LOST CANYONS Final EIR Volume IV of V

City of Simi Valley

Whiteface Speciﬁc Plan Amendment 6: LOST CANYONS Final EIR Volume IV of V

SCH #2008061111 Whiteface Specific Plan Amendment 6: Lost Canyons Draft EIR

Prepared for: City of Simi Valley Department of Environmental Services 2929 Tapo Canyon Road Simi Valley, California 93063

Prepared by:

IMPACT SCIENCES, INC. 803 Camarillo Springs Road, Suite A Camarillo, California 93012 (805)437-1900 Fax: (805)437-1901 November 2010

Would you make a June 2009 admin draft appendix CD label for Lost Canyons? Whiteface Specific Plan Amendment 6: Lost Canyons Final Environmental Impact Report Volume IV Comments on the Draft EIR and Responses SCH #2008061111

Prepared for:

City of Simi Valley Department of Environmental Sciences 2929 Tapo Canyon Road Simi Valley, California 93063

Prepared by:

Impact Sciences, Inc. 803 Camarillo Springs Road, Suite A Camarillo, California 93012

November 2010 TABLE OF CONTENTS

Volume I Section Page

I Introduction to the Final EIR...... I-1 1.0 Executive Summary ...... 1.0-1

2.0 Introduction ...... 2.0-1 3.0 Project Description ...... 3.0-1

4.0 Environmental Setting, Impacts, and Mitigations Measures ...... 4.0-1 4.1 Aesthetics...... 4.1-1 4.2 Air Quality...... 4.2-1 4.3 Biological Resources...... 4.3-1 4.4 Cultural Resources...... 4.4-1 4.5 Geology and Soils...... 4.5-1

Volume II 4.6 Hazards and Hazardous Materials...... 4.6-1 4.7 Hydrology and Water Quality...... 4.7-1 4.8 Land Use and Planning ...... 4.8-1 4.9 Mineral Resources...... 4.9-1 4.10 Noise ...... 4.10-1 4.11 Population and Housing...... 4.11-1 4.12 Public Services – Fire Protection ...... 4.12-1 4.13 Public Services – Law Enforcement...... 4.13-1 4.14 Public Services – Education ...... 4.14-1 4.15 Public Services – Parks and Recreation...... 4.15-1 4.16 Traffic and Transportation...... 4.16-1 4.17 Utilities – Water...... 4.17-1 4.18 Utilities – Wastewater...... 4.18-1 4.19 Utilities – Solid Waste...... 4.19-1 5.0 Growth-Inducing Impacts...... 5.0-1

6.0 Alternatives...... 6.0-1 7.0 Effects Found Not To Be Significant...... 7.0-1

8.0 List of Preparers, Organizations, and Persons Consulted...... 8.0-1 9.0 References...... 9.0-1

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Appendices

2.0 Whiteface Specific Plan, Notice of Preparation (NOP), Comments on the NOP Lost Canyons Draft Whiteface Specific Plan, Volume II, April 2008 Initial Study and Notice of Preparation (NOP) Responses to the NOP NOC Transmittal Form 4.0 Environmental Setting Summaries City of Simi Valley Department of Environmental Services, Planning Division, Summary of Residential Development, Second Quarter 2008 City of Simi Valley Department of Environmental Services, Planning Division, Summary of Industrial Development, Second Quarter 2008

4.2 Air Quality Reports and Health Risk Assessment URBEMIS2007 Combined Annual Construction Emissions Reports URBEMIS2007 Combined Annual Operational Emissions Reports URBEMIS2007 Combined Annual Greenhouse Gas Construction Emissions Reports URBEMIS2007 Detail Greenhouse Gas Report for Annual Area Source Unmitigated Emissions URBEMIS2007 Detail Greenhouse Gas Report for Annual Operational Unmitigated Emissions TDM Fund Calculation Health Risk Assessment

4.3 Biological Resources Reports Results of Focused California Gnatcatcher Surveys on the Lost Canyons Project Site; August 1, 2008 Biological Resource Assessment, Lost Canyons Project; June 26, 2007 Vireo bellii pusillus and Empidonax trailli extimus Presence-Absence Surveys; July 30, 2008 Jurisdictional Delineation of the Lost Canyons Project; August 31, 2007 Jurisdictional Delineation Letter of Transmittal; April 16, 2009 Jurisdictional Delineation Memorandum; March 31, 2009 Preliminary Tree Report, Lost Canyons Estates; August 16, 2007 Botanical Inventory and Rare Plant Survey of the Lost Canyons Development; June 21, 2007 4.4 Cultural Resources Reports Paleontological Assessment of the Lost Canyons Project, October 2006 Cultural Resources Archival Research for the Proposed Lost Canyons Preliminary Concept Plan, November 2006

Impact Sciences, Inc. ii Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 Appendices (continued)

4.5 Geological Studies and Responses Geological and Geotechnical Engineering Assessment, Lost Canyons Development; June 4, 2007 Response to Review Comments for Geological and Geotechnical Engineering Assessment; September 4, 2007 City of Simi Valley Department of Public Works Engineering Geology and Geotechnical Engineering Review; October 1, 2007 Geological and Geotechnical Engineering Assessment of the Proposed Water Tank, April 1, 2008 Waterworks District No. 8, Engineering Geology and Geotechnical Engineering Review on Proposed Water Tank; April 21, 2008 4.6 ENSR Environmental Site Assessment Update, Big Sky Country Club Golf Course; May 28 1999 4.7 Hydrology Reports GEOtivity Data Summary Report for Simi Valley; March 21, 2007 WRA Hydrology Study for Lost Canyons; August 27, 2007 WRA Tapo Canyon Flood Control Alternatives for Lost Canyons; October 8, 2007 WRA Dry Canyon Flood Control Alternatives for Lost Canyons; October 8, 2007 WRA Addendum to Tapo Canyon and Dry Canyon Flood Control Studies for Lost Canyons; March 12, 2008 WRA Addendum to Tapo Canyon and Dry Canyon Flood Control Studies for Lost Canyons; September 5, 2008 WRA Addendum to Tapo Canyon and Dry Canyon Flood Control Studies for Lost Canyons, April, 2, 2009 City of Simi Valley Status of Application Update; May 14, 2008 4.10 Noise Calculations Existing Conditions CNEL Existing plus Project CNEL Existing plus Project plus Cumulative CNEL Internal Circulation CNEL Lost Canyons Project Demolition Noise Estimates Lost Canyons Project Grading Noise Estimates Lost Canyons Project Construction Noise Estimates 4.16 Traffic Documentation Lost Canyons Project Traffic Impact Analysis; October 3, 2007 Tapo Canyon Road Analysis; April 9, 2009 Addendum to Lost Canyons Project Traffic Impact Analysis; March 30, 2010 4.17 Office of the Governor Press Release Regarding Water Shortage

4.18 Utilities– WRA Sewer Area Study for Lost Canyons

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Comments on the Draft EIR and Responses

Section Page 10.0 Introduction to Comments on Draft EIR...... 10.0-1

11.0 Response to Comments ...... 11.0-1 Letter 1 Allen Matkins Leck Gamble Mallory & Natsis LLP...... 11.0-2 Letter 2 County of Ventura, Resource Management Agency, Planning Division, Tricia Maier...... 11.0-53 Letter 3 Ventura County Air Pollution Control District...... 11.0-55 Letter 4 County of Ventura, Resource Management Agency, Planning Division, Christina Danko...... 11.0-57 Letter 5 County of Ventura, Resource Management Agency, Planning Division, Kari Finley ...... 11.0-62 Letter 6 County of Ventura, Public Works Agency, Transportation Department ...... 11.0-64 Letter 7 Ventura County Watershed Protection District, Water & Environmental Resources Division ...... 11.0-67 Letter 8 Ventura County Watershed Protection District, Advanced Planning Section...... 11.0-69 Letter 9 United States Department of Interior, Fish and Wildlife Service...... 11.0-71 Letter 10 JemStreet Properties, Inc...... 11.0-79 Letter 11 State of California, Governor’s Office of Planning and Research, State Clearinghouse, January 28, 2010...... 11.0-81 Letter 12 State of California, Governor’s Office of Planning and Research, State Clearinghouse, January 29, 2010...... 11.0-84 Letter 13 California Natural Resources Agency, Department of Fish and Game ...... 11.0-86 Letter 14 State of California, Santa Monica Mountains Conservancy...... 11.0-92

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Planning Commission and City Council Staff Reports and Resolutions

Section Page 12.0 Correspondence for Planning Commission...... 12.0-1

13.0 Staff Report for City Council...... 13.0-1 14.0 Minutes of xx City Council Hearing...... 14.0-1

15.0 Resolution xx...... 15.0-1 16.0 Second Reading xx ...... 16.0-1

17.0 Notice of Determination...... 17.0-1

Impact Sciences, Inc. v Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 10.0 INTRODUCTION TO COMMENTS ON DRAFT EIR

10.1 TITLE

This document is the Final Environmental Impact Report for the Whiteface Specific Plan Amendment No. 6: Lost Canyons Project, State Clearinghouse No. 2008061111.

10.2 PURPOSE

This Final Environmental Impact Report (EIR) assembles all the comments received on the information and analysis contained within the Draft EIR and responses by the City of Simi Valley to those comments. The intent of the Final EIR is to provide a forum to air and address comments pertaining to the analysis contained within the Draft EIR, and to provide an opportunity for clarifications, corrections, or minor revisions to the EIR, as needed.

The evaluation and response to public comments is an important part of the California Environmental Quality Act (CEQA) process as it allows the following: (1) the opportunity to review and comment on the methods of analysis contained with the EIR; (2) the ability to detect any omissions that may have occurred during the preparation of the EIR; (3) the ability to check for accuracy of the analysis contained within the EIR; (4) the ability to share expertise; and (5) the ability to discover public concerns.

10.3 PROCESS

Pursuant to the State CEQA Guidelines, Sections 15087, the Draft EIR was available for public comment during the 45-day review period December 14, 2009 through January 27, 2010. The City took the following steps to ensure that all interested parties had an opportunity to comment on the Draft EIR including:

 The City published the availability of the Draft EIR on December 14, 2009, in the Ventura County Star, and the Ventura County Clerk’s office.

 Copies of the Draft EIR were available at the Simi Valley Library and the Planning Counter at the City.

The 14 comment letters contained in this Final EIR represent 11 written comment letters received by the City during the 45-day public review period on the Draft EIR, and three comment letters received after close of the public review period for the Whiteface Specific Plan Amendment No. 6: Lost Canyons project.

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Pursuant to Section 15088 of the State CEQA Guidelines, as amended, the City of Simi Valley, as the Lead Agency for the project, has evaluated and prepared written response to all comments received on the Draft EIR. The written response shall describe the disposition of significant environmental issues raised.

10.4 CONTENTS OF THE FINAL EIR

Pursuant to Section 15132 of the State CEQA Guidelines, this document consists of the following:

Volumes I and II – the Draft EIR with revisions shown in strikeout/underline format

Volume III – the Draft EIR Appendices

Volume IV – Comments on the Draft EIR and Responses, which consists of

1. a list of persons, organizations, and public agencies commenting on the Draft EIR

2. copies of all comment letters that include comments and recommendations received on the Draft EIR and

3. responses to significant environmental points raised in the review and consultation process concerning the Draft EIR

Volumes V – the Planning Commission and City Council Staff Reports and Resolutions

Impact Sciences, Inc. 10.0-2 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 11.0 RESPONSE TO COMMENTS

11.1 INTRODUCTION

This section of the Final EIR presents the comment letters received regarding the Draft EIR or Specific Plan and responses to those comments. Each comment letter is followed by the corresponding response(s). Within each comment letter, distinct issues or points are identified by a comment number, and the following responses are numbered accordingly.

11.2 COMMENTS RECEIVED

The following public agencies, organizations, and interested parties submitted written comments on the Draft EIR:

1. Allen Matkins Leck Gamble Mallory & Natsis LLP, January 27, 2010

2. County of Ventura, Resource Management Agency, Planning Division, Tricia Maier, January 27, 2010

3. Ventura County Air Pollution Control District, January 25, 2010

4. County of Ventura, Resource Management Agency, Planning Division, Christina Danko, January 25, 2010

5. County of Ventura, Resource Management Agency, Planning Division, Kari Finley, January 22, 2010

6. County of Ventura, Public Works Agency, Transportation Department, January 14, 2010

7. Ventura County Watershed Protection District, Water & Environmental Resources Division, January 7, 2010

8. Ventura County Watershed Protection District, Advanced Planning Section, January 7, 2010

9. United States Department of Interior, Fish and Wildlife Service, January 27, 2010

10. JemStreet Properties, Inc., January 25, 2010

11. State of California, Governor’s Office of Planning and Research, State Clearinghouse, January 28, 2010

12. State of California, Governor’s Office of Planning and Research, State Clearinghouse, January 29, 2010;

13. California Natural Resources Agency, Department of Fish and Game, January 29, 2010

14. State of California, Santa Monica Mountains Conservancy, February 11, 2010

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Letter Number 1. Allen Matkins Leck Gamble Mallory & Natsis LLP, dated January 27, 2010 Response 1-1

The following text has been added Section 1.0, Executive Summary:

“All homes are accessed via internal private roadways with a gated access point located at the proposed project’s Lost Canyons Drive main entry.”

Response 1-2

Comment indicating that the applicant, Lost Canyons LLC (LCLLC), agrees with the Draft EIR and that LCLLC may enter into a development agreement with the City as a discretionary action is noted.

Response 1-3

Comment indicating that the applicant would provide a possible connection to the Whiteface escarpment through the proposed project’s internal trail system, as Objective 14 of the Specific Plan, is noted. The proposed project does not provide a trail connection to the existing nearby 6.5 acre park; should a connection be desired, such a connection would need to be provided by the property owners of the parcel(s) of the area between the nearby 6.5-acre park and the project boundary. No further response is required.

Response 1-4

As described in Section 4.16, Traffic and Transportation, the proposed 2-lane configuration of Tapo Canyon Road would potentially have fewer impacts to Tapo Creek and the adjacent hillsides then that of the General Plan identified four-lane configuration. In addition, the two-lane configuration would contribute to a “sense” of a rural community as described in the proposed project’s objectives. The comment is noted and no further response is required.

Response 1-5

The text has been amended to Section 1.0, Executive Summary as follows:

“The applicant has agreed to set aside land, at a minimum, to the Ventura County Watershed Protection District (VCWPD) for a regional detention basin just north of Lost Canyons Drive bridge and adjacent to the west of Tapo Canyon Road in the Tapo Canyon watershed.”

As a result of the proposed deletion of Dry Canyon Regional Detention Basin from the City’s Master Plan of Drainage, the project will be required to participate in Tapo and Dry Canyon Regional facilities, the extent of which will be determined with the Tentative Map review process. Changes to the EIR will be made to clarify this.

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The comment that implementation of the proposed project would not generate a significant impact with respect to water quality is consistent with the EIR and is noted.

Response 1-6

The comment indicates that Section 1.0, Executive Summary is correct and that impacts to regional detention basins and certain downstream improvements identified in the Draft EIR are less than significant. The comment further notes that the proposed project will comply with the applicable requirements of the City’s Master Plan of Drainage and Ventura County Watershed Protection District (VCWPD). The comment is noted and no further response is needed. However, certain downstream drainage improvements identified in the Project’s Preliminary Drainage Studies provide alternatives, which upon City-acceptance, allow the Dry Canyon Regional Detention Basin site to be developed as proposed with this project. As a result of the proposed deletion of Dry Canyon Regional Detention Basin from the City’s Master Plan of Drainage, the project will be required to participate in Tapo and Dry Canyon Regional facilities, the extent of which will be determined with the Tentative Map review process.

Response 1-7

The City’s Master Plan of Drainage identifies a general location for a future regional detention basin in Dry Canyon. It should be noted that while this regional facility is identified in the City’s current Master Plan of Drainage it is not proposed as part of this project. A hydrology study was prepared for the proposed project that considered the potential effect of the proposed project and also reviewed the more general analysis and information in the City’s Master Plan of Drainage to determine the consistency of the project. The project Project Preliminary Drainage Studieshydrology study concluded the regional drainage need could be met with a detention facility in Tapo Canyon and identified that the regional detention basin in Dry Canyon as one of five Dry Canyon drainage alternativesidentified in the City’s master plan was not required. The drainage impacts from the proposed project can be mitigated accordingly and the future planned regional facility is not a part of the project. As a result of the proposed deletion of Dry Canyon Regional Detention Basin from the City’s Master Plan of Drainage, the project will be required to participate in Tapo and Dry Canyon Regional facilities, the extent of which will be determined with the Tentative Map review process.

The following text was added to clarify consistency of the Draft EIR on page 4.7-19:

“The City’s Master Plan of Drainage has designated a location of a regional detention basin in Dry Canyon. The proposed project would amend the Master Plan of Drainage through the dedication of land, in accordance with Ventura County Watershed Protection District (VCWPD) standards, for a regional detention basin in Tapo Canyon. The proposed project has proposed two potential alternatives for the

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Tapo Canyon watershed and five potential alternatives for the Dry Canyon watershed to handle the runoff from the drainage needs of these watersheds. Both All alternatives were compared by the benefit- to-cost ratio, a number that depicts the cost of damages prevented or benefits obtained using the average cost of damages prevented (the higher the number the higher return).”

Response 1-8

The comment states that the Dry and Tapo Canyons hydrology studies and subsequent addendums were developed for alternatives to the Dry Canyon detention basin as designated on the City’s Master Plan of Drainage. It should be noted that the studies and analysis were incorporated into the hydrology analysis and the discussion has been clarified above in Response 1-7.

The proposed project’s storm drainage system has been designed with two objectives: (1) meet storm drainage design requirements of the City of Simi Valley and VCWPD, and (2) minimize impacts to the existing channels and support the natural vegetation and wildlife. (As stated on page III-43 of the Specific Plan.)

The proposed project consists of two independent watersheds, Tapo Canyon and Dry Canyon. Tapo Canyon watershed is generally located on the east side of the project site and initiates beyond the project’s northern boundary. This watershed includes approximately 13,182 acres at the confluence with Arroyo Simi and ultimately drains to Arroyo Simi. Dry Canyon represents the second watershed and is generally located on the western edge of the project site and includes approximately 2,234 acres at the confluence with Arroyo Simi. The Dry Canyon watershed initiates above the northern boundary of the project site and ultimately flows to Arroyo Simi. In addition to the land provided for the location of a regional detention facility, the proposed Specific Plan would implement on-site drainage improvements.

The proposed project will be required to comply with the drainage requirements of the City of Simi Valley, the VCWPD, and applicable Regulatory Agency(s), such as the Los Angeles Regional Water Quality Control Board (LARWQCB) and the National Pollution Discharge Elimination System (NPDES) requirements. The subsequent Tentative Tract Map (TTM), Planned Development Permit, and other related approvals will address the project level-specific measures to be incorporated.

