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HomeMy WebLinkAbout2015-11-24 - AGENDA REPORTS - WATERSHED MANAGEMENT PRGM (2)D Agenda Item• 7 CITY OF SANTA CLARITA AGENDA REPORT CONSENT CALENDAR CITY MANAGER APPROVAL: %� ✓��?� DATE: November 24, 2015 SUBJECT: UPPER SANTA CLARA RIVER ENHANCED WATERSHED MANAGEMENT PROGRAM CALIFORNIA ENVIRONMENTAL QUALITY ACT ACTION DEPARTMENT: Public Works PRESENTER: Travis Lange RECOMMENDED ACTION City Council: 1. Consider and accept the environmental effects of the projects described in Programmatic Environmental Impact Report for the Upper Santa Clara River Enhanced Watershed Management Program prepared by the Los Angeles County Flood Control District. 2. Make the findings of fact listed in Exhibit A for the projects listed in the Upper Santa Clara River Watershed Enhanced Watershed Management Program. BACKGROUND The draft Enhanced Watershed Management Program (EWMP) was developed to comply with the state and federal requirements of the Stormwater Permit (Permit) issued by the Los Angeles Regional Water Quality Control Board (Regional Board). The City Council awarded the contract and entered into a legal agreement with Los Angeles County (County) to develop the EWMP and partner document, the Coordinated Integrated Monitoring Program (CIMP) on July 9, 2013. The Upper Santa Clara River Enhanced Management Program Group (USCR EWMP Group), which includes the City of Santa Clarita (City), County, and Los Angeles County Flood Control District (Flood Control District), collaboratively developed the EWMP to comply with requirements of the Permit. The EWMP is a highly technical document that defines the compliance program for Permit and water quality standards to the Regional Board. The Permit requires the EWMP to disclose potential efforts required and potential costs, between now and 2035. Regulatory milestones include the years 2022, 2029, and 2035 to reduce bacteria and zinc pollution. The EWMP [� a Page 1 Packet Pg. 33 implementation envisions collaboration on multi -benefit regional projects to retain both non- stormwater and stormwater runoff and facilitate flood control and increase water supply. By participating in the EWMP process the City gained an additional 30 months to customize the efforts needed to comply with the Permit, model the watershed, and implement. This avoided immediate violation of the Permit from any high level of pollutants coming from the storm drains that exceeded water quality standards. Implementing the EWMP is included in the Sustaining Public Infrastructure section of the Santa Clarita 2020 Plan. The EWMP was submitted to the Regional Board for comments on June 30, 2015. The City received comments from the Regional Board on the draft EWMP on October 5, 2015, and is required to resubmit the final EWMP on January 4, 2016, on behalf of the USCR EWMP Group. The projects scheduled through 2022 are source reduction best management practices, high priority, regional, multi -benefit infiltration projects on public property, and low impact development/green street retrofits with an estimated cost of $13.8 million. The total, modeled construction cost for the City, through 2035, is estimated at $367.5 million. These are estimates required in the Permit, but the following factors may impact the final implemented program: • Over 78 percent of the construction costs, or $288.5 million, are assumed large projects on private property after 2022 that would require acquisition in addition to construction. • There is a lack of breadth of water quality monitoring throughout the upper Santa Clara River. Mandated water quality monitoring being conducted through the CIMP (recently adopted by the City Council) will provide better information over time and more accurate results of the efforts still required after 2022. • It is likely implementation actions after 2022 will be modified in response to water quality monitoring data. Should the monitoring demonstrate milestones are being achieved more quickly than anticipated, some projects identified in the EWMP may not need to be implemented. • All proposed projects would also consider benefits to water supply infiltration, public spaces in need of redevelopment or construction, the reduction of flood hazards, and needed street retrofits as part of regular maintenance. • The Los Angeles County Division of the League of California Cities, through a Stormwater Steering Committee, is working to implement a series of recommended efforts to make funding for stormwater projects less burdensome. Their efforts recently supported the passage of Senate Bill 485 that will allow the Sanitation Districts of Los Angeles County to manage and treat stormwater and dry weather urban runoff in Los Angeles County. They are also working to include stormwater project funding in Measure R2. Other efforts are in progress and the City participates in the committee implementing these recommendations. • Ventura County recently completed a draft plan for compliance with the bacteria Total Maximum Daily Load (TMDL) in the Santa Clara River. They estimate their capital costs at $370 to $750 million for that one pollutant. If not for the EWMP, the City would have had to produce single pollutant plans for bacteria and other future pollutants at a substantially higher cost. Staff is working to evaluate, track, and apply for grants. Any future investment will be based on the principles of integration with multiple benefits and collaboration in addition to helping to meet water quality standards. Page 2 Packet Pg. 34 The EWMP was developed with stakeholder involvement. There were open houses and a public comment process. The stakeholders, besides the City and County, include the Regional Board, United States Environmental Protection Agency, non-governmental organizations, Santa Clarita Valley citizens, the local development and business community, Santa Clarita Valley Family of Water Suppliers, Santa Clarita Valley Sanitation District, Integrated Regional Water Management Group members, and other interested parties. Staff has provided updates to the City Council throughout the process, conducted open house events throughout the development process, made presentations to business groups, the Integrated Regional Water Management Plan stakeholder group, and City staff. In a survey of four other EWMP areas in the County, City staff has found their costs to be 2.5 to 12 times as expensive as the Santa Clara River effort, with more aggressive time schedules. Overall, the estimated costs for all of the County EWMPs together are near $13 billion. Water Quality Priorities One of the first steps in the EWMP process was identifying water quality priorities. The water quality priorities provide the basis for selecting and scheduling actions in the EWMP. The current water quality condition information available was characterized based on a comparison of available data with applicable state water quality objectives. Each pollutant was then classified into one of three categories specified in the Permit: highest priority, high priority, and medium priority. A source assessment was conducted to identify potential sources of the pollutants likely to be present in the USCR EWMP area from stormwater and that would contribute to any pollutant exceedances. The primary pollutant addressed is bacteria during rain events with a compliance deadline of 2029, with zinc requiring more effort in specific areas by 2035. Reasonable Assurance Analysis The Permit requires the EWMP to include a Reasonable Assurance Analysis (RAA), a rigorous modeling process that is required for stormwater in the Santa Clara River to meet water quality standards. The RAA used a comprehensive watershed model of the entire Santa Clarita Valley area that identifies the lowest -cost water quality improvements through an integrated, watershed - based approach. The Permit requires the model to assign an estimated cost to the entire effort through 2035 for all pollutants. EWMP Implementation Plan The EWMP Implementation Plan is the proposed Watershed Control Measures (WCM) needed to comply with water quality standards. There is an implementation process and timeline to address water quality priorities and comply with the provisions of the state -issued Permit based on the information available today. The EWMP will likely change over time through adaptive management based on monitoring results and updated modeling. Prioritized projects have been identified and evaluated as part of the EWMP Implementation Plan. The prioritization process evaluated additional benefits beyond water quality improvements with a focus on groundwater replenishment and flood hazard management. Through the EWMP process, the volume of stormwater requiring treatment was reduced, resulting in a lower number of projects and, therefore, less cost. As previously mentioned, the City would have been obligated to complete a stand-alone implementation plan for the bacteria TMDL this year. This implementation plan addresses 0 Page 3 Packet Pg. 35 multiple pollutants at once and prioritizes projects with multiple benefits, such as additional infiltration into local groundwater basins. The projects scheduled through 2022 are source reduction best management practices, high priority infiltration projects on public property, and low impact development/green street retrofits, for an estimated cost of $13.8 million. There are many policies, programs, and results that may significantly alter what will be required beyond 2022 when compared to the current version. Assessment and Adaptive Management An adaptive management approach was designed to address the relationship between water quality monitoring, implementation plan scheduling, and long term WCM planning. Adaptive management is a critical component of the EWMP implementation process, and EWMP updates are required at two-year cycles by the Permit. The EWMP will be modified in response to water quality monitoring results, updated modeling results, and lessons learned from WCM implementation to meet the requirements of the Permit. While the EWMP is a long-term planning document that identifies a pathway to compliance with the final TMDL targets and receiving water limitations and water quality objectives, the long timeframe of the document (through 2035) prevents the identification of specific actions to be taken for the entire implementation period. The EWMP includes more detail and specificity for implementation actions that can be implemented through 2022 based on existing funding sources. However, it is likely that implementation actions after 2022 will be modified in response to water quality monitoring data. Should the monitoring demonstrate milestones are being achieved more quickly than anticipated, some projects identified in the EWMP may not need to be implemented. Tier A Regional Multi -Benefit Infiltration Projects The Permit obligates cities and Los Angeles County to infiltrate a certain volume of stormwater to be in compliance. The EWMP demonstrates the details of where the City intends to implement regional multi -benefit projects on the following publicly owned areas by the dates listed to meet the Permit requirements. This City Council action does not obligate the City to implement the listed projects, as the Permit already mandates the volume of treatment required. Based on stakeholder input and the number of multi -benefits, Newhall Park, Santa Clara River Floodplain, and Canyon Country Park are considered the highest priority projects for the City. They are listed in bold below. These are proposed projects to address water quality priorities and comply with the Permit based on the information available today. The plan may change over time through adaptive management based on monitoring results, updated modeling, and future opportunities that are unknown at this time. Compliance is based on the volume of stormwater infiltrating into the ground from urbanized areas. While these projects represent the most volume with the highest number of multiple benefits the stakeholder community supports, other projects that become known with equivalent benefits may be utilized through an amendment process. Page 4 Packet Pg. 36 City Publicly Owned Land Project Deadline Site 5 - Open Space at South Fork Trail 2020 Site 8 - Santa Clarita Park 2020 Site 12 - Valencia Meadows Park 2020 Site 13 - Northbridge Park 2020 Site 17 - Open Space at Damar Court 2020 Site 25 - Canyon Country Park 2020 Site 11 - Almendra Park 2022 Site 3b - Newhall Park 2029 Site 14 - Valencia Glen Park 2029 Site 18 - Valencia Heritage Park 2029 Site X - Santa Clara River Floodplain 2029 In addition to the regional multi -benefit projects, there will be adjustments to the existing stormwater program implementation in 2017 and low impact development/green streets projects in 2020 and 2022 at locations to be determined. Costs and Financial Strategy The projects scheduled through 2022 are source reduction best management practices, high priority infiltration projects on public property, and low impact development/green street retrofits for an estimated cost of $13.8 million. The total, modeled construction cost for the City through 2035 is estimated at $367.5 million. The estimated total cost analysis generated by the model through 2035 is required by the Regional Board and provides a broad view of the level of effort that may be required to meet state requirements over time. These costs are based on averages throughout the United States for the project size and volume of stormwater required to be infiltrated into the ground. These costs are not quotes. Any of the projects that might be constructed will be included in the City budget process, include community outreach, be designed by professionals, have defined and adopted budgets, and follow City bidding and purchasing rules before any construction takes place. The implementation plan has been developed in consideration of the available financial resources in the short term. It includes an implementation process that emphasizes the lowest cost actions (institutional controls/true source control) and progressively implements more costly controls by starting with high priority regional projects and projects on public lands, followed by implementation of projects on private parcels if needed. Constraints and challenges exist for all of the potential funding strategies, and as such, while the USCR EWMP Group will work to implement actions to gather the needed funding resources, the implementation of the actions outlined in the EWMP after 2022 is dependent on obtaining additional funding. Staff is currently and continually evaluating how to address future costs related to Permit compliance. Additionally, to the extent additional funding is obtained earlier in the implementation schedule, those resources will be utilized to implement additional actions. The City joined in an unfunded mandates claim process related to stormwater program costs via Page 5 Packet Pg. 37 action taken by the City Council in June 2014. The group has filed the claim; however, the claims for the 2012 Stormwater Permit are on hold, pending a decision by the California Supreme Court on a similar claim for the 2001 Stormwater Permit that has not been scheduled as of the writing of this report. There are several, additional litigations from cities and environmental groups currently pending on this Permit. Proposition 1 Stormwater Grant Application Beginning December 2015 or January 2016, there will be a competitive grant opportunity to apply for up to $5 million to implement the types of projects identified in the USCR EWMP. The Water Quality, Supply, and Infrastructure Improvement Act of 2014 (Prop 1) was approved by California voters in the general election on November 4, 2014. Among other funds, Prop 1 provided $200 million for matching grants to public agencies, nonprofit organizations, public utilities, state and federally recognized Indian tribes, and mutual water companies for multi - benefit stormwater management projects. Prop 1 requires a 50 percent match. Up to $80 million will be available to fund implementation projects during the first solicitation (Round 1) with applications due in the spring of 2016. Work supported by this grant is required to be completed by February 2020. This timeline tracks well with the current USCR EWMP milestones. Approximately $86 million will be available to fund implementation projects during the second solicitation (Round 2). The state anticipates Round 2 for implementation projects to occur in the spring of 2018; however, the solicitation date is dependent upon legislative appropriation of the funds. One of the requirements of the grant is that all projects funded must comply with the California Environmental Quality Act (CEQA). In this highly competitive process, proposals with projects that already have completed CEQA will score higher than those that do not. CEQA The Flood Control District prepared a Programmatic Environmental Impact Report (PEIR) that covers the activities for all 12 EWMP areas in the County. The Flood Control District, as a regional agency, is a member of each of the EWMP working groups, and as such provides a commonality supporting the PEIR covering all of the EWMP areas. The Flood Control District will work with the applicable permittees in all 12 EWMP watersheds as an equal partner to identify the types and locations of best management practices needed to achieve permit compliance within each watershed. On May 26, 2015, the County Board of Supervisors certified the EWMP Draft PEIR on behalf of the Flood Control District. A copy of the certified PEIR is located in the City Clerk's reading file. The document can be found online at www.LACoH2Osheds.com and a link is provided at GreenSantaClarita.com. The PEIR provides CEQA compliance, if necessary, for all responsible agencies (such as cities) preparing EWMPs within the County. Per CEQA guidelines Section 15096, a responsible agency must "consider the environmental effects of the project as shown in the EIR" and must "make the findings required ... for each significant effect of the project." The responsible agency does not "adopt" or "certify" the PEIR -- that has already been done by Flood Control District as the lead agency, but must consider the environmental effects shown in the adopted PEIR. Staff is asking for the City Council to consider the PEIR findings and accept them for the purposes of the USCR EWMP to be in compliance with CEQA. The findings are in Exhibit A. In Page 6 Packet Pg. 38 summary, the Environmentally Superior Alternative is implementing the EWMP as this proposed alternative would provide the best chance of achieving regional water quality objectives. There are mitigation measures set forth in the PEIR that will reduce or eliminate other impacts the City will accept later in the process when constructing the projects set forth in the EWMP. ALTERNATIVE ACTION If the City Council does not accept the findings of the PEIR, this would significantly reduce the likelihood of obtaining the Stormwater grant and other Prop 1 funding. FISCAL IMPACT The City Stormwater Utility Fund has an unreserved fund balance of $1,735,472. The projects scheduled through 2022 are source reduction best management practices, high priority infiltration projects on public property, and low impact development/green street retrofits, for an estimated cost of $13.8 million. The total modeled construction cost for the City through 2035 is estimated at $367.5 million, although costs beyond 2022 are extremely uncertain and preliminary. The preliminary costs beyond 2022 will be subject to substantial analysis and refinement in the future. ATTACHMENTS Exhibit A Findings of Fact in Support Related to Significant Environmental Impacts for Enhanced Watershed Management Program (available in the City Clerk's Reading File) Final Program Environmental Impact Report (available in the City Clerk's Reading File) Page 7 Packet Pg. 39771 4 J Exhibit A FINDINGS OF FACT IN SUPPORT OF FINDINGS RELATED TO SIGNIFICANT ENVIRONMENTAL IMPACTS State CEQA Guidelines Section 15091 for Enhanced Watershed Management Programs Final Program Environmental Impact Report SCH# 2014081106 Lead Agency: Los Angeles County Flood Control District 1.0 Introduction The following findings of fact are based in part on the information contained in the Draft and Final Program Environmental Impact Report (Program EIR) for the Enhanced Watershed Management Program, as well as additional facts found in the complete record of proceedings. The Final Program EIR is hereby incorporated by reference and is available for review at the Department of Public Works, 900 south Fremont Avenue, 11 th Floor, Alhambra, CA 91803, during normal business hours, and is also available on the District's website www.LACoH2Osheds.com. In December 2012, the Los Angeles Regional Water Quality Control Board (LARWQCB) issued a Municipal Separate Storm Sewer System (MS4) Permit (Order No. R4-2012-0175; National Pollutant Discharge Elimination System [NPDES] Permit No. CAS004001) covering discharges within coastal watersheds from the collective storm sewer systems in Los Angeles County (except from the City of Long Beach). The Permit regulates the discharge of stormwater runoff to waters of the United States from facilities owned and maintained by the Los Angeles County Flood Control District (LACFCD or District), the County of Los Angeles, and 84 incorporated cities within Los Angeles County (collectively referred to as Permittees). The purpose of the MS4 Permit is to achieve and maintain water quality objectives to protect beneficial uses of the receiving waters in the Los Angeles region. Each of the Permittees identified in the MS4 permit is responsible for meeting the conditions of the permit for MS4 discharges occurring within their jurisdiction. The MS4 Permit gives Permittees the option of implementing an innovative approach to permit compliance through development of an Enhanced Watershed Management Program (EWMP). The EWMPs will identify potential and priority structural and non-structural Best Management LA County Flood Control District ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact It Findings of Fact Practices (BMPs) within the region's stormwater collection system to improve runoff water quality. The LACFCD, along with participating Permittees, has opted to exercise this option and has submitted to the LARWQCB 12 separate Notices of Intent (NOIs) for the development of EWMPs within 12 distinct watershed groups. Implementation of the EMWPs would be the responsibility of each Permittee and would occur following approval of the EWMPs by the LARWQCB. The LACFCD, as a regional agency, is a member of each of the 12 EWMP working groups, and as such provides a commonality within each EWMP group. However, LACFCD does not have a special status or authority designated by the MS4 Permit over any of the other Permittees. The LACFCD will be working with the applicable Permittees in all 12 EWMP watersheds as an equal partner to identify the types and locations of BMPs needed to achieve permit compliance within each watershed. The timeline identified in the MS4 Permit requires that Permittees submit the EWMP to the LARWQCB by June 28, 2015, in order to be in compliance with the permit conditions. The LACFCD recognizes that implementation of the EWMPs may potentially result in changes to environmental conditions. As a result, the LACFCD has prepared this Program Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the EWMPs. The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior to submittal of the EWMPs. The EWMPs will be submitted by each EWMP group to the LARWQCB. The LACFCD issued a notice of preparation of a Draft Program EIR on July 27, 2012. The notice of preparation stated that the Draft Program EIR would contain a comprehensive analysis of environmental issues identified in Appendix G of the California Environmental Quality Act (CEQA) Guidelines. With respect to all impacts identified as "less than significant" or as having "no impact" in the Final Program EIR, the District finds that those impacts have been described accurately and are less than significant or have no impact. In addition, some impacts in the Final Program EIR were found to be potentially "significant" but are able to be mitigated to less -than - significant levels, and others were found to be "significant and unavoidable." The District finds that those impacts , have been described accurately and are less than significant with the implementation of mitigation or are significant and unavoidable. The District further finds that the application of mitigation measures identified in the Final Program EIR would be the responsibility of each agency implementing projects identified in the program (implementing agencies). The District finds that the mitigation measures identified in the Final EIR are reasonable and readily implementable under foreseeable circumstances, such that it is reasonably assumed that implementing agencies can and should adopt and implement them for their projects. The conclusions of significance for each impact in the Final Program EIR therefore assume that mitigation measures identified in the Final Program EIR would be applied as described therein. LA County Flood Control District 2 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fad v Findings of Fad The District has adopted the mitigation measures identified in the Final Program EIR, and will implement those measures for projects it implements under the Program. However, as explained more fully in Section 5.0, because the District will not be the implementing agency for all projects being implemented as part of the proposed program, the District cannot state with certainty that all impacts capable of being mitigated to less -than -significant levels will in fact be mitigated to a less -than -significant level. Accordingly, the District finds that as to projects where the District will not be an implementing agency, the impacts described in the Program EIR as being potentially "significant" but capable of being mitigated to less -than -significant levels must be found to be "significant and unavoidable." 2.0 Project Description The 12 EWMPs will vary for each watershed group, but will generally provide the opportunity for Permittees to customize their stormwater programs to achieve compliance with applicable receiving water limitations (RWLs) and water -quality -based effluent limits (WQBELs) in accordance with the MS4 Permit through implementation of stormwater best management practices (BMPs) or watershed control measures. BMPs vary in function and type, with each BMP providing unique design characteristics and benefits from implementation. The overarching goal of BMPs in the EWMP is to reduce the impact of stormwater and non-stormwater on receiving water quality and address the water quality priorities as defined by the MS4 Permit. The development of each EWMP will involve the evaluation and selection of multiple BMP types, including nonstructural (institutional) and distributed, centralized, and regional structural watershed control measures, that will be implemented to meet compliance goals and strategies under the 2012 MS4 Permit. The LACFCD has limited jurisdictional authority for ordinance and code enactment or enforcement and therefore is limited in nonstructural BMPs to education and outreach measures. The structural watershed control measures that will be implemented by the LACFCD will be multi -benefit stormwater projects that emphasize flood risk mitigation and water conservation and supply. The LACFCD has a vested interest in increasing opportunities for stormwater capture and groundwater recharge as a means of assisting local water supply augmentation. The LACFCD will be working with the applicable Permittees and other stakeholders in all 12 EWMP watersheds to develop such projects. The EWMPs will be implemented by the Permittees that have jurisdiction within each EWMP area. The implementing agencies will be responsible for the contents of the EWMPs affecting their jurisdictions and for implementing the projects developed by the EWMPs. Structural control measures are constructed BMPs that reduce the impact of stormwater and non- stormwater on receiving water quality. They are broken into three categories: • Distributed Structural BMPs, which treat runoff close to the source and are typically implemented at a single- or few -parcel level (e.g., facilities typically serving a contributing area less than one acre). LA County Flood Control District 3 ESA 1140474 Enhanced Watershed Management Programs April 2015 Findings of Fact r Findings of Fact • Centralized Structural BMPs, which treat runoff from a contributing area of multiple parcels (e.g., facilities typically serving a contributing area on the order of tens or hundreds of acres or larger). • Regional Structural BMPs, which are meant to retain the 85th percentile storm over 24 hours from a contributing area. Generally, the 85"' percentile storm is approximately 0.75 inches over 24 hours Whether distributed, centralized, or regional, the major structural BMP functions are infiltration, treatment, and storage, which may be used individually or combination: • Infiltration, where runoff is directed to percolate into the underlying soils. Infiltration generally reduces the volume of runoff and increases groundwater recharge. • Treatment, where pollutants are removed through various unit processes, including filtration, settling, sedimentation, sorption, straining, and biological or chemical transformations. • Storage, where runoff is captured, stored (detained), and slowly released into downstream waters. Storage can reduce the peak flow rate from a site, but does not directly reduce runoff volume. The types of structural BMPs to be implemented will vary between EWMPs, but most EMWPs will include a variety of distributed, centralized, and regional BMPs. Non-structural BMPs are policies, actions, and activities which are intended to minimize or eliminate pollutant sources. Most institutional BMPs are implemented to meet Minimum Control Measure (MCM) requirements in the MS4 permit; MCMs are considered a subset of institutional BMPs. These BMPs are not constructed, but may have costs associated with the procurement and installation of items such as signage or spill response kits. 3.0 CEQA Review and Public Participation A Notice of Preparation (NOP)/Initial Study (SCH No. 2014081106) was circulated for a 30 -day public review period beginning on August 29, 2014. Twenty (20) individual written comment letters were received and used in the preparation of the Draft PEIR. The Draft PEIR for the proposed project was initially circulated for a 45 -day public review period beginning on January 21, 2015 and ending on March 9, 2015. Per an announcement via e-mail blast on March 6, the comment period was extended through March 16, 2015 at 5PM. A total of 46 individual written comment letters were received on the Draft PEIR. Section 15088 of the CEQA Guidelines requires that the lead agency evaluate comments on environmental issues received from persons and agencies that reviewed the Draft PEIR and prepare a written response addressing each of the comments received. The response to comments LA County Flood Control District 4 ESA 1140474 Enhanced Watershed Management Programs April 2015 Findings of Fad Findings of Fact is contained in this document—Volume 3, Chapter 12 of the Final PEIR. Volumes 1 through 3 together constitute the Final PEIR. A list of agencies and interested parties who have commented on the Draft PEIR is provided below. A copy of each numbered comment letter and a lettered response to each comment are provided in Chapter 12, Response to Comments, of this Final PEIR. LACFCD held 6 community meetings on January 29 and February 3, 5, 10, 11 and 17, 2015 to discuss the Draft PEIR analysis and alternatives. The six public meetings that took place at 6PM each night listed are as follows: • Public Meeting 1 (Florence -Firestone Service Center – January 29, 2015) • Public Meeting 2 (LA County Fire Camp – February 3, 2015) • Public Meeting 3 (San Pedro Service Center – February 5, 2015) • Public Meeting 4 (Topanga Library – February 10, 2015) • Public Meeting 5 (Hacienda Heights Community Center – February 11, 2015) • Public Meeting 6 (East Los Angeles Library – February 17, 2015) 4.0 No Environmental Impacts 4.1 Structural BMPs 4.1.1 Aesthetics The proposed program would not create a new source of substantial light or glare that would adversely affect day or nighttime views in the area (Impact 3.1-4). Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the creation of new sources of substantial light or glare that would adversely affect day or nighttime views in the area. 4.1.2 Air Quality The proposed program would not conflict with or obstruct implementation of the applicable air quality plan (Impact 3.2-1). Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to conflicting with or obstructing implementation of the AQMP prepared by SCAQMD and SCAG. LA County Flood Control District 5 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact 4.1.3 Biological Resources The proposed program would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. (Impact 3.3-4) The proposed program would not conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan. (Impact 3.3-6) Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the Proposed Program would result in no impact relating to the interference with the movement of any native resident or migratory fish or wildlife or with established native resident or migratory wildlife corridors, or the impediment of the use of native wildlife nursery sites. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan. 4.1.4 Cultural Resources The proposed program would not have any environmental effects related to cultural resources that would result in no impacts or less than significant impacts unmitigated. 4.1.5 Geologic and Mineral Resources The proposed program would not locate new facilities in areas susceptible to seismic impacts such as (1) rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area based on other substantial evidence of a known fault, (2) strong seismic groundshaking, or (3) seismically induced liquefaction or landslides, which could expose people, structures, or. habitat to potential risk of loss, damage, injury, or death (Impact 3.5-1). The proposed program would not result in substantial soil erosion or the loss of topsoil (Impact 3.5-2). The proposed. program would not be located on expansive soil as defined in 24 CCR 1803.5.3 of the California Building Code (2013), creating substantial risks to life or structures. (Impact 3.5- 4). The proposed program would not have soils incapable of adequately supporting the use of a septic tank or alternative wastewater treatment systems where sewers are not available for the disposal of wastewater (Impact 3.5-5). The proposed program would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state or a locally important mineral LA County Flood Control District 6 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fad Findings of Fad resource recovery site delineated on a local General Plan, Specific Plan, or other land use plan (Impact 3.5-6). Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to location of new facilities in areas susceptible to seismic impacts of various kinds. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to substantial soil erosion or loss of topsoil. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to location on expansive soil. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to having soils incapable of adequately supporting the use of septic tank or alternative wastewater treatment systems. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the loss of availability of a known mineral resource that would be of value to the region and the residents of the state, or a locally important mineral resource recovery site delineated on a local General Plan, Specific Plan, or other land use plan. 4.1.6 Greenhouse Gas Emissions The proposed program would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment (Impact 3.6-1). The proposed program would not conflict with an applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs (Impact 3.6-2). The proposed program would not result in significant cumulative impact to GHGs. Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the Proposed Program would result in no impact relating to generation of GHG emissions. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to confliction with an applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program does not have the potential to result in significant cumulative impacts to GHGs. LA County Flood Control District 7 ESA 1140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact 4.1.7 Hazards and Hazardous Materials The proposed program would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials or the accidental release during construction and maintenance activities (Impact 3-7.1). The proposed program would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing school (Impact 3.7-3). The proposed program would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan (Impact 3.7-6). The proposed program would not expose people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands (Impact 3.7-7). Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the creation of a significant hazard to the public or environment through routine transport, use, or disposal of hazardous materials or accidental release during construction and maintenance activities. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the Proposed Program would result in no impact relating to hazardous emissions or handling of hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing school. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the implementation of an adopted emergency response or emergency evacuation plan. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to exposure of people or structures to significant risk of loss, injury or death involving wildland fires. 4.1.8 Hydrology and Water Quality The proposed program would not violate water quality standards or waste discharge requirements or further degrade water quality (Impact 3.8-1). The proposed program would not substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river, or by other means, in a manner that would result in substantial erosion or siltation on- or off-site (Impact 3.8-3). The proposed program would not substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river or, by other means, substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site (Impact 3.8-4). LA County Flood Control District 8 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad The proposed program would not create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff (Impact 3.8-5). The proposed program would not place housing within a 100 -year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other authoritative flood hazard delineation map (Impact 3.8-6). The proposed program would not place within a 100 -year flood hazard area structures that would impede or redirect flood flows (Impact 3.8-7). The proposed program would not expose structures to a significant risk of loss, including flooding as a result of the failure of a levee or dam (Impact 3.8-8). The proposed program would not place structures in areas subject to inundation by seiche, tsunami, or mudflow (Impact 3.8-9). The proposed program would not result in significant cumulative impact to hydrology and water quality. Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the violation of water quality standards or waste discharge requirements. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the alteration of the existing drainage pattern of a site in a manner that would result in substantial erosion or siltation on- or off-site. In response to comment received on the Draft EIR, Mitigation Measure HYDR04 has been added to ensure that Impact 3.8-3 and Impact 3.8-4 remain less than significant. The modification does not identify any new significant impact or trigger the need to recirculate the Draft PEIR under Section 15088.5 of the CEQA Guidelines. HYDRO -4: Prior to approving a structural BMP, the implementing agencies shall conduct an evaluation of the potential hydromodification impacts of the project. The evaluation shall recommend design measures necessary to prevent or minimize any identified impacts, including flooding, erosion and/or scour. Design measures could include velocity dissipaters and bank re -enforcement components. Implementing agencies shall include these measures in project designs. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the alteration of the existing drainage pattern of a site which would increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the creation or contribution to runoff water. LA County Flood Control District 9 ESA / 140474 Enhanced Watershed Management Programs April 2015. Findings of Fact Findings of Fad The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to placement of housing within a 100 -year flood hazard area. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to placement of structures within a 100 -year flood hazard area that would impede or redirect flood flows. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to exposure of structures to a significant risk of loss, including flooding as a result of the failure of a levee or dam. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to placement of structures in areas subject to inundation by seiche, tsunami, or mudflow. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program does not have the potential to result in significant cumulative impacts to hydrology and water quality. 4.1.9 Land Use and Agriculture The proposed program would not physically divide an established community (Impact 3.9-1). The proposed program would not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the program (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect (Impact 3.9-2). The proposed program would not conflict with any applicable habitat conservation plan or natural community conservation plan (Impact 3.9-3). The proposed program would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use. The proposed program would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of agricultural land to non-agricultural use or conversion of forest land to non -forest use. (Impact 3.9-4) The proposed program would not conflict with existing zoning for agricultural use, or a Williamson Act contract (Impact 3.9-5). The proposed program would not conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)). The proposed program would not result in the loss of forest land or conversion of forest land to non -forest use (Impact 3.9-6). The proposed program would not result in significant cumulative impact to land use and ayriculture. LA County Flood Control District 10 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fad Findings of Fact Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the physical division of an established community. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to confliction with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the program adopted for the purpose of avoiding or mitigating an environmental impact. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to confliction with any applicable habitat conservation plan or natural community conservation plan. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, or conversion of agricultural land to non-agricultural use or conversion of forest land to non -forest use. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to confliction with existing zoning for agricultural use, or a Williamson Act contract. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to confliction with existing zoning for forest land or timberland, or the loss of forest land or conversion of forest land to non -forest use. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program does not have the potential to result in significant cumulative impacts to land use and agriculture. 4.1.10 Noise The proposed program would not result in exposure of persons to, or generation of, excessive groundborne vibration (Impact 3.10-2). For a project located within an airport land use plan, or, where such a plan has not been adopted, in an area within 2 miles of a public airport or public use airport, implementation of the proposed program would not expose people residing or working in the area to excessive noise levels (Impact 3.10-5) For a project located in the vicinity of a private airstrip, the proposed program would not expose people residing or working in the project area to excessive noise levels (Impact 3.10-6). LA County Flood Control Dlsfict ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to exposure of persons to, or generation of, excessive groundborne vibration. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to projects located within an airport land use plan or within 2 miles of a public airport or public use airport. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to projects located in the vicinity of a private airstrip. 4.1.11 Population and Housing and Environmental Justice Implementation of the proposed program would not induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure) (Impact 3.11-1). Implementation of the proposed program would not displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere (Impact 3.11-2). Implementation of the proposed program would not displace substantial numbers of people, necessitation the construction of replacement housing elsewhere (Impact 3.11-3). Implementation of the proposed program would not affect the health or environment of minority or low income populations disproportionately (Impact 3.11-4). The proposed program would not result in significant cumulative impact to population and housing and environmental justice. Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to introduction of substantial population growth in an area, either directly or indirectly. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to displacement of substantial numbers of existing housing. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to displacement of substantial numbers of people. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the Proposed Program would result in no impact relating to impacting the health or environment of minority or low income populations disproportionately. LA County Flood Control District 12 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program does not have the potential to result in significant cumulative impacts to population and housing and environmental justice. 4.1.12 Public Services and Recreation The proposed program would not result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered governmental police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for police protection services (Impact 3.12-2). The proposed program would not result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered schools, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for schools (Impact 3.12-3). The proposed program would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated (Impact 3.12-4). The proposed program would not include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment (Impact 3.12-5). The proposed program would not result in significant cumulative impact to public services and recreation. Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the provision of, or need for, new or physically altered governmental police protection facilities. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the provision of, or need for, new or physically altered schools. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to increased use of existing neighborhood and regional parks or other recreational facilities. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would not result significant cumulative impact to public services and recreation. However, Mitigation Measure PS -1 has been included to ensure that cumulative impacts remain less than significant. LA County Flood Control District 13 ESA 1140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact PS -1: The Permittee implementing the EWMP project shall provide reasonable advance notification to service providers such as fire, police, and emergency medical services as well as to local businesses, homeowners, and other residents adjacent to and within areas potentially affected by the proposed EWMP project about the nature, extent, and duration of construction activities. Interim updates should be provided to inform them of the status of the construction activities. 4.1.13 Transportation and Circulation Construction of the proposed program would not potentially cause traffic safety hazards for vehicles, bicyclists, and pedestrians on public roadways, and would not increase traffic hazards due to possible road wear (Impact 3.13-2). The proposed program would not result in inadequate emergency access during construction (Impact 3.13-3). Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to traffic safety hazards for vehicles, bicyclists, and pedestrians on public roadways. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to inadequate emergency access during construction. 4.1.14 Utilities and Service Systems Implementation of the proposed program would not exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board or result in the construction of new treatment facilities or expansion of existing facilities if the wastewater treatment provider has inadequate capacity to serve the proposed program (Impact 3.14-1). The proposed program would not require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which would cause significant environmental effects (Impact 3.14-2). Construction and operation of the proposed program would not require additional energy use that could result in wasteful consumption, affect local and regional energy supplies, or conflict with applicable energy efficiency policies or standards (Impact 3.14-5). Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to exceedance of wastewater treatment requirements of the applicable Regional Water Quality Control Board or result in the construction of new treatment facilities or expansion of existing facilities. LA County Flood Control District 14 ESA 1140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to construction of new storm water drainage facilities or expansion of existing facilities. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to additional energy use. 4.2 Non -Structural (Institutional) BMPs Non-structural control measures are policies, actions, and activities which are intended to minimize or eliminate pollutant sources. Most institutional BMPs are implemented to meet Minimum Control Measure (MCM) requirements in the MS4 permit; MCMs are considered a subset of institutional BMPs. These BMPs are not constructed, but may have costs associated with the procurement and installation of items such as signage or spill response kits. The MS4 Permit categorizes institutional BMPs into six program categories: • Development Construction Programs, which establish standards for stormwater management from construction sites of all sizes (e.g., with or without a stormwater pollution prevention plan [SWPPP]). • Industrial/Commercial Facilities Programs, which establish standards for pollutant reduction and control measures at industrial and commercial facilities. • Illicit Connection and Illicit Discharges (IC/ID) Detection and Elimination Programs, which describe procedures for identifying, eliminating, and reporting illicit connections and discharges to the stormwater system. • Public Agency Activities Programs, which describe a broad range of municipal practices such as street cleaning, landscape management, storm drain operation, and more. • Planning and Land Development Programs, which encourage the application of smart growth and low -impact development (LID) practices to development and redevelopment projects. • Public Information and Participation Programs, which educate and engage the public on a broad range of pollution- and stormwater-related issues. Permittees can evaluate the MCMs, identify potential modifications that will address water quality priorities, and provide justification for modification or elimination of any MCM that is determined to be ineffective (with the exception of the Planning and Land Development Program, which may not be eliminated or modified). MCM customization may include replacement, reduced implementation, augmented implementation, focused implementation, or elimination. Because the LACFCD has limited jurisdictional authority for ordinance and code enactment or enforcement, it is limited in application of MCMs to activities such as public information and participation programs. LA County Flood Control District 15 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad Non-structural/institutional BMPs do not include construction of new facilities. Consequently, the Final Program EIR finds no significant environmental impacts associated with this type of BMP, and no mitigation is required for any of the environmental resource areas. Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in either less than significant impacts or no impacts to all environmental topic areas analyzed in the Final Program EIR relating to implementation of non- structural/institutional BMPs within the program area. 5.0 Less than Significant Environmental Impacts The significant impacts identified in this section are capable of being mitigated to levels of less than significant through the mitigation identified in the Final Program EIR. This mitigation has been adopted by the District. Thus, for projects implemented under the program where the District has jurisdiction over the project, the significant impacts will be mitigated to a level of less than significant. However, the EWMPs cover numerous jurisdictions and include potential projects that will be entirely within the jurisdiction of a different implementing agency. Because the District cannot ensure that these Implementing Agencies will adopt and implement the proposed mitigation measures, the District finds that the impacts identified in this section may also be significant and unavoidable with respect to projects where the District will not be an implementing agency. The conclusions of "less than significant" below will apply to the extent the Implementing Agencies adopt the proposed mitigation. 5.1 Aesthetics Significant Effect The proposed program could create a substantial adverse effect on a scenic vista (Impact 3.1-1). Description of Specific Impact During construction, equipment and materials required for temporary ground disturbances would be visible from public vantage points, but would not affect any scenic vistas past the temporary construction periods. Given the predominantly urban character of potential pump station sites and temporary nature of construction activities, impacts would be considered less than significant. A majority of structural BMPs would be located underground and would not introduce impacts to scenic vistas. Aboveground structures such as pump stations would be located in urbanized areas and would generally be single -story buildings. Such aboveground structures have the potential to impact scenic vistas, but will be required to be designed so as not to contrast existing neighborhood aesthetic features. LA County Flood Control District 16 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact Finding Permanent aboveground structures associated with certain BMPs have the potential to create substantial adverse effects on scenic vistas in the project area. The implementation of Mitigation Measure AES -1 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce the impacts caused by the project relating to the creation of a substantial adverse effect on a scenic vista. Implementation of Mitigation Measure AES -1 would reduce the impact to a less -than - significant level by designing aboveground structures in a way that would avoid obstructing scenic vistas or views from public vantage points, and would ensure design consistency with neighboring structures. AES -1: Aboveground structures shall be designed to be consistent with local zoning codes and applicable design guidelines and to minimize features that contrast with neighboring development. Significant Effect The proposed program could substantially damage scenic resources, including but not limited to, trees, rocks, outcroppings, and historic buildings within a state scenic highway (Impact 3.1-2). Description of Specific Impact Parts of the proposed program may be visible from designated scenic highways or other locally designated scenic roadways in the project area. Rock outcroppings and historic buildings would likely not be disturbed by the project as most of the BMPs will be underground and not visible after construction is complete. Construction of the proposed program would involve removal of vegetation from individual project sites. Smaller aboveground structures would not substantially damage scenic resources, and impacts from larger structures would be reduced to a less -than - significant level with implementation of Mitigation Measure AES -1. Finding Permanent aboveground structures associated with certain BMPs have the potential to substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway. The implementation of Mitigation Measure AES -1 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts. Implementation of Mitigation Measure AES -1 would serve to ensure design consistency with neighboring structures in individual project areas, thereby reducing damage to scenic resources within a state scenic highway. AES -1: Aboveground structures shall be designed to be consistent with local zoning codes and applicable design guidelines and to minimize features that contrast with neighboring development. LA County Flood Control District 17 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad Significant Effect The proposed program could substantially degrade the existing visual character or quality of the site and its surroundings (Impact 3.1-3). Description of Specific Impact Construction activities would visually degrade the project site and its surroundings as a result of the appearance of demolition materials, excavated areas, stockpiles, and other materials. Due to the temporary nature of construction, these adverse effects are considered less than significant. Once constructed, the BMPs would be located predominantly in urban areas and largely underground, which will not have a permanent effect on the visual character or quality of an area. Aboveground structures may degrade existing visual character of project areas as they will add to the visual landscape. Without proper maintenance of BMPs, especially wet ponds or constructed wetlands, there is a potential for substantial degradation of existing visual quality of project sites due to algal growth or public littering. Finding Operation of the proposed program has the potential to result in impacts related to substantial degradation of existing visual character or quality of the site and its surroundings. The implementation of Mitigation Measures AES -1 and AES -2 would reduce impacts to a less -than - significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce the impacts caused by the project relating to the substantial degradation of existing visual character or quality of the site and its surroundings. Implementation of Mitigation Measures AES -1 and AES - 2 would reduce the impact to a less -than -significant level. AES -1: Aboveground structures shall be designed to be consistent with local zoning codes and applicable design guidelines and to minimize features that contrast with neighboring development. AES -2: Implementing agencies shall develop BMP maintenance plans that are approved concurrently with each structural BMP approval. The maintenance plans must include measures to ensure functionality of the structural BMPs for the life of the BMP. These plans may include general maintenance guidelines that apply to a number of smaller distributed BMPs. Significant Effect The proposed program would result in a less than significant cumulative aesthetic impact with mitigation. Description of Significant Impact Cumulative projects in the program region have the potential to result in cumulative impacts to aesthetic resources if they would result in the removal or substantial adverse change of visual LA County Flood Control District 18 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact character or image of a neighborhood, community, state scenic highway, or localized area. Given that the BMPs will be located in primarily urbanized areas, introduction of structural BMPs would result in only minor changes to the visual landscape. The cumulative impacts of aboveground structures could have a significant impact to the aesthetic environment due to their potential size and location. Finding The proposed program's cumulative aesthetic impact is considered cumulatively significant, but would be reduced to less -than -significant with mitigation. Overall, implementation of BMPs is anticipated to have a positive impact on the aesthetic environment through the creation of open space areas and less impervious surfaces in urbanized or residential areas. After implementation of Mitigation Measures AES -1 and AES -2, cumulative impacts associated with aesthetics would be considered less -than -significant. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce the impacts caused by the project that results in a cumulative aesthetic impact. With the implementation of Mitigation Measures AES -1 and AES -2, implementation of the proposed projects would result in less -than -significant cumulative aesthetics impacts. 5.2 Air Quality Significant Effect The proposed program could expose sensitive receptors to substantial pollutant concentrations (Impact 3.2-4). Description of Significant Impact While construction -related traffic on local roadways would occur during construction, the net increase of construction vehicle trips to the existing traffic volumes on local roadways would be relatively small and would not result in carbon monoxide (CO) hotspots. These construction - related trips would only occur in the short-term, and because trip -generating land uses are not associated with the proposed program, impacts associated with CO hotspots would be less than significant. Off-road heavy-duty diesel equipment would be used only temporarily at each individual structural BMP site, therefore the construction activities associated with each structural BMP project in the EWMP areas would not expose sensitive receptors to substantial emissions of TACs. During construction of the individual structural BMPs in the project area, sensitive receptors such as residences, schools, hospitals, and daycare centers would be exposed to significant adverse localized air quality impacts. Operation of structural BMPs would not involve the emission of toxic air contaminants (TAC), and would operate passively without use of mechanical equipment. Project operation would not introduce health risks associated with TAC emissions. Construction activities could expose sensitive receptors to criteria air pollutants from vehicle exhaust and dust. Depending on the size and scope of the individual structural BMPs, a localized significance threshold (LST) analysis may be required to ensure construction emissions LA County Flood Control District 19 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact would not exceed SCAQMD's LSTs or result in pollutant emissions that would cause or contribute to the exceedance of the most stringent applicable federal or state ambient air quality standards. Finding The proposed program has the potential to expose sensitive receptors to substantial criteria air pollutant concentrations. However, implementation of Mitigation Measure AIR -3 would reduce this impact to a less -than -significant level. Brief Explanation of the Rationale for Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts to the exposure of sensitive receptors to substantial pollutant concentrations. Implementation of Mitigation Measure AIR -3 would reduce this impact to a less -than -significant level. AIR -3: For large construction efforts associated with regional or centralized BMPs, implementing agencies shall conduct a project -specific LST analysis where necessary to determine local health impacts to neighboring land uses. Where it is determined that construction emissions would exceed the applicable LSTs or the most stringent applicable federal or state ambient air quality standards, the structural BMP project shall reduce its daily construction intensity (e.g., reducing the amount of equipment used daily, reducing the amount of soil graded/excavated daily) to a level where the structural BMP project's construction emissions would no longer exceed SCAQMD's LSTs or result in pollutant emissions that would cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standards. Significant Effect The proposed program could create objectionable odors affecting a substantial number of people (Impact 3.2-5). Description of Significant Impact The proposed program does not include any uses typically associated with odor complaints including agricultural uses, wastewater treatment plants, food processing plans, and landfills, among others. During the construction phase, exhaust odors from equipment may produce discernible odors typical of most construction sites and would be a temporary source of nuisance to adjacent uses. These odors would be temporary and intermittent in nature, so would not be considered a significant environmental impact. Certain BMPs such as restored creeks and estuaries may result in odors from saturated mud or algal blooms when left permanently wet. This may result in a severe nuisance for sensitive receptors near such BMPs, and regular maintenance may be sufficient to reduce odors in some situations. Finding The proposed program has the potential to create objectionable odors affecting a substantial number of people. However, implementation of Mitigation Measures AES -2 and AIR -4 would reduce impacts to a less -than -significant levels. lA County Flood Control District 20 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad Brief Explanation of the Rationale for Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce the potential creation of objectionable odors affecting substantial numbers of people. Implementation of Mitigation Measures AES -2 and AIR -4 would reduce this impact to a less -than -significant level. AES -2: Implementing agencies shall develop BMP maintenance plans that are approved concurrently with each structural BMP approval. The maintenance plans must include measures to ensure functionality of the structural BMPs for the life of the BMP. These plans may include general maintenance guidelines that apply to a number of smaller distributed BMPs. AIR -4: During planning of structural BMPs, implementing agencies shall assess the potential for nuisance odors to affect a substantial number of people. BMPs that minimize odors shall be considered the priority when in close proximity to sensitive receptors. 5.3 Biological Resources Significant Effect The proposed program would have a substantial adverse impact, either directly or through habitat modifications, on species identified as special -status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service (Impact 3.3-1). Description of Significant Impact Construction of structural BMPs may affect large open space or riparian habitats that would have a higher potential to support special -status wildlife species, such as streams, wetlands, and upland scrub or oak woodlands. Mitigation Measures 13I0-1 through 13I0-8 require suitability studies for potential BMP sites for their potential to impact valued habitats, and require impact characterization, minimization and compensation for impacts to highly valued habitats in consultation with the USFWS and CDFW. The proposed program will implement BMPs that are designed to retain dry -weather flows, which could reduce wetted area or completely eliminate flows in certain drainages that support sensitive species. Implementation of Mitigation Measures BIO -1 through 13I0-8 would help ensure that impacts to downstream biological resources are less than significant for regional and centralized BMPs. The smaller distributed BMPs would not result in significant impacts and would not be required to implement the mitigation measures. Finding The proposed program would have a substantial adverse impact, either directly or through habitat modifications, on species identified as special -status species in local or regional plans, policies, or regulations, or by California Department of Fish and Wildlife or the U.S. Fish and Wildlife LA County Flood Control District 21 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact Service. These impacts would be reduced to a less -than -significant level with the implementation of the mitigation measures described below. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would have a substantial adverse impact, either directly or through habitat modifications, on any sensitive species identified as special -status in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service. In consideration of the potential use of the project site by special -status wildlife species, impacts on special -status wildlife species would be significant. Implementation of Mitigation Measures 13I0-1 through 13I0-8 would reduce impacts to a less -than -significant level. BI0-1: Prior to approving a regional or centralized BMP, the Permittee shall conduct an evaluation of the suitability of the BMP location. Appropriate BMP sites should avoid impacting large areas of native habitats including upland woodlands and riparian forests that support sensitive species to the extent feasible. The evaluation shall include an assessment of potential downstream impacts resulting from flow diversions. BI0-2: Prior to ground -disturbing activities in areas that could support sensitive biological resources, a habitat assessment shall be conducted by a qualified biologist to determine the potential for special -status wildlife species to occur within affected areas, including areas directly or indirectly impacted by construction or operation of the BMPs. BI0-3: If a special -status wildlife species is determined to be present or potentially present within the limits of construction activities, a qualified biologist shall conduct preconstruction surveys of proposed work zones and within an appropriately sized buffer around each area as determined by a qualified biologist within 14 days prior to ground disturbing activities. Any potential habitat capable of supporting a special -status wildlife species shall be flagged for avoidance if feasible. BI04: If avoidance of special -status species or sensitive habitats that could support special -status species (including, but not limited to, critical habitat, riparian habitat, and jurisdictional wetlands/waters) is not feasible, the Permittee shall consult with the appropriate regulating agency (USACE/USFWS or CDFW) to determine a strategy for compliance with the Endangered Species Act, California Fish and Game Code, and other regulations protecting special -status species and sensitive habitats. The Permittee shall identify appropriate impact minimization measures and compensation for permanent impacts to sensitive habitats and species in consultation with regulatory agencies. Construction of the project will not begin until the appropriate permits from the regulatory agencies are approved. BI0-5: If construction and vegetation removal is proposed between February 1 and August 31, a qualified biologist shall conduct a pre -construction survey for breeding and nesting birds and raptors within 500 -feet of the construction limits to determine and map LA County Flood Control District 22 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact the location and extent of breeding birds that could be affected by the project. Active nest sites located during the pre -construction surveys shall be avoided until the adults and young are no longer reliant on the nest site for survival as determined by a qualified biologist. BI0-6: All construction areas, staging areas, and right-of-ways shall be staked, flagged, fenced, or otherwise clearly delineated to restrict the limits of construction to the minimum necessary near areas that may support special -status wildlife species as determined by a qualified biologist. BI0-7: Prior to construction in areas that could support special -status plants, a qualified botanist shall conduct a pre -construction floristic inventory and focused rare plant survey of project areas to determine and map the location and extent of special -status plant species populations within disturbance areas. This survey shall occur during the typical blooming periods of special -status plants with the potential to occur. The plant survey shall follow the CDFW Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (November 24, 2009). BI0-8: If temporary construction -related impacts to special -status plant populations are identified within a disturbance area, the implementing agencies shall prepare and implement a special -status species salvage and replanting plan. The salvage and replanting plan shall include measures to salvage, replant, and monitor the disturbance area until native vegetation is re-established under the direction of CDFW and USFWS. Significant Effect The proposed program would have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the CDFW or USFWS. (Impact 3.3-2) Description of Significant Impact Significant Ecological Areas (SEA), as identified by the Los Angeles County General Plan, riparian, and other sensitive communities are not expected to occur within the disturbance areas of the BMP projects since the majority of the structural BMPs would occur in developed or disturbed areas. While some regional and centralized structural BMPs could occur within or adjacent to SEAS, riparian habitat or other sensitive natural communities, these types of BMPs would provide multi -beneficial water quality and habitat restoration improvements to the applicable EWMP watershed. Additionally, each development proposed within a designated SEA must undergo a performance review process for compliance with the SEA design compatibility criteria and other standards for approval by the LA County Department of Regional Planning. Finding Future project -level environmental review processes would consider all proposed projects on a case-by-case basis to determine whether an individual project would impact riparian or other sensitive natural communities. Site-specific mitigation measures would be required to minimize LA County Flood Control District 23 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad and reduce potentially significant impacts to riparian and other sensitive natural communities. These impacts would be reduced to a less -than -significant level with the implementation of Mitigation Measures 13I0-1 through 13I0-8. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the CDFW or USFWS. Implementation of Mitigation Measure BI0-1 through BI0-8 would reduce impacts to a less -than -significant level. Significant Effect The proposed program would have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. (Impact 3.3-3) Description of Significant Impact Wetlands occur throughout the EWMP areas, and once project facility locations are determined, exact locations and acreages of jurisdictional areas located within or adjacent to impact areas shall be determined through a formal jurisdictional delineation. For projects impacting native vegetation within jurisdictional drainages, the implementing agency would be required to obtain California Fish and Game Code Section 1602 compliance and Section 404 compliance from the USACE and Section 401 Certification from the RWQCB. In addition, implementation of Mitigation Measures 13I0-1 through 13I0-9 would ensure compliance with state and federal regulations relating to potentially jurisdictional features, including wash habitat vegetation that may fall under CDFW jurisdiction. Finding Any projects impacting native vegetation within jurisdictional drainages would be required to comply with California Fish and Game Code Section 1602 compliance and Section 404 compliance from the USACE and Section 401 Certification from the RWQCB. These impacts would be further reduced to a less -than -significant level with the implementation of the mitigation measures described below. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act through direct removal, filling, hydrological interruption, or other means. Implementation of Mitigation Measures BI0-1 through BI0-9 would reduce impacts to a less -than -significant level. BI0-9: Prior to construction, a qualified wetland delineator shall be retained to conduct formal wetland delineation in areas where potential jurisdictional resources (i.e., wetlands or drainages) subject to the jurisdiction of USACE, RWQCB, and CDFW may be LA County Flood Control District 24 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fad Findings of Fad affected by the project. If jurisdictional resources are identified in the EWMP area and would be directly or indirectly impacted by individual projects, the qualified wetland delineator shall prepare a jurisdictional delineation report suitable for submittal to USACE, RWQCB, and CDFW for purposes of obtaining the appropriate permits. Habitat mitigation and compensation requirements shall be implemented prior to construction in accordance with Mitigation Measure 13I0-4. Significant Effect The proposed program would conflict with local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. (Impact 3.3-5) Description of Significant Impact The proposed program would mainly be constructed within highly urbanized and disturbed areas within existing infrastructure. Any impacts to oak trees within Los Angeles County would be required to comply with the Oak Tree Preservation Ordinance (or other tree ordinances established by the local city). A tree permit may be required if impacts to oak trees or other protected trees are determined to be necessary. Finding No impacts to oak trees or other protected tree species is anticipated. However, the exact locations of the BMP projects have not been established. Implementation of Mitigation Measure BIO -10 would reduce any potential impacts to protected tree species to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. Implementation of Mitigation Measure BIO -10 would reduce impacts to a less -than -significant level. BIO -10: Oak trees and other protected trees shall be avoided to the extent feasible. If trees may be impacted by project construction, a certified arborist shall conduct a tree inventory of the construction impact area. If any oak trees or other protected trees will be impacted by BMP construction, the implementing agency shall obtain any required County or City permits. Significant Effect The proposed program would result in cumulative biological resource impacts. Description of Significant Impact Cumulatively, throughout the region, the retention of stormwater and treatment of pollutants within each watershed, and the reduction of pollutant loading in waterways would substantially benefit the water quality of the region's aquatic and coastal habitats, as well as the plants and wildlife dependent on them. Implementation of the BMPs would also return the local hydrology LA County Flood Control District 25 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact to a more natural condition. Although some drainage segments may exhibit reduced riparian habitat or wetlands over time due to the reduced dry -weather flow, the cumulative effect would be offset by increased groundwater recharge and seepage supporting expanded wetland and riparian vegetation supporting local flora and fauna populations. Therefore, the program's potential contribution to cumulative effects on biological resources is considered less than significant. Finding Most of the distributed BMPs would be small in scale and would not result in cumulatively significant impacts, as they would occur within existing developed or disturbed areas at existing stormwater infrastructure/facilities. For regional and centralized BMPs at the larger scale, Mitigation Measures 13I0-1 through BIO -10 would reduce potentially significant impacts to biological resources, and any additional or more site-specific mitigation measures developed during the future project -level environmental review processes may further reduce potential impacts. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts to biological resources. Any potentially significant cumulative impacts to biological resources in the project region would be reduced by the implementation of Mitigation Measures 13I0-1 through 13I0-10. 5.4 Cultural Resources Significant Effect The proposed program could cause a substantial adverse change in the significance of unique archaeological resources as defined in § 15064.5 (Impact 3.4-2). Description of Significant Impact The program area, which spans most of Los Angeles County, should be considered sensitive for archaeological resources, with degree of sensitivity varying across the program area based on specific environmental factors. Any structural BMP which involves grading, trenching, excavation, vegetation removal, or other forms of ground disturbance could impact archaeological resources. Finding The proposed program's potential to cause a substantial adverse change in the significance of unique archaeological resources is considered significant; however, potential adverse effects caused by the proposed program could be mitigated to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would cause a substantial adverse change in the significance of unique LA County Flood Control District 26 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad archaeological resources. The project impacts are considered significant but would be reduced to a level that is less than significant with implementation of Mitigation Measures CUL -2 through CUL -2. CUL -2: Implementing agencies shall ensure that individual EWMP projects that require ground disturbance shall be subject to a Phase I cultural resources inventory on a project - specific basis prior to the implementing agency's approval of project plans. The study shall be conducted or supervised by a qualified archaeologist, defined as an archaeologist meeting the Secretary of the Interior's Professional Qualifications Standards for Archaeology, and shall be conducted in consultation with the local Native American representatives expressing interest. The cultural resources inventory shall include a cultural resources records search to be conducted at the South Central Coastal Information Center; scoping with the NAHC and with interested Native Americans identified by the NAHC; a pedestrian archaeological survey where deemed appropriate by the qualified archaeologist; and formal recordation of all identified archaeological resources on California Department of Parks and Recreation 523 forms and significance evaluation of such resources presented in a technical report following the guidelines in Archaeological Resource Management Reports (ARMR): Recommended Contents and Format, Department of Parks and Recreation, Office of Historic Preservation, State of California, 1990. If potentially significant archaeological resources are encountered during the survey, the implementing agency shall require that the resources are evaluated by the qualified archaeologist for their eligibility for listing in the CRHR and for significance as a historical resource or unique archaeological resource per CEQA Guidelines Section 15064.5. Recommendations shall be made for treatment of these resources if found to be significant, in consultation with the implementing agency and the appropriate Native American groups for prehistoric resources. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred manner of mitigation to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project reroute or redesign, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, which may include data recovery or other appropriate measures, in consultation with the implementing agency, and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. CU1-3: The implementing agency shall retain archaeological monitors during ground - disturbing activities that have the potential to impact archaeological resources qualifying as historical resources or unique archaeological resources, as determined by a qualified archaeologist in consultation with the implementing agency, and any local Native LA County Flood Control District 27 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad American representatives expressing interest in the project. Native American monitors shall be retained for projects that have a high potential to impact sensitive Native American resources, as determined by the implementing agency in coordination with the qualified archaeologist. CU1,4: During project -level construction, should subsurface archaeological resources be discovered, all activity in the vicinity of the find shall stop and a qualified archaeologist shall be contacted to assess the significance of the find according to CEQA Guidelines Section 15064.5. If any find is determined to be significant, the archaeologist shall determine, in consultation with the implementing agency and any local Native American groups expressing interest, appropriate avoidance measures or other appropriate mitigation. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred means to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project reroute or redesign, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, such as data recovery or other appropriate measures, in consultation with the implementing agency and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. Significant Effect The proposed program could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature (Impact 3.4-3). Description of Significant Impact The program area is underlain by a number of high or undetermined paleontological sensitivity units, which may contain significant paleontological resources. Significant paleontological resources can be uncovered even in areas of low sensitivity, though, and it is possible that ground -disturbing construction activities associated with structural BMPs could result in the inadvertent discovery of paleontological resources, which could be a significant impact. Finding The proposed program's potential to directly or indirectly damage or destroy unique paleontological resources or sites or unique geologic features is considered significant; however, potential adverse effects caused by the proposed program could be mitigated to a less -than - significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would damage or destroy paleontological resources or sites or unique geologic LA County Flood Control District 28 ESA 1140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact features. The project impacts are considered significant but would be reduced to a level that is less than significant with implementation Mitigation Measures CUL -5 and CUL -6. CU1,5: For individual structural BMP projects that require ground disturbance, the implementing agency shall evaluate the sensitivity of the project site for paleontological resources. If deemed necessary, the implementing agency shall retain a qualified paleontologist to evaluate the project and provide recommendations regarding additional work, potentially including testing or construction monitoring. CUL -6: In the event that paleontological resources are discovered during construction, the implementing agency shall notify a qualified paleontologist. The paleontologist will evaluate the potential resource, assess the significance of the find, and recommend further actions to protect the resource. Significant Effect The proposed program could disturb human remains, including those interred outside of formal cemeteries (Impact 3.4-4). Description of Significant Impact There is no indication, either from the archival research results or the archaeological survey, that any particular location in the project area has been used for human burial purposes in the recent or distant past. However, in the event that human remains are inadvertently discovered during project construction activities, the human remains could be inadvertently damaged, which could be a significant impact. Finding The proposed program's potential to uncover buried archaeological deposits including human remains is considered significant; however, potential adverse effects caused by the project could be mitigated to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to the disturbing of any human remains, including those interred outside of a formal cemetery. The project impacts are considered significant but would be reduced to a level that is less than significant with implementation of Mitigation Measure CUL -7. CUIr7: The implementing agency shall require that, if human remains are uncovered during project construction, work in the vicinity of the find shall cease and the County Coroner shall be contacted to evaluate the remains, following the procedures and protocols set forth in Section 15064.5 (e)(1) of the CEQA Guidelines. If the County Coroner determines that the remains are Native American, the Coroner will contact the Native American Heritage Commission, in accordance with Health and Safety Code Section 7050.5, subdivision (c), and Public Resources Code 5097.98 (as amended by AB 2641). The NAHC will then designate a Most Likely Descendant of the deceased LA County Flood Control District 29 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact Native American, who will engage in consultation to determine the disposition of the remains. 5.5 Geologic and Mineral Resources Significant Effect The proposed program could be located on a geological unit or soil that is unstable, or that would become unstable as a result of the program, and potentially result in on-site or off-site non - seismically induced geologic hazards such as landslides, lateral spreading, subsidence, collapse or sinkholes, settlement, or slope failure (Impact 3.5-3). Description of Significant Impact Infiltration of water into subsurface soils can increase soil instability and result in saturated soils, soil piping through preferential pathways, breakouts due to infiltrated water finding utility trenches and other preferential pathways, and raising the local groundwater levels such that infrastructure foundations and underground structures could be affected by unstable soils. Structural BMPs could potentially be undermined by unstable soils or impact adjacent infrastructure and buildings; Mitigation Measure GEO-1 would reduce the impact to a less -than - significant level. Finding The proposed program's potential to be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the program, and potentially result in on-site or off-site non - seismically induced geologic hazards such as landslides, lateral spreading, subsidence, collapse or sinkholes, settlement, or slope failure is considered significant; however, potential adverse effects caused by the proposed program would be mitigated to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to the project being located on a geologic unit or soil that is unstable, or that would become unstable as a result of the program, and potentially result in on-site or off-site non - seismically induced geologic hazards such as landslides, lateral spreading, subsidence, collapse or sinkholes, settlement, or slope failure. The project impacts are considered significant but would be reduced to a level that is less than significant with implementation of Mitigation Measure GEO-1. GEO-1: Prior to approval of infiltration BMPs, implementing agencies shall conduct a geotechnical investigation of each infiltration BMP site to evaluate infiltration suitability. If infiltration rates are sufficient to accommodate an infiltration BMP, the geotechnical investigation shall recommend design measures necessary to prevent excessive lateral spreading that could destabilize neighboring structures. Implementing agencies shall implement these measures in project designs. LA County Flood Control District 30 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact Significant Effect Cumulative impacts on geology and soils would have a less than significant impact on the environment with implementation of mitigation. Description of Significant Impact The cumulative effect of multiple infiltration projects could increase the severity of perched or migrating water, which has the potential to inundate underground utilities or structures. Mitigation Measure GEO-1 would minimize the cumulative impact to regional infrastructure from perched or migrating water. The management of groundwater pumping among regional managers prevents impacts to structural foundations resulting from groundwater mounding from existing recharge efforts. Mitigation Measure GEO-2 would reduce the cumulative effects to soil stability from elevated groundwater levels to a less -than -significant level. Finding The proposed program's cumulative impact to geology and soils is considered significant; however, potential adverse effects caused by the proposed program would be mitigated to a less - than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce cumulative impacts related to geology and soils. The cumulative project impacts are considered significant but would be reduced to a level that is less than significant with implementation of Mitigation Measures GEO-1 and GEO-2. GEO-1: Prior to approval of infiltration BMPs, implementing agencies shall conduct a geotechnical investigation of each infiltration BMP site to evaluate infiltration suitability. If infiltration rates are sufficient to accommodate an infiltration BMP, the geotechnical investigation shall recommend design measures necessary to prevent excessive lateral spreading that could destabilize neighboring structures. Implementing agencies shall implement these measures in project designs. GEO-2: Prior to installing BMPs designed to recharge the local groundwater supplies, the implementing agency shall notify local groundwater managers, including the Upper Los Angeles River Area Water Master, the Water Replenishment District of Southern California, or the San Gabriel Water Master as well as local water producers such as local municipalities and water companies. The implementing agency shall coordinate BMP siting efforts with groundwater managers and producers to mitigate high groundwater levels while increasing local water supplies. 5.6 Greenhouse Gas Emissions The proposed program would not have any environmental effects related to greenhouse gas emissions that are potentially significant but can be mitigated to less -than -significant levels. LA County Flood Control District 31 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact 5.7 Hazards and Hazardous Materials Significant Effect The proposed program would create a significant hazard to the public or the environment through the accumulation of potentially hazardous materials into BMPs (Impact 3.7-2). Description of Significant Impact Because of their function as water conveyance systems, the entire storm sewer system, as augmented by structural BMPs, would collect and retain sediment and chemicals from urban runoff, along with any accidental or illicit spills of hazardous materials. The introduction of hazardous materials into the storm sewer system could occur in large events as in a catastrophic spill, or could occur in small concentrations as in petroleum hydrocarbons and heavy metals picked up and carried by stormwater in urban runoff from the streets. Contaminants in the runoff water or as discrete concentrated spills could accumulate in the soils and vegetation of structural BMPs. To address the accumulation of contaminants in soil at BMPs, operations and maintenance plans for BMPs that might accumulate constituents in surface soils and media will be developed to include periodic removal and replacement of these potentially impacted surface materials to reduce the potential for long-term loading leading to hazardous concentrations in soils and groundwater. Finding The proposed program has the potential to create a significant hazard to the public or the environment through the accumulation of potentially hazardous materials into BMPs. The implementation of Mitigation Measure HAZ-1 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to the creation of a significant hazard to the public or the environment through the accumulation of potentially hazardous materials into BMPs to less -than -significant. With the implementation of Mitigation Measure HAZ-1, these impacts would be considered less than significant. HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The Maintenance Plan shall include vector control requirements. The BMP Maintenance Plan LA County Flood Control District 32 ESA 1140474 Enhanced Watershed Management Programs April 2015 Findings of Fad Findings of Fact may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. Significant Effect The proposed program would be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, could create a significant hazard to the public or the environment (Impact 3.74). Description of Significant Impact It is possible that a proposed BMP may be located on a hazardous materials site listed on the Cortese List, which would expose construction workers, the public, and the environment to hazardous materials during earth -moving activities, introducing a significant impact. Finding The proposed program has the potential to result in significant impacts related to the project location on a site which is included on a list of hazardous materials sites, and, as a result, could create a significant hazard to the public or the environment. The implementation of Mitigation Measure HAZ-2 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to hazardous materials to less -than -significant. With the implementation of Mitigation Measures HAZ-2, these impacts would be considered less than significant. HAZ-2: Prior to the initiation of any construction requiring ground -disturbing activities in areas where hazardous material use or management may have occurred, the implementing agencies shall complete a Phase I Environmental Site Assessment (ESA) in accordance with American Society for Testing and Materials Standard E1527-13 for each construction site. Any recommended follow up sampling (Phase 11 activities) set forth in the Phase I ESA shall be implemented prior to construction. The results of Phase II studies, if necessary, shall be submitted to the local overseeing agency and any required remediation or further delineation of identified contamination shall be completed prior to commencement of construction. Significant Effect For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, for a project within the vicinity of a private airstrip, the proposed program could result in a safety hazard for people residing or working in the project area (Impact 3.7-5). LA County Flood Control District 33 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact Description of Significant Impact Some structural BMPs, such as detention basins that store water for a period of time or constructed wetlands that would increase or improve wildlife habitat, could be constructed on or near airports and could result in attracting wildlife. Deer and birds are known wildlife hazards to airports. If the proposed project is at or near an airport, this could increase hazards to aircraft from wildlife. Finding The proposed program, if located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, for a project within the vicinity of a private airstrip, has the potential to result in safety hazard for people residing or working in the project area. The implementation of Mitigation Measures HAZ-3 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to hazardous materials to less -than -significant. With the implementation of Mitigation Measures HAZ-3, these impacts would be considered less than significant. HAZ-3: Implementing Agencies shall require that those BMPs that are within an airport land use plan area are compatible with criteria specified in FAA Advisory Circular No: 150/5200-33B (FAA, 2007). If the proposed BMP is within the minimum separation criteria, the implementing agency shall consult with the airport and collaboratively evaluate whether the potential increase in wildlife hazards can be mitigated. Significant Effect The proposed program would result in cumulatively significant impacts to hazardous materials. Description of Significant Impact Most of the distributed BMPs would be small in scale and would not result in cumulatively significant impacts due to increased hazards from construction or operation. However, the combination of BMPs throughout the region would change the flow paths of stormwater and urban runoff that currently occurs in the region, resulting in the retention of pollutants generally within the soil of the BMPs that use soil for filtration and retention. Cumulatively, throughout the region, the retention and treatment of pollutants within each watershed and the reduction of pollutant loading in waterways will substantially benefit water and sediment quality of the region's habitats, rivers, and beaches. Therefore, the project's potential contribution to cumulative effects on hazards and hazardous materials is considered beneficial. Finding The proposed program has the potential to result in cumulatively considerable impacts related to hazardous resources. Hazardous material could be released during project construction or operation. The implementation of appropriate safety measures during construction of the proposed project, as well as any other cumulative project, would reduce the impact to a level that LA County Flood Control District 34 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact would not contribute to cumulative effects. Implementation of Mitigation Measures HA -Z-1, HAZ-2, and HAZ-3 would reduce impacts to less -than -significant levels. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce cumulative impacts caused by the project. With the implementation of Mitigation Measures HAZ-1, HAZ-2, and HAZ-3, impacts would be less than significant. 5.8 Hydrology and Water Quality Significant Effect The proposed program would result in higher groundwater levels and could potentially affect groundwater quality (Impact 3.8-2). Description of Significant Impact Regional BMPs would recharge stormwater into the groundwater basin and could raise local groundwater levels following major storm events. Distributed infiltration BMPs would typically be too small to have a measureable effect on local groundwater levels. The increased water supplies captured by the infiltration basins through the EWMP areas would be a beneficial impact of the projects. Infiltration BMPs would not be suitable in areas of low permeability, though, and potential locations would need to be evaluated for suitability. Concentrations of contaminants found in stormwater runoff could increase, resulting in contaminated shallow soils and groundwater. Finding The proposed program has the potential to result significant impacts related to higher groundwater levels and degradation of groundwater quality. The implementation of Mitigation Measures HYDRO -1 through HYDRO -3 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to higher groundwater levels and potential degradation of groundwater quality to less -than -significant. With the implementation of Mitigation Measures HYDRO -1 through HYDRO -3, these impacts would be considered less than significant. HYDRO -1: Prior to approving an infiltration BMP, the Permittee shall conduct an evaluation of the suitability of the BMP location. Appropriate infiltration BMP sites should avoid areas with low permeability where recharge could adversely affect neighboring subsurface infrastructure. HYDRO -2: Prior to approving an infiltration BMP, the Permittee shall identify pretreatment technologies, type, and depth of filtration media; depth to groundwater; and other design considerations necessary to prevent contaminants from impacting groundwater quality. The design shall consider stormwater quality data within the BMP's LA County Flood Control District 35 ESA 1140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact collection area to assess the need and type of treatment and filtration controls. Local design manuals and ordinances requiring minimum separation distance to groundwater shall also be met as part of the design. HYDRO -3: Prior to the installation of an infiltration BMP, the Permittee shall conduct a regulatory database review for contaminated groundwater sites within a quarter mile of the proposed infiltration facility. The review shall include locations of on-site wastewater treatment systems. The Permittee shall identify whether any contaminated groundwater plumes or leach fields are present and whether coordination with the local and state environmental protection overseeing agency and responsible party is warranted prior to final design of infiltration facility. 5.9 Land Use and Agriculture The proposed program would not have any environmental effects on land use that are potentially significant and that cannot be mitigated to less -than -significant levels. 