundabouts at the S. Cloverdale interchange), a Conceptual Approval Report is required for roundabouts on state highways. With the eastern roundabout, southbound Asti Road shows 85% capacity in the afternoon—may need more detailed analysis.

Response: Comment noted. The installation of roundabouts (east and west) at the S. Cloverdale Interchange is programmed as part of the City's implementation and policy goals in the recent General Plan Update. Implementation CE 2.1c states "Configure the south interchange with roundabouts to accommodate traffic levels related to the over-crossing, off-ramps, Asti Road and South Cloverdale Boulevard to achieve LOS D. Alternative designs may be considered if LOS D can be achieved by those designs." The General Plan's Impact and Mitigation section states "Consolidation of the intersections of Cloverdale Boulevard/South Interchange and US101 Southbound ramps/South Interchange into a single roundabout would operate acceptably at LOS D or better and have acceptable queuing during the peak hours. Similarly, consolidation of the intersections of US101 Northbound Ramps/South Interchange and Asti Road/South Interchange into a single roundabout would operate acceptably at LOS D or better and have acceptable queuing during both peak hours. (Note—this roundabout could be completed while maintaining the existing overpass structure)."

It is understood that specific design(s) for proposed east and west roundabouts at the South Cloverdale Interchange are in the very conceptual/preliminary design stage (if at all). At this time, roundabout LOS calculations have been conducted (Sidra software) as part of the City's General Plan Update. When roundabout design plans for the South Cloverdale Interchange are realized with cumulative development, a Conceptual Approval Report (CAR) will be submitted to Caltrans for full review.

At the proposed "S. Cloverdale Consolidated Roundabout East," the southbound Asti Road approach would be operating at more than 85% capacity during the PM peak hour as calculated by Sidra software. However, the southbound Asti Road approach would be operating at LOS D within the City's established significance criteria. When the future design of the roundabout is scrutinized and reviewed by all appropriate agencies, the southbound Asti Road approach may be altered or revised depending on final LOS calculations using 20-year design horizon for traffic projections.

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Comment R1.2.1 The Regional Board is concerned about development impacts degrading surface and groundwater quality. Impacts have to be fully mitigated.

Response: The City of Cloverdale is committed to full mitigation of all surface and groundwater quality impacts associated with the proposed Project.

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Comment R1.2.2 The RDEIR needs a more detailed map. The map on page 19 isn't detailed enough for thorough review. For example, page 19 says a blending pond will be on the eastern edge of the golf course and the site will have vegetated swales and other water-quality treatment before off-site discharge—but those details aren't shown. If they're not available now, an engineering report has to be submitted to the Board before any permits.

Response: Precise details of the blending pond and other water quality features of the project have not been submitted to the City of Cloverdale, however, a more detailed but still conceptual depiction of the pond is shown on Exhibit 5.2-1 of the RDEIR (page 45). Generally, the pond is proposed to be located in the easterly portion of the proposed golf course and a final design will be submitted to the City of Cloverdale as part of the Precise Development Plan for the golf course.

Mitigation Measure 4.5-1 contained in the Original DEIR and restated in the RDEIR document requires the Project developer to submit Storm water Pollution Prevention Plan for the overall Project as well as for individual project components, such as the Hotel, golf course and other components. As required prior to issuance of any permits by the Board, project details will be reviewed by the Board to ensure that full mitigation of water quality impacts is provided.

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Comment R1.2.3 Wastes associated with the former Louisiana-Pacific and Masonite facilities are still under Regional Board oversight for cleanup and groundwater remediation.

Response: This comment is noted and no further action is required.

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Comment R1.2.4 The RDEIR realigns golf-course fairways, hotel, resort, residential, and other areas—some of which are covered by Waste Discharge Requirements. More changes are likely before construction. Site work needs careful coordination with WDRs. Site Development Plans must be submitted to the Regional Board to make sure development doesn't conflict with cleanup operations. Some work may need written approval before construction.

Response: The RDEIR only analyses the revised Project as submitted by the applicant based on the most current Alexander Valley Resort Specific Plan. Pursuant to the current Specific Plan, all Project components will be required to obtain approvals of Precise Development Plan by the City of Cloverdale prior to actual construction. Board staff will be routed copies of the Precise Development Plans and final approval will be coordinated with Board for consistency with Waste Discharge Requirements for clean up of industrial waste. If required, the Project Developer must secure written approval from Board staff prior to commencing construction.

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Comment R1.2.5 The RDEIR says bioremediated soils have been approved for reuse in hardscape areas. Clarification: the Report of Waste Discharge isn't detailed enough yet to actually allow that reuse. More detail must be submitted before reuse. Also, reuse was proposed on a 12-acre site outside the project area—that needs a new, sufficiently detailed proposal for reuse of low-level petroleum hydrocarbon material.