In general, Stormwater Quality Management Plans (SQMP) will be developed to meet NPDES requirements. Best Management Practices will be developed based upon the Ventura Countywide Stormwater Management Program (VCSMP) and the City of Simi Valley Water Quality Permit to reduce and control the impacts of stormwater runoff pollution and erosion upon the receiving waters. An objective of the proposed project’s developed areas is to retain runoff on site to the maximum extent feasible. Stormwater treatment systems, including detention basins and structural stormwater treatment

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systems will be designed and constructed for water quality treatment. A number of debris basins are proposed throughout the project site to collect debris produced upstream of the developed area and to meet the proposed project’s requirements for debris mitigation. These measures are being evaluated based on the limits of the project’s disturbance and are not intended to address regional debris mitigation.

Extended detention facilities are proposed to meet flood control requirements for the proposed project’s developed areas. These facilities will consist of primarily off channel drainage facilities intended to mitigate the incremental runoff contributed by the proposed development and meet the specific impacts of the developed areas.

Additionally, the City of Simi Valley Master Plan of Drainage currently identifies a regional detention basin in the Dry Canyon Watershed. Based on discussions with the City and VCWPD, the preliminary location of the proposed Tapo Canyon basin is proposed north of the Lost Canyons Drive bridge and west of Tapo Canyon Road. Any requirement to dedicate the land for the Tapo Canyon Regional Basin will be in accordance with the standards of the VCWPD. As a result of the proposed deletion of Dry Canyon Regional Detention Basin from the City’s Master Plan of Drainage, the project will be required to participate in Tapo and Dry Canyon Regional facilities, the extent of which will be determined with the Tentative Map review process.Dry Canyon Regional Detention Basin will be removed from the City of Simi Valley Master Plan of Drainage and replaced with a regional detention basin to be located within Tapo Canyon as shown on Figure 3.0-6, Proposed Lost Canyons Conceptual Land Use Plan.

Response 1-9

The project’s preliminary drainage studies identify There are currently five alternatives for flood control in Dry Canyon. If the regional basin is determined by the City not to be the preferred drainage alternative, the basin site can be developed as proposed by this projectthat would be implemented by the VCWPD to provide justification for amending the City’s Master Plan of Drainage. As a result of the proposed deletion of Dry Canyon Regional Detention Basin from the City’s Master Plan of Drainage, the project will be required to participate in Tapo and Dry Canyon Regional facilities, the extent of which will be determined with the Tentative Map review process. Implementation of the proposed Specific Plan would provide on-site control, as further described above in Response 1-8, to minimize flooding impacts according to the VCWPD.

The EIR text has been revised to clarify that the proposed project would set aside land for the VCWPD to be used as the site for a regional detention basin. See Response 1-7 and 1-8 above.

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The language “There are currently … in order for proposed project to proceed…” has been deleted in Revised Draft EIR. The revised language is “The Preliminary Drainage Studies identify five alternatives for flood control in Dry Canyon that would be implemented by the VCWPD … to provide justification for amending the City’s Master Plan of Drainage.”

Response 1-10

The Project’s Preliminary Drainage Studies’ analysis of the Tapo Canyon and Dry Canyon Flood Control Alternatives was provided to show the most effective regional flood control facilities. If the Dry Canyon regional detention basin is determined by the City not to be the preferred drainage alternative, the basin site can be developed as proposed by this project. As a result of the proposed deletion of Dry Canyon Regional Detention Basin from the City’s Master Plan of Drainage, the project will be required to participate in Tapo and Dry Canyon Regional facilities, the extent of which will be determined with the Tentative Map review process. for the potential amendment of the City’s Master Plan of Drainage. The proposed project would not be responsible for the construction of the regional detention basin or the downstream improvements, As clarification, the following text was added:

”As proposed the project would also, at a minimum, include land for a regional detention basin, debris basins, channel improvements, and storm drain inlets, the preliminary design and construction of which will be evaluated during tentative tract map review and/or through a Planned Development Permit.”

It should be noted that the proposed project would construct on-site drainage facilities, as specified by the SQMPs, to meet NPDES requirements and VCWPD as described in Response 1-8 above.

Response 1-11

The comment notes that the proposed project does not result in significant impacts to water quality and will decrease surface water runoff from the project site when compared to existing conditions with the 100-year storm event. The proposed project includes on-site, not watershed wide controls, improvements. The proposed project will provide on-site project related drainage improvements in compliance with applicable requirements of the City’s Master Plan of Drainage and VCWPD.

The following text was added to the Draft EIR to identify that the project would utilize on-site stormwater control:

“The flood control alternatives provided for the amendment to the City’s Master Plan of Drainage will be created to comply with provisions outlined in the NPDES permit for Ventura County.

The stormwater quality-control design for the proposed project utilizes on-site control (see Detention Basin). On-site control involves the construction of individual treatment facilities. These facilities will be

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used to collect the amount of sediment that travels with the erosion of the topography from normal precipitation. The Specific Plan hydrology report shows 25 proposed debris basins that would be able to collect 8,515 cy of sediment. However, the locations, sizes, and the number of debris basins are still in the conceptual phase; the proposed locations can be seen in Appendix 4.7.”

Response 1-12

The comment notes that the Project’s Preliminary Drainage Studies’ review of downstream Dry and Tapo Canyon drainage improvements were prepared and provided to the VCWPD and the City to facilitate the removal of the Dry Canyon regional basin for a more efficient regional facility. The Preliminary Drainage Studyies for the proposed project includes drainage facilities necessary to meet the requirements of the City of Simi Valley Master Plan of Drainage, the Ventura County Watershed Protection District, and other applicable regulatory agencies.

In addition, NPDES facilities will be provided to ensure the quality of runoff water. NPDES permits will be obtained for both the construction and ultimate development phases. Best Management Practices (BMPs) will be incorporated into the development and final design of drainage facilities should be proposed and reviewed as part of subsequent plan approvals (e.g., Final Tract Maps). (As described on page III-20 of the Specific Plan.)

The EIR text has been revised as previously noted; the comment is noted and no further response is required.

Response 1-13

See Response 1-12 above regarding the potential impacts that would alter the existing drainage pattern of the site.

Response 1-14

The comment notes the requirements of dedicating land for a regional detention center. The mitigation measure has been changed to include the following language: “The project owner shall dedicate land to VCWPD for development of the Tapo Canyon regional detention basin, and participate in on-site and off-site Dry and Tapo Canyon Watershed regional drainage facilities resulting from the proposed deletion of the Dry Canyon Regional Detention Basin from the City’s Master Plan of Drainage as determined with the Tentative Tract Map approval process.” The comment is correct is noting that there are no significant impacts to water quality as the proposed on-site drainage improvements would result in less than significant impacts. Language regarding water quality has been removed.

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Response 1-15

See Responses 1-7 through 1-14 in regards to the discussion of the drainage requirements for the project. The project shall dedicate land to VCWPD for development of the Tapo Canyon regional detention basin, and participate in on-site and off-site Dry and Tapo Canyon Watershed regional drainage facilities resulting form the proposed deletion of the Dry Canyon Regional Detention Basin from the City’s Master Plan of Drainage as determined with the Tentative Tract Map approval process. Any such improvements would be constructed to the meet the standards of the City of Simi Valley, VCWPD, and applicable regulatory agencies. Drainage improvements will be designed and constructed to proportionately mitigate flooding impacts to the existing watersheds from the project. As previously noted, there are no significant impacts to water quality as the proposed on-site drainage improvements would result in less than significant impacts and no mitigation for such is required.

Response 1-16

The proposed project would increase the amount of impervious land and would increase the proposed surface water runoff for each of the developed areas. To adequately handle existing and additional surface water runoff, the project The project shall dedicate land to VCWPD for development of the Tapo Canyon regional detention basin, and participate in on-site and off-site Dry and Tapo Canyon Watershed regional drainage facilities resulting form from the proposed deletion of the Dry Canyon Regional Detention Basin from the City’s Master Plan of Drainage as determined with the Tentative Tract Map approval process. Any such improvements would comply with the City’s Drainage Guidelines and City’s Master Plan of Drainage. In addition, the drainage improvements would also provide for treatment to meet the NPDES discharge requirements of the VCWPD. Impacts would be less than significant. This information has been inserted on page 4.7-38 of the EIR to clarify that the proposed project would not need construction of the regional detention basin to mitigate potential off-site runoff impacts which would exceed existing drainage facilities.

Response 1-17

The proposed project would increase the amount of impervious land and would increase the proposed surface water runoff for each of the developed areas. To adequately handle existing and additional surface water runoff, the project The project shall dedicate land to VCWPD for development of the Tapo Canyon regional detention basin, and participate in on-site and off-site Dry and Tapo Canyon Watershed regional drainage facilities resulting form from the proposed deletion of the Dry Canyon Regional Detention Basin from the City’s Master Plan of Drainage as determined with the Tentative Tract Map approval process. As previously noted, there are no significant impacts to water quality as the proposed on-site drainage improvements would result in less than significant impacts and no mitigation for such is required.

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Response 1-18

See Response 1-17 above.

Response 1-19

The comment states that the proposed setback should be from “active” oil wells. This is a request by the applicant and does not conform to existing standard for “active” oil wells. The project proposes 50-foot setbacks from active oil wells. The project proposes 50-foot setbacks from active oil wells; regulations established by the California Public Resources Code limit the location of well sites within a drill site to 100 feet from the border. The setback would not apply if the drill site agreement is expired or terminated.

The proposed Specific Plan amendment would supersede existing City Development Code requirements on the minimum distance between residences and oil wells. Depending on the location of existing or future wells within these drill sites, residences may be developed closer to wells than currently allowed by the City’s Development Code with regard to setbacks from wells. However, to place development adjacent to or over abandoned oil and gas wells, the project is subject to, and would be required to comply with DOGGR’s Well Review Program.

The comment is noted and no changes have been made to the EIR.

Response 1-20

Although Well No. 35-1 is not currently active, as it has not been fully abandoned and plugged, the potential exists for it to become active in the future. As such, it would then be classified as a “critical well.”

While the Specific Plan may permit development of residential units in proximity to oil wells, the EIR provides mitigation to assure for the public health and welfare.

As the comment notes, a Conditional Use Permits (CUP) would be required for operating oil wells within the project site if residential development exists.

Response 1-21

The word “gate” has been included has been added to the Section 1.0, Executive Summary, of the Revised text for the Draft EIR.

Response 1-22

The commenter has suggested the revision of text to clarify that a traffic signal is recommended at Lost Canyons Golf Club and Lost Canyons Drive. However, the text in the EIR is clear that the traffic signal at the main project entrance with Lost Canyons Drive is only recommended and not required.

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Response 1-23

The comment has been noted.

Response 1-24

The following revisions to the mitigation measure have been made to Section 1.0, Executive Summary and in Section 4.1, Aesthetics:

“Graded slopes should reuse topsoil and be planted and stabilized with non-toxic stabilizers in compliance with City-approved landscape, irrigation, and maintenance requirements.”

Additionally, the use and terminology of “purple pipe” will remain in the text based on the uncertainty anticipation of the use of reclaimed water for the project site in the future, as stated in Section 4.17, Utilities – Water.

Response 1-25

The following text has been added in Section 1.0 and Section 4.1:

“The Specific Plan has design guidelines that establish architectural styles and elements, building materials, and colors for the proposed houses that fit in with the surrounding landscape; further described in detail in the Specific Plan Design Guidelines Section 4.0 Architecture. Exterior building and roofing materials shall be natural in appearance; bright or contrasting colors shall not be used.”

Response 1-26

Section 3.3(C) of Appendix A of the Specific Plan Design Guidelines (March 2009 version) mentions the range and varying size of trees to be used in the common sloped areas. The correct replacement tree size should be “15-gallons.” The text has been deleted in Section 4.1 to remain consistent with Section 1.0.

Response 1-27

The commenter has requested clarification of Mitigation Measure 4.3-7, a measure which includes provisions for the minimization of human activities that may impact wildlife and their habitat in open space areas, to allow consideration of new technology electric fence options and the play area amenities within the open space areas. The mitigation measure as it was written in the Draft EIR does not preclude the use of electric fences as long as the function to prevent domestic animals from entering open space habitat areas is achieved. Nonetheless, the mitigation measure has been modified to allow such electric fences.

The provision that CC&Rs prohibit the construction of tree houses is designed to eliminate the potential for impacts within the natural habitat areas of wildlife use of the native biological resources. However,

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the measure has been modified to prohibit tree houses in native oak and riparian trees or any other tree that may be used by raptors for nesting.

The revised mitigation measure is as follows:

4.3-7 Pets and other domestic animals shall be prohibited from the remaining open space areas and in any revegetation areas on the project site unless restrained by leash and accompanied at all times by the owner or responsible party. Fencing of sufficient height and design or landscaping acceptable to the City shall be constructed between the edge of development and the natural areas to prevent domestic animals from entering open space habitat areas, including use of new technology such as electric fences. Human access into the open space areas shall only occur in designated areas such as trails or along the perimeter of the habitats. Prohibitions against human and domestic animal use in sensitive habitat areas shall be established by ordinance and/or CC&Rs. The CC&Rs shall also state that tree houses shall not be constructed within native oak or riparian habitat trees, or any other trees known to be used by raptors for nesting. Interpretative signs shall be constructed and placed in appropriate areas, as determined by a qualified biologist, that explain the sensitivity of natural habitats and the need to minimize impacts on these adjacent areas. The project applicant shall be responsible for installation of interpretive signs and fencing.

Response 1-28

The commenter asks whether a phrase is missing in the last sentence of Mitigation Measure 4.3-8. The phrase “to include at a minimum” has been deleted from the mitigation measure.

The revised mitigation measure is as follows:

4.3-8 Landscape plans within common areas of the project shall be reviewed by a qualified botanist, who shall recommend appropriate provisions to prevent invasive plant species from colonizing remaining natural areas. These provisions may include the following: (a) review and screening of proposed plant palette and planting plans to identify and avoid the use of invasive species; (b) weed removal during the initial planting of landscaped areas; and (c) the monitoring for and removal of weeds and other invasive plant species as part of ongoing landscape maintenance activities. The frequency and method of monitoring for invasive species shall be determined by a qualified botanist. In addition, residents shall be encouraged to plant non-invasive plant species within private

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yards. A list of plants to avoid shall be developed by a qualified botanist, to include at a minimum and distributed by the homeowners association or included in the CC&Rs.

Response 1-29

The commenter requests that Mitigation Measure 4.3-9 concerning lighting into the open space areas be revised to allow the project proponent to establish acceptable parameters consistent with the Specific Plan Design Guidelines, such as uplighting of trees. The lighting limitations are specific to the interface from the developed areas to the natural areas, where uplighting of trees would be inappropriate. Uplighting of trees within landscape areas away from the natural areas is not precluded by this mitigation measure. The mitigation measure has been modified to clarify that some uplighting of trees may be used in areas not along the perimeter of the natural areas.

The revised mitigation measure is as follows:

4.3-9 All lighting along the perimeter of natural areas, particularly street lamps, shall be downcast luminaries and shall be shielded and oriented in a manner that will prevent spillage or glare into the remaining natural and open space areas. All security lighting within common areas will be controlled by motion detectors. Acceptable lighting parameters will be included in the Specific Plan Design Guidelines and will allow such features of uplighting of trees in areas not along the perimeter of the natural areas.

Response 1-30

The comment requests modification of Mitigation Measure 4.3-28 as the Corridors specified no longer possess the same linkage characteristics as they did in 1993 when they were identified by an Envicom study. The mitigation measure as written is identical to the measure of the 1995 certified Supplement to the Final Subsequent EIR for the Whiteface Specific Plan. If three of the four corridors identified (Corridors C, E, and F) are already present as designed or could be with minor adjustment, then compliance with the mitigation measure would be possible by the submittal of “As-Built” plans indicating the nature of these corridors consistent with the design parameters. These corridors are corroborated in the Draft EIR for Corridor C.

The following is the descriptions of the corridors from the 1995 certified Supplement to the Final Subsequent EIR and in the Draft EIR (see revised Draft EIR and new Figure 4.3-4 “Existing Linkage Relationships of 640 Acre Parcel” from the 1993 Envicom study):

Corridor B: This Corridor consists of the largest tributary into Dry Canyon from the open space dedication, with excellent connections from Dry Canyon into Sand, Brea and Alamos canyons. All of

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these canyons eventually connect with the Oak Ridge/Big Mountain Linkage to the north. Accommodation of wildlife movement at Linkage B should be incorporated into the project design. Recommendations of the original Envicom Corporation report on features necessary to preserve wildlife movement should be reviewed and followed where feasible. Where features appear infeasible, such as underpasses, other recommendations as to fencing, at grade road crossings, warning signs, speed limits and design limits on residential lot locations should be observed and incorporated into the design.

Corridor C: Corridor C would extend northwest from the open space dedication area to the confluence of Oak and Dry canyons. There is ample opportunity for wildlife to enter Oak Canyon at this location and continue northwest into the Oak Ridge/Big Mountain Linkage north of Whiteface. Alternatively, animals entering Dry Canyon drainage can continue south, utilizing Dry Canyon’s resources, or they can continue west from Dry Canyon through numerous secondary pathways and gain access to other significant habitat areas farther west.

Corridor E: In the northeast section of the 640-acre open space dedication is an area of alternating ridges and shallow canyons, which provide wildlife access to and from one of the main tributaries to Tapo Canyon. The southwestern boundary of this zone is formed by a steep, but passable ridgeline that separates the movement zone from a tributary to Tapo Canyon which originates within the open space area. The significance of Corridor E is its proximity to high quality habitat within the open space dedication area and access to varied habitats in the larger Tapo Canyon tributary to the northeast, as well as further access to the core habitat of the Santa Susan Mountains.

Corridor F: The only drainage that completes most of its course within in the open space areas is located in the eastern portion of the area and continues southeast to its confluence with Tapo Canyon. It is separated from Corridor E by the steep ridgeline which forms that region’s southwestern boundary. Corridor F is significant because it contains numerous oak woodlands, rocky outcrops, and dense vegetative cover. It also contains the topography necessary to promote wildlife movement (two ridges divided by a canyon bottom). It has direct connection to Tapo Canyon; a feature which does not occur elsewhere in the open space area. In addition, the drainage encompassing Corridor F is mirrored on the opposite side of Tapo Canyon by a similar drainage connection to Marr Ranch and core habitat to the east. These two drainages form a complex of intersecting habitats and drainage with the permanent water source in Tapo Canyon Creek. This combination of characteristics perhaps makes this the most important wildlife movement corridor associated with the designated open space area.