5.10 Noise Significant Effect The proposed program would result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project (Impact 3.10-3). Description of SigniFcant Impact No operational noise levels would be generated by the structural BMPs given their passive manner of operation. However, it is anticipated that some of the centralized and regional structural BMPs would require the use of irrigation pump stations and associated components to divert the collected stormwater. At these structural BMP sites, noise levels generated from the long-term operation of the pumps and associated components could result in increased noise levels in the surrounding noise environment. Finding The proposed program has the potential to result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project. The implementation of Mitigation Measures NOISE -I and NOISE -2 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project. With the implementation of Mitigation Measures NOISE -1 and NOISE -2 included below, these impacts would be considered less than significant. LA County Flood Control District 36 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad NOISE -1: The implementing agencies shall implement the following measures during construction as needed: • Include design measures necessary to reduce the construction noise levels to where feasible. These measures may include noise barriers, curtains, or shields. • Place noise -generating construction activities (e.g., operation of compressors and generators, cement mixing, general truck idling) as far as possible from the nearest noise -sensitive land uses. • Locate stationary construction noise sources as far from adjacent noise -sensitive receptors as possible. • If construction is to occur near a school, the construction contractor shall coordinate the with school administration in order to limit disturbance to the campus. Efforts to limit construction activities to non -school days shall be encouraged. • For the centralized and regional BMP projects located adjacent to noise -sensitive land uses, identify a liaison for these off-site sensitive receptors, such as residents and property owners, to contact with concerns regarding construction noise and vibration. The liaison's telephone number(s) shall be prominently displayed at construction locations. • For the centralized and regional BMP projects located adjacent to noise -sensitive land uses, notify in writing all landowners and occupants of properties adjacent to the construction area of the anticipated construction schedule at least 2 weeks prior to groundbreaking. NOISE -2: All structural BMPs that employ mechanized stationary equipment that generate noise levels shall comply with the applicable noise standards established by the implementing agency with jurisdiction over the structural BMP site. The equipment shall be designed with noise -attenuating features (e.g., enclosures) and/or located at areas (e.g., belowground) where nearby noise -sensitive land uses would not be exposed to a perceptible noise increase in their noise environment. 5.11 Population and Housing and Environmental Justice The proposed program would not have any environmental effects related to population, housing and environmental justice that would be potentially significant, but could be mitigated to less than significant levels. LA County Flood Control District 37 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact 5.12 Public Services and Recreation Significant Effect The proposed program would not result in substantial adverse physical impacts associated with the provision of, or need for, new or physically altered governmental fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for fire protective services (Impact 3.12-1). Description of Significant Impact The structural BMPs are not habitable structures, would not be constructed with flammable materials, and would not require fire protection services. Because of the relative scale of these infrastructure improvements, the construction of the various structural BMPs are not expected to result in the need for new or physically altered fire protection facilities. However, construction of new structural BMPs in streets, sidewalks, parkland, or other facilities (these may include public service facilities such as police stations, fire stations, and municipal maintenance yards) within existing high-density urban, commercial, industrial, and transportation areas, as well as associated staging areas, could temporarily disrupt the provision of fire services, resulting in potentially significant impacts. Finding The proposed program has the potential to result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered governmental fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for fire protection services. Implementation of Mitigation Measure PS -1 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project related to significant cumulative impacts associated with public services. With the implementation of Mitigation Measure PS -1, these impacts would be considered less than significant. PS -1: The Permittee implementing the EWMP project shall provide reasonable advance notification to service providers such as fire, police, and emergency medical services as well as to local businesses, homeowners, and other residents adjacent to and within areas potentially affected by the proposed EWMP project about the nature, extent, and duration of construction activities. Interim updates should be provided to inform them of the status of the construction activities. LA County Flood Control District 38 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fad Findings of Fact 5.13 Transportation and Circulation Significant Effect The proposed program would intermittently and temporarily increase traffic levels and traffic delays due to vehicle trips generated by construction workers and construction vehicles on area roadways (Impact 3.13-1). Description of Significant Impact Vehicle trips would be generated primarily by construction workers commuting to and from the BMP work sites, and by trucks hauling materials and equipment to and from the sites. The construction traffic impacts associated with each individual structural BMP project would be short-term in nature and limited to the period of time when construction activity is taking place for that particular project. Although project -related traffic would be temporary, supplemental project -level analysis of potential site-specific impacts could determine that addition of project - generated traffic would be considered substantial in relation to traffic flow conditions on local roadways. For this program -level assessment, this impact is considered potentially significant. Finding The proposed program will potentially intermittently and temporarily increase traffic levels and traffic delays due to vehicle trips generated by construction workers and construction vehicles on area roadways; however, implementation of Mitigation Measure TRAF-1 would reduce impacts to a less -than- significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to temporary and intermittent increase in traffic levels and traffic delays due to vehicle trips generated by construction workers and construction vehicles on area roadways to less -than -significant. With the implementation of Mitigation Measure TRAF-1, below, this impact would be considered less than significant. TRAF-1: For projects that may affect traffic, implementing agencies shall require that contractors prepare a construction traffic control plan. Elements of the plan should include, but are not necessarily limited to, the following: • Develop circulation and detour plans to minimize impacts to local street circulation. Use haul routes minimizing truck traffic on local roadways to the extent possible. • To the extent feasible, and as needed to avoid adverse impacts on traffic flow, schedule truck trips outside of peak morning and evening commute hours. • Install traffic control devices as specified in Caltrans' Manual of Traffic Controls for Construction and Maintenance Work Zones where needed to maintain safe driving conditions. Use flaggers and/or signage to safely direct traffic through construction work zones. LA County Flood Control District 39 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact • Coordinate with facility owners or administrators of sensitive land uses such as police and fire stations, hospitals, and schools. Provide advance notification to the facility owner or operator of the timing, location, and duration of construction activities. Significant Effect The proposed program would contribute to cumulative impacts to traffic and transportation (Impact 3.13-4). Description of Significant Impact During construction of the structural BMPs, intermittent and temporary traffic -related impacts in the cumulative context would occur. The proposed program has the potential to contribute to potentially significant cumulative construction -related impacts as a result of (1) cumulative projects (such as land development projects) that generate increased traffic at the same time on the same roads as would the proposed program, causing increased congestion and delays; and (2) infrastructure projects in roads that would be used by project construction workers and trucks, which could delay project -generated vehicles past the work zones of those other projects. Finding The proposed program is expected to cumulatively impact traffic and transportation; however, implementation of Mitigation Measure TRAF-1 is expected to reduce impacts to a less -than - significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to cumulative impacts to traffic and transportation to less than significant. With the implementation of Mitigation Measure TRAF-1, these impacts would be considered less than significant. 5.14 Utilities and Service Systems Significant Effect The proposed program would require new or expanded water supply resources or entitlements or require or result in the construction of new water facilities or expansion of existing facilities, the construction of which could cause significant environmental effects (Impact 3.14-3). Description of Significant Impact Implementation of the EWMPS would not increase water demand due to the relatively short construction period for structural BMPs. Impacts to the existing water supplies are anticipated to be beneficial as a result of the stormwater and non-stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. Construction requiring ground disturbance could encounter buried utilities including water supply infrastructure. Construction of BMPs to detain stormwater and dry -weather flows may reduce flows downstream, thereby LA County Flood Control District 40 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact reducing access to beneficial uses downstream. As part of the project design, Implementing Agencies would be required to identify the potential for underground utilities and determine whether they would need to be relocated to accommodate the BMP. Dry -weather flows in coastal streams and foothills are largely fed by groundwater seepage or wastewater discharges. Any detention of storm flows upstream would not substantially reduce storm flows downstream or significantly impede access to storm flow. Finding The proposed program is not expected to require expansion of existing water entitlements or result in the construction of new facilities that could result in environmental effects; the proposed program would further reduce its impact by implementing Mitigation Measure UTIL-1. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to landfill capacity to less than significant. With the implementation of Mitigation Measure UTIL-1, these impacts would be considered less than significant. UTIIrl: Prior to implementation of BMPs, the implementing agency shall conduct a search for local utilities above and below ground that could be affected by the project. The implementing agencies shall contact each utility potentially affected and relocate the utility if necessary to ensure access and services are maintained. DTII. -2: Prior to approval of BMPs, implementing agencies shall evaluate the potential for impacts to downstream beneficial uses including surface water rights. Implementing agencies shall not approve BMPs that result in preventing access to previously appropriated surface water downstream. Significant Effect The proposed program would be served by a landfill with insufficient permitted capacity to accommodate the proposed program's solid waste disposal needs or the proposed program could not comply with federal, state, and local statuses and regulations related to solid waste (Impact 3.14-4). Description of Significant Impact Construction activities associated with the structural BMPs would include excavation and demolition of some existing infrastructure, which would produce solid waste requiring disposal in the nearest landfill. Some of the EWMPs are required to implement trash Total Maximum Daily Limits (TMDLs) and associated trash removal structural BMPs, which would require the disposal of the trash collected by the BMPs, thereby increase the amount of trash being sent to landfills. The non-structural BMPs would include street cleaning, landscape management, and storm drain operation, which produce debris and trash requiring disposal, which could exceed landfill limits. The new trash collected that is associated with proposed trash removal structural BMPs and non- structural BMPs such as street cleaning and landscape management would be accommodated with existing and planned trash disposal facilities. Based on landfill capacity in the Los Angeles LA County Flood Control District 41 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad region, there appears to be ample availability to receive the expected trash generated by the program. The program would comply with all federal, state, and local statutes and regulations related to solid waste, including the Los Angeles County Construction and Demolition Debris Recycling and Reuse Program. Finding The program is not expected to be served by a landfill with insufficient capacity to accommodate its waste disposal needs and would comply with all solid waste regulations; however, implementation of Mitigation Measure UTIL-2 would further reduce impacts to a less -than - significant level Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to landfill capacity to less than significant. With the implementation of Mitigation Measure UTIL-2, these impacts would be considered less than significant. UTI1,3: Implementing agencies shall encourage construction contractors to recycle construction materials and divert inert solids (asphalt, brick, concrete, dirt, fines, rock, sand, soil, and stone) from disposal in a landfill where feasible. Implementing agencies shall incentivize construction contractors with waste minimization goals in bid specifications where feasible. Significant Effect The proposed program would result in less than significant cumulative impacts to utilities and service systems. Description of Significant Impact Structural BMPS constructed to treat, infiltrate, and/or store stormwater and non-stormwater throughout the watershed would not generate wastewater or require wastewater treatment or result in adverse cumulative impacts from operation or construction. Installation of storm drainage facilities identified in the proposed EWMPs would not substantially affect existing storm drain facilities. Impacts to the existing water supplies are anticipated to be beneficial as a result of the stormwater and non-stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. Construction and operation of the structural BMPs would generate solid waste; however, landfills serving the program area are expected to have sufficient capacity to accommodate the amount of waste generated. Disposal of the solid waste generated during construction and operation would comply with all pertinent regulations and statutes. All other projects implemented in the area would also be required to comply with federal, state, and local solid waste regulations and statutes. The use of energy anticipated for the proposed program is minor when compared to the County -wide use of electricity. The proposed program would use energy-efficient equipment and would not result in wasteful consumption. The non-structural BMPs would include street cleaning, landscape management, and storm drain operation, which would produce debris and trash for disposal. LA County Flood Control District 42 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad Finding The proposed program would not likely result in cumulative impacts to utilities and service systems. The proposed program would further reduce its cumulative impact on utilities and service systems to a less -than -significant -level by implementing Mitigation Measures UTIL-1 and UTIL-2. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce cumulative impacts related to utilities and service systems. With the implementation of Mitigation Measure UTI, -1 and UTIL-2, these impacts would be considered less than significant. 6.0 Significant and Unavoidable Environmental Impacts As described above in Section 5.0, the impacts identified above as being less than significant with the implementation of mitigation measures could be significant and unavoidable if the proposed mitigation measures are not adopted and implemented by the Implementing Agencies for projects within their jurisdiction. Because the District cannot ensure that these Implementing Agencies will adopt and implement the proposed mitigation measures, the District finds that the impacts identified in section 5.0 may also be significant and unavoidable with respect to projects where the District will not be an implementing agency. The impacts discussed below were identified in the Final Program EIR as being "significant and unavoidable" for the program because they cannot be mitigated to a less -than -significant level. 6.1 Aesthetics The proposed program would not have any environmental effects on aesthetics that cannot be mitigated to a less -than -significant level. 6.2 Air Quality Significant Effect The proposed program could violate air quality standards or contribute substantially to an existing or projected air quality violation (Impact 3.2-2). Description of Significant Impact Construction activities at the individual project sites would temporarily create emissions of dust, fumes, equipment exhaust, and other air contaminants.. Through representative "worst-case" construction scenarios of each structural BMP type, ranging from small-, medium-, and large- scale projects, the magnitude of the daily emissions that can be generated by each structural BMP type is presented. The maximum daily construction emissions for the three structural BMP project types were estimated using the California Emissions Estimator Model (CalEEMod). The LA County Flood Control District 43 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fad Findings of Fact construction -related emissions of criteria air pollutants for the three structural BMP types were modeled based on general information provided in the project description and CalEEMod default settings along with reasonable assumptions based on other similar types of projects. The model found that for smaller BMPs including distributed BMPs, air emissions would not be significant and would not require mitigation measures. For some of the larger regional and centralized BMPs, the model shows that the maximum daily level of construction -generated emissions of NOx would exceed the applicable SCAQMD-recommended thresholds under the worst-case construction scenarios. Implementation of Mitigation Measures AIR -1 and AIR -2 would reduce emissions, but they may not reduce these emissions to levels below the SCAQMD thresholds for every structural BMP project, as the amount of emissions generated, the land area that would need disturbing, and the length of the construction schedule for each structural BMP project would vary. Implementation of large regional or centralized BMPs could result in temporary significant and unavoidable air emissions during peak periods of construction. Long term operation of the proposed program would not result in substantial emissions of criteria air pollutants. There would be no new land use projects which would generate daily vehicle emissions. Inspection and maintenance activities would occur to the project site, but would be periodic throughout the year and would result in minimal emissions. Equipment for pump stations and ancillary components would be electrically powered, so would not generate emissions at the project site. Finding The proposed program would implement projects that could exceed identified emissions thresholds, and therefore have the potential to violate any air quality standard or substantially contribute to an existing or projected air quality violation. Implementation of Mitigation Measures AIR -1 and AIR -2 would help reduce this impact, but construction emissions would remain significant and unavoidable for some larger projects. Impacts from operational emissions would be considered less -than -significant. Brief Explanation of the Rationale for Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to the violation of any air quality standard or substantial contribution to an existing or projected air quality violation. Implementation of Mitigation Measures AIR -1 and AIR -2 would help reduce the impact, but impacts from construction emissions would remain significant and unavoidable for some of the larger projects. Impacts from operational emissions would be less than significant. AIR -1: Implementing agencies shall require for large regional or centralized BMPs the use of low -emission equipment meeting Tier II emissions standards at a minimum and Tier III and IV emissions standards where available as CARB-required emissions technologies become readily available to contractors in the region. AIR -2: For large construction efforts that may result in significant air emissions, implementing agencies shall encourage contractors to use lower -emission equipment through the bidding process where appropriate. LA County Flood Control District 44 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fad Findings of Fad Significant Effect The proposed program could result in a cumulatively considerable net increase of any criteria pollutant for which the program region is non -attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors) (Impact 3.2-3). The proposed program could result in a significant cumulative impact to air quality. Description of Significant Impact As the Basin is currently in nonattainment for ozone, PM,o, and PM2.5, cumulative development consisting of the proposed program along with other reasonably foreseeable future projects in the Basin as a whole could violate an air quality standard or contribute to an existing or projected air quality violation. Under conditions where multiple structural BMPs would be constructed concurrently in the EWMP areas, it is anticipated that the total aggregate construction emissions generated from these multiple structural BMP projects on a daily basis would exceed the SCAQMD's significance thresholds for criteria pollutants. Even with implementation of Mitigation Measures AIR -1 and AIR -2, the resulting aggregate daily emissions may not be reduced to levels below the SCAQMD thresholds should multiple structural BMP projects be constructed concurrently. Thus, construction -related air quality impacts associated with the proposed program would be considered significant and unavoidable. With respect to operational emissions, program implementation would not result in substantial long-term regional emissions of criteria air pollutants and would not exceed the SCAQMD thresholds of significance for criteria pollutants. As such, the proposed program's operational emissions would not be cumulatively considerable and cumulative air quality impacts would be less than significant. Finding As air pollutants for which the Basin is in nonattainment (i.e., ozone, PMio, and PM2.5) would be emitted as a result of the proposed program in excess of SCAQMD's thresholds for construction activities, these pollutant emissions would, in conjunction with other past, current, and probable future projects, be cumulatively considerable, and cumulative impacts would be significant and unavoidable. Implementation of Mitigation Measures AIR -1 and AIR -2 would reduce cumulative air quality impacts, but not to a level that is less than significant. With respect to operational emissions, program implementation would not result in substantial long-term regional emissions of criteria air pollutants and would not exceed the SCAQMD thresholds of significance for criteria pollutants. As such, the proposed program's operational emissions would not be cumulatively considerable and cumulative air quality impacts would be less than significant. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts. Even after the implementation of Mitigation Measures AIR -1 and AIR -2, impacts related to cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard remain significant and unavoidable for construction. Program implementation would not result in substantial long - LA County Flood Control District _ 45 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad term regional emissions of criteria pollutants with respect to operational emissions, therefore operational emissions would be less than significant. AIR -1: Implementing agencies shall require for large regional or centralized BMPs the use of low -emission equipment meeting Tier II emissions standards at a minimum and Tier III and IV emissions standards where available as CARB-required emissions technologies become readily available to contractors in the region. AIR -2: For large construction efforts that may result in significant air emissions, implementing agencies shall encourage contractors to use lower -emission equipment through the bidding process where appropriate. 6.3 Biological Resources The proposed program would not have any environmental effects on biological resources that cannot be mitigated to a less -than -significant level. 6.4 Cultural Resources Significant Effect The proposed program would cause a substantial adverse change in the significance of an historical resource as defined in §15064.5. (Impact 3.4-1) Description of Significant Impact Implementation of structural BMPs could impact significant historic built environment resources that exist within the program area, which may include not only buildings and structures, but also built infrastructure such as concrete channels, dams, sidewalks, and roads. Impacts to the could include not only physical demolition or alteration of built environment resources, but also changes to the historic setting of a resource, and impacts that may adversely affect that ability of a resource to convey its significance. Similarly, potentially significant buried archaeological resources could still exist within the program area, beneath and between structures and roads. If previously undiscovered artifacts or buried archaeological resources are uncovered during excavation or construction, significant impacts could occur. Not all EWMP projects may result in a significant and unavoidable impact with regard to historical resources, as impacts associated with each project would be dependent on location; presence, nature, and significance of any historical resources within the construction area; and specific impacts to historical resources. In some circumstances, no mitigation is sufficient to maintain the historic integrity of the affected archaeological and other cultural resource or its surroundings, therefore implementation of the proposed program may ultimately result in a substantial adverse change. Finding The proposed program's potential to cause a substantial adverse change in the significance of an historical resource is considered significant. Potential adverse effects caused by the proposed LA County Flood Control District 46 ESA 1140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad program could be minimized by mitigation measures; however the impact would remain significant and unavoidable. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would cause a substantial adverse change in the significance of an historical resource. The project impacts are considered significant and unavoidable; implementation of Mitigation Measures CUL -1 through CUL -4 would help minimize impacts. CUL -1: For individual EWMP projects that could impact buildings or structures (including infrastructure) 45 years old or older, implementing agencies shall ensure that a historic built environment survey is conducted or supervised by a qualified historian or architectural historian meeting the Secretary of the Interior's Professional Qualification Standards for Architectural History. Historic built environment resources shall be evaluated for their eligibility for listing in the CRHR or local register prior to the implementing agency's approval of project plans. If eligible resources that would be considered historical resources under CEQA are identified, demolition or substantial alteration of such resources shall be avoided. If avoidance is determined to be infeasible, the implementing agency shall require the preparation of a treatment plan to include, but not be limited to, photo -documentation and public interpretation of the resource. The plan will be submitted to the implementing agency for review and approval prior to implementation. CUL -2: Implementing agencies shall ensure that individual EWMP projects that require ground disturbance shall be subject to a Phase I cultural resources inventory on a project - specific basis prior to the implementing agency's approval of project plans. The study shall be conducted or supervised by a qualified archaeologist, defined as an archaeologist meeting the Secretary of the Interior's Professional Qualifications Standards for Archaeology, and shall be conducted in consultation with the local Native American representatives expressing interest. The cultural resources inventory shall include a cultural resources records search to be conducted at the South Central Coastal Information Center; scoping with the NAHC and with interested Native Americans identified by the NAHC; a pedestrian archaeological survey where deemed appropriate by the qualified archaeologist; and formal recordation of all identified archaeological resources on California Department of Parks and Recreation 523 forms and significance evaluation of such resources presented in a technical report following the guidelines in Archaeological Resource Management Reports (ARMR): Recommended Contents and Format, Department of Parks and Recreation, Office of Historic Preservation, State of California, 1990. If potentially significant archaeological resources are encountered during the survey, the implementing agency shall require that the resources are evaluated by the qualified archaeologist for their eligibility for listing in the CRHR and for significance as a historical resource or unique archaeological resource per CEQA Guidelines Section 15064.5. Recommendations shall be made for treatment of these resources if found to be LA County Flood Control District 47 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fad Findings of Fact significant, in consultation with the implementing agency and the appropriate Native American groups for prehistoric resources. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred manner of mitigation to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project reroute or redesign, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, which may include data recovery or other appropriate measures, in consultation with the implementing agency, and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. CU1-3: The implementing agency shall retain archaeological monitors during ground - disturbing activities that have the potential to impact archaeological resources qualifying as historical resources or unique archaeological resources, as determined by a qualified archaeologist in consultation with the implementing agency, and any local Native American representatives expressing interest in the project. Native American monitors shall be retained for projects that have a high potential to impact sensitive Native American resources, as determined by the implementing agency in coordination with the qualified archaeologist. CUL -4: During project -level construction, should subsurface archaeological resources be discovered, all activity in the vicinity of the find shall stop and a qualified archaeologist shall be contacted to assess the significance of the find according to CEQA Guidelines Section 15064.5. If any find is determined to be significant, the archaeologist shall determine, in consultation with the implementing agency and any local Native American groups expressing interest, appropriate avoidance measures or other appropriate mitigation. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred means to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project reroute or redesign, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, such as data recovery or other appropriate measures, in consultation with the implementing agency and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. Significant Effect The proposed • program would result in cumulatively significant impacts to cultural resources. LA County Flood Control District 48 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad Description of Significant Impact Cumulative impacts to cultural resources in the cultural resources geographic scope of analysis could occur if other existing or proposed projects, in conjunction with the proposed program, had or would have impacts on cultural resources that, when considered together, would be significant. With implementation of Mitigation Measures CUL -2, CUL -3 and CUL -4, cumulatively significant environmental impacts to unique archaeological resources would be reduced to a less than significant level. With implementation of Mitigation Measures CUL -5 and CUL -6, cumulative impacts to paleontological resources would be less than significant. Further, implementation of CUL -7 would reduce potentially significant impacts to human remains should they be encountered during ground -disturbing activities to a less -than -significant level. Implementation of the proposed program may ultimately result in a substantial adverse change to historical resources through various development activities for which no possible mitigation may be available to maintain the historic integrity of the affected resource or its surroundings, and impacts to historical resources would remain significant and unavoidable at a program level. Therefore, the implementation of structural 13MPs may contribute to a cumulatively significant environmental impact to historical resources. Finding The proposed program has the potential to result in cumulatively considerable impacts related to cultural resources, specifically in regard to substantial adverse changes in the significance of historical resources resulting from excavation activities associated with projects in the cumulative impacts scenario. The implementation of Mitigation Measures CUL -1 through CUL -7 would reduce impacts relating to unique archaeological resources, paleontological resources, and human remains to a less -than -significant level, however, these mitigation measures would not reduce impacts to historical resources below a significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce cumulative impacts caused by the project. With the implementation of Mitigation Measures CUL - 1 through CUL -7, these cumulative cultural resource impacts would be reduced, but still considered significant and unavoidable. 6.5 Geologic and Mineral Resources The proposed program would not have any environmental effects related to geology and soils that cannot be mitigated to a less -than -significant level. 6.6 Greenhouse Gas Emissions The proposed program would not have any environmental effects related to greenhouse gas emissions that cannot be mitigated to a less -than -significant level. LA County Flood Control District 49 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact 6.7 Hazards and Hazardous Materials The proposed program would not have any environmental effects related to hazards and hazardous materials that cannot be mitigated to a less -than -significant level. 6.8 Hydrology and Water Quality The proposed program would not have any environmental effects on hydrology and water quality that cannot be mitigated to a less -than -significant level. 6.9 Land Use and Agriculture The proposed program would not have any environmental effects on land use and planning that cannot be mitigated to a less -than -significant level. 6.10 Noise Significant Effect The proposed program would result in exposure of persons to, or generation of, noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies (Impact 3.10-1). Description of Significant Impact The proposed program would result in a temporary increase in noise levels during construction at the project sites. Noise generated during temporary construction is anticipated, and because of the possibility that certain structural BMP projects may exceed noise levels established by their respective local jurisdictions, this impact would be significant and unavoidable. Finding The proposed program has the potential to result in exposure of persons to, or generation of, noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. Implementation of Mitigation Measures NOISE -1 and NOISE -2 would reduce the proposed program's construction -related noise levels by requiring the project contractor to locate equipment such that noise is directed away from sensitive receptors and to maintain noise controls on standard construction equipment. In addition, the mitigation measures would require a construction noise coordinator to resolve complaints about noise. However, even with the project's adherence to all applicable noise requirements and guidelines in addition to implementation of Mitigation Measures NOISE -1 and NOISE -2, it is anticipated that there would be times during the project's construction activities where the nearest sensitive receptors would be exposed to a perceptible increase in noise levels. Therefore, the project would result in perceptible increases in noise levels during construction and this impact would be considered significant and unavoidable. LA County Flood Control District 550 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to exposure of persons to, or generation of, noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. Even with the implementation of Mitigation Measures NOISE -1 and NOISE -2, these impacts would still be considered significant and unavoidable. Significant Effect The proposed program would result in a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project (Impact 3.10-4). Description of Significant Impact During construction of the distributed, centralized, and regional structural BMPs, temporary or periodic increases in noise levels in and around each structural BMP site would result from the operation of construction equipment. Where a structural BMP site is located within 25 feet of an existing noise -sensitive land use, the resulting construction noise levels at that existing land use could reach as high as 95 dBA Leq during excavation activities, which would result in a substantial noise increase over existing ambient noise levels at that existing land use. Therefore this impact would be significant and unavoidable. The identification of a significant and unavoidable program -level impact in this Program EIR for the proposed program, however, does not preclude the finding of future less -than -significant impacts for individual structural BMP projects. Finding The proposed program has the potential to result in a substantial temporary or periodic increase in ambient noise levels above levels existing without the project in the vicinity of individual projects. Implementation of Mitigation Measure NOISE-] would reduce the project's construction -related noise levels by requiring the project contractor to locate equipment such that noise is directed away from sensitive receptors and to maintain noise controls on standard construction equipment. In addition, the mitigation measures would require a construction noise coordinator to resolve complaints about noise. However, even with the project's adherence to all applicable noise requirements and guidelines in addition to implementation of the mitigation measure, it is anticipated that there would be times during the project's construction activities where the nearest sensitive receptors would be exposed to a perceptible change in noise levels. Therefore, the proposed program would result in perceptible increases in noise levels during construction and this impact would be considered significant and unavoidable. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to a substantial temporary or periodic increase in ambient noise levels. With the implementation of Mitigation Measure NOISE -1 included, impacts would still be significant and unavoidable during construction. LA County Flood Control District 51 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact Significant Effect The proposed program would result in significant cumulative construction noise impacts. Description of Significant Impact Noise and vibration are both defined as localized phenomena that significantly reduce in magnitude as distance from the source increases. The structural BMPs associated with the proposed program would be constructed in multiple jurisdictions of Los Angeles County, which aside from the County also includes 46 cities and LACFCD. As such, these structural BMP projects would be generally spread over a large geographic area within the County. These structural BMPs in combination with other current and planned projects in the County would result in an increase in construction -related noise levels, which would temporarily increase the ambient noise levels of the existing noise environment in areas where a construction project would occur. This would result in significant and unavoidable impacts for construction. Finding The proposed program has the potential to result in the exposure of persons to noise levels in excess of applicable standards. Even with implementation of Mitigation Measures NOISE -1 and NOISE -2, impacts would still be significant and unavoidable during construction. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to inappropriate noise levels. Even with implementation of Mitigation Measures NOISE -1 and NOISE -2, impacts would still be significant and unavoidable during construction. 6.11 Population and Housing and Environmental Justice The proposed program would not have any environmental effects on population, housing and environmental justice that cannot be mitigated to a less -than -significant level. 6.12 Public Services and Recreation The proposed program would not have any environmental effects on public services and recreation that cannot be mitigated to a less -than -significant level. 6.13 Transportation and Circulation The proposed program would not have any environmental effects on transportation and traffic that cannot be mitigated to a less -than -significant level. 6.14 Utilities and Service Systems The proposed program would not have any environmental effects on utilities that cannot be mitigated to a less -than -significant level. LA County Flood Control District 52 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad 7.0 Findings Regarding Project Alternatives The following findings and brief explanation of the rationale for the findings regarding program alternatives identified in the EIR are set forth to comply with the requirements of Section 15091(s)(3) of the CEQA Guidelines. The consideration of alternatives is an integral component of the CEQA process. The selection and evaluation of a reasonable range of alternatives provides the public and decision -makers with information on ways to avoid or lessen environmental impacts created by a proposed program. When selecting alternatives for evaluation, CEQA requires alternatives that meet most of the basic objectives of the project, while avoiding or substantially lessening the program's significant effects. Thus, objectives for the proposed program were considered by this board in evaluating the alternatives. These objectives are: • To collaborate among agencies (Permittee jurisdictions) across the watershed to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the MS4 Permit; • To develop watershed -wide EWMPs that will, once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff in a cost-effective manner; and • To reduce the impact of stormwater and non-stormwater on receiving water quality. 7.1 No Program Alternative Under this alternative, the existing land uses on the project site would continue to operate as they do under existing conditions. The existing land uses would continue for an indefinite period and no physical changes within the proposed program area would occur. In addition, existing ancillary structures, such as buildings, roadways and parkways within the project area, would remain in their current capacity. The No Project Alternative would maintain the current zoning and land use designations. Finding This alternative would not meet the first and second objectives to collaborate among agencies across the watershed to prepare EWMPs that promote more cost-effective and multi -beneficial water quality improvement projects. However, compliance with the MS4 Permit is still required regardless of implementation of the EWMP. Under the No Project Alternative some water quality projects would be implemented in an effort to achieve compliance with the MS4 permit. This alternative would result in slightly greater impacts to air quality with regards to emissions generated, because the programs would need to be installed rapidly and more BMPs would likely be required as a result of the inefficiencies of multiple boundaries. Hydrology and water quality impacts would also be greater, as an installation grace period would not be granted for BMPs outside of the EWMP, increasing the likelihood of noncompliance with the MS4 Permit. All other impacts would be similar under this alternative when compared with the proposed program. This LA County Flood Control District 53 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fad alternative would not eliminate significant and unavoidable impacts when associated with the proposed project. 7.2 Non -Structural BMPs Only Project Alternative This alternative would involve implementation of the proposed program and its associated non- structural BMPs only. No structural BMPs would be implemented. Finding This alternative would not meet any of the objectives of the proposed program to collaborate among agencies to promote more cost-effective and multi -beneficial water quality improvement projects and to prepare EWMPs to reduce pollutant loading. Non -Structural BMPs are generally implemented individually in each jurisdiction. Since no facilities would be constructed, temporary impacts to the environment would be less than the proposed program for many topic areas. However, impacts to population and housing, land use, and recreation would be greater than the proposed program. This alternative would result in greater impacts to aesthetics, as it would not include green -streets and grassy swales that would improve local aesthetics. Impacts to hydrology and water quality would also be greater under this alternative, as achieving water quality objectives with no structural BMPs would be unlikely. 7.3 Distributed Structural and Non -Structural BMPs Only Program Alternative (No Centralized or Regional) This alternative would involve implementation of the proposed program and only its associated distributed structural BMPs and non-structural BMPs. Finding This alternative would achieve the first and third project objectives to collaborate among agencies to promote more cost-effective and multi -beneficial water quality improvement projects that reduce the impact of stormwater on receiving water quality. However, it would likely require more BMPs to meet the MS4 Permit water quality objectives, as distributed structural BMPs tend to be smaller in nature and are located in a wide distribution throughout the watershed. Therefore, it would not meet the second project objective (developing EWMPS that will remove or reduce pollutants from urban runoff and removal of stormwater and non-stormwater impacts on receiving water quality). Since much of the impacts of program implementation would occur during construction of the large-scale regional and centralized BMPs, this alternative would result in fewer construction impacts than the proposed project and fewer impacts to aesthetics. However, the alternative would result in greater impacts to land use planning/agriculture, as eliminating the use of large open space areas for BMPs would require a more dispersed land use acquisition for small scale BMPs, thereby increasing potential land use compatibility impacts. This alternative would LA County Flood Control District 54 ESA 1140474 Enhanced Watershed Management Programs April 2015 Findings of Fact r J. Findings of Fact eliminate the water quality benefit and more likely potential to comply with the MS4 Permit provided by large-scale regional BMPs, and would therefore result in greater hydrology and water quality impacts. All other impacts under this alternative would be similar to the proposed program. 7.4 Environmentally Superior Alternative The purpose of the alternatives analysis is to consider a reasonable range of alternatives that could feasibly attain most of the basic project objectives and avoid or substantially lessen significant program impacts. The CEQA Guidelines require the identification of an environmentally superior alternative of a project other than or the "no project" alternative (CEQA Guidelines Section 15126.6 (e)(2)). An environmentally superior alternative is an alternative to the project that would reduce and/or eliminate the significant environmental impacts associated with the project without creating other significant impacts and without substantially reducing and/or eliminating the environmental benefits attributable to the project. Finding The Environmentally Superior Alternative would be the proposed program itself. The proposed program would avoid increasing the impacts to hydrology and water quality that would occur under all three of the alternatives. The No Program Alternative would require that individual Permittees design and construct BMPs locally to achieve MS4 Permit compliance. None of the significant and unavoidable impacts of the proposed alternative would be avoided by this alternative. Furthermore, since the ability to achieve compliance with MS4 Permit water quality objectives would be reduced if each Permittee were on their own, impacts to hydrology and water quality would be greater under this alternative. The Distributed Structural BMPs Only Alternative would result in construction of an increased number of distributed BMPs This alternative would result in fewer impacts to air quality, cultural resources and noise, and would therefore reduce the significant and unavoidable impacts associated with the proposed program. However, since the ability to achieve compliance with MS4 Permit water quality objectives would be reduced without the larger -scale centralized and regional BMPs, impacts to hydrology and water quality would be greater under this alternative. The Non -Structural BMPs Only Alternative would avoid all of the significant and unavoidable impacts associated with construction of the structural BMPs. In addition, nearly all of the impacts associated with the proposed alternative would be avoided, including impacts from infiltration to neighboring subsurface structures, mobilization of contaminants, and site-specific impacts to cultural and biological resources. However, since the ability to achieve compliance with MS4 Permit water quality objectives would be substantially reduced, impacts to water quality would be greater under this alternative, and compliance with the MS4 Permit would be unlikely. Even though this alternative would avoid significant and unavoidable impacts of construction and LA County Flood Control District 55 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact Findings of Fact operation of structural BMPs, the failure to meet water quality objectives and achieve MS4 Permit compliance would outweigh the avoidance of the other impacts. Since the proposed alternative would provide the best chance of achieving regional water quality objectives, it is considered the environmentally superior alternative. LA County Flood Control District 56 ESA / 140474 Enhanced Watershed Management Programs April 2015 Findings of Fact LOS ANGELES COUNTY FLOOD CONTROL DISTRICT ENHANCED WATERSHED MANAGEMENT PROGRAMS Draft Program Environmental Impact Report Prepared for County of Los Angeles Department of Public Works January 2015 1JSA LOS ANGELES COUNTY FLOOD CONTROL DISTRICT ENHANCED WATERSHED MANAGEMENT PROGRAMS Draft Program Environmental Impact Report Prepared for January 2015 County of Los Angeles Department of Public Works F` ESA J 626 Wilshire Boulevard Suite 1100 Los Angeles, CA 90017 213.599.4300 W W.esassoc.com Oakland Orlando Palm Springs Petaluma Portland Sacramento San Diego San Francisco Seattle Tampa Woodland Hills 140474 TABLE OF CONTENTS Administrative Draft Program Environmental Impact Report for the Los Angeles County Flood Control District Enhanced Watershed Management Programs U - ExecutiveSummary ..................................................................................................... ES -1 7. Introduction............................................................................................................1-1 1.1 Introduction.....................................................................................................1-1 1.2 Project Background........................................................................................1-4 1.3 CEQA Environmental Review Process...........................................................1-8 1.4 Documents Incorporated by Reference........................................................1-16 1.5 PEIR Organization ........................................................................................1-18 2. Project Description................................................................................................2-1 2.1 Introduction.....................................................................................................2-1 2.2 Goals and Objectives......................................................................................2-2 2.3 Watersheds, Participants, and Process..........................................................2-2 2.4 EWMP BMP Types.........................................................................................2-5 2.6 EWMP BMP Implementation Schedule........................................................2-57 2.7 Operation and Maintenance.........................................................................2-57 2.8 Required Approvals......................................................................................2-57 3. Environmental Impacts and Mitigation Measures 3.1 Aesthetics Resources..................................................................................3.1-1 3.2 Air Quality....................................................................................................3.2-1 3.3 Biological Resources...................................................................................3.3-1 3.4 Cultural Resources......................................................................................3.4-1 3.5 Geologic and Mineral Resources.................................................................3.5-1 3.6 Greenhouse Gases......................................................................................3.6-1 3.7 Hazards and Hazardous Materials...............................................................3.7-1 3.8 Hydrological Resources...............................................................................3.8-1 3.9 Land Use and Agriculture............................................................................3.9-1 3.10 Noise.........................................................................................................3.10-1 3.11 Population and Housing.............................................................................3.11-1 3.12 Public Services and Recreation.................................................................3.12-1 3.13 Transportation and Circulation...................................................................3.13-1 3.14 Utilities, Service Systems and Energy .......................................................3.14-1 IA County Flood Control District ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Progmm Environmental Impact Report Paqe 4. Cumulative Impacts...............................................................................................4-1 4.1 Introduction.....................................................................................................4-1 4.2 Related Projects.............................................................................................4-2 4.3 Plan Consistency............................................................................................4-6 4.4 Cumulative Impacts and Mitigation Measures................................................4-7 5. Growth-Inducement...............................................................................................5-1 5.1 CEQA Requirements......................................................................................5-1 5.2 Methodology...................................................................................................5-2 5.3 Growth Inducement Potential and Significant and Irreversible Effects ............ 5-2 5.4 Secondary Effects of Growth..........................................................................5-3 5.5 Significant Irreversible Environmental Changes.............................................5-3 6. Alternatives Analysis.............................................................................................6-1 6.1 Introduction..................................................................................................... 6-1 6.2 Review of Proposed Program Goals and Objectives......................................6-2 6.3 Review of Significant Environmental Impacts.................................................6-3 6.4 Program -Level Alternatives Analysis..............................................................6-3 6.5 Comparison of Alternatives...........................................................................6-12 6.6 Alternatives Suggested in Scoping...............................................................6-12 6.7 Environmentally Superior Alternative............................................................6-13 7. Organizations and Persons Contacted................................................................7-1 7.1 Participating Permittees..................................................................................7-1 7.2 NOP and Draft EIR Distribution List................................................................7-1 8. Report Preparers....................................................................................................8-1 8.1 Lead Agency...................................................................................................8-1 8.2 Draft PEIR......................................................................................................8-1 9. References.............................................................................................................9-1 Appendices A. Notice of Preparation B. Scoping Report and Comment Letters C. CaIEEMod Air Quality Data D. Sensitive Natural Communities Descriptions E. CNDDB Species List F. Supplemental Hydrology and Water Quality Data G. EWMP Proposed BMP and Priority Project Data LA County Flood Control District II ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report Table of Contents Pape List of Figures 1-1 Watersheds and EWMP Groups within LACFD Boundaries.................................1-2 2-1 Watersheds and EWMP Groups within LACFCD Boundaries..............................2-4 2-2 Location of Example Planned and Installed Distributed BMP Projects ...............2-21 2-3 Location of Example Planned and Installed Centralized BMP Projects ..............2-33 2-4 Location of Example Planned and Installed Regional BMP Projects ..................2-39 2-5 Marina del Rey Watershed Management Group.................................................2-45 2-6 Ballona Creek Watershed Management Group..................................................2-46 2-7 Beach Cities Watershed Management Group.....................................................2-47 2-8 Santa Monica Bay Watershed Jurisdictions 2 and 3 Watershed Management Groups.....................................................................................2-48 2-9 Palos Verdes Peninsula Watershed Management Group...................................2-49 2-10 Malibu Creek Watershed Management Group....................................................2-50 2-11 North Santa Monica Bay Coastal Watersheds....................................................2-51 2-12 Upper San Gabriel River Watershed Management Groups................................2-52 2-13 Rio Hondo / San Gabriel River Watershed Management Group .........................2-53 2-14 Upper Los Angeles River Watershed Management Group.................................2-54 2-15 Dominguez Channel Watershed Management Group........................................2-55 2-16 Upper Santa Clara River Watershed Management Group..................................2-56 3.1-1 Scenic Highways...............................................................................................3.1-7 3.3-1 Typical Drainages in the Southern Coastal EWMP Watersheds ........................3.3-3 3.3-2 Typical Drainages in the Dominguez Channel Watershed Management Areas............................................................................................................. 3.3-4 3.3-3 Typical Drainages in the Northern Coastal EWMP Watersheds ........................3.3-5 3.3-4 Typical Drainages in the Upper Los Angeles River Watershed .........................3.3-6 3.3-5 Typical Drainages in the Upper San Gabriel and Rio Hondo Watersheds ......... 3.3-8 3.3-6 Typical Drainages in the Upper Santa Clara River Watershed ..........................3.3-9 3.3-7 Natural Communities.......................................................................................3.3-10 3.3-8 Los Angeles County Significant Ecological Areas and Critical Habitat ............3.3-14 3.5-1 Regional Geology..............................................................................................3.5-3 3.5-2 Local Faults with Recent Movement..................................................................3.5-6 3.5-3 Liquefaction and Landslide Potential Map.........................................................3.5-9 3.5-4 Mineral Resources Map...................................................................................3.5-12 3.7-1 Los Angeles County Fire Hazard Severity Zone Map for State Responsibility Areas......................................................................................3.7-5 3.7-2 Los Angeles County Fire Hazard Severity Zone Map for County Responsibility Areas......................................................................................3.7-6 3.8-1 Watersheds and EWMP Groups........................................................................3.8-2 3.8-2 South Santa Monica Watershed Area — Hydrologic Features and Potential BMPLocations............................................................................................3.8-11 3.8-3 Northern Coastal Watershed Area— Hydrologic Features and Potential BMP Locations..................................................................................................... 3.8-12 3.8-4 Upper San Gabriel Watershed Area— Hydrologic Features and Potential BMPLocations............................................................................................3.8-13 3.8-5 Upper Los Angeles River Watershed — Hydrologic Features and Potential BMPLocations............................................................................................3.8-14 3.8-6 Dominguez Channel and Palos Verdes Watersheds— Hydrologic Features and Potential BMP Locations......................................................................3.8-15 IA County Flood Control District III ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report Table of Contents List of Tables ES -1 Paqe List of Figures (cont.) ES -7 1-1 3.8-7 Upper Santa Clara River Watershed - Hydrologic Features and Potential EWMP Participants and Watersheds....................................................................2-3 2-2 Typical Structural Best Management Practices....................................................2-7 BMPLocations............................................................................................3.8-16 2-3 Examples of Planned or Installed Distributed BMP Projects...............................2-17 3.8-8 2-4 Effect of Urbanization on an Example Stream Hydrograph and Hydrograph 2-5 Example of Planned Regional Projects...............................................................2-37 after Implementation of Retention -Type BMP.............................................3.8-18 Required Approvals............................................................................................2-58 3.8-9 Summary of Aesthetics Impacts Requiring Mitigation Measures ..................... System of Dams and Reservoirs in Los Angeles Basin...................................3.8-19 3.2-1 South Coast Air Basin Attainment Status..........................................................3.2-6 3.8-10 3.2-2 Groundwater Basins within the EWMP Areas..................................................3.8-22 3.2-3 3.9-1 Land Use in the Ballona Creek Watershed Management Group .......................3.9-3 Modeling Parameters for Worst -Case Construction Scenario for a 3.9-2 Distributed BMP project..............................................................................3.2-18 Land Uses in the Beach Cities Watershed Management Group ........................ 3.2-5 3.9-5 3.9-3 Land Use in the Dominguez Channel Watershed Management Group .............3.9-7 3.2-6 3.9-4 Land Use in the Malibu Creek Watershed Management Group ......................... BMPProject................................................................................................3.2-19 3.9-9 3.9-5 ESA / 140474 Land Use in the Marina del Rey Watershed Management Group....................3.9-11 Management programs January2015 3.9-6 Environmental Impact Report Land Uses in the North Santa Monica Bay Watershed Management Group... 3.9-13 3.9-7 Land Uses in the Peninsula Cities EWMP Agencies.......................................3.9-16 3.9-8 Land Uses in the Rio Hondo / San Gabriel River Watershed Management Group..........................................................................................................3.9-18 3.9-9 Land Use in the Santa Monica Bay Watershed Jurisdictions 2 and 3 Watershed Management Group..................................................................3.9-20 3.9-10 Land Use in the Upper Los Angeles River Watershed Management Group.... 3.9-22 3.9-11 Land Use in Upper San Gabriel River Watershed Management Group ........... 3.9-24 3.9-12 Land Use in Upper Santa Clara River Watershed Management Group ........... 3.9-25 3.10-1 Effects of Noise on People...............................................................................3.10-2 3.12-1 Public School Locations...................................................................................3.12-4 3.12-2 County Parks Locations...................................................................................3.12-6 3.14-1 Water Recharge Facilities................................................................................3.14-3 4-1 Planned EWMP Projects......................................................................................4-5 List of Tables ES -1 Summary of Impacts and Mitigation Measures for the Enhanced Watershed ManagementPrograms................................................................................. ES -7 1-1 NOP Commenters..............................................................................................1-12 2-1 EWMP Participants and Watersheds....................................................................2-3 2-2 Typical Structural Best Management Practices....................................................2-7 2-3 Examples of Planned or Installed Distributed BMP Projects...............................2-17 2-4 Examples of Planned Centralized BMP Projects................................................2-29 2-5 Example of Planned Regional Projects...............................................................2-37 2-6 Required Approvals............................................................................................2-58 3.1-1 Summary of Aesthetics Impacts Requiring Mitigation Measures ..................... 3.1-15 3.2-1 South Coast Air Basin Attainment Status..........................................................3.2-6 3.2-2 Ambient Air Quality Standards for Criteria Pollutants........................................3.2-8 3.2-3 SCAQMD Regional Air Quality Significance Thresholds.................................3.2-16 3.2-4 Modeling Parameters for Worst -Case Construction Scenario for a Distributed BMP project..............................................................................3.2-18 3.2-5 Modeling Parameters for Worst -Case Construction Scenario for a Centralized BMP project.............................................................................3.2-18 3.2-6 Modeling Parameters for Worst -Case Construction Scenario for a Regional BMPProject................................................................................................3.2-19 IA County Flood Control District Iv ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report Table of Contents Pape List of Tables (cont.) 3.2-7 Estimated Peak Daily Emissions for Project Construction Activities for a Distributed BMP Project..............................................................................3.2-20 3.2-8 Estimated Peak Daily Emissions for Project Construction Activities for a Centralized BMP Project.............................................................................3.2-21 3.2-9 Estimated Peak Daily Emissions for Project Construction Activities for a Regional BMP Project.................................................................................3.2-21 3.2-10 Summary of Air Quality Impacts Requiring Mitigation Measures .....................3.2-30 3.3-1 Summary of Biological Resource Impacts Requiring Mitigation Measures ......3.3-32 3.4-1 Paleontologically Sensitive Geologic Units/Formations within the ProgramArea..............................................................................................3.4-10 3.4-2 Summary of Cultural Resource Impacts Requiring Mitigation Measures ......... 3.4-29 3.5-1 Modified Mercalli Intensity Scale........................................................................3.5-5 3.5-2 Principal Historically Active and Active Faults in the Project Vicinity .................3.5-7 3.5-3 Summary of Geologic Resource Impacts Requiring Mitigation Measures .......3.5-29 3.6-1 Recommended Actions from CARB climate change scoping plan.....................3.6-7 3.6-2 Estimated Construction -Related Greenhouse Gas Emissions - Proposed Distributed BMP Project..............................................................3.6-13 3.6-3 Estimated Construction -Related Greenhouse Gas Emissions - Proposed Centralized BMP Project.............................................................3.6-13 3.6-4 Estimated Construction -Related Greenhouse Gas Emissions - Proposed Regional BMP Project.................................................................3.6-14 3.6-5 Summary of Greenhouse Gas Impacts Requiring Mitigation Measures ..........3.6-17 3.7-1 Summary of Hazards Impacts Requiring Mitigation Measures ........................3.7-25 3.8-1 Major Impaired Water Bodies in the Study area..............................................3.8-20 3.8-2 Groundwater Basins within the EWMP Areas..................................................3.8-24 3.8-3 Summary of Hydrological Resource Impacts Requiring Mitigation Measures.. 3.8-43 3.9-1 Ballona Creek Watershed Land Area Distribution..............................................3.9-2 3.9-2 Beach Cities Watershed Land Area Distribution................................................3.9-4 3.9-3 Dominguez channel Watershed Land Area Distribution....................................3.9-6 3.9-4 Dominguez channel Watershed Land Use........................................................3.9-6 3.9-5 Malibu Creek Watershed Land Area Distribution...............................................3.9-8 3.9-6 Marina del Rey Watershed Land Area Distribution..........................................3.9-10 3.9-7 Marina del Rey Watershed Land Use..............................................................3.9-10 3.9-8 North Santa Monica Bay Watershed Land Use...............................................3.9-12 3.9-9 Palos Verdes Peninsula Land Area Distribution..............................................3.9-15 3.9-10 Rio Hondo / San Gabriel River Land Area Distribution....................................3.9-17 3.9-11 Rio Hondo / San Gabriel River Watershed Land Use......................................3.9-17 3.9-12 Santa Monica Bay Land Area Distribution.......................................................3.9-19 3.9-13 Upper Los Angeles River Land Area Distribution.............................................3.9-21 3.9-14 Upper San Gabriel River Land Area Distribution.............................................3.9-23 3.9-15 Upper Santa Clara River Land Area Distribution.............................................3.9-23 3.9-16 Summary of Land Use and Agriculture Impacts Requiring Mitigation Measures....................................................................................3.9-40 3.10-1 Construction Vibration Damage Criteria..........................................................3.10-7 3.10-2 Community Noise Exposure (Ldn or CNEL) ....................................................3.10-9 3.10-3 Caltrans Vibration Damage Potential Threshold Criteria ...............................3.10-10 3.10-4 Caltrans Vibration Annoyance Potential Criteria............................................3.10-10 IA County Flood Control District v ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report Table of Contents IA County Flood Control District vi ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report Paqe List of Tables (cont.) 3.10-5 County of Los Angeles Exterior Noise Standards By Noise Zones................3.10-11 3.10-6 County of Los Angeles Interior Noise Standards for dwelling units................3.10-12 3.10-7 County of Los Angeles Construction noise standards ...................................3.10-13 3.10-8 Typical Outdoor Construction Noise Levels ...................................................3.10-15 3.10-9 Typical Noise Levels from Construction Equipment.......................................3.10-16 3.10-10 Vibration Velocities for Construction Equipment............................................3.10-20 3.10-11 Summary of Noise Impacts Requiring Mitigation Measures ..........................3.10-25 3.11-1 2014 Los Angeles County Area Median Household Income Classification inU.S. Dollars.............................................................................................3.11-2 3.11-2 Summary of Population and Housing Impacts Requiring Mitigation Measures....................................................................................3.11-9 3.12-1 School Districts in EWMP Areas......................................................................3.12-3 3.12-2 Summary of Public Services and Recreation Impacts Requiring Mitigation Measures..................................................................................3.12-16 3.13-1 Summary of Transportation and Circulation Impacts Requiring Mitigation Measures....................................................................................3.13-8 3.14-1 EWMP Area Water Purveyors.........................................................................3.14-2 3.14-2 EWMP Area Wastewater Treatment Plants .....................................................3.14-5 3.14-3 Summary of Utilities and Service System Impacts Requiring MitigationMeasures..................................................................................3.14-22 4-1 EWMP Projects.....................................................................................................4-4 4-2 Key Regional Resource Management and/or Protection Agencies ......................4-7 4-3 Summary of Cumulative Impact Analysis.............................................................4-8 6-1 Summary of Program Impact Analysis..................................................................6-4 6-2 Ability of Project Alternatives to Meet Project Objectives....................................6-13 IA County Flood Control District vi ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report Acronym List AB Assembly Bill ACS American Community Survey AGB Alamitos Gap Barrier AOA Air Operations Area AQMP Air Quality Management Plan AR4 IPCC Fourth Assessment Report ARMR Archaeological Resource Management Reports ASBS Areas of Special Biological Significance ASTM American Society for Testing and Materials ASTs Aboveground Storage Tanks ATCM Airborne Toxics Control Measure B.P. Before Present BACT Best Available Control Technology BAU Business As -usual BMP Best Management Practices BMPs Best Management Practices BWER Ballona Wetlands Ecological Reserve C1-C4 Chlordane (tissue), Chrysene CAA Clean Air Act CAAA CAA Amendments of 1990 CAAQS California Ambient Air Quality Standards Cal/OSHA California Division of Occupational Safety and Health CalARP California Accidental Release Prevention CalEPA California Environmental Protection Agency CARB California Air Resources Board CB Catch Basin CBC California Building Code CCAA California Clean Air Act CCAP Community Climate Action Plan CCAT California Climate Action Team CCC California Coastal Commission CCR California Code of Regulations CDFW California Department of Fish and Wildlife CDP Coastal Development Permit CEC California Energy Commission CEQA California Environmental Quality Act CESA California Endangered Species Act CFCs Chlorofluorocarbons CFR Code of Federal Regulations CGP Construction General Permit CH4 Methane CHLs California Historical Landmarks CIRS Coastal Interceptor Relief Sewer CIWMB California Integrated Waste Management Board CNDDB California Natural Diversity Database CNPS California Native Plant Society CO Carbon Monoxide CO2 Carbon Dioxide CPUC California Public Utilities Commission CRHR California Register of Historical Resources IA County Flood Control District ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report List Acronym List (cont.) CWA Clean Water Act DGSG Dominguez Channel Spreading Grounds DHS Department of Health Services DNL Day -Night Average Noise Level DOT Department of Transportation DTSC Department of Toxic Substances Control EIR environmental impact report ERP Emergency Response Plan ESA Environmental Site Assessment ET Evapotranspiration EWMP Enhanced Watershed Management Program FAA Federal Aviation Administration FESA Federal Endangered Species Act FHSZs Fire Hazard Severity Zones FMMP Farmland Mapping and Monitoring Program GHG Greenhouse Gas GWP Global Warming Potential HAPs Hazardous Air Pollutants HFCs Hydrofluorocarbons HMBP Hazardous Materials Business Plan HR Hydrologic Region HVAC Heating, Ventilation, and Air Conditioning IC/ID Illicit Connection / Illicit Discharges IPCC Intergovernmental Panel on Climate Change IRAs Identified Resource Areas JWPCP Joint Water Pollution Control Plant LACFCD Los Angeles County Flood Control District LACFD Los Angeles County Fire Department LACOE Los Angeles County Office of Education LACSD Los Angeles County Sanitation Districts LARWQCB Los Angeles Regional Water Quality Control Board LASD Los Angeles County Sheriffs Department LAUSD Los Angeles Unified School District LCFS Low Carbon Fuel Standard LCPs Local Coastal Programs LFD Low -Flow Diversion LID Low -Impact Development LOS Level of Service LST Localized Significance Threshold LUSTs Leaking Underground Storage Tanks MACT Maximum Achievable Control Technology MBTA Migratory Bird Treaty Act MCM Minimum Control Measure ML Richter Local Magnitude MMRP Mitigation Monitoring and Reporting Program MMT Million Metric Tons MOU Memorandum of Understanding MPO Metropolitan Planning Organization MRZs Mineral Resource Zones M34 Municipal Separate Storm Sewer System IA County Flood Control District II ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report List Acronym List (cont.) N2O Nitrous Oxide NAAQS National Ambient Air Quality Standards NCCP/HCP Natural Community Conservation Planning/Habitat Conservation Plan NESHAPs National Emission Standards for Hazardous Air Pollutants NH3 Ammonia NHPA National Historic Preservation Act NMFS National Marine Fisheries Service NO Nitric Oxide NO2 Nitrogen Dioxide NOI Notice of Intent NOP Notice of Preparation NOX Nitrogen Oxides NPDES National Pollutant Discharge Elimination System NRHP National Register of Historic Places OEHHA Office of Environmental Health Hazard Assessment DES Office of Emergency Services OPR Office of Planning and Research OSHA Office of Safety and Health Administration P -C Production -Consumption PEIR Program Environmental Impact Report PFCs Perfluorocarbons PGA Peak Ground Acceleration PHI Points of Historical Interest PM10 Particulate Matter (10 micrometers or less) PM2.5 Particulate Matter (2.5 micrometers or less) PPV Peak Particle Velocity PRDs Permit Registration Documents PSD Prevention of Significant Deterioration PVC Polyvinyl Chloride RAA Reasonable Assurance Analysis RCRA Resource Conservation and Recovery Act RMP Risk Management Plan RMS Root Mean Square ROG Reactive Organic Gases RWLs Receiving Water Limitations RWQCB Regional Water Quality Control Board RWQCBs Regional Water Quality Control Boards SAR Second Assessment Report SB Senate Bill SCAG Southern California Association of Governments SCAQMD South Coast Air Quality Management District SEAs Significant Ecological Areas SF6 Sulfur Hexafluoride SIP State Implementation Plan SLIC Spills, Leaks, Investigations, and Cleanups Program SMARA State Surface Mining and Reclamation Act SMURRF Santa Monica Urban Runoff Recycling Facility SO2 Sulfur Dioxide SO3 Sulfur Trioxide SO4 Sulfates IA County Flood Control District III ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report List Acronym List (cont.) SOX Sulfur Oxides SPCC Spill Prevention, Control and Countermeasure SVP Society for Vertebrate Paleontology SWPPP Stormwater Pollution Prevention Plan SWRCB State Water Resources Control Board SZs Scientific Resource Zones TAC Technical Advisory Committee TACs Toxic Air Contaminants TDS Total Dissolved Solids TMDLs Total Maximum Daily Loads UCMP University of California Museum of Paleontology ULSD Ultra Low Sulfur Diesel UNFCCC United Nations Framework Convention on Climate Change USACE U.S. Army Corps of Engineers USEPA U.S. Environmental Protection Agency USFS U.S. Forest Service USFWS U.S. Fish and Wildlife Service USTs Underground Storage Tanks UWMP Urban Water Management Plan VMT Vehicle Miles Traveled VOC Volatile Organic Compound WCBB West Coast Basin Barrier Project WDRs Waste Discharge Requirements WMA Watershed Management Area WMG Watershed Management Group WMP Watershed Management Program WRP Water Reclamation Plants WWII World War II IA County Flood Control District iv ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report EXECUTIVE SUMMARY ESA Introduction The Los Angeles County Flood Control District (LACFCD) has prepared this Draft Program Environmental Impact Report (Draft PEIR) to provide the public and responsible and trustee agencies with information about the potential effects, both beneficial and adverse, on the local and regional environment associated with implementation of the Enhanced Watershed Management Programs (proposed program). This Draft PEIR has been prepared pursuant to the California Environmental Quality Act (CEQA) of 1970 (amended), codified at California Public Resources Code Sections 21000 et. seq., and the CEQA Guidelines in the Code of Regulations, Title 14, Division 6, Chapter 3. This document is being circulated to local, state and federal agencies, and to interested organizations and individuals who may wish to review and comment on the Draft PEIR. Publication of this Draft PEIR marks the beginning of a 45 -day public review period, during which written comments may be directed to the address below. Comments on the project should be directed to: Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 Qbeeellnu,dnw.lacounty. ¢ov ES.2 Background The Los Angeles County Flood Control District (LACFCD) was created in 1915 when the State Legislature adopted the Los Angeles County Flood Control Act to provide flood risk management, water conservation, and recreation and aesthetic enhancement within its boundaries. The LACFCD owns and maintains a broad network of flood control facilities that convey storrnwater to the local rivers and ultimately to the ocean. The LACFCD is governed as a separate entity by the County of Los Angeles Board of Supervisors, and is operated by the County's Department of Public Works. The LACFCD, the County of Los Angeles, and 84 incorporated cities within Los Angeles County (collectively referred to as Permittees) are covered under a Municipal Separate Storm Sewer System (MS4) Permit (Order No. R4-2012-0175; National Pollutant Discharge Elimination System [NPDES] Permit No. CAS004001) for the discharge of urban runoff to waters of the United States. The purpose of the MS4 Permit is to achieve and a County Flood Control District ES -1 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report Executive maintain water quality objectives to protect beneficial uses of the receiving waters in the Los Angeles region. Each of the Permittees identified in the MS4 permit is responsible for meeting the conditions of the permit for MS4 discharges occurring within their jurisdiction. The 2012 MS4 Permit for Los Angeles County gives Permittees the option of implementing an innovative approach to Permit compliance through development of an Enhanced Watershed Management Program (EWMP). The EWMPs will identify potential and priority structural and non-structural Best Management Practices (BMPs) within the region's storrnwater collection system to improve runoff water quality. The LACFCD, along with participating Permittees, has opted to exercise this option and has submitted to the LARWQCB 12 separate Notices of Intent (NOIs) for the development of EWMPs within 12 distinct watershed groups (refer to Figure 1-1). Implementation of the EMWPs would be the responsibility of each Permittee and would occur following approval of the EWMPs by the LARWQCB. The LACFCD, as a regional agency, is a member of each of the 12 EWMP working groups, and as such provides a commonality within each EWMP group. However, LACFCD does not have a special status or authority designated by the MS4 Permit over any of the other Permittees. The LACFCD will be working with the applicable Permittees in all 12 EWMP watersheds as an equal partner to identify the types and locations of BMPs needed to achieve permit compliance within each watershed. The timeline identified in the MS4 Permit requires that Permittees submit the EWMP to the LARWQCB by June 28, 2015, in order to be in compliance with the permit conditions. The LACFCD recognizes that implementation of the EWMPs may potentially result in changes to environmental conditions. As a result, the LACFCD has prepared this Program Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the EWMPs. The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior to submittal of the EWMPs. The EWMPs will be submitted by each EWMP to the LARWQCB. This PEIR describes and evaluates each of the EWMPs being prepared by the Permittees collectively. The discretionary action prompting the need for CEQA compliance is the submittal of the completed EWMPs to the LARWQCB. The EWMPs will identify management strategies including hundreds of structural Best Management Practices (BMPs) that may be designed and implemented by the Permittees to meet permit compliance objectives. A few of the BMPs are currently well defined but most are yet to be fully developed under the EWMPs. A set of priority BMPs will be detailed in each of the EWMPs; these are being developed in parallel with the PEIR. The PEIR describes the details that are available for each of the EWMPs currently under preparation by the EWMP working groups. The PEIR analysis is not intended to focus on the site-specific construction and operation details of each management strategy and project included in the EWMP. Rather, this PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to IA County Flood Cenral District ES -2 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive reduce urban runoff pollution. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis outlines mitigation strategies to be followed by implementing agencies to avoid or minimize impacts wherever feasible. LACFCD is the CEQA Lead Agency for this PEIR. This PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual EWMP projects. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects as appropriate or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. ES,3 Project Objectives The primary goals and objectives of the EWMPs are: • To collaborate among agencies (Permittee jurisdictions) across the watershed to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the MS4 Permit. • To develop watershed -wide EWMPs that will, once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff in a cost-effective manner. • To reduce the impact of stormwater and non-stormwater on receiving water quality. ESA Project Description The 12 EWMPs will vary for each watershed group, but will generally provide the opportunity for Permittees to customize their stormwater programs to achieve compliance with applicable receiving water limitations (RWLs) and water -quality -based effluent limits (WQBELs) in accordance with the MS4 Permit through implementation of stormwater best management practices (BMPs) or watershed control measures. BMPs vary in function and type, with each BMP providing unique design characteristics and benefits from implementation. The overarching goal of BMPs in the EWMP is to reduce the impact of stormwater and non-stormwater on receiving water quality and address the water quality priorities as defined by the MS4 Permit. The development of each EWMP will involve the evaluation and selection of multiple BMP types, including nonstructural (institutional) and distributed, centralized, and regional structural watershed control measures, that will be implemented to meet compliance goals and strategies under the 2012 MS4 Permit. The LACFCD has limited jurisdictional authority for ordinance and code enactment or enforcement and therefore is limited in nonstructural BMPs to education and outreach measures. The structural watershed control measures that will be implemented by the LACFCD will be multi -benefit stormwater projects that emphasize flood risk mitigation and water conservation and supply. The LACFCD has a vested interest in increasing opportunities for stormwater capture and groundwater recharge as a means of assisting local water supply augmentation. The LACFCD will be working with the applicable Permittees and other stakeholders in all 12 EWMP a County Flood Cenral District ES -3 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report Executive watersheds to develop such projects. The EWMPs will be implemented by the Permittees that have jurisdiction within each EWMP area. The implementing agencies will be responsible for the contents of the EWMPs affecting their jurisdictions and for implementing the projects developed by the EWMPs.. Structural control measures are constructed BMPs that reduce the impact of stormwater and non- stormwater on receiving water quality. They are broken into three categories: • Distributed Structural BMPs, which treat runoff close to the source and are typically implemented at a single- or few -parcel level (e.g., facilities typically serving a contributing area less than one acre). • Centralized Structural BMPs, which treat runoff from a contributing area of multiple parcels (e.g., facilities typically serving a contributing area on the order of tens or hundreds of acres or larger). • Regional Structural BMPs, which are meant to retain the 85th percentile storm over 24 hours from a contributing area. Generally, the 85th percentile storm is approximately 0.75 inches over 24 hours Whether distributed, centralized, or regional, the major structural BMP functions are infiltration, treatment, and storage, which may be used individually or combination: • Infiltration, where runoff is directed to percolate into the underlying soils. Infiltration generally reduces the volume of runoff and increases groundwater recharge. • Treatment, where pollutants are removed through various unit processes, including filtration, settling, sedimentation, sorption, straining, and biological or chemical transformations. • Storage, where runoff is captured, stored (detained), and slowly released into downstream waters. Storage can reduce the peak flow rate from a site, but does not directly reduce runoff volume. The types of structural BMPs to be implemented will vary between EWMPs, but most EMWPs will include a variety of distributed, centralized, and regional BMPs. These are policies, actions, and activities which are intended to minimize or eliminate pollutant sources. Most institutional BMPs are implemented to meet Minimum Control Measure (MCM) requirements in the MS4 permit; MCMs are considered a subset of institutional BMPs. These BMPs are not constructed, but may have costs associated with the procurement and installation of items such as signage or spill response kits ES,5 Project Alternatives An EIR must describe a range of reasonable alternatives to the proposed project or alternative project locations that could feasibly attain most of the basic project objectives and would avoid or substantially lessen any of the significant environmental impacts to the proposed project. The IA County Flood Cenral District ES -4 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive alternatives analysis must include the "No Project Alternative" as a point of comparison. The No Project Alternative includes existing conditions and reasonably foreseeable future conditions that would exist if the proposed project were not approved (CEQA Guidelines § 15126.6). ES.6 Summary of Impacts Table ES -1, at the end of this chapter, presents a summary of the impacts and mitigation measures identified for the proposed project. The complete impact statements and mitigation measures are presented in Chapter 3. The level of significance for each impact was determined using significance criteria (thresholds) developed for each category of impacts; these criteria are presented in the appropriate sections of Chapter 3. Significant impacts are those adverse environmental impacts that meet or exceed the significance thresholds; less -than -significant impacts would not exceed the thresholds. Table ES -1 indicates the measures that will avoid, minimize, or otherwise reduce significant impacts to a less -than -significant level if implemented by the Permittees. ES.7 Areas of Controversy Several comment letters from agency and public comments were received during the scoping period. Public comments received are provided in Appendix A of this PEIR. Some of the comments from non-governmental organizations and the public expressed concerns regarding the lack of project -specific details provided in the NOP for individual BMPs. Several comments were received questioning the funding strategies to be employed by Permittees. The full list of comments highlighting areas of potential controversy received during the public scoping period is included in Appendix A. ES.8 Issues to be Resolved Section 15123(b)(3) of the CEQA Guidelines requires that an EIR contain issues to be resolved, which includes the choice among alternatives and whether or how to mitigate significant impacts. The following major issues are to be resolved: • Determine whether the PEIR adequately describes the environmental impacts of the proposed program; • Choose among alternatives; • Determine whether the recommended mitigation measures should be adopted or modified; and • Determine whether additional mitigation measures need to be applied to the project. IA County Flood Control District ES -5 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report Executive ES.9 Organization of this PER This Draft PEIR is organized into the following chapters and appendices: Executive Summary. This chapter summarizes the contents of the Draft PEIR. Chapter 1, Introduction and Project Background. This chapter discusses the CEQA process and the purpose of the PEIR and provides background info on the proposed project. Chapter 2, Project Description. This chapter provides an overview of the proposed program, describes the need for and objectives of the proposed program, and provides detail on the characteristics of the proposed program. Chapter 3, Environmental Setting, Impacts and Mitigation Measures. This chapter describes the environmental setting and identifies impacts of the proposed program for each of the following environmental resource areas; Aesthetics; Air Quality; Biological Resources; Cultural Resources; Geology and Soils / Mineral Resources; Greenhouse Gas Emissions; Hazards and Hazardous Waste; Hydrology and Water Quality; Land Use and Planning / Agriculture; Noise; Population and Housing; Public Services / Recreation; Transportation and Circulation; and Utilities and Service Systems. Measures to mitigate the impacts of the proposed program are presented for each resource area. Chapter 4, Cumulative Impacts. This chapter analyzes the potential for the proposed program to have significant cumulative effects when combined with other past, present, and reasonably foreseeable future projects in each resource area's cumulative geographic scope. Chapter 5, Growth Impacts. This chapter identifies areas of the EIR where significant environmental effects that cannot be avoided would occur, if any. It will also include an analysis of growth inducement impacts that would be provided by the program. Chapter 6, Alternatives. This chapter presents an overview of the alternatives development process and describes the alternatives to the proposed program that were considered. Chapter 7, Organizations and Persons Contacted, Chapter 8, Report Preparers. This chapter identifies authors involved in preparing this Draft DEIR, including persons and organizations consulted. Chapter 9, References, IA County Flood Control District ES -6 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Progmm Environmental Impact Report Executive TABLE ES -1 SUMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE ENHANCED WATERSHED MANAGEMENT PROGRAMS Impacts Mitigation Measures Significance before Mitigation Significance if Mitigation is Implemented Aesthetics 3.1.1: The proposed program could create a AES -1: Aboveground structures shall be designed to be Significant Less than significant substantial adverse effect on a scenic vista. consistent with local zoning codes and applicable design guidelines and to minimize features that contrast with neighboring development. 3.1.2: The proposed program could Implementation of AES -1 Significant Less than significant substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway. 3.1.3: The proposed program could Implementation of AES -1 Significant Less than significant substantially degrade the existing visual AES -2: Implementing agencies shall develop BMP character or quality of the site and its maintenance plans that are approved concurrently with each surroundings. structural BMP approval. The maintenance plans must include measures to ensure functionality of the structural BMPs for the life of the BMP. These plans may include general maintenance guidelines that apply to a number of smaller distributed BMPs. 3.1.4: The proposed program could create a None required Less than significant Not applicable new source of substantial light or glare which would adversely affect day or nighttime views in the area. Air Quality 3.2.1: The project could conflict with or None required Less than significant Not applicable obstruct implementation of the applicable air quality plan. 3.2.2: The project could violate any air AIR -1: Implementing agencies shall require for large Regional Significant Significant and quality standard or contribute substantially or Centralized BMPs the use of low -emission equipment unavoidable for to an existing or projected air quality meeting Tier II emissions standards at a minimum and Tier III construction; Less than violation. and IV emissions standards where available as CARB- significant for required emissions technologies become readily available to operations. contractors in the region AIR -2: For large construction efforts that may result in significant air emissions, implementing agencies shall encourage contractors to use lower -emission equipment through the bidding process where appropriate. LA County Flood Control District ES -7 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program EmAronmental Impact Report Executive Impacts 3.2.3: The program could result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors). 3.2.4: The project could expose sensitive receptors to substantial pollutant concentrations. TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Mitigation Measures Implementation of AIR -1 and AIR -2 AIR -3: For large construction efforts associated with Regional or Centralized BMPs, implementing agencies shall conduct a project -specific LST analysis where necessary to determine local health impacts to neighboring land uses. Where it is determined that construction emissions would exceed the applicable LSTs or the most stringent applicable federal or state ambient air quality standards, the structural BMP project shall reduce its daily construction intensity (e.g., reducing the amount of equipment used daily, reducing the amount of soil graded/excavated daily) to a level where the structural BMP project's construction emissions would no longer exceed SCAOMD's LSTs or result in pollutant emissions that would cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standards. 3.2.5: The proposed program could create AIR -4: During planning of structural BMPs, implementing objectionable odors affecting a substantial agencies shall assess the potential for nuisance odors to number of people. affect a substantial number of people. BMPs that minimize odors shall be considered the priority when in close proximity to sensitive receptors. Biological Resources 3.3.1: The proposed project could have a substantial adverse effect, either directly or through habitat modifications, on any sensitive species identified as special -status in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service. BIO -1: Prior to approving a Regional or Centralized BMP., the Permittee shall conduct an evaluation of the suitability of the BMP location. Appropriate BMP sites should avoid impacting large areas of native habitats including upland woodlands and riparian forests that support sensitive species to the extent feasible. The evaluation shall include an assessment of potential downstream impacts resulting from flow diversions. BI0.2: Prior to ground disturbing activities in areas that could support sensitive biological resources, a habitat assessment shall be conducted by a qualified biologist to determine the potential for special -status wildlife species to occur within Significance before Significance if Mitigation Mitigation is Implemented Significant Significant and unavoidable for construction; less than significant for operations. Significant Significant Significant Less than significant Less than significant Less than significant LA County Flood Control District ES -8 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Significance before Significance if Mitigation Mitigation is Impacts Mitigation Measures Implemented affected areas, including areas directly or indirectly impacted by construction or operation of the BMPs. BI0-3: If a special -status wildlife species is determined to be present or potentially present within the limits of construction activities, a qualified biologist shall conduct pre -construction surveys of proposed work zones and within an appropriately sized buffer around each area as determined by a qualified biologist within 14 days prior to ground disturbing activities. Any potential habitat capable of supporting a special -status wildlife species shall be flagged for avoidance if feasible. BIO -4: If avoidance of special -status species or sensitive habitats that could support special -status species (including, but not limited to, critical habitat, riparian habitat, and jurisdictional wetlands/waters) is not feasible, the Permittee shall consult with the appropriate regulating agency (USAGE/USFWS or CDFW) to determine a strategy for compliance with the Endangered Species Act, California Fish and Game Code, and other regulations protecting special - status species and sensitive habitats. The Permittee shall identify appropriate impact minimization measures and compensation for permanent impacts to sensitive habitats and species in consultation with regulatory agencies. Construction of the project will not begin until the appropriate permits from the regulatory agencies are approved. BIO -5: If construction and vegetation removal is proposed between February 1 and August 31, a qualified biologist shall conduct a pre -construction survey for breeding and nesting birds and raptors within 500 -feet of the construction limits to determine and map the location and extent of breeding birds that could be affected by the project. Active nest sites located during the pre -construction surveys shall be avoided until the adults and young are no longer reliant on the nest site for survival as determined by a qualified biologist. BI0.6: All construction areas, staging areas, and right-of- ways shall be staked, flagged, fenced, or otherwise clearly delineated to restrict the limits of construction to the minimum necessary near areas that may support special -status wildlife species as determined by a qualified biologist. BI0.7: Prior to construction in areas that could support special status plants, a qualified botanist shall conduct a pre - LA County Flood Control District ES -9 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive Impacts TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Mitigation Measures construction floristic inventory and focused rare plant survey of project areas to determine and map the location and extent of special -status plant species populations within disturbance areas. This survey shall occur during the typical blooming periods of special -status plants with the potential to occur. The plant survey shall follow the CDFW Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (November 24, 2009). B10.8: If temporary construction -related impacts to special - status plant populations are identified within a disturbance area, the implementing agencies shall prepare and implement a special -status species salvage and replanting plan. The salvage and replanting plan shall include measures to salvage, replant, and monitor the disturbance area until native vegetation is re-established under the direction of CDFW and USFWS. Significance before Significance if Mitigation Mitigation is Implemented 3.3.2: The proposed project could have a Implement BILA through B10.8 Significant Less than significant substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the CDFW or USFWS. 