Response: The City of Cloverdale defers to the Regional Board in terms of regulating the clean up and remediation of contaminated groundwater and soils and will cooperate to the fullest extent possible. Copies of Precise Development Plans, subdivision maps and other applications to the City will be routed to the Board for review and comment. The commenter is directed to Revised Mitigation Measure 5.6-2 contained in the RDEIR.

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Comment R1.2.6 International Paper is still investigating wood-treatment chemicals in shallow and bedrock groundwater. Once that's done, groundwater cleanup will start to restore beneficial use. Wood-treatment chemicals are present where the golf course will go—and irrigating the golf course could complicate cleanup.

Response: This comment is noted and the commenter's concern is addressed in Revised Mitigation Measure 5.6-2, which provides for Regional Water Board oversight and approval of irrigation on portions of the site impacted by the previous Masonite operation.

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Comment R1.2.7 Hazardous-materials mitigation should target a cumulative cancer risk of 1 in 1 million (10⁻⁶), not 1 in 100,000 as the document currently uses.

Response: Based on the above comment, Revised Mitigation Measure 5.6-3(a) is hereby revised:

Revised Mitigation Measure 5.6-3 (exposure to hazardous materials). The Specific Plan shall contain the following policies:

(a) A Human Health Risk Assessment (HHRA) and Risk Management Plan (RMP) shall be prepared by a qualified environmental professional, as approved by the City of Cloverdale. The HHRA shall evaluate potential health risks from petroleum hydrocarbons, metals, dioxins, furans, and wood preservation compounds proposed to remain in soils and groundwater following remedial activities at the project site and clean closure of the wood waste landfill. The RMP shall incorporate the findings of the HHRA and include measures to ensure that any potential added health risks to future site users as a result of hazardous materials are reduced to a cumulative risk of less than 10⁻⁵ (one in 100,000) one in a million (10⁻⁶) for carcinogens and a cumulative hazard index of 1.0 for non-carcinogens. The potential risks to human health in excess of these goals may be reduced either by remediation of the contaminated soils or groundwater. The HHRA and RMP shall be submitted to the Regional Water Quality Control Board for approval.

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Comment R1.2.8 The RDEIR says on-site water will be used if reclaimed water isn't available, with a Groundwater Hydraulic Report prepared as part of the first Precise Development Plan. That report needs to cover golf-course irrigation and impacts on contaminated groundwater migration and control.

Response: The commenter is directed to Page 33 of the RDEIR which states that Mitigation Measure 4.14-4 in the Original DEIR no longer applies to the Project, since the applicant now proposes the use of recycled secondary water for golf course irrigation. No Groundwater Hydraulic Report will need to be prepared.

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Comment R1.2.9 The RDEIR adequately updates the landfill remediation status. Work remains—including groundwater monitoring and final cleanup assessment. Before any final subdivision, grading, or utility trenching, final closure plans must be reviewed and approved by the Regional Board. Groundwater monitoring and post-closure cleanup may still be needed. All remaining stockpiled waste must go to a legal disposal point or have an approved reuse plan.

Response: In response to this comment, the Project Developer has indicated that a Clean Closure Report was submitted to the Regional Board staff in February 2009.

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Comment R1.2.10 The applicant plans to use municipal water for domestic use and treated wastewater for irrigation, with on-site water (potentially groundwater) as a backup. Groundwater contamination investigations are still ongoing. No new production wells should be drilled within the influence of those investigations until a comprehensive groundwater study is complete and all pollution sources are identified. The Final EIR should describe alternative water sources if on-site supplies are unavailable due to contamination.

Response: In response to this comment, Revised Mitigation Measure 5.6-2 is hereby modified to read as follows:

Revised Mitigation Measure 5.6-2 (remediation of hazardous materials). The Specific Plan shall contain the following policies:

(a) Prior to regulatory closure of the Cloverdale sawmill complex and former Masonite facility sites, written approval from the RWQCB shall be required for all construction and grading in those areas to ensure that proposed development activities do not interfere with investigation or remedial activities.

(b) Prior to regulatory closure of the Cloverdale sawmill complex and former Masonite facility sites, additional groundwater extraction at the site may be permitted only as determined by the Regional Water Quality Control Board. No new groundwater extraction wells shall be drilled or used unless approved by the Regional Water Quality Control Board.

(c) Prior to regulatory closure of the Cloverdale sawmill complex and former Masonite facility sites, irrigation in those areas with well water shall only be permitted as allowed by the Regional Water Quality Control Board.

The commenter is also directed to Revised Mitigation Measure 5.13-1 on page 119 of the RDEIR. In the event adequate treated wastewater is not available, this Revised Mitigation Measure requires that a water contingency plan be developed. At the present time, the City believes that adequate treated wastewater will be available and a Water Contingency Plan will not be needed.

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Comment R1.2.11 Both the eastern and western landfill footprints are still under groundwater investigation, with no completion date. All residential lots in the former wood-waste disposal area should be cleared of further soils investigation and deed-restricted from new water-supply wells until investigations are complete and Regional Board permits are met.