The project would not significantly impact migration corridors further to the north of the project site. The City also concurs in principle that strict conformance with the earlier Envicom study is the only feasible measure available to maintain connectivity of the designated open space and the natural areas to the

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north, east and further west. The comment concurs that a linkage in the general location of Corridor C, E and F are important to maintain but the Corridor B has less obvious benefit to link the designated open space area to natural areas to the west. As such, Mitigation Measure 4.3-28 has been modified to add flexibility in the retention or enhancement of linkage corridors to natural areas to the west, north and east of the designated open space area.

The revised mitigation measure is as follows:

4.3-28 The project applicant shall design wildlife overcrossings, undercrossings, and surface crossings to meet minimum standards for cross-section, length, location, fencing and vegetative plantings as shown in the habitat linkage studies prepared by Envicom Corporation. The applicant shall submit a Wildlife Corridor Exhibit for Corridors B, C, E, and F incorporating designs within the grading plan, in compliance with the mitigation measures within the studies to the City for review and approval of the Director of Environmental Services and the Director of Public Works. The applicant shall comply with the formulas and design parameters of the Envicom Reports and Undercrossing Structures of the study entitled A Consideration of Wildlife Movement in the Santa Susana Mountains. Designs in compliance with the described mitigation measures shall be submitted with the submission of the project improvement plans, grading plans, and permits for the project, and approved prior to the issuance of grading permits for the project.

Response 1-31

The comment requests revision of Mitigation Measure 4.3-29 to allow for contemporary practice and methodology to achieve movement corridor objectives. The measure as written in the Draft EIR does not preclude the use of contemporary methodologies and practices in order to allow wildlife corridor success. The measure was written to allow such flexibility to incorporate new science and technology. Nonetheless, the mitigation measure is modified to specify the use of contemporary methodology.

The revised mitigation measure is as follows:

4.3-29 The applicant shall prepare and submit a Wildlife Habitat Management Plan for review and approval by the Director of Environmental Services prior to the issuance of a Zone Clearance for the project, including therein provisions for biological monitoring to evaluate corridor functioning and appropriate funding to ensure the sustainability of the corridors, pursuant to the recommendations of pages 54 and 55 of the Envicom Wildlife Study. The Wildlife Habitat Management Plan may incorporate contemporary

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methodologies and practices that foster wildlife corridor objectives in maintaining open space connectivity.

Response 1-32

The comment requests that non-native invasive tree species be excluded from the requirements of Mitigation Measure 4.3-30 for replacement if removed. The tree ordinance does not exempt non-native or invasive tree species.

The revised mitigation measure is as follows to reflect the correct section of the City municipal code:

4.3-30 Simi Valley Development Code Section 9-38.010(d)070(D) requires replacement of all mature trees, especially oak trees of the genus Quercus and species agrifolia, berberidifolia, and lobata; but also including historic trees and other protected mature trees, removed or otherwise impacted as a result of a development project. The value of the replacement trees shall be equal to the appraised value of the trees removed.

Response 1-33

This comment requests revision of Mitigation Measure 4.3-46 to prevent conflicts with Simi Valley Development Code Section 9-38, Tree Preservation Ordinance. Non-native and invasive tree species would be removed and replaced with value on-site with an appropriate native species as approved by the City.

Response 1-34

The Draft EIR notes the potential impacts that could occur with grading and ground disturbance activities near Ventura County Historical Landmark No. 71. While the comment questions the historic value of the landmark, it is a designated landmark and therefore afforded a level of protection. It is the responsibility of the applicant to demonstrate that no impacts will occur; not of the City or County to re-evaluate the landmark in light of potential nearby development. The comment is noted and no further response is required.

Response 1-35

The following text has been added to Mitigation Measure 4.6-3 for clarification in Section 1.0 and in Section 4.6, Hazards and Hazardous Materials:

4.6-3 Prior to the issuance of grading permits, the top of the abandoned wells located within 50 feet of a building pad should be a minimum of 10 feet below grade (California Code of Regulations, Title 14, Division 2, Chapter 3, Article 3, Section 1723.5) and wells located

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below structures will require proper venting under supervision of the City Engineer (Department of Conservation Well Review Program Item 6).

Response 1-36

The following text has been added to the Mitigation Measure 4.12-3 for clarification in Section 1.0 and in Section 4.12, Public Services – Fire Protection:

4.12-3 Prior to the issuance of building permits, the applicant shall submit proof that all structures adjacent to open space shall be designed to satisfy at least a 1-hour fire-resistant rating. Such structures shall incorporate fire retardant features such as boxed-in eaves, reduced overhangs, double-paned windows, convection resistant roof design, non-combustible roofing material, and related design features, as determined necessary by the VCFPD set forth in the City of Simi Valley Building Code (Ventura County Fire Protection District, Fire Prevention Standard 14.3.1). Building permits shall not be issued until review of fire-retarding architectural features has been completed by the VCFPD and City of Simi Valley Building and Safety Division. Design standards meeting VCFPD City of Simi Valley Building and Safety Division criteria shall be included in the Fire Hazard Reduction Program and incorporated into the Fire Hazard Reduction Design Guidelines for the residential units (City of Simi Valley Development Code, Section 9-30.030).

Response 1-37

The text has been revised in Section 1.0 and Section 4.12, Public Services – Fire Protection:

4.12-7 Prior to issuance of building permits tentative map approval, the applicant shall pay the required fire protection facilities fees for each applicable structure.

Response 1-38

The comment expresses concern for a potential open ended fee. The City of Simi Valley Municipal Code, Section 3-2.04, Payment, states, “however, there shall be a refund of such fees in the event the building permit is not used for such construction.”

The text has been revised in Section 1.0 and Section 4.13, Public Services – Law Enforcement, to clarify Mitigation Measure 4.13-1 as follows:

4.13-1 Prior to the issuance of building permits Prior to final plan approval, the developer of the proposed project shall pay the City's police facilities fee that is required of all new developments to defray the cost of providing increased levels of police protection. The

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sum of $150.00 (as of 2009) for each dwelling unit containing not more than one bedroom and the sum of $75.00 (as of 2009) for each additional bedroom contained therein; provided, however, the total fees for any new dwelling unit shall not exceed the sum of $300.00 (as of 2009). The required amount to be paid shall be determined at the time of final plan review.

Response 1-39

The comment refers to the general applicability of defensible space concepts within the context of the proposed project, which would be a gated community. As identified above in Response 1-38, the proposed project would defray the cost of providing increase levels of police protection through the payment of the City’s police facilities fee and through the defensible space concepts of a gated community. The comment is noted.

Response 1-40

The proposed project does not include a public park. The following text has been added to Objective 5 in Section 3.0, Project Description:

“The project proposes a private park and not a public park.”

The comment also acknowledges that the project would include 500 acres of open space. The comment is noted.

Response 1-41

Comment notes that the proposed project intends to minimize disturbance of environmental impacts to Tapo Creek and adjacent hillsides. The comment also notes that the proposed two-lane roadway along Tapo Canyon would reduce impacts over a four lane road way.

The EIR provides a discussion of the relative impacts of the proposed two lane and four lane roadways in subsection 4.16.10.

Response 1-42

The comment notes that the form of conservation mechanism has not been established but that it will be to the satisfaction of the City Attorney. Subsection 3.3.1 has been revised to reflect the clarification as follows:

“The conservation mechanism form, which would include private and public dedication, will be addressed as part of the subsequent Tentative Tract Map and Planned Development Permit, or development agreement to the satisfaction of the City Attorney. The public conservation mechanism

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would be dedicated to the Rancho Simi Recreation and Park District. The private conservation mechanism would be dedicated to, and the responsibility of, the homeowner’s association.”

Response 1-43

See Response 1-42, above in regards to the conservation mechanism.

Response 1-44

Subsection 3.3.5.3 has been corrected to reflect the Specific Plan’s Residential Parking Standards as follows:

“Residential parking shall be provided by two parking stalls within enclosed attached, two-car garages.”

Response 1-45

Section 3.0, Project Description, has been revised to reflect that areas on privately owned lots subject to a conservation mechanism would not be maintained by the homeowners associations (HOA).

Response 1-46

Section 3.0, Project Description, has been revised to include the term “million” after the number 13 to reflect the correct language.

Response 1-47

See Response 1-24, above in regards to the removal of purple pipe.

Response 1-48

See Response 1-25 above in regards to the clarification of the design guidelines for the proposed houses.

Response 1-49

This comment states that grading activities could occur over a period longer than one-year, and that the site logistics and timing driven by market characteristics could result in grading activities that exceed one year.

A timeframe of one-year was used as a conservative estimate (i.e., an overestimate) to calculate air emissions. This is considered a conservative assumption because grading during a later year would result in lower emission factors due to construction equipment turnover and the greater use of emission control technologies required under California Air Resources Board (CARB) regulations. As newer technologies are implemented and older technologies are phased out, emissions would be expected to decrease for later years.

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Response 1-50

The comment questions the applicability of the fees required by the Ventura County Air Pollution Control District (VCAPCD) for air quality mitigation. These fees apply to all projects in Ventura County and are required mitigation by the VCAPCD. The City of Simi Valley Development Code (9-39.010, Transportation Demand Management) provides for the application of fees and states:

“This Chapter is intended to promote trip reduction and travel demand measures in the City of Simi Valley and meet the Transportation Demand Management (TDM) facilities ordinance adoption requirement as identified in the Ventura County Congestion Management Plan (CMP).”

Therefore, the fees determined in Mitigation Measure 4.2-3 are according to the VCAPCD Guidelines (Section 7.5.3 Contribution to an Off-Site TDM Fund) and are required to be collected per the City’s TDM Ordinance.

Response 1-51

The comment notes that the applicant supports the dual use of the trail system as a wildlife corridor as well as a public linkage. This comment has been noted.

Response 1-52

The commenter requests correction of the statement that four of seven corridors were identified in the 1993 Envicom study1 as being critical, as the commenter correctly states that only three of the seven corridors (Corridors C, E, and F) are recommended as priorities of the study. However, subsequent to the February 1993 study, Envicom completed further study of movement corridors in Dry Canyon2 and in a December 22, 1993 letter address to Tom Preece, Senior Planner of the City of Simi Valley, they revised their recommendation of the earlier February 1993 study to include Corridor B. The following is an extract from the December 1993 letter:

The most biologically sound mix of corridors consist of routes going, east, west and north – under the current project design this goal is satisfactorily met through the required implementation of corridor C and E (northbound), corridor B (westbound), and corridor F (eastbound).” And, “The major emphasis on the design and location of linkages has been placed on corridors C, B, E and F as they provide the best available opportunity to meet the needs of wildlife.

It is this subsequent recommendation by Envicom that is included in the 1995 certified Supplement to the Final Subsequent EIR for the Whiteface Specific Plan as Mitigation Measure #5 (Page IV.C-10). Therefore, no change to the Draft EIR text is required as four corridors were identified.

1 Envicom Corporation, A Consideration of Wildlife Movement in the Santa Susana Mountains, February 1993. 2 Envicom Corporation, A Study of Wildlife Movement in Dry Canyon, December 1993.

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The City understands that a corridor crossing from the designated open space west toward Sand Canyon is highly constrained but the City does not hold that such constraints should preclude the inclusion of an east-west linkage to provide additional wildlife movement opportunities. However, the final design of the Corridor B can be modified to best reflect the existing constraints in this area.

Response 1-53

See Response 1-27 above for clarification of Mitigation Measure 4.3-7.

Response 1-54

See Response 1-28 above regarding a missing phrase in Mitigation Measure 4.3-8.

Response 1-55

See Response 1-29 above with a request to establish acceptable parameters concerning lighting in Mitigation Measure 4.3-9.

Response 1-56

The commenter has requested that Figure 4.3-3, Wildlife Movement Corridors, be revised to reflect more current conditions. Figure 4.3-3 has been revised to more closely reflect both the current movement opportunities and those reflected in the certified Supplement to the Final Subsequent EIR for the Whiteface Specific Plan. The City believes these are either existing movement linkages or areas where linkage opportunity still exists. The City agrees with the commenter that the project design is responsive to maintaining linkage from the designated open space area to the natural areas to the west, north and east. Where undercrossings currently exist to facilitate wildlife movement, the project design can be found to be in compliance with the Mitigation Measure 4.3-28 and no further linkage improvements would be necessary. Where such wildlife movement improvements currently exist then Mitigation Measure 4.3-28 will afford the opportunity to improve these connections.

Response 1-57

The comment states that one corridor depicted in the Draft EIR Figure 4.3-3 indicates connection with the urban edge and the surrounding existing neighborhoods. This statement is correct as it applies the location of Corridor F in the Draft EIR Figure 4.3-3. This Figure has been revised as noted in Response 1-56 above to more accurately reflect the linkage between this drainage within the designated open space of Tapo Canyon to the east. The Draft EIR reflects the existing condition with the following statement contained on Page 4.3-42 of the Draft EIR:

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“Located to the east just outside of the project boundaries are three established undercrossings that would provide wildlife the opportunity for movement and the potential to be used as movement corridors.”

Additionally, three underpasses beneath Lost Canyon Drive within the Sand Canyon development facilitate wildlife movement in the general area of Corridor C.

Response 1-58

The comment states that the Corridor E depicted in the Draft EIR Figure 4.3-3 is inconsistent with the 1993 Envicom Study. As new Figure 4.3-4, Existing Linkage Relationships of 640 Acre Parcel, (see revised Draft EIR) indicates, the Envicom illustration of linkages highlighted drainages and a few ridgelines as corridor routes and Corridor E was not a single location but a series of shallow canyons. The revised Figure 4.3-3 depicts two locations with the broader general Corridor E area and a linkage closer to the intersection of Lost Canyon Drive and Tape Canyon Road would be equally useful. The City will accept the applicant’s design of a corridor that will permit the linkage function of movement northward away from the designated open space area.

Response 1-59

The comment states that the Corridor F as depicted in the Figure 4.3-3 does not provide linkage to open space to the east but to existing urban neighborhoods. The City concurs with this assessment and the revised Figure 4.3-3 contained in this Final EIR more accurately depicts the location where linkage from the designated open space area to natural areas to east is possible. The concept for Corridor F was always to allow this primary drainage of the open space area to connect to Tapo Canyon.

Response 1-60

The comment considers the location of Corridor F to be infeasible. The City does not agree because the Corridor F location (as shown in revised Figure 4.3-3) is conceptual and until an actual design is proposed, the feasibility is unknown. The City encourages the applicant to work with the consulting biologist to provide a corridor design that allows the proposed residential development while accommodating wildlife movement from the open space dedication area to Tapo Canyon. In this regard, the City is willing to consider the design features of a Corridor F in the general location of the 1993 Envicom study, which intends for the corridor to be located north of the existing urban neighborhoods.

Response 1-61

See Response 1-30 above with a request to modify Mitigation Measure 4.3-28.

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Response 1-62

See Response 1-31 above with a request to revise Mitigation Measure 4.3-29.

Response 1-63

See Response 1-32 above with a request to revise Mitigation Measure 4.3-30.

Response 1-64

See Response 1-33 above with a request to revise Mitigation Measure 4.3-46 to prevent conflicts with the City’s Tree Preservation Ordinance. Non-native and invasive tree species would be removed and replaced with value on-site with an appropriate native species as approved by the City.

Response 1-65

The comment has requested that references to the investigation of the tank site be removed as issues concerning the tank site are essentially the same as issues posed to the remainder of the project site. The section was broken down into two different overall discussions.

The discussions were included to adequately consider the two different studies that were completed and were incorporated for disclosure of the site conditions and suitability for locating a water tank relative to the rest of the project site.

Response 1-66

See Response 1-65 above.

Response 1-67

See Response 1-65 above.

Response 1-68

The commenter has asked for a revision on Figure 4.5-2 to show the location of the proposed water tank location. Figure 4.5-2 does show the location of the proposed water tank location; it is called out with a blue boundary and is shown east of the western boundary designated near the “Village Core.”

Response 1-69

See Response 1-65 above.

The comments have requested that Mitigation Measure 4.5-17 be deleted as it is not applicable for expansive soils. The mitigation measure describes those areas identified to consist of shallow groundwater shall include the installation of subdrains, backdrains, and slope toe drains. As described in

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the subsection 4.5.4.2 under impacts related to expansive soils, soils that exhibit expansive properties occur in low-lying areas, especially near river channels.

In addition, the expansive soils impact discussion also identifies that “a soil’s potential to shrink and swell depends on the amount and types of clay in the soil. Certain types of clay are more responsive to changes in water content than others; they expand when wet and disproportionately shrink when dry.” Therefore, the potential for expansive soils located in areas with shallow groundwater is greater than under normal groundwater conditions. Consequently, Mitigation Measure 4.5-17 has been incorporated to minimize the expansive properties of soils in shallow groundwater areas.

Response 1-70

The commenter has requested that the requirement for a permit from VCWPD for access to Presidio Drive be deleted. The EIR has been revised to reflect the request and the requirement has been deleted.

Response 1-71

See Response 1-7 above which discusses the purpose of the Dry and Tapo Canyon Flood Control Alternatives studies.

Response 1-72

See Response 1-8 above in regards to the justification of the Flood Control Studies and the less than significant water quality impact.

Response 1-73

See Response 1-9 above clarifying the discussion of the Dry Canyon Flood Control Alternatives study.

Response 1-74

See Response 1-10 above in regards to downstream improvements or a regional detention basin.

Response 1-75

See Response 1-11 above regarding the analysis of the 100-year storm event and the proposed project.

Response 1-76

See Response 1-12 concerning on-site drainage improvements.

Response 1-77

See Response 1-76 above.

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Response 1-78

See Response 1-14 above concerning land dedication for the regional detention basin.

Response 1-79

See Response 1-15 above in regards to improvements required before project implementation.

Response 1-80

See Response 1-16 above concerning improvements (i.e., downstream improvements and the regional detention basin) to mitigate potential flooding impacts.

Response 1-81

See Response 1-80 above.

Response 1-82

See Response 1-81 above in regards to flooding impacts.

Response 1-83

See Response 1-19 above regarding the discussion of active wells versus fully abandoned wells.

Response 1-84

The commenter has identified that the Ventura County Waterworks District No. 8 supplies water to the project site, not Calleguas Municipal Water District. The following correction to the text in Section 4.12 has been made:

“In addition, construction sites are subject to Calleguas Municipal Water District Ventura County Waterworks District No. 8 and VCFPD standards relative to water availability and fire department fire- fighting equipment accessibility standards.”

Response 1-85

The comment notes the difference in fire flow requirements for the club house (3,500 gallons per minute [gpm]) versus residential requirements (1,500 gpm). The text has been clarified according to the Ventura County Fire Protection District (Fire Prevention Standard 14.5.2, Water Supplies) and Ventura County Waterworks District No. 8 Standards in Section 4.12 as follows:

“The proposed project clubhouse would be expected to require a minimum fire flow of 3,500 gallons per minute (gpm) for a 4-hour duration, which can be provided by existing water tanks in the area in conjunction with the new water tank proposed for the northeastern portion of the Specific Plan area. The

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proposed project residential fire hydrants would be expected to require a minimum fire flow of 1,500 gpm for a 4-hour duration.”

