APPENDIX C COMMENTS AND RESPONSE TO COMMENTS RECEIVED ON DRAFT NEGATIVE DECLARATION

APPENDIX C COMMENTS AND RESPONSE TO COMMENTS RECEIVED ON DRAFT NEGATIVE DECLARATION

APPENDIX C RESPONSE TO COMMENTS APPENDIX C FINAL NEGATIVE DECLARATION RIM OF THE WORLD SCHOOL DISTRICT SCHOOL CONSOLIDATION PROJECT RESPONSE TO COMMENTS INTRODUCTION This Appendix, together with the Draft Negative Declaration, constitutes the Final Negative Declaration for the Rim of the World School District (RWUSD) School Consolidation Project. The Draft Negative Declaration was circulated for a 21-day shortened public review and comment period (per CEQA Guideline Section 15205(d)), which started on May 18, 2010 and ended on June 7, 2010). The Draft Negative Declaration is available at the Rim of the World Unified School District, 27315 North Bay Road, Blue Jay, CA 92317 or phone at (909) 336-2031. The Draft Negative Declaration included a detailed project description, the environmental setting for each environmental resource, and an analysis of the each environmental resource on the California Environmental Quality Act (CEQA) checklist, including all potentially significant environmental impacts. Based on the Draft Negative Declaration, no significant adverse environmental impacts were identified associated with the proposed project. The RWUSD received two comments via e-mail on the Draft Negative Declaration during the public comment period. One additional comment was also received. Responses to the comments are presented in this Appendix. The comments are bracketed and numbered. The related responses are identified with the corresponding number and are included in the following pages. Pursuant to CEQA Guidelines 15073.5(c)(2), recirculation is not necessary since the information provided in response to written comments on the project s effects does not identify any new, avoidable significant effects. C-1

RIM OF THE WORLD SCHOOL DISTRICT SCHOOL CONSOLIDATION PROJECT From: Julie.Gilbert@sce.com [mailto:julie.gilbert@sce.com] Sent: Monday, June 07, 2010 10:33 AM To: Petre, Ed Subject: Re: Rim of the World School Distrcit They did a traffic impact analysis, which they said was coordinated with you guys. See the link: http://www.rimsd.k12.ca.us/modules/groups/homepagefiles/cms/493705/file/bids/appendix%2 0B%20.pdf?sessionid=edb0b180e7c150665eee38d1440478f9 Yes, they are existing schools. However, Fir Lane is something like - 12 foot total width, instead of two, 12-foot lanes? All the roads around VOE school are narrow-one lane roads. Seeley Lane is like 18 feet total width? No shoulder, no nothing. 1 Buses go out on Waters Drive? There is a blind corner right there. The consolidation plan is proposing to take an existing school with 400 kids and go to 700-800 kids - there are no future projections either. 2 We, as parents, are very concerned about the roads being narrow, and there being a ton of kids at that school. What was your input to Rim? Comments on their initial study are due today. 3 Thanks Ed. Julie Gilbert Community Planner Planning & Strategies Group Corporate Environment, Health & Safety Division Southern California Edison P.O. Box 800 2244 Walnut Grove Avenue Rosemead, CA 91770 Telephone: (626) 302-9517 / PAX 29517 Fax: (626) 302-9130 C-2

APPENDIX C RESPONSE TO COMMENTS From: Petre, Ed [mailto:epetre@dpw.sbcounty.gov] Sent: Monday, June 07, 2010 10:41 AM To: 'Julie.Gilbert@sce.com'; Ronald Peavy Cc: Varma, Naresh Subject: RE: Rim of the World School Distrcit Julie, We have reviewed the Negative Declaration but are asking the School District to provide a traffic study showing local impacts for the Build Out Year. 4 Thanks Ed Petre County of San Bernardino Traffic Mr. Peavy, Also please have the traffic study address the concerns below Thanks Ed Petre County of San Bernardino Traffic C-3