Response: In response to this comment, the Alexander Valley Resort Specific Plan will include a provision that all residential lots shall be deed restricted to prohibit grading operations and installation of groundwater extraction wells until groundwater investigations in the area are completed and all requirements of Regional Water Quality Control Board permit requirements have been fulfilled.

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Comment R1.2.12 What about the recycling plan for building demolition and operation under Mitigation 4.13-5? Does it apply to solid-waste collection and recycling? Will recycling facilities be on-site or off-site? The Final EIR should clarify and include collection-services plans.

Response: On-site collection and recycling facilities are proposed to be provided for the operation of all land uses envisioned in the Project. In addition, Mitigation Measure 4.13-5(c) contained in the Original DEIR requires preparation and implementation of a recycling plan for project demolition.

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Comment R1.2.13 The Final EIR must clearly identify all potential impacts to waters of the State. Avoid or minimize impacts where possible. If avoidance isn't feasible, compensatory mitigation is required—and the Board may require greater than 1:1 replacement. Replacement wetlands must be protected by conservation easements, deed restrictions, or similar legal mechanisms.

Response: The commenter is directed to Mitigation Measure 4.9-4 in the Original DEIR. This Mitigation Measure was incorrectly identified as modified in the RDEIR, but no modification is actually required. Mitigation Measure 4.9-4 therefore remains in full force and effect.

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Comment R1.2.14 Disconnect impervious surfaces from storm drains and route to vegetated areas. Post-construction impacts must be identified and mitigated. The RDEIR must list all proposed mitigations, including low-impact development measures (LID) for stormwater detention and treatment.

Response: The commenter is directed to Mitigation Measure 4.5-1 in the Original DEIR that requires the Project developer to prepare Stormwater Pollution Prevention Plans (SWPPP) for the entire Project site as well as for individual components of the Project as they are submitted for City review through the Precise Development Plan process. The City of Cloverdale believes that concerns of the commenters will be met through approval of each SWPPP.

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Comment R1.2.15 The Board supports recycled water use if groundwater and surface-water protections are in place. But the RDEIR doesn't include mitigations like an engineered pond liner and applying recycled water at agronomic rates. Identify other groundwater protections being proposed.

Response: The commenter is directed to Mitigation Measures 4.5-1 and 4.5-2 contained in the Original DEIR and Revised Mitigation Measure 5.6-2, which is modified in this document.

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Comment R1.2.16 A word appears to be missing in the last paragraph of page 23.

Response: The last sentence of the last paragraph is hereby amended to read:

"Impact 4.5-2 noted that the application of golf course fertilizers and pesticides could result in long-term water quality degradation in receiving waters. Also, leaching of nitrates and pesticides may cause chemicals to enter the groundwater. Mitigation Measure 4.5-2 requires the Specific Plan to incorporate a number of measures dealing with water quality aspects of the Project, including but not limited to the preparation of a Water Quality Management Plan, establishing buffer areas around creeks within the golf course, routing of golf course stormwater through vegetated areas, recycling of storm water runoff, preparation of an integrated pest management program to limit chemical application and limitations on fertilizer applications."

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Comment R1.2.17 Revised Mitigation Measure 5.6-1 is too general and seems focused on public-health impacts of recycled water. The RDEIR needs a similar mitigation that addresses meeting all applicable water-quality protection standards. Sections of the Specific Plan dealing with recycled water need to be part of the Report of Waste Discharge submittal.

Response: In response to this comment, Revised Mitigation Measure 5.6-1 is amended:

"The Specific Plan shall contain policies to ensure that State Department of Health Services, Regional Water Quality Control Board and other applicable standards and requirements are met prior to the use of recycled water on the site in order to protect the environment and with regard to minimize human contact with recycled water and provision of adequate public notice of the use of recycled water."

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Comment R1.2.18 Lists the permits the developer needs before construction: 401 Water Quality Certification, Waste Discharge Requirements, and General Construction Activity Stormwater Permit.

Response: This comment is noted and the Project developer will be advised of the need to obtain these permits.

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Comment R1.3.1 State regulations require public water systems to provide a Maximum Day Demand (MDD) capacity. For Cloverdale that's 2,850,000 gallons (a continuous 1,979 gpm over 24 hours). A 2006 inspection found the City didn't meet that. A permit was issued in October 2007 for a new well, conditioned on a late-summer 2008 capacity study to determine actual operating capacity during peak demand. The City is designing another well in early 2009. But the City is still deficient on source capacity and must show it can meet current and projected MDD.

Response: This comment is noted, however, it is primarily directed to the City of Cloverdale's municipal water system and not the Alexander Valley Resort Project, which is the subject of the RDEIR. According to the Cloverdale Public Works Department, the City is making all feasible efforts to comply with California Code of Regulations regarding supplying adequate domestic water.