Response 1-86

The comment notes that the fuel modification zone should be measured from the building face and not the property/parcel boundary. The EIR (Section 4.12) has been modified accordingly.

Response 1-87

See Response 1-37 above in regards to Mitigation Measure 4.12-7.

Response 1-88

The fuel modification zone specifies that the zone will extend from the face of a building outwards. Four zones would be included. Zone A would extend from the building face to the property line. Zone B would extend 20 feet from outside the fence line. Zone C would extend 80 feet from the edge of Zone B. Zone D would extend 100 feet from the edge of Zone C. The following text has been added to Section 4.12 to clarify the fuel modification zone:

“The exact location, dimension, and requirements for the Fuel Modification zones will be further determined and refined in agreement with the Ventura County Fire Protection District and the City concurrent with the review and approval of the subsequent Tentative Tract Map and Planned Development Permit.”

The EIR has also been updated to clarify the exact location, dimension, and requirements for the fuel modification zones.

The comment notes that the reference to 138-foot modification zone in the General Plan Policy analysis table was incorrect and the discussion has been revised.

Response 1-89

See Response 1-88 above for clarification of the fuel modification zones within the project site.

Response 1-90

Traffic Impact Fees are credited for a project only when that project constructs improvements that are on the Traffic Impact Fee List of Improvements and the cost of the improvements constructed are more than the total amount of the fee. All street improvements constructed by projects in the City of Simi Valley are funded solely and totally by that project. There are no future reimbursements by other projects for any street improvements.

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Response 1-91

See Response 1-22 above regarding a traffic signal at the intersection of Lost Canyons Drive/Lost Canyons Golf Club. The signal warrant analysis in the EIR recommends a traffic signal, but does not require a traffic signal at this intersection.

Response 1-92

The following text has been revised in Section 4.16 to clarify the proposed two-lane Tapo Canyon approach:

“As part of the Lost Canyons Project, the applicant proposes reconstructing Tapo Canyon Road as a two-lane divided roadway with a raised center median varying in width from 4 to 14 feet between Presidio Drive and Lost Canyons Drive consistent with the Minor Arterial classification contained in City of Simi Valley General Plan Circulation Element.3 This design would be similar to the existing Lost Canyons Drive between Erringer Road and the western limits of the Lost Canyons Project site.

This two-lane approach would realign and reconstruct Tapo Canyon Road to improve horizontal and vertical curves to a 50-mile per hour design speed The reconstructed roadway would consist of one 14-foot travel lane and one 6-foot on-street bike lane in both directions of travel and one pedestrian pathway located within the east parkway. The proposed 14-foot travel lane in conjunction with proposed 6-foot bike lane in each direction will provide approximately 4 feet of additional paved roadway surface in each direction over what currently exists. The raised median addresses City staff concerns regarding illegal passing and vehicle encroachment into the opposing lane of travel. The 20-foot pavement width between the raised center median and the outside curb in each direction of travel will provide emergency vehicle access in both directions of the reconfigured roadway segment within a 74-foot right-of-way width. The proposed street is illustrated on Figure 3.0-14, Proposed Tapo Canyon Road Street Sections.”

Furthermore, the 6-foot or 8-foot dimension does not refer to “paved shoulders” but rather to the widths of the on-pavement bike lanes and is not undesirable. The standard design width for on-street bike lanes is 8 feet or less per the Caltrans Highway Design Manual. The City of Simi Valley follows that design guideline to provide the 8-foot-wide bike lane so long as the adjacent travel lane is not less than 12 feet wide.

It should be noted that approval of the proposed project, as a Specific Plan and General Plan Amendment, allows for the City to deviate from the standards by establishing specific requirements for the proposed project and thereby superseding the current municipal code requirements. The Specific Plan proposes a 14-foot travel lane with a proposed 6-foot bike lane in both directions. The City of Simi Valley

3 RBF Consulting, Tapo Canyon Road Analysis, City of Simi Valley, April 8, 2009.

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standard street design requirement is to have 8-foot-wide bike lanes as long as the adjacent travel lane is not less than 12-feet wide. Ultimately, the City Council will decide and approve the final configuration of the design of Tapo Canyon Road.

Response 1-93

See Response 1-91 above.

Response 1-94

The project traffic study notes that consideration should be given to a traffic signal at Lost Canyons Golf Club and Lost Canyons Drive. The language in the EIR is clear that the traffic signal at the main project entrance with Lost Canyons Drive is only recommended and not required.

Response 1-95

The comment has requested that the nature of the potential traffic hazard for bicyclists and large trucks and recreational vehicles as a result of the two-lane Tapo Canyon Road configuration is more of an opinion than demonstrated by fact. The following text has been added to Section 4.16.10.4:

“However, there is always the potential for vehicles to encroach into bike lanes under any roadway configuration.”

Response 1-96

The comment requests the additional discussion of the 24-foot internal street design section that occurs elsewhere in the proposed residential community. The following text has been included in Section 4.16, Traffic (Specific Plan Section G.1.b(ii), Infrastructure).

“The Minor Road Section with no parking consists of a 24-foot pavement width (travel way), with 5-foot-wide landscape easements on each side of the travel way. Refer to new Figure 3.0-13c, Proposed Local/Minor Road Sections.”

The Minor Road Sections with parking pullouts consists of a 24-foot pavement width (travel way) with 8-foot-wide by 22-foot-long parking spaces provided intermittently along the travel way and within 200 feet of each dwelling unit it serves. An additional 5-foot landscape easement will be provided on each side of the travel way. Roadway geometry will be based on a design speed of 20 miles per hour (mph) for traffic calming and to reduce grading impacts to the adjacent hillsides.”

Response 1-97

See Response 1-70 above in regards to Emergency Vehicle Access points for the proposed project.

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Response 1-98

The comment provides clarification on the number of parking stalls required for the clubhouse (120) and member suites (25). The total number of parking spaces in the text of the Draft EIR was corrected to reflect 145 total parking spaces. Table 4.16-29 is consistent with Table III-5 of the Specific Plan.

Response 1-99

The comment states that in lieu of sidewalks, the proposed project will include pedestrian pathways on one side of Tapo Canyon Road and Lost Canyons Drive. The following text in Section 4.16 has been revised to read:

“Tapo Canyon Road would provide a pedestrian pathway along the one side of the street and Lost Canyons Drive would provide a pedestrian pathway along one side of the street.”

It should be noted that the City of Simi Valley standard street design requirement is to have standard sidewalks on both sides of the streets. Ultimately, the City Council will decide and approve the final configuration of both of these streets.

Response 1-100

The information described in Section 4.18, Utilities – Wastewater, has been updated to reflect the land use statistical tables in Section 3.0, Project Description. The text has been revised as follows:

“As discussed in Section 3.0, Project Description, the proposed specific plan would permit development of 364 dwelling units on approximately 1,048 acres made up of several neighborhoods and designate an area of approximately 500 acres as open space. The proposed project will also retain approximately 222 acres for commercial recreation (golf).”

Response 1-101

The comment requests that the Mitigation Measure 4.18-1 be revised as described in the City’s Development Code Section 9-66.050.

4.18-1 Prior to approval of tentative tract maps, tThe applicant shall pays fees in accordance with Development Code Section 9-66.050 to the City of Simi Valley.

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Impact Sciences, Inc. 11.0-53 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 11.0 Response to Comments

Letter Number 2. County of Ventura, Resource Management Agency, Planning Division, Tricia Maier, dated January 27, 2010 Response 2-1

The County of Ventura, Resource Management Agency, Planning Division (County Planning Division) noted that the County commented on the proposed project and that additional letters are attached. This comment is acknowledged. Because this comment does not address the content of the Draft EIR, no further response is required.

Impact Sciences, Inc. 11.0-54 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 Letter No. 3

VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT Memorandum

TO: Laura Hocking/Dawnyelle Addison, Planning DATE: January 25, 2010

FROM: Alicia Stratton

SUBJECT: Request for Review of Draft Environmental Impact Report (DEIR) for the Whiteface specific Plan Amendment 6: Lost Canyons, City of Simi Valley (Reference No. 09-059)

Air Pollution Control District staff has reviewed the subject DEIR, which is a request for a Specific Plan Amendment, General Plan Amendment, and Zone change to allow a master planned gated community of private open space, multipurpose public recreation trails and trailhead, a private park, a maximum of 364 single family detached dwellings, and deletion of one existing public golf course. It also consists of the conversion of the existing 18-hole public golf course in Tapo Canyon to a private golf course and practice facility, a new or expanded private clubhouse with 25 attached membership suits, pro shop, spa, pool, fitness center, tennis facilities, restaurant, cart barn, and maintenance facility. In addition, the project consists of a residential sales office and ancillary community serving retail uses, private streets, gated emergency vehicle access and infrastructure improvements. The project location is 1,770 acres within the Dry and Tapo Canyon portions of the Whiteface Specific Plan area in the north portion of the City of Simi Valley.

Section 4.2 of the DEIR addresses air quality. We concur with the findings of this discussion that significant operational air quality impacts would result from the project. Implementation of the Air Quality Mitigation Measure described in Section 4.2-3 and the Air Quality Appendix, Transportation Demand Management Fund, will mitigate air quality impacts to the extent feasible. However, long-term impacts associated with the 1 project would continue to contribute to air quality deterioration as the Whiteface Specific Plan as a whole would generate pollutant emissions in excess of ROC and NOx thresholds and impacts would be significant and unavoidable. Project consistency with the population forecasts is confirmed in Section 4.2.5.2, Methodology.

If you have any questions, please call me at (805) 645-1426.

Impact Sciences, Inc. 11.0-55 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 11.0 Response to Comments

Letter Number 3. Ventura County Air Pollution Control District, dated January 25, 2010. Response 3-1

The Ventura County Air Pollution Control District (VCAPCD) concurs with the findings of air quality impacts as a result of the proposed project. Therefore, no further response is required.

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COUNTY OF VENTURA RESOURCE MANAGEMENT AGENCY PLANNING DIVISION

M E M O R A N D U M

DATE: January 25, 2010

TO: Laura Hocking, Planning Technician

FROM: Christina Danko, Planning Staff Biologist

SUBJECT: RMA09-059 - Whiteface Specific Plan Amendment 6: Lost Canyons Draft EIR

I have the following comments on Section 4.3, Biological Resources of the Draft EIR:

1) The discussion on the coastal California gnatcatcher does not inform the public that the entire project site is within critical habitat for coastal California gnatcatcher designated by the U.S. Fish and Wildlife Service. Ventura County Planning has access to the latest critical habitat maps, and the project site is covered by the designated critical habitat. The evaluation of impacts to the gnatcatcher in the draft EIR does include an analysis of the suitable habitat on 1 site and results of protocol surveys for the gnatcatcher. However, if a federal permit is required for the project, such as a Section 404 permit for impacts to “waters of the U.S.,” consultation with the U.S. Fish and Wildlife Service would be required under the Endangered Species Act.

2) The conclusion of less than significant impact to coastal western whiptail on page 4.3-50 does not include sufficient support. The analysis for this species is similar to the analysis for San Diego horned lizard, but the conclusion is different. The draft EIR states, “as the whiptail is considered a special animal with no official federal or state status and there is suitable habitat, impacts would be less than significant.” The San Diego horned lizard also is not listed under 2 the federal or state Endangered Species Acts, but it is considered rare and sensitive within the state, and the draft EIR finds impacts to this species to be potentially significant. Why are impacts to the coastal western whiptail considered less than significant? The conclusion is not supported by substantial evidence.

3) Mitigation Measure 4.3-1 calls for replacement of any special-status plants found on site during focused surveys required at least one year prior to construction. However, the required Native Plant Mitigation Plan must “identify performance standards by which to measure the success of the mitigation and shall include adaptive management procedures to ensure a 3 preservation or replacement, or combination of the two, of a 1:1 ratio.” This statement seems to say that preservation of existing plant populations on a 1:1 ratio would mitigate the impact from loss of special-status plants on the project site. If preservation of existing plant populations is selected over propagation and replacement of special-status plants, the mitigation ratio of 1:1

Location # 1740 800 South Victoria Avenue, Ventura, CA 93009

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would likely not be sufficient to fully mitigate the impact, because there would still be a net loss 3 of occurrences of the special status plant that would further increase its rarity.

4) Mitigation Measure 4.3-2 requires a relocation plan for certain special-status animals, and the relocation plan must “include provisions for monitoring the success of released animals.” While following up on the relocated animals is a good idea, what would be the contingency plan if the 4 relocation is not successful? If there is no contingency plan, then how does following-up on the relocated animals help to further mitigate the impact?

5) Impacts to coastal California gnatcatcher, least Bell’s vireo, and southwestern willow flycatcher are all considered to be less than significant, because protocol surveys for these species confirmed their absence. However, Mitigation Measure 4.3-3 requires additional protocol surveys for least Bell’s vireo within one year prior to construction. Protocol surveys for the other listed bird species are not required. It is not clear why updated protocol surveys would 5 be required for least Bell’s vireo and not for the other listed bird species, especially considering that the project site is mapped as critical habitat for coastal California gnatcatcher. By the time that construction would begin on this project, the protocol surveys for these species that have been conducted for the draft EIR would likely be out-of-date.

6) Direct impacts to over 400 acres of coastal sage scrub are considered less than significant in this draft EIR. However, certain coastal sage scrub alliances, including goldenbush scrub, are classified as rare by the California Department of Fish and Game (see the 2009 List of California Vegetation Allliances: http://www.dfg.ca.gov/biogeodata/vegcamp/natural_communities.asp). 6

In addition, the coastal sage scrub on the project site is designated as critical habitat for coastal California gnatcatcher and supports several California Species of Special Concern. These facts should be considered when determining whether impacts would be significant.

7) The proposed project would result in extensive impacts to riparian habitat, oak woodland, and coastal sage scrub that provides habitat for numerous special status species and is mapped as critical habitat for coastal California gnatcatcher. The proposed mitigation requires extensive 7 compensatory mitigation for impacts to riparian habitat and mature trees. The draft EIR is not clear about how significant impacts could be avoided and whether avoidance of significant biological impacts was considered in the design of the Specific Plan.

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Letter Number 4. County of Ventura, Resource Management Agency, Planning Division, Christina Danko, dated January 25, 2010. Response 4-1

The comment is correct that essentially the entire project site is included as critical habitat for the coastal California gnatcatcher. Protocol surveys and habitat suitability evaluation for coastal California gnatcatcher were conducted for the biological resources assessment. Upon evaluation of the habitat, surrounding land uses and the negative results from the protocol surveys, the Draft EIR concluded that the species is not expected to occur on the project site.

A federal action of issuance of a Section 404 permit to be issued by the U.S. Army Corps of Engineers (USACE), Section 7 consultation with the U.S. Fish and Wildlife Service may be required under the federal Endangered Species Act (ESA). Should this be required, the project applicant will be required to work with USACE to secure compliance with the federal ESA. As a conservation precaution, Mitigation Measure 4.3-5 has been modified to include mitigation specific for the potential occurrence of coastal California gnatcatcher (see Response 13-3 to California Department of Fish and Game [CDFG] Letter).

Response 4-2

The comment inquires why the impact significance determination for the coast horned lizard and the coastal western whiptail (on pages 4.3-49 and 4.3-50, respectively) are different considering the same level of analysis. The explanation for the two different levels of scrutiny is that the two species have different rankings of sensitivity; the coastal horned lizard status is California species of special concern, where as the coastal western whiptail has the sensitivity status of special animal. A species of special concern is typically afforded some protection by the CDFG through the CEQA process whereas a special animal is not afforded protection by the state or federal regulatory agencies.

Response 4-3

The comment references Mitigation Measure 4.3-1 in seeking the clarification of the Native Plant Mitigation Plan for special-status species discovered on the project site and the mitigation goal of no net loss. Preservation at a ratio of 1:1 implies that impact to the special-status species can be avoided and that maintenance of the on-site population would be sufficient mitigation for the avoidance of impacts. If a special-status plant species is located within an area proposed to be disturbed and therefore impacts the species, then the Native Plant Mitigation Plan would need to include the methodology, including the monitoring of success, by which the species will be propagated and replaced within a suitable habitat open space area in order to maintain a 1:1 replacement ratio to the impact species. In all case, preservation of an existing population is preferred but replacement is an acceptable mitigation for impacts to existing populations.

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Response 4-4

The comment inquires about the purpose of the success monitoring provisions for relocated special-status amphibian and reptile species required under Mitigation Measure 4.3-2. CDFG typically does not encourage the use of relocation mitigation measures for potential impacts to special-status species because there is limited documentation of the success of such relocation efforts. If relocation of individual animals is unsuccessful, there can be no contingency because the individual animal could no longer contribute to the species gene pool and viability of the local population. Therefore, the inclusion of provisions to monitor the survivability of relocated individuals is an effort to gather empirical evidence to garner support from CDFG that such mitigation by relocation is a successful method of mitigating against the direct loss of individuals.

Response 4-5

The comment questions why additional surveys for least Bell’s vireo are appropriate but no further surveys for coastal California gnatcatcher or southwestern willow flycatcher are included. The reason why future protocol surveys for least Bell’s vireo are included but not for southwestern willow flycatcher or coastal California gnatcatcher is because suitable habitat for both the flycatcher and the gnatcatcher has been determined to not be present under the current on-site conditions. In contrast, the riparian vegetation within which least Bell’s vireo prefers holds the potential for the species to migrate to the project site. As the USFWS has commented that the protocol survey for coastal California gnatcatcher will be out-of-date by the time Section 7 consultation is initiated, new protocols surveys for this species will be likely for successful conclusion of the consultation process. In addition, Mitigation Measure 4.3-5 requires pre-construction surveys for special-status species; include coastal California gnatcatcher, although these need not be protocol surveys.

Response 4-6

The comment states that coastal sage scrub habitat is sometimes considered a sensitive plant community. While the coastal sage scrub on the project site has been categorized into different alliances, only the coast prickly pear habitat is considered a sensitive plant community. However, the 2009 List of California Vegetation Alliances has ranked the coast prickly pear habitat as no longer being a rare community. Using the 2009 List of California Vegetation Alliances, none of the identified coastal sage scrub plant assemblages are considered rare. Therefore, the determination and impact assessment of impacts to coastal sage scrub in the Draft EIR is consistent with the CDFG categorization of plant alliances.

It is acknowledged that coastal sage scrub is the preferred habitat for the coastal California gnatcatcher, which has not been documented as occurring on the project site (see Response 4-5 above).

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Response 4-7

The comment states that impacts would occur to riparian habitat, oak woodland and coastal sage scrub but there is no discussion of what measures could be used to avoid impacts to these sensitive plant associations. While complete avoidance of impacts to these vegetation communities is not possible if a development project is to be approved, minimizing impacts to the most sensitive of the plant communities has been incorporated into the project design. Project design features include the preservation of mature trees within the open space portions of the project and the incorporation of certain native vegetation in the fuel modification zones.