RIM OF THE WORLD SCHOOL DISTRICT SCHOOL CONSOLIDATION PROJECT RESPONSE TO E-MAIL COMMENTS JUNE 7, 2010 Response 1 The scope of the traffic study was developed in consultation with staff from the County of San Bernardino Transportation Department (County) and the California Department of Transportation (Caltrans). The County s Congestion Management Plan (CMP) requires analysis of all key CMP intersections to which the project is forecasted to generate 100 to 250 two-way peak hour trips. Based on the project trip generation and distribution, the proposed consolidation project does not exceed the 250 round trip peak hour threshold that requires a Traffic Impact Analysis under the County s CMP. However, the Valley of Enchantment (VOE) could potentially generate more than 50 morning peak hour trips on a state highway (State Route 138) and therefore meets the threshold for a Caltrans traffic impact study. The County and Caltrans were both contacted to determine the scope of the traffic analysis including trip generation estimates, trip distribution, and intersection study locations. The County requested that the intersection of Peninsula Drive/Grass Valley Road and Peninsula Drive/North Bay Road be analyzed in addition to the intersections near the VOE school. Please note that overall enrollment in the school district is declining and overall traffic associated with the transportation of school children has been reduced through out the school district. However, additional traffic associated with the school consolidation project is expected at the VOE and Mary P. Henck school sites. As noted in the Negative Declaration (see pages 2-57 through 2-66 and Appendix B), all study intersections are projected to operate at satisfactory levels of services (LOS B or better). Therefore, no significant traffic impacts are expected due to the proposed modifications. A large portion of children attending school in the district use buses (about 60 percent), which helps to reduce the traffic associated with school transportation. The roads adjacent to the VOE school site are narrow, two lane streets. Phase II of the proposed project includes reconfiguration of the ingress and egress area of the school site to provide more seamless busing of students attending the school. These modifications will include separate drop-off lanes for buses and parents to reduce onsite congestion as well as to reduce traffic spill-over onto adjacent streets. The specific design for reconfiguration of the ingress and egress is still being developed. However, the modifications will be designed to allow better traffic flow during the peak traffic periods, improving existing traffic flow conditions at the school as well as safely handling the projected increase in students. Response 2 The enrollment at VOE is currently about 480 students. The projected number of students to start at VOE in September 2010, assuming the approval of the school C-4

APPENDIX C RESPONSE TO COMMENTS consolidation project, is about 550 students. The Negative Declaration, including the traffic analysis, analyzed the projected realistic capacity of the school of about 755 students (i.e., projected future build-out capacity). Currently, enrollment in the school district, is declining so the capacity of the VOE school is not expected to substantially increase in the near future. Response 3 Please see Response 1 for the input of Caltrans and the County into the traffic analysis. Response 4 As discussed in Response 3 above, the enrollment at VOE is currently about 480 students. The projected number of students to start at VOE in September 2010, assuming the approval of the school consolidation project, is about 550 students. The Negative Declaration, including the traffic analysis, analyzed the projected realistic capacity of the school of about 755 students (i.e., projected future capacity). Also, please see Response 1 regarding the reconfiguration of the VOE site ingress/egress. C-5