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Comment R2.1.1 Lists Sonoma LAFCO's policies on agricultural lands and asks the RDEIR to evaluate impacts of adding the territory to the Cloverdale Sphere of Influence.

Response: This comment is noted. The City of Cloverdale believes the proposed sphere of influence amendment would be consistent with Sonoma LAFCO policies as follows:

A.1) Although the 15-acre territory proposed for inclusion into the City's sphere is classified as a farmland of local importance, the territory is no longer used for agricultural production and is discontinuous to other major agricultural production areas. The subject territory is surrounded by the City's wastewater treatment plant to the north, industrial uses on Santana Drive to the west, the Russian River to the east and former industrial land to the south, which is proposed for the AVR project. Therefore, the agricultural significance of the subject territory is considered low.

A.2) The subject territory is vacant and is surrounded by non-agricultural lands as detailed in A.1, above.

A.3) Proposed utilities and services for the proposed AVR Project have been sized to support land uses on the AVR site and would not facilitate urban development on adjacent lands.

A.4) Existing and planned land uses surrounding the subject territory are devoted to non-agricultural uses as described in A.1. The Russian River, located just east of the subject 15-acre territory serves as a barrier between the subject territory and major agricultural lands and operations located east of the Russian River.

A.5) The existing City of Cloverdale sphere of influence is located north, west and south of the subject territory and the inclusion of the 15-acre territory would represent a logical expansion of the City's sphere. The territory is not located within any other assigned sphere of influence of a water or sewer district or within the Urban Service Boundary of another full service jurisdiction. However, the Project site is located within the boundary of the Cloverdale Fire Protection District.

A.6) The subject territory is designated for urban uses in the existing Cloverdale General Plan.

B) The subject territory is not designated for long-term agricultural uses on in the County General Plan but is designated for urban uses in the existing Cloverdale General Plan.

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Comment R2.1.2 Is the 15-acre site commercially viable for a different vineyard or other agriculture? Provide supporting information.

Response: Based on information supplied by the Project applicant, when the property was purchased in February 2003, the vines had been removed and the land was not in agricultural production. The prior vineyard owners indicated that the vines were old and that the size and location of the property did not warrant replanting. Although the property could be suitable for agriculture of some type, it is small and discontiguous from other nearby larger agricultural production areas that limits the financial feasibility of continued production.

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Comment R2.1.3 Could the project preserve part of the 15-acre site as vineyard? A Napa County golf course has integrated vineyards with golf.

Response: The property was purchased by the current owner because a regulation 18-hole golf course would not fit on its adjacent property. The 15-acre property was needed to provide room for two of the 18 holes. However, the Applicant intends to plant replacement vineyards elsewhere on the property. Based on the preliminary golf course routing plan included in the draft Specific Plan, it would not be feasible to mix vineyards and the golf course on this 15-acre site.

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Comment R2.1.4 Summarizes LAFCO Williamson Act policy. Notes that the Williamson Act contract on the project site has been non-renewed with less than 5 years remaining—letting the applicant apply for a sphere amendment and annexation without Board action. The RDEIR wording should reflect this changed condition.

Response: The statement on Page 4.3-6 of the Original DEIR was accurate at the time of the issuance of the Original DEIR (July 2004). The RDEIR is hereby amended on Page 36 to add a paragraph to read: "The LAFCO staff has indicated that based on the approval of the 'Notice of Non-Renewal' on September 23, 2003, the Contract has less than a five-year remaining term, allowing the applicant to apply to LAFCO for a sphere amendment and annexation without action by the Board of Supervisors." This modification is also included in the Clarifications and modification section of this document.

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Comment R2.1.5 LAFCO has significant concerns about loss of prime agricultural lands and would require justification for including them in any annexation. The Commission may require placing the land in an agricultural easement.

Response: The RDEIR notes that the placement of urban uses on the 15-acre subject territory would be a significant impact (Revised Impact 5.3-1) and requires mitigation to compensate for this loss (see Revised Mitigation Measure 5.3-1). The Revised Mitigation Measure would require the Project to secure a conservation easement in the Sonoma County area, or make a financial contribution to a non-profit organization that preserves agricultural lands or provide an alternative mitigation for loss of prime agricultural land as approved by the Cloverdale City Manager.

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Comment R2.1.6 LAFCO staff thinks adequate fire protection has to be in place before the project is complete. If the Cloverdale Fire Protection District needs more equipment to serve the project, it must be on-site and operating before occupancy. LAFCO is concerned about staffing levels for a major hotel fire—needs more info on response times, equipment, mutual aid, and staffing.

Response: The City of Cloverdale concurs that an adequate level of fire protection must be provided during both construction and occupancy of all facilities on the Project site.