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COUNTY OF VENTURA RESOURCE MANAGEMENT AGENCY PLANNING DIVISION

M E M O R A N D U M

DATE: January 22, 2009

TO: Laura Hocking, Planning Technician

FROM: Kari Finley, Senior Planner

SUBJECT: RMA 09-059 Whiteface Specific Plan Amendment 6: Lost Canyons Draft EIR

Planning Division staff has reviewed the subject Draft EIR and has the following comments:

1. Jobs/Housing Balance -

The Whiteface Specific Plan (WSP) Amendment 6 provides for potential development that could allow up to 364 residential dwelling units. The WSP also provides for other open space and recreational opportunities. However, the WSP does not provide any commercial or employment opportunities. Given 1 the potential for the addition of over 1100 new residents within the City of Simi Valley, a discussion of jobs/housing balance should be included.

2. Mineral Resources – Hauling Aggregate

Section 4.9 (page 4.9-7), recognizes that there are significant construction aggregate resources located north of the project site. It also indicates that Tapo Canyon Road serves as the transportation route and access to the aggregate resources north of the City of Simi Valley in the unincorporated areas of the County. The last paragraph of same page discusses hauling aggregate and reads as follows:

Hauling Aggregate—With the imbalance of aggregate grades in the Simi PCR, transporting the material for optimal mixes may become a necessity. Because the present mining and processing facilities are 2 located in the hills to the north and south of the City of Simi Valley, any transport of material between sites will invariably have to pass through the City. The movement of trucks for this purpose may create problems in the area. Any curtailment of the transport of material would effectively reduce the supply of PCC aggregate in the Simi PCR.

Figure 3.0-5, Proposed Lost Canyons General Plan Land Use Map, depicts a linear section of land designated Residential Low that follows along both sides of Tapo Canyon Road near the southeastern border of the WSP boundary. Although the DEIR recognizes that “[T]he movement of trucks for this purpose may create problems in the area”, it does not provide a discussion of the potential problems. The DEIR should discuss and analyze the potential conflicts that may be created by locating residential uses along a known truck route including noise and safety issues.

Location # 1740 800 South Victoria Avenue, Ventura, CA 93009

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Letter Number 5. County of Ventura, Resource Management Agency, Planning Division, Kari Finley, dated January 22, 2010. Response 5-1

As described in Section 3.0, Project Description, the proposed project would provide up to 6,000 square feet of total retail building space. The proposed project would generate 364 dwelling units. The number of employment opportunities within the project site would be 13.4 Therefore, the jobs to housing ratio would be 0.04 (13 employees/364 dwelling units = 0.04).

The City’s average monthly labor force in 2009 was 69,500 people. The average monthly number of people employed was 63,700. As of 2009, the City of Simi Valley has a total of 42,010 housing units (California Department of Finance, Table 2: E-5 City/County Population and Housing Estimates, 2009). The jobs to housing ratio for the City is 1.52 (people employed to housing units).

The 2009 (latest information) unemployment rate for the City of Simi Valley was 8.2 percent (California Employment Development Department, Monthly Labor Force Data for Cities and Census Designated Places December 2009 Preliminary Data Not Seasonally Adjusted).

The proposed project would generate an additional 13 new employment opportunities within the project site which would total to 63,713 people employed within the City. The proposed project would create 364 new dwelling units within the City which would result in a total of 42,374 dwelling units. Therefore, with incorporation of the proposed project the jobs to housing ratio would be 1.50. This would incrementally decrease the jobs to housing ratio 0.02 and would result in a less than significant impact.

Response 5-2

Traffic safety issues regarding truck usage along Tapo Canyon Road are addressed in Section 4.16, Traffic and Transportation. This impact analysis determined that heavy truck travel along Tapo Canyon Road would result in less than significant traffic hazards from either the two-lane configuration or the four-lane configuration. Section 4.16 also determines that a traffic signal is recommended at the intersection of Tapo Canyon Road and Lost Canyons Drive under certain conditions, pages 4.16-49 to 51.

Noise issues regarding potential noise generated along Tapo Canyon Road has been analyzed in Section 4.10, Noise.

4 This assumes that for every 450 square feet of retail space there would be a creation of 1 employee (6,000 square feet/450 square feet = 13).

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PUBLIC WORKS AGENCY TRANSPORTATION DEPARTMENT Traffic, Advance Planning & Permits Division M E M O R A N D U M

DATE: January 14, 2010

TO: RMA – Planning Division Attention: Laura Hocking

FROM: Behnam Emami, Engineering Manager II

SUBJECT: REVIEW OF DOCUMENT 09-059 Draft Environmental Impact Report (EIR) for the Whiteface Specific Plan Amendment 6: Lost Canyons Project Specific Plan and General Plan Amendments, and Zone Change to allow a master planned gated community and deletion of one existing public golf course in Dry Canyon. Within the Dry and Tapo Canyon portions of Whiteface Specific Plan area in the north portion of the city of Simi Valley (city) Lead Agency: City of Simi Valley

Pursuant to your request, the Public Works Agency -- Transportation Department has reviewed the Draft EIR for the Whiteface Specific Plan Amendment 6: Lost Canyons Project. The project consists of a Specific Plan Amendment, General Plan Amendment, and Zone Change to allow a master planned gated community of private open space, multipurpose public recreation trails and trailhead, private park, a maximum of 364 single-family detached dwellings, and deletion of one existing public golf course in Dry Canyon. It also consists of the conversion of the existing 18-hole public golf course in Tapo Canyon to a private golf course and practice facility, a new or expanded private clubhouse with 25 attached membership suites, pro shop, spa, pool, fitness center, tennis facilities, restaurant, cart barn, and maintenance facility. In addition, the project consists of a residential sales office, and ancillary community serving retail uses (thematic general store and daycare of not more than 6,000 SF), private streets, gates emergency vehicle access connections to Anderson Drive, Ditch Road/Presidio Drive, and Bennett Road, widening of Lost Canyons Drive and Tapo Canyon Road, water, sewer, drainage, and other infrastructure improvements. The project is located on 1,770 acres with the Dry and Tapo Canyon portions of the Whiteface Specific Plan area located in the north portion of the city of Simi Valley.

We offer these comments:

1. The Draft EIR indicates that the project will generate additional traffic to the local roads and the Regional Road Network. Page 1.0-23 of the Draft EIR provides that the proposed project will generate approximately 2,840 net new daily trips, which would include approximately 233 1 net new AM peak-hour trips and approximately 318 net new PM peak-hour trips.

Impact Sciences, Inc. 11.0-64 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 2. The cumulative impact of this project, when considered with the cumulative impact of all other approved (or anticipated) development projects in the County, is potentially significant. The condition for paying the County Traffic Impact Mitigation Fee (TIMF) to address the cumulative impacts of this project on the County Regional Road Network is included in the Mitigation Measure 4.16-2 (page 4.16-58) of the Draft EIR which states that prior to the approval of tract maps, the applicant shall pay Ventura County Reciprocal Traffic Fee, which is collected by the City of Simi Valley on behalf of the County. Based on the information from the Draft EIR, and the Reciprocal Agreement between the City of Simi Valley, and the County of Ventura, the fee due to the County is: 2

2,840 ADT x $4.38/ADT = $12,439.20

The above estimated fee may be subject to adjustment at the time of deposit, due to provisions in the TIMF Ordinance allowing the fee to be adjusted for inflation based on the Engineering News Record Construction Cost Index. The above fee is an estimate only based on information provided in the Initial Study. If the project cumulative impacts are not mitigated by payment of a TIMF, current General Plan policy will require County opposition to this project.

3. The EIR should require conditions to annex County roadways to the City of Simi Valley, which are adjacent to this project. In particular, the County segments of Tapo Canyon and Bennett 3 Roads. It appears one half of the southern section of Bennett Road is in the city boundary. The City should annex the remainder of Bennett Road.

4. Please provide us with a copy of the Final EIR for review, when it becomes available.

Our review is limited to the impacts this project may have on the County’s Regional Road Network.

Please contact me at 654-2087 if you have questions.

F:\transpor\LanDev\Non-County\09-059.doc

Impact Sciences, Inc. 11.0-65 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 11.0 Response to Comments

Letter Number 6. County of Ventura, Public Works Agency, Transportation Department, dated January 14, 2010. Response 6-1

The comment has been noted. Because this comment does not address the content of the Draft EIR, no further response is required.

Response 6-2

The comment has been noted. The Mitigation Measure 4.16-2 has been updated to reflect the County Traffic Impact Mitigation Fee (TIMF), based on the existing conditions set in the Initial Study, of $12,439.30. The comment has been reflected in Section 1.0, Executive Summary and Section 4.16, Traffic and Transportation, and the EIR revised to read as follows:

4.16-2 Prior to the approval of tract maps, the applicant shall pay the Ventura County Reciprocal Traffic Fee, which is collected by the City of Simi Valley on behalf of the County. The fee due to the County is $12,439.20 based on the Initial Study. This fee may be subject to adjustment at the time of deposit, due provisions in the TIMF Ordinance allowing the fee to be adjusted for inflation based on the Engineering News Record Construction Cost Index.

Response 6-3

The City of Simi Valley is not proposing to annex any county roadway. This comment has been noted. Because this comment does not address the content of the Draft EIR, no further response is required.

Impact Sciences, Inc. 11.0-66 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 Letter No. 7

Ventura County Watershed Protection District Water & Environmental Resources Division Water Quality Section

MEMORANDUM

DATE: January 7, 2010

TO: Laura Hocking, RMA- Planning Division

FROM: Paul Tantet

SUBJECT: RMA 09-059–WHITEFACE SPECIFIC PLAN AMENDMENT 6: LOST CANYONS DRAFT EIR, CITY OF SIMI VALLEY

I have reviewed the draft EIR for the City of Simi Valley project and have the following comment for general guidance to add to our overall County of Ventura response:

On May 7, 2009, the Los Angeles Regional Water Quality Control Board adopted Order No. 09-0057, a new Ventura Countywide Municipal Separate Storm Sewer NPDES Permit (“Permit”), which became active on August 7, 2009. Within the provisions of this Permit, are numerous changes to the regulatory framework governing the review and approval process of assessing new development projects for surface water quality concerns under CEQA.

Page 74, Section V. 2. of the Permit, requires that storm water quality management be considered when certain elements of a General Plan are updated. Specifically, the Permit reads as follows:

2. General Plan Update (a) Each Permittee shall amend, revise or update its General Plan to include watershed and storm water quality and quantity management considerations and policies when any of the following General Plan 1 elements are updated or amended: (1) Land Use (2) Housing (3) Conservation (4) Open Space

(b) Each Permittee shall provide the Regional Water Board with the draft amendment or revision when a listed General Plan element or General Plan is noticed for comment in accordance with Cal. Govt. Code § 65350 et seq.

As such, it is highly recommended that these new requirements be addressed within the specific plans’ CEQA documents.

Impact Sciences, Inc. 11.0-67 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 11.0 Response to Comments

Letter Number 7. Ventura County Watershed Protection District, Water & Environmental Resources Division, dated January 7, 2010. Response 7-1

The comment has been noted. The regulatory setting within Section 4.7, Hydrology and Water Quality, has been updated to reflect the current regulations regarding General Plan updates and the consideration of storm water quality management policies within the Land Use, Housing, Conservation, and Open Space Elements.

Impact Sciences, Inc. 11.0-68 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 Letter No. 8

Ventura County Watershed Protection District Advanced Planning Section (Floodplain Management)

MEMORANDUM

DATE: January 7, 2010

TO: Laura Hocking, RMA - Planning Division

FROM: Brian Trushinski, WPD – Floodplain Management

SUBJECT: RMA 09-059 City of Simi Valley Lost Canyon Draft EIR

The Advanced Planning Section of the Ventura County Watershed Protection District (Floodplain Management) has reviewed the Draft EIR for Whiteface Specific Plan Amendment 6: Lost Canyons Draft EIR and offers the following comment:

1. Any ‘Development’, as defined in Title 44 Code of Federal Regulations, Sections 59 and 60, that is proposed within the jurisdictional boundaries of the Unincorporated Ventura County shall be subject to obtaining a Floodplain 1 Development Permit from the County of Ventura Public Works Agency, prior to the issuance of other County or City permits on said lands.

Impact Sciences, Inc. 11.0-69 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 11.0 Response to Comments

Letter Number 8. Ventura County Watershed Protection District, Advanced Planning Section, dated January 7, 2010. Response 8-1

The Code of Federal Regulations (CFR), Title 44, Section 59, Development refers to any man-made change to improved or unimproved real estate, including but not limited to buildings or other structures, mining, dredging, filling, grading, paving, excavation or drilling operations or storage of equipment or materials.

In the event that any development, as defined by CFR, Title 44 Section 59, occurs within the jurisdictional boundaries of the unincorporated Ventura County, the applicant shall obtain a Floodplain Development Permit from the County of Ventura Public Works Agency, prior to the issuance of grading permits.

Impact Sciences, Inc. 11.0-70 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 Letter No. 9

United States Department of the Interior

FISH AND WILDLIFE SERVICE Ventura Fish and Wildlife Office 2493 Portola Road, Suite B Ventura, California 93003

IN REPLY REFER TO: 81440-2010-CPA-0039 January 27, 2010

Lauren Funaiole, Senior Planner Department of Environmental Services City of Simi Valley 2929 Tapo Canyon Road Simi Valley, California 93063-2100

Subject: Comments on the Draft Environmental Impact Report for the Lost Canyons Project, Simi Valley, Ventura County, California (SP-S-13 AMD-6/GPA-77/ Z-S-634)

Dear Ms. Funaiole:

This letter responds to your request for comments on the draft Environmental Impact Report (DEIR) for the subject project. The area proposed for development is approximately 1,770 acres within Dry and Tapo Canyons, Simi Valley. The DEIR describes the project proposal as a master planned gated community of private open space, multipurpose public recreation trails and trail head, a private park, a maximum of 364 single-family detached dwellings, deletion of one existing public golf course in Dry Canyon, and the conversion of an existing 18-hole public golf course in Tapo Canyon to a private golf course. The converted Tapo Canyon golf course would also include a practice facility, a new or expanded private clubhouse with 25 attached membership suites, pro shop, spa, pool, fitness center, tennis facilities, restaurant, cart barn, and maintenance facility. Additional project activities include a residential sales office and ancillary community serving retail uses (thematic general store and daycare of not more than 6,000 square feet), private streets, gated emergency vehicle access connections to Anderson Drive, Ditch Road/Presidio Drive, and Bennett Road, widening of Lost Canyons Drive and Tapo Canyon Road, water, sewer, drainage, and other infrastructure improvements.

The U.S. Fish and Wildlife Service’s (Service) responsibilities include administering the Endangered Species Act of 1973, as amended (Act), including sections 7, 9, and 10. Section 9 of the Act and its implementing regulations prohibits the taking of any federally listed endangered or threatened species. Section 3(18) of the Act defines “take” to mean “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.” Service regulations (50 CFR 17.3) define “harm” to include significant habitat modification or degradation which actually kills or injures wildlife by significantly impairing essential behavioral patterns, including breeding, feeding or sheltering. Harassment is defined by the Service as an intentional or negligent action that creates the likelihood of injury to wildlife by annoying it to such an extent as to significantly disrupt normal behavioral patterns which

Impact Sciences, Inc. 11.0-71 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 Lauren Funaiole 2

include, but are not limited to, breeding, feeding, or sheltering. The Act provides for civil and criminal penalties for the unlawful taking of listed species. Exemptions to the prohibitions against take may be obtained through the Service in two ways: through interagency consultation for projects with Federal involvement pursuant to section 7, or through the issuance of an incidental take permit under section 10(a)(1)(B) of the Act.

As it is not our primary responsibility to comment on documents prepared pursuant to the California Environmental Quality Act (CEQA), our comments on the DEIR do not constitute a full review of project impacts. We are providing our comments based upon a review of sections addressing biological resources, project activities that have potential to affect federally listed species, and our concerns for listed species within our jurisdiction related to our mandates under the Act. Based upon our review of the DEIR, we have the following comments:

1) We believe the proposed project is located within designated critical habitat for the coastal California gnatcatcher (Polioptila californica californica) (72 FR 72009). We recommend you address any potential affects to designated critical habitat for federally listed species. Please note that filling of the unnamed drainages onsite may fall within the U.S. Army Corp’s of Engineer’s 1 (Corps) jurisdiction. We recommend that you work with the Corps to determine if consultation pursuant to section 7 of the Act for potential adverse effects to listed species or designated critical habitat is warranted.

2) The DEIR states that focused protocol surveys for the coastal California gnatcatcher on the project site were conducted in 2008. The surveys conducted are more than 1 year old and are no longer valid for determining the presence or absence of the coastal California gnatcatcher. Because the coastal California gnatcatcher is known to be in the vicinity of the project site, has recently been observed in locations previously considered unoccupied, and according to the 2 DEIR, has been documented within the grading limits of the project area, we recommend that surveys according to the Service protocol are conducted for the coastal California gnatcatcher within the proposed project site at least once more within 1 year of any proposed ground breaking activities. Survey protocols can be accessed via the following website link: http://www.fws.gov/ventura/sppinfo/protocols/coastal-gnatcatcher_survey-guidelines.pdf.

3) The DEIR states that rare plant surveys were performed on the project site on May 22, 24, and 25, 2007. We recognize these surveys were conducted during the spring when both annual and perennial plant species are detectable. However, the DEIR notes that these surveys were conducted during a drought following the 2006/2007 rainy season. Therefore, we recommend additional spring surveys are conducted following a rainy season when at least average rainfall occurs. The project area could support federally listed plants such as, but not limited to, the 3 endangered Braunton’s milkvetch (Astragalus brauntonii), Lyon’s pentachaeta (Pentachaeta lyonii), and Slender-horned spineflower (Dodecahema leptoceras), and also the Federal candidate San Fernando Valley spineflower (Chorizanthe parryi var. Fernandina). We are enclosing a copy of the Service’s guidelines for conducting and reporting botanical inventories for federally listed, proposed, and candidate plants.

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4) It is difficult for us to determine from the information within the DEIR whether vernal pools may or may not be present within the project area. We are aware of other vernal pools in the general region some of which have been missed during surveys in dry years. Federally listed species such as, but not limited to, the federally endangered longhorn fairy shrimp (Branchinecta longiantenna), Riverside fairy shrimp (Streptocephalus woottoni), vernal pool tadpole shrimp 4 (Lepidurus packardi), and the federally threatened vernal pool fairy shrimp (Branchinecta lynchi) may occur within the project area if vernal pools are present. Therefore, we recommend surveys for vernal pools and their associated flora and fauna are conducted after a rainy season when the likelihood of any vernal pools, if present, would be filled.