RIM OF THE WORLD SCHOOL DISTRICT SCHOOL CONSOLIDATION PROJECT 5 6 7 C-6

APPENDIX C RESPONSE TO COMMENTS 7 cont. 8 9 10 11 C-7

RIM OF THE WORLD SCHOOL DISTRICT SCHOOL CONSOLIDATION PROJECT 11 cont. 12 13 14 15 C-8

APPENDIX C RESPONSE TO COMMENTS 16 17 18 19 20 21 C-9

RIM OF THE WORLD SCHOOL DISTRICT SCHOOL CONSOLIDATION PROJECT 21 cont. 22 23 C-10

APPENDIX C RESPONSE TO COMMENTS Response 5 RESPONSE TO JULIE GILBERT COMMENTS JUNE 7, 2010 The Rim of the World Unified School District (RWUSD) considered a variety of options for handling the declining enrollment in the Rim of the World USD School Consolidation Report. The report considered various options for handling declining enrollment and which options would result in the most cost-effective use of resources and minimize construction activities. This report was considered at a public meeting. Please note that the proposed project results in physical modifications (i.e., construction activities) at one school site only, VOE elementary school. The comment that the changes are proposed to the physical structure of three facilities is incorrect. As discussed in the Negative Declaration (Section 1.2, pages 1-1 through 1-3), the proposed school consolidation project constitutes a project as defined by CEQA. A Negative Declaration for a project subject to CEQA is prepared when an environmental analysis of the project shows that there is no substantial evidence that the project may have a significant effect on the environment (CEQA Guidelines 15070(a)). Regardless of what the name of the project is called, the required CEQA analysis remains the same. Response 6 CEQA requires that alternatives be evaluated when significant adverse environmental impacts have been identified and an environmental impact report (EIR) has been prepared. The evaluation in the Negative Declaration determined that the proposed project would not result in any significant adverse environmental impacts so an EIR or additional alternatives analysis is not required (CEQA Guidelines 15071). The basic purpose of CEQA is to inform governmental decision makers and the public about the potential, significant environmental effects of proposed activities (CEQA Guidelines 15002). Considerations other than environmental impacts are outside of the scope of CEQA analyses. The environmental impacts of the proposed consolidation project on aesthetics, air quality, traffic, and hazards are evaluated in Chapter 2. Response 7 Chapter 1 of the Negative Declaration provides an accurate description of the proposed modifications and addresses both Phase I and Phase II construction activities. Phase 1 includes the use of additional portable classrooms to provide about 4,800 square feet of additional classroom space on a temporary basis at the VOE school site, so that additional students can be accommodated beginning in the 2010/2011 school year (see page 1-6 of the Negative Declaration). Phase II will result in the construction of a 19,000-foot permanent building on the east side of the existing school to provide about ten new C-11

RIM OF THE WORLD SCHOOL DISTRICT SCHOOL CONSOLIDATION PROJECT classrooms, a maintenance room, and additional rest rooms (see pages 1-9 and 1-10 of the Negative Declaration). Therefore, the comment that no permanent classrooms or additional restrooms will be provided is incorrect and additional structures are included as part of Phase II. Although the exact date for the Phase II construction activities has not been established, the District intends to go forward with both phases, if the proposed project is approved. The basic purpose of CEQA is to inform governmental decision makers and the public about the potential, significant environmental effects of proposed activities (CEQA Guidelines 15002). Considerations other than environmental impacts are outside of the scope of CEQA analyses. Response 8 Please see Figure 1-4 (page 1-9) of the Negative Declaration. The district is proposing to use 14 portable classrooms at VOE on a temporary basis. (Note that two additional portable classrooms will continue to be used for a preschool and a headstart program). When Phase II of the proposed project is completed the temporary trailers will be removed from the site and all classrooms will be within permanent buildings. Response 9 The basic purpose of CEQA is to inform governmental decision makers and the public about the potential, significant environmental effects of proposed activities (CEQA Guidelines 15002). Considerations other than environmental impacts are outside of the scope of CEQA analyses. As the comment correctly states, environmental justice issues are outside the scope of CEQA analyses. No permits from federal agencies are required and no funding from the federal government is required for the proposed project. Therefore, NEPA does not apply to the proposed project modifications. Response 10 As noted in Response 7, the District is proposing to construct a permanent building structure on the east side of the existing school. The additional 19,000 square feet being added will accommodate ten classrooms, a maintenance room, and additional rest rooms (see pages 1-9 and 1-10 of the Negative Declaration). The District intends to go forward with both phases, if the proposed project is approved. Response 11 The Description of the Project on page 2-1 is a brief summary only. The complete project description is in Chapter 1. A reference has been added on page 2-1 of the Final Negative Declaration to refer the reader to Chapter 1 for a more detailed project description. C-12

APPENDIX C RESPONSE TO COMMENTS Response 12 Physical modifications (i.e., construction activities) are only proposed at the VOE elementary school as described in Chapter 1 of the Negative Declaration. A reference has been added in the Final Negative to refer the reader to Chapter 1 for a more detailed project description. No construction activities are proposed at any of the other school sites. Response 13 The public views of the VOE site are addressed on pages 2-6 through 2-8 of the Negative Declaration. The additional portable classrooms are no taller than the existing portable classrooms (about 12 feet high) and the existing portable classrooms do not currently block views of the mountains for any existing residents. Views of the mountains are largely blocked by the forest trees and the portable classrooms are well below the existing trees. The additional portable classrooms are temporary and will be removed from the site following completion of the construction of the permanent building addition. The new permanent classrooms will be the same height as the existing school building, which is approximately 38 feet tall on the south side (playground side) of the campus and about 22 feet tall from on the north side. l area. The new classrooms will be located to the east of Seeley Lane and views are towards the north so these buildings will not impact scenic views from residential areas. Response 14 The typographically errors are noted and have been revised in the Final Negative Declaration. Response 15 This comment regarding ozone is about the existing air quality in the South Coast Air Basin, specifically the San Bernardino Mountains, and is not an air quality impact associated with the proposed project. Ozone is not a constituent that is directly emitted from the existing school site or the proposed modifications to the VOE school. Ozone is generated from the interaction of nitrogen oxides (NOx), volatile organic compounds (VOCs), and sunlight. NOx and VOC emissions tend to be emitted in the greater Los Angeles Basin and are pushed by the predominant onshore winds towards the eastern portions of the Basin, including the San Bernardino Mountains. The proposed project will have no bearing on the greater ozone problem in southern California. The emissions from the proposed project were evaluated for both the construction and operational phases and determined to be below the SCAQMD CEQA significance thresholds, including emissions of NOx and VOC, the precursors to ozone. Therefore, no significant air quality impacts are associated with the proposed project. C-13