3.3.3: The proposed project could have a Implement BI0.1 through B10.8 Significant Less than significant substantial adverse effect on federally BI0.9: Prior to construction, a qualified wetland delineator protected wetlands as defined by Section shall be retained to conduct a formal wetland delineation in 404 of the Clean Water Act (including, but areas where potential jurisdictional resources (i.e., wetlands not limited to, marsh, vernal pool, coastal, or drainages) subject to the jurisdiction of USAGE, RWQCB, etc.) through direct removal, filling, and CDFW, may be affected by the project. If jurisdictional hydrological interruption, or other means. resources are identified in the EWMP area and would be directly or indirectly impacted by individual projects, the qualified wetland delineator shall prepare a jurisdictional delineation report suitable for submittal to USAGE, RWQCB, and CDFW for purposes of obtaining the appropriate permits. Habitat mitigation and compensation requirements shall be implemented prior to construction in accordance with Mitigation Measure BI0-4. 3.3.4: The proposed project could interfere None required Less than significant Not applicable substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the LA County Flood Control District ES -10 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Impacts use of native wildlife nursery sites. TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Mitigation Measures Executive Significance before Significance if Mitigation Mitigation is Implemented 3.3.5: The proposed project could conflict BIO -10: Oak trees and other protected trees shall be avoided Significant Less than significant with any local policies or ordinances to the extent feasible. If trees may be impacted by project protecting biological resources, such as a construction, a certified arborist shall conduct a tree inventory tree preservation policy or ordinance. of the construction impact area. If any oak trees or other protected trees will be impacted by BMP construction, the implementing agency shall obtain any required County or City permits. 3.3.6: The proposed project could conflict None required Less than significant Not applicable with the provisions of an adopted habitat conservation plan, natural community Conservation plan, or other approved local, regional, or state habitat conservation plan. Cultural Resources 3.4.1: The proposed program could cause a CUL -1: For individual EWMP projects that could impact Significant Significant and substantial adverse change in the buildings or structures (including infrastructure) 45 years old Unavoidable significance of an historical resource as or older, implementing agencies shall ensure that a historic defined in §15064.5. built environment survey is conducted or supervised by a qualified historian or architectural historian meeting the Secretary of the Interior's Professional Qualification Standards for Architectural History. Historic built environment resources shall be evaluated for their eligibility for listing in the CRHR or local register prior to the implementing agency's approval of project plans. If eligible resources that would be considered historical resources under CEQA are identified, demolition or substantial alteration of such resources shall be avoided. If avoidance is determined to be infeasible, the implementing agency shall require the preparation of a treatment plan to include, but not be limited to, photo- documentation and public interpretation of the resource. The plan will be submitted to the implementing agency for review and approval prior to implementation. CUL -2: Implementing agencies shall ensure that individual EWMP projects that require ground disturbance shall be subject to a Phase I cultural resources inventory on a project - specific basis prior to the implementing agency's approval of project plans. The study shall be conducted or supervised by a qualified archaeologist, defined as an archaeologist meeting the Secretary of the Interior's Professional Qualifications Standards for Archaeology, and shall be conducted in LA County Flood Control District ES -11 ESA 1140494 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Significance before Significance if Mitigation Mitigation is Impacts Mitigation Measures Implemented consultation with the local Native American representatives expressing interest. The cultural resources inventory shall include a cultural resources records search to be conducted at the South Central Coastal Information Center; scoping with the NAHC and with interested Native Americans identified by the NAHC; a pedestrian archaeological survey where deemed appropriate by the qualified archaeologist; and formal recordation of all identified archaeological resources on California Department of Parks and Recreation 523 forms and significance evaluation of such resources presented in a technical report following the guidelines in Archaeological Resource Management Reports IARMR): Recommended Contents and Format, Department of Parks and Recreation, Office of Historic Preservation, State of California, 1990. If potentially significant archaeological resources are encountered during the survey, the implementing agency shall require that the resources are evaluated by the qualified archaeologist for their eligibility for listing in the CRHR and for significance as a historical resource or unique archaeological resource per CEQA Guidelines Section 15064.5. Recommendations shall be made for treatment of these resources if found to be significant, in consultation with the implementing agency and the appropriate Native American groups for prehistoric resources. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred manner of mitigation to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project re-route or re -design, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, which may include data recovery or other appropriate measures, in consultation with the implementing agency, and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. CUL -3: The implementing agency shall retain archaeological LA County Flood Control District ES -12 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Significance before Significance if Mitigation Mitigation is Impacts Mitigation Measures Implemented monitors during ground -disturbing activities that have the potential to impact archaeological resources qualifying as historical resources or unique archaeological resources, as determined by a qualified archaeologist in consultation with the implementing agency, and any local Native American representatives expressing interest in the project. Native American monitors shall be retained for projects that have a high potential to impact sensitive Native American resources, as determined by the implementing agency in coordination with the qualified archaeologist. CUL -4: During project -level construction, should subsurface archaeological resources be discovered, all activity in the vicinity of the find shall stop and a qualified archaeologist shall be contacted to assess the significance of the find according to CEQA Guidelines Section 15064.5. If any find is determined to be significant, the archaeologist shall determine, in consultation with the implementing agency and any local Native American groups expressing interest, appropriate avoidance measures or other appropriate mitigation. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred means to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project re-route or re -design, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, such as data recovery or other appropriate measures, in consultation with the implementing agency and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. 3.4.2: The program could cause a Implementation of CUL -2 through CUL -4 Significant Less than significant substantial adverse change in the significance of unique archaeological resources as defined in § 15064.5. LA County Flood Control District ES -13 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive Impacts 3.4.3: The program could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature. 3.4.4: The program could disturb any human remains, including those interred outside of a formal cemetery. Geologic and Mineral Resources 3.5.1: The proposed program could locate new facilities in areas susceptible to seismic impacts such as (1) rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault, (2) strong seismic groundshaking, or (3) seismically induced liquefaction or landslides, which could expose people, structures, or habitat to potential risk of loss, damage, injury, or death. TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Mitigation Measures Significance before Significance if Mitigation Mitigation is Implemented CUL -5: For individual structural BMP projects that require Significant Less than significant ground disturbance, the implementing agency shall evaluate the sensitivity of the project site for paleontological resources. If deemed necessary, the implementing agency shall retain a qualified paleontologist to evaluate the project and provide recommendations regarding additional work, potentially including testing or construction monitoring. CUL -6: In the event that paleontological resources are discovered during construction, the implementing agency shall notify a qualified paleontologist. The paleontologist will evaluate the potential resource, assess the significance of the find, and recommend further actions to protect the resource. CUL -7: The implementing agency shall require that, if human Significant Less than significant remains are uncovered during project construction, work in the vicinity of the find shall cease and the County Coroner shall be contacted to evaluate the remains, following the procedures and protocols set forth in Section 15064.5 (e)(1) of the CERA Guidelines. If the County Coroner determines that the remains are Native American, the Coroner will contact the Native American Heritage Commission, in accordance with Health and Safety Code Section 7050.5, subdivision (c), and Public Resources Code 5097.98 (as amended by AB 2641). The NAHC will then designate a Most Likely Descendant of the deceased Native American, who will engage in consultation to determine the disposition of the remains. None required Less than significant Not applicable LA County Flood Control District ES -14 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive 3.5.4: The proposed program could be TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Less than significant Not applicable located on expansive soil as defined in 24 Significance before Significance if Mitigation Mitigation is Impacts Mitigation Measures Implemented 3.5.2: The proposed program could result in None required Less than significant Not applicable substantial soil erosion or the loss of topsoil. use of a septic tank or alternative 3.5.3: The proposed program could be GEC -1: Prior to approval of infiltration BMPs, implementing Significant Less than significant located on a geologic unit or soil that is agencies shall conduct a geotechnical investigation of each wastewater. unstable, or that would become unstable as a infiltration BMP site to evaluate infiltration suitability. If 3.5.6: The proposed program could result in None required result of the program, and potentially result in infiltration rates are sufficient to accommodate an infiltration on-site or off-site non -seismically induced BMP, the geotechnical investigation shall recommend design region and the residents of the state or a geologic hazards such as landslides, lateral measures necessary to prevent excessive lateral spreading locally important mineral resource recovery spreading, subsidence, collapse or sinkholes, that could destabilize neighboring structures. Implementing settlement, or slope failure. agencies shall implement these measures in project designs. Cumulative Impacts 3.5.4: The proposed program could be None required Less than significant Not applicable located on expansive soil as defined in 24 CCR 1803.5.3 of the California Building Code (2013), creating substantial risks to life or structures. 3.5.5: The proposed program could have None required Less than significant Not applicable soils incapable of adequately supporting the use of a septic tank or alternative wastewater treatment systems where sewers are not available for the disposal of wastewater. 3.5.6: The proposed program could result in None required Less than significant Not applicable the loss of availability of a known mineral resource that would be of value to the region and the residents of the state or a locally important mineral resource recovery site delineated on a local General Plan, Specific Plan, or other land use plan. Cumulative Impacts GEC -2: Prior to installing BMPs designed to recharge local Significant Less than significant groundwater supplies, the Implementing Agency shall notify local groundwater managers including the Upper Los Angeles River Area Water Master, the Water Replenishment District of Southern California, or the San Gabriel Water Master as well as local water producers such as local municipalities and water companies. The Implementing Agency shall coordinate BMP siting efforts with groundwater managers and producers to mitigate high groundwater levels while increasing local water supplies. Greenhouse Gas Emissions LA County Flood Control District ES -15 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive 3.7.2: The proposed program could create a TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES maintenance practices that include periodic removal and environment through the accumulation of replacement of surface soils and media that may accumulate Significance before Significance if constituents to sub -soils and groundwater. A BMP Mitigation Mitigation is Impacts Mitigation Measures Implemented 3.6.1: The proposed program could None required Less than significant Not applicable generate GHG emissions, either directly or represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid indirectly, that may have a significant impact accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The BMP on the environment. Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed 3.6.2: The proposed program could conflict None required Less than significant Not applicable with any applicable plan, policy or regulation includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying of an agency adopted for the purpose of sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact reducing the emissions of GHGs. groundwater. 3.7.3: The proposed program could emit Implementation of HAZ-1 Less than significant Not applicable Hazards and Hazardous Materials 3.7.1: The proposed program would create None required Less than significant Not applicable a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials or the accidental release during construction and maintenance activities. 3.7.2: The proposed program could create a HAZ-1: Implementing agencies shall prepare and implement Significant Less than significant significant hazard to the public or the maintenance practices that include periodic removal and environment through the accumulation of replacement of surface soils and media that may accumulate potentially hazardous materials into BMPs. constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the individual BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. 3.7.3: The proposed program could emit Implementation of HAZ-1 Less than significant Not applicable hazardous emissions or handle hazardous LA County Flood Control District ES -16 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Impacts or acutely hazardous materials, substances, or waste within one-quarter mile of an existing school. TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Mitigation Measures Executive Significance before Significance if Mitigation Mitigation is Implemented 3.7.4: The proposed program could be HAZ-2: Prior to the initiation of any construction requiring Significant Less than significant located on a site which is included on a list ground -disturbing activities in areas where hazardous of hazardous materials sites compiled material use or management may have occurred, the pursuant to Government Code Section implementing agencies shall complete a Phase 1 65962.5 and, as a result, could create a Environmental Site Assessment (ESA) in accordance with significant hazard to the public or the American Society for Testing and Materials (ASTM) Standard environment. E1527-13 for each construction site. Any recommended follow up sampling (Phase II activities) set forth in the Phase I ESA shall be implemented prior to construction. The results of Phase II studies, if necessary, shall be submitted to the local overseeing agency and any required remediation or further delineation of identified contamination shall be completed prior to commencement of construction. 3.7.5: For a project located within an airport HAZ-3: Implementing Agencies shall require that those BMPs Significant Less than significant land use plan or, where such a plan has not that are within an airport land use plan area are compatible been adopted, within two miles of a public with criteria specified in FAA Advisory Circular No: 150/5200 - airport or public use airport, for a project 33B (FAA, 2007). If the proposed BMP is within the minimum within the vicinity of a private airstrip, the separation criteria, the Implementing Agency shall consult project could result in a safety hazard for with the airport and collaboratively evaluate whether the people residing or working in the project potential increase in wildlife hazards can be mitigated. area. 3.7.6: The proposed program could impair None required Less than significant implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. 3.7.7: The proposed program could expose None required Less than significant people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands. Hydrology and Water Quality 3.8.1: The proposed project would result in HYDRO -1: Prior to approving an infiltration BMP, the Significant higher groundwater levels and could Permittee shall conduct an evaluation of the suitability of the BMP location. Appropriate infiltration BMP sites should avoid Not applicable Not applicable Less than significant LA County Flood Control District ES -17 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive Impacts TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Mitigation Measures potentially affect groundwater quality. areas with low permeability where recharge could adversely affect neighboring subsurface infrastructure. HYDRO -2: Prior to approving an infiltration BMP, the Permitee shall identity pre-treatment technologies, type, and depth of filtration media; depth to groundwater; and other design considerations necessary to prevent contaminants from impacting groundwater quality. The design shall consider stormwater quality data within the BMP's collection area to assess the need and type of treatment and filtration controls. Local design manuals and ordinances requiring minimum separation distance to groundwater shall also be met as part of the design. HYDRO -3: Prior to the installation of an infiltration BMP, the Permitee shall conduct a database review for contaminated groundwater sites within a quarter mile of the proposed infiltration facility. The Permittee shall identify whether any contaminated groundwater plumes are present and whether coordination with the local and state environmental protection overseeing agency and responsible party is warranted prior to final design of infiltration facility. 3.8.2: The proposed project could None required substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river, or by other means, in a manner that would result in substantial erosion or siltation on - or off-site. 3.8.3: The project could substantially alter None required the existing drainage pattern of a site or area through the alteration of the course of a stream or river or, by other means, substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site. 3.8.4: The proposed project could create or None required contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. Significance before Significance if Mitigation Mitigation is Implemented Less than significant Less than significant Less than significant Not applicable Not applicable Not applicable LA County Flood Control District ES -18 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Significance before Significance if Mitigation Mitigation is Impacts Mitigation Measures Implemented 3.8.5: The project could place housing within a 100 -year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other authoritative flood hazard delineation map. 3.8.6: The project could place within a 100 - year flood hazard area structures that would impede or redirect flood flows. 3.8.7: The proposed project could expose structures to a significant risk of loss, including flooding as a result of the failure of a levee or dam. 3.8.8: The proposed project could place structures in areas subject to inundation by seiche, tsunami, or mudflow. Land Use and Agriculture 3.9.1: The proposed program could physically divide an established community. 3.9.2: The proposed program could conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the program (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect. 3.93: The proposed program could conflict with any applicable habitat conservation plan or natural community conservation plan. 3.9.4: The proposed program could convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping None required None required None required None required None required. None required None required None required No impact Less than significant Less than significant Less than significant No Impact No Impact No Impact No Impact Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable LA County Flood Control District ES -19 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive Impacts and Monitoring Program of the California Resources Agency, to non-agricultural use. The proposed program could involve other changes in the existing environment which, due to their location or nature, could result in conversion of agricultural land to non- agricultural use or conversion of forest land to non -forest use. TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Mitigation Measures 3.9.5: The proposed program could conflict None required with existing zoning for agricultural use, or a Williamson Act contract. 3.9.6: The proposed program could conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)). The proposed program could result in the loss of forest land or conversion of forest land to non -forest use. Noise 3.10-1: The proposed program could result in exposure of persons to, or generation of, noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. None required NOISE -1: The implementing agencies shall implement the following measures during construction as needed:: • Include design measures necessary to reduce the construction noise levels where feasible. These measures may include noise barriers, curtains, or shields. • Place noise -generating construction activities (e.g., operation of compressors and generators, cement mixing, general truck idling) as far as possible from the nearest noise -sensitive land uses. • Locate stationary construction noise sources as far from adjacent noise -sensitive receptors as possible. • If construction is to occur near a school, the construction contractor shall coordinate the with school administration in order to limit disturbance to the campus. Efforts to limit construction activities to non -school days shall be encouraged. Significance before Significance if Mitigation Mitigation is Implemented No Impact Not applicable No Impact Not applicable Significant Significant and unavoidable for construction; less than significant for operations LA County Flood Control District ES -20 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Impacts TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Mitigation Measures • For the centralized and regional BMP projects located adjacent to noise -sensitive land uses, identify a liaison for these off-site sensitive receptors, such as residents and property owners, to contact with concerns regarding construction noise and vibration. The liaison's telephone number(s) shall be prominently displayed at construction locations. • For the centralized and regional BMP projects located adjacent to noise -sensitive land uses, notify in writing all landowners and occupants of properties adjacent to the construction area of the anticipated construction schedule at least 2 weeks prior to groundbreaking. NOISE -2: All structural BMPs that employ mechanized stationary equipment that generate noise levels shall comply with the applicable noise standards established by the implementing agency with jurisdiction over the structural BMP site. The equipment shall be designed with noise -attenuating features (e.g., enclosures) and/or located at areas (e.g., belowground) where nearby noise -sensitive land uses would not be exposed to a perceptible noise increase in their noise environment. 3.10.2: The proposed program could result None required in exposure of persons to, or generation of, excessive groundborne vibration. 3.10-3: The proposed program could result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project. Implementation of NOISE -1 and NOISE -2 3.10.4: The proposed program could result Implementation of NOISE -1 in a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project. 3.10-5: For a project located within an None required airport land use plan area, or, where such a plan has not been adopted, in an area within 2 miles of a public airport or public use airport, implementation of the proposed program could expose people residing or working in the area to excessive noise Executive Significance before Significance if Mitigation Mitigation is Implemented Less than significant Significant Significant Less than significant Not applicable Less than significant Significant and unavoidable Not applicable LA County Flood Control District ES -21 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive Impacts levels. TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Mitigation Measures 3.10.6: For a project located in the vicinity None required of a private airstrip, the proposed program could expose people residing or working in the project area to excessive noise levels. Population and Housing and Environmental Justice 3.11-1: Implementation of the proposed None required program could induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure). 3.11-2: Implementation of the proposed None required program could displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere. 3.11.3: Implementation of the proposed None required program could displace substantial numbers of people, necessitating the construction of replacement housing elsewhere. 3.11.4: Implementation of the proposed None required program could affect the health or environment of minority or low income populations disproportionately. Public Services and Recreation 3.12.1: The proposed program could result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered governmental fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for fire protection services. PS -1: The Permittee implementing the EWMP project shall provide reasonable advance notification to the service providers such as fire, police, local businesses, home owners and residents of adjacent to and within areas potentially affected by the proposed EWMP project about the nature, extent and duration of construction activities. Interim updates should be provided to inform them of the status of the construction activities. Significance before Significance if Mitigation Mitigation is Implemented Less than significant No Impact No Impact No Impact Less than significant Significant Not applicable Not applicable Not applicable Not applicable Not applicable Less than significant LA County Flood Control District ES -22 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Impacts TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Mitigation Measures 3.12.2: The proposed program could result None required in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered governmental police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for police protection services. 3.12.3: The proposed program could result None required in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered schools, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for schools. 3.12-4: The proposed program could None required increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. 3.12-5: The proposed program could None required include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. Transportation and Circulation 3.13-1: The proposed program could TRAF-1: For projects that may affect traffic, implementing intermittently and temporarily increase traffic agencies shall require that contractors prepare a construction levels and traffic delays due to vehicle trips traffic Control plan. Elements of the plan should include, but are generated by construction workers and not necessarily limited to, the following: construction vehicles on area roadways. 0 Develop circulation and detour plans to minimize impacts to local street circulation. Use haul routes minimizing truck traffic on local roadways to the extent possible. To the extent feasible, and as needed to avoid adverse Executive Significance before Significance if Mitigation Mitigation is Implemented Less than significant Less than significant Less than significant Less than significant Significant Not applicable Not applicable Not applicable Not applicable Less than significant LA County Flood Control District ES -23 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Executive Impacts TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Mitigation Measures impacts on traffic Flow, schedule truck trips outside of peak morning and evening commute hours. • Install traffic control devices as specified in Caltrans' Manual of Traffic Controls for Construction and Maintenance Work Zones where needed to maintain safe driving conditions. Use flaggers and/or signage to safely direct traffic through construction work zones. • Coordinate with facility owners or administrators of sensitive land uses such as police and fire stations, hospitals, and schools. Provide advance notification to the facility owner or operator of the timing, location, and duration of construction activities. Significance before Significance if Mitigation Mitigation is Implemented 3.13.2: Construction of the proposed None required Less than significant Not applicable program could potentially cause traffic safety hazards for vehicles, bicyclists, and pedestrians on public roadways, and could increase traffic hazards due to possible road wear. 3.13-3: The proposed program could result None required. Less than significant Not applicable in inadequate emergency access during construction. 3.13.4: Construction of the proposed Implementation of TRAF-1 Significant Less than significant program could contribute to cumulative impacts to traffic and transportation (traffic congestion, traffic safety, and emergency vehicle access). Utilities and Service Systems 3.14-1: Implementation of the proposed None required Less than significant Not applicable program could exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board or result in the construction of new treatment facilities or expansion of existing facilities if the wastewater treatment provider has inadequate rapacity to serve the proposed program. 3.14.2: The proposed program could None required Less than significant Not applicable require or result in the construction of new storm water drainage facilities or expansion LA County Flood Control District ES -24 ESA 1140494 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Impacts of existing facilities, the construction of which could cause significant environmental effects. TABLE ES -1 (continued) SUMMARY OF IMPACTS AND MITIGATION MEASURES Mitigation Measures Executive Significance before Significance if Mitigation Mitigation is Implemented 3.14.3: The proposed program could UTIL-1: Prior to approval of BMPs, implementing agencies Significant Less than significant require new or expanded water supply shall evaluate the potential for impacts to downstream resources or entitlements or require or beneficial uses including surface water rights. Implementing result in the construction of new water agencies shall not approve BMPs that result in preventing facilities or expansion of existing facilities, access to previously appropriated surface water downstream. the construction of which could cause significant environmental effects. 3.14.4: The proposed program could be UTIL-2: Implementing agencies shall encourage construction Significant Less than significant served by a landfill with insufficient contractors to recycle construction materials and divert inert permitted capacity to accommodate the solids (asphalt, brick, concrete, dirt, fines, rock, sand, soil, project solid waste disposal needs or the and stone) from disposal in a landfill where feasible. project could not comply with federal, state, Implementing agencies shall incentivize construction and local statutes and regulations related to contractors with waste minimization goals in bid specifications solid waste. where feasible. 3.14-5: Construction and operation of the None required proposed program would require additional energy use that could result in wasteful consumption, affect local and regional energy supplies, or conflict with applicable energy efficiency policies or standards. Less than significant Not applicable LA County Flood Control District ES -25 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report CHAPTER 1 Introduction 1.1 Introduction The Los Angeles County Flood Control District (LACFCD) was created in 1915 when the State Legislature adopted the Los Angeles County Flood Control Act to provide flood risk management, water conservation, and recreation and aesthetic enhancement within its boundaries. The LACFCD owns and maintains a broad network of flood control facilities that convey stormwater to the local rivers and ultimately to the ocean. This vast network of regional flood control channels is interconnected with local flood control facilities owned and maintained by the both the LACFCD and the incorporated municipalities within Los Angeles County. In December 2012, the Los Angeles Regional Water Quality Control Board (LARWQCB) issued a Municipal Separate Storm Sewer System (MS4) Permit (Order No. R4-2012-0175; National Pollutant Discharge Elimination System [NPDES] Permit No. CAS004001) covering discharges within coastal watersheds from the collective storm sewer systems in Los Angeles County (except from the City of Long Beach). The Permit regulates the discharge of stormwater runoff to waters of the United States from facilities owned and maintained by the LACFCD, the County of Los Angeles, and 84 incorporated cities within Los Angeles County (collectively referred to as Permittees). The purpose of the MS4 Permit is to achieve and maintain water quality objectives to protect beneficial uses of the receiving waters in the Los Angeles region. Each of the Permittees identified in the MS4 permit is responsible for meeting the conditions of the permit for MS4 discharges occurring within their jurisdiction. The MS4 Permit gives Permittees the option of implementing an innovative approach to permit compliance through development of an Enhanced Watershed Management Program (EWMP). The EWMPs will identify potential and priority structural and non-structural Best Management Practices (BMPs) within the region's stormwater collection system to improve runoff water quality. The LACFCD, along with participating Permittees, has opted to exercise this option and has submitted to the LARWQCB 12 separate Notices of Intent (NOIs) for the development of EWMPs within 12 distinct watershed groups (refer to Figure 1-1). Implementation of the EMWPs would be the responsibility of each Permittee and would occur following approval of the EWMPs by the LARWQCB. IA County Flood Control District ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report Ventura Kern 1 - Ballon Creek - 2 - Beach Cities - 3 - Dominguez Channel - 4 - Malibu Creek - 5 - Marina Del Rey - 6 - North Santa Monica Bay - 7 - Palos Verdes Peninsula 8 - Rio Hondo/San Gabriel River - 9 - Santa Monica Bay Jurisdictions 2+3 - 10 - Upper LA River - 11 - Upper San Gabriel River 12 - Upper Santa Clara River 0 Participating Permittees Q Watershed Boundary Northern Boundary LACFCD SOURCE: ESRI. MANHATTAN Los Angeles Loi Ang ei River eqp n er o PASADE AL AMBRA RON MEAD MONTER PARKGabriel Riv TERM 91 I ® San -� Bernardino ® ri � 4 r' � t` ®6 I A Orange o e I I Miles LA County PEIR EWMP. 140474 Figure 1-1 Watersheds and EWMP Groups within LACFD Boundaries 1. Introduction The LACFCD, as a regional agency, is a member of each of the 12 EWMP working groups, and as such provides a commonality within each EWMP group. However, LACFCD does not have a special status or authority designated by the MS4 Permit over any of the other Permittees. The LACFCD will be working with the applicable Permittees in all 12 EWMP watersheds as an equal partner to identify the types and locations of BMPs needed to achieve permit compliance within each watershed. The timeline identified in the MS4 Permit requires that Permittees submit the EWMP to the LARWQCB by June 28, 2015, in order to be in compliance with the permit conditions. The LACFCD recognizes that implementation of the EWMPs may potentially result in changes to environmental conditions. As a result, the LACFCD has prepared this Program Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the EWMPs. The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior to submittal of the EWMPs. The EWMPs will be submitted by each EWMP group to the LARWQCB. This PEIR describes and evaluates each of the EWMPs being prepared by the Permittees collectively. The discretionary action prompting the need for CEQA compliance is the submittal of the completed EWMPs to the LARWQCB. The EWMPs will identify management strategies including hundreds of structural Best Management Practices (BMPs) that may be designed and implemented by the Permittees to meet permit compliance objectives. A few of the BMPs are currently well defined but most are yet to be fully developed under the EWMPs. A set of priority BMPs will be detailed in each of the EWMPs; these are being developed in parallel with the PEIR. The PEIR describes the details that are available for each of the EWMPs currently under preparation by the EWMP working groups. The PEIR analysis is not intended to focus on the site-specific construction and operation details of each management strategy and project included in the EWMP. Rather, this PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis outlines mitigation strategies to be followed by the LACFCD and other implementing agencies that rely on this PEIR to avoid or minimize impacts wherever feasible. The determinations of significance after mitigation in this PEIR will apply to the LACFCD and other implementing agencies that rely on this PEIR and the mitigation measures proposed herein. LACFCD is the CEQA Lead Agency for this PEIR. This PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual EWMP projects. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects as appropriate or may determine that no additional CEQA analysis is required or that a IA County Flood Control District 1-3 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of their proposed projects. The PEIR provides the LACFCD a foundation for any necessary future environmental review documents that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. In addition, the PEIR can provide several advantages during the development and implementation of the EWMPs that may include: • More exhaustive consideration of effects and alternatives than would be practical in an environmental impact report (EIR) for an individual BMP project. • Consideration of cumulative impacts that might not be evident in a case-by-case or project -by -project analysis. • Consideration by LACFCD as Lead Agency of broad policy alternatives and program - wide mitigation measures early in the process when there is greater flexibility to deal with basic problems or cumulative impacts. The EWMPs are to include a discussion of the environmental documents, assessments, and permitting required for the implementation of the priority projects. The PEIR can provide a basis for this discussion. The use of the PEIR in the development and implementation of the EWMPs is further discussed in this chapter in the Purpose of the Program Environmental impact Report. 1.2 Project Background Stormwater/Water Quality MS4 discharges consist of stormwater and non-stormwater generated from point sources throughout a watershed, collected and conveyed through the MS4, and ultimately discharged into surface waters. The MS4 system includes curbs and gutters, man-made channels, catch basins, and storm drains throughout the Los Angeles region. Discharges may adversely affect receiving surface water quality with pollutants such as bacteria, nutrients (nitrogen and phosphorus), metals, pesticides, and other man-made organic compounds. Aquatic toxicity, particularly during wet weather, is also a concern. Stormwater and non-stormwater discharges of debris and trash are also a pervasive water quality problem in the Los Angeles region. Pollutants in stormwater and non-stormwater may have damaging effects on both human health and aquatic ecosystems when persistent at certain concentrations above water quality criteria/thresholds. Through water quality assessments conducted by the LARWQCB, the LARWQCB and U.S. Environmental Protection Agency (USEPA) have established 33 Total Maximum Daily Loads (TMDLs) that identify Los Angeles County MS4 discharges as pollutant sources causing or contributing to water quality impairments. The TMDL development process is explained in more detail in Chapter 2.0, Project Description. The MS4 Permit (described briefly later in this chapter) is designed to reduce pollutant loads into local surface waters. The implementation of the 12 EWMPs and their watershed -specific compliance strategies (which are explained in more detail in Chapter 2.0) would address the need for reduction in urban runoff pollution through IA County Flood Control District 1-4 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction treatment and infiltration, as well as increasing stormwater retention throughout the Los Angeles region. MS4 NPDES Permit On November 8, 2012, the LARWQCB adopted the fourth NPDES MS4 Permit (Order No. R4- 2012-0175) for discharges from the MS4s located within the coastal watersheds of Los Angeles County (excepting the City of Long Beach), which became effective on December 28, 2012. The MS4 Permit identifies conditions, requirements, and programs that municipalities must comply with to protect regional water resources from adverse impacts associated with pollutants in stormwater and urban runoff. The MS4 Permit contains effluent limitations, receiving water limitations (RWLs), minimum control measures, and TMDL provisions and outlines the process for developing watershed management programs, including EWMPs. Watershed Management Programs The MS4 Permit Section VLC (page 47) includes provisions that allow Permittees to voluntarily choose to implement a Watershed Management Program (WMP). The purpose of this program is to "allow Permittees the flexibility to develop Watershed Management Programs to implement the requirements of [the] Order on a watershed scale through customized strategies, control measures, and BMPs." The permit states that "participation in a Watershed Management Program is voluntary and allows a Permittee to address the highest watershed priorities." Several areas of the County covered in the permit chose to comply with the MS4 Permit through the preparation of WMPs only. In these areas, the structural BMPs needed to achieve local water quality objectives were primarily distributed BMPs that were found to be categorically exempt from CEQA. Actions needed to achieve MS4 Permit compliance in areas that have chosen to implement WMPs only are not evaluated in this PEIR. Enhanced Watershed Management Programs The Permit Section VI.C. Lg (page 48) allows for watersheds to collaborate in preparing an EWMP to achieve Permit compliance with RWLs. The intent of the EWMP is to comprehensively evaluate opportunities for collaboration on multi -benefit regional projects that retain MS4 discharges and also address flood control and/or water supply within the participating Permittees' collective jurisdictional boundaries. Twelve EWMP groups have formed to implement a collaborative approach to meeting the requirements of the 2012 MS4 Permit. As required by the provisions of the MS4 Permit, each of the 12 EWMPs includes several components aimed at identifying priorities for water quality improvement and the mechanisms that will achieve those improvements. In general, these components include: 1. Stakeholder outreach and collaboration, so that development and implementation of the EWMP is a collaborative effort between Permittees, stakeholders, and the public. 2. Identification of water quality priorities, which serve as the basis for implementation and monitoring activities within the EWMP. a County Flood Cenral District 1-5 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction 3. Identification of candidate watershed control measures that Permittees and stakeholders can customize to address water quality priorities. 4. Implementation of a Reasonable Assurance Analysis, so that the Permittees, stakeholders, and regulatory authorities can identify which control measures are likely to be the most effective, and have confidence in the performance of the selected watershed control measures. These components are discussed in further detail below. Stakeholder Outreach and Collaboration According to Part VLC. Lf,v (page 48) of the MS4 Permit, each EWMP must provide appropriate opportunities for meaningful stakeholder input, including the development of a watershed management program Technical Advisory Committee (TAC) that will advise and participate in the development of the EWMP. The MS4 Permit requires that at a minimum, the TAC include at least one Permittee representative from each Watershed Management Area (WMA) for which an EWMP is being developed (e.g., city administrators, stormwater program managers), one public representative from a non-government organization with public membership (e.g., environmental and community groups), and staff from the Regional Board, USEPA Region IX, and collaborating agencies (e.g., California Department of Transportation, U.S. Arany Corps of Engineers). Broader stakeholder groups will also be engaged through a series of workshops specific to each EWMP. The precise number and format of workshops will likely vary by watershed, with the overarching goal of providing a common and consistent orientation for stakeholders to the EWMP process, and a clear structure for stakeholders to contribute to the EWMPs. The TAC and stakeholders are expected to help define appropriate water quality priorities and identify suitable watershed control measures; these project elements are discussed further in this chapter. Water Quality Priorities The identification of water quality priorities is required in Section VLC.S.a (p. 58) of the MS4 Permit as part of EWMP development. The Permit describes a four -step process for prioritizing and sequencing water quality concerns within each EWMP watershed: 1. Water quality characterization based on available monitoring data, TMDLs, 303(d) lists, stormwater annual reports, etc. 2. Water body -pollutant classification 3. Source assessment for the water body -pollutant categories 4. Prioritization of the water body -pollutant categories The prioritization of pollutants under Step 4 is conducted for each EWMP watershed according to the following guidelines, established in the MS4 Permit: TMDLs (first category): a County Flood Control District 1-6 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction o Controlling pollutants for which there are water -quality -based effluent limitations and/or receiving water limitations with interim or final compliance deadlines within the permit term, or TMDL compliance deadlines that have already passed and limitations have not been achieved. o Controlling pollutants for which there are water -quality -based effluent limitations and/or receiving water limitations with interim or final compliance deadlines between September 6, 2012, and October 25, 2017. • Other Receiving Water Considerations (second category): o The second highest priority shall be considered controlling pollutants for which data indicate impairment of exceedances of receiving water limitations and the findings from the source assessment implicates discharges from the MS4. The EWMP prioritization process includes identifying the priority pollutants and the schedule for implementing BMPs to meet the following criteria: • For pollutants in the same class as TMDLs, the EWMPs evaluate the ability to consider these pollutants within the same time frame as the TMDLs. • For pollutants on 303(d) list or in same class as 303(d) listings, the EWMPs develop a schedule to address these pollutants as soon as possible with milestones. • For pollutants with exceedances that are not in the same class as the 303(d) listing, the EWMPs propose monitoring under CIMP to confirm exceedances and, if those exceedances are confirmed, the Permittees shall then develop a schedule to address these pollutants as soon as possible with milestones. • For pollutants without exceedances in the last five years, the EWMPs will include them in monitoring plans but not prioritize them for BMPs. The outcome of this process is the identification of water quality priorities in each EWMP and the proposed schedule for which BMPs are to be implemented to address these pollutants. Pollutants under a TMDL have higher priority and will be addressed under the timelines defined in the TMDLs. This further highlights that the EWMP is a continuation of water quality improvement efforts by the Permittees under existing TMDLs through adopted TMDL Implementation Plans. BMP types that are assessed in this PEIR therefore include BMPs that are under various stages of implementation and plan to meet TMDL waste load allocations. Identification of Candidate Watershed Control Measures The EWMPs describe a broad range of structural and non-structural control measures aimed at achieving compliance with the provisions of the MS4 Permit. These control measures are more commonly referred to as BMPs. BMPs vary in function and type, with each BMP providing unique design characteristics and benefits of implementation. Further description of both non- structural and structural BMP types, examples and anticipated distribution of the BMPs are presented in Chapter 2.0, Project Description, as these are the basis for the proposed program. IA County Flood Control District 1-7 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction Reasonable Assurance Analysis The Reasonable Assurance Analysis (RAA) is a critical component of the EWMPs and is used to demonstrate "that the activities and control measures will achieve applicable water -quality -based effluent limitations and/or RWLs with compliance deadlines during the Permit term" (Los Angeles MS4 Permit, Part VLC.5.b.iv.(5), page 63). While the MS4 Permit prescribes the RAA as a quantitative demonstration that control measures (such as BMPs) will be effective, the RAA also provides an opportunity to use a modeling process to identify and prioritize potential control measures. The RAA for each EWMP uses a model to simulate a critical storm (design storm) and demonstrate that the selected BMPs for each watershed will achieve compliance with the TMDLs and water -quality -based effluent limitations. The RAA is being performed as part of the preparation of the EWMPs, and in parallel with the preparation of this PEIR. The RAA demonstrates that the primary goal of the EWMP is to meet the water quality goals. The modeling being performed as part of the RAA will determine if the number and distribution of the BMP types and specific projects identified in the EWMP Work Plans will meet the water quality goals. This PEIR will assess the types of BMPs that may be implemented to meet these goals. Chapter 2.0, Project Description, provides examples of these types and maps showing the approximate location and potential distribution of these BMP types to meet these goals. These BMP examples are subject to change through the EWMP planning process that is developing on a parallel track to this PEIR. The EWMPs are also planning documents that will be revised periodically to reflect new data, further modeling, emerging technologies, and results of BMP monitoring and assessments. 1.3 CEQA Environmental Review Process CEQA Process Overview The basic purposes of CEQA are to: (1) inform the public and government decision makers regarding potential significant environmental effects of proposed activities, (2) identify ways in which potential environmental damage can be avoided or significantly reduced, (3) prevent significant, avoidable environmental damage by requiring changes in projects through the use of alternatives or mitigation measures, and (4) disclose to the public the reasons why a government agency approved the project if significant environmental effects are involved. CEQA states that an EIR should use a multidisciplinary approach applying social and natural sciences to make a qualitative and quantitative analysis of all the foreseeable environmental impacts that a proposed project would exert on the surrounding area. As stated in Section 15151 of the CEQA Guidelines: "An EIR should be prepared with a sufficient degree of analysis to provide decision -makers with information which intelligently takes an account of environmental consequences. An evaluation of the environmental effects of a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in the light of what is reasonable feasible." IA County Flood Control District t -S ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Progmm Environmental Impact Report 1. Introduction This PEIR for the proposed program was prepared to comply with CEQA regulations, and is to be used by local agencies and the public in their review of the potential environmental impacts of the EWMP's implementation, proposed alternatives, and mitigation measures that would minimize, avoid, or eliminate the potential environmental effects. The LACFCD will consider the information presented in this PEIR, along with other factors, in the development and implementation of the EWMPs. The EWMPs are to include a discussion of the environmental documents, assessments and permitting required for the implementation of the priority projects. The PEIR can provide a basis for this discussion. Significance criteria have been developed for each environmental resource analyzed in this Draft PEIR. The significance criteria are defined at the beginning of each impact analysis section. Impacts are categorized as follows: • Significant and Unavoidable: Mitigation might be recommended but impacts are still significant. • Less than Significant with Mitigation: Potentially significant impact but mitigated to a less -than -significant level. • Less than Significant: Mitigation is not required under CEQA but may be recommended. • No Impact. Purpose of the Program Environmental Impact Report The LACFCD determined that implementation of the 12 EWMPs could have a significant effect on the environment and therefore required preparation of a PEIR. The LACFCD prepared this Draft PEIR to provide the public and the responsible and trustee agencies with information about the potentially significant environmental effects of the proposed program, to identify possible ways to minimize potentially significant effects, and to describe and evaluate feasible alternatives to the proposed program. This document has been prepared as a PEIR. According to the CEQA Guidelines, Section 15168(a), a PEIR is one type of environmental review document that may be used to evaluate a plan or program that has multiple components (projects and actions) or to address a series of actions that are related in any of the following ways: • Geographically. • As logical parts in the chain of contemplated actions. • In connection with the issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program. • As individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental affects that can be mitigated in similar ways. IA County Flood Control District 1-9 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction The EWMPs would include multiple projects and actions that cover a broad geographic scale. This PEIR provides a foundation for any necessary future environmental review documents that focus on individual projects of the EWMPs. A PEIR can provide the following additional advantages (CEQA Guidelines, Section 15168[b]): • Provide for a more exhaustive consideration of effects and alternatives than would be practical in an EIR on an individual action. • Ensure consideration of cumulative impacts that might not be evident in a case-by-case or project -by -project analysis. • Avoid duplicative consideration of basic policy issues. • Allow Lead Agency to consider broad policy alternatives and program -wide mitigation measures early in the process when the agency has greater flexibility to deal with basic problems or cumulative impacts. • Facilitate a reduction in paperwork. A PEIR may be prepared on a plan before the details of each and every project within the long- term plan have been developed, as is the case for the EWMPs. Therefore, this PEIR addresses the environmental effects of the program as a whole. The analyses focus on the environmental effects of implementing the EWMPs as a program to improve surface water quality and increase water conservation. For the proposed program, many management strategies are only in the concept development or planning phase. The PEIR analysis is not intended to focus on the site-specific construction and operation details of each management strategy and project included in the EWMPs. Rather, this PEIR serves as a fust -tier environmental document that focuses on the effects of implementing the EWMPs overall as a plan to reduce urban runoff pollution. This PEIR evaluates the major environmental effects of implementing proposed EWMP projects from a broad perspective; this evaluation is a program -level analysis. While the Permittees are developing the design, construction, and operation details of the projects that would be included in the EWMPs, these project details are not the focus of this PEIR. Instead, the PEIR frames the nature and magnitude of the expected environmental impacts associated with these proposed EWMP projects and identifies program mitigation measures to reduce the impacts of the projects as proposed. As discussed further in this report, more detailed project -level analyses of individual EWMP projects may be conducted separately by each of the Permittees as required by CEQA. The EWMPs are to include a discussion of the environmental documents, assessments, and permitting required for the implementation of the priority projects. The PEIR can provide a basis for this discussion. This PEIR can be used by the LACFCD or other local implementing agencies to streamline environmental review of individual EWMP projects. The implementing agency may determine that a more detailed, project -level analysis is required, or may determine some projects to be exempt from CEQA. For non-exempt projects, project -level CEQA review will be conducted separately by the appropriate implementing agency. The separate environmental review of individual projects will evaluate site-specific impacts and incorporate feasible mitigation measures and alternatives (CEQA Guidelines, Section 15168[c]). IA County Flood Control District 1-10 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction Impact Assessment Methodology This PEIR provides a "program level' assessment, meaning that the type of BMPs that are envisioned for implementation are described and evaluated in concept, with examples of implemented projects provided to illustrate typical features. Each EWMP includes a list of potential locations where these BMP types may be installed, along with available information on the anticipated scale, location, and construction methods required for installation. Maps identifying potential and priority BMP locations are provided in Chapter 2, Project Description, with the overall EWMP watershed characteristics and BMP implementation strategy. The PEIR focuses its assessment on construction and operation of these potential and priority BMPs to be installed throughout the watersheds—but primarily within urbanized areas where the pollutant loading is greatest and where these BMPs can be most cost-effective in meeting water quality goals. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis outlines mitigation strategies to be followed by Implementing Agencies to avoid or minimize impacts wherever feasible. Exact locations and BMP designs are not defined. Rather, the overall compliance strategy of BMP type, quantity, and geographic distribution is assessed on a cumulative, regional scale. Scoping Period A Notice of Preparation (NOP) was published by the LACFCD on August 29, 2014 (Appendix A). The NOP was circulated to federal, state, and local agencies, as well as other interested parties, for a period of 30 days. The distribution list is also located in Appendix A. The NOP was made available in print and electronic form, and the LACFCD accepted comments on the NOP for a 30 -day period, closing on September 29, 2014. In addition, an email notification regarding the availability of the NOP was sent to over 700 interested EWMP stakeholders. The NOP discussed the purpose of the EWMPs and their management strategies, identified the EWMP Study Areas, and provided a brief and preliminary list of environmental issue areas that could be impacted. The initial 30 -day comment period was extended an additional 30 days to October 29, 2014, to provide greater opportunity for public comment on the NOP. The notification for the extension of the comments period was sent by email to the over 700 interested EWMP stakeholders. The notice of the extension was also provided through the LACFCD Twitter account. In addition, a recording of the Scoping Meeting presentation was posted on the LACFCD website. A link to the website (www.LACoH2Osheds.com) was provided in the email and Twitter feed announcements. Table 1-1 provides a list of the commenters that sent comments on the NOP. The comment letters are located in Appendix A. IA County Flood Control District 1-11 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction Date Name TABLE 1-1 NOP COMMENTERS Organization 1 10/16/2014 Enrique Huerta At -Large Stakeholder (Downey, CA) 2 10/23/2014 Enrique Huerta At -Large Stakeholder (Downey, CA) 3 10/28/2014 George Ball Citizen 4 10/29/2014 Jane Williams Los Angeles County Arboretum 5 10/27/2014 Kenneth Hill Los Angeles County Arboretum Foundation, President 6 10/23/2014 Marsha Perez Citizen, Los Angeles County Arboretum 7 09/29/2014 Rex Frankel Ballona Ecosystem Education Project, Director 8 10/29/2014 Rex Frankel Ballona Ecosystem Education Project, Director 9 10/29/2014 Tom Williams Sierra Club, Water Committee 10 10/08/2014 Elizabeth Byrne Debreu Los Angeles Arboretum Foundation 11 09/29/2014 Dianna Watson Department of Transportation 12 09/24/2014 Deirdre West Metropolitan Water District 13 09/25/2014 Katy Sanchez NAHC 14 09/29/2014 Douglas Fay Citizen 15 09/29/2014 Donna Murray Citizen 16 09/29/2014 Joyce Dillard Citizen 17 10/03/2014 Patricia McPherson Grassroots Coalition 18 10/14/2014 Jane Florentinus Citizen 19 10/29/2014 Dale Carter Arboretum volunteer and docent 20 08/29/2014 Scott Morgan State Clearinghouse Public Scoping Meetings Pursuant to CEQA Guidelines Section 15083, the LACFCD held three public Scoping Meetings on September 9, 10, and 15 of 2014 to receive comments on the NOP, as detailed below. The purpose of the meetings was to present the proposed EWMPs to the interested stakeholders and receive public input regarding the proposed scope of the PEIR analysis. Attendees were provided an opportunity to voice comments or concerns regarding potential effects of the program. A scoping report was prepared to summarize the public scoping process and the comments received in response to the NOP; the scoping report is included in Appendix B of this PEIR. Appendix B also includes the written comments received on the NOP. Scoping Meeting 1 Tuesday, September 9, 2014 6:00 P.M. Chace Park Community Room 13650 Mindanao Way Marina del Rey, CA 90292 IA County Flood Control District 1-12 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 1. Introduction Scoping Meeting 2 Wednesday, September 10, 2014 6:00 P.M. County of Los Angeles Department of Public Works 900 South Fremont Avenue First Floor Conference Room C Alhambra, CA 91803 Scoping Meeting 3 Monday, September 15, 2014 6:30 P.M. K Dalton Room Monrovia Community Center 119 W Palm Ave Monrovia, CA 91016 Draft Program EIR Public Review In accordance with Section 15105 of the CEQA Guidelines, the Draft PEIR is available for public review and comment for a 45 -day review period. The Draft PEIR has been circulated to federal, state, and local agencies and interested parties who may wish to review and issue comments on its contents. All written comments should be sent to: Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 All written comments received on the Draft PEIR will be commented on and included in the Final PEIR. Comments on the Draft PEIR must be received in writing by the end of the public review period. Copies of the Draft PEIR and related key documents, as well as documents incorporated by reference, are available for review at the following public locations: Lead Agency County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 Ballona Creek Culver City Julian Dixon Library 4975 Overland Ave. Culver City, CA 90230 View Park Library 3845 W. 54th Street Los Angeles, CA 90043 IA County Flood Control District 1-13 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction Beach Cities WMG Hermosa Beach Library 550 Pier Ave. Hermosa Beach, CA 90254 Manhattan Beach Library 1320 Highland Ave. Manhattan Beach, CA 90266 Dominguez Channel Hawthorne Library WMG 12700 Grevillea Ave. Hawthorne, CA 90250 Carson Library 151 E. Carson St. Carson, CA 90745 Malibu Creek Agoura Hills Library 29901 Ladyface Court Agoura Hills, CA 91301 Marina del Rey Lloyd Taber Marina del Rey Library 4533 Admiralty Way Marina del Rey, CA 90292 North Santa Monica Bay Malibu Library Coastal Watersheds 23519 W. Civic Center Way Malibu, CA 90265 Palos Verdes Peninsula Lomita Library 24200 Narbonne Ave. Lomita, CA 90717 Rio Hondo/San Gabriel Duarte Library WQG 1301 Buena Vista St. Duarte, CA 91010 Live Oak Library 4153-55 E. Live Oak Ave. Arcadia, CA 91006 Santa Monica Bay Wiseburn Library 5335 W. 135th St. Hawthorne, CA 90250 IA County Flood Control District 1-14 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction Upper Los Angeles River San Gabriel Library 500 S. Del Mar Ave. San Gabriel, CA 91776 La Canada Flintridge Library 4545 N. Oakwood Ave. La Canada Flintridge, CA 91011 Upper San Gabriel River Baldwin Park Library 4181 Baldwin Park Blvd. Baldwin Park, CA 91706 La Puente Library 15920 E. Central Ave. La Puente, CA 91744 Upper Santa Clara River Stevenson Ranch Express Library Dr. Richard H. Rioux Memorial Park 26233 W. Faulkner Dr. Stevenson Ranch, CA 91381 The Draft PEIR can also be accessed through the intemet at: www.LACoH2Osheds.com. Public Hearings Public comments on the Draft PEIR will be accepted from January 16, 2015 to March 2, 2015. Public hearings on the Draft PEIR to accept written or oral comments are scheduled as follows: I" Meeting Thursday, January 29: 6:00 P.M. — 8:00 P.M. Florence -Firestone Service Center — Contact: Tony Brookins, Director 7807 S. Compton Ave., Los Angeles, CA 90001 Phone: (323) 586-6502 2'dMeeting Tuesday, February 3: — 6:00 P.M. — 8:00 P.M. LA County Fire Camp #2 Classroom (Hahamongna Watershed Park) — Contact: Celia Hernandez 4810 Oak Grove Dr, La Canada Flintridge, CA 91011 (818) 790-6434 3m Meeting Thursday, February 5 — 6:00 P.M. — 8:00 P.M. San Pedro Service Center — Contact: Lilia Andres, Regional Manager 769 W. Third St., San Pedro, CA 90731 Phone: (310) 519-6091 4" Meeting Tuesday, February 10: 6:00 P.M. — 8:00 P.M. Topanga Library — Contact: Oleg Kagan, Library Manager 122 N. Topanga Canyon Blvd., Topanga, CA 90290 Phone: (310) 455-3480 5" Meeting Wednesday, February 11: 6:00 P.M. — 8:00 P.M. Hacienda Heights Community Center 1234 Valencia Avenue, Hacienda Heights CA 91745 IA County Flood Control District 1-15 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction 6" Meeting Tuesday, February 17: 6:00 P.M. — 8:00 P.M. East Los Angeles Library — Contact: Alice Medina, Librarian 4837 East 3rd Street, Los Angeles, CA 90022 Phone: (323) 264-0155 Final PEIR Publication and Certification Written comments received on the Draft PEIR will be addressed in a Response to Comments document which, together with the Draft PEIR, will constitute the Final PEIR. As required by CEQA, responses to comments submitted by responsible public agencies will be distributed to those agencies for review prior to consideration of the Final FIR by the Board of Supervisors. The Board of Supervisors will decide whether to certify the Final PEIR at a public meeting. Upon certification of the PEIR, LACFCD may proceed to take action on program approval and submittal of the EWMPs to the LARWQCB. CEQA requires the adoption of findings prior to approval of a project where a certified FIR identifies significant environmental effects (CEQA Guidelines, Sections 15091 and 15092). If the Board of Supervisors approves the program even though significant impacts identified by the PEIR cannot be mitigated, it will adopt a Statement of Overriding Considerations that states in writing the reasons for its actions (CEQA Guidelines Section 15093[b]). This Statement of Overriding Considerations must be included in the record of the project approval and mentioned in the Notice of Determination (CEQA Guidelines Section 15093(c)). Mitigation Monitoring and Reporting Program CEQA Section 21081.6(a) requires lead agencies to "adopt a reporting and mitigation monitoring program for the changes to the project which it has adopted or made a condition of project approval in order to mitigate or avoid significant effects on the environment." This Draft PEIR identifies and presents mitigation measures that would form the basis of such a monitoring program. Any mitigation measures adopted by the LACFCD will be included in a Mitigation Monitoring and Reporting Program (MMRP) to verify compliance. The MMRP will be included within the Final PEIR. 1A Documents Incorporated by Reference The following documents are incorporated by reference in this PEIR: Ballona Creek Watershed Management Group, Enhanced Watershed Management Program (EWMP) Final Work Plan, prepared by City of Beverly Hills, City of Culver City, City of Los Angeles, City of Inglewood, City of Santa Monica, City of West Hollywood, County of Los Angeles, and Los Angeles County Flood Control District, June 2014. Ballona Creek Watershed Management Group, Revised Notice oflntent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, December 2013. Beach Cities Watershed Management Group, Enhanced Watershed Management Program (EWMP) Work Plan, prepared by City of Hermosa Beach, City of Manhattan Beach, City a County Flood Cenral District 1-16 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction of Redondo Beach, City of Torrance, and Los Angeles County Flood Control District, June 2014. Beach Cities Watershed Management Group, Notice oflntent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, December 2013. California Environmental Protection Agency State Water Resources Control Board, official website, http://www.waterboards.ca.gov/losangeles/, accessed July 29, 2014. California Regional Water Quality Control Board Los Angeles Region, Waste Discharge Requirements for Municipal Separate Storm Sewer System (MS4) Discharges Within the Coastal Watersheds of Los Angeles County, Order NO. R4-2012-0175, NPDES Permit NO. CAS004001, December 2012. Dominguez Channel Watershed Management Area Group, Enhanced Watershed Management Program Work Plan, prepared by City of Los Angeles, County of Los Angeles, City of Hawthorne, City of Inglewood, City of El Segundo, City of Lomita, and Los Angeles County Flood Control District, June 2014. Dominguez Channel Watershed Management Area Group, Notice oflntent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, June 2013. Malibu Creek Watershed Group, Revised Notice of -Intent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, June 2013. Malibu Creek Watershed Management Group, Enhanced Watershed Management Program Work Plan, prepared for City of Calabasas, City of Agoura Hills, City of Westlake Village, City of Hidden Hills, County of Los Angeles and Los Angeles County Flood Control District, June 2014. Marina del Rey Enhanced Watershed Management Agencies, Marina del Rey Enhanced Watershed Management Program Work Plan, prepared for County of Los Angeles, Los Angeles County Flood Control District, City of Los Angeles, and City of Culver City, June 2014. Marina del Rey Watershed Group, Revised Notice oflntent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, March 2014. North Santa Monica Bay Coastal Watersheds EWMP Group, Enhanced Watershed Management Program (EWMP) Work Plan, prepared by City of Malibu, County of Los Angeles, and Los Angeles County Flood Control District, June 2014. North Santa Monica Bay Coastal Watersheds, Notice oflntent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, March 2014. Palos Verdes Peninsula EWMP Agencies, Notice oflntent: Peninsula Enhanced Watershed Management Plan, June 2013. Palos Verdes Peninsula Watershed Management Group, Palos Verdes Peninsula Enhanced Watershed Management Program Work Plan, June 2014. Rio Hondo/San Gabriel River Water Quality Group, Enhanced Watershed Management Program Work Plan, prepared for City of Arcadia, City of Azusa, City of Bradbury, City of Duarte, City of Monrovia, City of Sierra Madres, County of Los Angeles, and Los Angeles County Flood Control District, June 2014. IA County Flood Control District 1-17 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction Rio Hondo/San Gabriel River Water Quality Group, Notice oflntent: Enhanced Watershed Management Program (EWMP), June 2013. Santa Monica Bay Watershed (J2, J3), Notice oflntent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, December 2013. Santa Monica Bay Watershed Jurisdictions 2 & 3, Enhanced Watershed Management Program Work Plan, prepared by City of Los Angeles, Los Angeles County Flood Control District, County of Los Angeles, City of Santa Monica, and City of El Segundo, June 2014. Upper Los Angeles River Watershed Group, Notice of Intent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, June 2013. Upper Los Angeles River Watershed Management Group, prepared by City of Alhambra, City of Burbank, City of Calabasas, City of Glendale, City of Hidden Hills, City of La Canada Flintridge, City of Los Angeles, City of Montebello, City of Monterey Park, City of Pasadena, City of Rosemead, City of San Gabriel, City of San Marino, City of South Pasadena, City of Temple City, County of Los Angeles, and Los Angeles County Flood Control District, Enhanced Watershed Management Program Work Plan, June 2014. Upper San Gabriel River EWMP Group, Draft Enhanced Watershed Management Program Work Plan, prepared for City of Baldwin Park, City of Covina, City of Glendora, City of Industry, City of La Puente, County of Los Angeles, and Los Angeles County Flood Control District, June 2014. Upper San Gabriel River EWMP Group, Notice oflntent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, June 2013. Upper Santa Clara River Watershed Management Group, Enhanced Watershed Management Program — Work Plan, prepared for City of Santa Clarita, County of Los Angeles, and Los Angeles County Flood Control District, June 2014. Upper Santa Clara River Watershed Management Group, Notice oflntent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, June 2013. 1.5 PER Organization This Draft PEIR is organized into the following chapters and appendices: Executive Summary. This chapter summarizes the contents of the Draft PEIR. Chapter 1.0, Introduction. This chapter discusses the CEQA process and the background and purpose of the PEIR for the proposed program. Chapter 2.0, Project Description. This chapter provides an overview of the proposed program and each EWMP group, describes the need for and objectives of the proposed program, and provides detail on the characteristics of the proposed program. Chapter 3.0, Environmental Impact Analysis. This chapter describes the environmental setting and identifies impacts of the proposed program for each of the following environmental resource areas: Aesthetics; Air Quality; Biological Resources; Cultural Resources; Geology and Soils/Mineral Resources; Greenhouse Gas Emissions; Hazards and Hazardous Waste; Hydrology a County Flood Cenral District 1-18 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 1. Introduction and Water Quality; Land Use and Planning/Agriculture; Noise; Population and Housing; Public Services/Recreation; Transportation and Circulation; and Utilities, Service Systems, and Energy. Measures to mitigate the impacts of the proposed program, if necessary, are presented for each resource area. Chapter 4.0, Cumulative Impacts. This chapter evaluates the potential for the proposed program to result in secondary environmental cumulative effects. Chapter 5.0, Growth -Inducement Potential. This chapter evaluates the potential for the proposed program to induce population growth and result in secondary environmental effects due to such growth. Chapter 6.0, Alternatives Analysis. This chapter presents an overview of the alternatives development process and describes the alternatives to the proposed program that were considered. Chapter 7.0, Organizations and Persons Contacted. This chapter identifies authors involved in preparing this Draft PEIR, including persons and organizations consulted. Chapter 8.0, Report Preparers. This chapter identifies authors involved in preparing this Draft PEIR, including persons and organizations consulted. Chapter 9.0, References. This chapter includes all citations for sources used in the preceding chapters. IA County Flood Control District 1-19 ESA / 140674 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report CHAPTER 2 Project Description 2.1 Introduction The preparation of the 12 separate Enhanced Watershed Management Programs (EWMPs) is a collective effort among the Los Angeles County Flood Control District (LACFCD) and the applicable Permittees in each Watershed Management Group (WMG). The 12 EWMPs are being prepared on a parallel schedule to the Program Environmental Impact Report (PEIR). The 12 EWMPs will vary for each watershed group, but will generally provide the opportunity for Permittees to customize their stormwater programs to achieve compliance with applicable receiving water limitations and/or water -quality -based effluent limits in accordance with the Municipal Separate Storm Sewer System (MS4) Permit through implementation of stormwater Best Management Practices (BMPs) or watershed control measures. Each Permittee is responsible for discharges in its jurisdiction and meeting the water quality goals for these discharges. The EWMPs provide for a collaborative effort by Permittees on a watershed basis. The EWMP process allows for greater collaboration and accountability. The EWMPs, once complete, will include specific projects and identify Permittees that may benefit from the projects. Projects may be implemented individually or with partners. Each Permittee is responsible for the content of the EWMP projects that meet the water quality goals for the MS4 discharges within their jurisdiction. This Project Description describes types of BMPs presented in the 12 Notices of Intent (NOIs), EWMP Work Plans, and input from the EWMP WMG. The BMPs listed in each EWMP are in various phases of planning or implementation. Examples of existing BMPs are used to illustrate the function, type of construction, and general locations of the BMP types for the purpose of the environmental assessment of the BMP types identified in the EWMPs. BMPs vary in function and type, with each BMP providing unique design characteristics and benefits from implementation. The overarching goal of BMPs in the EWMPs is to reduce the impact of stormwater and non-stormwater on receiving water quality and address the water quality priorities as defined by the MS4 Permit. The development of each EWMP will involve the evaluation and selection of multiple BMP types, including nonstructural (institutional) and distributed, centralized, and regional structural watershed control measures, that will be implemented to meet compliance goals and strategies under the 2012 MS4 Permit. The LACFCD has limited jurisdictional authority for ordinance and code enactment or enforcement and therefore is limited in nonstructural BMPs to education and outreach measures. The structural watershed control measures that will be implemented by the LACFCD will be multi -benefit stormwater projects that emphasize flood risk mitigation and water conservation and supply. LA County Flood Control District 2-1 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. The LACFCD has a vested interest in increasing opportunities for storrnwater capture and groundwater recharge as a means of assisting local water supply augmentation. The LACFCD will be working with the applicable Permittees and other stakeholders in all 12 EWMP watersheds to develop such projects. The EWMPs will be implemented by the Permittees that have jurisdiction within each EWMP area. The implementing agencies will be responsible for the contents of the EWMPs affecting their jurisdictions and for implementing the projects developed by the EWMPs. 2.2 Goals and Objectives The primary goals and objectives of the EWMPs are: • To collaborate among agencies (Permittee jurisdictions) across the watershed to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the MS4 Permit. • To develop watershed -wide EWMPs that will, once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff in a cost-effective manner. • To reduce the impact of stormwater and non-stormwater on receiving water quality. 2.3 Watersheds, Participants, and Process Following the adoption of the MS4 Permit by the Los Angeles Regional Water Quality Control Board (LARWQCB), some Permittees from each EWMP area formed WMGs to collaborate on the development of EWMPs. The proposed program includes several WMGs of Los Angeles County, covering the following EWMP areas: Ballona Creek, Beach Cities, Dominguez Channel, Malibu Creek, Marina del Rey, North Santa Monica Bay Coastal Watersheds, Palos Verdes Peninsula, Rio Hondo/San Gabriel River, Santa Monica Bay, Upper Los Angeles River, Upper San Gabriel River, and Upper Santa Clara River. The geographic scope covered by each of these 12 EWMPs is detailed in Table 2-1 and shown in Figure 2-1, LA County Flood Control District 2-2 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. TABLE 2-1 - EWMP PARTICIPANTS AND WATERSHEDS Watershed Management Group Affected Watersheds Cities/Permittees Lead/Coordinator Ballona Creek Ballona Creek Watershed Beverly Hills, Culver City, Los Angeles Inglewood, Los Angeles, Santa Monica, West Hollywood, LA County, LACFCD Beach Cities Santa Monica Bay Watershed Hermosa Beach, Manhattan Redondo Beach Jurisdictional Group (SMB JG) 5 Beach, Redondo Beach, & 6, Dominguez Channel Torrance, LACFCD Watershed, and Machado Lake Watershed Dominguez Channel Dominguez Channel EI Segundo, Hawthorne, Los Angeles Watershed, the Machado Lake Inglewood, Los Angeles, Watershed, and the Los Lomita, LA County, LACFCD Angeles/Long Beach Harbors Watershed Malibu Creek Malibu Creek Watershed Agoura Hills, Calabasas, Hidden Calabasas Hills, Westlake Village, LA County, LACFCD Marina del Rey Marina del Rey Watershed Culver City, Los Angeles, LA County LACFCD, LA County North Santa Monica Bay SMB JG 1, SMB JG 4, and a LA County, LACFCD, Malibu Malibu portion of Malibu Creek within the City of Malibu's borders Palos Verdes Peninsula Most of the SMB JGT the Los Palos Verdes Estates, Rancho Rancho Palos Verdes Angeles Harbor subwatershed, Palos Verdes, Rolling Hills and the Machado Lake Estates, LA County, LACFCD subwatershed Rio Honda/San Gabriel River Portions of the Los Angeles and Arcadia, Azusa, Bradbury, Sierra Madre San Gabriel River Watersheds Duarte, Monrovia, County, LACFCD, Sierra Madre Santa Monica Bay SMB JG2 and SMB JG3 Los Angeles, EI Segundo, Santa Los Angeles Monica, LA County, LACFCD Upper LA River Upper reaches of the Alhambra, Burbank, Calabasas, Los Angeles Los Angeles River Watershed Glendale, Hidden Hills, La Canada Flintridge, Los Angeles, Montebello, Monterey Park, Pasadena, Rosemead, San Gabriel, San Marino, South Pasadena, Temple City, LA County, LAFCD Upper San Gabriel River Portions of the San Gabriel Baldwin Park, Covina, LA County River Watershed Glendora, Industry, La Puente, LACFCD, LA County Upper Santa Clara River Upper Santa Clara River LA County, LACFCD, Santa Santa Clarita Watershed Clarita LA County Flood Control District 2-3 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report Ventura Kern 1 - Ballon Creek - 2 - Beach Cities - 3 - Dominguez Channel - 4 - Malibu Creek - 5 - Marina Del Rey - 6 - North Santa Monica Bay - 7 - Palos Verdes Peninsula 8 - Rio Hondo/San Gabriel River - 9 - Santa Monica Bay Jurisdictions 2+3 - 10 - Upper LA River - 11 - Upper San Gabriel River 12 - Upper Santa Clara River 0 Participating Permittees Q Watershed Boundary Northern Boundary LACFCD SOURCE: ESRI. MANHATTAN Los Angeles Loi Ang ei River eqp n er o PASADE AL AMBRA RON MEAD MONTER PARKGabriel Riv TERM 91 I ® San -� Bernardino ® ri � 4 r' � t` ®6 I A Orange o e I I Miles LA County PEIR EWMP. 140474 Figure 2-1 Watersheds and EWMP Groups within LACFD Boundaries 2.4 EWMP BMP Types A variety of BMP types are defined in the EWMP Work Plans and NOIs. The following section provides an overview of non-structural and structural BMP types that will be part of the EWMPs. This section also includes a summary of planned and ongoing projects listed in the EWMP Work Plans for each BMP type to provide information on the anticipated scale, construction methods, and general locations of these BMP types. Additional information and figures on the location and distribution of potential and priority BMPs based on available data at the time of publication of this PEIR, are presented in Section 2.5, EWMP Watershed Characteristics and BMP Implementation Strategies. 2.4.1 Non -Structural Control Measures/institutional BMPs These are policies, actions, and activities which are intended to minimize or eliminate pollutant sources. Most institutional BMPs are implemented to meet Minimum Control Measure (MCM) requirements in the MS4 permit; MCMs are considered a subset of institutional BMPs. These BMPs are not constructed, but may have costs associated with the procurement and installation of items such as signage or spill response kits. The MS4 Permit categorizes institutional BMPs into six program categories: • Development Construction Programs, which establish standards for stormwater management from construction sites of all sizes (e.g., with or without a stormwater pollution prevention plan [SWPPP]). • Industrial/Commercial Facilities Programs, which establish standards for pollutant reduction and control measures at industrial and commercial facilities. • Illicit Connection and Illicit Discharges (IC/ID) Detection and Elimination Programs, which describe procedures for identifying, eliminating, and reporting illicit connections and discharges to the stormwater system. • Public Agency Activities Programs, which describe a broad range of municipal practices such as street cleaning, landscape management, storm drain operation, and more. • Planning and Land Development Programs, which encourage the application of smart growth and low -impact development (LID) practices to development and redevelopment projects. • Public Information and Participation Programs, which educate and engage the public on a broad range of pollution- and stormwater-related issues. Permittees can evaluate the MCMs, identify potential modifications that will address water quality priorities, and provide justification for modification or elimination of any MCM that is determined to be ineffective (with the exception of the Planning and Land Development Program, which may not be eliminated or modified). MCM customization may include replacement, reduced implementation, augmented implementation, focused implementation, or elimination. LA County Flood Control District 2-5 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. Because the LACFCD has limited jurisdictional authority for ordinance and code enactment or enforcement, it is limited in application of MCMs to activities such as public information and participation programs. 2,4,2 Structural Control Measures/Structural BMPs - General BMP Types and Categories Structural control measures are constructed BMPs that reduce the impact of stormwater and non- stormwater on receiving water quality. They are broken into three categories: • Distributed Structural BMPs, which treat runoff close to the source and typically implemented at a single- or few -parcel level (e.g., facilities typically serving a contributing area less than one acre). • Centralized Structural BMPs, which treat runoff from a contributing area of multiple parcels (e.g., facilities typically serving a contributing area on the order of tens or hundreds of acres or larger). • Regional Structural BMPs, which are meant to retain the 85th percentile storm over 24 hours from a contributing area. Generally, the 85" percentile storm is approximately 0.75 inches over 24 hours Whether distributed, centralized, or regional, the major structural BMP functions are infiltration, treatment, and storage that may be used individually or combination: • Infiltration, where runoff is directed to percolate into the underlying soils. Infiltration generally reduces the volume of runoff and increases groundwater recharge. • Treatment, where pollutants are removed through various unit processes, including filtration, settling, sedimentation, sorption, straining, and biological or chemical transformations. • Storage, where runoff is captured, stored (detained), and slowly released into downstream waters. Storage can reduce the peak flow rate from a site, but does not directly reduce runoff volume. The types of structural BMPs to be implemented will vary between EWMPs, but most EMWPs will include a variety of distributed, centralized, and regional BMPs. Table 2-2 describes the sub -types of distributed, centralized, and regional structural BMPs that form the basis of the water quality improvements proposed in the EWMPs. The following sub- sections provide further description and examples of the BMP types and subcategories under the categories of distributed, centralized, and regional structural BMPs. LA County Flood Control District 2-6 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report TABLE 2-2 TYPICAL STRUCTURAL BEST MANAGEMENT PRACTICES Main BMP Category BMP Types to be Assessed Sub -types of BMPs Distributed Structural Site -scale detention Dry detention basin BMPs Wet detention pond Detention chambers Green infrastructure/Low-impact Bioretention development (LID) Biofiltration Permeable pavement Green streets Infiltration BMPs Bioswales Planter boxes Rainfall harvest Flow-through treatment BMPs Debris booms/nets End -of -pipe nets Floating trash booms Hydrodynamic separators Water clarifiers Stormwater quality vaults Source control treatment BMPs Centralized Structural Infiltration BMPs Surface infiltration BMPs (infiltration basins, BMPs (do not retain the infiltration trenches, infiltration galleries, 85th percentile storm) bioretention, permeable pavement— implemented as single or multiple types), subsurface infiltration galleries Multi -directional infiltration BMPs (dry wells, hybrid bioretention and dry wells) Capture and use BMPs Underground cisterns, storage and use as irrigation Bioinfiltration BMPs Generally implemented as multiple types for regional BMPs: Bioretention with underdrain, bioinfiltration, high-flow biotreatment and raised underdrain, vegetated swales, filter strips Detention (promote settling out of larger Aboveground, belowground particles) Treatment facilities (capture, storage and treatment -train) Low -flow diversion (dry-weatherfiow and low -flow storm events) Engineered/constructed wetlands Aboveground, belowground Creek/river/floodplain/estuary restoration Multi -benefit flood management project Regional Structural Infiltration Surface infiltration BMPs: Infiltration basins, BMPs (retain the 85th infiltration trenches, infiltration galleries, and percentile storm) bioretention-implemented as single or multiple types Multidirectional infiltration BMPs: Dry wells, hybrid bioretention, and dry wells Capture and use BMPs Underground cisterns, storage, and use as irrigation LA County Flood Control District 2-7 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. 2,4e3 Distributed Structural BMPs - Overview and Example BMPs The following discussion presents an overview of various types of distributed BMPs and illustrates these further through example projects. The example project lists are based on existing and planned projects that will be part of the EWMPs. Included with each overview of the types of these BMPs is a discussion of the anticipated construction activities to implement these projects. Because of their nature (intended to treat runoff at the parcel -scale), distributed BMPs are most likely to be implemented in high-density urban, commercial, industrial, and transportation areas, where they will either replace or improve upon existing stormwater infrastructure. These types of BMPs are generally `retrofit" type projects that replace existing impervious surfaces with pervious surfaces such as bioinfiltration cells, bioswales, porous pavement, and filter strips that tie into existing stormwater management systems as part of the MS4. These projects may also augment the existing MS4 with additional inlet screens, filter media systems, sediment removal systems, and diversions to sanitary sewer lines. Types of distributed structural BMPs are discussed in the following pages; the definitions and photographs of these BMPs are from the "Structural Fact Sheets" as presented in some EWMP Work Plans (e.g., Ballona Creek). Site -scale detention. Site -scale detention facilities are designed to detain runoff from an individual parcel and improve water quality through pollutant settling. Site -scale detention facilities can reduce peak flows and improve water quality by storing water in a basin before slowly draining the water through an orifice to the downstream waterway. Settling of sediment and sediment -bound pollutants is the primary pollutant removal mechanism. There are two primary types of site -scale detention: dry detention basins, in which runoff fully drains during storm events, and wet detention ponds, which capture water in a temporary storage zone above a permanent pool. Both types are illustrated in the following photographs.. Dry Detention 6win Wet Detention PMW Anticipated Construction Activities: The construction of detention basins typically requires the permanent removal of aboveground infrastructure and/or surface materials such as asphalt and concrete for retrofit type projects and excavation and grading for projects on soil -covered sites. Ground disturbance for distributed detention is typically less than 1 to 2 acres in extent, but may extend in some limited applications up to 5 acres where space is available. Site soils must be excavated to create the desired storage volume for stormwater. The depth of excavation will vary with available space, existing grades, and desired storage volume. For these smaller -scale systems, excavation is likely to be several feet and up to 10 feet. Generally, excavation below LA County Flood Cenral District 2-8 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 6 feet is limited by the size of these systems and available space to provide adequate slope grading for safety and stability. Berms may be used to increase storage to reduce cost of excavation. Berms for these types of projects are several feet. Higher berms may be possible in some limited locations where space is available. Increasing berm height increases the footprint of these facilities to accommodate side slopes for safety and stability factors. On parcels where there is adequate room, soils may be placed on-site to balance cut and fill; smaller parcels may necessitate the off -hauling of excavated soils. Construction of dry detention basins in areas with high groundwater may limit the depth of the basins to meet minimum groundwater separation distances. The construction of dry detention basins may include the installation of recreational elements (nets, benches, etc.) so that the basins can serve as playing fields when not inundated. Wet detention ponds may require engineering (separate outlet structures with low -flow orifices, circulation elements, etc.) to ensure that the permanent pool does not become stagnant and a magnet for mosquito production (must be emptied within 72 hours). Detention basin includes beans and outlet structures that control the volume stored and the flow and velocity of the discharge. Green infrastructure/Low-impact development (LID). This BMP category describes a broad range of development elements that aim to manage and treat stormwater as a resource, and minimize the differences between pre- and post -development hydrology. BMP subtypes in this category include: • Bioretention and Biofiltration. Bioretention areas are shallow, depressed, vegetated basins with permeable soil media and no underdrains. Runoff temporarily ponds on the surface of these basins before filtering through the soil. Biofiltration areas are bioretention areas with underdrains. Infiltration is these systems is considered incidental, although substantial infiltration can occur in some unlined systems. Both systems are illustrated below; these examples use planted filter media and an underdrain to remove pollutants from stormwater. Blaretention in an Alley Anticipated Construction Activities: Similar to distributed detention basins, distributed bioretention and biofiltration BMPs would typically require the permanent removal of aboveground infrastructure and/or surface materials such as asphalt and concrete for retrofit type projects and excavation and grading for projects on soil covered sites. Ground disturbance for LID distributed BMPs is typically less than 1 to 2 acres in extent, but may extend in some limited applications up to 5 acres where space is available and where linear projects extend to adjacent parcels. The extent of land disturbance depends LA County Flood Cenral District 2-9 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. on the type of distributed BMP and may be more linear for bioswales and filter strips, compared to larger continuous areas for bioretention cells that store and then filter or infiltrate stormwater. In areas proposed for biofiltration without suitably permeable soils, native soils will have to be excavated, amended, and put back in place, or replaced entirely with biofiltration media (e.g., coarse gravels). The replacement of local soils would likely require that those soils then be hauled off-site. Systems with underdrains may require more extensive excavation and construction so that the underdrain can be connected to the MS4. The depth of excavation for these distributed systems will vary from several feet and up to 10 feet depending on the thickness and number of filter and storage layers. Generally, excavation is limited to 4 to 6 feet below existing grade for these systems. • Permeable Pavement. Permeable pavement is a stable load-bearing surface that allows for stormwater infiltration. Beneath the permeable surface is a crushed -rock/ aggregate reservoir that provides structural support while allowing runoff to percolate to the underlying soils. Permeable pavement can be fully infiltrating or can have an underdrain like biofiltration practices. There are multiple types of permeable pavement; three are illustrated below. The mixes for pervious concrete and porous asphalt exclude fines from the aggregate to create permeable void space. Permeable interlocking concrete pavers allow infiltration of stormwater through joints between the blocks. Pervious Concrete Permeable Interlocking Porous Aspha}t Anticipated Construction Activities: Similar to distributed bioretention and biofiltration BMPs, porous pavement BMPs would typically require the permanent removal of aboveground infrastructure and/or surface materials such as asphalt and concrete for retrofit type projects and excavation and grading for projects on soil covered sites. Porous pavement projects are generally retrofit type projects to increase infiltration and/or filtering of stormwater, but may include installation in new development and redevelopment, which may require clearing and grubbing activities prior to installation. Ground disturbance for these systems is typically less than 1 to 2 acres in extent, but may extend in some limited applications up to 5 acres where space is available. The depth of excavation for these distributed systems will vary from several feet and up to 6 feet depending on the thickness and number of structural support, filter, underground stormwater storage, and underdrain transmission layers. Systems with underdrains will require additional excavation. Generally, excavation is limited to 2 to 6 feet below existing grade for these systems. The installation of permeable pavement is frequently LA County Flood Control District 2-10 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report associated with the reconstruction of transportation elements such as parking lots, sidewalks, non -motorized paths, and related features. Green streets. Green streets are systems of multiple BMPs arranged in a linear fashion within the street right-of-way (as opposed to a parcel -based implementation). Green streets are designed to reduce runoff and improve water quality of runoff from the roadway and adjacent parcels by replacing impervious surfaces with more porous ones, and directing stormwater to vegetated systems that can filter and infiltrate stormwater. Bioretention, biofiltration, and permeable pavement BMPs are commonly used in conjunction and can be hydraulically connected using subsurface stone reservoirs. The examples below show curb cuts that direct stormwater from the parking areas and roadways to a bioswale designed to collect, filter, and infiltrate stormwater. Anticipated Construction Activities: The installation of green street BMPs is similar to the construction activities that are summarized for the porous pavement and the LID -type distributed BMPs provided above as these include elements of both these types. These BMPs would typically require the permanent removal of aboveground infrastructure and/or surface materials such as asphalt and concrete for retrofit type projects and excavation and grading for projects on soil covered sites. Ground disturbance for green streets is typically less than 1 to 2 acres in extent, but may extend in some limited applications up to 5 acres where space is available and where these more linear projects extend to adjacent parcels. In areas proposed for biofiltration without suitably permeable soils, native soils will either have to be excavated, amended, and put back in place, or replaced entirely with biofiltration media (e.g. coarse gravels). The replacement of local soils would likely require that those soils then be hauled off-site. Systems with underdrains may require more extensive excavation and construction so that the underdrain can be connected to the MS4. The depth of excavation for these distributed systems will vary from several feet up to 6 feet depending on the thickness and number of filter and storage layers. Generally, excavation is limited to 4 feet below existing grade for these systems. • Infiltration BMPs. Infiltration BMPs capture and infiltrate runoff into unvegetated underlying soils. Runoff is typically stored in subsurface trenches or vaults filled with engineered soil media, gravel, or concrete chambers. There are multiple types of infiltration BMPs, including: dry/wet wells, which are gravel -surrounded vaults with perforated walls that receive runoff form a pipe and allow it to infiltrate into the ground, LA County Flood Control District 2-11 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. and infiltration trenches, which are media -filled trenches that capture runoff in pore space prior to infiltration. These following pictures illustrate these types of BMPs. f t Various DryWell Sizes(sourcc: vvww.peertesscnncre [e.com) Iniiltratlon Trench Infiltration Trench Anticipated Construction Activities: The ground disturbance footprint necessary to install infiltration BMPs can vary depending on the project's size and location. As illustrated above, infiltration trenches tend to be linear features and as such typically have relatively small footprints (less than 1 acre) unless they are very long (e.g., associated with transportation upgrades — roads, rail corridors, etc.). Subsurface excavation is typically required to replace native soils with highly porous infiltration media, vaults or other subsurface storage structures that will retain runoff and allow it to infiltrate into the subsurface. Larger underground storage and infiltration structures will require greater depths and volume of excavation. These types of infiltration BMPs may disturb larger (2 to 3 acres) areas. Larger systems are designed for multi -parcels and are characterized as centralized BMPs rather than distributed BMPs that are for one to two parcels. Depth of excavation of infiltration BMPs will depend on the storage requirements and depth to groundwater. Minimum separation distances of 10 feet to groundwater are typical. Excavation for these distributed type infiltration projects is generally 2 to 4 feet for infiltration trenches and 4 to 8 feet for vault and dry well systems. Dry/wet wells require deeper excavation but are more localized and smaller in footprint. • Biosivales. Bioswales are BMPs that convey storm flow through vegetated, shallow depressions to remove sediment -associated pollutants by settling and filtering mechanisms. Infiltration and filtration through soil media are not key components of bioswales; rather, bioswales are typically implemented to act as pretreatment and used to transport runoff to an associated bioretention cell or infiltration type of distributed BMP to provide additional pollutant removal and volume reduction. There are two primary types of bioswales: vegetated swales (which are linear), vegetated channels that convey concentrated flow to another structural BMP (detention, infiltration, storage), and vegetative filter strips (which are more broadly sloped than swales). LA County Flood Control District 2-12 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report Vegetated Swale Vegetative Filter Strip Bioswale Integrated with Community Park/Trail Anticipated Construction Activities: The construction of bioswales typically requires the removal and off -hauling of any impermeable surfaces within the bioswale footprint, and the regrading of site soils to facilitate drainage to the associated storage/infiltration BMP. Bioswales with more landscaping and natural contouring elements may have more complex grading. • Planter Boxes. Planter boxes are bioretention systems enclosed in concrete structures. They are most commonly designed to drain runoff from paved areas or roofs. They are typically used in urbanize settings where space constraints limit the implementation of other LID elements such as bioswales and biorentention systems. Planter boxes may be designed to both filter and store runoff using a series of filter media and aggregate layers below the vegetated layers. They can be used in combination with rain barrels and cisterns that store the runoff and then direct it these boxes to filter the runoff. Anticipated Construction Activities: Construction activities associated with planter boxes will be in most cases much less than other types of distributed BMPs as the footprint of these BMPs are generally smaller and integrated into the construction and design of existing buildings and structures. The space saving advantages limits construction disturbance. Planter boxes for retrofit projects are generally fabricated off-site and installed after the ground surface is graded and prepared for the planters. Soil, filter media, and aggregate are generally brought to the site and placed in the planter boxes per the design requirements. Some excavation may be performed if portions of the planters L County Flood Control District 2-13 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. are set below ground and connected to existing drainage pipes and MS4 through an underdrain system in the planter box. • Rainfall Harvest. Rainfall harvesting improves water quality by intercepting rooftop runoff and lowering the overall impervious impact of a developed site. Runoff can be reduced through interception and evapotranspiration on green roofs or used for alternative uses with a cistern or rain barrel. There are multiple kinds of rainfall harvest mechanisms; two of the more common are green roofs and cisterns/rain barrels. Green roofs are engineered, vegetated roof structures meant to intercept rainfall within a plant growth medium. Cisterns and rain barrels are storage tanks used to intercept and store rooftop runoff for nonpotable use such as landscape irrigation or gradual infiltration. Green Raof Cistern Anticipated Construction Activities: Similar to planter boxes, construction activities associated with green roofs and cisterns will be in most cases much less than other types of distributed BMPs as the footprint of these BMPs are generally smaller and integrated into the construction and design of existing buildings and structures. Construction activities associated with rainfall harvest systems tend to be minimal unless cisterns are placed underground, in which case subsurface excavation would be necessary. The depth and extent of excavation will depend on the size of the cisterns, but for single to several parcel distributed systems, the excavation will generally be limited to 4 to 6 feet and an area of less than an acre. • Flow -Through Treatment BMPs. Manufactured flow-through devices are commercial products that aim to provide stormwater treatment using patented, innovative technologies. Typical types of manufactured devices for stormwater management include cartridge/media filters and high-flow biotreatment devices. Cartridge/media filters are proprietary filtration devices used to remove pollutants; high-flow biotreatment devices are modular, vault -type practices that contain high-flow media and typically incorporate vegetation. LA County Flood Control District 2-14 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report Media/Cartridge filter High -Flow Bivtreat rnant(Pluyto Source: lonatlran Nae., HCSII-BRE) Curb Inlet Biofilter Anticipated Construction Activities: The construction activities necessary to install flow- through treatment BMPs can vary based on the location, size, and configuration of the BMP. These BMPs are generally installed as part of the MS4 within catch basins and curb inlets. Typically, flow-through BMPs have a relatively small footprint (< 1 ac) because they are designed to provide a higher rate of pollutant removal/transformation than less engineered approaches (e.g. infiltration trenches). Stormwater moves through most flow-through treatment BMPs via gravity flow. This may require expansion of existing catch basins or installation of new catch basin or vaults to intercept and direct storm flows to these treatment units and back into the MS4. This may then require limited subsurface excavation and off -hauling to create the below -grade space for the treatment device. The extent and volume of excavation is much less than LID, retention and Green Street projects. Source Control BMPs. Source control structural BMPs are commercial products designed to treat runoff in highly urbanized environments. Mechanical separation, or more complex physicochemical processes, provides separation of gross solids and other pollutants. Many models feature media or materials designed to sequester hydrocarbons and other pollutants. Two types of source control BMPs are illustrated below: catch basin inserts, which use nets, screens, fabric, or similar filtration media to separate sediment and gross solids from stormwater, and hydrodynamic separators, which use screens, baffles, or vertical flow to separate the two. L County Flood Control District 2-15 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. r c :ell— 4 Catch mein insert Hydrodynamic 5eparaMr Connactor pipe 5crean Anticipated Construction Activities: Similar to flow-through devices, the construction activities necessary to construct source control BMPs can vary based on the location, size, and configuration of the BMP, but are generally less than other types of distributed BMPs. Source control measures such as catch basin inserts and connector pipe screens are typically installed as retrofits to the existing MS4 within catch basins and curb inlets, and generally do not result in an increased ground disturbance footprint. Hydrodynamic separators may require expansion of existing catch basins or installation of new catch basins or vaults to intercept and direct storm flows to these treatment units and back into the MS4. This may then require limited subsurface excavation and off -hauling to create the below -grade space for the treatment device. The extent and volume of excavation is much less than LID, retention and Green Street projects, and is usually limited to less than one acre. Specific examples of distributed BMPs that are in various stages of planning and implementation and part of a possible EWMP are presented in Table 2-3. The locations of these examples of planned distributed BMPs are shown in Figure 2-2. Table 2-3 presents the locations, project description, and key elements of the distributed BMPs to further illustrate these types of structural BMPs that may be part of an EWMP. Additional information and figures on the location and distribution of potential and priority BMPs, where data is available, are presented in Section 2.5, EWMP Watershed Characteristics and BMP Implementation Strategies. LA County Flood Control District 2-16 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report TABLE 2-3 EXAMPLES OF PLANNED OR INSTALLED DISTRIBUTED BMP PROJECTS L County Flood Control District 2-17 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report Project Features c c o u rn m o d c_ d m ' o c m E m°. OZ 4;p d N N EWMP Group Project Name and Photo Status of Project Project Description in i K °u E m LL o` K Dominguez Phase IV Trash TMDL Implementation Installation of catch basin This project primarily proposes the installation of Catch basin (CB) opening screen covers and inserts Channel covers began the summer in those structures found in the Santa Monica Bay, Machado Lake, and Dominguez Channel of 2013. watersheds of the City of Los Angeles. The CB opening screen covers are coarse screens that are .