The RDEIR references Impact 4.13-5 contained in the Original DEIR. The Original DEIR contains information regarding staffing, facilities and mutual aid arrangements for the Cloverdale Fire Protection District. Mitigation Measure 4-13-5(b) requires the Project developer to a fair share financial contribution to the District for fire fighting equipment to protect buildings more than 27 feet in height if and when a fund is established by the City. The Development Agreement shall also provide for financial assistance for on-going staff costs.

In addition, all Precise Development Plans for component portions of the overall Project will be routed to the Fire District for their conditions of approval.

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Comment R2.1.7 LAFCO doesn't understand the comment that "property tax revenues for the development in the City should remain equivalent to the property tax revenues the fire district would share if the project remained in the County." Since the project site wouldn't be detached from the District, the District wouldn't lose any property tax.

Response: The commenter is correct, no change is anticipated to the amount of property tax revenues that would be received by the Cloverdale Fire Protection District before and after the annexation, should the annexation be approved by Sonoma LAFCO.

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Comment R2.2.1 The RDEIR appears to address what the Commission asked for in its Notice of Preparation response. The revised project doesn't substantially change the ALUC's earlier conclusions, the revised project remains consistent with the 2006 CALUP determination, and Revised Mitigation Measure 5.2-1 looks consistent with CALUP requirements.

Response: These comments are noted and no additional response is necessary.

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Comment R3.1.1 Fanelli is impressed with the project's scale and how well it addresses EIR concerns and neighbor concerns. The project would be a real win-win for Cloverdale, would improve quality of life, and is welcomed.

Response: These comments are noted and no additional response is necessary, since no environmental issues are raised.

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Comment R3.2.1 The previous project layout had residential bordering Reuser's industrial center—that would have been a Sandholm Lane situation, where industrial plans got abandoned because of nearby residents. The current AVR plan puts a driving range as the buffer, which is good. Reuser has also taken steps to reduce environmental impacts (new buildings and facilities). Concern: future developers may try to redevelop the driving range as residential. Cite the new General Plan policy to guarantee the buffer stays.

Response: Comments regarding buffering existing industrial uses to the north are noted. If approved, the currently proposed AVR Specific Plan will "lock in" the location of the driving range adjacent to industrial uses to the north. The only way to change this use would be through a Specific Plan Amendment, which requires notification of surrounding property owners and public hearings by the Cloverdale Planning Commission and City Council.

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Comment R3.2.2 The RDEIR calls Santana Drive "an unimproved two-lane roadway." Santana Drive is fully built to City standards with curb, gutter, and streetlights. It serves a 28-acre general industrial area north of the project site.

Response: The RDEIR is hereby corrected by reference to read as follows:

Page 64: "Santana Drive is located off of Asti Road north of South Cloverdale interchange overcrossing and the proposed project site. Extending east from Asti Road, Santana Drive is an unimproved improved roadway with curbs, gutters and streetlights two lane roadway."

Page 3 of the Traffic Analysis contained in Appendix 9.4 is also updated by reference to indicate that Santana Drive is an improved roadway.

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Comment R3.2.3 The industrial area north of the project averages 100 truck trips per day, mostly using the South Cloverdale Boulevard interchange to reach US 101. There's currently 60,000 sq ft of vacant industrial space for lease/sale on Santana Drive plus a 3-acre subdivision under development—both of which will add traffic, mostly using the South Cloverdale interchange.

Response: Traffic generated from the industrial area on Santana Drive has been included in the RDEIR analysis of traffic analyzed for the AVR Project. Adherence to Revised Mitigation Measure 5.10-1 to require the AVR Project developer to install a traffic signal at the South Cloverdale Boulevard/South Cloverdale Interchange will allow this intersection to operate successfully, even with the addition of industrial and AVR Project traffic. In addition, the AVR Project developer will install a traffic signal at the US 101 northbound ramp/US 101 overcrossing to allow future traffic to operate at acceptable levels.

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Comment R3.2.4 The RDEIR didn't account for a 44,000 sq ft industrial project under construction on Santana Drive, or the approved subdivision at 605 Santana Drive. The traffic study needs to be redone with that traffic.

Response: Based on discussions with the Project traffic engineer, adherence to Revised Mitigation Measures 5.10-1 and 5.10-2 will ensure that traffic generated by both the proposed AVR Project and from buildout of the industrial area on Santana Drive will not result in significant traffic impacts.

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Comment R3.3.1 Add the following topics to Section 1.0 (Project Summary) of the RDEIR: Plan and Policy Consistency, Geology/Soils/Seismicity, Cultural Resources, Biological Resources, and Noise.

Response: These five topic areas are hereby included by reference into Section 1, page 1-1, since they are addressed in the RDEIR.

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Comment R3.3.2 Several revised mitigation measures from the Draft Final EIR should be carried into the RDEIR.

Response: The Draft Final EIR was a document based on an earlier version of the proposed Project which has been replaced by the revised Project analyzed in the RDEIR. Therefore, it is not appropriate to reference the earlier Draft Final EIR as part of the RDEIR.