RIM OF THE WORLD SCHOOL DISTRICT SCHOOL CONSOLIDATION PROJECT See Response 7 regarding permanent classrooms. The District has tested the portable classrooms for mold and no detectable mold was found in any of the portable classrooms analyzed. The District is not aware of any other potential indoor air quality issues associated with the portable classrooms. Response 16 The proposed project will not result in any physical modifications (i.e., no construction activities and no other physical alterations) to the Lake Gregory Elementary, Grandview Elementary, Lake Arrowhead Elementary, Charles Hoffman Elementary, or Mary P. Henck Intermediate schools. Therefore, the proposed project will have no impact on any of these schools or on any cultural/historic resources and no additional impact analysis is required. The construction dates at the VOE school site is unrelated to the potential for impacts to cultural resources at the site. There are no buildings, structures or equipment at the VOE school site listed on registers of historic resources and no buildings will be removed as part of the proposed project. Therefore, no significant impacts to historic cultural resources are expected as a result of the proposed project. Response 17 The proposed project will not result in any physical modifications (i.e., no construction activities and no other physical alterations) to the Lake Gregory Elementary school. Therefore, no additional geological hazards are associated with this school site. Note that the Lake Gregory fault and its relationship to the VOE school site is addressed on page 2-27. Response 18 As discussed in the Negative Declaration (see page 2-36), the RWUSD has developed emergency evacuation procedures for schools within the District both during and outside of normal school hours. The proposed physical modifications to the VOE school site are not expected to interfere with an emergency response plan or emergency evacuation plan. Emergency response plans will be updated at both the VOE and MPH school to assure that adequate plans are in place to respond to emergencies given the additional students in attendance at the schools. Since enrollment is declining at the other school sites no impacts on emergency response plans would be expected. Since adequate emergency response plans are expected to be in place, no additional mitigation measures are required. Response 19 C-14

APPENDIX C RESPONSE TO COMMENTS The comment is noted and the Final Negative Declaration checklist has been revised to correctly reflect that no impacts on any habitat conservation or natural community conservation plan is expected. Response 20 See Response 1. Please note that there are no currently proposed or known uses for the MTE facility, therefore, any future use is considered speculative, and no further environmental analysis is required (CEQA Guidelines 15145). Further, the MTE facility will no longer be operated by the District so the District will operate one less facility, i.e., less facilities than what the District currently operates. However, LGE will become available to relocated Mountain High, a continuation high school, as well as alternative and adult education activities from their current location at the MTE facility. Response 21 As discussed in Response 1, the roads adjacent to the VOE school site are narrow, two lane streets. Phase II of the proposed project includes reconfiguration of the ingress and egress area of the school site to provide more seamless busing of students attending the school. These modifications will include separate drop-off lanes for buses and parents to reduce onsite congestion as well as to reduce traffic spill-over onto adjacent streets. The specific design for reconfiguration of the ingress and egress is still being developed. However, the modifications will be designed to allow better traffic flow during the peak traffic periods, improving existing traffic flow conditions at the school as well as safely handling the projected increase in students. This will also help with emergency access. The comment that the traffic analysis omits buildout projections is incorrect. Please see Response 4 for further details. Response 22 See Responses 18 and Response 21 regarding emergency access Response 23 Your comments are noted and specific comments are addressed in Responses 1 through 22. The comments and responses will be included as part of the Final Negative Declaration. Please note that closing GVE and dispersing students to LGE and LAE would involve the same type of impacts as the proposed project, i.e., increased traffic at LGE and LAE. C-15

RIM OF THE WORLD SCHOOL DISTRICT SCHOOL CONSOLIDATION PROJECT C-16