TRAFFIC:

             "The FEIS continues to misstate the relevant threshold of significance...."

             "The FEIS also continues to improperly rely on funding of the Hwy 101/Wilfred Avenue and other HOV projects as mitigation. As the County has repeatedly commented, those projects were developed to address existing conditions and planned growth in the region without the project...As a result, contributing to the HOV projects would not mitigate the project's significant traffic impacts."

             "...the FEIS should recognize that the project would add the equivalent of one entire traffic lane of volume to the entire Hwy 101 corridor from Rohnert Park southbound. The FEIS should disclose that the project would generate close to 1600 vph during peak traffic times, which Caltrans uses a LOS C volume for freeway segments. The FEIS should be revised to discuss the actual measure that would be necessary to mitigate the project-the addition of another full lane to the entire Hwy 101 corridor south of Rohnert Park. "

             "It is especially inappropriate to claim credit for funding the Wilfred Project. The Wilfred Project has already been awarded and will start construction in spring of 2009. No further funding is necessary, and the FEIS should not claim to the contrary, much less pretend that a monetary contribution would mitigate the project's significant traffic impacts."

             "As the County has previously commented, all identified full-share road improvements should be constructed by the Tribe instead of simply being funded, as the FEIR indicates (2nd paragraph of Section 5.2.7, Mitigation for Intersections). The County's standard practice in conditioning all other development projects requires the developer to construct road improvements necessary to mitigate project impacts. This developer should not be treated differently. Nor should the County be expected to incur the administrative and organizational burden of designing and constructing such developer-driven road improvements. In addition, all full-share improvements listed must be constructed prior to project occupancy/operation start-up. This is necessary to ensure timely mitigation of the project's significant traffic safety and capacity impacts."

             "The FEIS also fails to address targeted treatment for special populations such as women, older adults, and ethnic and cultural groups. The FEIS's funding calculation for treatment would limit access to problem and pathological gamblers who seek help. It proposes minimal to no public awareness and education campaign, which would serve to skew funding formulas by generating artificially low projections of gamblers needing problem and pathological gambling treatment services. Artificially reducing the number of problem and pathological gamblers affected by the project would in turn generate insufficient mitigation funding for prevention, education and treatment capacity. "

             "The FEIS should be revised to include a neutral and frank evaluation of the project's potentially significant socioeconomic and related impacts, including its obvious community risk for developing problem and pathological gambling."

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LAND USE:

             "The FEIS also should revise response 2.13.11, which incorrectly claims that the site's future trust status renders it consistent with General Plan goals regarding intense development in the designated community separator. This claim is unavailing. Regardless of who owns the project site, the proposed project site is inconsistent with the General Plan, a significant impact. " 

             "The response also falsely states that "the appearance of the proposed development would be consistent with the commercial activities" to the east and is therefore consistent with a General Plan goal. In fact, the proposed project would be 10 stories, much taller than allowed by either the City or the County in the vicinity. The project's appearance would not be remotely consistent with the commercial activities to the east."

             "The FEIS also should revise response 2.22.11, which incorrectly states that the project is consistent with Goals LU-5 and OS-1, which address the community separator open space designation. The project would not be consistent with these goals unless and until the City of Rohnert Park annexes the site. Since the FEIS does not propose annexation, the project lies outside of the City on lands that are designated for open space and agriculture and is not consistent with the County General Plan."

AGRICULTURE:

             "The FEIS should revise Appendix FF response 2.20.4, which incorrectly claims that soil quality is the only relevant measure of a site's agricultural potential. As the County has previously commented, this claim is incorrect. In Sonoma County in particular, many soil types that were thought to be marginal by NCRS or Storie Index are in productive and profitable use. The FEIS should acknowledge that the project would result in a cumulatively significant loss of potentially productive agricultural land."

             "...the FEIS continues to include no mitigation measures for effects on agriculture."

             "...Page 3.8-50 and Table 3.8-8 should be revised to explain that the project site is considered "Farmland of Local Importance," in productive agricultural use, and designated for continued agricultural use by the County General Plan.