�� installed in the CB openings and prevent trash from entering the storm drain system. Each CB opening screen cover has a self -opening device activated by a predetermined street gutter flow to disengage its locking mechanism. The CB inserts are perforated screens that are installed inside the CB in front of the outlet pipe of the catch basin. ,.A Malibu Creek Citywide Smart Irrigation Control System Unknown This project calls for the installation of a smart irrigation control system using evapotranspiration technology. This system would be put into place at all City of Calabasas -owned facilities, street medians, and parkways. This project will reduce irrigation run off and prevents pollutants from reaching the receiving waters. Replacement of irrigation controllers is projected to provide regional benefits by reducing urban runoff that is associated with nutrient loaded recycled water used for irrigation and will reduce discharges of other pollutants to the MS4 system carried by overwatering of y.. landscaped areas. The City uses 66,431 gallons of water on annual basis for landscape irrigation. It's anticipated that with the new system, the City will save between 13,300 to 16,600 gallons of water. It ♦ will translate to approximately 5,000 to 7,000 gallon of reduction in run-off. s L County Flood Control District 2-17 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report L County Flood Control District 2-18 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report Project Features C o u mo ° .� c d 0 c 4 m E d Z W V d N N C! a L Y N r O °u LL EWMP Group Project Name and Photo Status of Project Project Description tY y z tY 3 X m 3 Q. 3 W North Santa Wildlife Road Storm Drain Improvements Construction work on the This project is located within a developed residential neighborhood. Two existing storm drain inlets, Monica Bay _ _ Wildlife Road Storm Drain SD -1 and SD -2 are located on Whitesands Place and Wildlife Road in the City of Malibu. The Project Coastal. _:,fie Improvements project was consists of the installation of bioretention swales and biofilters within the City Right of Way, treating Watersheds r �•^�•^• scheduled to begin March stormwater and urban runoff prior to the entering of flows into City -owned catch basins. Due to the 2014 and continue through limited about of space within the City's Right of Way, the project will include a combination of .h August 2014. bioretention swales and biofilters. w Palos Verdes Model Equestrian Center Completion anticipated The Model Equestrian Center project will use the existing municipal Peter Weber Equestrian Center, a Peninsula -. ,1 June 2015 7.5 -acre facility that houses 116 horses, to create a public demonstration site for environmentally sustainable horse -keeping practices while improving the quality of stormwater and other runoff. This project will be divided into two parts. Part A of this project will involve retrofits of the existing equestrian facilities to improve drainage and stormwater runoff quality. These retrofits will include downspout redirection, drainage correction from existing horse stalls, bioswale or similar water quality treatment system installation, cover for daily manure storage, and drainage improvements to existing arenas and the overall site. Water quality will be improved by providing a permanent cover for daily manure storage, directing runoff away from areas where horses are kept, and bioswales will provide stormwater treatment by filtering large particles in the swale and removing smaller particles and associated contaminants through the bioretention portion provided by the vegetation. Part B of this ♦ ♦ project involves new construction. A new 15,000 -square -foot barn and associated improvements will "-_ be constructed on the 2.5 -acre northwest portion of the site. Key water quality features will include a covered horse wash area with wash water captured and reused for subsurface irrigation to maintain appearance of habitat buffers and treatment bioswales, manure management to control vectors, odors and runoff, and a cistern or rain barrels to collect rainfall from the barn roof for use in irrigation. In addition, the facility will use low -impact development (LID) and green building techniques, integrated pest management through structural design, and equine -safe native and drought -proof plant buffers. Interpretive signage will demonstrate and educate the equestrian community on how the BMPs protect and improve stormwater quality. This signage will be installed to educate horse boarders and visitors on the specific BMPs integrated into the facilities and on the site. Upper LA River Brandon Street and Green Street Improvements Project Construction Spring 2014 The project will reconstruct approximately 0.16 miles of roadway on Green Street and 0.39 miles on to Fall 2014 Brandon Street. The design includes several green street elements including permeable pavers, bio - retention planters, sediment filtration catch basins, and an underground infiltration basin. Much of the M. runoff from the streets and private properties that would have otherwise drained to the Rio Hondo will be directed to the infiltration area. L County Flood Control District 2-18 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report L County Flood Control District 2-19 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report Project Features C o u O mo ° .� c d a'a$ 0 c 4 m E d i= d N N C! a L Y N r O EWMP Group Project Name and Photo Status of Project Project Description �n z 3 °u X m 3 LL Q. 3 W Upper San Avocado Heights Multiuse Trail Project Constructed The project will construct multiuse trails to provide a safer route to equestrian, bicycle, and pedestrian Gabriel River users away from existing traffic hazards. The majority of the existing roadway width will be reduced from 40 to 36 feet, thereby reducing the amount of impermeable surfaces as well as runoff. Approximately 2,300 feet of the multiuse trail on 5th Avenue will be constructed with decomposed granite to provide 14,000 cubic feet of infiltration capacity. In addition, an infiltration swale will be constructed at the end of 5th Avenue immediately adjacent to San Jose Creek to provide 3,200 cubic - , feet of rapacity. Combined together, up to 115 acre-feet of groundwater will be recharged annually. Upper Santa Trash removal BMPs Planned Implementation Trash removal BMPs for 79 storm drains in a commercial/industrial park (County of LA) and 110 storm Clara River i=-- Date July 2015 drain inlets in a commercial/industrial park (City of Santa Clarita). _ y a I L County Flood Control District 2-19 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report 2. This page left intentionally blank LA County Flood Control District 2-20 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program EmAronmental Impact Report Ventura LJ 0 Participating Permittees EWMP Boundaries 1 - Ballon Creek - 2 - Beach Cities - 3 - Dominguez Channel 4 - Malibu Creek 5 - Marina Del Rey - 6 - North Santa Monica Bay - 7 - Palos Verdes Peninsula 8 - Rio Hondo/San Gabriel River 9 - Santa Monica Bay Jurisdictions 2+3 - 10 - Upper LA River - 11 - Upper San Gabriel River - 12 - Upper Santa Clara River SOURCE: ESRI. Los Angeles 0 San Bernardino 0 � ® rl � L` f� � ®6 I A Orange o T s Miles LA County PER EWMP. 140474 Figure 2-2 Location of Example Planned and Installed Distributed BMP Projects Example of Planned and Installed Distributed BMPs Kern O Phase IV Trash TMDL Implementation ® Citywide Smart rogation Control System ® Wiildlifs Road Storm Drain Improvements ® Model Equestrian Center ® Brandon Street and Green Street Improvements Project ® Avocado Heights Mulh-Use Trall Project ® Trash Removal BMPs LJ 0 Participating Permittees EWMP Boundaries 1 - Ballon Creek - 2 - Beach Cities - 3 - Dominguez Channel 4 - Malibu Creek 5 - Marina Del Rey - 6 - North Santa Monica Bay - 7 - Palos Verdes Peninsula 8 - Rio Hondo/San Gabriel River 9 - Santa Monica Bay Jurisdictions 2+3 - 10 - Upper LA River - 11 - Upper San Gabriel River - 12 - Upper Santa Clara River SOURCE: ESRI. Los Angeles 0 San Bernardino 0 � ® rl � L` f� � ®6 I A Orange o T s Miles LA County PER EWMP. 140474 Figure 2-2 Location of Example Planned and Installed Distributed BMP Projects 2. 2.4.4 Centralized Structural BMPs Centralized structural BMPs use similar elements to the LID, infiltration and biofiltration type BMP used in distributed structural BMPs, but collect, store, treat and filter stormwater from multiple parcels and much larger drainage areas. Centralized BMPs also include diversion and treatment type BMPs that use similar technologies for these types of BMPs under distributed BMPs, but can be implemented on a much larger scale collecting, diverting and treating urban runoff (dry -weather flows) or limited stormwater flows from multiple parcels and large drainage areas. Therefore, centralized structural BMPs require greater footprints for construction and implementation, but provide a greater potential for water quality improvement through the filtering, treatment and/or infiltration of greater volume and rates of stormwater and urban runoff. Centralized BMPs that include storage and infiltration or storage and use have similar functions and construction methods to regional BMPs using the same stormwater management elements. However, regional BMPs have the distinct requirement per the Permit to retain on-site the 85th percentile 24-hour storm event for the drainage area served by the BMP (i.e., in the Los Angeles area, the 85th percentile storm is around 0.75 inch of rain in a 24-hour period). Finally, centralized BMPs include two unique BMP types, treatment wetlands and stream/creek restoration projects. Unlike the other structural BMP types described, these BMPs use natural systems to filter and clean the water. Treatment wetlands are typically off-line treatment systems that are not in the receiving waters, but may have habitat benefits through the establishment of more native plants and ecosystems. Creek, river, and estuary restoration projects provide a unique opportunity to restore natural cleansing processes, reestablish habitats and address impacts from hydromodification and urban runoff. These projects are the only BMPs that are implemented within the receiving water. Types of centralized structural BMPs and the definitions for these BMPs (which were taken from Los Angeles Department of Public Works' "Structural Fact Sheets") include the following: • Infiltration BMPs. Infiltration facilities are designed to decrease runoff volume through groundwater recharge and improve water quality through filtration and sorption. Facilities can incorporate engineered media to improve percolation into native soils. Infiltration facilities can be open -surface basins or subsurface galleries (see the following photographs). Surface infiltration basins can be vegetated to encourage evapotranspiration and aesthetics; subsurface infiltration galleries are often used when limited land is available for BMP implementation. An example of a centralized infiltration BMP is the infiltration gallery that was installed as part of the Elmer Avenue Neighborhood Retrofit Project in Los Angeles. The project includes two infiltration galleries capable of infiltrating over 1,300 gallons a minute from a 40 -acre drainage area (CWH 2014). Catch basins divert stormwater to the infiltration galleries, while bioswales capture and treat additional urban runoff. LA County Flood Control District 2-22 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report Anticipated Construction Activities: Centralized infiltration facilities are generally larger than distributed BMPs and can vary from 2 to 10 acres in size, depending on the number of parcels (drainage area). Subsurface excavation is typically required to replace native soils with highly porous infiltration media, vaults or other subsurface storage structures that will retain runoff and allow it to infiltrate into the subsurface. Larger underground storage and infiltration structures will require greater depths and volume of excavation. Depth of excavation of infiltration BMPs will depend on the storage requirements and depth to groundwater. Minimum separation distances of 10 feet to groundwater are typical. Excavation for these centralized infiltration project is generally 2 to 6 feet for surface infiltration and 4 to 10 feet for vault or infiltration gallery systems. Excavated soils must also be off -hauled unless the site is of an adequate size to allow balancing of cut and fill on-site. Subsurface infiltration galleries require that subsurface soils be excavated and replaced with highly permeable structures that rapidly infiltrate stormwater. These structures are typically transported to the site on flatbed trucks and then lowered into the ground using specialized cranes and related equipment. Subsurface infiltration galleries also require pretreatment facilities to remove sediment and debris prior to entering the galleries or vaults to reduce the potential for clogging. These systems increase the project footprint and required excavation by 25 to 50 percent of the vault footprint. Capture and Use BMPs. Capture and use BMPs capture stormwater runoff and store it for later use, typically as irrigation water. An example of a centralized capture and use BMP is the cistern at the Tuxford Green Project in Los Angeles. The cistern can hold up to 45,000 gallons of treated stormwater, which is then used to irrigate native landscaping. Anticipated Construction Activities: The construction activities for these BMPs are similar to those summarized for the infiltration galleries above with the exception that these galleries and vaults are designed to retain and reuse (not infiltrate) the stormwater. In addition to the anticipated ground surface disturbance and excavation for the installation of the underground storage units, these systems also require a pre- and post- treatment system that generally consist of additional and more sophisticated treatment steps and thereby a larger footprint. In addition, these systems need to be connected to a distribution system for the treated water that can be used for irrigation or for grey water or groundwater recharge systems. This additional infrastructure will require additional construction grading, excavation, and transportation of materials and equipment on--- and off-site. LA County Flood Control District 2-23 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. • Bioinfiltration BMPs. Centralized bioinfiltration BMPs are a larger -scale version of their distributed counterpart, and typically incorporate elements of both infiltration (using native soils or underdrains) and treatment (using vegetated swales or filter strips). Anticipated Construction Activities: Bioretention and biofiltration BMPs typically require the permanent removal of aboveground infrastructure and/or surface materials such as asphalt and concrete for retrofit type projects and excavation and grading for projects on soil covered sites. Ground disturbance for bioinfiltration centralized BMPs is typically 2 to 5 acres in extent, but may extend in some limited applications up to 10 acres where space is available. The extent of land disturbance depends on the type of BMP and may be more linear for bioswales and filter strips, compared to larger continuous areas for bioretention cells that store and then filter or infiltrate stormwater. In areas proposed for biofiltration without suitably permeable soils, native soils will either have to be excavated, amended, and put back in place, or replaced entirely with biofiltration media (e.g., coarse gravels). The replacement of local soils would likely require that those soils then be hauled off-site. Systems with underdrains may require more extensive excavation and construction so that the underdrain can be connected to the MS4. The depth of excavation for these distributed systems will vary from several feet to up to 10 feet depending on the thickness and number of filter and storage layers. Generally, excavation is limited to 4 to 6 feet below existing grade for these systems. • Detention BMPs. Centralized detention facilities are designed to detain runoff and improve water quality through pollutant settling. Facilities encourage settling by decreasing runoff flow rates and allowing ponding to occur. Detention facilities can be open -surface practices or subsurface galleries and can be dry during non -rainy seasons or wet year-round. Surface detention basins are designed to detain stormwater runoff for a specified amount of time so that particle -bound pollutants can settle. Subsurface detention galleries are underground storage systems designed to detain water in areas where limited land is available for BMP implementation. Surface Detention Basin t Anticipated Construction Activities: Centralized detention facilities can range from between an acre to 5 acres in size, and up to 10 acres. Surface detention basins require the removal and off -hauling of surface armoring and infrastructure, as well as the excavation of adequate soil to create the target storage volume. Excavated soils may either be balanced on-site or hauled off-site; the latter is more likely in most cases due to the larger size of centralized basins. Surface detention basins may in some cases be utilized as recreational facilities during the dry season, allowing for the installation of features such LA County Flood Cenral District 2-24 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report as athletic fields and benches. Subsurface detention galleries require the excavation of native soils and their replacement with engineered structures that detain water underground. The construction and installation of these structures can be complex and require the use of specialized cranes and related construction equipment. • Treatment Facilities and Low -Flow Diversions. Other centralized water quality technology falls into the low flow diversion (LFD) and treatment facilities subcategories. LFDs reduce stormwater pollution by diverting a design flow rate to a sanitary sewer for treatment. Treatment facilities convey stormwater through a physical, chemical, or radiological treatment system before returning it to the original channel, or diverting it for beneficial reuse. Below are photographs of an example LFD. LFDs may include on-site treatment of the diversion low flows prior to discharge back into the storm drain, or diversion to a local wastewater treatment plant. The LFD that has been installed at Marie Canyon in Malibu, shown in the photographs below, has an on-site treatment facility to reduce indicator bacteria concentrations prior to discharge back into the storm drain. This LFD is designed to filter and treat as much as 100 gallons per minute of dry -weather flows (Los Angeles Department of Public Works, 2007). Treatment Facility Inlet in a Storm Drain Marie Canyon Low -Flow Diversion — Flat Gate Diverting flow to treatment unit for bacteria Anticipated Construction Activities: Low -flow diversions and treatment facilities usually have a relatively small footprint of less than 2 acres. Construction typically requires subsurface excavation and off -haul of excavated soils in order to create adequate room for the subsurface engineered structures. The installation of these BMPs can often be complex due to the need to retrofit existing stormwater infrastructure and, in the case of LFDs, connect to active wastewater treatment infrastructure. L County Flood Control District 2-25 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. Constructed Wetlands. Constructed wetlands are engineered, shallow -marsh systems designed to control and treat stormwater runoff. Particle -bound pollutants are removed through settling, and other pollutants are removed through adsorption and biogeochemical transformation. Constructed wetlands must always maintain a baseflow into the system, which can come from an intersected groundwater or an associated LFD using dry -weather flows. There are two primary types of constructed treatment wetlands: wetland basins, which have shallow permanent pools and outlet structures that regulate dewatering, and flow-through linear wetlands, which are typically constructed parallel to existing channels so water can be easily diverted in/out of the wetland. An example of a treatment wetland includes the South LA Wetland Park, which will use an approximately 4.5 -acre constructed wetland to treat a portion of the runoff from a 525 -acre tributary watershed. Wetland Basin Flow-Through/Linear Wetland Anticipated Construction Activities: Due to their multi -benefit nature and their ability to provide significant habitat benefits (most wetlands within the Los Angeles Basin have been lost to development and urbanization), most constructed wetland projects are greater than 5 acres in size and may be up to 10 acres or larger. Typical constructed wetland projects require extensive grading of site soils, though excavated soils are often balanced on-site to provide material for levees, berms, ecotones, and other flood control/habitat features. Many constructed wetland projects require the construction/installation of water control structures such as screw gates and culverts to manage how water is directed into, out of, and through the wetland. Constructed wetlands are often actively planted to accelerate the establishment of mature wetland vegetation and resultant stormwater treatment. • Creek/River/Floodplain/Estuary Restoration. This category includes multi -benefit projects that typically combine elements of habitat restoration for fish and wildlife as well as flood management and water quality improvement. Project components such as setback levees, floodplain bench excavation, levee breaches, and other actions can increase the flood storage capacity of a water body and thereby slow flow rates. An example of a multi -benefit creek restoration project is the Tujunga Wash Greenway and Stream Restoration Project in Los Angeles. This project restored 1.2 miles of natural - bottomed creek habitats, which are capable of infiltrating up to 118 million gallons of stormwater form the wash into the local groundwater aquifer. Plants in the wash also aid the biogeochemical removal of pollutants such as nitrogen. LA County Flood Control District 2-26 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report Before and After — Tujunga Wash Greenway Restoration Project Anticipated Construction Activities: These projects may require ground disturbance and construction to convert lined flood channels into more naturalized creek/river systems. Projects are typically greater than 5 acres in size, and many have footprints of over 10 acres. This category of BMP may require removal and off -hauling of concrete and asphalt, grading/excavation/off-hauling of site soils (particularly if contaminants are present, since they could pose a threat to the health of fish and wildlife), the construction of elements such as setback levees and water control structures, and active revegetation with native plants. Projects that aim to enhance habitats within more naturalized settings (e.g., floodplain expansion along an unarmored/channelized creek) would have to account for the potential for construction to disturb existing natural communities, and incorporate appropriate impact avoidance/minimization/mitigation measures, though most projects are designed to be self -mitigating. • Multi -benefit flood management projects. This category includes a broad range of redevelopment, transit, transportation improvement, and related projects that are designed to result in direct or indirect benefits to flood management. For example, greenway projects such as the Tujunga Wash Greenway project that incorporates infiltration and/or detention elements can improve flood management by reducing stormwater flow rates and/or volumes. Construction Impacts. Multi -benefit flood management projects are typically expansive projects that range from a few to tens of acres in size. Construction requirements can vary extensively based on the nature of the project. Because of their scale, multi -benefit flood L County Flood Control District 2-27 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. management projects usually require extensive excavation and grading of site soils, off -hauling of soils and related materials, utility relocation, infrastructure construction, and related activities. It is not uncommon for these types of projects to be constructed over multiple construction seasons. Specific examples of centralized BMPs that are in various stages of planning and implementation and are part of the EWMP are presented in Table 2-4. The locations of these examples of planned and implemented centralized BMP are shown in Figure 2-3. Table 2-4 presents the location, project description and key elements of the centralized BMPs to further illustrate these types of structural BMPs that are part of the EWMP. Additional information and figures on the location and distribution of potential and priority BMPs, where data is available, are presented in Section 2.5, EWMP Watershed Characteristics and BMP Implementation Strategies. LA County Flood Control District 2-28 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report TABLE 2-4 EXAMPLES OF PLANNED CENTRALIZED BMP PROJECTS L County Flood Control District 2-29 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report Project Features C 0 C O c m r u c m o ° m a'c� 0 0 E 0. a t Y m .�. O y y y CN 0 N m a C V m d u EWMP Group Project Name and Photo Status of Project Project Description d w z O in m a x x 3 ou z a E `m m _°o LL a 3 X Ballona Phase II of the Mar Vista Recreation Center Stormwater BMP Phase II is expected to be The Phase II project components are expected remove 6,000 gallons per day (5.5 acre-ft/year) of Creek Project completed by December stormwater and provide additional storage space for the underground cisterns that were constructed 2014. during Phase I. Phase I facilities include : 1) storm drain diversion structure; 2) trash maintenance hole; 3) stormwater lift station; 4) hydrodynamic separator; 5) 270,000 -gallon underground detention tank; 6) disinfection facility; 7) overflow/return piping; and 8) pump and control systems. Phase I was _ completed and is operational at limited capacity. Phase 11 includes the following slormwater beneficial reuse components: • Stormwater drip irrigation system for 43 shrubs, 86 bushes, and 68 trees ..�0 Installation of an irrigation pump station and associated components • Creation of 3,800 square feet of plant community ♦ ♦ ♦ ♦ ♦ Installation of back-flow prevention system Construction of flow containment curbs The objective of Phase 11 is to include an irrigation system to beneficially use the treated water at the —� park, to increase the treatment capacity of the facility and associated pollutant load reductions and to conduct a facility optimization project to fine-tune the grey and green infrastructure components of the project and optimize overall performance of the facility. Beach Cities Manhattan Beach Greenbelt Infiltration System The project construction The Manhattan Beach Greenbelt Infiltration project was designed to utilize the linear greenbelt parkland WMG was completed February which runs through the City of Manhattan Beach to intercept and infiltrate dry -weather and wet -weather I 19, 2013. low flows from existing storm drains that cross or abut the parkway. Low flows from a 50 -acre drainage area are screened to remove trash and gross solids before flowing by gravity to a subsurface infiltration system which also provides limited storage of storm flows for subsequent percolation into the sandy soils below the greenbelt. The Greenbelt Low Flow Infiltration system was designed to effectively divert dry - weather and wet -weather low flows from the storm drain system year round. L County Flood Control District 2-29 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report IA County Flood Control District 2-30 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report Project Features c 0 = C u t o o to 1° 0 dmw� mm a = a d d w N N A 0 d a G V E N 0 d y EWMP Group Project Name and Photo Status of Project Project Description F 2 y 2 K 3 u 0: m m 3 LL 3 2 Marina Del Oxford Basin Multi -Use Enhancement Project LACFCD anticipates the The project involves removing approximately 3,000 cubic yards of accumulated contaminated sediment Rey project to commence from the bottom of Oxford Basin, constructing a berm in the center of Oxford Basin to enhance water construction by the end of quality through circulation, planting new native or drought -resistant plants, and installing new bioswales. this year or early 2015. The proposed berm that will be installed to improve circulation, in conjunction with the reprogramming of the operating cycles of the existing tide gates, will maximize the circulation of the water around the berm f��.y during the daily tidal cycles. During a rising tide, the water will enter via one of the tide gates on one side M ,,. >u of the new berm, circulate around Oxford Basin, and then exit via a second tide gate during a falling tide. °� ` r' This innovative approach to improving water quality through circulation will increase dissolved -oxygen f levels in the water within Oxford Basin, which is expected to result in less algae growth, lower bacteria (�+�J.r• levels, and reduction of unpleasant odors. The proposed project will also implement Low -Impact Development features to reduce the impacts of the existing roads adjacent to Oxford Basin. The project's . . _ Low -Impact Development features include a bioswale along the bike path at Washington Boulevard to ., collect surface runoff and two bioretention systems along Admiralty Way to collect local runoff from the - roadway. The project will also enhance recreational opportunities for visitors through the installation of •' -:, observation areas and decks, interpretive signage, a lighted walking/jogging path, and fencing that will - - - provide enhanced viewing of the improved habitat. , Malibu Creek Lindero Parkway Improvements Construction of the The project is part of an overall City of Westlake Village streetscape improvement project that creates proposed improvements is infiltration and urban pollutant mitigation opportunities along all arterial medians and parkways. This expected to commence parkway project is 30 foot wide by over a mile long. Half of this parkway was originally a flood control either Spring 2015 or early maintenance road and the other half a landscaped area. This project will have a Riparian Zone theme. Summer 2015. With the new project, the combined width of the old maintenance road and landscaped area, this area will become a new walking path where there is currently no sidewalk. This project, when completed, will provide a long and meandering walking path with conversation seating areas. This project will also include drainage facilities that will include specific BMP's. The newly renovated area will be drained via bio-swales throughout the entire length of the project. These swales will meander thru the entire length with the main goal of percolation and evaporation of all nuisance flows throughout the year. Stormwater 6 6 6 6 6 runoff would then be treated in the bio-swale followed by discharge into Westlake Lake. This project will also have educational signage on a riparian zone and the stormwater cleanup objectives of this project. _ Ot��O. . Y..0.== -.. IA County Flood Control District 2-30 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report IA County Flood Control District 2-31 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report Project Features U r L O U G d o C O is d O 0. a E L r IL �+ O d N N 0 N N tl -O N d O mm m0yac-o Tb o m EWMP Group Project Name and Photo Status of Project Project Description � E %n x X 3 °u o: m a 3 LL 3 s North Santa Broad Beach Biofiltration Project January 2014 The Project consists of the installation of different types of biofilters at nine catch basins within the City of Monica Bay Coastal (Commencement of Construction) Malibu Right of Way, treating slormwater and urban runoff prior to the entering of flows into City -owned catch basins, which discharge to owned storm drain systems. The Project includes a _ T� privately Watersheds -_ R d 4 -. - June 2014 (Completion) combination of bioflters, and flow control, with potential to incorporate harvest and use systems for Malibu drains. Three types of bioflters are contemplated; small footprint biofilters, biofilters with volume control, and harvest and use systems. Palos Verdes San Ramon Canyon Stormwater Flood Reduction Project Anticipated to be The San Ramon Canyon provides a natural drainage course for areas near Palos Verdes Drive East. Peninsula.;. a. completed June 2015. Because of the geographical characteristics of the San Ramon Canyon, landslide induced rock and soil deposits in the canyon bottom are transported during heavy rainfall events. This creates flooding of the roadway, overwhelming existing drainage facilities, endangering nearby roadway integrity and threatening downstream residents. The San Ramon Canyon Stormwater Flood Reduction Project, rridor for canyon involves significant drainage restoration work to stabilize Palos Verdes Drive East and Palos Verdes Drive South. Install sub -drainage pipe - Fill the Canyon bottom to form pipe bedding Rio Honda - Monrovia Station SquarelTransit Village Multi -Benefit Park and Planned Implementation This project will include design and development of a 2.5 -acre multi -benefit green space along the future San Gabriel Greenway Project Date Spring 2015. Metro Gold Line Foothill Extension. The project includes a multi -use trail, native trees and shrubs, runoff River storage and infiltration systems prior to discharging into Sawpit Wash and Peck Road Water Conservation Park to the south. �r 2 ... M.+q.u... tmmut rr.e Pr.. aP.a *Public aPx. M1..er1e b•, IA County Flood Control District 2-31 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report L County Flood Control District 2-32 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report Project Features = O d r L O U G d o C is L 6r d O O E tl a O d N N 0 N N 'O N d O m m m 0 y °u a c a Ta o m EWMP Group Project Name and Photo Status of Project Project Description o:E y x X 3 o: m a 3 LL 3 s Rio Honda - Metro Gold Line Infiltration Project Planned Implementation The City of Azusa in coordination with the Foothill Construction Authority forthe Gold Line Project has San Gabriel Dale Spring 2016. constructed infiltration systems at some of the major crossings in town. Infiltration will occur at the catch River basins which are soft bottom. Anticipated tributary areas are approximately 17 acres and will include the rail corridor. The 10 year storm event is to be infiltrated. ♦ ♦ ♦ Santa Penmar Water Quality Improvement Project (Phase I and Phase Phase II - expected Phase II of the Penmar project is expected to supply approximately 34.7 million gallons of treated water Monica Bay II) completion by Spring 2015. per year for irrigation of Penmar Golf Course and the Penmar Park & Recreation Center in the City of Jurisdictions - Los Angeles and the Marine Park in the City of Santa Monica. Replacing this volume of potable water 2 and 3 with treated storm water produced in Phase II provides 34.7 million gallons per year increase to annual runoff diversion capacity of Phase 1, resulting in a significant pollutant load reduction into the Santa Monica Bay. Phase II entails the incorporation of the reuse component of the project offering additional water quality benefits as well as multi-regional benefits. By installing the reuse option, the overall project capacity will increase, thereby also increasing the volume of urban runoff that can be retained by the project for use as an alternative source of water to potable water for landscape irrigation. t.s ' ..._ Upper LA Humboldt Greenway Project Under Construction This project will intercept an existing storm drain system and construct a stormwater greenway with a River "stream" eco -system through the corridor on Humboldt Street with a pedestrian path connecting Avenue ? 18 and Avenue 19. The project is adjacent to the Los Angeles River, just north of Civic Center area of the City of Los Angeles. The bioremediation elements include a pollution reduction/infiltration system and ,,, an approximately 175 -foot -long graded swale/open-channel, which is surrounded by a vegetated basin. y.` ! - "' Work also includes a) an overflow structure; b) a pedestrian bridge; c) an irrigation system; _...� *� d) landscaping and tree planting; and e) solar lighting. L County Flood Control District 2-32 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report C Ventura 0 Participating Permittees EWMP Boundaries 1 - Ballon Creek - 2 - Beach Cities - 3 - Dominguez Channel IIIII� 4 - Malibu Creek IIIII� 5 - Marina Del Rey - 6 - North Santa Monica Bay - 7 - Palos Verdes Peninsula 8 - Rio Hondo/San Gabriel River 9 - Santa Monica Bay Jurisdictions 2+3 - 10 - Upper IA River - 11 - Upper San Gabriel River - 12 - Upper Santa Clara River SOURCE: ESRI. Los Angeles n � 0 m J ® l r-- rr r r I r' t` ® J San Bernardino Orange o T a I Miles LA County PER EWMP. 140474 Figure 2-3 Location of Example Planned and Installed Centralized BMP Projects Example Centralized BMPs 0 Phase II of the Mar Vista Recreation Center Stonnwater BMP Project K e r n ® Manhattan Beach Greenbelt Infiltration System ® Oxford Basin Multi -Use Enhancement Project 0 Lindero Parkway Improvements © Broad Beach Biofiltration Project 0 San Ramon Canyon Str nnwater Flood Reduction Project 0 Monrovia Station Square/Ransit Village Multi -Benefit Park and Greenway Project 0 Metro Gold Line Infiltration Project © Penmar Water Quality Improvement Project (Phase I and Phase 11) 0 Humboldt Greenway Project C Ventura 0 Participating Permittees EWMP Boundaries 1 - Ballon Creek - 2 - Beach Cities - 3 - Dominguez Channel IIIII� 4 - Malibu Creek IIIII� 5 - Marina Del Rey - 6 - North Santa Monica Bay - 7 - Palos Verdes Peninsula 8 - Rio Hondo/San Gabriel River 9 - Santa Monica Bay Jurisdictions 2+3 - 10 - Upper IA River - 11 - Upper San Gabriel River - 12 - Upper Santa Clara River SOURCE: ESRI. Los Angeles n � 0 m J ® l r-- rr r r I r' t` ® J San Bernardino Orange o T a I Miles LA County PER EWMP. 140474 Figure 2-3 Location of Example Planned and Installed Centralized BMP Projects 2. 2,4,5 Regional Structural BMPs Regional structural BMPs are those that can capture the volume of water from an 85th percentile, 24 -hr storm in a contributing watershed, known as the design volume (Generally, the 85th percentile storm is approximately 0.75 inches over 24 hours). The two types of regional BMPs are retention/infiltration and capture and use, though many regional projects would incorporate more than one BMP type. The definitions of these BMPs are the same as for centralized BMPs with the exception that they can capture the design volume. Like centralized BMPs, regional BMPs can be implemented in a broad range of land use types, from high-density urban to open space, and can have multiple benefits (e.g. habitat, recreation, aesthetics). An additional example of a multi-benefit/multi-type regional BMP is the suite of improvements being made to Sun Valley Park in Los Angeles. The project's BMPs improve stonnwater quality and alleviate local flooding by collecting runoff from a 21 -acre drainage area, routing it through flow-through treatment units (hydrodynamic separators and settling units) to remove suspended solids and heavy metals, and directing it into two underground infiltration galleries buried beneath soccer and baseball fields. Bioswales at the site treat local runoff and are vegetated with native plants. Sun Valley Park Regional Infiltration Project — (from upper left to lower right) Storm water Pre -Treatment Devices to Remove Trash and Sediment / r- Bioswale and Bioretention Area / Construction of Underground Storage and Infiltration Vaults Anticipated Construction Activities: The construction activities for regional BMPs are generally similar to those of their centralized counterparts, with the exception of regional retention BMPs, which must have adequate storage capacity to hold runoff from the design storm. The need for this capacity will generally result in more extensive excavation and off -hauling of site soils. Larger, multi -benefit regional BMPs are similar to centralized multi -benefit regional flood management projects (above) that their scale and complexity often requires an intensive construction effort executed over multiple seasons. L County Flood Control District 2-34 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report Specific examples of regional BMPs that are in various stages of planning that are part of the EWMP are presented in Table 2-5. The locations of these examples of regional BMPs are shown in Figure 2-5. Table 2-5 presents the location, project description, and key elements of the regional BMPs to further illustrate these types of structural BMPs that are concepts being developed through the EWMP process. Additional information and figures on the location and distribution of potential and priority BMPs, where data is available, are presented in Section 2.5, EWMP Watershed Characteristics and BMP Implementation Strategies. LA County Flood Control District 2-35 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. This page left intentionally blank LA County Flood Control District 2-36 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report TABLE 2-5 EXAMPLE OF PLANNED REGIONAL PROJECTS IA County Flood Control District 2-37 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report Project Features c 0 o m c a - m o d N O Z u d N N o N d v t - d 0 0 o a d m m y 6 C m d0 a d EWMP Group Project Name and Photo Status of Project Project Description x w x m 3 LL 3 x Beach Cities Torrance Stormwater Basin Recharge and Enhancement Construction was The Torrance Stormwater Basin Recharge and Enhancement Project will retrofit three existing WMG Project scheduled for Spring detention basins serving 1,453 acres of drainage area in total within the City of Torrance. The project 2014. will use a number of BMPs to conserve water, recharge the aquifer, create critical habitat, and improve stormwater quality that discharges into the Santa Monica Bay, and eliminate non- stormwater discharges to the Dominguez Channel. This Stormwater Basin Recharge and Enhancement project proposes significant advances over the current system by providing wetland - treatment of stormwater and non-stormwater runoff at the detention basins, recharging vitally needed groundwater supplies, and sustaining wetland habitat during the dry season in the basins. The Project will eliminate dry -weather runoff and associated load for multiple pollutants. The Project will treat all stormwater from 1,453 acres for multiple pollutants, including priority pollutants such as trash ♦ . . . and sediments by a combination of wetland treatment and infiltration. The project will capture and recharge an estimated 20 acre feet per year of runoff that would have otherwise been discharged to the Santa Monica Bay. The project will enable the elimination of all discharges from the drainage area to Dominguez Channel, will eliminate dry -weather discharges to Santa Monica Bay and will reduce the wet -weather discharge to the Santa Monica Bay from this system. North Santa Malibu Legacy Park Pump Station Improvements Anticipated to be Malibu Legacy Park is a regional project that provides water quality and water resources benefits. Monica Bay completed June 2015. The project exceeds requirements to put over 300 acres of Malibu (including City Hall) into full Coastal compliance with Malibu Creek Bacteria TMDL requirements, providing a capture volume consistent Watersheds z with Los Angeles Standard Urban Stormwater Mitigation Plan requirements (assuming no upstream 1 ?+ LID or source control measures). Captured water is managed, disinfected, and used to offset potable water uses for park irrigation. t- �y -!ry IA County Flood Control District 2-37 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program EmAronmental Impact Report 2. This page left intentionally blank LA County Flood Control District 2-38 ESA 1140474 Enhanced Watershed Management Programs January2015 Draft Program EmAronmental Impact Report C Ventura 0 Participating Permittees EWMP Boundaries 1 - Ballon Creek - 2 - Beach Cities - 3 - Dominguez Channel 4 - Malibu Creek 5 - Marina Del Rey - 6 - North Santa Monica Bay - 7 - Palos Verdes Peninsula 8 - Rio Hondo/San Gabriel River 9 - Santa Monim Bay Jurisdictions 2+3 - 10 - Upper LA River - 11 - Upper San Gabriel River - 12 - Upper Santa Clara River SOURCE: ESRI. Los Angeles 0 ...��y 91 AIL `\ s O bIr — — \ rS' rr ® Q J '(U i J San Bernardino Orange o � a I I Miles LA County PEIR EWMP. 140474 Figure 2-4 Location of Example Planned and Installed Regional BMP Projects Example Regional BMPs ® Torrance Stormwater Basin Recharge and Enhancement Project- Entradero Basin Kern ® Torrance Stormwater Basin Recharge and Enhancement Project - Amis Basin Q Torrance Stormwater Basin Recharge and Enhancement Project - Henrietta Basin © Malibu Legacy Park Pump Station Improvements C Ventura 0 Participating Permittees EWMP Boundaries 1 - Ballon Creek - 2 - Beach Cities - 3 - Dominguez Channel 4 - Malibu Creek 5 - Marina Del Rey - 6 - North Santa Monica Bay - 7 - Palos Verdes Peninsula 8 - Rio Hondo/San Gabriel River 9 - Santa Monim Bay Jurisdictions 2+3 - 10 - Upper LA River - 11 - Upper San Gabriel River - 12 - Upper Santa Clara River SOURCE: ESRI. Los Angeles 0 ...��y 91 AIL `\ s O bIr — — \ rS' rr ® Q J '(U i J San Bernardino Orange o � a I I Miles LA County PEIR EWMP. 140474 Figure 2-4 Location of Example Planned and Installed Regional BMP Projects 2. 2.5 EWMP Watershed Characteristics and EMP Implementation Strategies Summarized below are the general characteristics of the watersheds within the EWMP Groups and the overall strategies for BMP implementation that reflect these characteristics. The twelve EWMPs are consolidated to six watershed areas grouped by similar watershed characteristics. This summary provides additional detail on the distribution and location of potential and priority BMPs, where data is available, based on the overall BMP implementation strategy and maps of BMP distribution. These maps are presented for each EWMP and show the location and distribution of planned and priority regional/centralized BMPs for which data are available at the time of publication of this PEIR. The priority BMPs are a subset of the potential BMPs that have undergone a site review and project evaluation that has identified these BMPs as a priority. These priority projects are shown based upon available data at the time of publication of this PEIR. Appendix G provides the location and general description of the priority BMPs shown on the figures referenced in this discussion. Distributed BMPs are planned to be implemented throughout the urbanized areas of each EWMP. 1. South Santa Monica Bay EWMP Watersheds (Marina del Rey, Ballona Creek, Beach Cites, South Santa Monica Bay Jurisdictional Group 2 and 3, and Peninsula Cities EWMP groups) — These watershed groups are dominated by urbanized beach communities with high density residential and commercial land uses throughout the watershed. Key BMP strategies in these watersheds are to address dry and wet -weather flows that may impact beach water quality through bacteria loading. Other water quality priorities include trash, marine debris, metals, and toxics. The BMP strategy includes LFDs to comply with dry -weather metals and bacteria Total Maximum Daily Loads (TMDLs). Although large regional and centralized retention and infiltration BMPs will be part of the wet -weather pollutant load reduction strategy, the predominate structural BMP will be smaller distributed BMPs such as bioinfiltration, media filtration, and flow-through BMPs located in street right-of-ways, parking lots, landscaped areas, and as part of green streets and buildings. Because of the high ground water near the shore, capture and reuse regional projects or treatment BMP opportunities will be preferred. The receiving waters for the South Santa Monica Bay include the Santa Monica Bay, the Ballona Creek, and the Marina del Rey Harbor. Marina del Rey EWMP — Figure 2-5 provides the location and distribution of potential regional/centralized BMPs for the Marina del Rey EWMP. Distributed BMPs will be located throughout the urbanized areas of the EWMP. Because of the tidal influence of the marina to most of the watershed, regional projects will be located near the upstream end of the watershed where ground water depths are favorable. The tidally influenced areas will consist of mostly treatment distributed BMPs, including bioinfiltration or tree wells. LA County Flood Control District 2-40 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report Ballona Creek EWMP — Figure 2-6 provides the locations and distribution of potential regional/centralized BMPs for the Ballona Creek EWMP. Regional infiltration BMPs will be well distributed throughout the watershed and will be incorporated with distributed BMPs consisting mostly of distributed BMPs such as green streets. LFDs may also be pursued to comply with dry -weather TMDL requirements. Beach Cities EWMP — Figure 2-7 provides the location and distribution of potential regional/centralized BMPs for the Beach Cities EWMP. Distributed BMPs will be located throughout the urbanized areas of the EWMP. The Beach Cities will focus their efforts on regional projects near the outlet on the Beach similar to the Hermosa Beach Infiltration Trench or the Torrance infiltration basins. Where regional projects are infeasible, distributed projects will be implemented such as green streets. Santa Monica Bay J2/3 — Figure 2-8 provides the location and distribution of potential regional/centralized BMPs for the Santa Monica Bay J2/3 EWMP. Many efforts have already been completed for the Santa Monica Bay J2/J3 Watershed including LFDs and reuse facilities. The group will investigate the possibility of more regional projects that are able to capture and reuse the flow. Remaining areas will be subject to distributed BMPs. Peninsula Cities — Figure 2-9 provides the location and distribution of potential regional/centralized BMPs for the Peninsula Cities EWMP. Distributed BMPs will be located throughout the urbanized areas of the EWMP. The Santa Monica Bay J7 side of the Peninsula Cities area is mostly comprised of anti -degradation sites so there will not be many control measures in this subwatershed. 2. Northern Coastal EWMP Watersheds (Malibu Creek and North Santa Monica Bay Coastal Watersheds EWMP groups) — These watersheds are characterized by lower density development along the coast and the larger creeks with greater open space and park areas inland. There is increased development in the upper areas of the Malibu Creek Watershed. Receiving waters in these watersheds are largely unlined and riparian corridors remain. Water quality priorities include bacteria, toxics, trash, and nutrients as well as benthic community impairments. Figures 2-10 and 2-11 provide the location and distribution of potential regional/centralized BMPs for the Malibu Creek and North Santa Monica Bay Coastal Watersheds EWMP groups, respectively. Smaller distributed BMPs that include biofiltration, media filtration, green streets, and flow-through BMPs will be used in greater percentage than larger centralized BMPs and will be located in developed areas as retrofit BMPs. 3. Unser San Gabriel Watershed — This watershed is characterized by higher density development in the lower watershed area and lower density and open space in the upper watershed where the foothills to the San Gabriel Mountains begin. The priority pollutants in these watersheds include selenium in dry -weather flows, and metals in wet weather flows. This watershed is further differentiated by the importance of groundwater recharge basins that are supplied by a series of reservoirs further upstream in the mountains. The San Gabriel LA County Flood Cenral District 2-41 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. River is unlined in the upper watershed and conveys controlled non -storm and storm flows to recharge basins and downstream sections of the river. Figure 2-12 provides the location and distribution of potential regional/centralized BMPs for the Upper San Gabriel EWMP. The BMP strategy in this watershed focuses more on regional and centralized retention and infiltration BMPs that take advantage of the favorable groundwater recharge characteristics of this area. These BMPs are located near or adjacent to the river. Distributed smaller BMPs are located in urbanized areas as retrofits in existing developments and streets. 4. Rio Hondo/San Gabriel and Upper Los Angeles River Watersheds (Rio Hondo/ San Gabriel and Upper Los Angeles EWMPs) — These watersheds traverses a large diverse area of the Los Angeles Basin with characteristics of Upper San Gabriel in the farthest upper reaches near the foothills, but most of this watershed is characterized by greater urbanization similar to Ballona Creek watershed. The greater urbanization also results in additional priority pollutants compared to Upper San Gabriel watershed, and include nutrients, trash, metals, bacteria and sediment impacted by metals and organic compounds (DDT, PCBs, PAHs). The Rio Hondo/San Gabriel EWMP is characterized by increasing urbanization south of the foothills and industrial and commercial development along the 210 corridor. Figure 2-13 provides the location and distribution of potential regional/centralized BMPs for the Rio Hondo/San Gabriel EWMP. The strategy for the locations and types of regional/centralized BMPs is to use remaining available sites for retention and infiltration, which takes advantage of the favorable infiltration rates of this area, including existing groundwater recharge basins near the San Gabriel River. Distributed BMPs will be located in throughout the urbanized areas of the EWMP. The Los Angeles River is approximately 51 miles long, and five of six reaches lie within the Upper Los Angeles River EWMP. The natural hydrology of the Los Angeles River watershed has been altered by channelization and the construction of dams and flood control reservoirs. The Los Angeles River and many of its tributaries are lined with concrete for most or all of their length. Soft -bottomed segments of the Los Angeles River occur where groundwater upwelling prevents armoring of the river bottom. Figure 2-14 provides the location and distribution of potential regional/centralized BMPs for the Upper Los Angeles River EWMP. Because of the greater extent and number of pollutant priorities, the BMP strategy in the Upper Los Angeles River watershed includes well over a hundred planned regional and centralized retention and infiltration BMPs that take advantage of the favorable groundwater recharge characteristics in defined areas of the watershed. Also planned are centralized treatment wetlands and bioinfiltration BMPs in parks and open spaces with favorable subsurface soils that promote higher infiltration rates. The BMP strategy also includes distributed smaller BMPs located throughout the urbanized areas of the watershed as retrofits in existing developments and streets. LFDs to comply with dry -weather bacteria TMDLs may also be included. LA County Flood Control District 2-42 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 5. Dominguez Channel Watershed (Dominguez Channel EWMP, Beach Cities, Peninsula Cities) – This watershed is differentiated by a larger area of industrial land use, but also includes Beach Cities and Machado Lake. Because of the high density of development and industrial land uses, large regional and centralized infiltration type BMPs will be limited. Figure 2-15 provides the location and distribution of potential regional/centralized BMPs for the Dominguez Channel EWMP. The structural BMP strategy will be more LFDs, both large (centralized) and small (distributed), located at MS4 outfalls near the channelized Dominguez Chanel. The other BMP strategy are smaller distributed BMPs that include the LID type BMP such as Green Streets and biofiltration BMPs throughout the Beach Cities. These distributed BMPs will be retrofit type BMPs that treat runoff from already developed properties and are located in street right-of-ways, parking lots, and limited open areas on public and private parcels. Distributed flow-through treatment BMPs will also be the other predominant BMP that will be retrofitted to the existing MS4 systems. 6. Upper Santa Clara River Watershed – The Santa Clara River Watershed is distinctive in that it is predominantly open space—nearly ninety percent of the watershed—is open space with approximately 88 percent being undeveloped. The watershed contains one of the last remaining natural rivers in Southern California. In years of significant rainfall, ephemeral springs and year-round flows exist in some tributaries and natural upstream areas. Flows in Santa Clara River reaches that pass through the EWMP area are predominantly stormwater runoff during wet -weather months and water reclamation plant effluent discharges in the drier months. Priority pollutants in the watershed are bacteria, nutrients, and chloride. In the source assessments for the Nutrients TMDL and the Chloride TMDL for the Santa Clara River, the storm drain system is not considered the primary source of these pollutants. Lake Elizabeth is also subject to a trash TMDL. The EWMP will evaluate potential MS4 nutrients and chlorides contributions and serve as the implementation plan for the Bacteria TMDL. BMP strategies for this watershed are likely to include a focus more on regional and centralized retention and infiltration BMPs and less on filtration type BMPs, which are not as effective at addressing bacteria. Figure 2-16 provides the location and distribution of potential regional/centralized BMPs. Distributed BMPs will be located in the urbanized areas of the EWMP. As shown in Figures 2-5 through 2-16, each of the EWMPs involves a wide distribution of BMPs to achieve permit compliance. Appendix G provides the locations and general descriptions of the priority BMPs (where data is available), shown in Figures 2-5 through 2- 16. Priority Projects are projects that have been identified through the EWMP process as targeted for implementation within the first years following the EWMPs approval by the LARWQCB. Identification of Priority Projects is underway and has not been completed by all EWMPs at this time. The PEIR is being prepared in parallel to the EWMPs. Priority Projects will be defined in all the EWMPs to be submitted for public comment in June 2015. Priority Projects that have been identified at this time through the EWMP process are shown on the following figures. Priority Projects may be regional, centralized or distributed type BMPs. For potential projects that are shown on the following figure, the location of potential regional and centralized BMPS are shown. Distributed BMP will be distributed throughout the urbanized areas and are not shown on the following figures. Because of land availability LA County Flood Control District 2-43 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. restrictions, large parcels that can support regional or centralized BMPs are fewer and more difficult to obtain than smaller parcels or easements needed for distributed BMPs. The overall strategy engaged by each of the WMGs is to maximize the benefits of regional and centralized BMPs while relying on distributed and non-structural BMPs to achieve a larger majority of the water quality improvement benefits provided by the EWMP. The distributed BMPs will be scattered throughout the watersheds, predominantly in urbanized areas, resulting in widely distributed implementation impacts as discussed in Chapter 3. LA County Flood Control District 2-44 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report e �c �Q CULVER CITY LOS ANGELES : goo has Pacific Ocean COUNTY COUNTY Priority Projects Q Marina del Rey WMG Q Participating Permittees n m Water Resources � Artificial PathBallona Wetlands Participating Permittees — Stream/River T - Culver City Canal/Ditch 0 2,000 - Los Angeles -LACFCD Lake/Pond Feet - LA County SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP . 140474 Figure 2-5 Marina del Rey Watershed Management Group UpperLos Angcics R;vcr O: loner Fra ;q Stone Reservoir L Reservoir Franklin Car: T'. �. BEVERLY <t . HILLS Garapitc • • Creek-Fron fill `� Santa Monica Bay LOB ANGELES • SANTA MONICA �� 2 fps ✓ Santa Monica Bay • Priority Project • Potential BMPs (Regional and Centralized)' Sepun ��tt J Ballona Creek WMG Q Participating Permittees Los ANGELES Q Sub -Watersheds Water Resources , �• • — Artificial Path — Stream/River ° z� Canal/Ditch Mlles f Lake/Pond Potential Distributed BMP not shown - predominantly /opted in urbanized areas SOURCE: ESRI; National Hydrology Dataset. J COUNTY ��u Snguez Channel " � Rollywuod Reservoir Powers -\2 Restroir i V / • Lower Los Angeles River Participating Permittees - Beverly Hills - Culver City - Inglewood - Los Angeles - Santa Monica - West Hollywood - LA County -LACFCD LA County PEIR EWMP . 140474 Figure 2-6 Ballona Creek Watershed Management Group SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP. 140474 Figure 2-7 Beach Cities Watershed Management Group SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP. 140474 Figure 2-8 Santa Monica Bay Watershed Jurisdictions 2 and 3 Watershed Management Groups Participating Permittees - Palos Verdes Estates - Rancho Palos Verdes - Rolling Hills Estates - LA County LACFCD Yy• • t g •L ESTATES S ESTATES ES•ROLLING f., • o : HawMprne • "-- a.' • e! • •• • + COUNTY ROLLING HILLS :} • • • ESTATESv • � Pa os Verdes �^ eservoir • s • T' • • 7: • \t RANCHO PALOS VERDES • • c • Priority Projects ` • Potential BMPs (Regional and Centralized)' Q Palos Verdes Peninsula WMG • r Q Participating Permittees s Q Sub -Watersheds Water Resources Pacific Ocean — Artificial Path — Stream/River -- Canal/Ditch a t f Lake/Pond Milos 'otential Distributed BMP not shown - predominantly located in urbanized areas SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP . 140474 Figure 2-9 Palos Verdes Peninsula Watershed Management Group SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP . 140474 Figure 2-10 Malibu Creek Watershed Management Group SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP . 140474 Figure 2-11 North Santa Monica Bay Coastal Watersheds SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP . 140474 Figure 2-12 Upper San Gabriel River Watershed Management Groups SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP . 140474 Figure 2-13 Rio Hondo / San Gabriel River Watershed Management Group COUNTY `/ • a % SAN FERNANDO ° 0 LOS NGELES 0 �. Y £ • 3 �e,I�� • . °p 4nHeles • • NIGGex NILLsOBLA \+''e • GU Ar° e°111.1. • CAMBASAS 11 • Priority Projects • Potential BMPs (Regional and Centralized)' Q Upper Los Angeles River WMB Q Participating Permittees Water Resources Santa Monica Bay — Artificial Path — Stream/River — Canal/Ditch o 4 Lake/Pond Miles otential Distributed BMP not shown - predominantly located in urbanized areas SOURCE: ESRI; National Hydrology Dataset. \� LA CANADA FLINTRIDG� P COUNTY G. GLENDALE 4• . 4.$V1 �. vAsnoeNA a CnUTH PN ® JeN �A T `M1RLE CITY LOS ANGELES ALHAMBRA �RIEU.Sr ROSEMEAD G5 V�.Re'.!MONTEREY P] MD .E RN r COUNT TY � n M—o� ELL.a Participating Permittees -Alhambra -Burbank - Calabasas i • - Glendale - Hidden Hills _ - La Canada Flintridge t, - Los Angeles LOS ANGELES r - Montebello r - Monterey Park - -Pasadena T - Rosemead • - San Gabriel - San Marino - South Pasadena - Temple City Y -LAFCD LA County PEIR EWMP . 140474 Figure 2-14 Upper Los Angeles River Watershed Management Group SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP. 140474 Figure 2-15 Dominguez Channel Watershed Management Group SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP . 140474 Figure 2-16 Upper Santa Clara River Watershed Watershed Management Group 2.6 EWMP BMP Implementation Schedule The EWMPs that are being prepared in parallel to the PEIR will provide a timeline for the implementation of the BMPs. The priority BMPs are a subset of the potential BMPs that have undergone a site review and project evaluation and have been identified as a priority project, based on available data at the time of publication of this PEIR. The EWMPs will be submitted to the LARWQCB in June 2015. Implementation of priority BMPs will begin following approval of the EWMPs by the LARWQCB, which is anticipated in the later part of 2015 or early 2016. Implementation of BMPs will depend on the approval of the EWMPs, further environmental assessment, permitting, and availability of funding sources. The RAA as part of the EWMPs provides a basis for the needed level of BMP implementation to meet water quality goals. 2.7 Operation and Maintenance Once constructed, structural BMPs will require periodic maintenance. The level and frequency of operation and maintenance (O&M) will depend on the BMP type, size, and complexity. BMPs implemented and under the jurisdiction of the LACFCD would be maintained and operated to meet design performance standards and the efficiencies needed to meet the waste load reductions in accordance with the EWMPs. O&M will also include addressing identified minimum mitigation measures to avoid potential impacts. Project Costs Funding for installation and maintenance of the BMPs identified in each EWMP will be the responsibility of the implementing agencies. The EWMPs will include development of cost estimates for proposed watershed control measures. Financial strategies to implement the EWMP will also be developed and included in the EWMP Plan. The financial strategies may include available State grants, recent Water Bond funding, and partners that can benefit from these projects (e.g. Water agencies). Each EWMP will define priority projects, and installation of these projects will move forward depending on the availability of funding and outcome of further project -specific CEQA review. Funding options for implementing agencies would include obtaining grant funds, low-interest loans, tax -based general funds, or special assessments. Each jurisdiction will be responsible for securing the necessary funds over time to achieve permit compliance. 2.8 Required Approvals LACFCD intends to use this PEIR to consider implementation of the proposed program. As Lead Agency, LACFCD may use this PEIR to approve the proposed program, make Findings regarding identified impacts, and, if necessary, adopt a Statement of Overriding Considerations regarding these impacts. The LARWQCB has discretionary approval over the EWMPs themselves, while a broad range of responsible agencies have discretionary approval over the BMPs described in the EWMPs. These agencies and their approvals are described in Table 2-. The specific approvals LA County Flood Control District 2-57 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 2. necessary for each BMP will vary by BMP; for example, BMPs that do not result in fill of jurisdictional waters of the United States will not need a Clean Water Act Section 404 Permit. TABLE 2-6 REQUIRED APPROVALS Approving Agency Implementing Agencies LA County Flood Control District California Department of Transportation Local Railroad Authorities Local Cities/Permittees U.S. Army Corps of Engineers California Department of Fish and Wildlife U.S. Fish and Wildlife Service and National Marine Fisheries Service California Coastal Commission Regional Water Quality Control Board Approval CEQA approval CEQA approval, Encroachment Permit Encroachment Permit Encroachment Permit Encroachment Permits, certification of compliance with local historic/cultural preservation policies Clean Water Act Section 404 Permit, Rivers and Harbors Act Sections 9 and 10 Permits Lake/Streambed Alteration Agreement (1600 Permit) Endangered Species Act consultations for Clean Water Act and Rivers and Harbors Act permits Coastal Development Permits Clean Water Act Section 401 Water Quality Certification Waste Discharge Requirements for discharge to waters of the state or to land Groundwater Anti -Degradation Analysis Water Recycling Requirements NPDES permits for discharges to waters of the United States Groundwater Recharge Recycled Water Project approval (currently draft regulations) General Construction Permit/SWPPP approval LA County Flood Control District 2-56 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report CHAPTER 3 Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources This section addresses the aesthetic and visual quality of the region and potential impacts associated with the implementation of the Enhanced Watershed Management Program (EWMP). It includes a description of existing visual conditions and an evaluation of potential effects on aesthetic resources. 3,1,1 Environmental Setting Regional Setting Visual resources consist of natural landscapes and scenic views, including landforms, vegetation, and water features, as well as unique elements of the built environment. The proposed program would be located in various watershed areas in the County of Los Angeles (County). Although much of the County is densely populated, the region also has a significant amount of scenic resources, from the coastline to the mountain vistas, including hillsides, scenic viewsheds, and ridgelines. The San Gabriel Mountains, Siena Pelona Mountains, Verduga Hills, Santa Susana Mountains, Simi Hills, Santa Monica Mountains, and Puente Hills help shape the region physically, and also provide aesthetic, environmental, and recreational benefits to residents. The majority of native plants and animals reside in the hillside terrain, which indicates the biological and aesthetic importance of these areas (Los Angeles County Draft General Plan, 2014). Ridgelines or mountain edges with steep drops on either side, located in the Los Angeles region provide dramatic views and are protected and preserved by individual communities. Significant ridgelines are dispersed throughout the County, but are generally located in the Angeles National Forest and the Santa Monica Mountains. The urban landscape varies, and includes low-lying residential, industrial, and commercial buildings along with high-density, high-rise residential and commercial buildings in downtown areas. Program Area Each Watershed Management Area, and EWMP group, associated with the proposed program has its own unique aesthetic resources depending on its location within the County. For example, the coastal watersheds will have significantly different aesthetic resources than the inland watersheds near the mountains. Specific locations of projects have not been established at this point; therefore, the discussion remains at a broader watershed -area level. Existing aesthetic resources within each Watershed Management Area group are summarized in this section. a County Flood Cenral District 3.1-1 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources Santa Monica Bay Watershed Management Area The Santa Monica Bay Watershed Management Area includes the Malibu Creek Watershed EWMP, North Santa Monica Bay EWMP, Santa Monica Bay Jurisdictions 2 and 3 EWMP, Marina del Rey EWMP, Ballona Creek EWMP, and a portion of Beach Cities EWMP and Palos Verdes Peninsula EWMP groups. The Santa Monica Bay Watershed Management Area, which encompasses an area of 414 square miles, is quite diverse. Its borders reach from the crest of the Santa Monica Mountains on the north and from the Ventura—Los Angeles County line to downtown Los Angeles. From there it extends south and west across the Los Angeles plain to include the area east of Ballona Creek and north of the Baldwin Hills. The Santa Monica Bay Watershed Management Area includes several watersheds, the two largest being Malibu Creek to the north and Ballona Creek to the south. The Malibu Creek area contains mostly undeveloped mountain areas, large -acreage residential properties, and many natural streams, while Ballona Creek is predominantly channelized and highly developed with both residential and commercial properties (LARWQCB, 2011). There are large industrial centers in El Segundo, Manhattan Beach, Redondo Beach, and Torrance, which serve as a base for aerospace and other high-tech manufacturing. Other concentrated commercial/industrial areas in the watershed include Westchester—Los Angeles Airport (LAX)—Playa del Rey (commercial), Santa Monica—West Los Angeles—Century City (commercial and light industry), Culver City (entertainment industry), Los Angeles Civic Center, and the Highway 101 corridor in Thousand Oaks—Westlake Village (light industry and commercial) (LARWQCB, 2011). Of the Santa Monica Bay's 414 -square -mile watershed, 121 square miles (29 percent) are developed or impervious. The Ballona Creek subwatershed accounts for most of the impervious area, with 72 square miles of impervious surface. The Malibu Creek watershed, with its large expanse of open area, has nearly 14 square miles of impervious surface (LARWQCB, 2011). The Ballona Creek Wetlands are currently located within the area identified as the Ballona Wetlands Ecological Reserve, which is located at the mouth of Ballona Creek. The Ballona Creek Wetlands encompass approximately 600 acres and is the last remaining major coastal wetland in the Santa Monica Bay. The Ballona Creek Wetlands comprise salt marsh and freshwater wetlands, coastal bluffs, dunes, and upland habitats. The Ballona Creek Wetlands supports several state- and federally -listed species of concern. Developed urban areas surrounding the wetlands, as well as many other human activities, have significantly impacted the wetlands (USEPA, 2012). Riparian habitat exists along each natural watercourse flowing to the ocean and around the lakes of the watershed. Riparian corridors include those found throughout the Ballona Creek Wetlands, Malibu Creek watershed, in other Santa Monica Mountain watersheds such as Arroyo Sequit and Solstice Creek, and adjacent to lakes such as Westlake Lake, Lake Sherwood, and Malibu Lake. The land in the Santa Monica Mountains to the north by contrast is still mostly open space and remains in a somewhat natural state, mostly free of alteration or development but impacted by a County Flood Control District 3.1-2 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources invasive species and mostly bacteria- and nutrient -related water quality issues (LARWQCB, 2011). There are approximately 22 "scenic resources" in the City of Malibu and surrounding areas identified in the Malibu Local Coastal Program. There are numerous vista points in the Malibu area. There are five areas in and adjacent to Malibu that display characteristics which make them suitable as vista points. Significant ridgelines also constitute a scenic resource of the coastal zone because of their high visibility from many vantage points. Ridgelines are typically defined as the line separating drainage basins. Significant ridgelines are those whose ridges silhouette the sky or the ocean, and are clearly visible from scenic roads. These ridgelines are located throughout Malibu and the Santa Monica Mountains (City of Malibu, 1995). Agoura Hills is known as the "Gateway to the Santa Monica Mountains National Recreation Area." The hills of the Santa Monica Mountains provide panoramic vistas, majestic oak trees, and dramatic backdrops of picturesque canyons and hillsides. Four road segments are valuable scenic resources in Agoura Hills that provide scenic views of the Santa Monica Mountains. Important scenic resources include Strawberry Hill, Morrison Ranch Hills, Palo Comado Hills, and the higher more distant Simi Hills that border the city on the north (City of Agoura Hills, 2010). Dominguez Channel Watershed Management Area The Dominguez Channel Watershed Management Area includes the Dominguez Channel EWMP group and a portion of the Beach Cities EWMP and Palos Verdes Peninsula EWMP groups. Approximately 81 percent of the watershed or 93 percent of the land is developed. Residential development covers nearly 40 percent of the watershed, and another 41 percent comprises industrial, commercial, and transportation uses. It is estimated that 62 percent of the land is covered with impervious surfaces (e.g., asphalt, concrete), which represents the highest percentage for any watershed area in Los Angeles County. Parkland and open space are in short supply and generally are deficient in meeting the goal ratio of 0.4 hectare (1 acre) of park per each 1,000 population. Vacant land and open space areas account for 16 percent of the entire watershed. The largest "natural' habitat is associated with the Los Angeles and Long Beach Harbors, which cover 3,289 hectares (8,128 acres), or approximately 9.5 percent of the watershed. The Dominguez Watershed has an extensive transportation system consisting of streets, major highways, and freeways; rail service; three airports; and commercial shipping (Los Angeles County, 2004). The cities with the largest amount of land in the watershed are Los Angeles (22 percent), Carson (14 percent), and Torrance (13 percent). These communities are dominated by high density and multi -family residential land use types, with a fair amount of active redevelopment. The watershed is also home to several smaller, upscale communities, including Palos Verdes Estates, Rancho Palos Verdes, Rolling Hills, and Rolling Hills Estates, which are characterized by low density residential and equestrian land uses (Los Angeles County, 2004). Approximately 50.6 square kilometers (19.5 square miles) of the Dominguez watershed, including Lomita and portions of Rolling Hills, Rolling Hills Estates, Torrance, and the City of IA County Flood Control District 3.1-3 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources Los Angeles, drains to Machado Lake near the intersection of Vermont Avenue and Anaheim Street in the City of Los Angeles. Much of the Machado Lake subwatershed consists of the hilly regions of Rolling Hills and Rolling Hills Estates. This portion of the watershed is unique for Dominguez by consisting of relatively steep hills with drainage ways in canyons. These drainage ways flow generally northwest from the hills toward Machado Lake (Los Angeles County, 2004). Machado Lake (16 hectares, 40 acres) and the Machado Lake wetlands (25 hectares, 64 acres) are located within the Ken Malloy Harbor Regional Park, in the southeastern corner of the Machado Lake subwatershed. Both Machado Lake and the Machado Lake wetlands serve as flood retention basins for the Machado Lake subwatershed. Machado Lake receives urban and stormwater runoff from a complex network of storm drain systems. Machado Lake discharges at the southern end by overflowing a concrete dam into the Machado Lake wetlands. Water discharges from the wetland through the Harbor Outflow structure and into the West Basin of the Los Angeles Harbor (Los Angeles County, 2004). Several types of habitats occur within the Dominguez watershed; the largest is urban land that supports few natural resources. To a lesser extent, biological resources use several small, disturbed pocket wetlands scattered throughout the watershed and retention and detention basins located in the City of Torrance. These biological resources within the Dominguez watershed are highly fragmented and are impacted by a variety of problems directly related to the surrounding urban environment. Several stresses also affect habitats within the Dominguez Channel. The most notable impact to biological resources is the channelization of drainages throughout the system, many of which are concrete -lined (Los Angeles County, 2004). Los Angeles River Watershed Management Area The Los Angeles River Watershed Management Area includes the Upper Los Angeles River EWMP and a portion of the Rio Hondo/San Gabriel River Quality Group EWMP. The Los Angeles River Watershed is one of the largest in the region. It is also one of the most diverse in terms of land use patterns. Approximately 324 square miles of the watershed are covered by forest or open space land, including the area near the headwaters that originate in the Santa Monica, Santa Susana, and San Gabriel Mountains. The rest of the watershed is highly developed (LARWQCB, 2006). The river flows through the San Fernando Valley past heavily developed residential and commercial areas. From the Arroyo Seco, north of downtown Los Angeles, to the confluence with the Rio Hondo, the river flows through industrial and commercial areas and is bordered by rail yards, freeways, and major commercial and government buildings. From the Rio Hondo to the Pacific Ocean, the river flows through industrial, residential, and commercial areas, including major refineries and petroleum products storage facilities, major freeways, rail lines, and rail yards serving the Ports of Los Angeles and Long Beach (LARWQCB, 2006). Also in various parks in the watershed are a number of lakes, including Peck Road Park, Belvedere Park, Hollenbeck Park, Lincoln Park, and Echo Park Lakes as well as Lake Calabasas. These lakes are heavily used for recreational purposes (LARWQCB, 2006). a County Flood Control District 3.1-4 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources San Gabriel River Watershed Management Area The San Gabriel River Watershed Management Area includes a portion of the Rio Hondo/San Gabriel River Quality Group EWMP and the Upper San Gabriel River EWMP. The entire San Gabriel River watershed covers more than 640 square miles and includes portions of 37 cities in Los Angeles and Orange Counties, as well as communities in unincorporated Los Angeles County. More than one-third of the upper watershed falls within the Angeles National Forest, including significant portions of the San Gabriel Mountains. The watershed also contains the Merced and San Jose Hills, and the Puente -Chino Hills, as well as the major urban populations of the San Gabriel and Pomona Valleys and the coastal plain of the Los Angeles Basin (Los Angeles County, 2006). About 26 percent of the watershed's total area is developed with urban and related land uses. The San Gabriel River consists of 22 creeks, washes, and streams, including four major tributaries or subwatersheds, which join to form the overall watershed (Los Angeles County, 2006). The river environment changes dramatically during the 58 -mile course. The river is divided into seven reaches; each reach is defined by distinct landscape, cultural, geological, and hydrological features, which naturally change as the river flows from the mountains through the valley, into the coastal plain, and eventually out to sea (Los Angeles County, 2006). Santa Clara River Watershed Management Area The Santa Clara River Watershed Management Area includes the Upper Santa Clara River EMWP. The Santa Clara River watershed encompasses approximately 1,030 square miles. The Upper Santa Clara River Watershed is approximately 786 square miles within County of Los Angeles limits with approximately 243 square miles within Ventura County and 1 square mile within Kern County. The Santa Clara River Watershed Management Area is dominated by vacant land, which comprises 88 percent of the total land use. Much of the watershed is in mountainous terrain within either the Angeles or Los Padres National Forests (LARWQCB, 2006). Only small portions of agriculture (4 percent) and urban land (6 percent) exist. Much of the residential area (3 percent) is located near the City of Santa Clarita in the center of the watershed. The Santa Clara River Watershed Management Area is the least developed and urbanized of the watershed management areas in Los Angeles County (Weston, 2005). The Santa Clara River watershed's impervious area is estimated to be 7 percent based on assumptions on impervious areas in each land use type. This is the lowest ratio of impervious land area in the Watershed Management Areas of Los Angeles County (Weston, 2005). The Santa Clara River is the largest river system in Southern California remaining in a relatively natural state (LARWQCB, 2006). Extensive patches of high-quality riparian habitat are present along the length of the river and its tributaries (LARWQCB, 2006). IA County Flood Control District 3.1-5 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources One of the largest of the Santa Clara River's tributaries, Sespe Creek, is designated a wild trout stream by the State of California and supports significant spawning and rearing habitat. The Sespe Creek is also designated a wild and scenic river (LARWQCB, 2006). State Scenic Highways There are several Designated State Scenic Highways, Eligible State Scenic Highways, and Historic Parkways with the EWMP areas. Refer to Figure 3.1-1, Scenic Highways. Santa Monica Bay, Los Angeles River, and San Gabriel River watersheds contain both officially designated County scenic highways and Eligible State Scenic Highways not officially designated (State Route 1 and Highway 10 1) (see Figure 4.1-1). In addition, the Los Angeles River watershed also includes historic parkways and the Santa Clara River watershed includes Eligible State Scenic Highways. Many roads in Malibu are considered scenic, but only the Pacific Coast Highway has been officially designated as an eligible scenic highway by the California Department of Transportation (Caltrans) (City of Malibu, 1996). Light and Glare There are two types of light intrusion: the first source emanates from the interior of structures and passes through windows, while the second type emanates from exterior sources such as parking lot lighting and street lamp lighting. Glare is the result of sunlight or an artificial light source being reflected on a flat surface or reflective exterior coatings. Light and glare can disturb wildlife in natural habitat areas and act as a nuisance to adjacent residential areas and motorists. Light and glare are typical features of urbanized settings, such as the EWMP project areas. The primary sources of light within the project areas are associated with transportation, including car headlights associated with vehicular traffic and commercial and residential land uses. 3.1.2 Regulatory Setting State State Scenic Highway Program In 1963, the California legislature created the Scenic Highway Program to protect scenic highway corridors from changes that would diminish the aesthetic value of lands adjacent to the highways. The state regulations and guidelines governing the Scenic Highway Program are found in the Streets and Highways Code, Section 260 et seq. A highway is designated under this program when a local jurisdiction adopts a scenic corridor protection program, applies to Caltrans for scenic highway approval, and receives notification from Caltrans that the highway has been designated as a Scenic Highway. When a city or county nominates an eligible scenic highway for official designation, it defines the scenic corridor, which is land generally adjacent to and visible to a motorist on the highway. IA County Flood Control District 3.1-6 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report EWMP Boundaries Kern 1 - Ballona Creek 2 - Beach Cities C\ -- --- - - - - - - -- — - — - _ - - - - - - - — — — — — 3 - Dominguez Channel `----- 4 - Malibu Creek \ 5 - Marina Del Rey \6 -North Santa Monica Bay \ 7 - Palos Verdes Peninsula 8 - Rio Hondo/San Gabriel River �\ 9 - Santa Monica Bay Jurisdictions 2+3 \ 10 - Upper LA River \, 11 - Upper San Gabriel River \ 12 - Upper Santa Clara River \ Santa Clam River \ I \v 126 Ventura \ Los Angeles I j I 1"r^' se � MULHOLLAND HWY Losanyeles Rroer ,ry i I / — s2,n. Monica Bay m San eaerrat Rlvar , ��V — MALIBU �V ® f,—J �i CANYON RD _1 MULHOLLAND HWY ® ® San \s Bernardino rT ochannel' F— Scenic Highways Designated State Scenic Highways o e Eligible State Scenic Highways Historic Parkways Miles SOURCE: ESRI; Los Angeles County GIS, 2014. Orange LA County PEI EWMP . 140474 Figure 3.1-1 Scenic Highways 3. Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources Local Los Angeles County Existing General Plan, Adopted 1980 The following policy from the Conservation and Open Space Element of the Existing General Plan is relevant to the proposed program: Policy C/OS 16: Protect the visual quality of scenic areas including ridge -lines and scenic views from public roads, trails and key vantage points. Los Angeles County 2014 Draft General Plan 2035 The following policies from the Conservation and Natural Resources Element of the Draft General Plan are relevant to the proposed program: Goal C/NR 13: Protected visual and scenic resources Policy C/NR 13.1: Protect scenic resources through land use regulations that mitigate development impacts. Policy C/NR 13.2: Protect ridgelines from incompatible development that diminishes their scenic value. Policy C/NR 13.3: Reduce light trespass, light pollution and other threats to scenic resources. City Land Use Regulations and Ordinances Local regulations and ordinances vary widely in the EWMP project areas. Aesthetic -related policies included in General Plans typically concern protecting valuable scenic resources. Some local jurisdictions incorporate restrictions to their General Plans that pertain to protection of scenic resources and trees in their jurisdictional areas. 