Again, this letter does not reflect a comprehensive project review on our part; however, we believe that if any federally listed species are present within the proposed project site, project development could result in take of this species. Therefore, we encourage the city of Simi Valley and the applicant to work with us to ensure compliance with the Act either through consultation or preparation of a habitat conservation plan and issuance of an incidental take permit. It should be noted that even with the incorporation of mitigation measures pursuant to the California Environmental Quality Act, any take of federally listed animal species would require exemption pursuant to section 7 or authorization pursuant to section 10 of the Act.

Lastly, we recommend that you review information in the California Department of Fish and Game’s (CDFG) Natural Diversity Data Base and that you contact the CDFG at (916) 324-3812 for information on other species of concern that may occur in this area. We appreciate the opportunity to provide comments on the DEIR and look forward to working with the city of Simi Valley in the future. If you have any questions, please contact Robert McMorran of our staff at (805) 644-1766, extension 232.

Sincerely,

/s/: Chris Dellith

Chris Dellith Senior Biologist

Impact Sciences, Inc. 11.0-73 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed, Proposed and Candidate Plants

These guidelines describe protocols for conducting botanical inventories for federally listed, proposed and candidate plants, and describe minimum standards for reporting results. The Service will use, in part, the information outlined below in determining whether the project under consideration may affect any listed, proposed, or candidate plants, and in determining the direct, indirect, and cumulative effects.

Field inventories should be conducted in a manner that will locate listed, proposed, or candidate species (target species) that may be present. The entire project area requires a botanical inventory, except developed agricultural lands. The field investigator(s) should:

1. Conduct inventories at the appropriate times of year when target species are present and identifiable. Inventories will include all potential habitats. Multiple site visits during a field season may be necessary to make observations during the appropriate phenological stage of all target species.

2. If available, use a regional or local reference population to obtain a visual image of the target species and associated habitat(s). If access to reference populations(s) is not available, investigators should study specimens from local herbaria.

3. List every species observed and compile a comprehensive list of vascular plants for the entire project site. Vascular plants need to be identified to a taxonomic level which allows rarity to be determined.

4. Report results of botanical field inventories that include:

a. a description of the biological setting, including plant community, topography, soils, potential habitat of target species, and an evaluation of environmental conditions, such as timing or quantity of rainfall, which may influence the performance and expression of target species

b. a map of project location showing scale, orientation, project boundaries, parcel size, and map quadrangle name

c. survey dates and survey methodology(ies)

d. if a reference population is available, provide a written narrative describing the target species reference population(s) used, and date(s) when observations were made

e. a comprehensive list of all vascular plants occurring on the project site for each habitat type

Impact Sciences, Inc. 11.0-74 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 f. current and historic land uses of the habitat(s) and degree of site alteration

g. presence of target species off-site on adjacent parcels, if known

h. an assessment of the biological significance or ecological quality of the project site in a local and regional context

5. If target species is (are) found, report results that additionally include:

a. a map showing federally listed, proposed and candidate species distribution as they relate to the proposed project

b. if target species is (are) associated with wetlands, a description of the direction and integrity of flow of surface hydrology. If target species is (are) affected by adjacent off-site hydrological influences, describe these factors.

c. the target species phenology and microhabitat, an estimate of the number of individuals of each target species per unit area; identify areas of high, medium and low density of target species over the project site, and provide acres of occupied habitat of target species. Investigators could provide color slides, photos or color copies of photos of target species or representative habitats to support information or descriptions contained in reports.

d. the degree of impact(s), if any, of the proposed project as it relates to the potential unoccupied habitat of target habitat.

6. Document findings of target species by completing California Native Species Field Survey Form(s) and submit form(s) to the Natural Diversity Data Base. Documentation of determinations and/or voucher specimens may be useful in cases of taxonomic ambiguities, habitat or range extensions.

7. Report as an addendum to the original survey, any change in abundance and distribution of target plants in subsequent years. Project sites with inventories older than 3 years from the current date of project proposal submission will likely need an additional survey. Investigators need to assess whether an additional survey(s) is (are) needed.

8. Adverse conditions may prevent investigator(s) from determining presence or identifying some target species in potential habitat(s) of target species. Disease, drought, predation, or herbivory may preclude the presence or identification of target species in any year. An additional botanical inventory(ies) in a subsequent year(s) may be required if adverse conditions occur in a potential habitat(s). Investigator(s) may need to discuss such conditions.

Impact Sciences, Inc. 11.0-75 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 9. Guidance from California Department of Fish and Game (CDFG) regarding plant and plant community surveys can be found in Guidelines for Assessing the Effects of Proposed Developments on Rare and Endangered Plants and Plant Communities, 1984. Please contact the CDFG Regional Office for questions regarding the CDFG guidelines and for assistance in determining any app

Impact Sciences, Inc. 11.0-76 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 11.0 Response to Comments

Letter Number 9. United States Department of Interior, Fish and Wildlife Service (USFWS), dated January 27, 2010 Response 9-1

The comment states that the project site is located within the designated critical habitat for the Federally Threatened coastal California gnatcatcher. Protocol surveys following USFWS parameters and habitat suitability evaluation for coastal California gnatcatcher were conducted for the biological resources assessment in the Draft EIR. Upon evaluation of the habitat, surrounding land uses and the negative results from the protocol surveys, the Draft EIR concluded that the species is not expected to occur on the project site. Development of the project site would not jeopardize the long term viability of the coastal California gnatcatcher because the project site is not currently used by the species nor is the species expected to make use of the habitat because the area has been used for decades for agricultural uses.

A federal action of issuance of a Section 404 permit to be granted by the U.S. Army Corps of Engineers (USACE) may require Section 7 consultation with the USFWS under the federal Endangered Species Act (ESA). The project proponent will work with the USACE to ensure compliance with the federal ESA.

Response 9-2

The comment states that protocol surveys for wildlife species are considered valid for one year. This comment also misstates that the Draft EIR reports that the coastal California gnatcatcher has been documented within the grading limits of the proposed project area. On the contrary, the Draft EIR states that protocol surveys were conducted in spite of the species having a low potential to occur on the project site because only marginally suitable habitat is present. The negative results of the protocol surveys indicating that the species was not observed corroborate the assessment that there is only a low potential for the species to occur on the project site. As the protocol surveys for coastal California gnatcatcher will be considered out-of-date by the USFWS when Section 7 consultation with that agency is likely to be initiated, new protocols surveys for this species will be needed for successful conclusion of the consultation process. Therefore, new surveys according to USFWS protocol for coastal California gnatcatcher shall be conducted within one year of proposed ground disturbing activities as part of the Section 7 consultation process.

Response 9-3

The comment states that the year in which focused rare plant surveys was conducted was a below average rainfall year and the results of such surveys may not accurately detect all species. The agency recommends that focused special-status plant surveys be conducted following a rainy season of at least an average rainfall amount and to follow the USFWS guidelines for conducting surveys for federally

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listed plant species. Mitigation Measure 4.3-1 requires that pre-ground disturbance surveys for special-status plant surveys be conducted during the year prior to such actions.

Response 9-4

The comment inquires whether vernal pools may be present on the project site. The experienced biologists conducting the biological surveys for special-status plant and animal species would be alert for the presence of vernal pools, as indicated by the observation of a small man-made depression by the biologist conducting the coastal California gnatcatcher surveys. No vernal pools have been reported for the project location as these would have been noticed during the various biological surveys. Additionally, the numerous biological surveys for the Whiteface Specific Plan did not detect the presence of vernal habitat. The applicant will comply with the federal ESA regarding listed fairy shrimp species should suitable and appropriate habitat be determined to occur on the project site during any follow up biological surveys required by the project mitigation measures.

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Impact Sciences, Inc. 11.0-79 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 11.0 Response to Comments

Letter Number 10. JemStreet Properties, Inc., dated January 25, 2010 Response 10-1

The comment is noted and does not pertain to the adequacy or completeness of the Draft EIR. No further response is required.

Impact Sciences, Inc. 11.0-80 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 Letter No. 11

Impact Sciences, Inc. 11.0-81 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 Impact Sciences, Inc. 11.0-82 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 11.0 Response to Comments

Letter Number 11. State of California, Governor’s Office of Planning and Research, State Clearinghouse, dated January 28, 2010 Response 11-1

The Office of Planning and Research (OPR) notes that the City of Simi Valley has complied with State Clearinghouse review requirements. This comment is acknowledged. Because this comment does not address the content of the Draft EIR, no further response is required.

Impact Sciences, Inc. 11.0-83 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 Letter No. 12

Impact Sciences, Inc. 11.0-84 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 11.0 Response to Comments

Letter Number 12. State of California, Governor’s Office of Planning and Research, State Clearinghouse, dated January 29, 2010 Response 12-1

The letter also notes that one state agency, the California Department of Fish and Game, submitted comments to the OPR after the end of the state review period. These comments are provided in Letter Number. 13.

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Impact Sciences, Inc. 11.0-87 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 Impact Sciences, Inc. 11.0-88 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 11.0 Response to Comments

Letter Number 13. California Natural Resources Agency, Department of Fish and Game, dated January 29, 2010. Response 13-1

The comment references the CDFG California Wildlife Action Plan in which wildlife stressors affecting behavior and habitat are identified. The comment does not question the adequacy of the Draft EIR and no further response is needed.

Response 13-2

The comment states the CDFG concurrence with the mitigation measures recommended in the Draft EIR. The comment does not question the adequacy of the Draft EIR, but to the contrary recognizes the analysis as being thorough. No further response is needed.

Response 13-3

The comment recommends that protocol surveys for both the coastal California gnatcatcher and burrowing owl be conducted prior to project implementation. Protocol surveys for the coastal California gnatcatcher have been conducted without detecting the presence of the species. While formal protocol surveys for burrowing owl were not conducted, the several biological surveys for the Whiteface Specific Plan and the current Lost Canyon project would have detected evidence burrowing owl within the proposed development area. Mitigation Measure 4.3-4 requires nesting bird surveys to be conducted prior to grading or construction activities and Mitigation Measure 4.3-5 requires pre-construction surveys for special-status wildlife species. Mitigation Measure 4.3-5 has been modified to specifically include surveys for burrowing owl. In addition, language has been to this mitigation measure in the event that coastal California gnatcatcher is discovered on the project site.

The revised mitigation measure is as follows:

4.3-5 The applicant shall retain a qualified biologist to conduct pre-construction surveys no more than 30 days prior to construction activities on the proposed project site within the proposed development areas and 500 feet beyond the grading limits for the presence of those special-status wildlife species with the potential to occur in on-site habitats that will be directly impacted by project activities. The qualified biologist shall possess a CDFG Scientific Collection Permit and obtain a CDFG Authorization prior to the implementation of pre-construction surveys. Surveys shall include an examination of all areas where ground disturbance may occur. For burrowing owl, the surveys shall consist of three site visits and shall be conducted in areas dominated by field crops, disturbed habitat, and grasslands.

Impact Sciences, Inc. 11.0-89 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 11.0 Response to Comments

If any animal species is observed on the project site during clearance surveys, potential loss of individual animals shall be mitigated by (1) ensuring that construction activities do not enter the specific area in which the individual was observed until the individual has been observed vacating the area and moving into habitat that will not be directly impacted by project activities, or (2) through capture or an active trapping and relocation program, conducted by a qualified biologist and in coordination with the CDFG, that will move individuals to suitable on-site habitat that will not be directly impacted by project implementation. Surveys shall occur within one day prior to the areas where impacts (i.e., ground disturbance, grading of access roads and staging areas, trenching, etc.) would occur.

If a burrowing owl is located, occupied burrows shall not be disturbed during the nesting season (February 1 through August 31) unless a qualified biologist approved by CDFG verifies through non-invasive methods that either the birds have not begun egg-laying and incubation or that juveniles from the occupied burrows are foraging independently and are capable of independent survival. If a burrowing owl is detected but nesting is not occurring, construction work can proceed after any owls have been evacuated from the site using CDFG-approved burrow closure procedures and after alternative nest sites have been provided in accordance with the CDFG Staff Report on Burrowing Owl Mitigation (10-17-95). Unless otherwise authorized by CDFG, a 500-foot buffer, within which no activity will be permissible, will be maintained between Project activities and nesting burrowing owls during the nesting season. This protected area will remain in effect until August 31 or at CDFG's discretion and based upon monitoring evidence, until the young owls are foraging independently. Results of the surveys and relocation efforts shall be provided to CDFG in a mitigation status report.

If a coastal California gnatcatcher is observed, vegetation removal and clearing for the proposed project shall occur between September 1 and February 15, outside the gnatcatcher breeding season. All clearing of vegetation shall take place in the presence of a biological monitor. Prior to and during the initial cleaning and grubbing of the coastal sage scrub, or other suitable gnatcatcher habitat, between February 15 and August 31, the biological monitor shall locate any individual gnatcatchers on-site and direct operators to begin in an area away from the birds. In addition, the biological monitor shall walk ahead of clearing and grubbing equipment to flush birds towards areas of habitat that will be avoided. If nesting gnatcatchers are detected within 100 feet of proposed construction areas, gnatcatcher nest monitoring shall be initiated and use of heavy

Impact Sciences, Inc. 11.0-90 Whiteface Specific Plan Amendment 6: Lost Canyons Final EIR 0024.007 November 2010 11.0 Response to Comments

equipment within 100 feet of active nest shall be postponed until the nest(s) are determined to be inactive. If operation of grading equipment results in nest abandonment, the USFWS will be contacted immediately.

Response 13-4

The comment recommends that the designated open space area be conserved in perpetuity through the use of a conservation easement. The City supports the use of conservation easements for open space areas and will be pleased to work with CDFG on language of a conservation easement should the City Council include this as a condition of approval.

Response 13-5

The comment recommends that the applicant coordinate with the CDFG for confirmation of the project delineation of CDFG wetland areas. The City concurs that this is appropriate and will encourage the applicant to meet early with CDFG on the processing of a streambed alteration agreement.

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STATE OF CALIFORNIA—THE RESOURCES AGENCY ARNOLD SCHWARZENEGGER, Governor SANTA MONICA MOUNTAINS CONSERVANCY RAMIREZ CANYON PARK 5750 RAMIREZ CANYON ROAD MALIBU, CALIFORNIA 90265 PHONE (310) 589-3200 FAX (310) 589-3207

February 11, 2010

Paul Drury, Deputy Director Department of Environmental Services 3855-A Alamo Street City of Simi Valley Simi Valley, California 93063-2100

DEIR Comments Whiteface Specific Plan Amendment 6 - Lost Canyons Project SP-S-13 AMD-6/GPA-77/Z-S-634 SCH No. 2008061111

Dear Mr. Drury:

When the City of Simi Valley approved the Whiteface Specific Plan and its Final Environmental Impact Report in 1992, the project made provision for an ecologically viable open space area, located south of Lost Hills Road, and that is now composed of the 190 acres of the Dry Canyon golf course, 640 acres of designated open space, and approximately 150 acres of permanent open space from the completed Sand Canyon portion of the Specific Plan. At a minimum, this open space complex is currently a 1,000-plus-acre-habitat block that encompasses the Dry Canyon golf greens, fairways and cart paths along its western edge.

In 1992-3 the Conservancy pushed hard for this habitat block to remain well connected to the Santa Susana Mountains core habitat area. To further the planning process, the City required three specialized wildlife movement studies that forged new scientific ground. 1 Based on these reports, and the consensus of biologists involved, there was agreement that this multi-hundred-acre habitat block could sustain use by a range of target wildlife species. The dozens of acres of riparian and riparian scrub habitat in Dry Canyon are key components that allow for this ecological sustainability. In 1994 the City circulated a Supplemental EIR that includes specific wildlife corridor mitigation measures. Wildlife underpasses were integrated into the Lost Hills Road design and were subsequently built.

When all of the relevant agencies and members of the public considered the project and CEQA documents between 1992 and 1994, it was generally assumed that the designated open space represented in the FEIR, the Supplemental EIR, and the Specific Plan would be

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honored with the potential for a few small, unavoidable plan change exceptions. The DEIR does not address this issue of public expectation. It was also assumed that the “640-acre open space” area located south of Lost Hills Road would be transferred in fee simple to the 1 Rancho Simi Recreation and Park District. It has not been transfered to date and the DEIR includes no explanation for the change in direction.

This State agency falsely assumed that the open space configuration and restrictions were mitigation measures for the loss of over a thousand acres of habitat in the total Specific Plan area. We also assumed that the project was a single project under the California Environmental Quality Act in which the FEIR and FSEIR mitigation measures addressed all of the project’s impacts as proposed in the Specific Plan. The “permanent” open space “mitigation” in the adopted Specific Plan and certified FEIR and FSEIR works as a collective natural system that is oblivious to the boundaries of the different Specific Plan tracts and 2 ownerships. However, the DEIR provides zero analysis of the potential adverse ecological, recreational, and visual impacts of effectively cutting one third of this open space out of this collective natural system and effectively plopping 148 houses, 100 acres of annual brush clearance, and two miles of paved road into the otherwise natural 240 acres composing the Dry Canyon golf course. Either the proposed project violates the permanent CEQA mitigation measures in the 1992 FEIR and 1994 FSEIR or it represents a radical departure from the public perception of the approved 1992-4 land uses.

Even if the 1992 FEIR, 1994 FSEIR and Specific Plan as amended to date, provide the technical capability to eliminate 300 acres of designated natural open space and eliminate the ecological value of the 240-acre Dry Canyon golf course area, the current DEIR must specifically analyze how these broad land use changes would adversely affect the ecological capacity of the 640-acre designated natural open space represented in these 1992 and 1994 documents and the additional 340-plus acres of habitat connected to the 640 acres. The DEIR is deficient for not addressing these potential impacts to large-designated-Specific Plan open space areas located both north and south of existing Lost Hills Road. The DEIR 3 is further deficient for not addressing at all the loss of open space north of Lost Hills Road that the FEIR and FSEIR represented a key habitat element to connect the 460-acre area to core habitat offsite to the north and northwest.

The DEIR is further deficient for addressing the proposed project impacts in an ecological vacuum defined and limited by the 1,770-acre project area. For example the DEIR does not adequately analyze how the 148 new Dry Canyon homes and their commensurate two miles of roads, annual brush clearance, irrigation, house and yard lighting, pets, fencing, and utilities could adversely impact the 200-plus permanent acres of open space in the adjacent Sand Canyon tract.

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Adverse Impacts to “640-acre Open Space Area” South of Lost Hills Road

How does the proposed project affect the ecological viability of the existing 1,000-plus-acre open space area south of Lost Hills Road and more specifically the 640 acre open space area shown in the 1992 Specific Plan and FEIR? The attached figure shows the proposed reduction in both this dedicated 640-acre area and the elimination of all but about 40 acres of designated open space north of Lost Hills Road.