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Comment R3.3.3 In Mitigation Measure 4.5-2(g), change the second sentence to: "Preventative chemical use shall only be employed in limited situations where other methods will not be successful and only by a licensed technician."

Response: The City believes the original wording of Mitigation Measure 4.5-2(g) contained in the Original DEIR provides the Project applicant with sufficient flexibility to apply limited chemicals when there is a persistent pest problem and other non-chemical methods have failed.

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Comment R3.3.4 The "Status" of Impact 4.9-4 says "Mitigation Measure 4.9-4 is modified as set forth in Section 5.9 of the RDEIR"—but no such language actually exists in the RDEIR. The first bullet of Mitigation Measure 4.9-4(a) was modified in response to 2004 DEIR comments to read:

"The proposed site plan shall be revised to designate important jurisdictional wetlands and other 'High/Moderate Constraint' biological resources as Natural Resource Preserves, if the Planning Commission determines that the designation is feasible and consistent with the site plan."

The second bullet of Mitigation Measure 4.9-4(a) and subsections (b) and (c) [which is erroneously identified as a second subsection (b) in the Original DEIR] continue to apply.

Response: Although the City may have supported a revision to Original Mitigation Measure 4.9-2(a) to allow the Cloverdale Planning Commission to determine the status of wetlands on the Project Site, the City acknowledges that the designation of wetlands is a function of other biological regulatory agencies and not the Planning Commission. No change to the Original Mitigation Measure is therefore recommended.

The commenter is correct that the wording under "Status" on page 28 of the RDEIR is incorrect.

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Comment R3.3.5 On page 40, paragraph e: all of the "land uses included in the current Project" have been reviewed by the Sonoma County ALUC, but at different hearings. Suggest leaving the first sentence intact and adding: "since adoption of the City's Airport Master Plan, which provides for a 240-ft. extension of the existing runway to the north."

Response: The following text is added to the end of the third paragraph on page 40:

"Also, since circulation of the Original DEIR, the City of Cloverdale has adopted the Airport Master Plan, which provides for a 240-ft. extension of the existing runway to the north."

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Comment R3.3.6 On Revised Mitigation Measure 5.2-1: modify it to require compliance with applicable documents/rules/regulations and include a requirement that the applicant sign an avigation easement. Proposed building and structural heights have been submitted to the FAA.

Response: Inasmuch as the Sonoma County Airport Land Use Commission has reviewed the current text of Revised Mitigation Measure and found it acceptable (see Letter R2.2), no changes are proposed to the wording of this measure.

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Comment R3.3.7 Revised Mitigation Measure 5.3-2 only applies if the existing Williamson Act contract is rescinded.

Response: The comment is noted.

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Comment R3.3.8 Revise Mitigation Measure 5.5-2 wording to allow preventative chemicals in limited situations where other methods don't work.

Response: See Response to Comment 3.3.3.

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Comment R3.3.9 Revise Mitigation Measure 5.6-2 to: (a) drop "sawmill" and "sawmill complex" since there's no ongoing regulatory action at the former Masonite sawmill complex; and (b) eliminate or modify subsection (b) so it doesn't apply to pumping from the SB 610 Water Supply Assessment wells.

Response: In response to the comment, the words "Cloverdale sawmill complex" are removed from Revised Mitigation Measure 5.6-2. Regarding the second portion of the comment, that subsection "b" be removed or eliminated from Revised Mitigation Measure 5.6-2, such a revision to eliminate oversight of groundwater pumping from areas near the Masonite cleanup site by the Regional Board can only be granted by the Regional Water Board, regardless of any EIR language adopted by the City of Cloverdale. Also, refer to other changes in this mitigation measure as requested by the Regional Water Board in Comment R1.2.7.

Revised Mitigation Measure 5.6-2 (remediation of hazardous materials). The Specific Plan shall contain the following policies:

(a) Prior to regulatory closure of the Cloverdale sawmill complex and former Masonite facility sites, written approval from the RWQCB shall be required for all construction and grading in those areas to ensure that proposed development activities do not interfere with investigation or remedial activities.

(b) Prior to regulatory closure of the Cloverdale sawmill complex and former Masonite facility sites, additional groundwater extraction at the site may be permitted only as determined by the Regional Water Quality Control Board. No new groundwater extraction wells shall be drilled or used unless approved by the Regional Water Quality Control Board.

(c) Prior to regulatory closure of the Cloverdale sawmill complex and former Masonite facility sites, irrigation in those areas with well water shall only be permitted as allowed by the Regional Water Quality Control Board.

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Comment R3.3.10 Same as R3.3.4—restating the Mitigation Measure 4.9-4 modification.

Response: See Response to Comment 3.3.4.

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Comment R3.3.11 Impact 4.10-6 isn't applicable to the revised project, as stated on page 29 of the RDEIR.