3,13 Impact Assessment Thresholds of Significance For the purposes of this Project Environmental Impact Report (PEIR) and consistency with Appendix G of the CEQA Guidelines, the project would have a significant impact on aesthetic resources if it would: • Create a substantial adverse effect on a scenic vista. • Substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway. • Substantially degrade the existing visual character or quality of the site and its surroundings. • Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. IA County Flood Control District 3.1-8 ESA / 140474 Enhanced Watershed Management programs January 2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources Program Impact Discussion Scenic Vistas Impact 3.1-1: The proposed program could create a substantial adverse effect on a scenic vista. Structural (Regional, Centralized, and Distributed) BMPs A scenic vista can be described as an expansive view of a highly valued landscape for the benefit of the general public. There are portions of the EWMP project areas that could be characterized as having scenic vistas, including undeveloped hillsides, ridgelines, and open space areas that provide a unifying visual backdrop to the urban environment of the Los Angeles Basin. Impacts to scenic vistas can occur when the visible scenic landscape itself is altered or when a new contrasting object is introduced that blocks or obstructs a scenic vista from a particular public vantage point. The construction of structural Best Management Practices (BMPs) for the proposed program would require temporary ground disturbance, primarily on existing sidewalks, streets, parks, and city -owned lands. The presence of construction equipment and materials would be visible from public vantage points but would not affect any scenic views or vistas for longer than the temporary construction periods. Construction of aboveground structures, such as pump stations, would involve excavation, pump station construction, pump and motor installation, and final site completion. Similar to structural BMPs construction, site disturbance and the presence of construction equipment and materials during construction of pump stations could temporarily introduce contrasting elements into scenic views and vistas. However, given the predominantly urban character of potential pump station sites and the temporary nature of construction, impacts would be considered less than significant. It is anticipated that the majority of structural BMPs would be located underground and not visible once construction is complete. Therefore, construction and operation of the majority of structural BMP improvements would not permanently affect views or scenic vistas. Although the exact locations of pump stations have not been determined, based on their proposed function and exterior design, they would not significantly affect views or scenic vistas from publically accessible vantage points. Aboveground structures such as pump station components of projects associated with structural BMPs typically would be single -story buildings; the project areas where pump stations may be located are generally characterized by urban development. As such, aboveground structures would be designed to be similar to and compatible with surrounding architecture and neighborhood character. However, impacts to scenic vistas from individual projects could be significant if inappropriately designed or located. With implementation of Mitigation Measure AES -1, aboveground structures would be designed to avoid obstructing scenic vistas or views from public vantage points. Impacts would be less than significant with mitigation. IA County Flood Control District 3.1-9 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources Mitigation Measure: AES -1: Aboveground structures shall be designed to be consistent with local zoning codes and applicable design guidelines and to minimize features that contrast with neighboring development. Significance Determination: Less than significant with mitigation. (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.1-1.) Non -Structural (Institutional) BMPs Non-structural BMPs consist of policies, actions, and activities aimed at preventing pollutants from entering stormwater runoff, there would not be a physical impact to the environment. The non-structural BMPs associated with the proposed program would not create a substantial adverse effect on a scenic vista. Mitigation Measures: None Significance Determination: No impact State Scenic Highway Impact 3.1-2: The proposed program could substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway. Structural (Regional, Centralized, and Distributed) BMPs State scenic highways within the EWMP areas include portions of State Route 1 or Pacific Coast Highway, State Route 101, State Route 27, State Route 57, State Route 39, State Route 2, State Route 126, and portions of Interstate 5, Interstate 110, and Interstate 210, as shown in Figure 3.1- 1. In addition, there are designated scenic roadways, including Mulholland Highway and Malibu Canyon Roadway. Some of the proposed program could be visible from any of these designated scenic highways or other locally designated scenic roadways. The proposed program would not likely involve damage to rock outcroppings or historic buildings because it is anticipated that the majority of structural BMPs would be located underground and would not be visible once construction is complete. Construction of the proposed program would involve the removal of vegetation, including possibly the removal of native and non-native trees from the individual project sites. Aboveground structures may be constructed as part of the structural BMPs. Small aboveground pump stations and supporting ancillary facilities would not substantially damage scenic resources of the area. Larger structures, such as single -story housing for pump stations and treatment facilities, would be compatible with existing visual character with implementation of Mitigation Measure AES -1. Therefore, construction and operation of the majority of structural BMPs would not permanently affect scenic resources within a state scenic highway with implementation of Mitigation Measure AES -1. Mitigation Measure: Implementation of Mitigation Measure AES -1 IA County Flood Control District 3.1-10 ESA / 140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources Significance Determination: Less than significant with mitigation. (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.1-1.) Non -Structural (Institutional) BMPs Non-structural BMPs consist of policies, actions, and activities aimed at preventing pollutants from entering stormwater runoff, there would not be a physical impact to the environment. The non-structural BMPs associated with the proposed program would not substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway. Mitigation Measures: None Significance Determination: No impact Visual Character Impact 3.1-3: The proposed program could substantially degrade the existing visual character or quality of the site and its surroundings. Structural (Regional, Centralized, and Distributed) BMPs Construction activities associated with all structural BMP projects would require the use of construction equipment and storage of materials on-site, thus introducing contrasting features into the visual landscape that would affect the visual quality of project sites and/or their surroundings. Contrasting features would include demolition materials, excavated areas, stockpiled soils, and other materials generated and stored on-site during construction. However, adverse effects to visual character associated with project construction would be temporary and are considered less than significant. The purpose of the EWMPs is to improve upon the Perrnittee's structural BMPs and it includes the following elements, or BMPs: replacing existing impervious surfaces with pervious surfaces such as bioinfrltration cells, bioswales, porous pavement, and filter strips. Centralized BMPs also include diversion- and treatment -type BMPs that use similar technologies for these types of BMPs under distributed BMPs, but they can be implemented on a much larger scale for collecting, diverting, and treating urban runoff (dry weather flows) or limited stormwater flows from multiple parcels and large drainage areas. Therefore, centralized structural BMPs require greater footprints for construction and implementation. Centralized BMPs include two unique BMP types, treatment wetlands and stream/creek restoration projects. Unlike the other structural BMP types described, these BMPs use natural systems to filter and clean the water. Treatment wetlands are typically off-line treatment systems that are not in the receiving waters, but may have habitat benefits through the establishment of more native plants and ecosystems. Creek, river, and estuary restoration projects provide a unique opportunity to restore natural cleansing processes, reestablish habitats, and address impacts from hydromodifrcation and urban runoff. Once constructed, the proposed EWMP facilities would be located predominantly in urban areas. Underground facilities, such as storm drains, are not expected to have a permanent effect on visual character of an area. Implementation of the structural BMPs is anticipated to have an IA County Flood Control District 3.1-11 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources overall positive impact on the aesthetic environment. For example, there is anticipated to be more green space areas and less impermeable surfaces from pavement and concrete, thereby enhancing the level of greenness in the watersheds. Greenness includes "green spaces" that have well- defined boundaries that do not contain residential, commercial, or industrial structures or vehicular access or "green areas," which are within the street grid and are landscape design features such as street trees, bioswales, green or vegetated roofs, or other vegetated small areas integrated into the built environment. These BMPs contribute to the natural open space character compared to the more built environment that it is replacing. Aboveground structures within urban areas would be constructed on or adjacent to existing developed and built-up landscapes. Small aboveground pump stations and supporting ancillary facilities would have no significant effect on the visual character of the area. Larger structures, such as single -story housing for pump stations and treatment facilities, would be compatible with existing visual character with implementation of Mitigation Measure AES -1. BMP maintenance is also important when considering long-term impacts on aesthetics. Poorly maintained BMPs, such as wet ponds or constructed wetlands, may be unsightly as a result of excess algal growth or public littering. Wet ponds and constructed wetlands can also become mosquito -breeding grounds. However, mosquito problems can usually be reduced or eliminated through proper design and/or organic controls such as mosquito -eating fish. Successful design avoids shallow or stagnant water and reduces large areas of periodic drying, which can occur in a dry detention basin. In addition, all BMPs need to have trash and debris removed periodically to prevent odor and preserve aesthetic values. With proper maintenance of all implemented BMPs as required in Mitigation Measure AES -2, impacts would be less than significant. Mitigation Measures: Implementation of Mitigation Measure AES -1 AES -2: Implementing agencies shall develop BMP maintenance plans that are approved concurrently with each structural BMP approval. The maintenance plans must include measures to ensure functionality of the structural BMPs for the life of the BMP. These plans may include general maintenance guidelines that apply to a number of smaller distributed BMPs. Significance Determination: Less than significant with mitigation. (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.1-1.) Non -Structural (Institutional) BMPs Non-structural BMPs consist of policies, actions, and activities aimed at preventing pollutants from entering stormwater runoff; there would not be a physical impact to the environment. The non-structural BMPs associated with the proposed program would not degrade the existing visual character or quality of the site and its surroundings. Mitigation Measures: None Significance Determination: No Impact IA County Flood Control District 3.1-12 ESA / 140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources Light and Glare Impact 3.1-4: The proposed program could create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. Structural (Regional, Centralized, and Distributed) BMPs Security lighting used during the construction of all structural BMP projects, if necessary, may introduce new sources of light and glare to the immediate project areas; however, nighttime construction is not anticipated. If security lighting is needed, it can be shielded and directed away from surrounding light-sensitive land uses, consistent with implementing agency design standards. Temporary impacts associated with light and glare during construction activities would be less than significant. It is not anticipated that the structural BMP projects would involve the installation of permanent new outdoor lighting for the distributed, centralized, and regional structural watershed control measures. The goal of the BMPs in the EWMP projects is to reduce the impact of stormwater and non-stormwater on receiving water quality. Whether distributed, centralized, or regional, the major structural BMP functions are infiltration, treatment, and storage; these may be used individually or in combination. Distributed BMPs are most likely to be implemented in high- density urban, commercial, industrial, and transportation areas where currently there are no BMPs. These types of BMPs are generally "retrofit" -type projects that replace existing impervious surfaces with pervious surfaces such as bioinfiltration cells, bioswales, porous pavement, and filter strips that tie into existing stormwater management systems as part of the MS4. These projects may also augment the existing MS4 with additional inlet screens, filter media systems, sediment removal systems, and diversions to sanitary sewer lines. In addition, many of the proposed EWMP programs would include underground storm drain facilities. Because these types of BMPs would not require lighting, they would not create a new source of light or glare that would adversely affect day or nighttime views in the area. Aboveground pump stations and treatment facilities associated with potential structural BMP projects may require new exterior daytime and nighttime lighting for operational and security purposes. If security lighting is needed for these facilities, they would be shielded to avoid glare impacts to local areas, consistent with implementing agency design standards. Operational impacts associated with light and glare would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs Non-structural BMPs consist of policies, actions, and activities aimed at preventing pollutants from entering stormwater runoff; there would not be a physical impact to the environment. The non-structural BMPs associated with the proposed program would not create a new source of light or glare which would adversely affect day or nighttime views in the area. Mitigation Measures: None Significance Determination: No impact IA County Flood Control District 3.1-13 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs Cumulative projects located in the Los Angeles County region would have the potential to result in a cumulative impact to aesthetic resources if in combination they would result in the removal or substantial adverse change of one or more features that contribute to the valued visual character or image of a neighborhood, community, state scenic highway, or localized area, such as a landmark (designated), historic resource, trees, or rock outcropping. Changes in land use are not included in the proposed program and the structural BMPs are generally limited to portions of the EWMP areas that feature existing urban development. The introduction of structural BMPs in these areas would result in minor changes to the community character and visual appearance of the applicable EWMP areas. In addition, many of the structural BMPs are anticipated to result in more open space areas and less pavement and concrete, thereby enhancing the level of greenness in the watersheds. These BMPs contribute to the natural open space character compared to the more built environment that these BMPs are replacing. Overall, implementation of the structural BMPs is anticipated to have a positive impact on the aesthetic environment. Implementation of Mitigation Measures AES -1 and AES -2 would minimize cumulative impacts to aesthetic resources. Mitigation Measures: Implementation of Mitigation Measure AES -1 and AES -2 Significance Determination: Less than significant with mitigation. (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.1-1.) Non -Structural (Institutional) BMPS Non-structural BMPs consist of policies, actions, and activities aimed at preventing pollutants from entering stormwater runoff, there would not be physical impact to the environment. Non- structural BMPs would not include any direct impacts to aesthetic resources; therefore, there would be no cumulative impacts to aesthetic resources. Mitigation Measures: None required Significance Determination: No impact IA County Flood Control District 3.1-14 ESA / 140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.1 Aesthetic Resources 301.3 Summary of Impact Assessment Table 3.1-1 shows a summary of the structural BMPs requiring mitigation. TABLE 3.1-1 SUMMARY OF AESTHETICS IMPACTS REQUIRING MITIGATION MEASURES Structural BMPs Applicable Mitigation Measures: Scenic Vistas AES -1 Thresholds of Significance Scenic Visual Highways Character AES -1 AES -1; AES -2 Light and Glare None Required Cumulative Impacts AES -1; AES -2 Regional BMPs Regional Retention and Yes No Yes No Yes Infiltration Regional Capture, Detention, Yes No Yes No Yes and Use Centralized BNP Biofiltration Yes No Yes No Yes Constructed Wetlands No No Yes No Yes Treatment/Low-Flow Yes No Yes No Yes Diversions Creek, River, Estuary No No Yes No Yes Restoration Distributed BNPS Site Scale Detention Yes No Yes No Yes LID — Infiltration/Filtration Yes No Yes No Yes BMPs — Porous Pavement, Green Streets, Bioswale/Filter Strips, Downspout Disconnects LID — Green Infrastructure — Yes No Yes No Yes Capture and Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes Flow-through Treatment BMPs Yes No Yes No Yes Source Control Treatment Yes No Yes No Yes BMPs (catch basin inserts/screens, hydrodynamic separators, gross solids removal devices) Low -Flow Diversions Yes Yes Yes No Yes NOTE: These conclusions are based on typical size and function of BMPs. IA County Flood Control District 3.1-15 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.2 Air Quality This section of the Program Environmental Impact Report (PEIR) addresses potential air quality impacts associated with implementation of the proposed program. The environmental setting provides a description of the general air quality and meteorological conditions in the South Coast Air Basin (Basin). The regulatory setting provides a description of applicable federal, state, and local regulatory policies. The impact assessment section evaluates the potential for short-term and long-term air quality impacts to result from implementation of the proposed program. Mitigation measures are recommended as necessary to reduce significant air quality impacts. 3.201 Environmental Setting Regional Setting The proposed program is located in Los Angeles County (County), which covers an area of about 4,083 square miles and comprises 88 cities and approximately 2,650 square miles of unincorporated areas. The majority of the County is highly urbanized and consists of several cities, communities, and unincorporated areas. The proposed program is located in multiple jurisdictions of Los Angeles County, which include the Los Angeles County Flood Control District (LACFCD), County of Los Angeles, and the following 46 cities: Los Angeles, Beverly Hills, Culver City, Inglewood, Santa Monica, West Hollywood, Hawthorne, El Segundo, Lomita, Baldwin Park, Covina, Glendora, Industry, La Puente, Malibu, Calabasas, Agoura Hills, Westlake Village, Hidden Hills, Santa Clarita, Rancho Palos Verdes, Palos Verdes Estates, Rolling Hills Estates, Redondo Beach, Hermosa Beach, Torrance, Manhattan Beach, Arcadia, Azusa, Bradbury, Duarte, Monrovia, Sierra Madre, Alhambra, Burbank, Glendale, Hidden Hills, La Canada Flintridge, Montebello, Monterey Park, Pasadena, Rosemead, San Gabriel, San Marino, South Pasadena, and Temple City (refer to Figure 1-1). Each of these jurisdictions have independent planning documents that guide the development of urban, agricultural and other land uses within their jurisdictional boundaries. Climate and Meteorology The program is located in the portion of Los Angeles County that lies within the Basin. The program area is under the jurisdiction of the South Coast Air Quality Management District (SCAQMD). The Basin is an approximately 6,600 -square -mile coastal plain bounded by the Pacific Ocean to the southwest and the San Gabriel, San Bernardino, and San Jacinto Mountains to the north and east. The Basin includes the non -desert portions of Los Angeles, Riverside, and San Bernardino Counties, and all of Orange County. The ambient concentrations of air pollutants are determined by the amount of emissions released by sources and the atmosphere's ability to transport and dilute such emissions. Natural factors that affect transport and dilution include terrain, wind, atmospheric stability, and sunlight. Therefore, existing air quality conditions in the program area are determined by such natural factors as topography, meteorology, and climate, in addition to the amount of emissions released by existing air pollutant sources. IA County Flood Control District 3.2-1 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality Atmospheric conditions such as wind speed, wind direction, and air temperature gradients interact with the physical features of the landscape to determine the movement and dispersal of air pollutants. The topography and climate of Southern California combine to make the Basin an area of high air pollution potential. The Basin is a coastal plain with connecting broad valleys and low hills, bounded by the Pacific Ocean to the west and high mountains around the rest of the perimeter. The general region lies in the semi-permanent high-pressure zone of the eastern Pacific, resulting in a mild climate tempered by cool sea breezes with light average wind speeds. The usually mild climatological pattern is disrupted occasionally by periods of extremely hot weather, winter storms, or Santa Ana winds. During the summer months, a warm air mass frequently descends over the cool, moist marine layer produced by the interaction between the ocean's surface and the lowest layer of the atmosphere. The warm upper layer forms a cap over the cool marine layer and inhibits the pollutants in the marine layer from dispersing upward. In addition, light winds during the summer further limit ventilation. Furthermore, sunlight triggers the photochemical reactions that produce ozone. The region experiences more days of sunlight than any other major urban area in the nation except Phoenix (SCAQMD, 2012). Criteria Pollutants The California Air Resources Board (GARB) and the United States Environmental Protection Agency (USEPA) currently focus on the following air pollutants as indicators of ambient air quality: ozone, carbon monoxide (CO), nitrogen dioxide (NOA sulfur dioxide (SO2), respirable or breathable particulate matter with an aerodynamic diameter of 10 micrometers or less (PM10), fine particulate matter with an aerodynamic diameter of 2.5 micrometers or less (PM2.5), and lead. The pollutants are referred to as "criteria air pollutants" since they are the most prevalent air pollutants known to be harmful to human health, and extensive health -effects criteria documents are available about their effects on human health and welfare. Standards have been established for each criteria pollutant to meet specific public health and welfare criteria set forth in the federal Clean Air Act (CAA). California has generally adopted more stringent ambient air quality standards for the criteria air pollutants (referred to as State Ambient Air Quality Standards, or state standards) and has adopted air quality standards for some pollutants for which there is no corresponding national standard. Ozone Ozone, the main component of photochemical smog, is primarily a summer and fall pollution problem. Ozone is not emitted directly into the air, but is formed through a complex series of chemical reactions involving other compounds that are directly emitted. These directly emitted pollutants (also known as ozone precursors) include reactive organic gases (ROGs) or volatile organic compounds (VOCs), and oxides of nitrogen (NOx)• While both ROGs and VOCs refer to compounds of carbon, ROG is a term used by CARB and is based on a list of exempted carbon compounds determined by CARB. VOC is a term used by the USEPA and is based on USEPA's own exempt list. The time period required for ozone formation allows the reacting compounds to spread over a large area, producing regional pollution problems. Ozone concentrations are the cumulative result of regional development patterns rather than the result of a few significant emission sources. IA County Flood Control District 3.2-2 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality Once ozone is formed, it remains in the atmosphere for 1 or 2 days. Ozone is then eliminated through reaction with chemicals on the leaves of plants, attachment to water droplets as they fall to earth (rainout), or absorption by water molecules in clouds that later fall to earth with rain (washout). Short-term exposure to ozone can irritate the eyes and cause constriction of the airways. In addition to causing shortness of breath, ozone can aggravate existing respiratory diseases such as asthma, bronchitis, and emphysema. Carbon Monoxide CO, a colorless and odorless gas, is a relatively nonreactive pollutant that is a product of incomplete combustion and is mostly associated with motor vehicles. When inhaled at high concentrations, CO combines with hemoglobin in the blood and reduces the oxygen -carrying capacity of the blood. This results in reduced oxygen reaching the brain, heart, and other body tissues. This condition is especially critical for people with cardiovascular diseases, chronic lung disease, or anemia. CO measurements and modeling were important in the early 1980s, when CO levels were regularly exceeded throughout California. In more recent years, CO measurements and modeling have not been a priority in most California air districts because of the retirement of older polluting vehicles, lower emissions from new vehicles, and improvements in fuels. Nitrogen Dioxide NO2 is a reddish -brown gas that is a by-product of combustion processes. Automobiles and industrial operations are the main sources of NO2. Combustion devices emit primarily nitric oxide (NO), which reacts through oxidation in the atmosphere to form NO2. The combined emissions of NO and NO2 are referred to as NOx, which are reported as equivalent NO2. Aside from its contribution to ozone formation, NO2 can increase the risk of acute and chronic respiratory disease and reduce visibility. NO2 may be visible as a coloring component of a brown cloud on high -pollution days, especially in conjunction with high ozone levels. Sulfur Dioxide SO2 is a colorless, extremely irritating gas or liquid. It enters the atmosphere as a pollutant, mainly as a result of burning high -sulfur -content fuel oils and coal, and from chemical processes occurring at chemical plants and refineries. When SO2 oxidizes in the atmosphere, it forms sulfur trioxide (S03). Collectively, these pollutants are referred to as sulfur oxides (SOx). Major sources of SO2 include power plants, large industrial facilities, diesel vehicles, and oil - burning residential heaters. Emissions of SO2 aggravate lung diseases, especially bronchitis. It also constricts the breathing passages, especially in people with asthma and people involved in moderate to heavy exercise. SO2 potentially causes wheezing, shortness of breath, and coughing. Long -tern SO2 exposure has been associated with increased risk of mortality from respiratory or cardiovascular disease. IA County Flood Control District 3.2-3 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality Particulate Matter PMto and PM2.5 consist of particulate matter that is 10 microns or less in diameter and 2.5 microns or less in diameter, respectively (a micron is one -millionth of a meter). PMto and PM2.5 represent fractions of particulate matter that can be inhaled into the air passages and the lungs and can cause adverse health effects. Acute and chronic health effects associated with high particulate levels include the aggravation of chronic respiratory diseases, heart and lung disease, and coughing, bronchitis, and respiratory illnesses in children. Recent mortality studies have shown an association between morbidity and mortality and daily concentrations of particulate matter in the air. CARB has estimated that achieving the ambient air quality standards for PM to could reduce premature mortality rates by 6,500 cases per year (CARB, 2002). Particulate matter can also damage materials and reduce visibility. One common source of PM2.5 is diesel exhaust emissions. PMtg consists of particulate matter emitted directly into the air (e.g., fugitive dust, soot, and smoke from mobile and stationary sources, construction operations, fires, and natural windblown dust) and particulate matter formed in the atmosphere by condensation and/or transformation of SO2 and ROGs. Traffic generates particulate matter emissions through entrainment of dust and dirt particles that settle onto roadways and parking lots. PMtg and PM2.5 are also emitted by wood burning in residential wood stoves and fireplaces and open agricultural burning. PM2.5 can also be formed through secondary processes such as airborne reactions with certain pollutant precursors, including ROGs, ammonia (NHA NOx, and SOx. Lead is a metal found naturally in the environment and present in some manufactured products. There are a variety of activities that can contribute to lead emissions, which are grouped into two general categories, stationary and mobile sources. On -road mobile sources include light-duty automobiles; light-, medium-, and heavy-duty trucks as well as motorcycles. Emissions of lead have dropped substantially over the past 40 years. The reduction before 1990 was largely due to the phase-out of lead as an anti -knock agent in gasoline for on -road automobiles. Substantial emission reductions have also been achieved through enhanced controls in the metals -processing industry. In the Basin, atmospheric lead is generated almost entirely by the combustion of leaded gasoline and contributes less than one percent of the material collected as total suspended particulates. Toxic Air Contaminants Concentrations of toxic air contaminants (TACs), or in federal parlance, hazardous air pollutants (HAPS), are also used as indicators of ambient air quality conditions. A TAC is defined as an air pollutant that may cause or contribute to an increase in mortality or in serious illness, or that may pose a hazard to human health. TACs are usually present in minute quantities in the ambient air; however, their high toxicity or health risk may pose a threat to public health even at low concentrations. LA County Flood Control District 3.2-4 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality According to The California Almanac of Emissions and Air Quality (CARB, 2009), the majority of the estimated health risk from TACs can be attributed to relatively few compounds, the most important being particulate matter from diesel -fueled engines (diesel particulate matter). Diesel particulate matter differs from other TACs in that it is not a single substance, but rather a complex mixture of hundreds of substances. Although diesel particulate matter is emitted by diesel -fueled internal combustion engines, the composition of the emissions varies depending on engine type, operating conditions, fuel composition, lubricating oil, and whether an emission control system is present. Unlike the other TACs, no ambient monitoring data are available for diesel particulate matter because no routine measurement method currently exists. However, CARB has made preliminary concentration estimates based on a particulate matter exposure method. This method uses the CARB emissions inventory's PMfg database, ambient PM1g monitoring data, and the results from several studies to estimate concentrations of diesel particulate matter. In addition to diesel particulate matter, the TACs for which data are available that pose the greatest existing ambient risk in California are benzene, 1,3 -butadiene, acetaldehyde, carbon tetrachloride, hexavalent chromium, para -dichlorobenzene, formaldehyde, methylene chloride, and perchlorcethylene. Odorous Emissions Odors are generally regarded as an annoyance rather than a health hazard. However, manifestations of a person's reaction to foul odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and respiratory effects, nausea, vomiting, and headache). Offensive odors are unpleasant and can lead to public distress, generating citizen complaints to local governments. Although unpleasant, offensive odors rarely cause physical harm. The occurrence and severity of odor impacts depend on the nature, frequency, and intensity of the source, wind speed, direction, and the sensitivity of receptors. Program Area Air Quality Setting Existing Air Quality SCAQMD maintains monitoring stations within district boundaries that monitor air quality and compliance with associated ambient standards. The Enhanced Watershed Management Program (EWMP) areas associated with the proposed program are located in multiple jurisdictions within the County of Los Angeles, all of which are located within in the Basin. Given the large geographic region of the EWMP areas, an extensive listing of the air quality monitoring data collected by each SCAQMD monitoring station located within the EWMP areas is not provided in this PEIR. As individual EWMP projects are not assessed separately in this PEIR, the presentation of the air quality data collected by the monitoring stations relevant to each EWMP project is more applicable for inclusion in the environmental documents for future individual EWMP projects. Both CARB and USEPA use the data measured at air quality monitoring stations to designate areas according to their attainment status for criteria air pollutants. The purpose of these designations is to identify the areas with air quality problems and thereby initiate planning efforts IA County Flood Control District 3.2-5 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality for improvement. The three basic designation categories are nonattainment, attainment, and unclassified. Unclassified is used in an area that cannot be classified on the basis of available information as meeting or not meeting the standards. In addition, the California designations include a subcategory of nonattainrnent-transitional, which is given to nonattainment areas that are progressing and nearing attainment. The current attainment status for the Basin is provided in Table 3.2-1. TABLE 3.2-1 SOUTH COAST AIR BASIN ATTAINMENT STATUS Attainment Status Pollutant California Standards Federal Standards Ozone Extreme Nonattainment Severe Nonattainment CO Attainment Unclassified/ Attainment NO2 Attainment Unclassified/ Attainment SO2 Attainment Attainment PMtc Nonattainment Attainment PM2.6 Nonattainment Nonattainment SOURCE: CARE, 2013b; USEPA, 2013. Sensitive Land Uses Land uses such as schools, children's daycare centers, hospitals, and convalescent homes are considered to be more sensitive to poor air quality than the general public because the population groups associated with these uses have increased susceptibility to respiratory distress. In addition, residential uses are considered more sensitive to air quality conditions than commercial and industrial uses, because people generally spend longer periods of time at their residences, resulting in greater exposure to ambient air quality conditions. Recreational land uses are considered moderately sensitive to air pollution. Exercise places a high demand on respiratory functions, which can be impaired by air pollution, even though exposure periods during exercise are generally short. In addition, noticeable air pollution can detract from the enjoyment of recreation. Given that the majority of the County is highly urbanized with a variety of land use types (e.g., open space, residential, commercial, mixed-use, public and semi-public, and industrial uses), and that the proposed program would be located in various watersheds across the County that span multiple jurisdictions, existing sensitive uses such as residences, schools, hospitals, daycare centers, etc., would be located within and in proximity to the EWMP areas. As described in Section 3.9, Land Use and Agriculture, of this PEIR, many of the EWMP areas, including Ballona Creek, Beach Cities, Dominguez Channel, and Marina del Rey, have residential uses as the predominant land use. 3,2,2 Regulatory Setting The EWMP areas associated with the proposed program are located in Los Angeles County within the Basin. Air quality in the County is regulated by USEPA, CARB, and SCAQMD. The IA County Flood Control District 3.2-6 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality County of Los Angeles General Plan also contains an Air Quality Element in their 2014 draft document. This element summarizes air quality issues and outlines the goals and policies in the General Plan that will improve air quality and reduce greenhouse gas emissions (Los Angeles County, 2014). Los Angeles County's adopted General Plan has not yet been updated to include this element. USEPA Criteria Air Pollutants At the federal level, USEPA has been charged with implementing national air quality programs. USEPA's air quality mandates are drawn primarily from the federal CAA, which was enacted in 1970. The most recent major amendments to the CAA were made by Congress in 1990. The CAA requires USEPA to establish National Ambient Air Quality Standards (NAAQS). USEPA has established primary and secondary NAAQS for the following "criteria air pollutants": ozone, CO, NO2, SO2, PMIg, PM2_5, and lead. Table 3.2-2 shows the NAAQS for these pollutants. The CAA also requires each state to prepare an air quality control plan, referred to as a state implementation plan (SIP). The CAA Amendments of 1990 (CAAA) added requirements for states with nonattainment areas to revise their SIPS to incorporate additional control measures to reduce air pollution. The SIPS are modified periodically to reflect the latest emissions inventories, planning documents, and rules and regulations of the air basins, as reported by their jurisdictional agencies. USEPA is responsible for reviewing all SIPS to determine whether they conform to the mandates of the CAA and its amendments, and to determine whether implementing the SIPS will achieve air quality goals. If USEPA determines a SIP to be inadequate, a federal implementation plan that imposes additional control measures may be prepared for the nonattainment area. If an approvable SIP is not submitted or implemented within the mandated time frame, sanctions may be applied to transportation funding and stationary sources of air pollution in the air basin. USEPA also has regulatory and enforcement jurisdiction over emission sources beyond state waters (outer continental shelf), and those that are under the exclusive authority of the federal government, such as aircraft, locomotives, and interstate trucking. USEPA's primary role at the state level is to oversee state air quality programs. USEPA sets federal vehicle and stationary source emissions standards and provides research and guidance in air pollution programs. In June 2004, USEPA finalized the adoption of a comprehensive national program/rule to reduce emissions from off-road diesel engines used primarily in construction, agricultural, and industrial applications by integrating engine and fuel controls as a system to gain the greatest emission reductions. Specifically, USEPA adopted new emission standards for off-road diesel engines and sulfur reductions in off-road diesel fuel aimed at dramatically reducing harmful emissions and helping states and local areas that have been designated as 8 -hour ozone nonattainment areas to improve their air quality. The new engine standards, which are based on the use of advanced exhaust emission control devices, began to take effect in 2008 and would continue to be phased in until 2015. USEPA estimates particulate matter reductions of 95 percent, NOx reductions of 90 IA County Flood Control District 3.2-7 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality TABLE 3.2-2 AMBIENT AIR QUALITY STANDARDS FOR CRITERIA POLLUTANTS Pollutant Averaging Time° State Standard National Standard Pollutant Health and Atmospheric Effects Major Pollutant Sources Ozone 1 hour 0.09 ppm --- High concentrations can directly affect lungs, causing irritation. Formed when ROG and NOx react in the presence of 8 hours 0.070 ppm' 0.075 ppm Long-term exposure may cause damage to lung tissue. sunlight. Major sources include on -road motor vehicles, 1 hour 0.25 ppm Dioxide (SO2) 3 hours solvent evaporation, and commercial/industrial mobile damage; degradation of visibility; property damage. 24 hours 0.04 ppm Standard equipment. Carbon Monoxide 1 hour 20 ppm 35 ppm Classified as a chemical asphyxiant, carbon monoxide interferes Internal combustion engines, primarily gasoline -powered (CO) 8 hours 9.0 ppm 9 ppm with the transfer of fresh oxygen to the blood and deprives motor vehicles. Nitrogen Dioxide 1 hour 0.18 ppm (NO2) Annual Arithmetic 0.030 ppm No National Mean Standard Sulfur 1 hour 0.25 ppm Dioxide (SO2) 3 hours — damage; degradation of visibility; property damage. 24 hours 0.04 ppm Standard Annual Arithmetic --- Mean Respirable 24 hours 50 pg/m' Particulate Matter Annual Arithmetic 20 pg/m3 (PM10) Mean Fine Particulate 24 hours — Matter Annual Arithmetic 12 pg/m' (PM25) Mean Lead (Pb) 30 Day Average 1.5 pg/m' Calendar Quarter --- Rolling 3 -Month — Average Hydrogen Sulfide 1 hour 0.03 ppm Sulfates (SO4) 24 hours 25 pg/m3 Visibility -Reducing 8 hours Extinction of Particles 0.23/km; visibility of 10 miles or more 0.100 ppm 0.053 ppm 75 ppb 0.5 ppm 0.14 ppm 0.030 ppm 150 pg/m' 35 pg/m' 12.0 pg/m' sensitive tissues of oxygen. Irritating to eyes and respiratory tract. Colors atmosphere Motor vehicles, petroleum refining operations, industrial reddish -brown. sources, aircraft, ships, and railroads. Irritates upper respiratory tract; injurious to lung tissue. Can Fuel combustion, chemical plants, sulfur recovery plants, yellow the leaves of plants; destructive to marble, iron, and steel. and metal processing. Limits visibility and reduces sunlight. May irritate eyes and respiratory tract, decreases in lung capacity, increases cancer and mortality. Produces haze and limits visibility. Increases respiratory disease, lung damage, cancer, and premature death. Reduces visibility and results in surface soiling. --- Disturbs gastrointestinal system, and causes anemia, kidney 1.5 pg/m3 disease, and neuromuscular and neurological dysfunction (in 0.15 pg/m' severe cases). No National Nuisance odor (rotten egg smell), headache, and breathing Standard difficulties(higher concentrations) No National Decrease in ventilatory functions; aggravation of asthmatic Standard symptoms; aggravation of cardio -pulmonary disease; vegetation damage; degradation of visibility; property damage. No National Reduces visibility, reduced airport safety, lower real estate Standard value, and discourages tourism. Dust and fume -producing industrial and agricultural operations, combustion, atmospheric photochemical reactions, and natural activities (e.g., wind -raised dust and ocean sprays). Fuel combustion in motor vehicles, equipment, and industrial sources; residential and agricultural burning; Also formed from photochemical reactions of other pollutants, including NO, sulfur oxides, and organics. Present source: lead smelters, battery manufacturing, and recycling facilities. Past source: combustion of leaded gasoline. Geothermal power plants, petroleum production and refining Industrial processes. See PMzs Vinyl Chloride 24 hours 0.01 ppm No National Short-term exposure to high levels of vinyl chloride in the air can Polyvinyl chloride (PVC) plastic and vinyl products. Standard cause dizziness, drowsiness, and headaches. Long-term exposure through inhalation and oral exposure can cause liver damage. Cancer is a major concern from exposure to vinyl chloride via inhalation. Vinyl chloride exposure has been shown to increase the risk of angiosarcoma, a rare form of liver cancer in humans. NOTE: ppm = parts per million; ppb = parts per billion; pg/m' = micrograms per cubic meter. The averaging time is the interval of time over which the sample results are reported. b This concentration was approved by CARS on April 28, 2005, and became effective May 17, 2006. SOURCE: CARE. 2013c. IA County Flood Control District 3.2-8 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality percent, and the virtual elimination of SOx from off-road engines that meet the new standards. Because the emission control devices in the off-road diesel engines could potentially be damaged by sulfur, USEPA also targeted the reduction of sulfur levels in off-road diesel fuel as part of its rule. The rule aimed to reduce off-road diesel fuel sulfur levels by 99 percent, resulting in an Ultra Low Sulfur Diesel (ULSD) fuel that has a maximum sulfur concentration of 15 parts per million (ppm). The phase-in of fuel controls to reduce the sulfur levels in off-road diesel fuel began in 2007. With respect to on -road diesel engines, USEPA promulgated the Heavy -Duty Highway Rule in 2007, which aims to reduce emissions from on -road, heavy-duty diesel trucks by establishing a series of increasingly strict emission standards for new engines. Manufacturers are required to produce new diesel vehicles that meet particulate matter and NOx emission standards beginning with model year 2007. Hazardous Air Pollutants USEPA has programs for identifying and regulating HAPS. The first National Emission Standards for Hazardous Air Pollutants (NESHAPs) were originally required by the CAA in 1970, which were developed for sources and source categories of HAPS that were determined to pose adverse risk to human health. The USEPA Administrator was directed to set risk-based NESHAPs at a level that provided an ample margin of safety to protect the public health from HAPS. Subsequently, in Section 112(d) of the 1990 CAAA, Congress directed USEPA to develop technology-based standards to further regulate HAPS. As opposed to the original conception of NESHAPs as a risk-based standard, the technology-based NESHAPS were established according to Maximum Achievable Control Technology (MACT) requirements. The MACT NESHAP standards were different for major sources than for area sources of HAPS. Major sources are defined as stationary sources with potential to emit more than 10 tons per year (tpy) of a single HAP or more than 25 tpy of any combination of HAPs; all other sources are considered area sources. Section 112(f) of the 1990 CAAA also specified that USEPA determine whether or not to promulgate additional NESHAP standards beyond the MACT within 8 years after promulgation of the MACT standard (but within 9 years after promulgation of the 2 -year MACT source categories). Thus, USEPA is required to evaluate the NESHAPs developed according to the MACT standards for any "residual risk" with 8 years of promulgation. If the "residual risk" for a source category does not protect public health with "an ample margin of safety," then USEPA must promulgate health -based standards for that source category to further reduce HAP emissions. The CAAA also required USEPA to promulgate vehicle or fuel standards containing reasonable requirements that control toxic emissions of, at a minimum, benzene and formaldehyde. Performance criteria were established to limit mobile -source emissions of toxics, including benzene, formaldehyde, and 1,3 -butadiene. In addition, Section 219 required the use of reformulated gasoline in selected areas with the most severe ozone nonattainrnent conditions to further reduce mobile -source emissions. IA County Flood Control District 3.2-9 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality CARB Criteria Air Pollutants CARB, a department of the California Environmental Protection Agency, oversees air quality planning and control throughout California. CARB is responsible for coordination and oversight of state and local air pollution control programs in California and for implementation of the California Clean Air Act (CCAA). The CCAA, which was adopted in 1988, requires CARB to establish the California Ambient Air Quality Standards (CAAQS). CARB has established CAAQS for sulfates, hydrogen sulfide, vinyl chloride, visibility -reducing particulate matter, and the above-mentioned criteria air pollutants. Applicable CAAQS are shown in Table 3.2-2. The CCAA requires all local air districts in the state to endeavor to achieve and maintain the CAAQS by the earliest practical date. The act specifies that local air districts shall focus particular attention on reducing the emissions from transportation and area -wide emission sources, and provides districts with the authority to regulate indirect sources. Among CARB's other responsibilities are overseeing compliance by local air districts with California and federal laws; approving local air quality plans; submitting SIPS to USEPA; monitoring air quality; determining and updating area designations and maps; and setting emissions standards for new mobile sources, consumer products, small utility engines, off-road vehicles, and fuels. Toxic Air Contaminants Air quality regulations also focus on TACs. In general, for those TACs that may cause cancer, there is no concentration that does not present some risk. In other words, there is no safe level of exposure. This contrasts with the criteria air pollutants, for which acceptable levels of exposure can be determined and for which the ambient standards have been established. Instead, USEPA and CARB regulate HAPs and TACs, respectively, through statutes and regulations that generally require the use of the MACT or best available control technology (BACT) for toxics and to limit emissions. These statutes and regulations, in conjunction with additional rules set forth by the districts, establish the regulatory framework for TACs. TACs in California are regulated primarily through the Tanner Air Toxics Act (Assembly Bill [AB] 1807 [Chapter 1047, Statutes of 1983]) and the Air Toxics Hot Spots Information and Assessment Act (Hot Spots Act) (AB 2588 [Chapter 1252, Statutes of 1987]). AB 1807 sets forth a formal procedure for CARB to designate substances as TACs. This includes research, public participation, and scientific peer review before CARB can designate a substance as a TAC. To date, CARB has identified more than 21 TACs and adopted USEPA's list of HAPS as TACs. Most recently, diesel particulate matter was added to the CARB list of TACs. Once a TAC is identified, CARB then adopts an airborne toxics control measure (ATCM) for sources that emit that particular TAC. If there is a safe threshold for a substance at which there is no toxic effect, the control measure must reduce exposure below that threshold. If there is no safe threshold, the measure must incorporate BACT to minimize emissions. IA County Flood Control District 3.2-10 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality The Air Toxics Hot Spots Information and Assessment Act requires existing facilities emitting toxic substances above a specified level to prepare a toxic -emission inventory, prepare a risk assessment if emissions are significant, notify the public of significant risk levels, and prepare and implement risk -reduction measures. CARB published the Air Quality and Land Use Handbook: A Community Health Perspective (Handbook), which provides guidance concerning land use compatibility with TAC sources (CARB, 2005). Although it is not a law or adopted policy, the Handbook offers advisory recommendations for the siting of sensitive receptors near uses associated with TACs, such as freeways and high -traffic roads, commercial distribution centers, rail yards, ports, refineries, dry cleaners, gasoline stations, and industrial facilities, to help keep children and other sensitive populations out of harm's way. SCAQMD Criteria Air Pollutants SCAQMD attains and maintains air quality conditions in the Basin through a comprehensive program of planning, regulation, enforcement, technical innovation, and promotion of the understanding of air quality issues. The clean air strategy of SCAQMD includes preparation of plans for attainment of ambient air quality standards, adoption and enforcement of rules and regulations concerning sources of air pollution, and issuance of permits for stationary sources of air pollution. SCAQMD also inspects stationary sources of air pollution and responds to citizen complaints; monitors ambient air quality and meteorological conditions; and implements programs and regulations required by the CAA, CAAA, and CCAA. Air quality plans applicable to the proposed program are discussed below. Air Quality Management Plan SCAQMD and the Southern California Association of Governments (SLAG) are responsible for preparing the air quality management plan (AQMP), which addresses federal and state CAA requirements. The AQMP details goals, policies, and programs for improving air quality in the Basin. The 2012 AQMP was adopted by the SCAQMD Governing Board on December 12, 2012. The purpose of the 2012 AQMP for SCAG is to set forth a comprehensive and integrated program that will lead the Basin into compliance with the federal 24-hour PM2.5 air quality standard, and to provide an update to the Basin's commitments toward meeting the federal 8 -hour ozone standards. The AQMP also serves to satisfy recent USEPA requirements for a new attainment demonstration of the revoked 1 -hour ozone standard, as well as a vehicle miles traveled (VMT) emissions offset demonstration.1 Specifically, once approved by CARB, the AQMP would serve as the official SIP submittal for the federal 2006 24-hour PM2.5 standard, for which USEPA has t Although the federal 1 -hour ozone standard was revoked in 2005, the USEPA has proposed to require anew 1 -hour ozone attainment demonstration in the South Coast extreme ozone nonattainment area as a result of a recent court decision. Although USEPA has replaced the 1 -hour ozone standard with a more health protective 8 -hour standard, the CAA anti -backsliding provisions require that California have approved plans for attaining the 1 -hour standard. IA County Flood Control District 3.2-11 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality established a due date of December 14, 2012.21n addition, the AQMP updates specific new control measures and commitments for emissions reductions to implement the attainment strategy for the 8 -hour ozone SIP. The 2012 AQMP sets forth programs which require integrated planning efforts and the cooperation of all levels of government: local, regional, state, and federal. Currently, SCAQMD staff has already begun initiating an early development process for the 2015 AQMP. SCAQMD Rules and Regulations All projects are subject to SCAQMD rules and regulations in effect at the time of construction. Specific rules applicable to the construction anticipated under the proposed program would include the following: Rule 401 — Visible Emissions. This rule is intended to prevent the discharge of pollutant emissions from an emissions source that results in visible emissions. Specifically, the rule prohibits the discharge of any air contaminant into the atmosphere by a person from any single source of emission for a period or periods aggregating more than 3 minutes in any 1 hour that is as dark or darker in shade than that designated No. 1 on the Ringelmann Chart, as published by the United States Bureau of Mines. Rule 402 — Nuisance. This rule is intended to prevent the discharge of pollutant emissions from an emissions source that results in a public nuisance. Specifically, this rule prohibits any person from discharging quantities of air contaminants or other material from any source such that it would result in an injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public. Additionally, the discharge of air contaminants would also be prohibited where it would endanger the comfort, repose, health, or safety of any number of persons or the public, or that cause, or have a natural tendency to cause, injury or damage to business or property. This rule does not apply to odors emanating from agricultural operations necessary for the growing of crops or the raising of fowl or animals. Rule 403 — Fugitive Dust. This rule is intended to reduce the amount of particulate matter entrained in the ambient air as a result of anthropogenic (human -made) fugitive dust sources by requiring actions to prevent, reduce, or mitigate fugitive dust emissions. Rule 403 applies to any activity or human -made condition capable of generating fugitive dust, and requires best available control measures to be applied to earthmoving and grading activities. Toxic Air Contaminants At the local level, air pollution control or management districts may adopt and enforce CARB control measures. Under SCAQMD Regulation XIV (Toxics and Other Non -Criteria Pollutants), and in particular Rule 1401 (New Source Review), all sources that possess the potential to emit TACs are required to obtain permits from SCAQMD. Permits may be granted to these operations 2 Although the 2012 AQMP was approved by the SCAQMD Board on December 7, 2012, the plan did not get submitted to the USEPA by December 14, 2012 as it fust required approval from CARB. The 2012 AQMP was subsequently approved by CARB on January 25, 2013, and as of February 13, 2013 the plan has been submitted by CARB to the USEPA. IA County Flood Control District 3.2-12 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality if they are constructed and operated in accordance with applicable regulations, including new source review standards and air toxics control measures. SCAQMD limits emissions and public exposure to TACs through a number of programs. SCAQMD prioritizes TAC -emitting stationary sources based on the quantity and toxicity of the TAC emissions and the proximity of the facilities to sensitive receptors. As none of the proposed Best Management Practices (BMP) projects in the County would involve TAC -emitting stationary sources, no permits from SCAQMD would be required for operation of the proposed BMP projects. The Air Toxics Control Plan (March 2000, revised March 26, 2004) is a planning document designed to examine the overall direction of SCAQMD's air toxics control program. It includes development and implementation of strategic initiatives to monitor and control air toxics emissions. Control strategies that are deemed viable and are within SCAQMD's jurisdiction will each be brought to the SCAQMD Board for further consideration through the normal public review process. Strategies that are to be implemented by other agencies will be developed in a cooperative effort, and the progress will be reported back to the Board periodically. In September 2008, the SCAQMD completed the Multiple Air Toxics Exposure Study III (MATES III). MATES III is a monitoring and evaluation study conducted in the Basin and is a follow-up to previous air toxics studies. The study consists of several elements, including a monitoring program, an updated emissions inventory of toxic air contaminants, and a modeling effort to characterize risk across the Basin. The study focuses on the carcinogenic risk from exposure to air toxics. However, it does not estimate mortality or other health effects from particulate exposures. MATES III shows that areas within the County have an estimated carcinogenic risk ranging from 1,173 to 1,449 in a million. These model estimates were based on monitoring data collected at 10 fixed sites within the Basin. As of June 2012, SCAQMD began conducting the MATES IV. County of Los Angeles General Plan The Conservation and Open Space Element of the 1980 County of Los Angeles General Plan sets the policy direction for management of the County's natural resources, including air quality. The specific policies in the County General Plan related to improving air quality include: Policy 1: Actively support strict air quality regulations for mobile and stationary sources, and continued research to improve air quality. Promote vanpooling, carpooling and improved public transportation. Policy 2: Support the conservation of energy and encourage the development and utilization of new energy sources including geothermal, thermal waste, solar, wind and ocean -related sources. Policy 3: Promote the use of solar energy to the maximum extent possible. IA County Flood Control District 3.2-13 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality The Air Quality Element of the Draft 2014 County of Los Angeles General Plan summarizes air quality issues and outlines goals and policies that will improve air quality and reduce greenhouse gas emissions. These specific policies include: Policy AQ 1.1: Minimize health risks to people from industrial toxic or hazardous air pollutant emissions, with an emphasis on local hot spots, such as existing point sources affecting immediate sensitive receptors. Policy AQ 1.2: Encourage the use of low or no volatile organic compound (VOC) emitting materials. Policy AQ 1.3: Reduce particulate inorganic and biological emissions from construction, Action Plan grading, excavation, and demolition to the maximum extent feasible. Policy AQ 1.4: Work with local air quality management districts to publicize air quality warnings, and to track potential sources of airborne toxics from identified mobile and stationary sources. Policy AQ 2.1: Encourage the application of design and other appropriate measures when siting sensitive uses, such as residences, schools, senior centers, daycare centers, medical facilities, or parks with active recreational facilities within proximity to major sources of air pollution, such as freeways. Policy AQ 2.2: Participate in, and effectively coordinate the development and implementation of community and regional air quality programs. Policy AQ 3.1: Facilitate the implementation and maintenance of the Community Climate Action Plan to ensure that the County reaches its climate change and greenhouse gas emission reduction goals. Policy AQ 3.2: Reduce energy consumption in County operations by 20 percent by 2015. Policy AQ 3.3: Reduce water consumption in County operations. Policy AQ 3.4: Participate in local, regional and state programs to reduce greenhouse gas emissions. Policy AQ 3.5: Encourage maximum amounts of energy conservation in new development and municipal operations. Policy AQ 3.6: Support and expand urban forest programs within the unincorporated areas. City General Plans The numerous cities encompassed by the EWMP project area all have their own respective city General Plans, some of which may contain policies that address air quality. As implementation of the individual structural BMP projects proceed, specific policies and objectives pertaining to air IA County Flood Control District 3.2-14 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality quality from applicable city General Plans will be identified and evaluated on a project -by -project basis during subsequent California Environmental Quality Act (CEQA) environmental processes. 30203 Impact Assessment Thresholds of Significance Based on Appendix G of the CEQA Guidelines, impacts related to air quality may be considered significant if the proposed program would: • Conflict with or obstruct implementation of the applicable air quality plan. • Violate any air quality standard or contribute substantially to an existing or projected air quality violation. • Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors). • Expose sensitive receptors to substantial pollutant concentrations. • Create objectionable odors affecting a substantial number of people. As guided by Appendix G of the CEQA Guidelines, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the above determinations. As such, the significance thresholds and analysis methodologies in SCAQMD's CEQA Air Quality Handbook are used in evaluating project impacts. The SCAQMD has established daily mass emissions thresholds for criteria pollutants and ozone precursors, which are shown in Table 3.2-3 Program Impact Discussion Air Quality Plan Impact 3.2-1: The project could conflict with or obstruct implementation of the applicable air quality plan. Structural (Regional, Centralized, and Distributed) BMPs In preparation of the AQMP, SCAQMD and SCAG use land use designations contained in General Plan documents to forecast, inventory, and allocate regional emissions from land use and development -related sources. For purposes of analyzing consistency with the AQMP, projects that are consistent with the regional population, housing, and employment forecasts identified by SCAG are considered to be consistent with the AQMP growth projections, since the forecast assumptions by SCAG forms the basis of the land use and transportation control portions of the AQMP. IA County Flood Control District 3.2-15 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality TABLE 3.2-3 SCAQMD REGIONAL AIR QUALITY SIGNIFICANCE THRESHOLDS Additionally, since SCAG's regional growth forecasts are based upon, among other things, land uses designated in General Plans, a project that is consistent with the land use designated in a city's General Plan would also be consistent with the SCAG's regional forecast projections, and thus also with the AQMP growth projections. Implementation of the proposed program would involve the installation of structural control measures that would be constructed as BMPs to reduce the impact of stormwater and non- stonnwater on receiving water quality within the EWMP areas. As such, the proposed program is not a land use project and its implementation would not induce any additional growth within the EWMP areas in the County. Therefore, the proposed program would not conflict with, or obstruct, implementation of the AQMP. Overall, this impact would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPS As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, no impacts associated with implementation of the SCAQMD's AQMP would result. Mitigation Measures: None required IA County Flood Control District 3.2-16 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Mass Daily Thresholds (lbslday) Pollutant Construction Operations Oxides of Nitrogen (NOx) 100 55 Reactive Organic Gases (ROG) 75 55 Respirable Particulate Matter (PM,p) 150 150 Fine Particulate Matter (PM25) 55 55 Oxides of Sulfur (SOx) 150 150 Carbon Monoxide (CO) 550 550 Leads 3 3 TACs (including carcinogens and Maximum Incremental Cancer Risk non -carcinogens z 10 in 1 million Cancer Burden > 0.5 excess cancer cases (in areas > 1 in 1 million) Chronic & Acute Hazard Index >_ 1.0 (project increment) ' As the proposed program would not involve the development of any major lead emissions sources, lead emissions are not analyzed further in the PER. SOURCE: SCAQMD, 2011. Additionally, since SCAG's regional growth forecasts are based upon, among other things, land uses designated in General Plans, a project that is consistent with the land use designated in a city's General Plan would also be consistent with the SCAG's regional forecast projections, and thus also with the AQMP growth projections. Implementation of the proposed program would involve the installation of structural control measures that would be constructed as BMPs to reduce the impact of stormwater and non- stonnwater on receiving water quality within the EWMP areas. As such, the proposed program is not a land use project and its implementation would not induce any additional growth within the EWMP areas in the County. Therefore, the proposed program would not conflict with, or obstruct, implementation of the AQMP. Overall, this impact would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPS As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, no impacts associated with implementation of the SCAQMD's AQMP would result. Mitigation Measures: None required IA County Flood Control District 3.2-16 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality Significance Determination: No impact Air Quality Standards Impact 3.2-2: The project could violate any air quality standard or contribute substantially to an existing or projected air quality violation. Structural (Regional, Centralized, and Distributed) BMPs Construction Development of the proposed structural BMPs would generally involve construction phases such as site preparation, grading and excavation, and construction of the structural control measure. Construction activities associated with each structural BMP (regional, centralized, and distributed) would generate pollutant emissions from the following general activities: (1) site preparation, grading, and excavation; (2) construction workers traveling to and from a BMP site; (3) delivery and hauling of construction supplies to and soil and debris from the structural BMP site; (4) fuel combustion by on-site construction equipment; and (5) construction of the structural BMP. These construction activities would temporarily create emissions of dust, fumes, equipment exhaust, and other air contaminants. Construction activities involving site preparation and grading would primarily generate PMtg emissions. Mobile source emissions (use of diesel -fueled equipment on-site, and traveling to and from a BMP site) would primarily generate NOx emissions. The amount of emissions generated on a daily basis would vary, depending on the intensity and types of construction activities occurring at the same time. The timing and sequencing of the development of the proposed structural BMPs within the EWMP areas are currently unknown. Thus, the amount of program -related construction that would occur on a daily or annual basis cannot be determined with any certainty at this time. As such, it is expected that the construction activities for the structural BMPs in the EWMP areas would occur intermittently throughout the course of the program implementation period Construction impacts associated with each structural BMP development would be short-term in nature and limited to the period of time when construction activity is taking place for that particular development. Although it is beyond the scope of this PEIR to assess the construction emissions for each individual BMP project, for the purpose of this analysis an emissions estimate for a representative "worst-case" construction scenario of each structural BMP type (i.e., distributed, centralized, and regional) is provided to demonstrate the magnitude of the daily emissions that can be generated by each structural BMP type. As such, a worst-case construction scenario was defined for a small-, medium-, and large-scale structural BMP project, which corresponds to a distributed, centralized, and regional structural BMP project, respectively. In addition, the year 2015 was used as the construction analysis year to provide a conservative analysis, since construction equipment used in future years beyond 2015 would likely emit pollutants at a lower rate because of more stringent emission standards, advances in technologies and fuels, and equipment turnover. The maximum daily construction emissions for the three structural BMP project types were estimated using the California Emissions Estimator Model (CalEEMod), which is designed to model construction emissions for land use development projects based on building size, land use IA County Flood Control District 3.2-17 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality and type, and disturbed acreage, and allows for the input of project -specific information. The construction -related emissions of criteria air pollutants for the three structural BMP types were modeled based on general information provided in the project description and CalEEMod default settings along with reasonable assumptions based on other similar types of projects. The specific modeling parameters pertaining to the types and amount of construction equipment used during each construction phase for a representative distributed, centralized, and regional structural BMP project that was used to generate construction emissions are shown in Tables 3.2-4, 3.2-5, and 3.2-6, respectively. TABLE 3.2-4 MODELING PARAMETERS FOR WORST-CASE CONSTRUCTION SCENARIO FOR A DISTRIBUTED BMP PROJECT IA County Flood Control District 3.2-18 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Construction Construction Equipment Construction Equipment Daily Usage Construction Phase Equipment Type Quantity Hours Site Preparation Excavator 1 8 Tractors/Loaders/Backhoes 1 6 Other General Industrial 1 8 Equipment Grading Graders 1 4 Rubber Tired Dozers 1 4 Tractors/Loaders/Backhoes 1 8 Building Construction Forklifts 1 8 Generator Sets 1 8 Tractors/Loaders/Backhoes 2 8 Welders 1 8 Acres of Grading: 2 TABLE 3.2-5 MODELING PARAMETERS FOR WORST-CASE CONSTRUCTION SCENARIO FOR A CENTRALIZED BMP PROJECT Construction Construction Equipment Construction Equipment Daily Usage Construction Phase Equipment Type Quantity Hours Site Preparation Excavator 2 6 Tractors/Loaders/Backhoes 3 8 Other General Industrial 1 8 Equipment Grading Graders 2 8 Rubber Tired Dozers 2 8 Tractors/Loaders/Backhoes 2 8 Building Construction Forklifts 2 8 Generator Sets 2 8 Tractors/Loaders/Backhoes 3 8 Welders 1 8 Acres of Grading: 10 IA County Flood Control District 3.2-18 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality TABLE 3.2-6 MODELING PARAMETERS FOR WORST-CASE CONSTRUCTION SCENARIO FOR A REGIONAL BMP PROJECT Construction Construction Equipment Construction Equipment Daily Usage Construction Phase Equipment Type Quantity Hours Site Preparation Excavator 3 8 Tables 3.2-7, 3.2-8, and 3.2-9 summarize the modeled worst-case daily emissions that are estimated to occur on peak construction days for a representative distributed, centralized, and regional structural BMP project, respectively. The CaIEEMod modeling for each representative structural BMP project type assumes that appropriate dust control measures would be implemented during each phase of development as required by SCAQMD Rule 403—Fugitive Dust. These dust control measures generally include, but are not limited to, the following: • All haul trucks shall be covered when loaded with fill. • Paved streets shall be swept at least once per day where there is evidence of dirt that has been carried on to the roadway. • Watering trucks shall be used to minimize dust. Watering should be sufficient to confine dust plumes to the project work areas. • Active disturbed areas shall have water applied to them three times daily. • Inactive disturbed areas shall be revegetated as soon as feasible to prevent soil erosion. • For disturbed surfaces to be left inactive for four or more days and that will not be revegetated, a chemical stabilizer shall be applied per manufacturer's instruction. • For unpaved roads, chemical stabilizers shall be applied or the roads shall be watered once per hour during active operation. • Vehicle speed on unpaved roads shall be limited to 15 miles per hour. • For open storage piles that will remain on-site for two or more days, water shall be applied once per hour, or coverings shall be installed. IA County Flood Control District 3.2-19 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Tractors/Loaders/Backhoes 4 8 Other General Industrial 3 8 Equipment 2 8 Rubber Tired Dozers Grading Graders 2 8 Rubber Tired Dozers 3 8 Tractors/Loaders/Backhoes 4 8 Building Construction Forklifts 3 8 Generator Sets 4 8 Tractors/Loaders/Backhoes 4 7 Welders 1 8 Acres of Grading: 40 Tables 3.2-7, 3.2-8, and 3.2-9 summarize the modeled worst-case daily emissions that are estimated to occur on peak construction days for a representative distributed, centralized, and regional structural BMP project, respectively. The CaIEEMod modeling for each representative structural BMP project type assumes that appropriate dust control measures would be implemented during each phase of development as required by SCAQMD Rule 403—Fugitive Dust. These dust control measures generally include, but are not limited to, the following: • All haul trucks shall be covered when loaded with fill. • Paved streets shall be swept at least once per day where there is evidence of dirt that has been carried on to the roadway. • Watering trucks shall be used to minimize dust. Watering should be sufficient to confine dust plumes to the project work areas. • Active disturbed areas shall have water applied to them three times daily. • Inactive disturbed areas shall be revegetated as soon as feasible to prevent soil erosion. • For disturbed surfaces to be left inactive for four or more days and that will not be revegetated, a chemical stabilizer shall be applied per manufacturer's instruction. • For unpaved roads, chemical stabilizers shall be applied or the roads shall be watered once per hour during active operation. • Vehicle speed on unpaved roads shall be limited to 15 miles per hour. • For open storage piles that will remain on-site for two or more days, water shall be applied once per hour, or coverings shall be installed. IA County Flood Control District 3.2-19 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality • For paved road track -out, all haul vehicles shall be covered and shall maintain a freeboard height of 12 inches. • During high wind conditions (wind speeds in excess of 25 miles per hour), all earthmoving activities shall cease or water shall be applied to soil not more than 15 minutes prior to disturbing such soil. • Install wheel washers where vehicles enter and exit unpaved roads onto paved roads, or wash off trucks and any equipment leaving the construction site each trip on a gravel surface to prevent dirt and dust from impacting the surrounding areas. TABLE 3.2-7 ESTIMATED PEAK DAILY EMISSIONS FOR PROJECT CONSTRUCTION ACTIVITIES FOR A DISTRIBUTED BMP PROJECT Estimated Maximum Daily Emissions (lbs/day) Construction Activity ROG NOx CO sox PM10' PMx.s' Site Preparation: On -Site 1.08 10.83 7.38 0.01 0.73 0.67 Off -Site 0.04 0.05 0.53 1.06 7.90 7.20 Total Emissions: 1.12 10.88 7.91 1.07 8.63 7.87 Grading: On -Site 2.24 16.06 15.02 0.20 1.30 1.20 Off -Site 5.87 80.41 67.88 0.21 1.52 1.39 Total Emissions: 8.11 96.47 82.90 0.41 2.82 2.59 Building: On -Site 2.30 16.03 12.00 .02 1.24 1.19 Off -Site 0.17 0.23 2.45 4.91 3.64 3.34 Tota/ Emissions: 2.47 16.26 14.45 4.93 4.88 4.53 Maximum Regional Daily 8.11 96.47 82.90 0.41 2.82 2.59 Emissions Regional Significance Threshold 75 100 550 150 150 55 Significant Impact? No No No No No No NOTE: See Appendix C for CaIEEMod model outputs. ' PM1s and PMz5 emission estimates are based on compliance with SCAQMD Rule 403 requirements for fugitive dust suppression. IA County Flood Control District 3.2-20 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality TABLE 3.2-8 ESTIMATED PEAK DAILY EMISSIONS FOR PROJECT CONSTRUCTION ACTIVITIES FOR A CENTRALIZED BMP PROJECT Estimated Maximum Daily Emissions (lbs/day) Construction Activity ROG NOx CO sox PM10a PM2s' Site Preparation: On -Site 2.10 20.98 14.56 0.02 1.45 1.34 Off -Site 0.07 0.09 0.99 1.99 1.48 1.35 Total Emissions: 2.17 21.07 15.55 2.01 2.93 2.69 Grading: On -Site 5.39 57.37 36.76 0.04 3.10 2.85 Off -Site 6.93 108.06 80.26 0.25 1.79 1.64 Total Emissions: 12.32 165.43 117.02 0.29 4.89 4.49 Building: On -Site 3.48 25.48 18.62 0.03 1.97 1.88 Off -Site 1.60 8.32 21.25 0.04 0.14 0.13 Total Emissions: 5.08 33.80 39.87 0.07 2.11 2.01 Maximum Regional Daily 18.51 256.27 184.36 0.46 6.88 6.32 Emissions 12.32 165.43 117.02 0.29 4.89 4.49 Emissions 75 100 550 150 150 55 Regional Significance Threshold 75 100 550 150 150 55 Significant Impact? No Yes No No No No NOTE: See Appendix C for CaIEEMod model outputs. a PMrs and PM2s emission estimates are based on compliance with SCAQMD Rule 403 requirements for fugitive dust suppression. TABLE 3.2-9 ESTIMATED PEAK DAILY EMISSIONS FOR PROJECT CONSTRUCTION ACTIVITIES FOR A REGIONAL BMP PROJECT Estimated Maximum Daily Emissions (lbs/day) Construction Activity ROG NOx CO sox PMl,a PM2.5a Site Preparation: On -Site 6.43 67.27 48.36 0.05 4.00 3.68 Off -Site 0.14 0.19 1.98 3.98 2.95 2.71 Total Emissions: 6.57 67.46 50.34 4.03 6.95 6.39 Grading: On -Site 6.75 72.62 48.35 0.05 3.84 3.53 Off -Site 11.76 183.65 136.01 0.41 3.04 2.79 Total Emissions: 18.51 256.27 184.36 0.46 6.88 6.32 Building: On -Site 5.46 41.01 29.69 0.04 3.14 3.02 Off -Site 6.43 33.48 85.27 0.16 0.56 0.52 Total Emissions: 11.89 74.58 114.96 .20 3.70 3.54 Maximum Regional Daily 18.51 256.27 184.36 0.46 6.88 6.32 Emissions Regional Significance Threshold 75 100 550 150 150 55 Significant Impact? No Yes No No No No NOTE: See Appendix C for CaIEEMod model outputs. a PM10 and PM25 emission estimates are based on compliance with SCAQMD Rule 403 requirements for fugitive dust suppression. IA County Flood Control District 3.2-21 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality As shown in Table 3.2-7, implementation of distributed BMPs would not result in significant air emissions when assuming worst-case construction methods. However, as shown in Tables 3.2-8 and 3.2-9, for some of the larger regional and centralized BMPs, the maximum daily level of construction -generated emissions of NOx would exceed the applicable SCAQMD-recommended thresholds under the worst-case construction scenario. The remaining criteria pollutants (i.e., ROG, CO, SOx, PMtg, and PM2_5) would not exceed the applicable SCAQMD-recommended thresholds. The exceedance of SCAQMD's threshold for NOx emissions for larger BMPs would be generated primarily during the grading phase, when emissions associated with off-road construction equipment and on -road soil hauling activities would occur. Thus, impacts associated with NOx emissions during construction activities of centralized and regional structural BMPs are considered significant. It should be noted that the sample construction scenarios provided in this analysis for a single distributed, centralized, and regional structural BMP project represent an estimation of construction methods and emissions. It is likely that the actual emissions associated with each structural BMP type would be less than those presented in this PEIR. As discussed previously, it is anticipated that future structural BMP developments associated with the proposed program would be reviewed on a case-by-case basis to ascertain whether an individual development would generate potentially significant air quality impacts during construction, and, where it is necessary, will require the implementation of mitigation measures to minimize air emissions and reduce potentially significant impacts. As such, the identification of a significant program -level impact from construction in this PEIR for the proposed program does not preclude the finding of less -than -significant impacts from construction for future individual structural BMP projects within the EWMP areas. For BMPs that may result in significant air emissions as determined by implementing agencies, Mitigation Measures AIR -1 and AIR -2 would need to be implemented to reduce construction emissions to less than significant levels. For smaller BMPs including distributed BMPs, air emissions would not be significant and would not require mitigation measures. Table 3.2-10 summarizes which BMPs would require mitigation measures. While implementation of Mitigation Measures AIR -1 and AIR -2 would reduce construction - related emissions, they may not reduce these emissions to levels below the SCAQMD thresholds for every structural BMP project, as the amount of emissions generated for each structural BMP project would vary depending on its size, the land area that would need to be disturbed during construction, and the length of the construction schedule. Implementation of large regional or centralized BMPs could result in temporary significant and unavoidable air emissions during peak periods of construction. Operation Implementation of the proposed program would not result in substantial long-term regional emissions of criteria air pollutants. The proposed structural BMPs are not land use projects and, therefore, would not generate daily vehicle -exhaust emissions by the motor vehicles traveling to and from the individual project areas. While it is anticipated that implementing agencies would IA County Flood Control District 3.2-22 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality conduct visits to the structural BMP sites for inspection and maintenance activities, these visits would occur only periodically throughout the year and would result in minimal emissions. Additionally, while some of the centralized and regional structural BMPs may require the installation of pump stations and ancillary components, this equipment would be electrically powered and would not generate emissions at the BMP sites. Some Regional BMPs may involve grading large areas to be used as percolation basins. Some of these areas may be unvegetated, which may result in dust erosion. Implementing agencies would be required to prepare a Dust Control Plan to be in compliance with Rule 403. Stabilizing soils with binders, gravel, or vegetation would reduce dust emissions from large graded areas and prevent significant PMfg emissions. Compliance with existing dust emission regulations, specifically Rule 403, would ensure that operational impacts would be less than significant. Mitigation Measures: AIR -1: Implementing agencies shall require for large regional or centralized BMPs the use of low -emission equipment meeting Tier II emissions standards at a minimum and Tier III and IV emissions standards where available as CARB-required emissions technologies become readily available to contractors in the region. AIR -2: For large construction efforts that may result in significant air emissions, implementing agencies shall encourage contractors to use lower -emission equipment through the bidding process where appropriate. Significance Determination: Impacts from construction emissions would remain significant and unavoidable for some of the larger projects as there are no other feasible mitigation measures available to reduce these impacts at this program level; impacts from operational emissions would be less than significant. (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.2-10.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, no air quality impacts associated with construction or operational activities would result. Mitigation Measures: None required Significance Determination: No impact Cumulative Impacts Impact 3.2-3: The program could result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors). IA County Flood Control District 3.2-23 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality Structural (Regional, Centralized, and Distributed) BMPS As the Basin is currently in nonattainment for ozone, PM1g, and PM2,5, cumulative development consisting of the proposed program along with other reasonably foreseeable future projects in the Basin as a whole could violate an air quality standard or contribute to an existing or projected air quality violation. However, based on SCAQMD's cumulative air quality impact methodology, SCAQMD recommends that if an individual project results in air emissions of criteria pollutants (ROG, CO, NOx, SOx, PMtg, and PM2.5) that exceed the SCAQMD's recommended daily thresholds for project -specific impacts, then it would also result in a cumulatively considerable net increase of these criteria pollutants for which the proposed program region is in nonattainment under an applicable federal or state ambient air quality standard. As discussed previously under Impact 3.2-2, under conditions where multiple structural BMPS would be constructed concurrently in the EWMP areas, it is anticipated that the total aggregate construction emissions generated from these multiple structural BMP projects on a daily basis would exceed the SCAQMD's significance thresholds for criteria pollutants. Even with implementation of Mitigation Measures AIR -1 and AIR -2, the resulting aggregate daily emissions may not be reduced to levels below the SCAQMD thresholds should multiple structural BMP projects be constructed concurrently. Thus, construction -related air quality impacts associated with the proposed program would be considered significant and unavoidable. Therefore, as pollutants for which the Basin is in nonattainment (i.e., ozone, PMtg, and PM2,5) associated with the proposed program could exceed SCAQMD's respective thresholds for construction, these pollutant emissions would, in conjunction with other past, current, and probable future projects, be cumulatively considerable, and cumulative impacts would be significant and unavoidable. With respect to operational emissions, program implementation would not result in substantial long-term regional emissions of criteria air pollutants and would not exceed the SCAQMD thresholds of significance for criteria pollutants. As such, the proposed program's operational emissions would not be cumulatively considerable and cumulative air quality impacts would be less than significant. Mitigation Measures: Implement Mitigation Measures AIR -1 through AIR -2 Significance After Mitigation: Significant and unavoidable for construction; less -than - significant for operations. (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.2-10.) Non -Structural (Institutional) BMPS As discussed in Chapter 2.0, Project Description, non-stmctural/institutional BMPS do not include the construction of new facilities. Consequently, no cumulative air quality impacts in the Basin would result. Mitigation Measures: None required Significance Determination: No impact IA County Flood Control District 3.2-24 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality Sensitive Receptors Impact 3.24: The project could expose sensitive receptors to substantial pollutant concentrations. Structural (Regional, Centralized, and Distributed) BMPs Construction and operation of new developments that would occur under the proposed program could potentially expose sensitive receptors in the EWMP areas of the County to localized air quality impacts from criteria pollutants and TACs. Separate discussions are provided below analyzing the potential for sensitive receptors to be exposed to these pollutant sources. Carbon Monoxide Hotspots A CO hotspot is an area of localized CO pollution that is caused by severe vehicle congestion on major roadways, typically near intersections. Projects may worsen air quality if they increase the percentage of vehicles in cold start modes by two percent or more; significantly increase traffic volumes (by five percent or more) over existing volumes; or worsen traffic flow, defined for signalized intersections as increasing average delay at intersections operating at Level of Service (LOS) E or F or causing an intersection that would operate at LOS D or better without the project, to operate at LOS E or F. While construction -related traffic on the local roadways would occur during construction of each structural BMP project, the net increase of construction worker vehicle trips to the existing traffic volumes on the local roadways would be relatively small and would not result in CO hotspots. Additionally, the construction -related vehicle trips would only occur in the short-term, and would cease once construction activities for a structural BMP project has been completed. Thus, because trip -generating land uses are not associated with the proposed program and the amount of maintenance visits to the structural BMP sites would be minimal, impacts associated with CO hotspots would be less than significant and no mitigation is required. Mitigation Measures: None required Significance Determination: Less than significant Localized Construction Air Quality Impacts — Criteria Air Pollutants The EWMP areas associated with the proposed program are located in multiple jurisdictions within the County of Los Angeles, all of which are located within in the Basin. Given that the majority of the County is highly urbanized with a variety of land use types and that the proposed program would be located in various watersheds across the County that span multiple jurisdictions, existing sensitive uses such as residences, schools, hospitals, daycare centers, etc., would be located within and in proximity to the EWMP areas. During construction of the individual structural BMP projects in the EWMP areas, existing sensitive receptors that happen to be located adjacent to or near these structural BMP construction sites could be exposed to significant adverse localized air quality impacts. According to SCAQMD's localized significance IA County Flood Control District 3.2-25 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality threshold (LST) methodology, projects greater than 5 acres in size should perform air quality dispersion modeling to determine whether construction activities would cause or contribute to adverse localized air quality impacts. Where projects would be less than 5 acres in size, the SCAQMD provides screening tables that can be used to determine the maximum allowable daily emissions that would satisfy the LSTs without project -specific dispersion modeling. LSTs represent the maximum emissions from a project that will not cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standard. According to SCAQMD's LST methodology, LSTs are only applicable to the on-site construction emissions that are generated by a project and do not apply to emissions generated off-site such as mobile emissions on roadways from worker, vendor, and haul truck trips. SCAQMD has indicated, in its 2003 Final Localized Significance Threshold Methodology document, that LSTs are applicable to projects at the project -specific level and are not intended for regional projects.3 Given the large geographic area associated with the project, an LST analysis would not be applicable to this PEIR. Depending on the size and scale of a particular structural BMP project and the intensity of the construction effort that would be required, the construction emissions generated by a new structural BMP project could potentially cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standards at the existing sensitive uses located in the vicinity of that project. For individual structural BMP projects that would fit this scenario, Mitigation Measure AIR -3 would be implemented, which requires a project -level LST analysis to be prepared to demonstrate that the construction emissions of a structural BMP project would not exceed SCAQMD's LSTs or result in pollutant emissions that would cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standards.4 With implementation of Mitigation Measures AIR -3, this impact would be reduced to less than significant. For smaller BMPs, including distributed BMPs, air emissions would not be significant and would not require mitigation measures. Mitigation Measures: AIR -3: For large construction efforts associated with regional or centralized BMPs, implementing agencies shall conduct a project -specific LST analysis where necessary to determine local health impacts to neighboring land uses. Where it is determined that construction emissions would exceed the applicable LSTs or the most stringent applicable federal or state ambient air quality standards, the structural BMP project shall reduce its daily construction intensity (e.g., reducing the amount of equipment used daily, reducing the amount of soil graded/excavated daily) to a level where the structural BMP project's construction emissions would no longer exceed SCAQMD's LSTs or result in pollutant Page 1-1 of SCAQMD's 2003 Final Localized Significance Threshold Methodology document. As discussed previously, the LSTs for NOx, CO, PMig, and PM2.5 provided in SCAQMD's screening tables represent the maximum emissions from a project that will not cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standard for those respective pollutants. For projects that are less than 5 acres, the SCAQMD's LST screening tables can be used to determine whether construction -related emissions would result in a potential significant air quality impact. For projects that exceed 5 acres in size, dispersion modeling should be conducted, per SCAQMD's LST methodology, to determine whether the most stringent applicable federal or state ambient air quality standards for pollutants would be exceeded, which would result in a significant air quality impact. IA County Flood Control District 3.2-26 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality emissions that would cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standards. Significance Determination: Less than significant with mitigation. (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.2- 10.) Localized Construction Air Quality Impacts — Toxic Air Contaminants Intermittent construction activities occurring throughout the program area over the implementation period of the individual structural BMPs would result in short-term emissions of diesel particulate matter, which is a TAC. During construction of each individual structural BMP project within the EWMP areas, the exhaust of off-road heavy-duty diesel equipment would emit diesel particulate matter during general construction activities, such as site preparation (e.g., excavation, grading, and clearing); materials transport and handling; structural BMP construction; and other miscellaneous activities. Similar to the localized criteria pollutant emissions during construction, the short-term emissions of diesel particulate matter associated with each structural BMP development would only affect its own remote group of existing sensitive receptors that are located nearby. SCAQMD has not adopted a methodology for analyzing such impacts and has not recommended that health risk assessments be completed for construction -related emissions of TACs. The dose to which receptors are exposed is the primary factor used to determine health risk (i.e., the potential exposure to TACs to be compared to applicable standards). Dose is a function of the concentration of a substance or substances in the environment and the duration of exposure to the substance. Dose is positively correlated with time, meaning that a longer exposure period would result in a higher exposure level for the maximally exposed individual. Thus, the risks estimated for a maximally exposed individual are higher if a fixed exposure occurs over a longer period of time. According to the Office of Environmental Health Hazard Assessment (OEHHA), health risk assessments, which determine the exposure of sensitive receptors to TAC emissions, should be based on a 70 -year exposure period; however, such assessments should be limited to the period or duration of activities associated with each of the future individual structural BMP development occurring in the EWMP areas under the proposed program. The construction period for any individual structural BMP that would occur in the EWMP areas under the proposed program would be finite and much less than the 70 -year period used for risk determination. Because off-road heavy-duty diesel equipment would be used only temporarily at each individual structural BMP site, the construction activities associated with each structural BMP project in the EWMP areas would not expose sensitive receptors to substantial emissions of TACs. This impact would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Operational Sources of Toxic Air Contaminants Implementation of the program, which would involve the installation of structural control measures that would be constructed as BMPs to reduce the impact of stormwater and non- stormwater on receiving water quality, would not result in new land uses in the EWMP areas. IA County Flood Control District 3.2-27 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality Operation of the structural BMPs would not involve TAC -emitting equipment, as the majority of the structural BMPs would operate passively without the use of mechanized equipment. While some of the centralized and regional structural BMPs may require the use of pump stations and associated components, such equipment would be electrically driven and would not result in direct emissions at the individual structural BMP sites. Therefore health risks from TAC emissions associated with project operations would not occur. Mitigation Measures: None required Significance Determination: No impact Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, no impacts associated with exposure of sensitive receptors to substantial pollutant emissions would result. Mitigation Measures: None required Significance Determination: No impact Objectionable Odors Impact 3.2-5: The proposed program could create objectionable odors affecting a substantial number of people, Structural (Regional, Centralized, and Distributed) BMPs According to the SCAQMD CEQA Air Quality Handbook, land uses associated with odor complaints typically include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding. The project does not include any uses identified by the SCAQMD as being associated with odors. During the construction phases for each of the new structural BMP projects that would occur in the EWMP areas over the course of the implementation period, exhaust from construction equipment may produce discernible odors typical of most construction sites. Such odors would be a temporary source of nuisance to adjacent uses, but because they are temporary and intermittent in nature, would not be considered a significant environmental impact. Therefore, impacts associated with objectionable odors during construction would be less than significant. Although rainfall in Southern California is limited to certain times of year, and most drainage channels are dry for most of the year, some structural BMPs may involve retaining intermittent stonnwater or dry weather flows on a site that may result in organic odors as water levels fluctuate and decomposition occurs in saturated mud. Restored creeks and estuaries may be permanently wet, resulting in odors from saturated mud or algal blooms. Standing water may emit odors if algal blooms occur for periods of time before the water dries or percolates. If these facilities are near sensitive receptors such as residential areas, these odors may result in a severe nuisance, particularly during night time hours. Regular maintenance may be sufficient to reduce IA County Flood Control District 3.2-28 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality odors in some situations. Mitigation Measure AES -2 requires implementing agencies to prepare and implement maintenance plans for all BMPs installed. Implementation of Mitigation Measure AIR -4 promotes the consideration of odors when siting BMP locations and types. Mitigation Measure: Implement Mitigation Measure AES -2 AIR -4: During planning of structural BMPs, implementing agencies shall assess the potential for nuisance odors to affect a substantial number of people. BMPs that minimize odors shall be considered the priority when in close proximity to sensitive receptors. Significance Determination: Less than significant. (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.2-10.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, no impacts associated with objectionable odors would result. Mitigation Measures: None required Significance Determination: No impact IA County Flood Control District 3.2-29 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.2 Air Quality 302.4 Summary of Impact Assessment Table 3.2-10 shows a summary of the structural BMPs requiring mitigation. TABLE 3.2-10 SUMMARY OF AIR QUALITY IMPACTS REQUIRING MITIGATION MEASURES Thresholds of Significance Structural BMPs Applicable Mitigation Measures: Air Quality Plan None Required Air Quality Standards AIR -1; AIR -2 Nonattainment Criteria Pollutants AIR -1; AIR -2 Sensitive Receptors AIR -3 Objectionable Odors AES -2; AIR -4 Regional BMPs Regional Detention and No Yes Yes Yes Yes Infiltration Regional Capture, Detention No Yes Yes Yes Yes and Use Centralized BMP Bioinfiltration No Yes Yes Yes Yes Constructed Wetlands No Yes Yes Yes Yes Treatment/Low-Flow Diversions No Yes Yes Yes Yes Creek, River, Estuary No Yes Yes Yes Yes Restoration Distributed BMPs Site -Scale Detention No No No No Yes LID— Infiltration/Filtration BMPs No No No No Yes — Porous Pavement, Green Streets, Bioswale/Filter Strips, Downspout Disconnects LID— Green Infrastructure— No No No No Yes Capture and Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes Flow-through Treatment BMPs No No No No Yes Source -Control Treatment BMPs No No No No Yes (catch basin inserts/screens, hydrodynamic separators, gross solids removal devices) Low -Flow Diversions No No No No Yes NOTE: These conclusions are based on typical BMP size and location. IA County Flood Control District 3.2-30 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.3 Biological Resources This section establishes the existing conditions and provides an evaluation of potential impacts to biological resources associated with the proposed program. 3.3.1 Environmental Setting The 12 Enhanced Watershed Management Program (EWMP) areas are each located within Los Angeles County (County), which exhibits native habitats corresponding with the California Floristic Province. The County experiences a mediterranean climate, which is generally characterized by relatively heavy winter precipitation and dry summers. The County encompasses the intersection of the Transverse and Peninsular mountain ranges, supporting a variety of habitats within mountain ranges, broad alluvial valleys, deserts, and coastal shorelines. Los Angeles County hosts one of the most dense and populous urban metropolises in the country, which has substantially altered the native habitats. However, within the mountainous areas and some drainage areas, native habitats still remain. Habitat Types The EWMP areas contain an array of coastal habitats such as: marine, intertidal, estuarine, coastal salt marsh, and beach dunes; freshwater aquatic habitat such as marshes, lakes, and ponds; riverine aquatic habitat including streambeds and associated riparian areas; and upland communities such as coastal sage scrub, chaparral, foothill woodlands, and coniferous forests in the mountains. The dominant native plant community in Los Angeles County is chaparral (Los Angeles County, 2012a). In general, communities that are relatively undisturbed and have connectivity to other open space areas function as higher -quality habitat for sensitive plants and wildlife. Non-native, disturbed, and/or isolated habitats generally provide lower -quality wildlife habitat, though some sensitive plants and wildlife are known to occur in such areas. Habitats within the EWMP Areas The proposed program comprises12 EWMP areas, each with a disparate mix of urban development and natural habitat features. Although diverse habitats may occur throughout the County and within each of the EWMP areas to varying degrees, the following summaries combine EWMP groups into the following six distinct watershed groups that have similar habitat types: 1. Southern Coastal EWMP Watersheds (Beach Cites, Peninsula, Southern Santa Monica Bay, Marina del Rey, Ballona, Peninsula) — These watersheds are dominated by urbanized inland and beach communities with high-density residential and commercial land uses throughout the watersheds. Sensitive habitats in these areas include coastal drainages, coastal lagoons, and dune scrub. However, the most of the drainages in these watersheds have been channelized with hard -bottom channels such as Ballona Creek and provide minimal habitat value to sensitive species. Most of the coastal creeks have been rechannelized and are largely underground with some exceptions in the Peninsula EWMP. The value of riparian and aquatic resources in these urbanized areas is generally low except for some key exceptions, including the Del Rey Lagoon and Ballona Lagoon IA County Flood Control District 3.3-1 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources and wetlands where the Ballona Creek watershed meets the coast. Figure 3.3-1 provides photographs of typical drainages in the watershed. 2. Dominguez Channel (Dominueez Channel EWMP) — This watershed is characterized by high-density inland communities and an industrial shoreline. Much of the drainages are urbanized and underground or otherwise concrete -lined, with notable exceptions such as Machado Lake. The Dominguez Channel is tidally influenced but is a man-made rip -rap or concrete -lined channel. Some vegetation occurs in localized drainages and some tributary drainages are being restored for wetland values. However, outside of the restoration areas and recreation features (such as Machado Lake), habitat values in this urban and industrial area are low. Figure 3.3-2 provides photographs of typical drainages in the watershed. 3. Northern Coastal EWMP Watersheds (Malibu and Upper Santa Monica Bay) — These watersheds are characterized by dense residential development along the coast and less development and greater open space areas inland along the coast mountain range. Sensitive habitats in these areas are more prevalent than in the more urbanized watersheds, including coastal lagoons and dunes, streams and riparian habitats, and upland forests and scrub. Receiving waters in these watersheds remain unlined with significant riparian corridors. The developed areas have lower -density developments than in the Southern Coastal watersheds and are interspersed with canyons and creeks. The coastal streams provide important habitat for sensitive species, including arroyo toad, native fish, and avian species found in riparian forests. Figure 3.3-3 provides photographs of typical drainages in the watershed. 4. Upper Los Angeles River Watershed — This watershed traverses a large diverse area of the Los Angeles Basin characterized by dense urbanization. The predominant urbanization results in limited biological value in the watershed. The natural hydrology of the Los Angeles River watershed has been altered by channelization and the construction of dams and flood control reservoirs. The Los Angeles River and many of its tributaries are lined with concrete for most or all of their length. Soft -bottomed segments of the Los Angeles River occur where groundwater upwelling prevents armoring of the river bottom. Numerous soft -bottom tributary streams feed into the river from the mountainous perimeter. Because of persistent dry -weather flows caused by irrigation run off and wastewater treatment plant discharges, vegetation within these drainages is common. The Los Angeles County Flood Control District routinely clears the vegetation from most of the vegetated drainages under permits from the U.S. Army Corps of Engineers (USACE) and California Department of Fish and Wildlife (CDFW). However, several stream segments exhibiting high-value habitats remain throughout this watershed, including Compton Creek and Bull Creek. When not cleared for flood control purposes, these areas can develop into substantial riparian habitats supporting sensitive species such as least Bell's vireo and southwest flycatcher as well as other diverse ecological communities. Lower in the watershed where perennial flows are substantial because of wastewater discharges, aquatic habitats occur that support waders, ducks, and gulls. Figure 3.3-4 provides photographs of typical drainages in the watershed. IA County Flood Control District 3.3-2 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Typical concrete -lined Ballona Creek segment near Culver City. F7 Fresh water marsh in Playa Del Rey, adjacent to Ballona Creek. SOURCE: ESA LA County PEIR EWMP. 140474 Figure 3.3-1 Typical Drainages in the Southern Coastal EWMP Watersheds Typical Dominguez Channel segment near Hawthorne. Dominguez Channel wetlands near Long Beach. SOURCE: ESA LA County PEIR EWMP. 140474 Figure 3.3-2 Typical Drainages in the Dominguez Channel Watershed Management Areas I I 81p � Showing aquatic and riparian habitat in concrete channeled Los Angeles River, near the Los Angeles Zoo. Showing riparian habitat in Bull Creek, near Van Norman Lakes Complex. SOURCE: ESA LA County PEIR EWMP. 140474 Figure 3.3-4 Typical Drainages in the Upper Los Angeles River Watershed 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources 5. Upper San Gabriel and Rio Hondo and Watersheds – These watersheds are characterized by high-density development in the lower watershed areas and lower - density development and open space in the upper watersheds in the San Gabriel Mountain foothills. Sensitive habitats in these areas range from sparse riparian areas and scrub within drainages in the urbanized lower watersheds to pristine mountain forests and riparian corridors the San Gabriel Mountains. The San Gabriel River and Rio Hondo are unlined in the upper watershed and convey controlled non -storm and storm flows to recharge basins and downstream sections of the river. Habitats within the soft -bottom river channels consist of chaparral and sage scrub with occasional riparian willow and sycamore riparian vegetation accustomed to long periods of dry weather with occasional ephemeral water flows. Upwelling of groundwater and dry -weather flows combine to support substantial riparian vegetation in the Whittier Narrows area. Figure 3.3-5 provides photographs of typical drainages in the watershed. 