The proposed Specific Plan Amendment would essentially transfer 148 homes, and overlay two miles of road network and formal recreation fields into the Dry Canyon portion of this 1,000-acre habitat block. In addition it would transfer a minimum, of 13 houses near the margin of the Tapo Canyon watershed and up to 8 minimum-twenty-acre estates with their road network into the subject habitat block. It also appears that a five-acre dam and 4 retention area will also be built in this habitat area. In addition there are undefined trail and equestrian uses proposed with the project.

Furthermore, with the proposed project, the prime identified (“C”) wildlife corridor (across Lost Hills Road) between the Santa Susana Mountains core habitat and the subject habitat block would be severed in regards to a direct natural lands connection. The DEIR fails to specifically address adverse impacts to this wildlife corridor C. How can EIR mitigation measures, in the form of open space set asides and road undercrossings, be severely compromised by new development not contemplated in the prior certified CEQA documents?

Understandably these 148 + 13 + 8 units would be pulled out of approved sites located north of Lost Hills Road in the Tapo Canyon watershed. However, those units were approved to be mixed in and clustered with the existing Tapo Canyon golf course. Under any and all circumstances, the ecological impact of clustering at least 350 houses within an 5 existing golf course is much less than the proposed project. The proposed project expands the permanent total ecological impact area by approximately 350 acres and completely “de- clusters” the project by spreading over 250 units into disturbance areas not contemplated in the approved Specific Plan or its FEIR. The DEIR is deficient for not acknowledging or addressing this difference.

The acres of “special concern” and “sensitive” habitat types that the proposed project would eliminate completely illuminates this point directly above. The proposed project 6

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would eliminate 389.64 acres of coastal sage scrub onsite and another 26.22 acres offsite. The proposed project would eliminate 49.74 acres of riparian habitat (17.53 acres of riparian scrub and 32.21 acres of southern willow scrub) in Dry Canyon and almost seven

additional acres towards Tapo Canyon. These impacts are avoidable and the DEIR is deficient for not addressing how they can be avoided.

A project (Specific Plan Amendment) that would result in a minimum direct loss of 400 acres of coastal sage scrub and 50 acres of riparian habitat poses several distinct biological impacts that cannot be mitigated to a level less than significant. Loss of that much acreage 6 of either habitat type is an unavoidable significant adverse impact. The DEIR is deficient for concluding that the proposed project would not result in unavoidable significant adverse ecological impacts.

The DEIR conclusion that the permanent loss of 400 acres of coastal sage scrub is rendered to a level less than significant with absolutely no mitigation just because that loss would not push any special status animal or plant species below self sustaining levels is deficient. The Conservancy hopes the planning staff, Planning Commission and City Council will not accept that conclusion. It would have far reaching extenuating effects detrimental to the public.

Typically the California Department of Fish and Game and the Army Corps of Engineers require high mitigation ratios for the loss of riparian habitat. Typical permits require 3:1 replacement ratios. These agencies will not look favorably on the greatly avoidable loss of 50 acres of riparian habitat. Even if the agencies just required a 1:1 replacement ratio the applicant would need to restore fifty acres of riparian habitat. Given that the project eliminates all the restorable riparian habitat within the 1,770-acre project area, where will the applicant find fifty acres to restore? As part of the Conservancy’s ten-year-old riparian in lieu mitigation program set up with the Army Corps, our staff has found it increasingly 7 difficult to find even one acres sites in the Arroyo Simi watershed to first acquire a land interest in and then conduct riparian restoration. Given a 2:1 replacement ratio and the applicant squeezing 10 acres of mitigation into the project site, the applicant would have to find 90 acres of riparian habitat and then pay over $150,000 per acre to restore the land. No other project has attempted mitigation of this magnitude and every day the amount of acquirable and restorable riparian habitat becomes less. This proposed mitigation measure is not feasible or good public policy. To defer the identification and feasibility of potential mitigation sites leaves the DEIR further deficient.

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The entire loss of the Dry Canyon riparian corridor represents the functional loss of an entire Arroyo Simi tributary habitat.

The applicant’s whole justifying premise is that the golf greens and fairways in Dry Canyon are mostly “already graded” and developed and thereby meet the objectives of the Specific Plan by having minimal impact on the environment. How can putting 148 homes in an area 8 that is functionally used by mountain lions at night not be an unavoidable significant adverse impact? An inadequacy of this argument is that the area where the homes would be removed from in Tapo Canyon would still have over a hundred homes spread over it. With these many homes, it would not have the same ecological capacity of the Dry Canyon golf course which has no homes around it.

For the proposed project and the Reduced Density Alternative the DEIR must address what the habitat capability will be for mountain lions, grey foxes, American badgers, and bobcats 9 in the open space area south of Lost Hills Road.

The DEIR must analyze how the proposed homes Dry Canyon would directly and indirectly adversely impact protected habitat from the adjacent Sand Canyon tract to the west. 11

Issues to Address in the FEIR

The Conservancy takes the position that the current DEIR is deficient in many areas addressed in this letter and that the document must be revised and recirculated per these stated deficiencies. However, if the City proceeds with a FEIR, we respectfully request that the preceding and following issues be analyzed and addressed. 12

First given the project description, project objectives, and mitigation measures in the certified 1992 FEIR and the Specific Plan as amended to date, the FEIR should explain the City’s technical and CEQA capability to eliminate 300 acres of designated natural open space and eliminate the ecological value of the 240-acre Dry Canyon golf course area.

When was the large dam area at most downstream part of Dry Canyon in the project area addressed by a CEQA review? If so the FEIR must state what CEQA document it was reviewed 13

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under. If it was not already addressed in a post-1992 CEQA document, it should be addressed as part of the proposed project. If the dam is not going to be built, how will runoff be detained from the 148 houses proposed in Dry Canyon? Are the structures 13 necessary to detain that runoff explicitly identified, located, and analyzed for potential impacts in the DEIR?

The DEIR should address what changes need to be made in the existing Development Agreement to permit the construction of the proposed project and Less Dense Alternative projects. 14 For the proposed project and the Reduced Density Alternative the DEIR must address what the habitat capability will be for mountain lions, grey foxes, American badgers, and bobcats in the open space area south or Lost Hills Road.

The DEIR must show the layout of the proposed 20-acre estates. The project description shall otherwise remain inadequate. The DEIR must address if any of the 20 acres estates will result in brush clearance requirements on the proposed designated open space. The DEIR 15 will remain inadequate until it provides figures on how much habitat will be directly and indirectly impacted by the estate complexes and their access road system. Grading figures must also be included in the DEIR.

The DEIR must analyze how the proposed homes Dry Canyon would directly and indirectly adversely impact protected habitat from the adjacent Sand Canyon tract to the west. 16 The DEIR is deficient for not quantifying potential fuel modification impacts for the proposed project or the Reduced Density Alternative for the proposed 148 homes in Dry Canyon.

The DEIR is deficient for not addressing the loss of perennial water sources in Dry Canyon addressed both in the DEIR appendices and in the December 1993 Envicom report, entitled, 17 A Study of Wildlife Movement in Dry Canyon.

The DEIR is deficient for not addressing how the loss of the identified spadefoot toad population could affect push a special status animal species below self sustaining levels in 18 an eight mile radius.

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The DEIR is deficient for not specifically addressing the loss of habitat connectivity between the identified 1000-plus acres of onsite habitat south of Lost Hills Road and the year-round water sources of Tapo Creek.

The DEIR is deficient for not specifically addressing the loss of habitat connectivity across 19 Lost Hills Road between core habitat north of the road and the 1000-plus acres of contiguous open space located south of the road within the Specific Plan area. For example, with the proposed project, animals at a minimum will have to cross over two paved roads to get between these two key habitat blocks.

What will the effects of future proposed equestrian uses be on the 640 acre habitat area set 20 aside in the original 1992-4 approved project?

The basis for slope analysis calculations must be pre-1987, not post-grading for the golf 21 courses. To do otherwise is CEQA piecemealing.

Wildlife Corridor Impacts

The one July 1993 Michaeal Brandman Associates wildlife movement study for Sand Canyon and the two Envicom (February and December, 2003) wildlife movement studies for the Santa Susana Mountains and Dry Canyon lay the groundwork for the importance of the subject habitat block in the Santa Susana Mountains ecosystem. The Draft Enviromental Impact Report (DEIR) does not specifically address the December 1993 Envicom report, entitled, A Study of Wildlife Movement in Dry Canyon. This last study was part of the City’s file for Case Nos. PDS-S-889/TT5165 and PDS-S-903/TT5244 and is hereby 22 incorporated into this letter by reference.

The DEIR includes one figure that shows the wildlife corridors identified in these studies. The DEIR includes no site specific or guaranteed mitigation measures to permanently protect the identified wildlife corridors. The DEIR includes only vague non-site specific mitigation measures could be interpreted a thousand different ways and are deficient. The DEIR does not show how the wildlife corridor mitigation measures are feasible.

The DEIR shall be deficient until there is an accurately mapped habitat linkage plan with guaranteed protection measures, otherwise the mitigation is deferred.

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The DEIR mitigation measures for wildlife corridors rely too much on the future wisdom and scientific knowledge of the Planning Director. 22 To meet the intent of the Specific Plan all open space should first be offered to a public agency. No matter what all open space areas must be protected by a third party restrictive conservation easement.

Need for Additional Site Specific Wildlife Corridor Mitigation Measures

The proposed project would sever connectivity between the open space south of Lost Hills Road through DEIRWildlife Corridor C to the already protected Sand Canyon open space. The protection of DEIR Wildlife Corridor C was secured in the 1992-94 City approvals. Any project that adversely impacts Wildlife Corridor C violates an existing CEQA mitigation measure. The DEIR fails to disclose this inconsistency.

The FEIR must include a project design that does not compromise Wildlife Corridor C and includes adequate mitigation measures that assure permanent protection of the existing 23 wildlife corridor capacity.

The FEIR must also include a project design that does not compromise DEIR Wildlife Corridor F and includes adequate mitigation measures that assure permanent protection of the existing wildlife corridor capacity. The FEIR must address how the proposed project, and any relevant alternative projects, benefit or detract from the wildlife movement capacity between 1,000 acres of onsite open space located south of Lost Hills Road and Tapo Creek. This analysis much show direct spatial comparison between projects and actual proposed permanently-protected corridor routes. To guarantee adequate permanent protection, there must be mitigation measures that offer conservation easements and fee simple dedication of open space to public agencies over all portions of these wildlife corridors. Said dedications must occur prior to map recordation to provide adequate mitigation.

The FEIR must specifically address the wildlife corridors shown in Figure 9 of the December 24 1993 Envicom report, entitled, A Study of Wildlife Movement in Dry Canyon.

The FEIR must show where any utility or future road easements cross any wildlife corridor 25 in the subject project area.

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Please direct all questions and future documents to Paul Edelman of our staff at the above letterhead address and by phone at 310-589-3200 ext. 128.

Sincerely,

RONALD P. SCHAFER Chairperson

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Letter Number 14. Santa Monica Mountains Conservancy, dated February 11, 2010. Response 14-1

The comment presents the understanding of the Santa Monica Mountains Conservancy (SMMC) of the environmental review and approval process for the Whiteface Specific Plan. This comment suggests that the 190-acre Dry Canyon golf course, the 640-acre open space area, and the 150 acres of open space in Sand Canyon to the west all function together ecologically as a greater than 1,000 acre habitat block. However, this position is not supported upon closer review of these three areas. The Dry Canyon golf course provides limited wildlife habitat because there is little vegetation for herbivore foraging and the lack of vegetative cover would make many species vulnerable to predation. Therefore, the golf course would at best function as habitat linkage between the designated open space area on the east and the small island of natural habitat remaining in the Sand Canyon development to the west. The habitat value of this island of habitat in Sand Canyon is diminished by the surrounding developed areas, and the associated indirect impacts, such as residential night lighting and intrusion by domestic pets. As a result, the 640-acre open space area between Dry and Tapo Canyons provides a habitat refuge for wildlife remaining in this small area after development of the golf course within the canyons to the west and to the north, and for wildlife that may gain access to this area through the wildlife corridors included in the Whiteface Specific Plan.

The 640-acre open space area referred to in this comment is designated as open space in the Whiteface Specific Plan, and intended for multiple uses including recreation, and for the protection of biological, cultural, and other natural resources. This area was not dedicated for permanent preservation. It should be noted that preservation of this area was not required by a mitigation measure in the Whiteface Specific Plan environmental impact report (EIR) to mitigate the impact of the proposed development in other portions of the Specific Plan Area. On the contrary, the EIR evaluated the potential impacts of this open space design and identified the preservation of four corridors to provide access to this area to preserve its ecological functions.

The 1995 certified Supplement to the Final Subsequent EIR states on Page IV.C-3: “The objective of the 640-acre open space area is to establish a series of corridors that would provide safe passage for target species while minimizing external intrusions that would likely impact wildlife behavior and populations.” The conservation issues associated with the location and configuration of this open space area was addressed through the mitigation measure protecting the four wildlife corridors recommended in the Envicom study.5 This mitigation was required because the development of both recreational and residential uses in both Dry and Tapo Canyons would result in a “… barrier to the current migration of

5 Envicom Corporation, A Consideration of Wildlife Movement in the Santa Susana Mountains, February 1993. and Envicom Corporation, A Study of Wildlife Movement in Dry Canyon, December 1993.

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wildlife on site.” Implementation of the recommended mitigation measures to create and preserve wildlife corridors throughout the project area would reduce potential impacts in this regard to a less than significant level.” This information makes it clear that development of recreational uses, specifically a golf course in Dry Canyon, was identified as an impact of the project as opposed to the golf course being considered an open space area with value for wildlife movement to other open space areas.

Response 14-2

The comment presents the understanding of the SMMC that the designation of the 640-acre open space area was a component of the mitigation for the change in land use designations authorized in the approved Specific Plan. The 1992 Final Subsequent EIR concluded that impacts to biological resources were an unavoidable significant impact, and the preservation of the designated open space areas identified in the Specific Plan was partial mitigation for these impacts. The 1995 certified Supplement to the Final Subsequent EIR states “Mitigation of adverse environmental impacts associated with the approved Whiteface Specific Plan (PD-S-828) for site development in Tapo and Dry Canyon includes the designation of approximately 640 acres as an open space reserve between Tapo Canyon on the east, and Dry Canyon to the west.” (Page IV.C-2) In accordance with the requirements set forth in the 1995 certified Supplement to the Final Subsequent EIR, the proposed project would designate 500 acres of open space in Dry and Tapo Canyons and would provide wildlife corridors to the remaining 140 acres of open space to the north of the specific plan boundary.

The incorporation of wildlife corridors into the Whiteface Specific Plan provided sufficient mitigation to maintain the ecological utility of the designated open space area connected to the large habitat block to the north of the specific plan boundary. With the implementation of the recommended wildlife corridors, impacts were found to be less than significant. The preservation of additional open space areas was not required as a mitigation measure and, for this reason, allowing the existing golf course to be replaced with residential development would not be inconsistent with any adopted mitigation measure for the Whiteface Specific Plan.

The comment also states that the Draft EIR provides no analysis of the potential adverse ecological, recreational, and visual impacts of the proposed land use changes from recreational to residential uses in Dry Canyon. The Draft EIR includes sections on aesthetics (Section 4.1), biological resources (Section 4.3), and recreation (Section 4.15). Contrary to the comment, an analysis of the proposed project, including the proposed amendment to the Specific Plan, is the subject of analysis in the Draft EIR.

Response 14-3

The comment indicates that the Draft EIR is deficient for not analyzing potential impacts to the open space areas of the Specific Plan and doing so in an “ecological vacuum.” As discussed in Responses 14-1

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and 14-2 above, the open space area designated in the Specific Plan contains substantial wildlife habitat value but the area was not designated as a natural wildlife reserve as is indicated in the comment. The Specific Plan recognizes the open space only as “Public Open Space,” within which a network of hiking and equestrian trails would be constructed by the Rancho Simi Park and Recreation District. Additionally, this open space area was planned to be surrounded by urban uses. The Dry Canyon golf course is identified in the Specific Plan as 173.5-acre public golf course to be surrounded with residential lots. The Draft EIR provides an analysis of potential impacts to wildlife movement and concludes that development of the proposed project would not prevent access for mountain lion, bobcat, American badger, mule deer, or any other mammal species to the regional wildlife movement corridors in the Santa Susana Mountains to the north of the Specific Plan area with the implementation of the mitigation measures for wildlife corridors. Further, the Draft EIR acknowledges that the project site contributes to the overall success of the inter-mountain linkages to the north by acting as a source of species and by providing required habitat including water, cover, and food.

Contrary to the comment that the open space north of Lost Hills Road represented a key element to connect the area to core habitat off site to the north and northwest, the focus of the environmental review of the Whiteface Specific Plan was on preventing isolation of the 640 acre open space area south of Lost Hills Road, as described above, by preserving corridors for wildlife to access this area.

The Draft EIR analyzes potential impacts from the project design, including to current open space areas, as this is the primary role of the document. Contrary to this comment, the Draft EIR does not address the potential impacts in a vacuum, but instead includes discussion of cumulative impacts and impacts to off-site areas, for example, the roadway intersections providing circulation access to the project site. For example, the Biological Resources section includes analysis of indirect impacts starting on Page 4.3-54 in which impacts associated with domestic pets, invasive species, and increase in human-tolerant species, light and glare, short-term construction related impacts, all of which have the potential to impact not only the proposed project but adjacent areas such as in Sand Canyon.

Response 14-4

The comment presents an opinion that the ecological viability of the 640-acre open space area will be compromised as a consequence of the proposed project. The Draft EIR makes a similar conclusion that open space areas adjacent to developed areas will be impacted by the proximity to urban features such as roadways, homes, and fuel modification. The figure provided with the comment letter by the SMMC, which shows the proposed reduction in open space areas, the majority of which resulting from the rural density of the estate lots.

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Within the 537 acres designated for estate lots, a maximum of 16 lots with a minimum lot size of 20 acres would be permitted. These estate lots will not be fully developed under the proposed development standards. On each 20-acre parcel size, the area impacted would be limited to 5 to 6 acres, including required fuel modification. The worst case impact for the estate land use would be approximately 100 acres or less, leaving the remaining 437 acres as natural undeveloped vegetation. It can conservatively be concluded that over 900 acres of natural open space will remain within the Specific Plan Area with the implementation of the proposed project.

The core of the 640-acre open space area will stay intact and the movement corridors identified in the 1995 certified Supplement to the Final Subsequent EIR and in the Draft EIR will also remain and continue to provide linkage to remaining natural areas to the west, north, and east, including Corridor C, which maintains a linkage to the north using the undercrossings along Lost Canyon Drive within Sand Canyon. The movement corridors as previously identified in 1995 and incorporated into the Whiteface Specific Plan still provide a viable connection to the regional movement corridor located north of the Specific Plan Area (Draft EIR page 4.3-73 to 4.3-74).

