The Initial Study for this proposal to create twelve 5-acre Rural Living-zoned lots in the Pioneertown area contains many conflicts with the County Wide Plan that are outlined in MBCA’s comment letter to Land Use Services. MBCA objects to the County's support of a  Mitigated Negative Declaration for the project and urges a full Environmental Impact Report be completed. MBCA's comment letter and appendices describe a number of critical oversights and lack of reference to key environmental concerns. Issues include: Project location within the Pipes Canyon Area of Environmental Concern (ACEC), fragmentation of wildlife habitat linkage, the Sentinel Landscape supporting military bases, scenic characteristics, dust affecting air quality, dark sky concerns and especially water availability and wastewater treatment issues. (“The IS incorrectly states the site is within the Morongo Valley Groundwater Basin. The site is within the Ames Valley Basin.”) The letter also notes the demonstrated need for affordable housing in the Morongo Basin, rather than 5-acre upscale homes.