6. Upper Santa Clara River Watershed – The Santa Clara River watershed is distinctive in that it is predominantly open space—nearly 90 percent of the watershed is open space with approximately 88 percent being undeveloped. The watershed contains one of the last remaining natural rivers in Southern California. In years of significant rainfall, ephemeral springs and year-round flows exist in some tributaries and natural upstream areas. The river is ephemeral in the upper watershed, experiencing groundwater -induced flows near Santa Clarita, and then wastewater treatment discharges create a perennial flow from Valencia to the Ventura County border. Habitat values in these areas are high, including extremely rare habitat for aquatic resources such as the three -spired stickleback, Santa Ana sucker, and arroyo toad. Figure 3.3-6 provides photographs of typical drainages in the watershed. Sensitive Habitats The California Natural Diversity Database (CNDDB), managed by CDFW, identifies 20 natural communities of special management concern within the broad -ranging EWMP areas, as shown below. Appendix D contains a description of each of these habitats and Figure 3.3-7 depicts their locations throughout the EWMP areas. • California Walnut Woodland • Canyon Live Oak Ravine Forest • Mainland Cherry Forest • Open Engelmann Oak Woodland • Riversidean Alluvial Fan Sage Scrub • Southern California Arroyo Chub/ Santa Ana Sucker Stream • Southern California Coastal Lagoon • Southern California Steelhead Stream • Southern Coast Live Oak Riparian Forest, • Southern California Threespine Stickleback Stream • Southern Coastal Bluff Scrub • Southern Coastal Salt Marsh • Southern Cottonwood Willow Riparian Forest • Southern Dune Scrub • Southern Mixed Riparian Forest • Southern Riparian Scrub • Southern Sycamore Alder Riparian Woodland • Southern Willow Scrub • Valley Oak Woodland • Walnut Forest a County Flood Control District 3.3-7 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report A, t Typical Upper San Gabriel River landscape. Drainage in Whittier Narrows, showing aquatic and riparian habitats SOURCE: ESA LA County PEIR EWMP. 140474 Figure 3.3-5 Typical Drainages in the Upper San Gabriel and Rio Hondo Watersheds 1Ir�11 i Drainage in Whittier Narrows, showing aquatic and riparian habitats SOURCE: ESA LA County PEIR EWMP. 140474 Figure 3.3-5 Typical Drainages in the Upper San Gabriel and Rio Hondo Watersheds Unlined river channel showing riparian habitat in Upper Santa Clara River. L Typical riparian and aquatic habitat in Upper Santa Clara River. SOURCE: ESA LA County PEIR EWMP. 140474 Figure 3.3-6 Typical Drainages in the Upper Santa Clara River Watershed Ventura / Ir li f -Y u, -N O EWMP Boundary Natural Cerebra lea California Walnut Woodland -Canyon Live Oak Ravine Forest �Mainland Cherty, Forest _ Open Engelmann Oak Woodland _ Rlversidian Allowing Fen Sage Scrub - Scud em California Arroyo Chub/Santa Sucker Stream - Southern California Coastal Lagoon - SouMem Courtrai Threespine Sluldeback Stream - SruMem Coast Live Oak Riparian Forest - souMem Coastal Bluff Scrub -Southern Coastal San Marsh _ SouMem Cotlonwcotl Willi Riparian Forest _ Southend Dune Scrub SruMem Mixed Riparian Forest -Southend Riparian Forest - Southern Sycamore Aber Riparian Woodland -SouMem Willow scrub -Valley Oak WOM6nt -Walnut Forest SOURCE: ESRI; California Natural Diversity Database (Cl 2014. Kern %7r�8rf ri l if - San Bernardino sixp 9 Orange r 0 T 8 Miles LA County PEIR EWMP. 140474 Figure 3.3-7 Natural Communities 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources Special -Status Species Special -status species are those plants and animals that, because of their recognized rarity or vulnerability to habitat loss or population decline, are recognized by federal, state, or other agencies. Some of these species receive specific protection that is defined by federal or state endangered species legislation. Others have been designated as "sensitive" on the basis of adopted policies and expertise of state resource agencies or organizations with acknowledged expertise, or policies adopted by local governmental agencies such as counties, cities, and special districts to meet local conservation objectives. These species are referred to collectively as "special -status species" and include the following categories: • Plants or animals listed or proposed for listing as threatened or endangered under the federal Endangered Species Act (FESA) (50 Code of Federal regulations [CFR] 17.12 [listed plants], 17.11 [listed animals] and various notices in the Federal Register [FR] [proposed species]) • Plants or animals that are candidates for possible future listing as threatened or endangered under FESA (61 FR 40, February 28, 1996) • Plants or animals listed or proposed for listing by the State of California (State) as threatened or endangered under the California Endangered Species Act (CESA) (14 California Code of Regulations [CCR] 670.5) • Plants listed as rare or endangered under the California Native Plant Protection Act (California Fish and Game Code, Section 1900 et seq.) • Plants that meet the definitions of rare and endangered under the California Environmental Quality Act (CEQA) (CEQA Guidelines Section 15380) • Plants considered under the California Native Plant Society (CNPS) to be "rare, threatened or endangered in California" (Lists IA, 1B, and 2 in CNPS 2014) • Plants listed by CNPS as plants about which more information is needed to determine their status and plants of limited distribution (Lists 3 and 4 in CNPS 2014), which may be included as special -status species on the basis of local significance or recent biological information • Animals fully protected in California (California Fish and Game Code, Sections 3511 [birds], 4700 [mammals], and 5050 [reptiles and amphibians]) • Plants or animals covered by a locally or state adopted species conservation plan, including sensitive plants and animals and narrow endemic plants that have reasonable potential to occur on-site The database search yielded 72 plant species and 83 wildlife species within the EWMP area and immediate vicinity (CNDDB 2014). Special -status species are typically supported by native upland and riparian habitats, but they can also inhabit disturbed and urbanized areas. Appendix E contains a list of special -status species found within the combined EWMP areas and a figure that depicts their locations. IA County Flood Control District 3.3-11 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources Wildlife Movement Habitat linkages are contiguous areas of open space that connect two larger habitat areas. Linkages provide for both diffusion and dispersal for a variety of species within the landscape. In addition, linkages can serve as primary habitat for some smaller species. Corridors are linear linkages between two or more habitat patches. Corridors provide for movement and dispersal, but do not necessarily include habitat capable of supporting all life history requirements of a species. Wildlife movement corridors are critical for the survivorship of ecological systems for several reasons. Corridors can connect water, food, and cover sources, spatially linking these three resources with wildlife in different areas. In addition, wildlife movement between habitat areas provides for the potential of genetic exchange between wildlife species populations, thereby maintaining genetic variability and adaptability to maximize the success of wildlife responses to changing environmental conditions. This is especially critical for small populations subject to loss of variability from genetic drift and effects of inbreeding. The nature of corridor use and wildlife movement patterns varies greatly among species. Jurisdictional Resources Wetlands and permanent and intermittent drainages, creeks, and streams identified as waters of the United States are subject to the jurisdiction of USACE and Regional Water Quality Control Board (RWQCB) under Section 404 and Section 401, respectively, of the Federal Clean Water Act. All of the rivers and flood control drainages that flow to the ocean within the EWMP area are within the jurisdiction of these agencies. Streambeds are subject to regulation by the CDFW under Section 1602 of the California Fish and Game Code. A stream is defined under these regulations as a body of water that flows at least periodically or intermittently through a bed or channel having banks and that supports fish or other aquatic life. This definition includes watercourses having a surface or subsurface flow that supports or has supported riparian vegetation. CDFW jurisdiction typically extends to the edge of the riparian vegetation canopy. 3.3.2 Regulatory Setting Federal Federal Endangered Species Act The U.S. Fish and Wildlife Service (USFWS) administers the federal Endangered Species Act (FESA) that provides a process for listing species as either threatened or endangered, and methods of protecting listed species. Species are listed as either endangered or threatened under Section 4 of the FESA that defines "endangered" as any plant or animal species that is in danger of extinction throughout all or a significant portion of its range and "threatened" if a species is likely to become endangered in the foreseeable future. Section 9 of the FESA prohibits take of listed threatened or endangered species. Except as provided in Sections 7 and 10 of the FESA, take of listed threatened or endangered species is prohibited. The term "take" means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in such conduct. Harm under the definition of take includes disturbance or loss of habitats used by a IA County Flood Control District 3.3-12 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources threatened or endangered species during any portion of its life history. Under the regulations of the FESA, the USFWS may authorize take when it is incidental to, but not the purpose of, an otherwise lawful act. Pursuant to the FESA, USFWS and National Marine Fisheries Service (NMFS) have designated critical habitat for several endangered and threatened species within Los Angeles County. Critical habitat is identified as a specific geographic area that contains features essential for the conservation of a threatened or endangered species and that may require special management and protection. Critical habitat may include an area that is not currently occupied by the species but that will be needed for its recovery (USFWS, 2014a). Figure 3.3-8 identifies federally designated critical habitats in the County. Migratory Bird Treaty Act The Migratory Bird Treaty Act (MBTA) of 1918 (16 U.S.C. 703-711) makes it unlawful to possess, buy, sell, purchase, barter or take any migratory bird listed in Title 50 of the Code of Federal Regulations Part 10. Take in the context of the MBTA is the possession or destruction of migratory birds, their nests or eggs. Disturbances that causes nest abandonment and/or loss of reproductive effort or the loss of habitats upon which these birds depend would be in violation of the MBTA. Although impacts to migratory birds are highly unlikely because of the disturbed nature of the proposed project's site locations, the applicant will be required to either avoid impacts to migratory birds and their nests, or to obtain a permit from the USFWS providing for the take of a migratory bird. Should the nesting of any migratory bird occur on or adjacent to the project site during grading or construction activities, a USFWS-qualified biological monitor would have the authority to halt all work activities and notify the city and corresponding resource agency. Clean Water Act Section 404 Wetlands are generally considered to be areas that are periodically or permanently inundated by surface or ground water and support vegetation adapted to life in saturated soil. Wetlands are recognized as important features on a regional and national level because of their high inherent value to fish and wildlife, use as storage areas for stormwater and floodwater, and water recharge, filtration, and purification functions. Technical standards for delineating wetlands have been developed USACE which generally define wetlands through consideration of three criteria: hydrology, soils, and vegetation. Under Section 404 of the Clean Water Act (CWA), USACE is responsible for regulating the discharge of dredged or fill material into waters of the United States. The term "waters" includes wetlands and non -wetland bodies of water that meet specific criteria as defined in the Code of Federal Regulations. All three of the identified technical parameters (hydrology, soils, and vegetation) must be met for an area to be identified as a wetland under USACE's CWA Section 404 jurisdiction, unless the area has been modified by human activity. In general, a permit must be obtained before the discharge of dredged or fill material can be placed in wetlands or other waters of the United States. USACE, at its discretion, issues several types of permits (Nationwide, Individual, or General) depending on the acreage and purpose of discharge of fill or dredged material into waters of the United States. a County Flood Control District 3.3-13 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report iiL Ventura .c• Kern u. Waster n Western snowy Tidewater gob snowy plover plover g. Western �p snowy p O EWMP Boundary plover ® Significant Ecological Areas (SEA) Critical Habitat Western snowy Arroyo (=anoyo southwestern) toad plover - California condor - California red -legged frog - Coastal California gnatcatcher Palos Verdes - Desert tortoise blue butterfly i Least Bell's vireo Palos Verdes Mountain yellow -legged frog blue buttarfly - Palos Verdes blue butterfly - Santa Ana sucker Tidewater goby Western snowy plover SOURCE: ESRI; Los Angeles County GIS; FWS, 2014. 0 1 San Bernardino Orange 0 It a Mlles LA County PEIR EWMP. 140474 Figure 3.3-8 Los Angeles County Significant Ecological Areas and Critical Habitat 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources State California Endangered Species Act The CDFW administers the CESA. The State of California considers an endangered species one whose prospects of survival and reproduction are in immediate jeopardy. A threatened species is one present in such small numbers throughout its range that it is likely to become an endangered species in the near future in the absence of special protection or management. And a rare plant species is one present in such small numbers throughout its range that it may become endangered if its present environment worsens. Except as provided in CESA Section 2081, State threatened, endangered, and candidate species are protected against take, which under the CESA is restricted to direct killing or harm of individual animals and does not apply to the loss of habitat as it does under FESA. Clean Water Act Section 401 Certification or Waiver, and State Discharge Permit under the Porter -Cologne Act The State of California regulates water quality related to discharge of fill material into waters of the State pursuant to Section 401 of the CWA. Section 401 compliance is a federal mandate regulated by the State. The local RWQCBs have jurisdiction over all those areas defined as jurisdictional under Section 404 of the CWA. Where a 404 permit is required, a 401 water quality certification from the RWQCB is also required. In addition, the State regulates water quality for all waters of the State, that may also include isolated wetlands as defined under the California Porter -Cologne Water Quality Control Act (Porter Cologne; Ca. Water Code, Div. 7, Section 13000 et seq.). The State 401 Certification Program regulates all discharges that can affect water quality, even if there is no significant nexus to a traditional navigable water body required for USACE determination of jurisdiction over waters of the United States. In such instances, a Waste Discharge Permit is required even though federal CWA Section 401 water quality certification or 404 permits are not required. Section 1602 Lake and Streambed Alteration Agreement Jurisdictional authority of the CDFW over the bed, bank, or channel of a river, stream, or lake is established under Section 1600 et seq. of the Fish and Game Code, which pertains to activities that would disrupt the natural flow or alter the channel, bed, or bank of any lake, river, or stream. The Fish and Game Code stipulates that it is unlawful to substantially divert or obstruct the natural flow or substantially change the bed, channel or bank of any river, stream, or lake resulting in a substantial effect on a fish or wildlife resource without notifying the CDFW and completing the Streambed Alteration Agreement process. Fish and Game Code of California All birds, and raptors specifically, and their nests, eggs, and parts thereof are protected under Sections 3503.5 of the Fish and Game Code of California. Disturbance that causes nest abandonment and/or loss of reproductive effort (e.g., killing or abandonment of eggs or young) is considered a violation of this code. Additionally Section 3513 prohibits the take or possession of any migratory nongame bird listed by the MBTA. a County Flood Control District 3.3-15 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources Non -Listed Species Management and Conservation Concerns Species of Special Concern is an informal designation used by CDFW for some declining wildlife species that are not proposed for listing as threatened or endangered. This designation does not provide legal protection, but signifies that these species are recognized as declining by CDFW. The CNPS has developed an inventory of California's sensitive plant species. This inventory summarizes information on the distribution, rarity, and endangerment of California's vascular plants. The inventory is divided into four lists based on the rarity of the species. In addition, the CNPS provides an inventory of plant communities that are considered natural communities of special concern by the State and federal resource agencies, academic institutions, and various conservation groups. The determination of the level of significance of impacts on plant species and natural communities is based on the number and size of remaining occurrences as well as recognized threats. Natural communities of special concern are those that support concentrations of special -status plant or wildlife species, are of relatively limited distribution, or are of particular value to wildlife. Natural communities of special concern are not afforded legal protection unless they are designated critical habitat for federally listed threatened or endangered species, support formally listed species, or are jurisdictional wetland habitats. Local Los Angeles County Significant Ecological Areas As part of the General Plan Conservation/Open Space and Land Use elements, the County has identified and adopted policies for Significant Ecological Areas (SEAs). The purpose of establishing a SEA is to maintain biological diversity by establishing natural biological parameters, including species, habitat types, and linkages. The County General Plan includes recommended management practices for each SEA. Forty-eight SEAS fall within the EWMP area, as shown in Figure 3.3-7. Santa Monica Mountains Conservancy The Santa Monica Mountains Conservancy was established by the California State Legislature in 1980. The Conservancy's mission is to preserve and restore natural habitats in Southern California to form an interlinking system of parks and wildlife habitats that are easily accessible to the general public. The Conservancy's Comprehensive Plan outlines conservation priorities and recreational opportunities in the Santa Monica Mountains. Development projects in the Santa Monica Mountains area subject to review by the County for consistency with the Comprehensive Plan. Los Angeles County Oak Tree Ordinance and City Tree Preservation Ordinances Title 22, Part 16, of the Los Angeles County Code of Ordinances is the Oak Tree Ordinance. The ordinance was established to recognize oak trees within the County as a historical, aesthetic, and ecological resource. The ordinance applies to all unincorporated areas of the County. Several cities within the County may have adopted this or a similar ordinance. The Los Angeles County IA County Flood Control District 3.3-16 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources ordinance, in particular, prohibits a person to "cut, destroy, remove, relocate, inflict damage, or encroach into the protected zone of any tree of the oak genus" that is 8 inches or more in diameter. Other city ordinances, such as the City of Los Angeles, may protect other tree species in addition to oaks. Los Angeles County Oak Woodland Management Plan Los Angeles County adopted a California Oak Woodlands Conservation Management Plan pursuant to the requirements of Assembly Bill (AB) 242 in 2011. The Los Angeles County Oak Woodlands Conservation Management Plan provides consistent policy for the management of oak woodlands that can be incorporated into the Los Angeles County General Plan and other relevant planning documents, developing a comprehensive and cohesive strategy for dealing with loss, and creating opportunities for recovering oak woodlands. 3.3.3 Impact Assessment Thresholds of Significance To determine the level of significance of an identified impact, the criteria outlined in the CEQA Guidelines were used. CEQA Guidelines Section 15065 directs lead agencies to find that a project may have a significant effect on the environment if it has the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of an endangered, rare, or threatened species, or eliminate important examples of the major periods of California history or prehistory. CEQA Guidelines Section 15206 further specifies that a project shall be deemed to be of statewide, regional, or area -wide significance if it would substantially affect sensitive wildlife habitats including, but not limited to, riparian lands, wetlands, bays, estuaries, marshes, and habitats for rare and endangered species as defined by the Fish and Game Code Section 903. CEQA Guidelines Section 15380 provides that a plant or animal species, even if not on one of the official lists, may be treated as `rare or endangered" if, for example, it is likely to become endangered in the foreseeable future. Additional criteria to assess significant impacts to biological resources due to the proposed project are specified in CEQA Guidelines Section 15382 (Significant Effect on the Environment) "...a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project including land, air, water, minerals, fora, fauna, ambient noise, and objects of historic or aesthetic significance." Appendix G of the CEQA Guidelines indicates that a project would have a significant impact on biological resources if it would: • Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special -status species in local or regional plans, policies, or regulations, or by the CDFG or USFWS. • Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the CDFG or USFWS. a County Flood Control District 3.3-17 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources • Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, veinal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. • Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. • Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. • Conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan. Project Impact Discussion Impact 3.3-1: The proposed project could have a substantial adverse effect, either directly or through habitat modifications, on any sensitive species identified as special -status in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service. Structural (Regional, Centralized, and Distributed) BMPs Construction Construction of structural Best Management Practices (BMPs) would occur primarily within high-density urban, commercial, industrial, and transportation areas where they will either replace or improve upon existing stormwater infrastructure. Construction typically requires the permanent removal of aboveground infrastructure and/or surface materials such as asphalt and concrete, as well as excavation and grading for projects on soil -covered sites. The majority of the construction impact area would occur within developed and disturbed areas adjacent to existing infrastructure that do not support native vegetation or undisturbed habitat. However, since most of the BMPs would be located in existing drainages, each individual BMP could affect riparian vegetation during installation. Most of the smaller BMPs would avoid impacting high-value habitats during construction. Upland scrubs and native oak forests would be only incidentally affected if at all. In stream effects could occur to riparian scrub and aquatic habitats. Construction of structural BMPs, regional and centralized BMPs in particular, may affect large open space or riparian habitats that would have a higher potential to support special -status wildlife species. For example, centralized BMPs include the construction of stream/creek restoration projects and low -flow diversion (LFD) projects which may require working within or adjacent to sensitive communities (i.e., streams or wetlands) that could support special -status wildlife species. Large projects could affect upland scrub or oak woodlands. Mitigation Measure 13I0-1 requires that implementing agencies evaluate the suitability of potential BMP sites for their potential to impact valued habitats such as oak woodland and riparian willow forests. Common and protected migratory birds and raptors are likely to nest or forage in habitats found within the EWMP area. Implementation of the structural BMPs may result in temporary or permanent loss of foraging habitat for migratory birds, including raptor species. Similarly, IA County Flood Control District 3.3-18 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources proposed construction activities could impact nesting birds or roosting bats. Potential bat roost sites in the vicinity of the project areas may include abandoned structures and bridges. Mitigation Measures BIO -2 through BI0-8 require impact characterization, minimization and compensation for impacts to highly valued habitats in consultation with the USFWS and CDFW. Implementation of mitigation measures requiring careful consideration of suitable sites would reduce impacts to natural habitats on a regional scale to less -than -significant levels. Operation Maintenance of BMPs may involve accessing drainages through habitat areas or clearing vegetation. If BMPs require routine maintenance that affects habitat, those activities would need to be conducted in the non -bird nesting season to avoid impacts to nesting birds where feasible. Since drainages are within the CDFW jurisdiction, any vegetation -clearing activities would be subject to permits from CDFW as well as potentially the Los Angeles RWQCB and USACE. These permits would include provisions to avoid and mitigate impacts to sensitive habitats and species. Adherence to these conditions of approval would ensure that impacts to natural resources from maintenance would be less than significant. BMPs designed to retain peak storm flows including regional BMPs would have no impact on downstream biological resources, since peak storm flows do not support perennial vegetation. The natural hydrology of the region experiences ephemeral flows that respond to seasonal precipitation, conveying water from the upper watersheds to the lower watersheds quickly. Urbanization has increased the speed of water flows through the system. The BMPs are designed to slow water flows and return to a hydrology closer to predevelopment conditions. However, some drainages have developed new perennial flow regimes that support vegetation as a result of landscape runoff or wastewater discharges. Some of this vegetation may support special -status species including least Bell's vireo or southwest willow flycatcher, particularly in suburban areas. If BMPs designed to retain dry -weather flows reduced the wetted area of drainages or completely eliminated flows in certain drainages that support riparian habitat, impacts to sensitive species would be significant. This potential effect is most likely to occur within suburban areas, which are more prevalent in the Santa Clara River watershed, Malibu watershed, and San Gabriel watershed. The more urbanized watersheds in the southern coastal areas, such as Dominguez Channel and Ballona Creek, would be less likely to experience impacts to riparian vegetation from low -flow retention, with some noted exceptions such as the Ballona wetlands. The primary threat to the local ecology in Los Angeles County is urban development. Returning the local hydrology to a more natural condition would occur over time and would result in improved natural habitat functions with little direct impact to protected sensitive species. Although riparian habitat may flourish in certain urban drainages, the vegetation is often a nuisance. Many soft -bottom channels are periodically cleared of vegetation by the Los Angeles County Flood Control District under a permit from the USFWS and CDFW that requires compensation elsewhere in the watershed. The reduction in perennial flows in most channels may a County Flood Control District 3.3-19 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources result in less "choking" of flood control channels with nuisance vegetation, resulting in flood control benefits. Furthermore, in many cases, it is difficult to attribute the health and extent of a wetted area supporting vegetation to specific Municipal Separate Storm Sewer System (MS4) discharge points. Individual BMP installation may reduce flows, but not eliminate wetted areas supporting certain habitat areas, resulting in no immediate observed reduction in riparian cover. Over time, the addition of BMPs into suburban watersheds may reduce vegetation within certain drainages slowly as the cumulative effects of multiple BMPs combine to limit dry -weather flows. The gradual reduction in habitat would allow sensitive species to adapt to the changing conditions, particularly avian species such as least Bell's vireo would relocate to other nesting areas as conditions change. This is not dissimilar to natural conditions where riparian areas change over time with large flood flows. Although this gradual decrease in dry -weather flows in the region may reduce riparian vegetation in certain locations, the overall reduction is not expected to be significant, since the high-value habitats are limited and largely dependent on groundwater or wastewater treatment discharges. Nonetheless, to ensure that impacts to downstream biological resources are less than significant, Mitigation Measure BIO -1 requires that implementing agencies evaluate the potential direct impacts that could result from dry -weather flow reduction to downstream habitats. These conditions may be most prevalent in the Santa Clara River watershed, Malibu Watershed, the Upper Los Angeles River Watershed, and San Gabriel River Watershed where suburban landscape irrigation runoff has created isolated patches of riparian vegetation. Mitigation Measures 11I0-2 and BIO -4 would require consultation with the wildlife agencies if flow reduction resulted in significant downstream habitat impacts. However, on a regional scale, a return to a more natural hydrology is not expected to significantly reduce the prevalence of high- value habitats or their use by sensitive species in the County. With implementation of Mitigation Measures BIO -1, BIO -2 and BIO -4, impacts to riparian vegetation from flow retention would be less than significant. Future project -level environmental review processes will consider proposed projects as necessary to determine project -level impacts on special -status wildlife species and will require the implementation of project -specific mitigation measures to minimize and reduce potentially significant impacts to special -status wildlife species. Where potentially significant impacts to biological resources are identified for individual projects, implementation of Mitigation Measures BIO -1 through BIO -8 would avoid or reduce the impact to a less than significant level. Summary of EWMP Groups The following discussion provides additional detail to each of the watershed groups: Southern Coastal EWMP Watersheds (Beach Cites, Southern Santa Monica Bay, Peninsula, Marine del Rey, Ballona) — Few direct impacts to biological resources from construction would be expected in these watersheds since the drainages are largely channelized. Large-scale lagoon restoration projects would temporarily affect habitats within the construction zones, but the IA County Flood Control District 3.3-20 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources objective of these projects is to enhance biological functions. Otherwise, the urbanized drainages in these areas exhibit low -quality habitats and any work on the beach that could affect sensitive avian species would be minimal. LFI)s and dry -weather flow retention in this EWMP area would result in less fresh water reaching the tidal areas than is currently the case. However, at the lower end of the watershed, impacts to riparian and aquatic resources would be minimal since the areas are highly urbanized and the drainages are channelized with low habitat value. An exception to this is the Ballona freshwater marsh. Reduction in dry -weather flows to the coastal lagoons would reduce pollutant loading from the watershed and as a result improve water quality and native habitat values compared to existing conditions. In the upper portion of the watersheds, the reduction of perennial flows in drainages could affect urban -influenced low -value habitats. However, if these habitats were of sufficient value to support least Bell's vireo or other sensitive species, mitigation may be required. Implementation of mitigation measures BIO -1 through BIO -8 would reduce impacts to less -than -significant levels. Northern Coastal EWMP Watersheds (Malibu and Upper Santa Monica Bay) — Installation of structural BMPs within drainages could affect existing habitats and sensitive species, particularly in the upper drainages that are largely undeveloped and exhibit high habitat values. Implementation of mitigation measures BIO -1 through BIO -8 would ensure that implementing agencies identify potentially affected resources and implement measures to avoid or reduce impacts to less -than -significant levels. Once installed, the modification to the hydrology created by the BMPs would more closely resemble historical conditions. LFI)s in the upper watersheds would return local coastal creeks to conditions resembling pre - urbanization. Native habitats along the coast have adapted to the climatological conditions and would continue to thrive with implementation of dry -weather -flow diversions and flow retention. However, in some localized areas, flow diversions could affect downstream riparian and aquatic habitat, reducing fresh water flow and wetted areas inhabited by willow forests. However, much of the high-value riparian and aquatic habitats in the upper coastal watershed that support sensitive birds and fish are fed from natural seepage. Infiltration BMPs would augment seepage and would serve to expand wetted areas supporting riparian and wetland habitats. Implementation of mitigation measures BIO -1 through BIO -8 would reduce impacts to less -than -significant levels. Unser San Gabriel and Rio Hondo and Watersheds — Installation of structural BMPs in the upper San Gabriel and Rio Hondo watersheds have the potential to impact riparian and in -channel scrub habitats. The larger rivers are dry most of the year and habitat is adapted to the ephemeral cycle. If construction activities were to occur in an area exhibiting native vegetation, implementing agencies would need to implement measures to avoid, reduce, or compensate for significant impacts. Implementation of mitigation measures BIO -1 through BIO -8 would ensure that implementing agencies identify potentially affected resources and implement measures to avoid or reduce impacts to less -than -significant levels. IA County Flood Control District 3.3-21 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources Upper Los Angeles River Watershed — The Upper Los Angeles River watershed is large and exhibits a large variety of habitats within drainages and within surrounding uplands and mountains. If construction activities were to occur in an area exhibiting native vegetation, implementing agencies would need to implement measures to avoid, reduce, or compensate for significant impacts. However, these construction effects would be temporary and would not result in significant reduction in habitat values within the watershed. LFDs and retention in this highly urbanized watershed could result in substantial modifications to hydrologic conditions in the smaller channels and streams. Much of the higher value habitat occurs on the perimeter of the watershed and would not be affected by the BMPs. However, the vegetated channels in the mid and lower portions of the watershed could be cut off from perennial flows, resulting in a reduction of wetted area and associated habitat. Implementation of mitigation measures BIO -1 through 13I0-8 would ensure that implementing agencies identify potentially affected resources and implement measures to avoid or reduce impacts to less -than -significant levels. Dominguez Channel Watershed — These watersheds are highly urbanized, supporting little native vegetation. What vegetation does exist is associated with either the tidal channel or urban runoff. Construction within these areas would not encounter high-value upland, riparian, or aquatic habitats. Implementation of mitigation measures would ensure that impacts to habitat values would be less than significant. Low -flow and dry -weather -flow retention in the Dominguez Channel watershed would not result in significant impacts to riparian or aquatic habitats downstream since very few high-value habitats exist in the watershed. One exception to this is Machado Lake, which relies on freshwater flows to maintain vegetation. However, returning the local hydrology to a more natural condition would result in less -than -significant impacts to biological resources. Upper Santa Clara River Watershed — The Santa Clara River watershed exhibits the most open space and high-value riparian habitats of all the EWMP groups. Construction of structural BMPs could impact upland forests, scrub, riparian and aquatic habitats. If construction activities were to occur in an area exhibiting native vegetation, implementing agencies would need to implement measures to avoid, reduce, or compensate for significant impacts. In addition mitigation measure BIO -1 requires that implementing agencies evaluate the suitability of BMP locations prior to development in order to avoid impacts to sensitive habitats. LFDs and dry -weather -flow retention may affect areas downstream of urbanized areas. However, the Upper Santa Clara River is ephemeral and generally dry upstream of the wastewater discharges. Furthermore, the stream is a gaining stream below the urbanized area, responding to rising groundwater levels. Any retention of dry -weather flow would have only minor effects on the aquatic or riparian habitats in tributary streams and no impacts to the Santa Clara River itself. In fact, increased underflow into the riverbed from groundwater would benefit the riparian and aquatic habitats. In addition, implementing agencies would be required to evaluate potential impacts from flow retention BMPs. Implementation of mitigation measures would ensure that impacts are less than significant. IA County Flood Control District 3.3-22 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources Summary of Impact BMPs designed to retain dry -weather flows could reduce wetted area or completely eliminate flows in certain drainages that support sensitive species. To ensure that impacts to downstream biological resources are less than significant for regional and centralized BMPs, Permittees would implement Mitigation Measures BIO -1 through BIO -8 which provide for the identification and minimization of potential effects. As a result, impacts to sensitive species resulting from the implementation the EWMPs would be less than significant. The smaller distributed BMPs would not result in significant impacts and would not be required to implement mitigation measures. Mitigation Measures 13I0-1: Prior to approving a regional or centralized BMP, the Permittee shall conduct an evaluation of the suitability of the BMP location. Appropriate BMP sites should avoid impacting large areas of native habitats including upland woodlands and riparian forests that support sensitive species to the extent feasible. The evaluation shall include an assessment of potential downstream impacts resulting from flow diversions. BI0-2: Prior to ground -disturbing activities in areas that could support sensitive biological resources, a habitat assessment shall be conducted by a qualified biologist to determine the potential for special -status wildlife species to occur within affected areas, including areas directly or indirectly impacted by construction or operation of the BMPs. 13I0-3: If a special -status wildlife species is determined to be present or potentially present within the limits of construction activities, a qualified biologist shall conduct preconstruction surveys of proposed work zones and within an appropriately sized buffer around each area as determined by a qualified biologist within 14 days prior to ground disturbing activities. Any potential habitat capable of supporting a special -status wildlife species shall be flagged for avoidance if feasible. 13I0-4: If avoidance of special -status species or sensitive habitats that could support special -status species (including, but not limited to, critical habitat, riparian habitat, and jurisdictional wetlands/waters) is not feasible, the Permittee shall consult with the appropriate regulating agency (USACE/USFWS or CDFW) to determine a strategy for compliance with the Endangered Species Act, California Fish and Game Code, and other regulations protecting special -status species and sensitive habitats. The Permittee shall identify appropriate impact minimization measures and compensation for permanent impacts to sensitive habitats and species in consultation with regulatory agencies. Construction of the project will not begin until the appropriate permits from the regulatory agencies are approved. 13I0-5: If construction and vegetation removal is proposed between February 1 and August 31, a qualified biologist shall conduct a pre -construction survey for breeding and nesting birds and raptors within 500 -feet of the construction limits to determine and map the location and extent of breeding birds that could be affected by the project. Active nest sites located during the pre -construction surveys shall be avoided until the adults and young are no longer reliant on the nest site for survival as determined by a qualified biologist. a County Flood Control District 3.3-23 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources BIO -6: All construction areas, staging areas, and right-of-ways shall be staked, flagged, fenced, or otherwise clearly delineated to restrict the limits of construction to the minimum necessary near areas that may support special -status wildlife species as determined by a qualified biologist. BIO -7: Prior to construction in areas that could support special -status plants, a qualified botanist shall conduct a pre -construction floristic inventory and focused rare plant survey of project areas to determine and map the location and extent of special -status plant species populations within disturbance areas. This survey shall occur during the typical blooming periods of special -status plants with the potential to occur. The plant survey shall follow the CDFW Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (November 24, 2009). BIO -8: If temporary construction -related impacts to special -status plant populations are identified within a disturbance area, the implementing agencies shall prepare and implement a special -status species salvage and replanting plan. The salvage and replanting plan shall include measures to salvage, replant, and monitor the disturbance area until native vegetation is re-established under the direction of CDFW and USFWS. Significance Determination: Less than significant with mitigation. (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.3- 1.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no direct impacts to special -status species or their habitats. However, many of the non-structural BMPs would result in the reduction of dry -weather urban runoff that could reduce perennial flows in local drainages. Returning the local hydrology to a more natural condition would occur overtime and would reduce overall wetted areas within minor drainages and swales throughout the region. Local riparian and lake features that rely on urban runoff could gradually shift from riparian and marsh to upland and sparse riparian. Shorelines may shift and wetted areas may decrease over time as more water is retained in the upper watershed, but these changes would not significantly degrade biological resources in the region as a whole since the revised hydrology would be a more natural condition for the and region. Groundwater seepage would continue to support the major riparian corridors in the Malibu, Santa Clara, Upper Los Angeles, and San Gabriel watersheds. Retention of flows in the upper watershed would even augment these groundwater resources, offsetting any impacts from surface flow reductions. Moreover, improved water quality in the region's drainages and lagoons would be beneficial to habitat health. Overall, implementation of non- structural BMPs will not significantly impact sensitive species in the EWMP areas. Mitigation Measures: None required Significance Determination: Less than significant IA County Flood Control District 3.3-24 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources Riparian Habitat or Other Sensitive Natural Communities Impact 3.3-2: The proposed project could have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the CDFW or USFWS. Structural (Regional, Centralized, and Distributed) BMPs As previously discussed, 20 sensitive natural communities tracked by the CNDDB occur within the EWMP area. In addition, Significant Ecological Areas are considered sensitive natural communities as identified by the Los Angeles County General Plan. The SEAS, riparian and other sensitive communities (which include riparian habitats such as Southern Cottonwood Willow Riparian Forest) are not expected to occur within the disturbance areas of the BMP projects since the majority of the structural BMPs would occur in developed or disturbed areas. While some regional and centralized structural BMPs (i.e., floodplain management and stream restoration projects) could occur within or adjacent to SEAS, riparian habitat or other sensitive natural communities, these types of BMPs would provide multi -beneficial water quality and habitat restoration improvements to the applicable EWMP watershed. Further, each development proposed within a designated SEA must undergo a performance review process for compliance with the SEA design compatibility criteria and other standards for approval by the Los Angeles County Department of Regional Planning (County of Los Angeles 2012). In addition, future project -level environmental review processes would consider all proposed projects on a case-by-case basis to determine whether an individual project would impact riparian or other sensitive natural communities and where it is necessary, would require the implementation of site-specific mitigation measures to minimize and reduce potentially significant impacts to riparian and other sensitive natural communities. Impacts would be reduced to less -than -significant levels with the implementation of Mitigation Measures BIO -1 through 13I0-8. Mitigation Measures: Implement Mitigation Measures 13I0-1 and 13I0-8. Significance Determination: Less than significant with mitigation. (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.3- 1.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-strnctural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts to riparian or other sensitive natural communities from construction. However, many of the non-structural BMPs would result in the reduction of dry -weather urban runoff that could reduce perennial flows in local drainages. Returning the local hydrology to a more natural condition would occur overtime and would reduce overall wetted areas within minor drainages and swales throughout the region. Local riparian and lake features that rely on urban runoff could gradually shift from riparian and marsh to upland and sparse riparian. Shorelines may shift and wetted areas may decrease over time as more water is retained in the upper watershed, but these changes would not significantly degrade biological resources in the region as a whole since the revised hydrology a County Flood Control District 3.3-25 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources would be a more natural condition for the and region. Groundwater seepage would continue to support the major riparian corridors in the Malibu, Santa Clara, Upper Los Angeles, and San Gabriel watersheds. Retention of flows in the upper watershed would even augment these groundwater resources, offsetting any impacts from surface flow reductions. Moreover, improved water quality in the region's drainages and lagoons would be beneficial to habitat health. Overall, implementation of non-structural BMPs will not significantly impact riparian habitat or other sensitive natural communities in the EWMP areas. Mitigation Measures: None required Significance Determination: No impact Wetland Habitats Impact 3.3-3: The proposed project could have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means, Structural (Regional, Centralized, and Distributed) BMPs Construction through areas within or adjacent to waterways (creeks, stream, reservoir) or wetland features would require approval from one or more of the following: USACE, RWQCB, or CDFW. Wetlands occur throughout the EWMP Areas ranging from isolated segments of improved urban channels to the open river segments of the Santa Clara, Los Angeles, and San Gabriel Rivers. Once project facility locations and designs are determined, exact locations and acreages of jurisdictional areas located within or adjacent to impact areas shall be determined through a formal jurisdictional delineation. For projects impacting native vegetation within jurisdictional drainages, the implementing agency would be required to obtain California Fish and Game Code Section 1602 compliance and Section 404 compliance from the USACE and Section 401 Certification from the RWQCB. In addition, implementation of Mitigation Measures BIO -1 through 13I0-9 would ensure compliance with state and federal regulations relating to potentially jurisdictional features, including wash habitat vegetation that may fall under CDFW jurisdiction. Mitigation Measures Implement Mitigation Measures BIO -1 through 13I0-8. BIO -9: Prior to construction, a qualified wetland delineator shall be retained to conduct a formal wetland delineation in areas where potential jurisdictional resources (i.e., wetlands or drainages) subject to the jurisdiction of USACE, RWQCB, and CDFWmay be affected by the project. If jurisdictional resources are identified in the EWMP area and would be directly or indirectly impacted by individual projects, the qualified wetland delineator shall prepare a jurisdictional delineation report suitable for submittal to USACE, RWQCB, and IA County Flood Control District 3.3-26 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources CDFW for purposes of obtaining the appropriate permits. Habitat mitigation and compensation requirements shall be implemented prior to construction in accordance with Mitigation Measure 13I0-4. Significance Determination: Less than significant with mitigation. (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.3- 1.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts to wetlands or other jurisdictional features from construction. Non-structural BMPs would result in a reduction of urban dry -weather surface flows that currently may support wetlands. Returning the local hydrology to a more natural condition would occur overtime. Local wetland features that rely on urban runoff could gradually become non -hydric, resulting in a reduction in wetlands in the region. However, their functions as ephemeral water ways would not be reduced, but rather would reflect the more natural condition afforded by the Southern California climate. The revised hydrology would not result in a reduction of waters of the United States. Moreover, the retained water infiltrated into the ground would augment the shallow groundwater that serves to support local wetlands and riparian habitats. Increased groundwater seepage would increase the extent of wetlands and wetted areas and on a regional scale offset any reduction caused by surface flow reductions. Implementation of BMPs would ensure compliance with the CWA requiring MS4s to reduce dry - weather flows in this region. Although compliance with Section 402 of the CWA may result in a reduction of wetlands in the region supported by surface flow, the infiltration of surface water into the ground would offset the potential impact, resulting in no net loss and a less -than - significant impact to wetlands. Mitigation Measures: None required Significance Determination: No impact Wildlife Movement Impact 3.3-4: The proposed project could interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. Structural (Regional, Centralized, and Distributed) BMPs There are no established wildlife movement corridors within the EWMP area as described within the Los Angeles County General Plan directly affected by implementation of the EWMPs. While portions of the EWMP areas are located within the linkage design for the San Gabriel-Castaic and Santa Monica -Sierra Madre connections, implementation of structural BMPs would primarily be constructed within existing stormwater facilities or disturbed areas. Furthermore, the EWMPs a County Flood Control District 3.3-27 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources would not reduce open water features used by migratory birds or reduce fresh water flows that support sensitive fish species. Implementation of the EWMP would not be expected to interfere with wildlife movement or any migratory corridor/linkage, and would not be constructed within a native wildlife nursery site. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts related to the movement of any native resident or migratory fish or wildlife species, or with established native resident or migratory wildlife corridors. Mitigation Measures: None required Significance Determination: No impact Local Policies or Ordinances Impact 3.3-5: The proposed project could conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. Structural (Regional, Centralized, and Distributed) BMPs The proposed project would mainly be constructed within highly urbanized and disturbed areas within existing infrastructure. Any impacts to oak trees within Los Angeles County would be required to comply with the Oak Tree Preservation Ordinance (or other tree ordinances established by the local city). A tree permit may be required if impacts to oak trees or other protected trees are determined to be necessary. No impacts to oak trees or other protected tree species is anticipated. However, the exact locations of the BMP projects have not been established. Implementation of Mitigation Measure BIO -10 would reduce any potential impacts to protected tree species to a less -than -significant level. Mitigation Measure BIO -10: Oak trees and other protected trees shall be avoided to the extent feasible. If trees may be impacted by project construction, a certified arborist shall conduct a tree inventory of the construction impact area. If any oak trees or other protected trees will be impacted by BMP construction, the implementing agency shall obtain any required County or City permits. Significance Determination: Less than significant with mitigation. (The application of this mitigation measures to specific BMP types and categories are identified in Table 3.3-1.) IA County Flood Control District 3.3-28 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts related to conflicts with local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. Mitigation Measures: None required Significance Determination: No impact Adopted Habitat Conservation Plans Impact 3.3-6: The proposed project could conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan. Structural (Regional, Centralized, and Distributed) BMPs The EWMP areas are not located within an adopted federal or state habitat conservation plan area, but 48 SEAS are located within the boundary of the EWMP area (Figure 3.3-1). In addition, the County Oak Woodland Management Plan covers habitats that exist within some EWMPs. The SEAS and Oak Woodland Management Plan provide protection to many of the sensitive natural communities and special -status species within the County; however, the majority of the structural 13MPs would occur in developed or disturbed areas that are expected to be outside of adopted SEAS. As previously discussed, while some regional and centralized structural BMPs (i.e., floodplain management and stream restoration projects) could occur within or adjacent to SEAS, these types of BMPs would provide multi -beneficial water quality and habitat restoration improvements to the applicable EWMP watershed. Further, each development proposed within a designated SEA must undergo a performance review process for compliance with the SEA design compatibility criteria and other standards for approval by the Los Angeles County Department of Regional Planning (County of Los Angeles 2012). Therefore, conflicts with the management policies for each SEA are not anticipated, and impacts would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant. Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts related to conflicts with an adopted habitat conservation plan or the Los Angeles County General Plan. Mitigation Measures: None required Significance Determination: No impact a County Flood Control District 3.3-29 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs BMPs would be constructed throughout the EWMP watersheds. Most of the distributed BMPs would be small in scale and would not result in cumulatively significant impacts, as they would occur within existing developed or disturbed areas at existing stormwater infrastructure/facilities. For regional and centralized BMPs at the larger scale, Mitigation Measures 13I0-1 through 13I0- 10 would reduce potentially significant impacts to biological resources, and any additional or more site-specific mitigation measures developed during the future project -level environmental review processes may further reduce potential impacts. Cumulatively, throughout the region, the retention of stormwater and treatment of pollutants within each watershed, and the reduction of pollutant loading in waterways would substantially benefit the water quality of the region's aquatic and coastal habitats, as well as the plants and wildlife dependent on them. Implementation of the BMPs would also return the local hydrology to a more natural condition. Much of the vegetation supported by urban runoff within these EWMP areas as discussed above is cleared to ensure sufficient flood control function of the channels. In addition, the majority of high-value habitats in the region rely on groundwater seepage rather than perennial urban runoff. Although some drainage segments may exhibit reduced riparian habitat or wetlands over time due to the reduced dry -weather flow, the cumulative effect would be offset by increased groundwater recharge and seepage supporting expanded wetland and riparian vegetation supporting local flora and fauna populations. Therefore, the program's potential contribution to cumulative effects on biological resources is considered less than significant. Implementation of BMPs would ensure compliance with Section 402 of the CWA that requires MS4s to reduce dry -weather flows in this region. Although compliance with Section 402 of the CWA may result in a reduction of wetlands in the region supported by surface flow, the infiltration of surface water into the ground would offset the potential impact, resulting in a less than significant cumulative impact to biological resources in the region. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPS As discussed previously, cumulatively, throughout the region, the retention of stormwater and treatment of pollutants within each watershed, and the reduction of pollutant loading in waterways would substantially benefit the water quality of the region's aquatic and coastal habitats, as well as the plants and wildlife dependent on them. Although some drainage segments may exhibit reduced riparian habitat or wetlands over time due to the reduced dry -weather flow, the cumulative effect would be offset by increased groundwater recharge and seepage supporting expanded wetland and riparian vegetation supporting local flora and fauna populations. IA County Flood Control District 3.3-30 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources Therefore, the program's potential contribution to cumulative effects on biological resources is considered less than significant. Mitigation Measures: None required Significance Determination: Less than significant IA County Flood Control District 3.3-31 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.3 Biological Resources 3.3.4 Summary of Impact Assessment Table 3.3-1 shows a summary of the structural BMPs requiring mitigation. TABLE 3.3.1 SUMMARY OF BIOLOGICAL RESOURCE IMPACTS REQUIRING MITIGATION MEASURES Structural BMPs Sensitive Sensitive Wetland Species Habitats Habitats Thresholds of Significance Local Habitat Wildlife Policies and Conservation Movement Ordinances Plans Cumulative Impacts Low -Flow Diversion No No No No No No No NOTE: These conclusions are based on typical sizes and locations of BMPs. IA County Flood Control District 3.3-32 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report BI0-1 BIO -1 BIO -1 Applicable Mitigation through through through None None Measures., 810-8 BIO -8 BIO -9 Required BIO -10 None Required Required Regional BMIPS Regional Retention and Yes Yes Yes No No No Yes Infiltration Regional Capture, Yes Yes Yes No No No Yes Detention and Use Centralized BMPs Bioinfiltration Yes Yes Yes No No No Yes Constructed Wetlands Yes Yes Yes No No No Yes Treatment/LFDs Yes Yes Yes No No No Yes Creek, River, Estuary Yes Yes Yes No No No Yes Restoration Distributed BNPs Site Scale Detention Yes Yes Yes No No No Yes LID— No No No No No No No Infiltration/Filtration BMPs — Porous Pavement, Green Streets, Bioswale/Filter Strips, downspout disconnects LID — Green No No No No No No No Infrastructure — Capture and Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes Flowthrough No No No No No No No Treatment BMPs Source Control No No No No No No No Treatment BMPs (catch basin inserts/screens, hydrodynamic separators, gross solids removal devices) Low -Flow Diversion No No No No No No No NOTE: These conclusions are based on typical sizes and locations of BMPs. IA County Flood Control District 3.3-32 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3A Cultural Resources This chapter addresses the potential impacts of the proposed program on cultural resources. Cultural resources include prehistoric and historic sites, structures, districts, places, and landscapes, or any other physical evidence associated with human activity considered important to a culture, a subculture, or a community for scientific, traditional, religious, or any other reason. Under the California Environmental Quality Act (CEQA), paleontological resources, although not associated with past human activity, are grouped within cultural resources. For the purposes of this analysis, cultural resources may be categorized into the following groups: archaeological resources, historic resources (including architectural/engineering resources), contemporary Native American resources, human remains, and paleontological resources. Archaeological resources are places where human activity has measurably altered the earth or left deposits of physical remains. Archaeological resources may be either prehistoric -era (before European contact) or historic -era (after European contact). The majority of such places in California are associated with either Native American or Euro -American occupation of the area. The most frequently encountered prehistoric or historic Native American archaeological sites are village settlements with residential areas and sometimes cemeteries; temporary camps where food and raw materials were collected; smaller, briefly occupied sites where tools were manufactured or repaired; and special -use areas like caves, rock shelters, and rock art sites. Historic -era archaeological sites may include foundations or features such as privies, corrals, and trash dumps. Historic resources include standing structures, infrastructure, and landscapes of historic or aesthetic significance that are generally 50 years of age or older. In California, historic resources considered for protection tend to focus on architectural sites dating from the Spanish Period (1529-1822) through World War II (WWII) and Post War—era facilities. Some resources, however, may have achieved significance within the past 50 years if they meet the criteria for exceptional significance. Historic resources are often associated with archaeological deposits of the same age. Contemporary Native American resources, also called ethnographic resources, can include archaeological resources, rock art, and the prominent topographical areas, features, habitats, plants, animals, and minerals that contemporary Native Americans value and consider essential for the preservation of their traditional values. These locations are sometimes hard to define and traditional culture often prohibits Native Americans from sharing these locations with the public. Paleontology is a branch of geology that studies the life forms of the past, especially prehistoric life forms, through the study of plant and animal fossils. Paleontological resources represent a limited, nonrenewable, and impact -sensitive scientific and educational resource. As defined in this section, paleontological resources are the fossilized remains or traces of multicellular invertebrate and vertebrate animals and multicellular plants, including their imprints from a previous geologic period. Fossil remains such as bones, teeth, shells, and leaves are found in the geologic deposits (rock formations) where they were originally buried. Paleontological resources IA County Flood Control District 3.4-1 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources include not only the actual fossil remains, but also the collecting localities, and the geologic formations containing those localities. 3.401 Environmental Setting Cultural Resources Part of the program area is located in the Los Angeles Basin. The basin is formed by the Santa Monica Mountains to the northwest, the San Gabriel Mountains to the north, and the San Bernardino Mountains and San Jacinto Mountains to the east. The basin was formed by alluvial and fluvial deposits derived from these surrounding mountains. Prior to urban development and the channeling of the Los Angeles River, much of the program area was likely covered with marshes, thickets, dense woodland, and grassland. Historically, the Los Angeles River originated from a spring near what is present-day Encino. The river flowed eastward from Encino through the southern portion of the San Fernando Valley near the foot of the Santa Monica Mountains before turning southeast at what is present-day Griffith Park (Gumprecht, 2001). From there, it flowed to the Pacific Ocean along a frequently shifting course, sometimes flowing south to empty into San Pedro Bay near Long Beach, sometimes flowing west to the Santa Monica Bay along the course of what is present-day Ballona Creek. In its natural state, the river's flow meandered dramatically, narrowed and widened intermittently, and even returned underground completely in certain locations. The floodplain forest of the Los Angeles Basin formed one of the most biologically rich habitats in Southern California. Willow, cottonwood, and sycamore and dense underbrush of alder, hackberry, and shrubs once lined the Los Angeles River as it passed near what is present-day downtown Los Angeles (Gumprecht, 2001). Although historically most of the Los Angeles River was dry for at least part of the year, shallow bedrock in the Elysian Park area north of what is present-day downtown forced much of the river's underground water to the surface. This allowed for a steady year-round flow of water through the area that later became known as downtown Los Angeles (Gumprecht, 2001). Prehistory The abundant and diverse environmental resources of the coastal Los Angeles basin have attracted human inhabitants from the earliest times. The prehistory of the region has been summarized within four major horizons or cultural periods: Early, Millingstone, Intermediate, and Late Prehistoric (Wallace, 1955). The Early period covers the interval from the first presence of humans in Southern California until post -glacial times. While people are known to have inhabited Southern California beginning at least 13,000 years Before Present (B.P.) (Arnold et al., 2004), the first evidence of human occupation of the Los Angeles area dates to at least 9,000 B.P. These occupations are associated with a period known as the Millingstone Cultural Horizon (7,000-4,000 B.P) (Wallace, 1955; McIntyre, 1990). Departing from the subsistence strategies of their nomadic big -game hunting predecessors, Millingstone populations established more permanent settlements. Settlements were located primarily on the coast and in the vicinity of estuaries, lagoons, lakes, streams, and marshes where a variety of resources, including seeds, fish, shellfish, small mammals, and birds, IA County Flood Control District 3.4-2 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources were exploited. Early Millingstone occupations are typically identified by the presence of handstones (manos) and millingstones (metates), while those Millingstone occupations dating later than 5,000 B.P. contain a mortar and pestle complex as well, signifying an increased dependence on new food sources, such as acorns and starchy tubers. Although many aspects of Millingstone culture persisted, by 3,500 B.P., a number of socioeconomic changes occurred (Wallace, 1955; McIntyre, 1990). These changes are associated with the period known as the Intermediate Horizon (3,500-1,500 B.P.) (Wallace, 1955). Increasing population size necessitated the intensified use of existing terrestrial and marine resources (Erlandson, 1994). This was accomplished in part through use of the circular shell fishhook on the coast and more abundant and diverse hunting equipment. The Intermediate Horizon marks a period in which specialization in labor emerged, trading networks became an increasingly important means by which both utilitarian and non -utilitarian materials were acquired, and travel routes were extended. Archaeological evidence suggests that the margins of rivers, marshes, and swamps within the Los Angeles River drainage, with their rich variety of resources, served as locations of prehistoric settlement and travel during this period. Settlement around the Ballona Lagoon increased significantly during this period (Altschul et al., 2003). The Late Prehistoric Period, spanning from approximately 1,500 years B.P. to the Spanish mission era, witnessed an increase in terrestrial and sea mammal hunting, along with continued seed collecting (Wallace, 1955). Small projectile points indicate the use of the bow and arrow. Although the location of Late Period villages does not significantly change, the villages become larger in size and fewer in number (McIntyre, 1990). Inter -village and inter -regional trade increased, and there is evidence for the use of shell beads as a form of money in economic exchanges. Ethnographic Background Tataviam The northern part of the program area is located within the territory traditionally occupied by the Tataviam. Tataviam territory was concentrated along the upper reaches of the Santa Clara River drainage between the San Fernando Valley on the south and Pastoria Creek in the Tehachapi Mountains to the north. Their territory also included east Pira Creek and the southern slopes of Sawmill and Liebre Moutains, and also extended into the southern end of the Antelope Valley (King and Blackburn, 1978). There are few historical sources regarding the Tataviam. The word "Tataviam" most likely came from a Kitanemuk word that may be roughly translated as "people of the south -facing slope," because of their settlement on south -facing mountain slopes (King and Blackburn, 1978). What the Tataviam called themselves is not known. The Tataviam spoke a language that was part of the Takic branch of the Uto-Aztecan language family (King and Blackburn, 1978). The language was related to that spoken by the Gabrielino-Tongva. Tataviam villages varied in size from larger centers with as many as 200 people, to smaller villages with only a few families (King and Blackburn, 1978). At the time of Spanish contact, the IA County Flood Control District 3.4-3 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources Tataviam population is estimated to have been less than 1,000. Primary vegetable food sources included acorns, juniper berries, seeds, and yucca buds. Small game such as antelope and deer supplemented these foods. Trade networks between inland groups such as the Tataviam, the coastal regions, and desert regions enabled the trade of exotic materials such as shell, asphaltum, and steatite. Gabrielino-Tongva The southern portion of the program area is located in a region traditionally occupied by the Takic-speaking Gabrielino-Tongva Indians. The term "Gabrielino" is a general term that refers to those Native Americans who were administered by the Spanish at the Mission San Gabriel Arcangel. Many contemporary Gabrielino identify themselves by the name "Tongva." Prior to European colonization, the Gabrielino-Tongva occupied a diverse area that included: the watersheds of the Los Angeles, San Gabriel, and Santa Ana rivers; the Los Angeles basin; and the islands of San Clemente, San Nicolas, and Santa Catalina (Kroeber, 1925). The Gabrielino language, like the Tataviam language, was part of the Takic branch of the Uto-Aztecan language family. The Gabrielino-Tongva Indians were hunter -gatherers and lived in permanent communities located near the presence of a stable food supply. Community populations generally ranged from 50 to 100 inhabitants, although larger settlements may have existed. The Gabrielino-Tongva are estimated to have had a population numbering around 5,000 in the precontact period (Kroeber, 1925). Villages are reported to have been the most abundant in the San Fernando Valley, the Glendale Narrows area north of downtown, and around the Los Angeles River drainage (Gumprecht, 2001). Maps produced by early explorers indicate that at least 26 Gabrielino villages were within close proximity to known Los Angeles River courses, while an additional 18 villages were within reasonably close proximity to the river (Gumprecht, 2001). Subsistence consisted of hunting, fishing, and gathering. Small terrestrial game were hunted with deadfalls, rabbit drives, and by burning undergrowth, while larger game such as deer were hunted using bows and arrows. Fish were taken by hook and line, nets, traps, spears, and poison (Bean and Smith, 1978). The primary plant resources were the acorn, gathered in the fall and processed in mortars and pestles, and various seeds that were harvested in late spring and summer and ground with manos and metates. The seeds included Chia and other sages, various grasses, and islay or holly -leafed cherry. Coming ashore on Santa Catalina Island in October of 1542, Juan Rodriguez Cabrillo was the first European to make contact with the Gabrielino-Tongva; the 1769 expedition of Gaspar de PortolA also passed through Gabrielino-Tongva territory (Bean and Smith, 1978). Native Americans suffered severe depopulation and their traditional culture was radically altered after Spanish contact. Nonetheless, Gabrielino-Tongva descendants still reside in the greater Los Angeles and Orange County areas and maintain an active interest in their heritage. IA County Flood Control District 3.4-4 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources Historic Setting Spanish Period (A.D. 1769-1821) Although Spanish explorers made brief visits to the region in 1542 and 1602, sustained contact with Europeans did not commence until the onset of the Spanish Period. In 1769 Gaspar de Portola led an expedition from San Diego, passing through Los Angeles Basin, San Fernando Valley, and Santa Clarita Valley on its way to the San Francisco Bay (McCawley, 1996). This was followed in 1776 by the expedition of Father Francisco Garces (Johnson and Earle, 1990). In the late 18th century, the Spanish began establishing missions in California and forcibly relocating and converting native peoples. Two missions were located in the vicinity of the program area: Mission San Gabriel Arcangel, founded in 1771, and Mission San Fernando Rey de Espana, founded in 1797. Gabrielino-Tongva Indians were primarily sent to Mission San Gabriel to be baptized, although some were also baptized at Mission San Fernando. By 1820, most of the Tataviam population had been baptized at Mission San Fernando (California Missions Resource Center, 2012). Disease and hard labor took a toll on the native population in California; by 1900, the Native Californian population had declined by as much as 90 percent (Cook, 1978). In addition, native economies were disrupted, trade routes were interrupted, and native ways of life were significantly altered. In an effort to promote Spanish settlement of Alta California, Spain granted several large land concessions from 1784 to 1821. At this time, unless certain requirements were met, Spain retained title to the land (State Lands Commission [SLC], 1982). Over 70 Spanish land grants were made within Los Angeles County. On September 4, 1781, El Pueblo de la Reina de los Angeles was established not far from the site where Portola and his men camped during their 1769 excursion. The original pueblo consisted of a central square surrounded by 12 houses and a series of agricultural fields (Gumprecht, 2001). Mexican Period (A.D. 1821-1848) The Mexican Period began when Mexico won its independence from Spain in 1821. Mexico continued to promote settlement of California with the issuance of land grants. In 1833, Mexico began the process of secularizing the missions, reclaiming the majority of mission lands and redistributing them as land grants. Many ranchos continued to be used for cattle grazing by settlers during the Mexican Period. Hides and tallow from cattle became a major export for Californios (native Hispanic Californians) (Pitt, 1994; Starr, 2007). After Mexico gained its independence, the city of Los Angeles became the capital of the California territory in 1835. But few visited the area and the town remained a "sleepy agricultural village" until the Gold Rush in 1848 (Gumprecht, 2001). American Period (A.D. 1848 -present) In 1846, the Mexican -American War broke out. Mexican forces were eventually defeated in 1847 and Mexico ceded California to the United States as part of the Treaty of Guadalupe Hildalgo in 1848. California officially became one of the United States in 1850. IA County Flood Control District 3.4-5 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources The County of Los Angeles was established on February 18, 1850, as one of the 27 original counties, several months before California was admitted to the Union on September 9, 1850. It derived its name from the community of Los Angeles, which was designated the County seat. Parts of the county's territory were given to San Bernardino County in 1853, to Kern County in 1866 and to Orange County in 1889 (County of Los Angeles, 2014). When the discovery of gold in Northern California was announced in 1848, a huge influx of people from other parts of North America flooded into California. The increased population provided an additional outlet for California cattle. As demand increased, the price of beef skyrocketed and California reaped the benefits. However, a devastating flood in 1861, followed by droughts in 1862 and 1864, led to a rapid decline of the cattle industry; over 70 percent of cattle perished during these droughts (McWilliams, 1949; Dinkelspiel, 2008). This event, coupled with the burden of proving ownership of their lands, caused many Californians to lose their lands during this period (McWilliams, 1949). Former ranchos were subsequently subdivided and sold for agriculture and residential settlement. The first transcontinental railroad was completed in 1869, connecting San Francisco with the eastern United States. Newcomers poured into Northern California. Southern California experienced a trickle-down effect, as many of these newcomers made their way south. The Southern Pacific Railroad extended this line from San Francisco to Los Angeles in 1876. The second transcontinental line, the Santa Fe, was completed in 1886 and caused a fare war, driving fares to an unprecedented low. Settlers flooded into the region and the demand for real estate skyrocketed. As real estate prices soared, land that had been farmed for decades outlived its agricultural value and was sold to become residential communities. The subdivision of the large ranchos took place during this time (Meyer, 1981; McWilliams, 1949). The city of Los Angeles would experience its greatest growth in the 1880s when two more direct rail connections to the East Coast were constructed. The resulting fare wars led to an unprecedented real estate boom. Despite a subsequent collapse of the real estate market, the population of Los Angeles increased 350 percent from 1880 to 1890 (Dinkelspiel, 2008). From 1890 to 1900, the city continued to grow, and many infrastructure projects were completed during this decade (McWilliams, 1949). E.L. Doheny discovered oil in 1892, adding fuel to the flame, and the population doubled by 1900. From 1900 to 1920, Los Angeles became a tourist mecca (McWilliams, 1949). The Los Angeles Aqueduct was constructed and a large portion of the San Fernando Valley annexed to the city during the first decade of the 20th century. From 1920 to 1930, Los Angeles experienced another population explosion, due in part to the automobile and the development of the movie industry. During the first three decades of the 20th century, more than two million people moved to Los Angeles County, transforming it from a largely agricultural region into a major metropolitan area with a population of 2.8 million within the city of Los Angeles and over 7 million within Los Angeles County by 1970 (U.S. Bureau of the Census, 1998;1995). IA County Flood Control District 3.4-6 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources Geoarchaeological Review A project's probability for encountering archaeological resources depends upon three factors: (1) original formation of an archaeological deposit, (2) post -depositional (mainly geomorphic) processes following deposition of archaeological remains, and (3) project -specific ground disturbances. The original formation of an archaeological deposit in any particular place requires a past human presence as well as behaviors that result in material culture residue. The formation of archaeological deposits is conditioned by the dynamic interaction of paleoenvironmental factors (e.g., past climate, availability of water, abundance of subsistence resources) with a culture's economic, technological, social, and other behavioral systems. As Meyer et al. (2010) have pointed out: "Archaeological deposits are not randomly distributed throughout the landscape, but tend to occur in specific geo-environmental settings." While there seems to be no commonly agreed upon set of landform characteristics for predicting locations in which archaeological sites would be expected to form, landform slope and proximity to water have been invoked as useful predictors in central California (Meyer et al., 2010) and may be relevant to the program area. Stated simply, flat landforms near permanent sources of water tend to be strongly associated with archaeological deposits, while sloping landforms that lack water tend not to have archaeological deposits (Meyer et al., 2010). Original formation of an archaeological deposit is a necessary, but not sufficient, condition to ensure that an archaeological site is still present centuries or millennia later. Post -depositional conditions must be suitable for preserving archaeological deposits for them to be discovered in the future. Geomorphological processes may work to either preserve or protect archaeological deposits, and their effects may vary depending on the specific setting. Landslides, for example, may displace and destroy archaeological sites at the top of a bluff, but may cover and protect sites at the bottom or toe of the bluff. In a similar vein, fluvial processes may erode archaeological sites along river cutbanks, but may deeply bury archaeological sites along the channel's floodplain. Absence of natural depositional forces—at the top a mountain ridgeline, for example—leave cultural materials exposed to the elements increasing their chance of destruction. Bedrock outcroppings, where little to no soil formation typically takes place, may lack sufficient matrix to cover and preserve traces of past human activity. One of the forces most capable of destroying archaeological sites is human activities. Agriculture, development of infrastructure, and urbanization especially can disturb and destroy archaeological sites, particularly surface or shallow sites, over immense areas. If the various Enhanced Watershed Management Program (EWMP) projects and approaches may be likened to different types of infrastructure development, then their potential effects to archaeological deposits can be understood in terms of human activity impacts. Program actions that would result in large areas of deep ground disturbance would have a greater probability for encountering and impacting buried archaeological deposits than approaches resulting in more limited horizontal and vertical disturbances. The program area is bounded on the northwest by the Santa Monica Mountains, on the northeast by the San Gabriel Mountains, on the southeast by the Orange County coastal plain, and on the west and southwest by the Pacific Ocean. The program area largely consists of the Los Angeles, IA County Flood Control District 3.4-7 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources Santa Clara, San Gabriel Rivers, Santa Monica Bay, and the Dominguez Channel Watersheds, and includes the Los Angeles Basin, San Fernando, and Santa Clarita Valleys. Topography varies regionally from sea level at the coast to several thousand feet in the surrounding mountains. Broadly, erosion of bedrock out of the San Gabriel and Santa Monica Mountains during the Pleistocene and Holocene has resulted in construction of a broad and recent alluvial plain (Los Angeles Basin) between the mountain foothills and the coast. With few exceptions, this plain has been heavily urbanized and modified within the last century. Tectonism and over -steepening has resulted in formation of extensive landslide zones within the mountains and foothills, and many low-lying valleys are filled with colluvium and/or alluvium. Urbanization has occurred within of these valleys, as well as overlooking ridgelines. The archaeological potential of the program area will be highly variable depending on local conditions. The low-lying alluvial plain and coastlines would be expected to have been preferred areas for past subsistence and occupation, and archaeological sites in these areas may have been subject to substantial burial. However, the extensive urbanization of these areas makes it likely that a high percentage of archaeological sites that once existed have been subject to disturbance or destruction by humans. On the other hand, while foothills and mountains may have been less favored for occupation because of their steeper slopes and more limited access to water, these areas have generally been subject to less development. Paleontological Resources The majority of the program area lies within the Los Angeles Basin, which is characterized by relatively flat (slight dip to the south) alluviated areas punctuated by tectonically uplifted highlands that drain into lower -lying areas and eventually the Pacific Ocean. It is these drainages that are, in part, responsible for the thick sequence of terrestrial sedimentary rocks that underlie much of the greater Los Angeles area and the diversity of fossils contained therein. During much of the early geological history of the program area, from the Early Miocene (approximately 23 million years before present) to the Late Pleistocene (approximately 11,000 years before present) sea level was much higher than today, and the much of the area was under water. Thick, richly fossiliferous (fossil -bearing) marine sedimentary sequences underlie much of the area, and where significant uplift has occurred because of tectonic forces, these fossil -rich rocks are exposed at the surface. The following analysis of paleontological sensitivity within the program boundaries is based on available surfrcial geological mapping, published and unpublished technical reports, published scientific journals, and the University of California Museum of Paleontology online specimen database. No museum paleontological records searches were enlisted for this analysis. Because of the large geographic area and complex geology represented by the proposed program, surfrcial geological units and paleontological resources are outlined separately by each of the five watersheds (Santa Clara River, Los Angeles River, San Gabriel River, Santa Monica Bay, and Dominguez Channel), as shown in Figure 1-1. Furthermore, igneous and metamorphic rock units are omitted from this analysis because of they have no potential to yield significant paleontological resources. IA County Flood Control District 3.4-8 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources Units are assigned a sensitivity rating based on Society for Vertebrate Paleontology (SVP) guidelines. The SVP has outlined criteria for screening the paleontological potential of rock units and has established assessment and mitigation procedures tailored to accommodating such potential. The SVP established four categories of paleontological sensitivity (potential) for rock units: high, undetermined, low, and no potential (SVP, 2010): High Potential. Rock units (or formations) in which vertebrate or significant invertebrate fossils have been found. These rock units include sedimentary and some volcanic formations that contain significant fossil resources anywhere within their geographic extent and sedimentary deposits formed in a time period or composed of materials suitable for the preservation of fossils. Only invertebrate fossils that provide new information on existing flora or fauna or on the age of a rock unit would be considered significant. Undetermined Potential. Rock units for which little information is available concerning their paleontological content, geologic age, and depositional environment are considered to have undetermined potential. Further study is necessary to determine if these rock units have high or low potential to contain significant paleontological resources. A field survey by a qualified professional paleontologist to specifically determine the paleontological resource potential of these rock units is required before a paleontological resource impact mitigation program can be developed. In cases where no subsurface data are available, paleontological potential can sometimes be determined by strategically located excavations into subsurface stratigraphy. • Low Potential. Rock units that have few, if any, records of vertebrate fossils in institutional collections, or that have been shown in surveys or paleontological literature to be largely absent of fossil resources. Low -potential rocks also include metamorphic and igneous rocks other than some volcanic rocks. • No Potential. Some rock units have no potential to contain significant paleontological resources, for instance high- grade metamorphic rocks (such as gneisses and schists) and plutonic igneous rocks (such as granites and diorites). Rock units with no potential require no protection or impact mitigation measures relative to paleontological resources. Units with no potential are not included in the following discussion. Table 3.4-1 identifies paleontologically sensitive geologic formations within the region. IA County Flood Control District 3.4-9 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources TABLE 3.4-1 PALEONTOLOGICALLY SENSITIVE GEOLOGIC UNITS/FORMATIONS WITHIN THE PROGRAM AREA Geologic Unit/Formation Sensitivity Watershed Recent Surficial Sediments (Quaternary Low, higher at depth All alluvium, slopewash) Pleistocene (Older) Alluvium and Quaternary High All Terrace Deposit Pacoima Formation Undetermined Los Angeles River La Habra Formation High San Gabriel River Saugus Formation High Santa Clara River and Los Angeles River San Pedro Sand High Los Angeles River and Santa Monica Bay Inglewood Formation Undetermined San Gabriel River Fernando Formation High Santa Clara River and Los Angeles River Pico Formation High Los Angeles River and Santa Monica Bay Modelo Formation High Los Angeles River The Towsley Formation High Santa Clara River and Los Angeles River Ridge Basin Group High Santa Clara River Sisquoc Formation High Santa Clara River and Los Angeles River Puente Formation High San Gabriel River Late Miocene Unnamed Marine Strata Undetermined Los Angeles River and Santa Monica Bay Castaic Formation High Santa Clara River The Monterey Formation High Santa Clara River Mint Canyon Formation High Santa Clara River and Los Angeles River Topanga Formation High Los Angeles River, Santa Monica Bay, and San Gabriel River Trances Formation Undetermined Santa Monica Bay Tick Canyon Formation High Santa Clara River Vasquez Formation Low Santa Clara River Sespe-Vaqueros Formations High Santa Clara River and Santa Monica Bay Uajas Formation High Los Angeles River and Santa Monica Bay Eocene Unnamed marine strata Undetermined Los Angeles River and Santa Monica Bay Santa Susana Formation High Los Angeles River and Santa Monica Bay Martinez Formation High Los Angeles River Chico Formation High Los Angeles River Chatsworth Formation High Los Angeles River SOURCES: Dibblee, 1996, 1997a, 1997b, 1997c, 1997d; Dibblee and Ehrenspeck 1989a, 1989b, 1990, 1991a, 1991b, 1991c, 1991d, 1992a, 1992b, 1992c, 1993a, 1993b, 1996a, 1996b, 1998, 1999, 2001 a, 2001 b; Dibblee at al., 1993, 1999; Dibblee and Minch, 2003, 2007; Durham at al., 1954; Evans and Miller, 1978; Fierstine at al, 2012; Groves 1991 a, 1991 b; Jennings, 1962; Kellogg, 1925, 1929; Kern, 1973; Koch at al., 1974; Mattson, 1930; Mount, 1971; Parham at al., 2003; Repenning, 1977; Smith at al., 2002; Squires, 1979, 2001; Squires at al., 2006; Stanton, 1960; Whistler, 1967; Yerkes and Campbell, 2005. IA County Flood Control District 3.4-10 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources 3,4,2 Regulatory Setting Federal, state, and local governments have developed laws and regulations designed to protect significant cultural resources that may be affected by actions that they undertake or regulate. The National Historic Preservation Act (NHPA) and CEQA are the primary federal and state laws governing preservation of historic and archaeological resources of national, regional, state, and local significance. If individual projects entail a federal nexus, such as a federal approval, federal funding, or federal property, federal historic preservation laws such as the NHPA may apply. Federal National Historic Preservation Act of 1966 Enacted in 1966, the NHPA declared a national policy of historic preservation and instituted a multifaceted program, administered by the Secretary of the Interior, to encourage the achievement of preservation goals at the federal, state, and local levels. Section 106 of the NHPA states that federal agencies with direct or indirect jurisdiction over federally funded, assisted, or licensed undertakings must take into account the effect of the undertaking on any historic property that is included in, or eligible for inclusion in, the National Register of Historic Places (NRHP) and that the ACHP must be afforded an opportunity to comment. The steps of the Section 106 process are accomplished through consultation with the State Historic Preservation Office, federally recognized Indian tribes, local governments, and other interested parties. The goal of consultation is to identify potentially affected historic properties, assess effects to such properties, and seek ways to avoid, minimize, or mitigate any adverse effects on such properties. National Register of Historic Places The NRHP was established by the NHPA of 1966, as "an authoritative guide to be used by federal, state, and local governments, private groups and citizens to identify the Nation's historic resources and to indicate what properties should be considered for protection from destruction or impairment" (Code of Federal Regulations 36 Section 60.2). The NRHP recognizes both historical -period and prehistoric archaeological properties that are significant at the national, state, and local levels. To be eligible for listing in the NRHP, a resource must be significant in American history, architecture, archaeology, engineering, or culture. Districts, sites, buildings, structures, and objects of potential significance must meet one or more of the following four established criteria (U.S. Department of the Interior, 1995): A. Are associated with events that have made a significant contribution to the broad patterns of our history. B. Are associated with the lives of persons significant in our past. C. Embody the distinctive characteristics of a type, period, or method of construction or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction. D. Have yielded, or may be likely to yield, information important in prehistory or history. IA County Flood Control District 3.4-11 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources Unless the property possesses exceptional significance, it must be at least 50 years old to be eligible for NRHP listing (U.S. Department of the Interior, 1995). In addition to meeting the criteria of significance, a property must have integrity. Integrity is defined as "the ability of a property to convey its significance" (U.S. Department of the Interior, 1995). The NRHP recognizes seven qualities that, in various combinations, define integrity: location, design, setting, materials, workmanship, feeling, and association. To retain historic integrity a property must possess several, and usually most, of these seven aspects. Thus, the retention of the specific aspects of integrity is paramount for a property to convey its significance. State California Register of Historical Resources Under the California Public Resources Code, Section 5024.19(a), the California Register of Historical Resources (CRHR) was created in 1992 and implemented in 1998 as "an authoritative guide in California to be used by State and local agencies, private groups, and citizens to identify the State's historical resources and to indicate what properties are to be protected, to the extent prudent and feasible, from substantial adverse change." Certain properties, including those listed in or formally determined eligible for listing in the NRHP and California Historical Landmarks numbered 770 and higher, are automatically included in the CRHR. Other properties recognized under the California Points of Historical Interest program, identified as significant in historical resources surveys or designated by local landmarks programs, may be nominated for inclusion in the CRHR. A resource, either an individual property or a contributor to a historic district, may be listed in the CRHR if the State Historical Resources Commission determines that it meets one or more of the following criteria, which are modeled on NRNP criteria: • Criterion 1. It is associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage. • Criterion 2. It is associated with the lives of persons important in our past. • Criterion 3. It embodies the distinctive characteristics of a type, period, region, or method of construction; represents the work of an important creative individual; or possesses high artistic values. • Criterion 4. It has yielded, or may be likely to yield, information important in history or prehistory. Furthermore, under California Public Resources Code (PRC) 5024. 1, Title 14 California Code of Regulations (CCR), Section 4852(c), a cultural resource must retain integrity to be considered eligible for the CRHR. Specifically, it must retain sufficient character or appearance to be recognizable as a historical resource and convey reasons of significance. Integrity is evaluated with regard to retention of such factors as location, design, setting, materials, workmanship, feeling, and association. IA County Flood Control District 3.4-12 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources California Historical Landmarks California Historical Landmarks (CHLs) are buildings, structures, sites, or places that have anthropological, cultural, military, political, architectural, economic, scientific or technical, religious, experimental, or other value and that have been determined to have statewide historical significance by meeting at least one of the criteria listed below. The resource also must be approved for designation by the County Board of Supervisors (or the city or town council in whose jurisdiction it is located); be recommended by the State Historical Resources Commission; and be officially designated by the Director of California State Parks. The specific standards now in use were first applied in the designation of CHL #770. CHLs #770 and above are automatically listed in the CRHR. To be eligible for designation as a landmark, a resource must meet at least one of the following criteria: • It is the first, last, only, or most significant of its type in the state or within a large geographic region (Northern, Central, or Southern California). • It is associated with an individual or group having a profound influence on the history of California. • It is a prototype of, or an outstanding example of, a period, style, architectural movement or construction or is one of the more notable works or the best surviving work in a region of a pioneer architect, designer, or master builder. California Points of Historical Interest California Points of Historical Interest (PHIS) are sites, buildings, features, or events that are of local (city or county) significance and have anthropological, cultural, military, political, architectural, economic, scientific or technical, religious, experimental, or other value. PHI designated after December 1997 and recommended by the SHRC are also listed in the CRHR. No historic resource may be designated as both a landmark and a point. If a point is later granted status as a landmark, the point designation will be retired. In practice, the point designation program is most often used in localities that do not have a locally enacted cultural heritage or preservation ordinance. To be eligible for designation as a PHI, a resource must meet at least one of the following criteria: • It is the first, last, only, or most significant of its type within the local geographic region (city or county). • It is associated with an individual or group having a profound influence on the history of the local area. • It is a prototype of, or an outstanding example of, a period, style, architectural movement or construction or is one of the more notable works or the best surviving work in the local region of a pioneer architect, designer, or master builder. IA County Flood Control District 3.4-13 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources California Environmental Quality Act CEQA is the principal statute governing environmental review of projects occurring in the state and is codified at PRC Section 21000 et seq. CEQA requires lead agencies to determine if a project would have a significant effect on the environment, including significant effects on historical or archaeological resources. Under CEQA (Section 21084. 