Response: The commenter is correct and page 63 of the RDEIR is hereby modified to add Original Impact and Mitigation 4.10-6 to the Introduction section of the RDEIR. See the Clarification and Modification section of the document.

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Comment R3.3.12 Add to Revised Mitigation Measure 5.10-1: "The Project applicant would be eligible for reimbursement from the City for non-Project costs of installing the signal."

Response: The suggestion involves modifying a Revised Mitigation Measure to describe a non-CEQA issue. Generally, topics such as funding of project improvements are not included in an EIR, although the RDEIR did include some funding information only as a point of reference. Decisions regarding reimbursement for non-project infrastructure will be included in the Project Development Agreement, in any future condition of approval as part of a Precise Development Plan or subdivision map, or both.

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Comment R3.3.13 Add a new mitigation measure requiring the Specific Plan to reduce or minimize greenhouse gas emissions. Suggested measures are in the appendix's GHG analysis.

Response: This comment that a new mitigation measure be included in the RDEIR is acknowledged; however, page 103 of the RDEIR suggests that there would not be a significant contribution to greenhouse gas emissions from the Project as long as the items listed on page 103 are included in the Alexander Valley Resort Specific Plan. Therefore, these items must be included in the Specific Plan, even though no special mitigation measure is required, in order to ensure that no significant impact would occur.

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Comment R3.3.14 In Revised Mitigation 5.12-1, change "would" to "may"—noise levels above City standards haven't been demonstrated.

Response: This comment is acknowledged and the wording of Revised Impact 5.12-1 is revised:

"Revised Impact 5.12-1 (noise from airport operations). Some future Project residences would may be subject to noise levels in excess of the maximum City noise exposure level for residential land uses."

The above modification is also included in the Clarifications and Modifications section of this document.

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Comment R3.3.15 Revise Mitigation Measure 5.12-1 to cover noise from both airport and railroad operations.

Response: This comment is acknowledged and the wording of Revised Mitigation Measure 5.12-1 is revised:

"Revised Mitigation Measure 5.12-1 (noise from rail and airport operations). The Precise Development Plan for the Estate Residential portion of the project shall include a detailed Acoustic Study and recommend measures to reduce anticipated rail and airport noise, while ensuring that natural features such as oak woodlands are not affected by noise attenuation. The Acoustic Study shall recommend specific measures, such as sound barriers, walls, or trees, as needed to reduce CNEL levels for the exterior areas of Estate Residential homes to 65 dBA outside. The Acoustic Study shall also include a requirement that an avigation easement is granted by the property owner and a fair disclosure covenant is recorded for all homes constructed within the 55 to 65 dBA airport noise contours, as measured for existing and future runway extensions, if adopted by the ALUC."

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Comment R3.3.16 Table 1.1 (Summary of Recirculated Impacts and Mitigation Measures) is missing several items: duplicates Revised Mitigation Measure 5.4-1, missing 5.4-1(d), missing Revised Impact 5.5-2 and Revised Impact/Mitigation 5.6-1, duplicates Revised Mitigation Measure 5.10-4, missing Revised Mitigation Measure 5.1-10, and partially duplicates 5.13-2.

Response: This comment is acknowledged. See updated Table 1.1, included in the Changes and Modifications section of this document.

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Comment R3.4.1 Concerns about using treated water for on-site irrigation: it could expose people to pathogens and other contaminants not removed by secondary treatment. The Human Health Risk Assessment and Risk Management Plan must cover residents, not just workers—and should be developed jointly with the State Department of Public Health, Department of Health Services, the Regional Water Board, and Fish and Game.

Response: This comment is acknowledged. The RDEIR recognizes that use of treated water could pose a potentially significant health impact (see Revised Impact 5.6-1). This would be reduced to a less-than-significant level by adherence to Revised Mitigation Measure 5.6-1. This measure requires that State Department of Health Services requirements be met to minimize human contact with treated wastewater.

With respect to the Health Risk Assessment, Original Mitigation Measure 4.6-4 requires preparation of a Health Risk Assessment and Risk Management Plan and requires on-going water quality testing as required by State requirements. The Plans will be prepared by qualified environmental professionals who will consult and coordinate with appropriate local and state agencies as may be required by these agencies.

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Comment R3.4.2 Concerned about herbicides, pesticides, and fertilizers used to maintain turf—they pose a risk to the Russian River. Unclear how contaminated runoff will be discharged into the river. Long-term water-quality degradation will happen without a clear, carefully monitored plan. How will runoff from the golf course be contained? Who will monitor the holding ponds, and how will discharges be diluted? Recommend diluting treated wastewater before applying to turf and landscaping.

Response: With respect to minimizing use of herbicides, pesticides and fertilizers, the Project is required by Original Mitigation Measure 4.5-2(f) to prepare an Integrated Pest Management Plan to limit use of chemicals only as a last resort and to avoid discharging runoff of pesticides and nitrates into stormwater conveyances.