Response 14-5

The comment indicates the Draft EIR does not address the shifting of the approved number of residential units within Dry and Tapo Canyon from higher density land use categories within Tapo Canyon to less dense to rural areas in the proposed amended Specific Plan. The Draft EIR acknowledges that the distribution of the approved residential units will be less clustered and the estate lots will become the interface with the open space areas. As discussed in Response 14-4 above, the estate lot interface provides a buffer between the designated open space area and the areas to become urbanized. With a maximum of 16 estate lots, each with a 20-acre minimum lot size, the majority of the estate lot land use designation will remain as natural open space.

The original Whiteface Specific Plan designated about 1,154 acres as Public Open Space and the proposed amendment includes the 500 acres of Open Space and the approximately 437 acres of the Residential – Estate Lot designation, as described in Response 14-4 above, for more than 900 acres of natural open space. This total does not include the more than 200 acres of Recreational Golf Course designation. As indicated in the previous responses, the ecological function of the designated open space and the wildlife corridors will not be substantially impacted by the proposed amendment.

Response 14-6

The comment states that the coastal sage scrub habitat on site is a sensitive plant community. The site contains a total of approximately 1,380 acres of coastal sage scrub habitat. As presented in Table 4.3-1 in the Draft EIR, the coastal sage scrub on the site consists of 13 separate coastal sage scrub communities

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based on the dominate plant species in each. The habitat value of the on-site coastal sage scrub has been compromised through decades of agricultural operations on the property. In addition, none of the coastal sage scrub vegetation associations identified as occurring on the project site are recognized by the California Department of Fish and Game (CDFG) as being a sensitive or rare community, with the exception of the small (0.2 acre) area of coastal prickly pear scrub. The Biological Resource Assessment prepared by Compliance Biology described the coastal sage scrub habitat appearing “to be more a result of post-burn reseeding than natural regrowth as slope aspect, gradient, and elevation suggest chaparral was likely the original association in most of these areas.”

The basis for the conclusion that the loss of approximately 416 of the 1,380 acres of coastal sage scrub vegetation on the site is not a significant impact is not solely based on the fact that the loss of this habitat would not result in the population of any special status animal or plant species dropping below self sustaining levels as stated in this comment. As stated on page 4.3-62 of the Draft EIR, coastal sage scrub is a common occurring plant community on the site, which contains 1,380 acres of coastal sage scrub, the surrounding area, and the region. As stated above, the coastal sage scrub vegetation associations located on the site are not identified as sensitive or rare by the CDFG. Surveys for sensitive plants and animals were conducted throughout the project site, including the coastal sage scrub communities. No sensitive plants were observed on the site. Potential impacts to sensitive wildlife species were considered and evaluated for significance. As discussed on page 4.3-49 of the Draft EIR, the coastal sage scrub on the site is considered a suitable habitat for the San Diego horned lizard, a California species of special concern and the Coastal western whiptail, a California special animal. Both of these species were observed within the coastal sage scrub on the site. Other habitat on the site is also suitable for these species however. As large amounts of suitable habitat for these species would be remain in the open space areas designated by the Specific Plan, the loss of the coastal sage scrub on the site would not significantly impact these, or other sensitive wildlife species, by resulting in their populations dropping below self sustaining levels.

The information in the Draft EIR supports the conclusion that the loss of 416 of the 1,380 acres of coastal sage scrub present on the site is not a significant impact because the coastal sage scrub on the site consists of common plant associations that are abundant on the site, in the surrounding area and the region, are not identified as sensitive by the CDFG and does not contain sensitive plant species. In addition, the coastal sage scrub on the site does not provide habitat occupied by large numbers of sensitive wildlife species that could not also occupy other habitat on the site and in the surrounding area.

Additionally, the proximity of the coastal sage scrub areas being impacted to the existing golf course discourages wildlife species less tolerant of human activity and limits species diversity to the more human-tolerant species as a result of the long linear urban interface.

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The EIR identifies impacts to riparian habitat as a potentially significant impact requiring mitigation to lessen the severity of the impact as further discussed in the following response.

Response 14-7

The comment notes the mitigation for the impacts to riparian vegetation will not be able to be implemented on the project site. Impacts to both jurisdictional and non-jurisdictional riparian vegetation may not be completely mitigated within the site due to the existing topography and availability of suitable mitigation areas. The City will require the project applicant to work cooperatively with the City, Ventura County Watershed Protection District, United States Army Corps of Engineers (USACE), and CDFG in order to fully mitigate the proposed impacts to sensitive riparian resources. Because the Draft EIR conservatively assumes impacts to entire drainages within the Residential - Estate land use category, the total area of impacts will be less than projected in this worst case analysis. Mitigation Measures 4.3-17 and 4.3-19 have been revised to reflect the opportunities for mitigating these impacts (see below). The drainages within the Specific Plan Area provide the potential for on-site riparian habitat enhancement. In addition, many of the drainage areas are currently adjacent to the existing golf course where habitat resources are compromised by the ongoing maintenance operations and, for this reason, less mitigation will be required to replace the biological value of these areas.

4.3-17 Mitigation for Southern Willow Scrub and Southern Riparian Scrub shall be provided in accordance with USACE and CDFG permit requirements and in conjunction with the City of Simi Valley and the Ventura County Watershed Protection District, since these plant communities are located along streambed channels regulated by these agencies. Mitigation shall consist of creation, restoration, enhancement, invasive species removal, in lieu fee payment or off-site property purchase, which are is further described under the subsection below and Mitigation Measure 4.3-19.

4.3-19 Mitigation for impacts to USACE, CDFG, and Regional Water Quality Control Board (RWQCB) jurisdictional areas and to sensitive Southern Willow Scrub and Southern Riparian Scrub non-jurisdictional areas would be by any of the following singly or in combination:

 Creation, restoration, and/or enhancement of sufficient acreage to mitigate for impacts to USACE jurisdictional waters and CDFG jurisdiction consisting of freshwater marsh, (wetlands) southern willow woodland, southern willow scrub, southern riparian scrub, native grassland, and/or coast live oak woodland habitat on site; or

 Removal of non-native plant species such as giant cane (Arundo donax), castor bean (Ricinus communis), and salt cedar (Tamarix ramosissima) within Tapo

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Canyon Creek, Gillibrand Canyon Creek (Tapo Canyon Tributary E) and Dry Canyon Creek on and/or off site to restore riparian function and value to portions of each drainage or elsewhere in the Arroyo Simi watershed; or

 Purchase of an off site parcel (or parcels of land within the Tapo Canyon Creek Watershed supporting sufficient USACE jurisdiction and CDFG jurisdiction and placing a conservation easement over the parcel (or parcels); and

 For temporary impacts, restore sufficient acreage of USACE jurisdictional waters and CDFG jurisdiction resulting from temporary impacts to compensate for the impacts.

Response 14-8

The comment states the proposed project would eliminate Dry Canyon as a tributary drainage to the Arroyo Simi watershed. While the City agrees the habitat function of Dry Canyon would be lost as a result of the urbanization of the area, the runoff component of the Dry Canyon tributary watershed will not be lost and the rainfall captured with Dry Canyon will be conveyed through stormwater provisions to the Arroyo Simi drainage. The loss of the Dry Canyon golf course will not significantly interfere with mountain lion movement through the project open space areas since this species has very large home range and can make use of a variety of potential linkages. The data summarized in the 2004 LSA Associates Wildlife Corridor Assessment6 does not indicate the presence of mountain lion usage in the Dry Canyon area (Figure B1, Wildlife Observation Map) as indicated in this comment. Dry Canyon has limited value for wildlife movement due to the presence of urban uses at the south end of the canyon.

Response 14-9

This comment requests the assessment of habitat capability of the open space dedication area south of Lost Canyon Drive for large carnivores such as coyote, grey fox, mountain lion, bobcat and American badger for the Reduced Density Alternative. With approximately 40 fewer residential units in the Tapo Canyon planning area, habitat capability may be slightly increased as a result of the fewer residences being built in the southeast corner of the project site. This would allow movement of wildlife from the open space area to Tapo Canyon channel. In addition, the wildlife corridors incorporated into the Whiteface Specific Plan, which will not be impacted by this proposed Specific Plan Amendment, will continue to provide the same linkage opportunities as currently exist.

6 LSA Associates, Inc. Final Wildlife Corridor Assessment Report, Ventura State Route 118. May, 2004. Prepared for Caltrans District 7.

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Response 14-10

The comment requests a design layout for the 20-acre estate parcels and states this information is needed to allow for the potential impacts of this proposed type of residential development to be adequately analyzed. There is no current design for these lots. Potential impacts can be adequately assessed based on the proposed development standards for these lots in the proposed Specific Plan Amendment, as discussed above in Responses 14-4 and 14-5. Because of the size of these proposed lots, it can be reasonably assumed that none of the fuel modification zones would overlap and therefore, 3 to 5 acres of habitat lost through fuel modification is a conservative estimate. The lack of design for the estate lots does not defer analysis required under the California Environmental Quality Act (CEQA) and the final design will require a subsequent tentative tract map application subject to further CEQA review, as discussed in the Project Description of the Draft EIR.

Response 14-11

The comment requests an analysis of impacts on the natural habitat from the adjacent Sand Canyon from the residential component in Dry Canyon. A list of potential impacts to off-site locations is presented under the indirect impacts starting on Page 4.3-50 of the Draft EIR. The only direct impact to Sand Canyon natural habitat would occur where Lost Canyons Drive joins to the two project boundaries. This grading impact of about 1 acre is currently associated with the existing golf course. There would be no further direct impacts to the Sand Canyon natural habitat areas. Please see Response 14-3 above for further information on the effect of the project on the open space areas designated by the Specific Plan. Impacts relative to the off-site Sand Canyon project were found to be less than significant because they do not exceed any significance threshold, including those for special-status species, riparian habitats, or sensitive plant communities, protected wetlands defined under the Clean Water Act, or wildlife movement corridors.

Response 14-12

The comment reiterates that the Draft EIR is deficient for the reasons stated in comments 1 through 11 above. Please see Responses 14-1 through 14-11 above. As indicated in these responses, the Draft EIR includes adequate analysis of the potential impacts raised in these comments.

Response 14-13

The comment requests clarification of the dam structure discussed within Dry Canyon and the CEQA documentation reviewing the potential impact of its implementation. The City’s master plan of drainage identifies a general location for a regional detention basin in Dry Canyon. It should be noted that this regional facility is identified in the City’s current master plan of drainage and is not proposed as part of this project. A hydrology study was prepared for the proposed project that considered the potential effect

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of the proposed project and also reviewed the more general analysis and information in the City’s master plan of drainage to determine the consistency of the project with the drainage master plan. The project hydrology study concluded that the regional detention basin in Dry Canyon identified in the City’s master plan was not required and the regional detention need could also be met with a facility in Tapo Canyon. The drainage impacts from the proposed project can be mitigated without this planned regional facility and this future planned regional facility is not a part of the project.

Response 14-14

The development agreement for this project has expired. For this reason, no changes are required to the development agreement as it is no longer in effect. See Response 14-9 above for discussion of the habitat capability of the open space areas.

Response 14-15

Please see Response 14-10 above in regard to estate lots.

Response 14-16

Please see Responses 14-3 and 14-11 above for comment on off-site impacts to Sand Canyon.

The comment requests quantification of fuel modification impacts for the proposed project. Specific impacts from fuel modification have been conservatively estimated in the impact assessments figures of the Draft EIR and the numbers presented in Table 4.3-5 Existing and Impacted Plant Communities on the Proposed Project Site in the Draft EIR consider all ground disturbing impacts. The fuel modification impacts were conservatively included in the overall impacts based on a generalized 200-foot modification zone away from proposed residences.

Response 14-17

The comment requests discussion of the potential loss of perennial water sources in Dry Canyon. The Glenn Lukos Jurisdictional Delineation report7 describes Dry Canyon as an ephemeral feature that contains no wetlands. There is mention of one nuisance flow area with saturated soils caused by golf course irrigation. There are no perennial water sources in Dry Canyon that will be impacted by the proposed project. Impacts to jurisdictional resources under the USACE and CDFG are addressed in the Draft EIR.

7 Glenn Lukos Associates. Jurisdictional Delineation of the Approximately 1,677-Acre Lost Canyons Project in the City of Simi Valley, Ventura County, California. August, 2007.

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Response 14-18

The comment indicates the Draft EIR is deficient for not fully analyzing impacts to western spadefoot. Impacts from the proposed project are considered to be less than significant with the implementation of Mitigation Measure 4.3-2, which requires the preparation of a sensitive species protection plan that will incorporate relocation of individuals found to suitable on-site locations within designated open space areas. The Draft EIR does not conclude that project impacts would push the local population below a sustainable level.

Response 14-19

The comment indicates that the Draft EIR did not analyze habitat connectivity between the designated open space area and Tapo Canyon. The Draft EIR addresses the linkage of the designated open space area with Tapo Canyon through the identification of both Corridor E and Corridor F. These corridors provide a linkage to Tapo Canyon from the north portion of the open space and the latter corridor permits linkage near the confluence of Tapo Canyon on this tributary drainage. This is discussed in subsection 4.3.3.7 Wildlife Movement Corridors, starting on page 4.3-40 and in the project impacts discussion starting on page 4.3-72. The Draft EIR concludes that maintaining the four most critical wildlife corridors, as recommended by the habitat linkage reports and required as mitigation in this Draft EIR, would reduce impacts to the movement of wildlife on site to a less than significant impact.

Response 14-20

The comment inquires about impacts associated with equestrian use in the designated open space area. The open space area has from the beginning been designated as private open space. The Specific Plan recognized “Public Open Space,” within which a network of hiking and equestrian trails to be constructed and managed by the Rancho Simi Park and Recreation District. The public trail system connects to a private residential trail system, linking the various neighborhoods to the Project Core Area. A trail system provides private trail loops ranging from 1.3 to 3.0 miles, and links the various neighborhoods and amenities (see Figure 3.0-9, Conceptual Trails Plan). Signage may be provided along the trail and at intersection points for direction and wildlife information. This trail system provides trail linkages for the public.

Response 14-21

The comment states the slope analysis calculations need to reference pre-1987 topography. The current Specific Plan residential density calculations are based on the 1987 topography consistent with the City’s Hillside Performance Standards. The current maximum number of 364 dwelling units is to be maintained by the proposed project.

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Response 14-22

The comment suggests the Draft EIR is deficient in the discussion and analysis of wildlife movement corridors. The Draft EIR analysis references the earlier studies for the Whiteface Specific Plan. The 1995 certified Supplement to the Final Subsequent EIR included mitigation measures to reduce the potential impact on wildlife corridors to a less than significant level. While the earlier wildlife movement studies prepared by Michael Brandman Associates for Sand Canyon and Envicom Corporation for Dry and Tapo Canyons have relevant and important information, the South Coast Wildlands report (Penrod et al, 2006)8 provides more current and up-to-date information and analysis on regional wildlife movement between the large habitat blocks from the Santa Monica Mountains in the south to the Los Padres National Forest to the north.

The report identifies a habitat linkage within the Santa Susana Mountains within the Marr Ranch property, just to the east of the Lost Canyons project site. This corridor continues north of the project site along the western edge of Tapo Canyon. This is the closest identified regional corridor to the project site, which is not included within this linkage. The closest identified corridor to the west occurs within Alamos Canyon. This report provides additional evidence that impacts to the regional movement of wildlife on site are less than significant, with the implementation of the recommended mitigation measures.

The City supports the use of conservation easements for open space areas and will work with California Department of Fish and Game on appropriate language for a conservation easement should one be determined to be appropriate.

Response 14-23

The comment addresses the loss of the Corridor C connection to the Sand Canyon protected open space and requests additional mitigation measures to assure the Corridor F linkage of the designated open space area with natural areas to the east through Tapo Canyon. The EIR assessment of wildlife movement provides updated analysis and finds that both corridors are still viable and will be maintained with the proposed project. Corridor C is a vital link between the designated open space area south of Lost Canyon Drive and the large habitat block north of the project site. The previous EIR concluded that Corridors B and C located in Dry Canyon, and corridors E and F located in Tapo Canyon, would provide the best opportunity for wildlife movement through the establishment of physical facilities, including

8 Penrod, K., C. Cabañero, P. Beier, C. Luke, W. Spencer, E. Rubin, R. Sauvajot, S. Riley, and D. Kamradt. 2006. South Coast Missing Linkages Project: A Linkage Design for the Santa Monica-Sierra Madre Connection. Produced by South Coast Wildlands, Idyllwild, CA. www.scwildlands.org, in cooperation with National Park Service, Santa Monica Mountains Conservancy, California State Parks, and The Nature Conservancy.

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overcrossings and undercrossings of arterial roads, protective fencing, speed limits and warning signs, vegetative plantings and limitations on development in the corridor locations.

Revised Figure 4.3-3, Wildlife Movement Corridors, indicates two locations within Corridor C that will allow the open space area in Planning Area 6 to be connected to the habitat block north of the project site. One of the corridors makes use of the natural open space within the Sand Canyon project through an unnamed tributary of Dry Canyon while the other corridor maintains connections with the upper watershed of Dry Canyon. Mitigation Measure 4.3-28 requires that these corridors remain open. Similarly, Corridor F provides access to Tapo Canyon where wildlife has access to the habitat block north of the project site by way of the undercrossing of Lost Canyons Drive. These corridor connections will remain functional as required by Mitigation Measure 4.3-28.

Response 14-24

The comment indicates the Draft EIR needs to further address the wildlife corridors shown in Figure 9 of the December 1993 Envicom report, entitled, A Study of Wildlife Movement in Dry Canyon. Because the City recognized these movement corridors in the 1995 certified Supplement to the Final Subsequent EIR, which was based on the 1993 Envicom study, the Draft EIR is consistent with that report as the same corridors are identified in 1993, 1995 and in 2009. Please see Response 14-22 above, which addresses these corridors.

Response 14-25

The comment requests that roadways and utility easements required for the project be shown in relation to wildlife corridors. The utility easements will generally be located along the roadways and the wildlife corridors have been designed to overcome the road obstacles to movement. Therefore, the obstacles that existed in the 1995 certified Supplement to the Final Subsequent EIR, including roadways and utility easements, are basically the same type of obstacles that will result from this proposed project. Specifically, the principal obstacle to wildlife movement between the designated open space area and the large habitat block north of the project site is Lost Canyons Drive between Erringer Road on the west and Tapo Canyon on the east. The preservation of Corridors C and E were recommended to prevent isolation within the designated open space area from habitat areas to the north as a consequence of such infrastructure. Please see Figures 3.0-15, Conceptual Sewer Plan, and Figure 3.0-14, Conceptual Circulation Plan, in the Draft EIR for depictions of roadways and utility Easements.

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