1), a project that may cause a substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment. The CEQA Guidelines (Title 14 CCR Section 15064.4) recognize that an historical resource includes: (1) a resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the CRHR; (2) a resource included in a local register of historical resources, as defined in PRC Section 5020.1(k) or identified as significant in a historical resource survey meeting the requirements of PRC Section 5024.1(g); and (3) any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California by the lead agency, provided the lead agency's determination is supported by substantial evidence in light of the whole record. The fact that a resource does not meet the three criteria outlined above does not preclude the lead agency from determining that the resource may be an historical resource as defined in PRC Sections 5020.10) or 5024.1. If a lead agency determines that an archaeological site is a historical resource, the provisions of Section 21084.1 of CEQA and Section 15064.4 of the CEQA Guidelines apply. If a project may cause a substantial adverse change (defined as physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired) in the significance of an historical resource, the lead agency must identify potentially feasible measures to mitigate these effects (CEQA Guidelines Sections 15064.4(b)(1), 15064.4(b)(4)). If an archaeological site does not meet the historical resource criteria contained in the CEQA Guidelines, then the site may be treated in accordance with the provisions of Section 21083, which is a unique archaeological resource. As defined in Section 21083.2 of CEQA a "unique" archaeological resource is an archaeological artifact, object, or site, for which it can be clearly demonstrated that without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria: • Contains information needed to answer important scientific research questions and there is a demonstrable public interest in that information. • Has a special and particular quality such as being the oldest of its type or the best available example of its type. • Is directly associated with a scientifically recognized important prehistoric or historic event or person. LA County Flood Control District 3.4-14 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources If an archaeological site meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site is to be treated in accordance with the provisions of Section 21083.2, which state that if the lead agency determines that a project would have a significant effect on unique archaeological resources, the lead agency may require reasonable efforts be made to permit any or all of these resources to be preserved in place (Section 21083.1(a)). If preservation in place is not feasible, mitigation measures shall be required. The CEQA Guidelines note that if an archaeological resource is neither a unique archaeological nor a historical resource, the effects of the project on those resources shall not be considered a significant effect on the environment (CEQA Guidelines Section 15064.4(c)(4)). Senate Bill 18 Senate Bill 18 (SB 18), which went into effect January 1, 2005, requires local governments (city and county) to consult with Native American Tribes before making certain planning decisions and to provide notice to tribes at certain key points in the planning process. The intent is to "provide California Native American tribes an opportunity to participate in local land use decisions at an early planning stage, for the purpose of protecting, or mitigating impacts to, cultural places" (Governor's Office of Planning and Research [OPR], 2005). The purpose of involving Tribes at these early planning stages is to allow consideration of cultural places in the context of broad local land use policy, before individual site-specific, project -level, land use designations are made by a local government. The consultation requirements of SB 18 apply to general plan or specific plan processes proposed on or after March 1, 2005. According to the Tribal Consultation Guidelines: Supplement to General Plan Guidelines (OPR, 2005), the following are the contact and notification responsibilities of local governments: Prior to the adoption or any amendment of a general plan or specific plan, a local government must notify the appropriate tribes (on the contact list maintained by the Native American Heritage Commission [NAHC]) of the opportunity to conduct consultations for the purpose of preserving, or mitigating impacts to, cultural places located on land within the local government's jurisdiction that is affected by the proposed plan adoption or amendment. Tribes have 90 days from the date on which they receive notification to request consultation, unless a shorter timeframe has been agreed to by the tribe (Government Code Section 65352.3). • Prior to the adoption or substantial amendment of a general plan or specific plan, a local government must refer the proposed action to those tribes that are on the NAHC contact list and have traditional lands located within the city or county's jurisdiction. The referral must allow a 45 -day comment period (Government Code Section 65352). Notice must be sent regardless of whether prior consultation has taken place. Such notice does not initiate a new consultation process. IA County Flood Control District 3.4-15 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources • Local government must send a notice of a public hearing, at least 10 days prior to the hearing, to tribes who have filed a written request for such notice (Government Code Section 65092). If an individual structural BMP project entailed the adoption or substantial amendment of a general plan or specific plan, the provisions of Senate Bill 18 may apply. Local County The Conservation and Open Space Element of the 2008 Los Angeles County General Plan governs the natural and cultural resources of the county. The Los Angeles County General Plan has the following relevant goals and policies related to the protection of cultural and paleontological resources. Goal C/OS-12: Protected cultural heritage resources. Policy C/OS 12.1: Support an inter jurisdictional collaborative system that protects and enhances the County's cultural heritage resources. Policy C/OS 12.2: Support the preservation and rehabilitation of historic buildings. Policy C/OS 12.3: Ensure proper notification procedures to Native American tribes in accordance with Senate Bill 18 (2004). Policy C/OS 12.4: Promote public awareness of the County's cultural heritage resources. Implementation Action C/OS 12.1 Evaluate the efficacy of the Landmarks Preservation Commission and the designation of historic landmarks within the unincorporated areas of the County. In addition, the General Plan makes the following recommendation: If a CEQA analysis determines that a project will impact a cultural resource area (historic, cultural, or paleontological), the following guidelines will apply: 1. A literature search for valid archaeological or paleontological surveys shall be conducted (for each initial study of a public or private project). 2. A study of the project site shall be made by a qualified archaeologist or paleontologist who shall determine the scientific value of finds, if any, and a recommendation as to their preservation or disposition. 3. The County Historical Landmarks Commission must be notified of all cultural, historical, or paleontological findings. 4. All significant impacts to cultural resource sites must be mitigated to the greatest extent feasible, and a reasonable period of time must be allowed to salvage the site. IA County Flood Control District 3.4-16 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources 5. The integrity of significant historical features of the structure and/or site should be maintained to the largest extent possible. 6. The integrity of sightlines to the structure or site should be maintained. 7. Development adjacent to a cultural resource site should consider design guidelines and appropriate building design, setbacks, landscaping, and other factors that will protect the integrity of the cultural resource area. 8. Materials collected during surface surveys or salvage operations should be donated to an appropriate nonprofit institution. In the event the property owner wishes to retain possession of the artifacts found, it is desirable that archaeologists or paleontologist be allowed to study and photograph the artifacts. City General Plans The numerous cities encompassed by the EWMP program area all have their own respective city General Plans, some of which may contain policies that address cultural resources. As implementation of the individual structural BMP projects proceed, specific policies and objectives pertaining to cultural resources from applicable city general plans will be identified and evaluated on a project -by -project basis during subsequent CEQA environmental processes. Paleontological Resources Federal A variety of federal statutes specifically address paleontological resources. They are generally applicable to a project if that project includes federally owned or federally managed lands, or involves a federal agency license, permit, approval, or funding. Federal legislative protection for paleontological resources stems from the Antiquities Act of 1906 (PL 59-209; 16 United States Code 431 et. seq.; 34 Stat. 225), which calls for protection of historic landmarks, historic and prehistoric structures, and other objects of historic or scientific interest on federal lands. =7 Paleontological resources are explicitly afforded protection by CEQA, specifically in Section V(c) of Appendix G, the "Environmental Checklist Form," which addresses the potential for adverse impacts to "unique paleontological resource[s] or site[s]." PRC Section 5097.5 specifies that any unauthorized removal of paleontological remains is a misdemeanor. Further, the California Penal Code Section 622.5 sets the penalties for the damage or removal of paleontological resources. Professional Standards The SVP has established standard guidelines for acceptable professional practices in the conduct of paleontological resource assessments and surveys, monitoring and mitigation, data and fossil recovery, sampling procedures, specimen preparation, identification, analysis, and curation. Most practicing professional paleontologists in the United States adhere closely to the SVP's assessment, mitigation, and monitoring requirements as specifically provided in its standard guidelines. Most California state regulatory agencies accept the SVP standard guidelines as a measure of professional practice. IA County Flood Control District 3.4-17 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources 3.4.3 Impact Analysis The proposed program's potential impacts have been assessed using the CEQA Guidelines Appendix G Checklist. The following sections discuss the key issue areas identified in the CEQA Guidelines with respect to the program's potential effect on cultural resources. Method of Analysis This impact analysis is a preliminary, program -level assessment of potential impacts on important cultural resources that could occur as a result of implementation of the proposed program. Because this a program -level analysis, impacts on specific cultural resources that could result from individual projects or structural BMPs are not addressed in this document, but may need to be assessed through additional analysis as project implementation actions are developed and further defined. The impacts and mitigation measures identified in this section address types of activities that could significantly impact cultural resources including archaeological sites, historic buildings and structures, and locations of importance to Native Americans. Proposed program facilities for structural BMPs include aboveground and belowground facilities, construction of which could result in impacts to cultural and paleontological resources. Program implementation actions that include these types of activities would be required to implement the identified mitigation measures in an effort to reduce any impacts to a less -than -significant level. The identification of specific impacts and mitigation measures that are appropriate for a specific project implementation action will depend on both the nature of the cultural resources that are present and on the nature of the action. In some instances, mitigation measures must be developed in consultation with multiple agencies and other interested parties. Thresholds of Significance For the purposes of this Program Environmental Impact Report (PEIR) and consistency with Appendix G of the CEQA Guidelines, applicable local plans, and agency and professional standards, the program would have a significant impact on cultural resources if it would: • Cause a substantial adverse change in the significance of a historical resource as defined in §15064.5. • Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5. • Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature. • Disturb any human remains, including those interred outside of a formal cemetery. According to CEQA Guidelines (CCR Title 14, 15064.4), a project with an effect that may cause a substantial adverse change in the significance of a historical resource is a project that may have a significant effect on the environment (CCR Title 14, 15064.4(b)). The Guidelines further state LA County Flood Control District 3.4-18 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.4 Cultural Resources that a substantial adverse change in the significance of a resource means the physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a historic resource would be materially impaired. Actions that would materially impair the significance of a historical resource are any actions that would demolish or adversely alter those physical characteristics of a historical resource that convey its historical significance and qualify it for inclusion in the CRHR or in a local register or survey that meet the requirements of PRC Sections 5020.1(k) and 5024.1(g). Identified cultural resources that may be impacted by individual structural BMP projects would be evaluated for eligibility for listing on the CRHR or local historic register. Cultural resources that are eligible for the CRHR or local historic register are considered to be significant historic resources. Cultural resources would also be evaluated for their qualification as a unique archaeological resource under CEQA. Cultural resources that are identified within individual structural BMP project areas subject to federal approval, permits, or funding would also be evaluated for eligibility for listing on the NRNP. Cultural resources determined to be eligible for listing on the NRNP are automatically eligible for listing on the CRHR and are considered to be significant cultural resources. Paleontological resources are also afforded protection by CEQA. Appendix G (Part V) of the CEQA Guidelines provides guidance relative to significant impacts on paleontological resources. A project will have a significant impact on the environment if it adversely affects a paleontological resource or site, or a unique geological feature. Program Impact Discussion Historical Resources Impact 3.4-1: The proposed program could cause a substantial adverse change in the significance of an historical resource as defined in §15064.5. Structural (Regional, Centralized, and Distributed) BMPs Distributed BMPs are most likely to be implemented in high-density urban, commercial, industrial, and transportation areas where they would either replace or improve upon existing storrnwater infrastructure. These types of BMPs are generally "retrofit' type projects that replace existing impervious surfaces with pervious surfaces such as bioinfiltration cells, bioswales, porous pavement, and filter strips that tie into existing stormwater management systems. These projects may also augment the existing stormwater management systems with additional inlet screens, filter media systems, sediment removal systems, and diversions to sanitary sewer lines. Ground disturbance for distributed BMPs is typically less than 1 to 2 acres in extent, but may extend in some limited applications up to 5 acres where space is available. Centralized structural BMPs collect, store, treat, and filter storrnwater from multiple parcels and much larger drainage areas. Like centralized BMPs, regional BMPs can be implemented in a broad range of land use types, from high-density urban to open space, and can have multiple benefits (habitat, recreation, aesthetics, etc.). Centralized and regional structural BMPs require greater footprints for construction and implementation. IA County Flood Control District 3.4-19 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources Built Environment Resources Any historic built environment resources (including buildings and structures) that are 50 years or older within the program area may be eligible for listing in the CRHR or local register, although such resources have not yet been identified. Historic built environment resources that are found eligible for the CRHR or local register would be considered historical resources under CEQA. A project that causes a substantial adverse change in the significance of a built environment resource that qualifies as an historical resource (i.e., physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings) would result in a significant impact to historical resources. Implementation of structural BMPs occurring under the proposed program could impact significant historic built environment resources that exist within the program area. Built environment resources can include not only buildings and structures, but also built infrastructure such as concrete channels, dams, sidewalks, and roads. Impacts could include not only physical demolition or alteration of built environment resources, but also changes to the historic setting of a resource, and impacts that may adversely affect that ability of a resource to convey its significance. Mitigation Measure CUL -1 would reduce impacts to significant historic built resources. However, in some circumstances, documentation of an historical resource, by way of historic narrative, photographs, or architectural drawings, as mitigation for the effects of demolition of the resource will not mitigate the effects to a point where clearly no significant effect on the environment would occur (CEQA Guidelines § 15126.4(b)(2)). Therefore, implementation of the proposed program may ultimately result in a "substantial adverse change" to historic resources through various development activities for which no possible mitigation may be available to maintain the historic integrity of the affected resource or its surroundings. Archaeological and Other Cultural Resources Historical resources can include not only buildings and structures, as discussed above, but also any object, site area, place, record, or manuscript which a lead agency determines to be historically significant, or which is listed in or determined eligible for listing in the CRHR (CEQA Guidelines Section 15064.5(a)). The program area has a long history of human occupation, dating to at least 9,000 years before the present. The abundant natural resources within the program area, including rivers, creeks, the Pacific Ocean, and the flora and fauna associated with these water features, would have attracted and sustained human settlement. Significant archaeological resources have been recorded throughout the program area, and numerous Native American village sites are known to have existed within the program area (Altschul et al., 2003; Gumprecht, 2001; McCawley, 1996). Archaeological sensitivity varies across the program area based on specific environmental factors, as discussed above, but archaeological resources could potentially be present in any individual structural BMP project area. Known archaeological resources, as well as unknown and unrecorded archaeological resources that may be unearthed during construction activities associated with implementation of structural BMPs, could be impacted by individual projects. Some of these resources may qualify as LA County Flood Control District 3.4-20 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.4 Cultural Resources historical resources. Disturbance of previously unknown and unrecorded archaeological resources can occur even in already developed areas, as older buildings are known to have often been built on top of or within archaeological deposits. Although much of the program area is already heavily developed, potentially significant buried archaeological resources could nevertheless still exist within the program area, beneath and between structures and roads. If previously undiscovered artifacts or buried archaeological resources are uncovered during excavation or construction, significant impacts could occur. Resources of importance to Native American Tribes or other cultural groups that may qualify as historical resources may also be present within individual EWMP areas. These resources may be identified through cultural resources studies and through consultation and coordination with local Native American Tribes or other cultural groups. Given the above, the proposed program has the potential to adversely affect archaeological resources and other cultural resources that qualify as historical resources. Since the proposed program is at the programmatic level, specific project locations and design elements have yet to be finalized. As such, impacts to specific cultural resources are not addressed here. However, as program implementation actions move forward, individual projects would undergo additional CEQA review prior to construction. The program area should be considered sensitive for archaeological and other cultural resources, which should be taken into consideration during subsequent CEQA review. Any structural BMP that involves grading, trenching, excavation, vegetation removal, or other form of ground disturbance could impact archaeological resources or other cultural resources. Indirect impacts to archaeological resources, as a result of erosion or vandalism resulting from increased access to or visibility of resources, could also occur. Implementation of Mitigation Measures CUL -2, CUL -3, and CUL4 would reduce impacts to archaeological and other cultural resources that qualify as historical resources. However, because the degree of impact and the applicability, feasibility, and success of these measures cannot be accurately predicted for each specific project at this time, the program level impact related to archaeological and cultural resources that qualify as historical resources is considered significant and unavoidable. In some circumstances, documentation and data recovery as mitigation for impacts to an historical resource of an archaeological nature will not mitigate the effects to a point where clearly no significant effect on the environment would occur. Data recovery as mitigation for historical resources that are eligible for the CRHR under Criterion 4, or that derive their significance from their scientific value or data potential, may effectively mitigate impacts to a less than significant level. However, for historical resources that are eligible to the CRHR under Criteria 1, 2, or 3, data recovery may not adequately mitigate impacts to those aspects of the resource that convey its significance and make it eligible for listing in the CRHR. Impacts to historical resources would remain significant and unavoidable after implementation of Mitigation Measures CUL -1 through CUL -4 at this program -level analysis. It should be noted that not all individual EWMP projects may result in a significant and unavoidable impact with regard to historical resources, as the impacts associated with each individual EWMP project would be dependent on its location; the presence, nature, and significance of any historical IA County Flood Control District 3.4-21 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources resources within the construction area; and specific impacts to historical resources. It is anticipated that the implementing agencies of the EWMP projects would, through the environmental review process, consider each discretionary EWMP project on a case-by-case basis to ascertain whether an individual project would impact cultural resources. Therefore, the identification of a significant and unavoidable program -level impact in this PEIR does not preclude the finding of future less -than -significant impacts for the individual structural BMP projects occurring in the EWMP areas. Mitigation Measures: CUL -1: For individual EWMP projects that could impact buildings or structures (including infrastructure) 45 years old or older, implementing agencies shall ensure that a historic built environment survey is conducted or supervised by a qualified historian or architectural historian meeting the Secretary of the Interior's Professional Qualification Standards for Architectural History. Historic built environment resources shall be evaluated for their eligibility for listing in the CRHR or local register prior to the implementing agency's approval of project plans. If eligible resources that would be considered historical resources under CEQA are identified, demolition or substantial alteration of such resources shall be avoided. If avoidance is determined to be infeasible, the implementing agency shall require the preparation of a treatment plan to include, but not be limited to, photo -documentation and public interpretation of the resource. The plan will be submitted to the implementing agency for review and approval prior to implementation. CUL -2: Implementing agencies shall ensure that individual EWMP projects that require ground disturbance shall be subject to a Phase I cultural resources inventory on a project - specific basis prior to the implementing agency's approval of project plans. The study shall be conducted or supervised by a qualified archaeologist, defined as an archaeologist meeting the Secretary of the Interior's Professional Qualifications Standards for Archaeology, and shall be conducted in consultation with the local Native American representatives expressing interest. The cultural resources inventory shall include a cultural resources records search to be conducted at the South Central Coastal Information Center; scoping with the NAHC and with interested Native Americans identified by the NAHC; a pedestrian archaeological survey where deemed appropriate by the qualified archaeologist; and formal recordation of all identified archaeological resources on California Department of Parks and Recreation 523 forms and significance evaluation of such resources presented in a technical report following the guidelines in Archaeological Resource Management Reports (ARMR): Recommended Contents and Format, Department of Parks and Recreation, Office of Historic Preservation, State of California, 1990. If potentially significant archaeological resources are encountered during the survey, the implementing agency shall require that the resources are evaluated by the qualified archaeologist for their eligibility for listing in the CR14R and for significance as a historical resource or unique archaeological resource per CEQA Guidelines Section 15064.5. Recommendations shall be made for treatment of these resources if found to be significant, in consultation with the implementing agency and the appropriate Native American groups LA County Flood Control District 3.4-22 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources for prehistoric resources. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred manner of mitigation to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project reroute or redesign, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, which may include data recovery or other appropriate measures, in consultation with the implementing agency, and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. CUL -3: The implementing agency shall retain archaeological monitors during ground - disturbing activities that have the potential to impact archaeological resources qualifying as historical resources or unique archaeological resources, as determined by a qualified archaeologist in consultation with the implementing agency, and any local Native American representatives expressing interest in the project. Native American monitors shall be retained for projects that have a high potential to impact sensitive Native American resources, as determined by the implementing agency in coordination with the qualified archaeologist. CUL -4: During project -level construction, should subsurface archaeological resources be discovered, all activity in the vicinity of the find shall stop and a qualified archaeologist shall be contacted to assess the significance of the find according to CEQA Guidelines Section 15064.5. If any find is determined to be significant, the archaeologist shall determine, in consultation with the implementing agency and any local Native American groups expressing interest, appropriate avoidance measures or other appropriate mitigation. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred means to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project reroute or redesign, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, such as data recovery or other appropriate measures, in consultation with the implementing agency and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. Significance Determination: Significant and unavoidable The application of these mitigation measures to specific BMP types and categories is identified in Table 3.4-2.) IA County Flood Control District 3.4-23 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities, demolition, or any ground disturbance. Consequently, implementation of non-structural BMPs would not impact historical resources. Mitigation Measures: None required Significance Determination: No impact Unique Archaeological Resources Impact 3.4-2: The program could cause a substantial adverse change in the significance of unique archaeological resources as defined in §15064.5. Structural (Regional, Centralized, and Distributed) BMPs As discussed under Impact 3.4-1, the program area should be considered sensitive for archaeological resources. Archaeological sensitivity varies across the program area based on specific environmental factors, as discussed above, but archaeological resources could potentially be present in any individual structural BMP project area. Known archaeological resources, as well as unknown and unrecorded archaeological resources that may be unearthed during construction activities associated with implementation of structural BMPs, could be impacted by individual EWMP projects. Any structural BMP which involves grading, trenching, excavation, vegetation removal, or other form of ground disturbance could impact archaeological resources, some of which may qualify as unique archaeological resources. Implementation of Mitigation Measures CUL -2, CUL -3, and CUL4 would require that unique archaeological resources be treated in accordance with the provisions of Section 21083.2, which would reduce impacts to unique archaeological resources to a less -than -significant level. Mitigation Measures: Implement Mitigation Measures CUL -2, CUL -3, CUL -4 Significance Determination: Less than significant (The application of these mitigation measures to specific BMP types and categories is identified in Table 3.4-2.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities or any ground disturbance. Consequently, implementation of non-structural BMPs would not impact unique archaeological resources. Mitigation Measures: None required Significance Determination: No impact IA County Flood Control District 3.4-24 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources Paleontological Resources Impact 3.4-3: The program could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature. Structural (Regional, Centralized, and Distributed) BMPs As discussed, the program area is underlain by a number of high or undetermined paleontological sensitivity units. These sensitive geological formations/units may contain significant paleontological resources. The Los Angeles County General Plan Conservation Element requires that a paleontologist be retained to mitigate potential impacts to nonrenewable paleontological resources. However, significant paleontological resources can be uncovered even in areas of low sensitivity, and it is possible that ground -disturbing construction activities associated with implementation of the program could result in the inadvertent discovery of paleontological resources, which could be a significant impact. Implementation of Mitigation Measures CUL -5 and CUL -6 would reduce these impacts to less -than -significant levels at this program -level of analysis. Mitigation Measures: CUL -5: For individual structural BMP projects that require ground disturbance, the implementing agency shall evaluate the sensitivity of the project site for paleontological resources. If deemed necessary, the implementing agency shall retain a qualified paleontologist to evaluate the project and provide recommendations regarding additional work, potentially including testing or construction monitoring. CUL -6: In the event that paleontological resources are discovered during construction, the implementing agency shall notify a qualified paleontologist. The paleontologist will evaluate the potential resource, assess the significance of the find, and recommend further actions to protect the resource. Significance Determination: Less than significant (The application of these mitigation measures to specific BMP types and categories is identified in Table 3.4-2.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities or any ground disturbance. Consequently, implementation of non-structural BMPs would not impact paleontological resources. Mitigation Measures: None required Significance Determination: No impact IA County Flood Control District 3.4-25 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources Human Remains Impact 3.4-4: The program could disturb any human remains, including those interred outside of a formal cemetery. Structural (Regional, Centralized, and Distributed) BMPs Program -level development involving ground disturbance within the program area could impact human remains. In the event that human remains are discovered, including those interred outside of formal cemeteries, the human remains could be inadvertently damaged, which could be a significant impact. Implementation of Mitigation Measure CUL -7 would reduce impacts to less - than -significant levels at this program -level of analysis. Mitigation Measures: CUL -7: The implementing agency shall require that, if human remains are uncovered during project construction, work in the vicinity of the find shall cease and the County Coroner shall be contacted to evaluate the remains, following the procedures and protocols set forth in Section 15064.5 (e)(1) of the CEQA Guidelines. If the County Coroner determines that the remains are Native American, the Coroner will contact the Native American Heritage Commission, in accordance with Health and Safety Code Section 7050.5, subdivision (c), and Public Resources Code 5097.98 (as amended by AB 2641). The NAHC will then designate a Most Likely Descendant of the deceased Native American, who will engage in consultation to determine the disposition of the remains. Significance Determination: Less than significant (The application of this mitigation measure to specific BMP types and categories is identified in Table 3.4-2.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities or any ground -disturbance. Consequently, implementation of non-structural BMPs would not impact human remains. Mitigation Measures: None required Significance Determination: No impact Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs The geographic area of analysis for cultural resources is defined as the jurisdictions within which the proposed program is located. This geographic scope of analysis is appropriate because the archaeological, historical, and paleontological resources within this radius are expected to be similar to those that occur on the individual project sites because of their proximity; similar IA County Flood Control District 3.4-26 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources environments, landforms, and hydrology would result in similar land-use—and, thus, site types. Similar geology within this vicinity would likely yield fossils of similar sensitivity and quantity. This is a large enough area to encompass any effects of the program on cultural and paleontological resources that may combine with similar effects caused by other projects, and provides a reasonable context wherein cumulative actions could affect cultural and paleontological resources. The program could cause impacts on cultural and paleontological resources during the construction period or as a result of operation and maintenance or closure and decommissioning activities. Cumulative impacts to cultural resources in the cultural resources geographic scope of analysis could occur if other existing or proposed projects, in conjunction with the proposed program, had or would have impacts on cultural resources that, when considered together, would be significant. Regional and centralized BMPs will not be well distributed throughout the watershed because of the limited feasible and applicable sites; however, distributed BMPs, which may comprise the majority of the BMPs implemented under the EWMPs, will be better distributed. Therefore, while the distributed BMPs may have limited or no impact on cultural resources on a project -by -project basis, when taken together, they may impact cultural resources on a regional scale. Los Angeles County contains a significant archaeological and historical record that, in many cases, has not been well documented or recorded. There is the potential for ongoing and future development projects in the vicinity to disturb landscapes that may contain known or unknown historical resources. Thus, potential construction impacts of the implementation of the proposed program, in combination with other projects in the area, could contribute to a cumulatively significant impact on historical resources. Mitigation measures are included in this PEIR to reduce potentially significant program impacts to historical resources during construction. While implementation of Mitigation Measures CUL -1 through CUL -4 would reduce impacts to historical resources, implementation of the proposed program may ultimately result in a substantial adverse change to historical resources through various development activities for which no possible mitigation may be available to maintain the historic integrity of the affected resource or its surroundings, and impacts to historical resources would remain significant and unavoidable at a program level. Therefore, the implementation of structural BMPs may contribute to a cumulatively significant environmental impact to historical resources. Implementation of Mitigation Measures CUL -2, CUL -3, and CUL4 would require that unique archaeological resources be treated in accordance with the provisions of CEQA Section 21083.2, which would reduce impacts to unique archaeological resources to a less -than -significant level. Therefore, the program would not contribute to a cumulatively significant environmental impact to unique archaeological resources. Excavation activities associated with the implementation of individual structural BMPs in conjunction with other projects in the area could contribute to the progressive loss of fossil remains, associated geological and geographic data, and fossil bearing strata, which is a potentially significant impact. However, the proposed program would have a less -than -significant impact to paleontological resources with incorporation of Mitigation Measure CUL -5 and IA County Flood Control District 3.4-27 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources CUL -6. Therefore, with the implementation of Mitigation Measures CUL -5 and CUL -6, cumulative impacts to paleontological resources would be less than significant. Furthermore, implementation of Mitigation Measure CUL -7 provides a mechanism to reduce impacts to human remains should they be encountered during ground -disturbing activities, and cumulative impacts to human remains would be less than significant. With implementation of applicable regulatory requirements and Mitigation Measures CUL -1 through CUL -7, the implementation of the proposed program would not have a cumulatively considerable contribution to impacts to unique archaeological resources, paleontological resources, or human remains from decommissioning activities. Implementation of the proposed program may contribute to a cumulatively significant environmental impact to historical resources. Mitigation Measures: Implement Mitigation Measures CUL -1 through CUL -7 Significance Determination: Significant and unavoidable (The application of these mitigation measures to specific BMP types and categories is identified in Table 3.4-2.) Non -Structural BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities or any ground disturbance. Consequently, implementation of non-structural BMPs would not contribute to a cumulatively significant environmental impact to cultural resources. Mitigation Measures: None required Significance Determination: No impact LA County Flood Control District 3.4-28 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.4 Cultural Resources 3.4.4 Summary of Impact Assessment Table 3.4-2 shows a summary of the structural BMPs requiring mitigation. TABLE 3.4-2 SUMMARY OF CULTURAL RESOURCE IMPACTS REQUIRING MITIGATION MEASURES Regional BIvPs Thresholds of Significance Regional Detention and Yes Yes Yes Yes Yes Archaeological Infiltration Built and Other Unique Yes Yes Yes Yes Environment Cultural Archaeological Paleontological Human Cumulative Structural BMPs Resources Resources Resources Resources Remains Impacts Bioinfiltration Yes Yes Yes Yes CUL -1 Yes Constructed Wetlands Yes Yes CUL -1 Applicable through CUL -1 through CUL -2; CUL -3; Yes Yes through Mitigation Measures: CUL -4 CUL -4 CUL -4 CUL -5 and CUL -6 CUL -7 CUL -7 Regional BIvPs Regional Detention and Yes Yes Yes Yes Yes Yes Infiltration Regional Capture, Yes Yes Yes Yes Yes Yes Detention and Use Centralized BW Bioinfiltration Yes Yes Yes Yes Yes Yes Constructed Wetlands Yes Yes Yes Yes Yes Yes TrealmenVLow-Flow Yes Yes Yes Yes Yes Yes Diversions Creek, River, Estuary Yes Yes Yes Yes Yes Yes Restoration Distributed BMs Site -Scale Detention Yes Yes Yes Yes Yes Yes LID — Infiltration/Filtration Yes Yes Yes Yes No Yes BMPs — Porous Pavement, Green Streets, Bioswale/Filter Strips, downspout disconnects LID — Green Yes Yes Yes No No Yes Infrastructure — Capture and Use—Cisterns, Rain Barrels, Green roofs, Planter Boxes (') Flow-through Treatment Yes Yes Yes Yes No Yes BMPs0) Source -Control Yes Yes Yes No No Yes Treatment BMPs (catch basin inserts/screens, hydrodynamic separators, gross solids removal devices)") Low -Flow Diversions Yes Yes Yes Yes No Yes /'I These type of BMPs are generally built as retrofits to existing MS4 systems and would require in most cases little or no excavation. NOTE: These conclusions are based on typical location and need for ground disturbance. IA County Flood Control District 3.4-29 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.5 Geologic and Mineral Resources This section addresses the potential impacts to geology, soils, and seismicity associated with implementation of the proposed program. This section provides a description of the regional geology, a summary of the regulations related to geologic and seismic hazards, and an evaluation of the potential impacts that may result from implementing the proposed program and identifies mitigation measures to minimize potential effects. This section also evaluates whether the proposed program would result in a loss of available mineral resources. 3.5.1 Environmental Setting Regional The project area is located in the center portion of the Transverse Ranges Geomorphic Province (California Geological Survey [CGS], 2002b). California's geomorphic provinces are naturally defined geologic regions that display a distinct landscape or landforms with unique, defining features based on geology, faults, topographic relief, and climate. This province consists of an east -west trending series of steep mountain ranges and valleys that deviate from the normal northwest trend of other Coastal California geomorphic provinces due to intense north -south compression squeezing the ranges within this province. The east -west structure of the Transverse Ranges is oblique to the normal northwest trend of coastal California, hence the name "Transverse." The province extends offshore to include San Miguel, Santa Rosa, and Santa Cruz islands. The eastern extension, the San Bernardino Mountains, has been displaced to the south along the San Andreas Fault. As a result, this is one of the most rapidly rising regions on earth and it is seismically active. Cenozoic petroleum -rich sedimentary rocks have been folded and faulted, making this an important oil-producing area in the United States. The Los Angeles Basin is in the southern part of the province and separates the Transverse Ranges Province from the Peninsular Ranges Provinces to the south. Project Area Topography The project area is bounded on the northwest by the Santa Monica Mountains, on the northeast by the San Gabriel Mountains, on the southeast by the Orange County coastal plain, and on the west and southwest by the Pacific Ocean. The project area largely consists of the watersheds for the Los Angeles, Santa Clara, San Gabriel Rivers, Santa Monica Bay, and the Dominguez Channel, and includes the Los Angeles Basin and the San Fernando and Santa Clarita Valleys. Topography varies regionally from sea level at the coast to several thousand feet in the surrounding mountains. IA County Flood Control District 3.5-1 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources Geology The project area geology consists of Tertiary and older (1.6 million years and older) bedrock mountain ranges and hills surrounding and separating Quaternary and younger (1.6 million years and younger) sediment -filled basins and valleys, as shown in Figure 3.5-1, Regional Geology (U.S. Geological Survey [USGS], 1990). To the northwest of the project area, the Santa Monica Mountains have a granitic and metamorphic core covered with marine sedimentary sandstone, shale, and conglomerate rocks. To the northeast of the project area, the San Gabriel Mountains consist mostly of granitic rocks with some metamorphic gneiss and schist rocks. Several lower hills separate the Los Angeles Basin and the San Fernando and Santa Clara Valleys. Marine sediments and erosion of the surrounding mountain ranges and hills within the project area have filled the intervening basins and valleys with thick deposits of sediments. The recent surface sediments are mostly sand and silt. Much of the basin and valley areas have been highly disturbed through development and much of the surface materials consist of undocumented fills. Seismicity and Faults This section characterizes the region's existing faults, describes historical earthquakes, estimates the likelihood of future earthquakes, and describes probable groundshaking effects. Earthquake Terminology and Concepts Earthquake Mechanisms and Fault Activity Faults are planar features within the earth's crust that have formed to release strain caused by the dynamic movements of the earth's major tectonic plates. An earthquake on a fault is produced when these strains overcome the inherent strength of the earth's crust, and the rock ruptures. The rupture causes seismic waves that propagate through the earth's crust, producing the groundshaking effect known as an earthquake. The rupture also causes variable amounts of slip along the fault, which may or may not be visible at the earth's surface. The State of California defines an active fault as one that has had surface displacement within Holocene time (the last 11,000 years). Earthquake Magnitude When an earthquake occurs along a fault, its size can be determined by measuring the energy released during the event. A network of seismographs records the amplitude and frequency of the seismic waves that an earthquake generates. The Richter magnitude (ML) of an earthquake represents the highest amplitude measured by the seismograph at a distance of 100 kilometers from the epicenter. While the Richter magnitude scale was historically the primary measure of earthquake magnitude, seismologists now use the moment magnitude (Mw) scale as the preferred way to express the size of an earthquake (USGS, 2009). The Mw scale is related to the physical characteristics of a fault, including the rigidity of the rock, the size of fault rupture, and the style of movement or displacement across the fault. IA County Flood Control District 3.5-2 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report SOURCE: USGS, 1990 LA County PEIR WMP. 140474 Figure 3.5-1 Regional Geology 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources Peak Ground Acceleration A common measure of ground motion at any particular site during an earthquake is the peak ground acceleration (PGA) (USGS, 2007b). The PGA for a given component of motion is the largest value of horizontal acceleration obtained from a seismograph. PGA is expressed as the percentage of the acceleration due to gravity (g), which is approximately 980 centimeters per second squared. In terms of automobile acceleration, one "g" of acceleration is equivalent to the motion of a car traveling 328 feet from rest in 4.5 seconds. For comparison purposes, the maximum PGA value recorded during the Mw 6.7 1994 Northridge earthquake was 1.8 g, among the highest ever instrumentally recorded in an urban area in North America. Unlike measures of magnitude, which provide a single measure of earthquake energy, PGA varies from place to place and is dependent on the distance from the epicenter and the character of the underlying geology (e.g., hard bedrock, soft sediments, or artificial fills). Modified Mercalli Intensity Scale The Modified Mercalli Intensity Scale assigns an intensity value based on the observed effects of groundshaking produced by an earthquake (CGS, 2002a). Unlike measures of earthquake magnitude and PGA, the Modified Mercalli Intensity Scale is qualitative in nature in that it is based on actual observed effects rather than measured values. Similar to PGA, Modified Mercalli values for an earthquake at any one place can vary depending on the earthquake's magnitude, the distance from its epicenter, the focus of its energy, and the type of geologic material. The Modified Mercalli values for intensity range from I (earthquake not felt) to XII (damage nearly total), and intensities ranging from IV to X can cause moderate to significant structural damage. Because the Modified Mercalli scale is a measure of groundshaking effects, intensity values can be correlated to a range of average PGA values, as shown in Table 3.5-1. Faults and Historical Earthquake Activity The project area is located in a seismically active region of California. Major earthquakes have affected the region in the past and are expected to occur in the near future on one of the active faults in the area. The San Andreas transform fault system, which forms the boundary between the North American and Pacific tectonic plates, is responsible for the highly seismic nature of Southern California. The fault bends in an east -west direction from the Southern end of the San Joaquin Valley to the eastern end of the San Bernardino Mountains. This portion of the San Andreas Fault system is referred to as the "Big Bend" and generates major compression forces, which in turn create many smaller fault branches (SCEC, 2011). The active faults in the vicinity of the project area are shown in Figure 3.5-2, Local Faults with Recent Movement. Table 3.5-2 identifies both historically active and active faults in the vicinity of the project area and their corresponding characteristics that are capable of generating significant groundshaking at the proposed EMWP facilities. Two other fault characteristics—the maximum moment magnitude and the slip rate—are also important in determining the potential damage a fault may cause. The maximum moment magnitude of a fault refers to the largest possible earthquake it can experience given its existing geology (USGS, 2009). A fault's slip rate is defined as how fast the two sides of a fault are slipping relative to one another. The fastest moving faults have more and larger earthquakes than faults that do not slip as fast. IA County Flood Control District 3.5-4 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental TABLE 3.5-1 MODIFIED MERCALLI INTENSITY SCALE Intensity Value Intensity Description and Mitigation Measures 3.5 Geologic Resources Average Peak Ground Acceleration" I Not felt except by a very few people under especially favorable circumstances. < 0.0017 g II Felt only by a few people at rest, especially on upper floors on buildings. 0.0017 — 0.014 g Delicately suspended objects may swing. Felt noticeably indoors, especially on upper floors of buildings, but many people III do not recognize it as an earthquake. Standing automobiles may rock slightly, 0.0017 — 0.014 g vibration similar to a passing truck. Duration estimated. During the day felt indoors by many, outdoors by few. At night, some awakened. IV Dishes, windows, doors disturbed; walls make cracking sound. Sensation like 0.014 — 0.039 g heavy truck striking building. Standing automobiles rocked noticeably. V Felt by nearly everyone, many awakened. Some dishes and windows broken; a (Light) few instances of cracked plaster; unstable objects overturned. Disturbances of 0.035 — 0.092 g trees, poles may be noticed. Pendulum clocks may stop. VI (Moderate) Felt by all, many frightened and run outdoors. Some heavy furniture moved; 0.092 — 0.18 g fallen plaster or damaged chimneys. Damage slight. Everybody runs outdoors. Damage negligible in buildings of good design and VII construction; slight to moderate in well-built ordinary structures; considerable in 0.18 — 0.34 g (Strong) poorly built or badly designed structures; some chimneys broken. Noticed by people driving automobiles. Damage slight in specially designed structures; considerable in ordinary VIII substantial buildings, with partial collapse; great in poorly built structures. Panel (Very Strong) walls thrown out of frame structures. Fall of chimneys, factory stacks, columns, 0.34 — 0.65 g monuments, walls. Heavy furniture overturned. Sand and mud ejected in small amounts. Changes in well water. People driving automobiles disturbed. Damage considerable in specially designed structures; well-designed frame IX structures thrown out of plumb; great in substantial buildings, with partial 0.65 — 1.24 g (Violent) collapse. Buildings shifted off foundations. Ground cracked conspicuously. Underground pipes broken. Some well-built wooden structures destroyed; most masonry and frame X structures destroyed with foundations; ground badly cracked. Rails bent. > 1.24 g (Very Violent) Landslides considerable from riverbanks and steep slopes. Shifted sand and mud. Water splashed (slopped) over banks. A Few, if any, masonry structures remain standing. Bridges destroyed. Broad (Very Violent) fissures in ground. Underground pipelines completely out of service. Earth > 1.24 g slumps and land slips in soft ground. Rails bent greatly. XII Damage total. Practically all works of construction are damaged greatly or (Very Violent) destroyed. Waves seen on ground surface. Lines of sight and level are distorted. > 1.24 g Objects are thrown upward into the air. " Value is expressed as a fraction of the acceleration due to gravity (g). Gravity (g) is 9.8 meters per second squared. 1.0 g of acceleration is a rate of increase in speed equivalent to a car traveling 328 feet from rest in 4.5 seconds. SOURCES: Adapted from CGS, 2002a. IA County Flood Control District 3.5-5 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Kern Ventura to �'ab ��fa4/tZo m 0 EWMP Boundary o T iz I Miles SOURCE: ESRI, USGS Historic Fault (<150 years) Holocene Fault (<15,000 years) Quaternary Fault (<1,600,000 years) In Los Angeles IP LA County PEIR EWMP . 140474 Figure 3.5-2 Local Faults with Recent Movement 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources TABLE 3.5-2 PRINCIPAL HISTORICALLY ACTIVE AND ACTIVE FAULTS IN THE PROJECT VICINITY Fault Maximum Moment Magnitude Historical Seismicity (Last 150 Years) Slip Rate (mm/year) Fault Classification San Andreas 7.4 M 7.0 (1899) 30.0 Historically Active (Mojave section) Newport -Inglewood 7.1 M 6.4 (1933) 1.0 Historically Active Sierra Madre 6.7 M 6.4 (1971) 2.0 Historically Active (San Fernando section) Whittier -Elsinore 6.8 M 5.9 (1987) 2.5 Historically Active Palos Verdes 7.3 - 3.0 Active San Gabriel 7.2 - 1.0 Active Verdugo 6.9 - 0.5 Active Santa Monica 6.6 - 1.0 Active Raymond 6.5 - 1.5 Active Hollywood 6.4 - 1.0 Active SOURCES: CGS, 2003, 2010 Seismic Hazards Seismic hazards are generally classified into two categories: primary seismic hazards (surface fault rupture and groundshaking) and secondary seismic hazards (liquefaction and other types of seismically induced ground failure, along with seismically induced landslides). Surface Fault Rupture Seismically induced ground rupture is defined as the physical displacement of surface deposits in response to an earthquake's seismic waves. The magnitude, sense, and nature of fault rupture can vary for different faults or even along different strands of the same fault. Although future earthquakes could occur anywhere along the length of an active fault, only regional strike slip earthquakes of magnitude 6.0 or greater are likely to be associated with significant surface fault rupture and offset (CDMG and USGS, 1996). It is also important to note that unmapped subsurface fault traces could experience unexpected and unpredictable earthquake activity and fault rupture. Ground rupture is considered more likely along active faults, which are referenced in Figure 3.5-2 and Table 3.5-2. The highest potential for surface faulting is along existing fault traces that have had displacement in the last 11,000 years (Holocene Epoch). Groundshaking Groundshaking intensity varies depending on the overall earthquake magnitude, distance to the fault, focus of earthquake energy, and type of geologic materials underlying an area. Geologists and engineers attempt to predict earthquake ground acceleration at sites to improve the structural design of buildings so that the building can withstand earthquake motion and not collapse. A probabilistic seismic hazard assessment describes seismic hazard from earthquakes that geologists and seismologists agree could occur. The analysis takes into consideration the uncertainties in the a County Flood Control District 3.5-7 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources size and location of earthquakes and the resulting ground motions that can affect a particular site. Given the presence of the known active faults listed in Table 3.5-2, the entire project area is susceptible to seismic groundshaking. Liquefaction and Lateral Spreading Liquefaction is the rapid loss of shear strength experienced in saturated, predominantly granular soils below the groundwater level during strong earthquake groundshaking and occurs due to an increase in pore water pressure (VT, 2013). Liquefaction -induced lateral spreading is defined as the finite, lateral displacement of gently sloping ground as a result of pore -pressure buildup or liquefaction in a shallow underlying deposit during an earthquake. The occurrence of this phenomenon is dependent on many complex factors, including the intensity and duration of groundshaking, particle -size distribution, and density of the soil. The potential damaging effects of liquefaction include differential settlement, loss of ground support for foundations, ground cracking, heaving and cracking of structures due to sand boiling, and buckling of deep foundations due to ground settlement. Dynamic settlement (i.e., pronounced consolidation and settlement from seismic shaking) may also occur in loose, dry sands above the water table, resulting in settlement of and possible damage to overlying structures. In general, a relatively high potential for liquefaction exists in loose, sandy soils that are within 50 feet of the ground surface and are saturated (below the groundwater table). Lateral spreading can move blocks of soil, placing strain on buried pipelines that can lead to leaks or pipe failure. Figure 3.5-3, Liquefaction and Landslide Potential Map, shows areas susceptible to seismically induced liquefaction and landslides within the county. Earthquake -Induced Settlement Settlement of the ground surface can be accelerated and accentuated by earthquakes. During an earthquake, settlement can occur as a result of the relatively rapid rearrangement, compaction, and settling of subsurface materials (particularly loose, noncompacted, and variable sandy sediments). Settlement can occur both uniformly and differentially (i.e., where adjoining areas settle at different rates). Areas are susceptible to differential settlement if underlain by compressible sediments, such as poorly engineered artificial fill. Earthquake -induced settlement could occur in the event of an earthquake and is a potential seismic hazard discussed further in the Impact and Mitigations Measures section. Seismically Induced Landslides Landslides are defined as the movement of rock, debris, or earth masses down a slope. Landslides are a form of "mass wasting," which refers to any downslope movement of soil and rock under the direct influence of gravity (USGS, 2004). Landslide events include rock falls, topples, slides, spreads, and debris flows. Causes of landslides include rainfall, earthquakes, volcanic activity, groundwater changes, and alteration of a slope by man-made construction activities. Figure 3.5-3, Liquefaction and Landslide Potential Map shows areas susceptible to seismically induced liquefaction and landslides within the County. IA County Flood Control District 3.5-8 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report SOURCE: ESRI Imagery, California Department of Conservation LA County PEI EWMP . 140474 Figure 3.5-3 Liquefaction and Landslide Potential Map 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources Geologic Hazards Geologic hazards include land movement of problematic soils, including landslides and other slope failures, expansive soils, erosion, settlement and subsidence, and sinkholes. These geologic hazards are discussed below. Landslides and Slope Failure As discussed, ground failure is dependent on the slope and geology as well as the amount of rainfall, excavation, or seismic activities. A slope failure is a mass of rock, soil, and debris displaced down a slope by sliding, flowing, or falling. Steep slopes and downslope creep of surface materials characterize landslide -susceptible areas. The areas shown in Figure 3.5-3 that are susceptible to seismically induced landslides and slope failure would also be susceptible to movement from non -seismic causes, such as excavation of the toe of a landslide area or the introduction of excessive water to the head of the landslide area. Expansive Soils Expansive soils are clay -rich and subsequently subject to changes in volume with changes in moisture (MRCS, 2013). This results in the shrinking and swelling of expansive soils from changes in water content. Expansive soils can exert pressure on building foundations, "heaving" or lifting buildings during periods of high moisture and resulting in the settlement of buildings during periods of low moisture. They can also exhibit high amounts of pressure on building foundations, resulting in lateral movement. Techniques exist to reduce effects of expansive soils. Such techniques include prewetting of the soil, which allows for pre -expansion of the soil with the idea that further pressure would be minimized, and structural slabs, which provide extra reinforcement to resist movement and distress caused by pressure of underlying expansive soil. Erosion Erosion is the wearing away of soil and rock by processes such as mechanical or chemical weathering, mass wasting, and the action of waves, wind, and underground water (NCRS, 2001 a, 2001b). Excessive soil erosion can eventually damage infrastructure such as pipelines, wellheads, building foundations, and roadways. In general, granular soils with relatively low cohesion and soils located on steep topography have a higher potential for erosion. In addition, soils erosion can be accelerated beyond natural rates in areas with depleted plant cover and degraded soil structure resulting from excessive disturbance or reduced organic matter input. During construction, exposed soils within the project area would be susceptible to erosion due to stormwater runoff during the rainy season. Settlement and Subsidence Settlement of the ground surface can occur under static forces (e.g., due to gravity or groundwater removal) but can also be accelerated and accentuated by earthquakes. As stated previously, during an earthquake, settlement can occur from rapid rearrangement, compaction, and settling of subsurface materials (particularly loose, noncompacted, and variable sandy sediments). Settlement can occur both uniformly and differentially (i.e., where adjoining areas settle at different rates). In addition, areas are susceptible to differential settlement if underlain by compressible sediments, such as poorly engineered artificial fill or poorly graded gravels. The IA County Flood Control District 3.5-10 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources sediments within the basins and valleys are typically alluvium comprised mostly of sand and silt. The potential for settlement would be higher in unconsolidated sediments and lower in consolidated or sediments reworked during development. Subsidence is a form of settlement defined as the gradual settling or sudden sinking of the earth's surface due to subsurface movement of earth materials. Principle causes include either natural (tectonic movement) or human extraction activities, such as the removal of groundwater, oil, or gas. The extraction activities reduce the pore pressure, increase void spaces, and allow the underlying soils to compact. Sinkholes A sinkhole is an area of ground which has no natural external surface drainage; all water stays inside the sinkhole and rains into the subsurface. Some sinkholes form so slowly they are not noticed, but others form suddenly when a collapse occurs. Sinkholes can have a dramatic effect if they occur in an urban setting. Sinkhole occurrence within Los Angeles County is generally limited but depends on several characteristics, including frequency of drought, type and structure of parent material, changes in groundwater dispersal, and localized topographic conditions, which can directly cause or exacerbate sinkholes (USGS, 2007a). Mineral Resources Mineral resources include commercially viable oil and gas deposits, and nonfuel mineral resources deposits. Nonfuel mineral resources include metals such as gold, silver, iron, and copper; industrial metals such as boron compounds, rare-earth elements, clays, limestone, gypsum, salt, and dimension stone; and construction aggregate, including sand, gravel, and crushed stone. Figure 3.54, Mineral Resources Map, shows the mineral and oil and gas resources zones identified in the draft County General Plan (County of Los Angeles, 2014c). California is the largest producer of sand and gravel in the nation and the greater Los Angeles area is the nation's leading producer for its geographical size. The County has large quantities of sand and gravel, which are located close to the market. Major sand and gravel extraction sites are located in the alluvial fans of the Big Tujunga Wash in the San Fernando Valley and in the San Gabriel River near Irwindale. Other extraction areas are located in northern Los Angeles County in other washes. IA County Flood Control District 3.5-11 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report ry:..i X1....5 i F,DaEs `I>TIr) JJAL FOBF_T ANGELES NATIONAL FOREST /—,IT' JPA, I i ANGELES NATIONAL FORLEF ro.,:Ey PACIFIC OCEAN LM EWMMP Boundary 0 It 12 I I Miles SOURCE: County of Los Angeles, 2014c LA County PEI EWMP . 140474 Figure 3.5-4 Mineral Resources Map Mineral Resource Zones ® Oil and Gas Resources '-C National Forest rl L -,I r,Tv 0 Unincorporated Areas 0 Cities ry:..i X1....5 i F,DaEs `I>TIr) JJAL FOBF_T ANGELES NATIONAL FOREST /—,IT' JPA, I i ANGELES NATIONAL FORLEF ro.,:Ey PACIFIC OCEAN LM EWMMP Boundary 0 It 12 I I Miles SOURCE: County of Los Angeles, 2014c LA County PEI EWMP . 140474 Figure 3.5-4 Mineral Resources Map 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources 3.5.2 Rer Wat®ry Framework State Alquist-Priolo Earthquake Fault Zoning Act The Alquist-Priolo Earthquake Fault Zoning Act was passed in 1972 to protect structures for human occupancy from the hazard of surface faulting (Bryant and Hart, 2007). In accordance with the Act, the State Geologist established regulatory zones—called earthquake fault zones— around the surface traces of active faults, and published maps showing these zones. Buildings for human occupancy) cannot be constructed across surface traces of faults that are determined to be active. Because many active faults are complex and consist of more than one branch that may experience ground -surface rupture, earthquake fault zones extend approximately 200 to 500 feet on either side of the mapped fault trace. Cities and counties must regulate certain development projects within the zones, which includes withholding permits until geologic investigations demonstrate that development sites are not threatened by future surface displacement. Surface fault rupture is not necessarily restricted within an Alquist-Priolo Zone. This applies to the project because structural Best Management Practices (BMPs) would be either prohibited within these fault zones or a geotechnical investigation would be required to develop design features to limit the impact from a seismic event. Seismic Hazard Mapping Act The Seismic Hazards Mapping Act was passed in 1990 following the Loma Prieta earthquake to reduce threats to public health and safety and to minimize property damage caused by earthquakes, strong ground shaking, liquefaction, landslides, or other hazards caused by earthquakes. This act requires the State Geologist to delineate various seismic hazard zones, and Cities, Counties, and other local permitting agencies to regulate certain development projects within these zones. Before a development permit is granted for a site within a seismic hazard zone, a geotechnical investigation must be conducted and appropriate mitigation measures incorporated into the project's design. For projects that would locate structures for human occupancy within designated Zones of Required Investigation, the Seismic Hazards Mapping Act requires project applicants to perform a site-specific geotechnical investigation to identify the potential site-specific seismic hazards and corrective measures, as appropriate, prior to receiving building permits. The CGS Guidelines for Evaluating and Mitigating Seismic Hazards (Special Publication 117A, CGS, 2008) provides guidance for evaluating and mitigating seismic hazards. The CGS is in the ongoing process of producing official maps based on USGS topographic quadrangles. This act applies to the program because structural BMPs would be either prohibited within these seismic hazard zones or a geotechnical investigation would be required to develop design features to limit the impact from a seismic event. California Building Code The California Building Code (CBC), which is codified in Title 24 of the California Code of Regulations, Part 2, was promulgated to safeguard the public health, safety, and general welfare 1 A habitable building is any structure where human occupancy would exceed approximately 2,000 hours annually. LA County Flood Control District 3.5-13 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources by establishing minimum standards related to structural strength, egress facilities, and general building stability. The purpose of the CBC is to regulate and control the design, construction, quality of materials, use/occupancy, location, and maintenance of all building and structures within its jurisdiction. Title 24 is administered by the California Building Standards Commission, which, by law, is responsible for coordinating all building standards. Under State law, all building standards must be centralized in Title 24 or they are not enforceable. The provisions of the CBC apply to the construction, alteration, movement, replacement, and demolition of every building or structure or any appurtenances connected or attached to such buildings or structures throughout California. NPDES Construction General Permit Construction associated with the proposed program would disturb more than one acre of land surface for centralized and regional structural BMPs (and possibly for those distributed structural BMPs larger than one acre), affecting the quality of Stormwater discharges into waters of the United States. The proposed program would therefore be subject to the NPDES General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Order 2009-0009-DWQ, NPDES No. CAS000002, Construction General Permit [CGP]), as amended by Order 2010-0014-DWQ and Order 2012-0006-DWQ). The CGP regulates discharges of pollutants in stormwater associated with construction activity to waters of the United States from construction sites that disturb one or more acres of land surface, or that are part of a common plan of development or sale that disturbs more than one acre of land surface. The CGP requires the development and implementation of a Stormwater Pollution Prevention Plan (SWPPP) that includes specific BMPs designed to prevent pollutants from contacting stormwater and keep all products of erosion from moving off-site into receiving waters. The SWPPP BMPs are intended to protect surface water quality by preventing the off-site migration of eroded soil and construction -related pollutants from the construction area. The CGP and SWPPPs are described in more detail in Section 3.8, Hydrology and Water Quality. Surface Mining and Reclamation Act of 1975 The State Surface Mining and Reclamation Act (SMARA), as amended, is the primary State law governing the conservation and development of mineral resources in California (Health and Safety Code, Division 2, Chapter 9, Section 2710, et seq.). Specifically, it mandates the development of mineral land classifications to help identify and protect mineral resources in areas within the State that are subject to urban expansion or other irreversible land uses that would preclude mineral extraction. After classification of mineral resource zones, SMARA provides for the designation of lands containing mineral deposits of regional or statewide significance, as discussed further below in the CGS section. In addition, SMARA was designed to provide guidelines for the proper reclamation of mineral lands. Local jurisdictions are required to enact specific procedures to guide mineral conservation and extraction at particular sites and to incorporate mineral resource management policies into their General Plans. SMARA applies to the program because structural BMPs would be either prohibited within these mineral resource areas or the local jurisdiction would be required to approve the placement of the structural BMP within the mineral resource zone. IA County Flood Control District 3.5-14 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources California Geological Survey Based on guidelines adopted by CGS, areas known as Mineral Resource Zones (MRZs) are classified according to the presence or absence of significant nonfuel mineral resources deposits. Nonfuel mineral resources include metals such as gold, silver, iron, and copper; industrial metals such as boron compounds, rare-earth elements, clays, limestone, gypsum, salt, and dimension stone; and construction aggregate including sand, gravel, and crushed stone. These classifrcatiom indicate the potential for a specific area to contain significant mineral resources. The classification process involves the determination of Production -Consumption (P -C) Region boundaries, based on identification of active aggregate operations (Production) and the market area served (Consumption). The P -C regional boundaries are modified to include only those portions of the region that are urbanized or urbanizing and are classified for their aggregate content. An aggregate appraisal further evaluates the presence or absence of significant sand, gravel, or stone deposits that are suitable sources of aggregate. The classification of these mineral resources is a joint effort of the State and local governments. It is based on geologic factors and requires that the State Geologist classify the mineral resources area as one of the four MRZs, or Scientific Resource Zones (SZs) or Identified Resource Areas (IRAs), which are described as the following (County of Los Angeles, 2014c): • MRZ-1: Areas where available geologic information indicates there is little or no likelihood for presence of significant mineral resources. • MRZ-2: Areas where available geologic information indicates that significant measured or indicated resources are present or where adequate information indicates that significant mineral deposits are present or where it is judged that a high likelihood for their presence exists. • MRZ-3: Areas where available geologic information indicates known or inferred mineral occurrences of undetermined mineral resource significance. • MRZ-4: Areas of no known mineral occurrences where geologic information does not rule out the presence or absence of significant mineral resources. • SZ Areas: Containing unique or rare occurrences of rocks, minerals, or fossils that are of outstanding scientific significance shall be classified in this zone. • IRA Areas: County or State Division of Mines and Geology Identified Areas where adequate production and information indicates that significant minerals are present. Much of the area within the MRZ sites in Los Angeles was developed with structures prior to the MRZ classification and, therefore, is unavailable for extraction. Local County of Los Angeles General Plan A General Plan is a basic planning document that, alongside the zoning code, governs development in a city or county. The State requires each city and county to adopt a General Plan with seven mandatory elements: land use, open space, circulation, housing, noise, conservation, and safety, along with any number of optional elements as appropriate. The proposed Enhanced a County Flood Control District 3.5-15 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources Watershed Management Programs (EWMPs, or "program") would be subject to the local plans and policies of the areas in which they are located. The County of Los Angeles is currently updating their General Plan from the element versions adopted in the 1980s and 1990s; the new comprehensive plan is expected to be complete by late 2014. Below are the relevant goals and policies from both the existing General Plan (County of Los Angeles, 1980, 1990) and the Draft General Plan 2035 (County of Los Angeles, 2014a) which relate to the EWMPs. Existing General Plan — Conservation and Open Space Element, Adopted 1980 Goal — Conserve Natural Areas: The variety and stability of plant and animal communities requires the preservation of important natural habitats. These are threatened by land development and the resultant extension of roads through environmentally sensitive areas. Policy 12: Protect watershed, stream, and riparian vegetation to minimize water pollution, soil erosion and sedimentation, maintain natural habitats, and aid in ground water recharge. Goal — Protect Mineral Resources: In the past, valuable mineral resources have been lost when incompatible urban uses were moved into productive areas. These reserves must be protected, and potential sites identified. At the same time, mineral production must not be allowed top conflict seriously with the goals of environmental protection. Policy 15: Protect and conserve existing mineral resources, evaluate the extent and value of additional deposits, and require future reclamation of depleted sites. Goal — Protect Public Safety: Our society places high value on human life. Development in areas subject to fires, floods, seismic and geologic hazards can result in loss of life and property, and increased governmental costs. Steep sloping lands are particularly vulnerable to fire, landslide, mudslide and erosion hazards. Protection and proper management of lands subject to these hazards are needed. Policy 21: Restrict urban development in areas subject to seismic and geologic hazards. Policy 22: Restrict urban development in flood prone areas, and thus avoid major new flood control works. Maintain natural watershed processes by regulating development in tributary watersheds. Minimize increased runoff, erosion, and siltation of streambeds that would limit the uses of streams and water bodies for recreation and other beneficial water -rated uses. Existing General Plan — Safety Element, Seismic Hazards, Adopted 1990 Goal: Minimize injury and loss of life, property damage, and the social, cultural, and economic impacts caused by earthquake hazards. IA County Flood Control District 3.5-16 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources Policy 1: Encourage the use of non -urbanized segments of active fault zones for rural and open space purposes. Policy 2: Review projects proposing new expansion and construction of new development, especially critical facilities, and encourage them to avoid localities exposed to high earthquake hazards through such techniques as cluster development and transfer of development rights. Policy 3: Continue enforcement of stringent site investigations (such as seismic, geologic, and soils investigations) and implementation of adequate hazard mitigation measures for development projects in areas of high earthquake hazard, especially those involving critical facilities. Do not approve proposals and projects which cannot mitigate safety hazards to the satisfaction of responsible agencies. Existing General Plan — Safety Element, Geologic Hazards, Adopted 1990 Goal: Protect public safety and minimize the social and economic impacts from geologic hazards. Policy 8: Review proposals and projects proposing new development and expansion of existing development in areas susceptible to land sliding, debris flow, and rock falls and in areas where collapsible or expansive soils are a significant problem; and disapprove projects which cannot mitigate safety hazards to the satisfaction of responsible agencies. Policy 9: Continue to improve and enforce stringent slope investigation and design standards, and to apply innovative hazard mitigation and maintenance plans for development in hillside areas. Policy 10: Upgrade slope maintenance measures and improve emergency response capability in hillside areas. Existing General Plan — Land Use Element, Adopted 1980 Goal: Conserve resources and enhance environmental quality. Policy 26: Protect known mineral resource reserves (including sand and gravel) from encroachment of incompatible land uses. Draft General Plan, 2014 — Conservation and Natural Resources Element Goal — C/NR-5: Protected and useable local surface water resources. (Some of these policies also apply to this geology section) Policy C/NR 5.2: Require compliance by all County departments with adopted Municipal Separate Storm Sewer System (MS4), General Construction, and point source NPDES permits. IA County Flood Control District 3.5-17 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources Policy C/NR 5.4: Actively engage in implementing all approved Enhanced Watershed Management Programs/Watershed Management Programs and Coordinated Integrated Monitoring Programs/Integrated Monitoring Programs or other County -involved TMDL implementation and monitoring plans. Policy C/NR 5.6: Minimize point and non -point source water pollution. (This applies to this geology section because this policy would include minimizing erosion that generates sediment) Goal — C/NR-10: Locally available mineral resources to meet the needs of construction, transportation, and industry. Policy C/NR 10.1: Protect MRZ-2s and access to MRZ-2s from development and discourage incompatible adjacent land uses. Draft General Plan, 2014 — Safety Element Goal S 1: An effective regulatory system that prevents or minimizes personal injury, loss of life and property damage due to seismic and geotechnical hazards. Policy S 1.1: Discourage development in Seismic Hazard and Alquist-Priolo Earthquake Fault Zones. Policy S 1.3: Require developments to mitigate geotechnical hazards, such as soil instability and landsliding, in Hillside Management Areas through siting and development standards. City General Plans The numerous cities encompassed by the EWMP area all have their own respective city General Plans, which may contain policies that address geology and minerals. As implementation of the individual structural BMP projects proceeds, specific policies and objectives pertaining to geology and minerals from applicable city General Plans would be identified and evaluated on a project -by -project basis during subsequent CEQA environmental processes. County of Los Angeles Building Code Section 113 Section 113 prohibits the location of most structures for human occupancy across the traces of active faults, and lessens the impacts of fault rupture. County of Los Angeles Low Impact Development Manual • The County of Los Angeles (County) prepared the 2014 Low Impact Development Standards Manual (LID Standards) to comply with the requirements of the National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit for stormwater and non-stormwater discharges from the MS4 within the coastal watersheds of Los Angeles County (CAS004001, Order No. R4-2012- 0175), referred to as the 2012 MS4 Permit (County of Los Angeles, 2014b). The LID IA County Flood Control District 3.5-18 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources Standards provide guidance for the implementation of storrnwater quality control measures in new development and redevelopment projects in unincorporated areas of the County with the intention of improving water quality and mitigating potential water quality impacts from storrnwater and non-stormwater discharges. The November 2013 LID Ordinance became effective December 5, 2013. City of Los Angeles Low Impact Development Manual In November 2011, the City of Los Angeles adopted the Stormwater Low Impact Development (LID) Ordinance #181899) with the stated purpose of: • Requiring the use of LID standards and practices in future developments and redevelopments to encourage the beneficial use of rainwater and urban runoff • Reducing storrnwater/urban runoff while improving water quality • Promoting rainwater harvesting • Reducing offsite runoff and providing increased groundwater recharge • Reducing erosion and hydrologic impacts downstream • Enhancing the recreational and aesthetic values in our communities The City institutionalized the use of LID techniques for development and redevelopment projects. Subsequent to the adoption of the Stormwater LID Ordinance, the City prepared the Development Best Management Practices Handbook, Low Impact Development Manual, dated June 2011, to describes the required BMPs (City of Los Angeles, 2011). Other Cities LID Various other cities within the County also have LID standards or guidance. The goals, objectives, and content of the LID document are similar to that of the County and City of Los Angeles, and are not referenced here. 3.5.3 Impact Analysis The proposed program's potential impacts were assessed using the California Environmental Quality Act (CEQA) Guidelines Appendix G Checklist. This section discusses the key issue areas identified in the CEQA Guidelines with respect to the project's potential effect to geologic and mineral resources. Thresholds of Significance For the purposes of this PEIR and consistency with Appendix G of the CEQA Guidelines, the project would have a significant impact on geologic resources if it would: • Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: IA County Flood Control District 3.5-19 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources Rupture of a known earthquake fault, as delineated on the most recent Alquist- Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault; Strong seismic groundshaking; Seismic -related ground failure, including liquefaction; or Landslides • Result in substantial soil erosion or the loss of topsoil • Be located on a geologic unit that is unstable or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse • Be located on expansive soils, as defined in 24 CCR 1803.5.3 of the CBC (2013)2 • Have soils incapable of adequately supporting the use of a septic tank or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater The project would have a significant impact on mineral resources if it would: • Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state • Result in the loss of availability of a locally important mineral resource recovery site delineated on a local General Plan, Specific Plan, or other land use plan Project Impact Discussion Exposure to Seismic -Related Hazards Impact 3.5-1: The proposed program could locate new facilities in areas susceptible to seismic impacts such as (1) rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault, (2) strong seismic groundshaking, or (3) seismically induced liquefaction or landslides, which could expose people, structures, or habitat to potential risk of loss, damage, injury, or death, Structural (Regional, Centralized, and Distributed) BMPs The EWMP area lies in a region that is seismically active and includes numerous active faults. In the event of an earthquake, fault rupture and seismic groundshaking could be experienced in the project area, as is typical throughout Southern California. The seismic groundshaking could trigger seismically induced liquefaction, landslides, or other slope failure. As discussed in Section 3.5.1, Environmental Setting, and shown in Figure 3.5-2, 10 active faults are known within the project area. Facilities constructed on or within up to 500 feet of an active fault trace could be damaged by fault rupture. Seismic groundshaking and seismically induced liquefaction, 2 The updated CBC no longer cites the UBC Table I8 -1-B for identifying expansive soils. The checklist in Appendix G of the CEQA Guidelines still refers to this out of date table. This PEIR uses the updated CBC section as defined in 24 CCR 1803.5.3 of the CBC (2013). IA County Flood Control District 3.5-20 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Seainq, Impacts, and Mitigation Measures 3.5 Geologic Resources landslides, or other slope failure could result in structural damage to facilities, which in turn could affect operation of related systems. Regional and centralized BMPs with above -ground infrastructure components that could be seismically impacted include infiltration, bioretention, or detention basins with above ground berms or levees that form the basin. Subsurface infiltration, retention, or storage structures (e.g., trenches, galleries, and wells) and structures generally flush with the surrounding area (e.g., permeable pavement, swales, filter strips, and wetlands) would be less vulnerable to significant seismic damage, but could still be damaged during large earthquakes. Damage to these underground systems include structural damage to the underground vaults, connection to existing MS4, and underdrains that connect to the MS4. Centralized BMPs that consist of large diversion and treatment systems can also experience structural damage under seismic events. Distributed structural BMPs would be smaller, site- or parcel -specific structures and would therefore be less vulnerable to seismic damage. Although distributed structural BMPs that include above -ground components (e.g., sides or levees to basins, planter boxes, rain barrels, water clarifiers) could be damaged by a seismic event, the resulting release of water would be smaller and less likely to cause significant damage. Damage to these underground systems includes structural damage to the underground vaults, connection to existing MS4, and underdrains that connect to the MS4. For all three structural BMPs, infiltration of water to the underlying soil can result in an increased potential for soil instability and liquefaction. All of the proposed facilities would be uninhabitable. However, damage to facilities could result in threats to the safety of people in downslope areas or damage to other downslope facilities. To ensure impacts to public safety are minimized, prior to construction of each specific project, a design -level geotechnical investigation would be required. The geotechnical evaluation would identify the potential geologic and seismic hazards and would recommend site-specific design criteria to abate seismic hazards, such as special foundations and structural setbacks, and these recommendations would be incorporated into the design of individual proposed projects. The geotechnical investigations would be conducted by a geotechnical engineer. Furthermore, project designs would be subject to the CBC design standards and local codes.3 The California Professional Engineers Act (Building and Professions Code Sections 6700-6799), and the Codes of Professional Conduct, as administered by the California Board of Professional Engineers and Land Surveyors, provide the basis for regulating and enforcing engineering practice in California. In addition, the County of Los Angeles LID Standards, as well as LID Standards for the various cities, require that all structural BMPs (regional, centralized, and distributed) that include ground - disturbance activities, regardless of size; conduct a site assessment; and identify design considerations. The site assessment specifically includes identifying the potential for fault rupture, seismic shaking, and seismically induced liquefaction and other ground failures. The 3 A geotechnical engineer specializes in structural behavior of soil and rocks. Geotechnical engineers conduct soil investigations, determine soil and rock characteristics, provide input to structural engineers, and provide recommendations to address problematic conditions or soils. IA County Flood Control District 3.5-21 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources design considerations must be prepared by a geotechnical engineer and must specifically include design features to minimize or avoid damage from fault rupture and seismic events. It is likely that the structural elements of each proposed project would be subjected to a moderate to strong earthquake at least once during their operational life which could include surface displacement from fault rupture or seismic shaking. Completion of a comprehensive design -level geotechnical investigation, adherence to the current CBC, LID Standards, and local ordinances and laws regulating construction, and the application of proven seismic design criteria as standard engineering practice would ensure that structures are designed to withstand seismic events without sustaining substantial damage or collapsing. Therefore, this impact is considered less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non-Structural/Institutional BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities that are susceptible to seismic impacts. Consequently, there would be no new facilities that would place people or structures at risk to injury or damage due to fault rupture. Therefore, this impact would have no impact relative to fault rupture. Mitigation Measures: None required Significance Determination: No impact Soil Erosion or Topsoil Loss Impact 3.5-2: The proposed program could result in substantial soil erosion or the loss of topsoil. Structural (Regional, Centralized, and Distributed) BMPs Construction activities for proposed program facilities such as excavation and grading could result in soil erosion or loss of topsoil during rain or high -wind events. Erosion could damage facilities, pose risk to people, or damage habitat or improvements downslope of a proposed program, resulting in potentially significant impacts. However, each BMP type would generally serve to slow down or fully retain stormwater runoff. This would act to reduce erosion potential compared with existing conditions. Discharge points from centralized and distributed BMPs would be designed to minimize scour potential, and in any case improve scour potential from existing conditions. To prevent erosion and runoff from construction sites, the CGP requires the preparation and implementation of a SWPPP that would include BMPs to control erosion and off-site IA County Flood Control District 3.5-22 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources sedimentation from construction sites. The required compliance with the SWPPP and implementation of erosion control BMPs would ensure that soil erosion and loss of topsoil would be minimized to levels considered less than significant. Proposed projects that are smaller than one acre would be required to comply with the BMPs identified in the Los Angeles County MS4 Permit (RWQCB Order No. R4-2010-0175), which would implement minimum -control BMPs to provide erosion control and sediment control strategies for small construction sites (see Chapter 3.8, Surface Hydrology and Water Quality, for a more detailed explanation of the MS4 Permit.). Compliance with SWPPPs and runoff BMPs (will vary with the area of disturbance, construction vehicles used, site grade, and duration of project) would ensure less than significant erosion during construction. Mitigation Measures: None required Significance Determination: Less than significant Non-Structural/Institutional BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no new facilities that would increase erosion or the loss of topsoil due to the construction of new facilities. Mitigation Measures: None required Significance Determination: No impact Soil Stability Impact 3.5-3: The proposed program could be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the program, and potentially result in on-site or off-site non -seismically induced geologic hazards such as landslides, lateral spreading, subsidence, collapse or sinkholes, settlement, or slope failure, Structural (Regional, Centralized, and Distributed) BMPs Non -seismically -induced geologic hazards such as landslides, lateral spreading, settlement, and slope failure can be caused by unstable soils. Infiltration of water into surficial soils can increase soil instability. Distributed structural BMPs would be smaller, site- or parcel -specific structures and would therefore be less vulnerable to geologic hazards. Although distributed structural BMPs that include above ground components (e.g., sides or levees to basins, planter boxes, rain barrels, water clarifiers) could be damaged by geologic hazards, the resulting release of water would be smaller and less likely to cause significant damage. The regional and centralized structural BMPs that include the construction of larger physical structures would be more susceptible to unstable soils. IA County Flood Control District 3.5-23 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources Furthermore, infiltration could result in saturated soils, soil piping through preferential pathways, breakouts due to infiltrated water finding utility trenches and other preferential pathways, and raising the local groundwater levels such that infrastructure foundations and underground structures could be affected by unstable soils. Increased saturation of shallow soils could reduce the strength of the soils, resulting in an increased susceptibility to failure (e.g., lateral spreading, settlement, instability, soil piping, reduced or loss of shear strength). In addition, infiltrated water could become perched or find preferential pathways such as utility trenches and potentially inundate or destabilize subterranean structures and utilities, or breakout downstream and damage above ground structures. To ensure that structural BMPs are not undermined by unstable soils or impact adjacent infrastructure and buildings, Mitigation Measure GEO-1 requires that each specific project would require a design -level geotechnical investigation. The geotechnical evaluation would identify the potential for geologic hazards and would recommend site-specific design criteria to abate geologic hazards, such as drainage barriers, lined trenches, continued monitoring of subsurface conditions, added site drainage, special foundations, and structural setbacks, and these recommendations would be incorporated into the design of individual proposed projects. Implementing the design requirements in the CBC and local (County and city) ordinances and recommendations of geotechnical investigations would ensure that all structures are constructed in compliance with the applicable laws, regulations, and policies, including the LID Ordinances. Therefore, this impact is considered less than significant. Mitigation Measures: GEO-1: Prior to approval of infiltration BMPs, implementing agencies shall conduct a geotechnical investigation of each infiltration BMP site to evaluate infiltration suitability. If infiltration rates are sufficient to accommodate an infiltration BMP, the geotechnical investigation shall recommend design measures necessary to prevent excessive lateral spreading that could destabilize neighboring structures. Implementing agencies shall implement these measures in project designs. Significance Determination: Less than significant (The application of this mitigation measure to specific BMP types and categories is identified in Table 3.5-3.) Non-Structural/Institutional BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities that would be located on a geologic unit or soil that is unstable. Consequently, there would be no new facilities that would increase erosion or the loss of topsoil due to the construction of new facilities. Mitigation Measures: None required Significance Determination: No impact IA County Flood Control District 3.5-24 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources Expansive Soils Impact 3.5-4: The proposed program could be located on expansive soil as defined in 24 CCR 1803.5.3 of the California Building Code (2013), creating substantial risks to life or structures, Structural (Regional, Centralized, and Distributed) BMPs Soil expansion, also referred to as linear extensibility or shrink -swell, occurs in certain clayey soils that when subjected to repeated wetting and drying, undergo shrinking or swelling. As discussed in Section 3.5.1, Environmental Setting, some areas within the project area have expansive soil. Soil expansion can occur in expansive soils that have not been removed or properly conditioned. The differential ground movement that occurs through soil expansion could result in structural damage to facilities over the long term, which in turn could affect operation of related systems. Damage to the facilities could result in threats to the safety of people at or near the facilities. All structural BMPs, regardless of size (regional, centralized, or distributed) would be susceptible to damage from soil expansion if placed on susceptible soil. Some distributed structural BMPs would be less or not susceptible (e.g., bioswales, planter boxes, flow-through treatment BMPs [debris booms/nets, end -of -pipe nets, floating trash booms]) because soil expansion beneath these BMPs, if any, would not result in significant damage. Completion of a comprehensive design -level geotechnical investigation, implementing the design requirements in the CBC and local (County and city) ordinances, and ensuring that all structures are constructed in compliance with the applicable laws, regulations, and policies, including the LID Ordinances, would ensure that structural BMPs are constructed in a manner that avoids impacts from expansive soils. Therefore, this impact is considered less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non-Structural/Institutional BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Therefore, this impact would have no impact relative to expansive soils. Mitigation Measures: None required Significance Determination: Less than significant IA County Flood Control District 3.5-25 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources On -Site Wastewater Treatment Systems Impact 3.5-5: The proposed program could have soils incapable of adequately supporting the use of a septic tank or alternative wastewater treatment systems where sewers are not available for the disposal of wastewater, Implementation of the proposed program would not include facilities that require the use of septic systems or alternate wastewater disposal systems where sewers are not available for the disposal of wastewater. Therefore, no impact would occur related to soil suitability for septic or alternative wastewater disposal systems. Mitigation Measures: None required Significance Determination: No impact Mineral Resources Impact 3.5-6: The proposed program could result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state or a locally important mineral resource recovery site delineated on a local General Plan, Specific Plan, or other land use plan. Structural (Regional, Centralized, and Distributed) BMPs The EWMP project area includes mineral resource areas in Los Angeles County that contain known or potentially productive petroleum fields, natural gas, construction aggregate, and mineral deposits. If the construction of a specific proposed program occurred within a mineral resources area, the access to or availability of that mineral resource could be restricted or eliminated. Typical distributed structural BMPs would be constructed within areas that are already urbanized and disturbed, and would therefore not be available for mineral resource activities. Regional or centralized structural BMPs could be constructed in locations that are not already urbanized and are located within a designated MRZ, specifically an MRZ-2, an area with known mineral resources. Siting projects within designated MRZs could be conducted if the BMPs do not impede access to the mineral resources. In any case, siting large and small BMPs would need to comply with local and County General Plan zoning restrictions. Compliance with local General Plans and the County of Los Angeles General Plan would ensure that impacts to mineral resources would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant IA County Flood Control District 3.5-26 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources Non-Structural/Institutional BMPs As discussed in Chapter 2.0, Project Description, Non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no new facilities that would affect mineral resources. Therefore, this impact would have no impact. Mitigation Measures: None required Significance Determination: Less than significant Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs Although the EWMP area is located within a seismically active region, with a wide range of geologic and soil conditions, these conditions can vary greatly within a short distance, making the cumulative context for potential impacts one that is typically more localized. Consequently, most projects would have minimal potential to impact or be impacted by other projects. Impacts would be largely contained within the footprint of each individual proposed project. Many of the distributed BMPs, as well as the larger -scale regional and central BMPs, would include infiltration as a primary component. Consequently, many infiltration projects could be implemented within each watershed. This would result in a significant amount of water infiltrated into the subsurface, which would saturate some shallow soils below the infiltration basins and raise groundwater levels. A general rise in groundwater levels due to stormwater retention and infiltration would provide water supply benefits to the region, but could also raise groundwater levels above current levels. A regional increase in the amount of infiltration added to subsoils throughout the urbanized areas where the structural BMPs will be installed may increase the potential for impacts to existing infrastructure and buildings. To ensure that structural BMPs are not undermined by unstable soils or impact adjacent infrastructure and buildings, each specific project would require a design -level geotechnical investigation. The geotechnical evaluation would identify the potential for geologic hazards and would recommend site-specific design criteria to abate geologic hazards, such as drainage barriers, lined trenches, continued monitoring of subsurface conditions, added site drainage, special foundations, and structural setbacks, and these recommendations would be incorporated into the design of individual proposed projects. Implementation of these requirements for a geotechnical investigation, assessment, and design recommendation for structural BMPs that include adding flows by infiltration and filtration to the subsurface should address the potential for cumulative impacts. All the groundwater basins in Los Angeles County are actively used for multiple beneficial uses; most are designated as drinking water sources. The potential for groundwater levels to rise high enough to impact structural foundations and other support structures is low since the aquifers are generally over 100 feet below ground surface and are actively managed by overlying users. Furthermore, targeted pumping in areas with elevated groundwater levels would mitigate any soil stability issues. However, water levels may rise in local areas with limited extraction capabilities. a County Flood Control District 3.5-27 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources In addition, percolating water could become perched or find preferential pathways such as utility trenches and inundate underground utilities or structures. The cumulative effect of multiple infiltration projects could increase the severity of the perched or migrating water. However, Mitigation Measure GEC -1 would require that BMPs be designed to avoid infiltrating in areas with the potential for perched groundwater or migration. This would minimize the cumulative impact to regional infrastructure. In addition, groundwater managers in each of the watersheds currently manage pumping effectively to prevent impacts to structural foundations resulting from groundwater mounding from existing recharge efforts. Under existing conditions, in areas with chronically high groundwater levels, dewatering operations are installed, and the water is beneficially used wherever possible. Implementation of Mitigation Measure GEO-2 would require that the Implementing Agency notify groundwater managers of local infiltration projects to provide better coordination between stormwater retention and groundwater levels management. With this coordination, the potential contribution to cumulative effects to soil stability from elevated groundwater levels would be considered less than significant. Significance Determination before Mitigation: Potentially significant Mitigation Measures: GEO-2: Prior to installing BMPs designed to recharge the local groundwater supplies, the Implementing Agency shall notify local groundwater managers, including the Upper Los Angeles River Area Water Master, the Water Replenishment District of Southern California, or the San Gabriel Water Master as well as local water producers such as local municipalities and water companies. The Implementing Agency shall coordinate BMP siting efforts with groundwater managers and producers to mitigate high groundwater levels while increasing local water supplies. Significance Determination after Mitigation: Less than significant (The application of this mitigation measure to specific BMP types and categories is identified in Table 3.5-3.