With respect to other water quality impacts as raised by the commenter, the Project will be required to complete a Stormwater Pollution Prevention Plan by Original Mitigation Measure 4.5-1 and a Water Quality Management Plan pursuant to Original Mitigation Measure 4.5-2 to minimize runoff of pollutants into the Russian River. Both plans shall be approved by the City of Cloverdale prior to commencement of grading operations. Both plans will comply with applicable local and state water quality standards.

With respect to dilution of treated water prior to application on the golf course, the draft Specific Plan includes a provision for an on-site blending pond, where treated wastewater would be blended with local groundwater prior to ground application.

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Comment R3.4.3 Which state or county agency will monitor construction and post-construction activities for water-quality degradation? Where will runoff from impervious surfaces (flowing west to east) be contained? Concern about excess vegetation in flow-control channels and the potential for unskilled maintenance to cause sediment and bank erosion.

Response: As indicated in the Response to Comment R3.4.3, the Project developer is required to submit both a Stormwater Pollution Prevention Plan and a Water Quality Management Plan. One or both of these documents will regulate the design of stormwater runoff into receiving waters to minimize water pollution. Both plans are required to meet Regional Water Quality Control standards in terms of including pollution reduction strategies and on-going monitoring and maintenance. Until such Plans are completed and approved by the City of Cloverdale, it is unknown where containment areas are to be located.

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Comment R3.4.4 Risk to salmon depends on amount and quality of discharge relative to river flow. The Sonoma County Water Agency monitors chemicals/pesticides into the river; SCWA is mandated by EPA, but the commenter is not impressed with how much supervision or commenting these agencies actually do. More input from those agencies is desired. The public trust doctrine applies—the benefits of the project must be weighed against protecting aquatic resources.

Response: The commenters concerns are noted; however, the level of monitoring of water quality by the SWCA is beyond the scope of the proposed Project. Comments regarding the merits of the proposed Project are also noted.

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Comment R3.5.1 The RDEIR says the project will use an estimated 509,700 gallons per day, with peak demand of 1,054,700 gallons. All of Cloverdale will feel this impact.

Response: This comment is acknowledged. The SB 610 Water Supply Analysis included in the RDEIR has indicated that a sufficient long-term water supply will be available to serve the proposed Project from the City's municipal supply so long as the golf course and other major open space areas are irrigated with treated wastewater and no domestic water.

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Comment R3.5.2 Cloverdale is building a new well, the government keeps cutting Russian River releases, and we're heading into another year of low rainfall—three years of drought in a row. A project this large makes no sense right now.

Response: This comment is acknowledged. As indicated in the Response to Comment 3.5.1, a long-term water supply assessment has been made of the proposed Project, which finds that there will be sufficient amount of water available so long as the City of Cloverdale continues to make planned expansions to the City's wells. The proposed Project has been envisioned on this site since adoption of the current General Plan in 1992.

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Comment R3.5.3 The City's wastewater treatment plant produces about 163,200 gallons per day for golf course and landscape irrigation. That isn't enough during much of the year. The commenter doesn't believe wastewater plant upgrades are coming any time soon—no funding.

Response: No upgrades are proposed to the City's wastewater treatment plant to serve the proposed Alexander Valley Resort Project—secondary treated water is proposed to be used. Also, limited irrigation of the golf course would be needed during winter and spring months of the year due to rainfall. When used in conjunction with pumped groundwater from existing on-site wells, the SB 610 water supply analysis indicates that sufficient water is anticipated to be available to serve the proposed Project.

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Comment R3.5.4 The commenter's well went dry for four months in summer 2008. Revised Impact 5.13-2 says the project could fall back on local well water for golf-course irrigation if reclaimed water is unavailable—that would be a disaster. The project's large pump would draw from the same aquifer that feeds neighboring wells. Those wells would definitely go dry in summer, and there's no telling how long this drought will last.

Response: The commenter correctly notes that Revised Impact 5.13-2 states that there could be a potentially significant impact in the event that treated wastewater is not available to serve the proposed golf course. However, in the event such treated wastewater is not available, the Project developer is required to prepare a contingency plan to ensure that sufficient water is available to serve the Project. However, the City of Cloverdale has agreed to supply treated wastewater, so the water contingency plan is viewed as a back up plan.

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Comment R3.5.5 The commenter doesn't believe the regional water source has the capacity or reserves for a project this large.

Response: The commenter's concerns about the water supply is noted. The City believes the Revised DEIR provides sufficient protection for their wells through the provision of treated wastewater for golf course irrigation and the requirement to prepare a water contingency plan should treated wastewater not be available.

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Comment R4.1.1 Bruce Reuser summarized his comment letter of January 9, 2009. Main points: the need for buffer areas between uses on the AVR site, the incorrect characterization of Santana Drive as "unimproved," and increased local traffic from projects under construction on his Santana Drive property.

Response: Responses to all of these comments are included in the Response to Comment R3.2.

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