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no new facilities that would contribute to cumulative impacts. Mitigation Measures: None required Significance Determination: Less than significant IA County Flood Control District 3.5-28 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.5 Geologic Resources 3.5.4 Summary of Impact Assessment Table 3.5-3 shows a summary of the structural BMPs requiring mitigation. TABLE 3.5-3 SUMMARY OF GEOLOGIC RESOURCE IMPACTS REQUIRING MITIGATION MEASURES Thresholds of Significance Regional BIVPs Exposure Regional Detention and to Soil No No On -Site No Yes Infiltration Seismic- Erosion or Wastewater Regional Capture, Related Topsoil Soil Expansive Treatment Mineral Cumulative Structural BMPs Hazards Loss Stability Soils Systems Resources Impacts Centralized BMP Applicable None None No None No None Yes Mitigation Measures: Required Required GEO-1 Required None Required Required GEO.2 Regional BIVPs Regional Detention and No No No No No No Yes Infiltration Regional Capture, No No No No No No Yes Detention and Use Centralized BMP Bioinfiltration No No No No No No Yes Constructed Wetlands No No No No No No Yes Treatment/Low-Flow No No No No No No Yes Diversions Creek, River, Estuary No No No No No No Yes Restoration Distributed BMPs Site -Scale Detention No No No No No No Yes LID — Infiltration/Filtration No No No No No No Yes BMPs — Porous Pavement, Green Streets, Bioswale/Filter Strips, Downspout Disconnects LID — Green No No No No No No Yes Infrastructure — Capture and Use—Cisterns, Rain Barrels, Green roofs, Planter Boxes Flow through Treatment No No No No No No Yes BMPs Source -Control No No No No No No Yes Treatment BMPs (catch basin inserts/screens, hydrodynamic separators, gross solids removal devices) Low -Flow Diversions No No No No No No Yes NOTE: These conclusions are based on typical BMP size and location. IA County Flood Control District 3.5-29 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.6 Greenhouse Gas Emissions This section provides a discussion of global climate change, existing regulations pertaining to global climate change, and potential greenhouse gas (GHG) emissions resulting from implementation of the proposed program. Impacts related to GHGs and climate change are analyzed and mitigation measures are provided for any potentially significant impacts. The methods of analyzing emissions described in this section are consistent with the recommendations of the South Coast Air Quality Management District (SCAQMD). 3.6.1 Environmental Setting Affected Environment This section presents a discussion of existing climate conditions, the current state of climate change science, and GHG emissions sources in California. Climate Climate is the accumulation of daily and seasonal weather events over a long period of time, whereas weather is defined as the condition of the atmosphere at any particular time and place (Ahrens, 2003). The proposed program is located in the County of Los Angeles within the Basin, which has a distinctive climate determined by its terrain and geographic location. The general region lies in the semipermanent high-pressure zone of the eastern Pacific, resulting in a mild climate tempered by cool sea breezes with light average wind speeds. The usually mild climate is interrupted occasionally by periods of extremely hot weather, winter storms, or Santa Ana winds. Climate Change Overview Various gases in the earth's atmosphere, classified as GHGs, play a critical role in determining its surface temperature. Solar radiation enters earth's atmosphere from space, and a portion of the radiation is absorbed by the earth's surface. Earth re -radiates this energy back toward space, but the properties of the radiation change from high -frequency solar radiation to lower -frequency infrared radiation. GHGs, which are transparent to solar radiation, are effective in absorbing infrared radiation. As a result, this radiation (that otherwise would have escaped back into space) is now retained in the atmosphere, and results in a warming of the atmosphere. This phenomenon, known as the greenhouse effect, is responsible for maintaining a habitable climate on earth. Without the greenhouse effect, the earth would not be able to support life as we know it. Prominent GHGs contributing to the greenhouse effect are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), chlorofluorocarbons (CFCs), perfluorocarbon (PFCs), and sulfur hexafluoride (SF6). Much of the scientific literature suggests that human - caused emissions of these GHGs in excess of natural ambient concentrations are responsible for intensifying the greenhouse effect and have led to a trend of unnatural warming of earth's climate, known as global climate change or global warming. While there is some debate regarding this issue, it is unlikely that global climate change of the past 50 years can be explained without contribution from human activities (IPCC, 2007). IA County Flood Control District 3.6-1 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 reenhouse Gases Climate change is a global problem. GHGs are global pollutants, unlike criteria air pollutants and toxic air contaminants, which are pollutants of regional and local concern. Whereas pollutants with localized air quality effects have relatively short atmospheric lifetimes (about one day), GHGs have long atmospheric lifetimes (one year to several thousand years). GHGs persist in the atmosphere for long enough time periods to be dispersed around the globe. Although the exact lifetime of any particular GHG molecule is dependent on multiple variables and cannot be pinpointed, it is understood that more CO2 is emitted into the atmosphere than is sequestered by ocean uptake, vegetation, and other forms of sequestration. Of the total annual human -caused CO2 emissions, approximately 54 percent is sequestered through ocean uptake, uptake by northern hemisphere forest regrowth, and other terrestrial sinks within 1 year, whereas the remaining 46 percent of human -caused CO2 emissions remains stored in the atmosphere (Seinfeld and Pandis, 1998). Similarly, impacts of GHGs are borne globally, as opposed to localized air quality effects of criteria air pollutants and toxic air contaminants. The quantity of GHGs that it takes to ultimately result in climate change is not precisely known; however, it is clear that the quantity is enormous, and no single project would measurably contribute to a noticeable incremental change in the global average temperature, or to global, local, or micro climates. From the standpoint of the California Environmental Quality Act (CEQA), GHG impacts to global climate change are inherently cumulative. Greenhouse Gas Emission Sources According to much of the scientific literature on this topic, emissions of GHGs contributing to global climate change are attributable in large part to human activities associated with the transportation, industrial/manufacturing, utility, residential, commercial, and agricultural sectors. In California, the transportation sector is the largest emitter of GHGs, followed by electricity generation (CARB, 2014a). Emissions of CO2 are by-products of fossil fuel combustion. CH4, a highly potent GHG, results from off -gassing (the release of chemicals from nonmetallic substances under ambient or greater pressure conditions) and is largely associated with agricultural practices and landfills. N2O is also largely attributable to agricultural practices and soil management. CO2 sinks, or reservoirs, include vegetation and the ocean, which absorb CO2 through sequestration and dissolution, respectively, and are two of the most common processes of CO2 sequestration. California is the 12th to 16th largest emitter of CO2 in the world (CEC, 2006a). California produced 452 million gross metric tons of CO2 equivalent (CO2e) in 2010 (CARB, 2014a). CO2e is a measurement used to account for the fact that different GHGs have different potential to retain infrared radiation in the atmosphere and contribute to the greenhouse effect. Expressing emissions in CO2e takes the contributions to the greenhouse effect of all GHG emissions and converts them to the equivalent effect that would occur if only CO2 were being emitted. This measurement, known as the global warming potential (GWP) of a GHG, is dependent on the lifetime, or persistence, of the gas molecule in the atmosphere. For example, as described in Appendix C, Calculation References, of the General Reporting Protocol of the California Climate Action Registry (CCAR, 2009), 1 ton of CH4 has the same contribution to the greenhouse effect as approximately 21 tons of CO2. Therefore, CH4 is a much more potent GHG than CO2. a County Flood Control District 3.6-2 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 Greenhouse Gases Combustion of fossil fuel in the transportation sector was the single largest source of California's GHG emissions in 2012, accounting for 36 percent of total GHG emissions in the state (CARB, 2014a). This sector was followed by the electric power sector (including both in-state and out-of- state sources) (21 percent) and the industrial sector (19 percent) (CARB, 2014a). 3.6.2 Regulatory Framework Federal The federal Clean Air Act (CAA) requires the U.S. Environmental Protection Agency (USEPA) to define national ambient air quality standards to protect public health and welfare in the United States. The CAA does not specifically regulate GHG emissions; however, on April 2, 2007, the U.S. Supreme Court in Massachusetts v. U.S. Environmental Protection Agency determined that GHGs are pollutants that can be regulated under the CAA. Currently, there are no federal regulations that establish ambient air quality standards for GHGs. On December 7, 2009, USEPA adopted its Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases under the CAA (Endangerment Finding). The Endangerment Finding is based on Section 202(a) of the CAA, which states that the USEPA Administrator should regulate and develop standards for "emission[s] of air pollution from any class or classes of new motor vehicles or new motor vehicle engines, which in [its] judgment cause, or contribute to, air pollution which may reasonably be anticipated to endanger public health or welfare." The rule addresses Section 202(a) in two distinct findings. The first addresses whether the concentrations of the six key GHGs (CO2, CH4, N2O, HFCs, PFCs, and SF6) in the atmosphere threaten the public health and welfare of current and future generations. The second addresses whether the combined emissions of GHGs from new motor vehicles and motor vehicle engines contribute to atmospheric concentrations of GHGs and, therefore, contribute to the threat of climate change. The USEPA Administrator determined that atmospheric concentrations of GHGs endanger the public health and welfare within the meaning of Section 202(a) of the CAA. The evidence supporting this finding consists of human activity resulting in "high atmospheric levels" of GHG emissions, which are likely responsible for increases in average temperatures and other climatic changes. Furthermore, the observed and projected results of climate change (e.g., higher likelihood of heat waves, wild fires, droughts, sea level rise, and higher intensity storms) are a threat to the public health and welfare. Therefore, GHGs were found to endanger the public health and welfare of current and future generations. Specific GHG regulations that USEPA has adopted to -date are as follows: 40 CFR Part 98. Mandatory Reporting of Greenhouse Gases Rule. This rule requires mandatory reporting of GHG emissions for facilities that emit more than 25,000 metric tons Of CO2e emissions per year (USEPA, 2011). Additionally, reporting of emissions is required for owners of S176- and PFC-insulated equipment when the total nameplate capacity of these insulating gases is above 17,280 pounds. IA County Flood Control District 3.6-3 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 reenhouse Gases 40 CFR Part 52. Proposed Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule. USEPA recently mandated to apply Prevention of Significant Deterioration (PSD) requirements to facilities whose stationary source CO2e emissions exceed 75,000 tons per year (USEPA, 2010). The USEPA also recently released a proposed rule which would regulate GHG emissions from existing power plants across the nation. The proposed rule establishes state -by -state 2030 GHG goals. State The California Air Resources Board (CARB) is the agency responsible for coordination and oversight of state and local air pollution control programs in California. Various statewide and local initiatives to reduce the state's contribution to GHG emissions have raised awareness that, even though the various contributors to and consequences of global climate change are not yet fully understood, global climate change is under way, and there is a real potential for severe adverse environmental, social, and economic effects in the long term. Because every nation emits GHGs and therefore makes an incremental cumulative contribution to global climate change, cooperation on a global scale will be required to reduce the rate of GHG emissions to a level that can help to slow or stop the human -caused increase in average global temperatures and associated changes in climatic conditions. There are currently no state regulations in California that establish ambient air quality standards for GHGs. However, California has passed laws directing CARB to develop actions to reduce GHG emissions, and several state legislative actions related to climate change and GHG emissions have come into play in the past decade. Assembly Bill 1493 (Pavley) In 2002, then -Governor Gray Davis signed Assembly Bill (AB) 1493. AB 1493 required that CARB develop and adopt, by January 1, 2005, regulations that achieve "the maximum feasible reduction of greenhouse gases emitted by passenger vehicles and light-duty trucks and other vehicles determined by CARB to be vehicles whose primary use is noncommercial personal transportation in the state." To meet the requirements of AB 1493, in 2004 CARB approved amendments to the California Code of Regulations (CCR) adding GHG emissions standards to California's existing standards for motor vehicle emissions. Amendments to CCR Title 13, Sections 1900 and 1961 (13 CCR 1900, 1961), and adoption of Section 1961.1 (13 CCR 1961.1) require automobile manufacturers to meet fleet -average GHG emissions limits for all passenger cars, light-duty trucks within various weight criteria, and medium -duty passenger vehicle weight classes (i.e., any medium - duty vehicle with a gross vehicle weight rating less than 10,000 pounds that is designed primarily for the transportation of persons), beginning with the 2009 model year. For passenger cars and light-duty trucks with a loaded vehicle weight of 3,750 pounds or less, the GHG emission limits for the 2016 model year are approximately 37 percent lower than the limits for the first year of the regulations, the 2009 model year. For light-duty trucks with a loaded vehicle weight of 3,751 IA County Flood Control District 3.6-4 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 Greenhouse Gases pounds to gross vehicle weight of 8,500 pounds, as well as medium -duty passenger vehicles, GHG emissions would be reduced approximately 24 percent between 2009 and 2016. Executive Order S-03-05 Executive Order S-03-05, which was signed by Governor Arnold Schwarzenegger in 2005, proclaims that California is vulnerable to the impacts of climate change. It declares that increased temperatures could reduce the Sierra's snowpack, further exacerbate California's air quality problems, and potentially cause a rise in sea levels. To combat those concerns, the Executive Order established total GHG emission targets. Specifically, emissions were to be reduced to the 2000 level by 2010 and are to be reduced to the 1990 level by 2020, and to 80 percent below the 1990 level by 2050. The Executive Order directed the Secretary of the California Environmental Protection Agency (CalEPA) to coordinate a multi -agency effort to reduce GHG emissions to the target levels. The Secretary will also submit biannual reports to the governor and state legislature describing progress made toward reaching the emission targets, impacts of global warming on California's resources, and mitigation and adaptation plans to combat these impacts. To comply with the Executive Order, the Secretary of Ca1EPA created the California Climate Action Team (CCAT), which is made up of members from various state agencies and commissions. CCAT released its first report in March 2006. The report proposed to achieve the targets by building on voluntary actions of California businesses, local government, and community actions, as well as through state incentive and regulatory programs. Assembly Bill 32 (California Global Warming Solutions Act of 2006) In September 2006, Governor Schwarzenegger signed the California Global Warming Solutions Act (AB 32; California Health and Safety Code Division 25.5, Sections 38500-38599). AB 32 establishes regulatory, reporting, and market mechanisms to achieve quantifiable reductions in GHG emissions and establishes a cap on statewide GHG emissions. AB 32 requires that statewide GHG emissions be reduced to 1990 levels by 2020. This reduction will be accomplished by enforcing a statewide cap on GHG emissions that will be phased in starting in 2012. To effectively implement the cap, AB 32 directs CARB to develop and implement regulations to reduce statewide GHG emissions from stationary sources. Senate Bill 1368 Senate Bill (SB) 1368 is the companion bill of AB 32 and was signed by Governor Schwarzenegger in September 2006. SB 1368 required the California Public Utilities Commission (CPUC) to establish a GHG emission performance standard for baseload generation from investor-owned utilities. CPUC adopted a GHG Emissions Performance Standard in January 2007. The California Energy Commission (CEC) adopted consistent regulations for implementing and enforcing SB 1368 for the state's publicly owned utilities in August 2007. These standards cannot exceed the GHG emission rate from a baseload combined -cycle natural -gas-fired plant. The legislation further requires that all electricity provided to California, including imported electricity, must be generated from plants that meet the standards set by the CPUC and CEC. IA County Flood Control District 3.6-5 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 reenhouse Gases Executive Order S-1-07 Executive Order 5-1-07, which was signed by Governor Schwarzenegger in 2007, proclaims that the transportation sector is the main source of GHG emissions in California, generating more than 40 percent of statewide emissions. It establishes a goal to reduce the carbon intensity of transportation fuels sold in California by at least ten percent by 2020. This order also directed CARB to determine whether this Low Carbon Fuel Standard (LCFS) could be adopted as a discrete early -action measure as part of the effort to meet the mandates in AB 32. On April 23, 2009, CARB approved the proposed regulation to implement the LCFS. The LCFS will reduce GHG emissions from the transportation sector in California by about 16 million metric tons (MMT) in 2020. Senate Bill 97 SB 97, signed August 2007 (Chapter 185, Statutes of 2007; Public Resources Code Sections 21083.05 and 21097), acknowledges that climate change is a prominent environmental issue that requires analysis under CEQA. The bill directs the California Office of Planning and Research (OPR) to prepare, develop, and transmit to the California Natural Resources Agency, guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions, as required by CEQA, by July 1, 2009. The Natural Resources Agency was required to certify or adopt those guidelines by January 1, 2010. On April 13, 2009, OPR submitted to the Secretary for Natural Resources its proposed amendments to the CEQA Guidelines for GHG emissions, as required by SB 97. On February 16, 2010, the Office of Administrative Law approved the amendments, and filed them with the Secretary of State for inclusion in the CCR. The amendments became effective on March 18, 2010. CARB Climate Change Scoping Plan On December 11, 2008, CARB adopted its Scoping Plan, which functions as a roadmap of CARB's plans to achieve GHG reductions in California required by AB 32 through subsequently enacted regulations (CARB, 2008). CARB's Scoping Plan contains the main strategies California will implement to reduce CO2e emissions by 169 MMT, or approximately 28.4 percent, from the state's projected 2020 emissions level of 596 MMT of CO2e under a "business -as -usual" (BAU) scenario. In August 2011, the Scoping Plan was reapproved by the Board and includes the Final Supplement to the Scoping Plan Functional Equivalent Document. This document includes expanded analysis of project alternatives as well as updates the 2020 emission projections in light of the current economic forecasts. Considering the updated 2020 BAU estimate of 507 MMT CO2e, a 16 percent reduction below the estimated BAU levels would be necessary to return to 1990 levels by 2020. The document also excludes one measure identified in the 2008 Scoping Plan that has been adopted and one measure that is no longer under consideration by CARB (CARB, 2011). CARB's Scoping Plan calculates 2020 BAU emissions as the emissions that would be expected to occur in the absence of any GHG reduction measures. The 2020 BAU emissions estimate was derived by projecting emissions from a past baseline year using growth factors specific to each of the different economic sectors (transportation, electrical power, commercial and residential, a County Flood Control District 3.6-6 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 Greenhouse Gases industrial, etc.). CARB used 3 -year average emissions, by sector, for 2002-2004 to forecast emissions to 2020. At the time CARB's Scoping Plan process was initiated, 2004 was the most recent year for which actual data was available. The measures described in CARB's Scoping Plan are intended to reduce the projected 2020 BAU levels to 1990 levels, as required by AB 32. CARB's Scoping Plan also breaks down the amount of GHG emissions reductions CARB recommends for each emissions sector of the state's GHG inventory. CARB's Scoping Plan calls for the largest reductions in GHG emissions to be achieved by implementing the following measures and standards: • Improved emissions standards for light-duty vehicles (estimated reductions of 31.7 MMT CO2e) • The LCFS (15.0 MMT CO2e) • Energy efficiency measures in buildings and appliances, and the widespread development of combined heat and power systems (26.3 MMT CO2e) • A renewable portfolio standard for electricity production (21.3 MMT CO2e) CARB has identified a GHG reduction target of 5 MMT (of the 174 MMT total) local land use changes (Table 2 of CARB's Plan), by implementation of Reduction Strategy T-3 regarding Regional Transportation -Related GHG Targets. Additional land use reductions may be achieved as SB 375 is implemented. CARB's Scoping Plan states that successful implementation of the plan relies on local governments' land use, planning, and urban growth decisions because local governments have primary authority to plan, zone, approve, and permit land development to accommodate population growth and the changing needs of their jurisdictions. CARB further acknowledges that decisions on how land is used will have large effects on the GHG emissions that will result from the transportation, housing, industry, forestry, water, agriculture, electricity, and natural gas emission sectors. CARB's Scoping Plan does not include any direct discussion about GHG emissions generated by construction activity. Table 3.6-1 shows the Recommended Actions contained in Appendices C and E of CARB's Scoping Plan. TABLE 3.6-1 RECOMMENDED ACTIONS FROM CARB CLIMATE CHANGE SCOPING PLAN ID # Sector Strategy Name T-1 T-2 T-3 Transportation Transportation Transportation Pavley I and II — Light -Duty Vehicle GHG Standards LCFS (Discrete Early Action) Regional Transportation -Related GHG Targets T-4 Transportation Vehicle Efficiency Measures T-5 Transportation Ship Electrification at Ports (Discrete Early Action) T-6 Transportation Goods -movement Efficiency Measures T-7 Transportation Heavy -Duty Vehicle GHG Emission Reduction Measure— Aerodynamic Efficiency (Discrete Early Action) T-8 Transportation Medium- and Heavy -Duty Vehicle Hybridization T-9 Transportation High -Speed Rail a County Flood Control District Enhanced Watershed Management Programs Draft Program Environmental Impact Report 3.6-7 ESA / 140379 January2015 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 reenhouse Gases TABLE 3.6-1 (CONTINUED) RECOMMENDED ACTIONS FROM CARB CLIMATE CHANGE SCOPING PLAN ID # Sector Strategy Name E-1 Electricity and Natural Gas Increased Utility Energy efficiency programs More stringent Building and Appliance Standards E-2 Electricity and Natural Gas Increase Combined Heat and Power Use by 30,000GWh E-3 Electricity and Natural Gas Renewables Portfolio Standard E-4 Electricity and Natural Gas Million Solar Roofs CRA Electricity and Natural Gas Energy Efficiency CR -2 Electricity and Natural Gas Solar Water Heating GBA Green Buildings Green Buildings W-1 Water Water Use Efficiency W-2 Water Water Recycling W-3 Water Water System Energy Efficiency W4 Water Reuse Urban Runoff W-5 Water Increase Renewable Energy Production W-6 Water Public Goods Charge (Water) 1-1 Industry Energy Efficiency and Co -benefits Audits for Large Industrial Sources 1-2 Industry Oil and Gas Extraction GHG Emission Reduction 1-3 Industry GHG Leak Reduction from Oil and Gas Transmission 14 Industry Refinery Flare Recovery Process Improvements 1-5 Industry Removal of CH4 Exemption from Existing Refinery Regulations RW -1 Recycling and Waste Management Landfill CH4 Control (Discrete Early Action) RW -2 Recycling and Waste Management Additional Reductions in Landfill CH4 — Capture Improvements RW -3 Recycling and Waste Management High Recycling/Zero Waste F-1 Forestry Sustainable Forest Target H-1 High GWP Gases Motor Vehicle Air Conditioning Systems (Discrete Early Action) H-2 High GWP Gases SFa Limits in Non -Utility and Non -Semiconductor Applications (Discrete Early Action) H-3 High GWP Gases Reduction in Perfiuorocarbons in Semiconductor Manufacturing (Discrete Early Action) H4 High GWP Gases Limit High GWP Use in Consumer Products (Discrete Early Action, Adopted June 2008) H-5 High GWP Gases High GWP Reductions from Mobile Sources H-6 High GWP Gases High GWP Reductions from Stationary Sources H -7a High GWP Gases Mitigation Fee on High GWP Gases A-1 Agriculture CH4 Capture at Large Dairies a This original measure in the 2008 Scoping Plan was subsequently excluded by CARS in the Final Supplement to the Scoping Plan Functional Equivalent Document in 2011, as CARS staff concluded that implementation of this measure would not be feasible. SOURCE: CARE. 2008. As discussed previously, a draft Update to the initial Scoping Plan was developed by CARB in collaboration with the CCAT to address the requirement by AB 32 that the Scoping Plan be updated at least every 5 years. The draft Update to the initial Scoping Plan developed by CARB in collaboration with the CCAT was presented to CARB's Board for discussion at its February 20, 2014 meeting. The draft Update builds upon the initial Scoping Plan with new strategies and expanded measures, and identifies opportunities to leverage existing and new funds to drive GHG a County Flood Control District 3.6-8 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 Greenhouse Gases emission reductions through strategic planning and targeted program investments. The first update to the AB 32 Scoping Plan was approved on May 22, 2014, by GARB. As part of the proposed update to the Scoping Plan, the emissions reductions required to meet the 2020 statewide GHG emissions limit were further adjusted. The primary reason for adjusting the 2020 statewide emissions limit was based on the fact that the original Scoping Plan relied on the Intergovernmental Panel on Climate Change (IPCC) 1996 Second Assessment Report (SAR) to assign the GWPs of greenhouse gases. Recently, in accordance the United Nations Framework Convention on Climate Change (UNFCCC), international climate agencies have agreed to begin using the scientifically updated GWP values in the IPCC's Fourth Assessment Report (AR4) that was released in 2007. Because CARB has begun to transition to the use of the AR4 100 -year GWPs in its climate change programs, CARB recalculated the Scoping Plan's 1990 GHG emissions level with the AR4 GWPs (CARB, 2014b). CEQA Guidelines Revisions In 2007, the State Legislature passed SB 97, which required amendment of the CEQA Guidelines to incorporate analysis of, and mitigation for, GHG emissions from projects subject to CEQA. The California Natural Resources Agency adopted these amendments on December 30, 2009, and they took effect on March 18, 2010, after review by the Office of Administrative Law and filing with the Secretary of State for inclusion in the CCR. The Guidelines revisions include a new section (Section 15064.4) that specifically addresses the potential significance of GHG emissions. Section 15064.4 calls for a "good -faith effort" to "describe, calculate or estimate" GHG emissions; Section 15064.4 further states that the analysis of the significance of any GHG impacts should include consideration of the extent to which the project would increase or reduce GHG emissions; exceed a locally applicable threshold of significance; and comply with "regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions." The new Guidelines also state that a project may be found to have a less -than -significant impact on GHG emissions if it complies with an adopted plan that includes specific measures to sufficiently reduce GHG emissions (Section 15064(h)(3)). The Guidelines do not, however, require or recommend a specific analytical methodology or provide quantitative criteria for determining the significance of GHG emissions. Local SCAQMD As an interim method for determining significance under CEQA until statewide significance thresholds are established, SCAQMD developed a draft tiered flowchart in 2008 for determining significance thresholds for GHGs for projects where SCAQMD is acting as the lead agency. The SCAQMD flowchart uses a tiered approach in which a proposed program is deemed to have a less -than -significant impact related to GHG emissions when any of the following conditions are met: • GHG emissions are within GHG budgets in an approved regional plan. a County Flood Control District 3.6-9 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 reenhouse Gases • Incremental increases in GHG emissions due to the project are below the defined Significance Screening Levels, or mitigated to less than the Significance Screening Levels. • Performance standards are met by incorporating project design features and/or implementing emission reduction measures. • Carbon offsets are made to achieve target significance screening level. County of Los Angeles General Plan The 1980 County of Los Angeles General Plan does not address GHG emissions and climate change. However, the Conservation and Open Space Element contains policies that would contribute to the reduction of GHG emissions (County of Los Angeles, 1980). These are as follows: Policy 1: Actively support strict air quality regulations for mobile and stationary sources, and continued research to improve air quality. Promote vanpooling, carpooling and improved public transportation. Policy 2: Support the conservation of energy and encourage the development and utilization of new energy sources including geothermal, thermal waste, solar, wind and ocean -related sources. Policy 3: Promote the use of solar energy to the maximum extent possible. The Air Quality Element of the Draft 2014 County of Los Angeles General Plan summarizes air quality issues and outlines goals and policies that will improve air quality and reduce GHG emissions (County of Los Angeles, 2014a). The policies that are most relevant to GHG emissions include: Policy AQ 1.2: Encourage the use of low or no volatile organic compound (VOC) emitting materials. Policy AQ 3.1: Facilitate the implementation and maintenance of the Community Climate Action Plan to ensure that the County reaches its climate change and greenhouse gas emission reduction goals. Policy AQ 3.2: Reduce energy consumption in County operations by 20 percent by 2015. Policy AQ 3.3: Reduce water consumption in County operations. Policy AQ 3.4: Participate in local, regional and state programs to reduce greenhouse gas emissions. Policy AQ 3.5: Encourage maximum amounts of energy conservation in new development and municipal operations. Policy AQ 3.6: Support and expand urban forest programs within the unincorporated areas. a County Flood Control District 3.6-10 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 Greenhouse Gases County of Los Angeles Community Climate Action Plan The County of Los Angeles released its Final Draft Community Climate Action Plan (CCAP) in July 2014, which serves to mitigate and avoid GHG emissions associated with community activities in unincorporated Los Angeles County. The CCAP addresses emissions from building energy, land use and transportation, water consumption, and waste generation. The measures and actions outlined in the CCAP ties together the County's existing climate change initiatives and provide a blueprint for a more sustainable future. Ultimately, the CCAP and associated GHG reduction measures will be incorporated into the Air Quality Element of the Los Angeles County General Plan 2035. Specifically, the CCAP will identify emissions related to community activities, establish a GHG reduction target consistent with AB 32, and provide a roadmap for successfully implementing GHG reduction measures selected by the County. Based on the CCAP's estimated amount of GHG emissions generated by community activities in the County's unincorporated areas in 2010, it was determined that building energy use is the largest source of emissions (49 percent), followed by transportation emissions from on- and off-road vehicles (42 percent) and community waste generation (7 percent). The remaining GHG emissions sources are water conveyance and wastewater generation (2 percent), agriculture (0.4 percent), and stationary sources (0.02 percent). The CCAP comprises a variety of state and local actions to reduce GHG emissions within the unincorporated areas. The state actions considered in the CCAP include: the Renewables Portfolio Standard, Title 24 Standards for Commercial and Residential Buildings (Energy Efficiency and CALGreen), Pavley/Advanced Clean Cars (Vehicle Efficiency), the LCFS, and the California cap -and -trade program. These state actions generally do not require action from the County, but will result in local GHG reductions in the unincorporated areas. To supplement these statewide initiatives, the CCAP has identified 26 local actions to reduce GHG emissions in the unincorporated areas of the County. Specifically, these 26 local actions are grouped into five strategy areas: green building and energy; land use and transportation; water conservation and wastewater; waste reduction, reuse, and recycling; and land conservation and tree planting. Many of the local actions will also be implemented through General Plan policies or other County ordinances. These actions undertaken as part of the CCAP will result in important community co -benefits, including improved air quality, energy savings, and increased mobility, as well as enhancing the resiliency of the community in the face of changing climate conditions. Overall, the goal of the CCAP, which will be a component of the Los Angeles County General Plan, will be to reduce GHG emissions from community activities in the unincorporated areas of Los Angeles County in a manner that is consistent with statewide goals outlined under AB 32 (County of Los Angeles, 2014b). The Final Draft CCAP is anticipated to be adopted with the County's General Plan update. City General Plans The numerous cities encompassed by the Enhanced Watershed Management Program (EWMP) area all have their own respective city General Plans, some of which may contain policies that address GHG emissions and climate change. As implementation of the individual structural Best Management Practice (BMP) projects proceed, specific policies and objectives pertaining to GHG IA County Flood Control District 3.6-11 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 reenhouse Gases emissions and/or climate change from applicable city General Plans will be identified and evaluated on a project -by -project basis during subsequent CEQA environmental processes. 30603 Impact Assessment Thresholds of Significance Based on Appendix G of the CEQA Guidelines, a project would have a significant effect on GHG emissions if it would: Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. • Conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs. As noted, the increased concentration of GHGs in the atmosphere has been linked to global warming, which can lead to climate change. Construction of the structural BMPs would incrementally contribute to GHG emissions along with past, present and future activities. As such, impacts of GHG emissions are analyzed here on a cumulative basis. Currently, LACFCD has not adopted any thresholds for GHG emissions. Additionally, while SCAQMD has issued proposed standards and guidelines, there is no adopted state or local standard for determining the cumulative significance of the proposed program's GHG emissions on global climate change. In December 2008, SCAQMD adopted a 10,000 metric tons of CO2 equivalents (MTCO2e)/year for industrial facilities, but only with respect to projects where SCAQMD is the lead agency. Additionally, SCAQMD has proposed, but not adopted, a 3,000 MT/year CO2e threshold for mixed use developments, a 3,500 MT/year CO2e threshold for residential developments, and a 1,400 MT/year CO2e threshold for commercial developments. As an alternative to the aforementioned proposed thresholds for residential, commercial, and mixed- use developments, SCAQMD has also recommended the use of a single numerical threshold of 3,000 MTCO2e/year for all non -industrial projects. These draft threshold options are being evaluated through the GHG Thresholds Working Group and have not been adopted as of this writing (SCAQMD, 2010). For the purposes of this analysis, because the BMPs (structural and non-structural) associated with the proposed program are not residential, commercial, mixed-use, or industrial projects, the most appropriate threshold that would apply to the proposed program would be, although not formally adopted, the 3,000 MTCO2e/year criteria recommended by SCAQMD. Program Impact Discussion Program -Generated GHG Emissions Impact 3.6-1: The proposed program could generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. IA County Flood Control District 3.6-12 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 Greenhouse Gases Structural (Regional, Centralized, and Distributed) BMPs The proposed program would primarily generate GHG emissions during construction of the proposed structural BMP projects in the EWMP areas. The amount of program -related construction that would occur on an annual basis cannot be determined with any certainty at this time. As such, it is expected that the construction activities for the structural BMPs in the EWMP areas would occur intermittently throughout the course of the program implementation period. Construction -related GHG emissions associated with each structural BMP development would be short-term in nature and limited to the period of time when construction activity is taking place for that particular development. Applying the same approach that was used for the program's air quality analysis in Section 3.2, Air Quality, of this PEIR, the maximum annual construction - related GHG emissions for the three structural BMP project types were estimated using the California Emissions Estimator Model (CalEEMod) based on general information provided for the structural BMP projects and CalEEMod default settings along with reasonable assumptions based on other similar types of projects (refer to Tables 3.2-4, 3.2-5, and 3.2-6 in Section 3.2, Air Quality, of this PEIR, for the modeling parameters used in CalEEMod for the representative distributed, centralized, and regional structural BMPs, respectively). Tables 3.6-2, 3.6-3 and 3.6-4 summarize the modeled worst-case annual GHG emissions that are estimated to occur for a representative distributed, centralized, and regional structural BMP project, respectively. TABLE 3.6-2 ESTIMATED CONSTRUCTION -RELATED GREENHOUSE GAS EMISSIONS - PROPOSED DISTRIBUTED BMP PROJECT Proposed Program Emission Source Emissions CO2e (MT/yr) Construction 53.52 Total Construction (Amortized over 30 years) 1.78 NOTES: CO2e= carbon dioxide equivalent; MT/yr = metric tons per year; see Appendix C for CaIEEMod model outputs. SOURCE: Modeling performed by ESA, 2013. TABLE 3.6-3 ESTIMATED CONSTRUCTION -RELATED GREENHOUSE GAS EMISSIONS — PROPOSED CENTRALIZED BMP PROJECT Proposed Program Emission Source Emissions CO2e (MT/yr) Construction 335.33 Total Construction (Amortized over 30 years) 11.18 CO2e= carbon dioxide equivalent; MT/yr = metric tons per year; see Appendix C for CaIEEMod model outputs. SOURCE: Modeling performed by ESA, 2013. IA County Flood Control District 3.6-13 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 reenhouse Gases TABLE 3.6-4 ESTIMATED CONSTRUCTION -RELATED GREENHOUSE GAS EMISSIONS - PROPOSED REGIONAL BMP PROJECT Emission Source Proposed Program Emissions CO2e (MT/yr) Construction Total 2,227.89 Construction (Amortized over 30 years) 74.26 NOTES: CO2e= carbon dioxide equivalent; MT/yr = metric tons per year; see Appendix C for CaIEEMod model outputs. SOURCE: Modeling performed by ESA, 2013. As shown in Tables 3.6-2, 3.6-3, and 3.6-4, the total construction -related GHG emissions resulting from representative distributed, centralized, and regional structural BMP projects would be 53.52 MTCO2e/year, 335.33 MTCO2e/year, and 2,227.89 MTCO2e/year, respectively. For construction GHG emissions, SCAQMD recommends that the total construction emissions for a project be amortized over 30 years and added to its operational emission estimates (SCAQMD, 2008). Based on the emissions presented in the tables above, when the highest annual GHG emissions for a representative regional structural BMP project (2,227.89 MTCO2e/year) is amortized over 30 years, the resulting annual emissions would be 74.26 MTCO2/year. Because this annual emissions amount only represents approximately 2.5 percent of the SCAQMD's recommended threshold of 3,000 MTCO2e/year for non -industrial projects, the construction - related GHG emissions generated would be relatively minimal. Additionally, although the number of pumps that may be installed for some of the centralized and regional structural BMPs is unknown at this juncture, it is not anticipated that the annual GHG emissions contribution from the operation of these pumps would, when added to the annual construction -related emissions at these applicable structural BMP sites, result in total GHG emissions that exceed 3,000 MTCO2e/year at an individual BMP site. Furthermore, because the structural BMPs introduced into the EWMP areas under the program are not land use projects that would generate vehicle trips, GHG emissions would not be generated by motor vehicles traveling to and from the various structural BMP sites on a daily basis. As it is anticipated that only periodic worker trips to the structural BMP sites throughout the year would be required for inspection and maintenance activities, and the mobile GHG emissions generated by these worker trips would be negligible. Thus, because the total GHG emissions generated by the largest structural BMP projects (i.e., regional structural BMPs) under a worst-case scenario would not exceed the 3,000 MTCO2e/year benchmark, impacts associated with GHG emissions generated by the structural BMPs in the EWMP areas under the proposed program would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant IA County Flood Control District 3.6-14 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 Greenhouse Gases Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts related to program -generated GHG emissions. Mitigation Measures: None required Significance Determination: No impact Consistency with GHG Emissions Reduction Plans or Policies Impact 3.6-2: The proposed program could conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs. As discussed in the impact analysis, the GHG emissions generated by each of the structural BMPs associated with the proposed program would not exceed the SCAQMD's recommended threshold of 3,000 MTCO2e /year for non -industrial projects. The primary source of GHG emissions generated by the majority of the structural BMPs would occur only during construction, which would be temporary in nature. Additionally, as the structural BMPs are not land use projects, GHG emissions associated with mobile sources would only occur from periodic vehicle trips by workers to the structural BMP sites for inspection and maintenance purposes, which would not generate substantial emissions. The annual GHG emissions associated with the operation of pumps at some of the centralized and regional structural BMP sites would also be minimal relative to the GHG emissions generated during construction of these structural BMPs. Consequently, the implementation of these structural BMPs in the EWMP areas under the program would not generate substantial amounts of GHG emissions that would hinder the State's ability to achieve AB 32's goal of achieving 1990 levels of GHG emissions by 2020. Consistency with CARB Scoping Plan Out of the Recommended Actions contained in CARB's Scoping Plan (see Table 3.6-1), the actions that are most applicable to the proposed program would be Action W-4 (Reuse Urban Runoff), which aims to reduce urban runoff by capturing and treating the runoff. The program's BMPs would be implemented for this purpose, reducing and treating urban runoff throughout the County of Los Angeles to comply with the MS4 Permit. Implementation of the structural BMPs in the EWMP areas would serve as GHG emission reduction measures that are consistent with this recommended action from the Scoping Plan. Therefore, the program would not conflict with the CARB scoping plan, and this impact would be less than significant. Consistency with County of Los Angeles Community Climate Action Plan As discussed previously, the County released its Final Draft CCAP in July 2014 that serves to mitigate and avoid GHG emissions associated with community activities in unincorporated Los Angeles County. The CCAP establishes a GHG reduction target that is consistent with AB 32. As part of the CCAP, 26 local actions have been identified to reduce GHG emissions in the unincorporated areas of the County. In particular, Measure WAW -2 (Recycled Water Use, Water a County Flood Control District 3.6-15 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 reenhouse Gases Supply Improvement Programs, and Stormwater Runoff) from the CCAP specifically aims to promote recycled water use and policies to better manage stormwater to protect local groundwater supplies. A part of the goal for this measure is to manage stormwater and protect local groundwater supplies. A specific implementation step associated with this measure identified in the CCAP is to expand the Low Impact Development (LID) stormwater catchment to more facilities where feasible in the County. Thus, the structural BMPs that would be implemented as part of the proposed program would be consistent with this GHG reduction measure of the CCAP. Therefore, the program would not conflict with the County's CLAP, and this impact would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no conflicts with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs. Mitigation Measures: None required Significance Determination: No impact Cumulative Impact Discussion As discussed previously, CEQA considers a project's impacts related to GHG emissions inherently cumulative. Therefore, the discussion presented above comprises the cumulative impact analysis related to global warming and climate change. As concluded, because the GHG emissions generated by the individual structural BMP projects in the EWMP areas would not exceed SCAQMD's recommended threshold of 3,000 MT CO2e /year for non -industrial projects, the BMPs implemented under the proposed program would not result in substantial GHG emissions into the environment. Additionally, because the proposed BMPs under the program would serve to capture, treat, and manage stormwater runoff in the EWMP areas, the program would also be consistent with the applicable actions and measures of the CARB's Scoping Plan and County's CCAP, respectively. Overall, the proposed program would result in less than significant GHG and climate change cumulative impacts. Mitigation Measures: None required Significance Determination: Less than significant IA County Flood Control District 3.6-16 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.6 Greenhouse Gases 306.3 Summary of Impact Assessment Table 3.6-5 shows a summary of the structural BMPs requiring mitigation. TABLE 3.6-5 SUMMARY OF GREENHOUSE GAS IMPACTS REQUIRING MITIGATION MEASURES Thresholds of Significance GHG Consistency with Cumulative Structural BMPs Emissions Plans Impacts Applicable Mitigation Measures: None Required None Required None Required Regional BMPs Regional Detention and Infiltration Regional Capture, Detention and Use Centralized BW Bioinfiltration Constructed Wetlands Treatment/Low Flow Diversions Creek, River, Estuary Restoration Distributed BM Site Scale Detention LID — Infiltration/Filtration BMPs — Porous Pavement, Green Streets, Bioswale/Filter Strips, downspout disconnects LID — Green Infrastructure — Capture and Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes Flow through Treatment BMPs Source Control Treatment BMPs (catch basin inserts/screens, hydrodynamic separators, gross solids removal devices) Low Flow Diversions No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No No NOTE: These conclusions are based on typical BMP size and location IA County Flood Control District 3.6-17 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials Potential hazards addressed in this section include uses of hazardous materials during the construction and operation of the proposed program, hazardous materials in soil and groundwater from existing contaminated sites, and hazards related to schools, airports, emergency preparedness, and wildfires. Mitigation measures to reduce impacts to a less -than -significant level are identified, as needed. 3.7A Environmental Setting Hazardous Materials and Hazardous Waste A hazardous material is defined as any material that, because of quantity, concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the workplace or the environment (Health and Safety Code §25501(o)). The tern "hazardous materials" refers to both hazardous substances and hazardous wastes. Under federal and state laws, any material, including wastes, may be considered hazardous if it is specifically listed by statute as such or if it is toxic (causes adverse human health effects), ignitable (has the ability to bum), corrosive (causes severe bums or damage to materials), or reactive (causes explosions or generates toxic gases). Hazardous wastes are hazardous substances that no longer have practical use, such as materials that have been spent, discarded, discharged, spilled, contaminated, or are being stored until they can be disposed of properly (22 California Code of Regulations [CCR] Section 66261.10). Soil that is excavated from a site containing hazardous materials is a hazardous waste if it exceeds specific 22 CCR criteria. While hazardous substances are regulated by multiple agencies, as described in the Regulatory Framework below, cleanup requirements of hazardous wastes are determined on a case-by-case basis according to the agency with lead jurisdiction over the project. Preschools, schools, daycare centers, nursing homes, and hospitals are considered sensitive receptors for hazardous material issues because children and the elderly are more susceptible than adults to the effects of many hazardous materials. There are numerous sensitive receptors located throughout the proposed EWMPs or "program" service area. Urban Runoff Within the EWMP area, much of the environment has been developed, resulting in large areas of impervious surfaces that include rooftops, highways and roads, and other hardscapes. Stormwater and urban runoff from these impervious surfaces tends to pick up trash, sediment, and other pollutants including (US EPA, 2003): • Sediment • Fuels, oil, grease, and chemicals from motor vehicles and mechanized equipment • Fertilizers, pesticides and herbicides from landscaping and gardens IA County Flood Control District 3.7-1 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials • Viruses, bacteria, and nutrients from pet waste and failing septic systems • Road salts • Heavy metals from roof shingles, motor vehicles, and other sources Impacted stormwater and urban runoff that is then directed to a structural Best Management Practices (BMPs) to retain and filter or infiltrate the runoff may accumulate concentrations of chemicals in the upper soils and/or filter media such as petroleum hydrocarbons (fuels, oils, and greases), metals (copper, lead and zinc), polycyclic aromatic hydrocarbons (created as combustion byproducts of gasoline and other fossil fuels), bacteria, nutrients (nitrogen, phosphorus, nitrate, and organic nitrogen), and pesticides. Hazardous Material Sites Hazardous materials are currently stored and used at numerous facilities and locations within the EWMP area for a variety of purposes. Some facilities within the area that use or store hazardous materials or hazardous wastes may have experienced unauthorized releases into soil or groundwater, and these releases may or may not have been reported to the appropriate agency or agencies. In California, regulatory databases listing hazardous materials sites provided by numerous federal, state, and local agencies are consolidated in the "Cortese List" pursuant to Government Code Section 65962.5. The Cortese List is located on the website of the California Environmental Protection Agency (Cal EPA; http://www.calepa.ca.gov/sitecleanup/corteselist/) and is a compilation of the following lists: • List of Hazardous Waste and Substances sites from Department of Toxic Substances Control (DTSC) EnviroStor database • List of Leaking Underground Storage Tank Sites by County and Fiscal Year from the State Water Resources Control Board (SWRCB) GeoTracker database • List of solid waste disposal sites identified by SWRCB with waste constituents above hazardous waste levels outside the waste management unit • List of "active" Cease and Desist Orders and Cleanup and Abatement Orders from the SWRCBI • List of hazardous waste facilities subject to corrective action pursuant to Section 25187.5 of the Health and Safety Code, identified by DTSC and listed on their EnviroStor database The five databases cited above identify sites with suspected and confirmed releases of hazardous materials to the subsurface soil and/or groundwater. The SWRCB GeoTracker database includes This list contains many Cease and Desist Orders and Cleanup and Abatement Orders that do NOT concern the discharge of wastes that are hazardous materials. Many of the listed orders concern, for example, discharges of domestic sewage, food processing wastes, or sediment that do not contain hazardous materials, but the Water Boards' database does not distinguish between these types of orders. See more at: http://www. calepa.ca.gov/sitecleanup/corteselist/default.htm#sthash.oSjMvSw7. dpuf IA County Flood Control District 3.7-2 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials leaking underground storage tanks (LUSTS), permitted underground storage tanks (USTs), and Spills, Leaks, Investigations, and Cleanup Database (SLIC) sites. The DTSC EnviroStor database includes federal and state response sites; voluntary, school, and military cleanups and corrective actions; and permitted sites. The reporting and statuses of these sites change as identification, monitoring, and cleanup of hazardous materials sites progress. Typically, a listed site is considered to no longer be of concern once it has been demonstrated that existing site uses combined with the levels of identified contamination present no significant risk to human health or the environment. The Los Angeles County Fire Department (LACFD) is the designated Los Angeles County Certified Unified Program Agency (LAC CUPA), described further in the Regulatory Framework. The LAC CUPA is responsible for the regulatory oversight of aboveground storage tanks (ASTs) and USTs, county hazardous materials and waste programs, and the California Accidental Release Prevention (CaIARP) Program. The LAC CUPA would be the primary source of information regarding hazardous materials use and hazardous waste disposal for facilities that are at or near proposed program within the EWMP area. The DTSC delegated corrective action oversight authority to LAC CUPA under Chapter 6.5 of Division 20 of California Health and Safety Code to implement corrective action under consent agreement at LAC CUPA facilities within its jurisdiction. Schools Schools are considered sensitive receptors for hazardous materials because children are more susceptible than adults to the effects of hazardous materials. There are over a thousand public and private schools, colleges, and universities within Los Angeles County. The proximity of a proposed project to day care centers would also need to be considered. Airports Aviation safety hazards can result if projects are sited on or in the vicinity of airports. Specifically, the land use compatibility plans at airports have land use restrictions, such as height, distracting light or glare, and attractants to wildlife, such as birds. The Federal Aviation Administration (FAA) Advisory Circular No: 150/5200-33B provides guidance on development projects affecting aircraft movement near hazardous wildlife attractants (FAA, 2007). The following list indicates the minimum separation criteria for specific aircraft types: • Airports Serving Piston -Powered Aircraft: Airports that do not sell Jet -A fuel normally serve piston -powered aircraft (propeller -powered). General aviation airports typically serve piston -powered aircraft. However, there are exceptions. For example, the Santa Monica Airport is a general aviation airport but does serve turbine -powered aircraft. The FAA recommends a separation distance of 5,000 feet at these airports for hazardous wildlife attractants. This distance is to be maintained between an airport's air operations area (AOA) and the hazardous wildlife attractant. • Airports Serving Turbine -Powered Aircraft: Airports selling Jet -A fuel normally serve turbine -powered aircraft (jet- or turbo -prop -powered). The FAA recommends a IA County Flood Control District 3.7-3 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials separation distance of 10,000 feet at these airports for hazardous wildlife attractants. This distance is to be maintained between an airport's AOA and the hazardous wildlife attractant. • Protection of Approach, Departure, and Circling Airspace: For all airports, the FAA recommends a distance of 5 statute miles between the farthest edges of the airport's AOA and the hazardous wildlife attractant if the attractant could cause hazardous wildlife movement into or across the approach or departure airspace. Specific information of the types of aircraft using a particular airport, airport land use compatibility plans, and land use maps for airports within Los Angeles County is available at the Los Angeles County Airport Land Use Commission website at http://planning.lacounty.gov/aluc/airports. Emergency Preparedness Los Angeles County Office of Emergency Management (LAC OEM) is the designated lead agency for emergency response and coordinates the development, maintenance, and implementation of the Los Angeles County Operational Area Emergency Response Plan (http://lacoa.org/oaerp.htm). This Plan serves as a guide for the County's response to emergencies/disasters in the County. Wildfires Both the State of California and the County of Los Angeles Fire Department map the Fire Hazard Severity Zones (FHSZs) within Los Angeles County. The FHSZs are based on an evaluation of fire history, existing and potential fuel, flame length, blowing embers, terrain, weather, and the likelihood of buildings igniting (California Department of Forestry and Fire Protection, 2012). Figure 3.7-1 presents the countywide FHSZ map for the state responsibility areas. Figure 3.7-2 presents the countywide FHSZ map for the county responsibility areas. The very high FHSZ areas tend to be outside of the urban developed areas in areas with flammable vegetation, such as brush. IA County Flood Control District 3.7-4 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report SOURCE: ESRI, Cal Fire 2007 LA County PEI EWMP . 140474 Figure 3.7-1 Los Angeles County Fire Hazard Severity Zone Map for State Responsibility Areas SOURCE: ESRI, Cal Fire 2007 LA County PEI EWMP . 140474 Figure 3.7-2 Los Angeles County Fire Hazard Severity Zone Map for County Responsibility Areas 3. Environmental Settinq, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials 3,7,2 Regulatory Framework Hazards and hazardous materials are subject to numerous federal, state, and local laws and regulations intended to protect health, safety, and the environment. The U.S. Environmental Protection Agency (USEPA), the California DTSC, RWQCB, and the County of Los Angeles are the primary agencies enforcing these regulations. Local regulatory agencies enforce many federal and state regulations through the CUPA program. In 1997, LACFD Health Hazardous Materials Division became the LAC CUPA for the Hazardous Waste Generator Program, the Hazardous Materials Release Response Plans and Inventory Program, the CalARP Program, and the Aboveground Storage Tank Program and the Underground Storage Tank Program in Los Angeles County. Federal Primary federal agencies with responsibility for hazardous materials management include the USEPA, Department of Labor (Federal Occupational Health and Safety Administration [OSHA]), and Department of Transportation (DOT). Major federal laws and issue areas include the following statutes (and regulations promulgated there under): Resources Conservation and Recovery Act (RCRA) 42 USC 6901 et sea. — RCRA is the principal law governing the management and disposal of hazardous materials. RCRA is considered a "cradle to grave" statute for hazardous wastes in that it addresses all aspects of hazardous materials from creation to disposal. Federal regulations for USTs derive from RCRA. RCRA applies to this program because RCRA is used to define hazardous materials. • Emergency Planning and Community Right -to -Know Act (EPCRA from SARA Title III) — EPCRA improved community access to information regarding chemical hazards and facilitated the development of business chemical inventories and emergency response plans. EPCRA also established reporting obligations for facilities that store or manage specified chemicals. EPCRA applies to this program because the contractors that construct the structural BMPs will be required to prepare and implement written emergency response plans to properly manage hazardous materials during construction and respond to accidental spills. • DOT Hazardous Materials Transportation Act (49 USC 5 10 1) — DOT, in conjunction with the USEPA, is responsible for enforcement and implementation of federal laws and regulations pertaining to safe storage and transportation of hazardous materials. The Code of Federal Regulations (CFR) 49, 171-180, regulates the transportation of hazardous materials, types of material defined as hazardous, and the marking of vehicles transporting hazardous materials. This Act applies to this program because contractors will be required to comply with its storage and transportation requirements that would reduce the possibility of spills. • The Federal Motor Carrier Safety Administration (49 CFR Part 382) —The Federal Motor Carrier Safety Administration, a part of the DOT, issues regulations concerning highway routing of hazardous materials, the hazardous materials endorsement for a commercial IA County Flood Control District 3.7-7 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials driver's license, highway hazardous material safety permits, and financial responsibility requirements for motor carriers of hazardous materials. This Act applies to this program because contractors will be required to comply with its storage and transportation requirements that would reduce the possibility of spills. • Occupational Safety and Health Administration (OSHA; 29 USC 15) – OSHA is the federal agency responsible for ensuring worker safety. These regulations provide standards for safe workplaces and work practices, including those relating to hazardous materials handling. OSHA applies to this program because contractors will be required to comply with its hazardous materials management and handling requirements that would reduce the possibility of spills. • The FAA Advisory Circular No: 150/5200-33B – The FAA Advisory Circular provides guidance on development projects affecting aircraft movement near hazardous wildlife attractants (FAA, 2007). This Circular applies to this program because BMPs will be required to comply with its restrictions if at or near airports. State The primary State agencies with jurisdiction over hazardous chemical materials management are the DTSC and the RWQCB. Other State agencies involved in hazardous materials management are the Department of Industrial Relations (State OSHA implementation), State Office of Emergency Services (OES)—CalARP implementation, California Air Resources Board (CARB), California Department of Transportation (Caltrans), State Office of Environmental Health Hazard Assessment (OEHHA—Proposition 65 implementation) and California Integrated Waste Management Board (CIWMB). Hazardous materials management laws in California include the following statutes and regulations promulgated there under. • Hazardous Waste Control Act (HWCA; California Health and Safety Code, Section 25100 et sea.l – The HWCA is the state equivalent of RCRA and regulates the generation, treatment, storage, and disposal of hazardous waste. This act implements the RCRA "cradle -to -grave" waste management system in California but is more stringent in its regulation of non-RCRA wastes, spent lubricating oil, small -quantity generators, transportation and permitting requirements, as well as in its penalties for violations. HWCA applies to this program because contractors will be required to comply with its hazardous waste requirements that would reduce the possibility of spills. • California Hazardous Materials Release Response Plans and Inventory Law of 1985 Business Plan Act) – The Business Plan Act requires preparation of hazardous materials business plans and disclosure of hazardous materials inventories, including an inventory of hazardous materials handled, plans showing where hazardous materials are stored, an emergency response plan, and provisions for employee training in safety and emergency response procedures (California Health and Safety Code, Division 20, Chapter 6.95, Article 1). Statewide, DTSC has primary regulatory responsibility for management of hazardous materials, with delegation of authority to local jurisdictions that enter into agreements with the state. Local agencies are responsible for administering these regulations. IA County Flood Control District 3.7-8 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials Several state agencies regulate the transportation and use of hazardous materials to minimize potential risks to public health and safety, including CaIEPA and the California Emergency Management Agency. The California Highway Patrol and Caltrans enforce regulations specifically related to the transport of hazardous materials. Together, these agencies determine container types used and license hazardous waste haulers for hazardous waste transportation on public roadways. The Business Plan Act applies to this program because contractors will be required to comply with its handling, storage, and transportation requirements that would reduce the possibility of spills, and to prepare an emergency response plan to respond to accidental spills. • California Division of Occupational Safety and Health (Cal/OSHA) — Cal/OSHA is responsible for developing and enforcing workplace safety standards and assuring worker safety in the handling and use of hazardous materials. Among other requirements, Cal/OSHA requires many entities to prepare injury and illness prevention plans and chemical hygiene plans, and provides specific regulations to limit exposure of construction workers to lead. OSHA applies to this program because contractors will be required to comply with its handling and use requirements that would reduce the possibility of spills, and to prepare an emergency response plan to respond to accidental spills. • California Vehicle Code Section 38366 — The California Vehicle Code, Section 38366, requires spark -arresting equipment on vehicles that travel off-road. This code applies to the program because the vehicles that construct structural BMPs in off-road areas will be required to have spark -arresting equipment to reduce the risk of wildfires. Local Certified Unified Program Agency In 1993, Senate Bill (SB) 1082 was passed by the State Legislature to streamline the permitting process for those businesses that use, store, or manufacture hazardous materials. The passage of SB 1082 provided for the designation of a CUPA that would be responsible for the permitting process and collection of fees. The CUPA would be responsible for implementing at the local level the Unified Program, which serves to consolidate, coordinate, and make consistent the administrative requirements, permits, inspections, and enforcement activities for the following environmental and emergency management programs: • Hazardous Materials Release Response Plans and Inventories (Business Plans) • California Accidental Release Prevention (CalARP) Program • Underground Storage Tank Program • Aboveground Petroleum Storage Act Requirements for Spill Prevention, Control and Countermeasure (SPCC) Plans • Hazardous Waste Generator and On -Site Hazardous Waste Treatment (tiered permitting) Programs IA County Flood Control District 3.7-9 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials • California Uniform Fire Code: Hazardous Material Management Plans and Hazardous Material Inventory Statements The CUPA in Los Angeles County is the LACoFD. As such, the Department is given the primary regulatory responsibility for implementing and managing the above -listed programs. Los Angeles County Operational Area Emergency Response Plan In 1998, the County of Los Angeles adopted the Los Angeles County Operational Area Emergency Response Plan, which provides emergency planning for the Los Angeles County Operational Area, an area that includes the project area. The purpose of this plan is to increase cooperation and coordination between relevant government agencies and jurisdictions in order to increase efficiency and minimize losses in the event of an emergency or disaster within the Operational Area (County of Los Angeles 1998). Los Angeles County Fire Department Wildfire Action Plan In 2009, the LACFD adopted a Wildfire Action Plan, which contains guidelines that recommend fire prevention measures such as creating defensible space and completing fire -resistive retrofits in homes (LACED 2009). In addition, this plan provides residents with information regarding emergency preparedness and planning in the event of a wildfire. Los Angeles County General Plan A General Plan is a basic planning document that, alongside the zoning code, governs development in a city or county. The State requires each city and county to adopt a General Plan with seven mandatory elements: land use, open space, circulation, housing, noise, conservation, and safety, along with any number of optional elements as appropriate. The proposed EWMPs would be subject to local plans and policies of the areas in which they are located. The County of Los Angeles is currently updating their General Plan from the element versions adopted in the 1980s and 1990s; the new comprehensive plan is expected to be complete by late 2014. Below are the relevant goals and policies from both the existing General Plan (County of Los Angeles, 1980, 1990) and the Draft General Plan 2035 (County of Los Angeles, 2014a) which relate to the EWMP. Existing General Plan — Safety Element, Adopted 1990 Goal: Reduce threats to public safety and protect property from wildland and urban fire hazards. Policy 16: Continue to coordinate firefighting efforts with State, Federal and local agencies in fire hazard areas; and review and update mutual and automatic aid agreements between the County and other fire protection agencies. Policy 19: Promote improved watershed management practices to reduce the risk of damaging runoff and debris movement into urban areas. Goal: Reduce threats to public safety and protect property from hazardous materials. IA County Flood Control District 3.7-10 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Pmgmm Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials Policy 20: Review proposed development projects involving the use or storage of hazardous materials, and disapprove proposals which cannot properly mitigate unacceptable threats to public health and safety to the satisfaction of responsible agencies. Policy 21: Promote the safe transportation of hazardous materials. Policy 22: Encourage businesses and organizations which store and us hazardous materials to improve management and transportation of such materials. Policy 24: Encourage improved, timely communication between businesses and emergency response agencies regarding hazardous materials/waste incidents. Draft General Plan, 2014 — Conservation and Natural Resources Element Goal — C/NR-5: Protected and useable local surface water resources. Policy C/NR 5.6: Minimize point and non -point source water pollution. Goal — C/NR-6: Protected and usable local groundwater resources. Policy C/NR 6.5: Prevent stormwater infiltration where inappropriate and unsafe, such as in areas with high seasonal groundwater, on hazardous slopes, within 100 feet of drinking water wells, and in contaminated soils. County of Los Angeles Low Impact Development Manual The County of Los Angeles (County) prepared the 2014 Low Impact Development Standards Manual (LID Standards) to comply with the requirements of the National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit for stormwater and non-stormwater discharges from the MS4 within the coastal watersheds of Los Angeles County (CAS004001, Order No. R4-2012-0175), referred to as the 2012 MS4 Permit (County of Los Angeles, 2014b). The LID Standards provide guidance for the implementation of stormwater quality control measures in new development and redevelopment projects in unincorporated areas of the County with the intention of improving water quality and mitigating potential water quality impacts from stormwater and non-stormwater discharges. The November 2013 LID Ordinance became effective December 5, 2013, and requires that all Designated, Non -Designated, street and road construction, and single family hillside home projects comply with Los Angeles County Code Title 12, Chapter 84. The LID Standards were prepared to complement and be consistent with the November 2013 LID Ordinance requirements. The LID Standards address the following objectives and goals: Lessen the adverse impacts of stormwater runoff from development and urban runoff on natural drainage systems, receiving waters, and other water bodies; IA County Flood Control District 3.7-11 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials • Minimize pollutant loadings from impervious surfaces by requiring development projects to incorporate properly -designed, technically -appropriate BMPs and other LID strategies; and • Minimize erosion and other hydrologic impacts on natural drainage systems by requiring development projects to incorporate properly -designed, technically appropriate hydromodification control development principles and technologies. City of Los Angeles Low Impact Development Manual In November 2011, the City of Los Angeles adopted the Storrnwater Low Impact Development (LID) Ordinance #181899) with the stated purpose of • Requiring the use of LID Standards and practices in future developments and redevelopments to encourage the beneficial use of rainwater and urban runoff • Reducing storrnwater/urban runoff while improving water quality • Promoting rainwater harvesting • Reducing off-site runoff and providing increased groundwater recharge • Reducing erosion and hydrologic impacts downstream • Enhancing the recreational and aesthetic values in our communities The City institutionalized the use of LID techniques for development and redevelopment projects. Subsequent to the adoption of the Stormwater LID Ordinance, the City prepared the Development Best Management Practices Handbook, Low Impact Development Manual, dated June 2011, to describes the required BMPs (City of Los Angeles, 2011). Other Cities LID Various other cities within the County also have LID standards or guidance. The goals, objectives, and content of the LID document are similar to that of the County and City of Los Angeles, and are not referenced here. City General Plans The numerous cities encompassed by the EWMP area all have their own respective city General Plans, some of which may contain policies that address hazards and hazardous materials. As implementation of the individual structural BMP projects proceed, specific policies and objectives pertaining to hazards and hazardous materials from applicable city General Plans will be identified and evaluated on a project -by -project basis during subsequent CEQA environmental processes. 3.7.3 Impact Analysis The proposed program's potential impacts were assessed using the CEQA Guidelines Appendix G Checklist. The following sections discuss the key issue areas identified in the CEQA Guidelines with respect to the program's potential hazard and hazardous material impacts. IA County Flood Control District 3.7-12 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials Thresholds of Significance Implementation of the proposed program may result in a potentially significant impact if any one of the following conditions would occur: • Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. • Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. • Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. • Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment. • For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area. • For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area. • Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. • Expose people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands. Project Impact Discussion Routine Hazardous Materials Transport, Storage, Use, and Disposal and Accidental Release of Hazardous Materials Related to Construction and Maintenance Impact 3.7-1: The proposed program would create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials or the accidental release during construction and maintenance activities. Structural (Regional, Centralized, and Distributed) BMPs Construction activities required for implementation of proposed program would potentially involve excavation, grading, drilling, trenching, and other ground -disturbing activities. Once constructed, the structural BMPs would require periodic maintenance activities such as channel clearing of sediment and vegetation maintenance that could include the use of chainsaws and weed- whackers that require fuel and oil. These anticipated construction and maintenance activities would likely require the transport, storage, use, and disposal of small amounts of hazardous materials, including fuels (e.g., gasoline, diesel), hydraulic fluids, oils and lubricants, IA County Flood Control District 3.7-13 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials paint, and other similarly related materials in varying quantities on each project site. The release of these materials could occur during routine transport, disposal, or use, and could potentially injure construction workers, contaminate soil, and/or affect habitats, surface water bodies, or groundwater. Impacts associated with release, although likely localized and short-term, could potentially create a significant hazard to the public or the environment. The majority of BMPs are more likely to be smaller -scale, site- or parcel -specific distributed type BMPs that do not use chemicals for treatment. Distributed BMPs primarily use passive treatment techniques that capture stormwater and then reduce pollutant loads and stormwater volumes through containment, filtration, infiltration, and/or treatment techniques. Stormwater is directed to these BMPs and contained or stored to settle or filter out sediment and trash load (e.g., detention basins and ponds, debris booms and nets), and then allow the stormwater to infiltrate or filter through pervious surfaces that can be vegetated (e.g., bioswales, green streets, planter boxes, bioretention, bioswales, planter boxes, green streets). The regional and centralized structural BMPs that include the construction of a smaller number of larger physical structures would use more equipment and materials, and could use larger volumes of potentially hazardous materials for longer periods of time. For example, low flow diversion structures may require chlorine treatment facilities rather than discharge to the sewer for treatment, in which case larger volumes of chlorine would be required to be stored on-site. However, the materials used would mostly be chemicals, fuels, oils, and lubricants, all of which are relatively common to store, transport, and handle. In the unlikely event of a spill, these petroleum products are relatively easy to clean up, treat, or biodegrade. Hazardous materials that are more difficult to treat, such as solvents and metals, would not be expected to be used or released in large quantities. Centralized structural BMPs that are treatment facilities may use treatment chemicals, such as chlorine depending on the treatment techniques (other options include ozone, ultraviolet, or electrocoagulation), and the structures may be painted. However, chlorination and dechlorination uses should consider proximity to residential areas for safety reasons, as well as access for chemical deliveries. The implementing agency and construction contractor would be required to comply with all relevant and applicable federal, state, and local laws and regulations that pertain to the transport, storage, use, and disposal of hazardous materials and waste during construction of the proposed program. Because the implementing agency and its contractor would be required to comply with all relevant laws and regulations associated with the transport, storage, use, and disposal of hazardous materials and waste, the construction impacts would be less than significant. Operation of proposed structural BMPs would generally require minimal to no transport, usage, or disposal of hazardous materials for activities such as maintaining detention basins, constructed wetlands, or infiltration galleries, which would require periodic transport and use of chemicals for purposes of operating equipment (e.g., weed -whackers), maintenance activities, and the transport of workers in vehicles. The implementing agency would be required to comply with all relevant and applicable federal, state, and local laws and regulations that pertain to the transport, storage, use, and disposal of hazardous materials and waste during operation of the proposed program. LA County Flood Control District 3.7-14 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Repent 3. Environmental Settinq, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials Under the Unified Program, the CalARP Program requires facilities that use regulated substances to develop a Risk Management Plan (RMP). A RMP would be required for the proposed program that uses hazardous materials. The RMP would be kept on file with the LACFD, in addition to a Hazardous Materials Release Response Plan within a Hazardous Materials Business Plan (HMBP). Existing treatment plants that undergo expansion will require an updated RMP and HMBP to include new facilities and any associated hazardous material use, storage, or transport. These are public documents that reflect a facility's overall effort to manage and prevent risks associated with the storage, use, and/or processing of regulated substances. The California Hazardous Materials Release Response Plans and Inventory Program (CCR Title 19, Division 2, Chapter 4) requires companies that store, use, and/or transport hazardous materials to prepare a HMBP that includes an inventory of hazardous substances and an Emergency Response Plan (ERP) to address emergencies such as accidental releases. For example, a contractor using fuels for chainsaws and weed -whackers to control vegetation at detention basins and infiltration galleries would be required to prepare and implement an HMBP and an ERP for their company activities. The ERP would include procedures for responding to accidental spills of fuels that might occur at any site they work at. The ERP would describe the cleanup procedures to be implemented in the event of an accidental release. In addition, the transport of hazardous materials is regulated by Caltrans. Transporters of hazardous waste would be required to be certified by Caltrans. All hazardous materials would be tracked by Caltrans and delivery vehicles would be required to use roadways approved for transportation of hazardous materials and maintain the proper storage containers for hazardous materials. Implementation of the RMP, HMBP, and ERP and compliance with existing regulations would reduce potential risks to the public and environment due to accidental release of hazardous materials to less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no new facilities that would require additional or new use of hazardous materials. While the non-structural BMPs would include a broad range of municipal practices such as street cleaning, landscape management, storm drain operation, and more, which does produce debris and trash for disposal, the materials collected are not considered hazardous waste or materials requiring hazardous waste disposal. Regular street sweeping is one of the most cost-effective non-structural BMPs used to remove sediment, metals, petroleum products, trash, and vegetation that accumulate on streets. Maintaining a regular street sweeping schedule reduces the buildup of trash on streets and IA County Flood Control District 3.7-15 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials prevents trash from entering catch basins and the storm drain system. The trash removed is disposed of in local landfills. Therefore, this program would have no impact relative to the routine use of hazardous materials. Mitigation Measures: None required Significance Determination: Less than significant Accumulation of Potentially Hazardous Materials into BMPs Impact 3.7-2: The proposed program could create a significant hazard to the public or the environment through the accumulation of potentially hazardous materials into BMPs. Structural (Regional, Centralized, and Distributed) BMPs The existing storm sewer systems convey stormwater and dry -weather flows to receiving waters that ultimately flow to the ocean. Operation of structural BMPs would not increase the potential for accidental releases of hazardous materials into the environment. Because of their function as water conveyance systems, the entire storm sewer system, as augmented by structural BMPs, would collect and retain sediment and chemicals from urban runoff, along with any accidental or illicit spills of hazardous materials. The introduction of hazardous materials into the storm sewer system could occur in large events as in a catastrophic spill, or could occur in small concentrations as in petroleum hydrocarbons and heavy metals picked up and carried by stormwater in urban runoff from the streets. Contaminants in the runoff water or as discrete concentrated spills could accumulate in the soils and vegetation of structural BMPs, as discussed below. In the case of large spills that occur within the capture area of a BMP, regional BMPs would retain the spill and prevent any further contamination downstream since they would be designed to retain in -flow. Centralized BMPs, although generally designed to use flow-through or filter techniques, would still slow and retain much of the spill volume. Even distributed BMPs would slow and retain spills, although on a smaller scale. This retention would help to minimize impacts of large spills compared to existing conditions. Responding to major spills is the responsibility of local municipalities, usually led by the local fire department. Local jurisdictions prepare spill response plans that outline measures to contain and remediate spills of all kinds. The LAC OEM leads emergency response activities within Los Angeles County that would include responses to large hazardous spills. LAC OEM has prepared an Emergency Response Plan to coordinate response efforts. The responsibility for responding to and remediating spills would be similar to existing conditions. All BMPs (regional, centralized, and distributed) would require cleanup following a spill event. Large spills could adversely affect the treatment systems including natural vegetation and filter matrices, including soil. Implementation of the BMPs would serve to add some protection against accidental or illicit spills compared with existing conditions. Cleanup of major spills would be IA County Flood Control District 3.7-16 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials coordinated through the LAC OEM in coordination with applicable regulations and regulatory agencies, specifically the RWQCB or the Department of Toxic Substance Control (DTSC). In the case of small concentrations of contaminants either from small spills or the accumulation of contaminants from urban runoff, BMPs would collect and retain pollutants on site. Potential contaminants include typical urban runoff contaminants, such as fuels, oil and grease, pesticides, PCBs, PAHs, metals, and nutrients, as well as sediment that would clog filter media (e.g., soil) or reduce volume capacity of the receiving BMP. Over time, infiltration of storrnwater runoff could increase contaminant loading in shallow soils and groundwater. Contaminants behave differently when filtered through native soils. Some contaminants (e.g., oil, grease, metals) adsorb onto surficial soils and remain within a few feet of the surface, while other more soluble contaminants (e.g., fuels, nitrate, and phosphate) may be entrained to deeper soils or migrate all the way to the groundwater. Over a long period of time, concentrations of these contaminants could increase resulting in contaminated soils and groundwater. Pretreatment of source water in areas with the potential for heavy contaminant loading would be implemented as a required design feature for regional and centralized BMPs to assist in reducing long-term loading. In addition, non-structural source control BMPs would help reduce contaminant loading over time. The LID Standards for the County of Los Angeles and the various cities participating in the EWMP provide protocols for designing regional and centralized BMPs that minimize the potential for contaminant loading. For example, the LID Manual requires a certain distance to groundwater to ensure that adequate soil filtration occurs prior to the percolating water reaching a drinking water aquifer. Distributed BMPs, although on a smaller parcel or site scale, would also be designed to collect and treat stormwater to reduce the loading of the smaller amounts of contaminants transported by their relatively smaller receiving areas. This would reduce contaminant loading to receiving waters compared with existing conditions while capturing contaminants in filter media. The vegetation and microbial activity in soil would work to biodegrade the typical fuels, oil, and grease in local urban runoff. To address the accumulation of contaminants in soil at BMPs, operations and maintenance plans for BMPs that might accumulate constituents in surface soils and media will be developed to include periodic removal and replacement of these potentially impacted surface materials to reduce the potential for long-term loading leading to hazardous concentrations in soils and groundwater. Implementation of Mitigation Measure HAZ-1 would reduce the potential for impacts to less -than -significant levels. Mitigation Measure: HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the BMP projects ,that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential IA County Flood Control District 3.7-17 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub- soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. Significance Determination: Less than significant with mitigation (The application of this mitigation measure to specific BMP types and categories are identified in Table 3.7-1.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. As a result, there would be no new facilities that would require additional or new use of hazardous materials. Therefore, this impact would have no impact relative to the accidental release of hazardous materials. Mitigation Measures: None required Significance Determination: Less than significant Hazardous Materials near Schools Impact 3.7-3: The proposed program could emit hazardous emissions or handle hazardous or acutely hazardous material, substances, or waste within one-quarter mile of an existing school. Structural (Regional, Centralized, and Distributed) BMPs BMPs may be installed throughout the watersheds. Some facilities may be installed within one- quarter mile of a school. Because construction and operation activities could potentially involve hazardous materials, the proposed program would have the potential to emit hazardous emissions or handle hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. In addition, BMPs that are constructed on school properties may collect spills from off-site sources or accumulate contaminants from urban runoff in soil in the BMPs over time. As discussed in Impact 3.7-1, individual BMP projects would be required to comply with regulations that would avoid or minimize the potential for releases of hazardous materials during the construction of the BMPs, in response to accidental spills either during the construction of the BMP, or as a result of the BMP collecting contaminants from an off-site spill. Air quality emissions are discussed in Section 3.2. Therefore, the potential impacts to nearby schools are considered less than significant. IA County Flood Control District 3.7-18 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials As discussed in Impact 3.7-2, BMPs that use soil to filter contaminants from urban runoff may accumulate contaminants over time. Implementation of the Mitigation Measure HAZ-1 discussed above would reduce the potential for impacts to less than significant levels. Mitigation Measure: HAZ-1 Significance Determination: Less than significant with mitigation (The application of this mitigation measure to specific BMP types and categories are identified in Table 3.7-1.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no new facilities that would require additional or new use of hazardous materials. Therefore, this impact would have no impact relative to schools. Mitigation Measures: None required Significance Determination: Less than significant Hazardous Materials Sites Impact 3.7-4: The proposed program could be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, could create a significant hazard to the public or the environment. Structural (Regional, Centralized, and Distributed) BMPs If a BMP were to be located on a hazardous materials site, construction workers could be exposed to hazardous materials during earth -moving activities. In addition, the earth -moving activities could mobilize hazardous materials to downslope or downgradient locations. If a BMP were to be located downslope or downgradient of a hazardous materials site, construction workers at the selected proposed project could be exposed to hazardous materials migrating from the nearby site. This could be considered a significant impact requiring mitigation. As discussed in Section 3.7.1, information on the presence of known hazardous materials sites is provided within the databases that make up the Cortese List, which includes information on hazardous materials sites from five regulatory agency lists. In addition, the LACFD is the designated LAC CUPA and maintains a list of sites under its responsibility. Reviewing these lists would identify known hazardous materials sites. It is possible that a proposed project may be on an unknown hazardous materials site not yet included in the databases. Contaminated soil and/or groundwater could be encountered during excavation posing a health hazard to construction crews, the public, and the environment. Implementation of Mitigation Measure HAZ-2 would reduce the potential impact to less than significant. IA County Flood Control District 3.7-19 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials Mitigation Measure: HAZ-2: Prior to the initiation of any construction requiring ground -disturbing activities in areas where hazardous material use or management may have occurred, the implementing agencies shall complete a Phase I Environmental Site Assessment (ESA) in accordance with American Society for Testing and Materials Standard E1527-13 for each construction site. Any recommended follow up sampling (Phase II activities) set forth in the Phase I ESA shall be implemented prior to construction. The results of Phase TI studies, if necessary, shall be submitted to the local overseeing agency and any required remediation or further delineation of identified contamination shall be completed prior to commencement of construction. Significance Determination: Less than significant with mitigation (The application of this mitigation measure to specific BMP types and categories are identified in Table 3.7-1.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no new facilities that would require additional or new use of hazardous materials. Therefore, this impact would have no impact relative to known hazardous materials sites. Mitigation Measures: None required Significance Determination: Less than significant Hazards near Public or Private Airports and Airstrips Impact 3.7-5: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, for a project within the vicinity of a private airstrip, the project could result in a safety hazard for people residing or working in the project area. Structural (Regional, Centralized, and Distributed) BMPs Aviation safety hazards can result if projects are sited in the vicinity of airports. Specifically, the land use compatibility plans at airports have land use restrictions, such as height, distracting light or glare, and attraction of birds. The construction of an object high enough to intersect the flight path of aircraft would result in aircraft collision hazards and risks of death or injury to people in the aircraft and on the ground if the aircraft crashes. Similar hazards would be created if a proposed project were to result in distracting light or glare that could interfere with a pilot's ability to control the flight path of the aircraft, or if a proposed project were to create an attraction to wildlife, especially birds, that would pose hazards to aircraft. IA County Flood Control District 3.7-20 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Pmgmm Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials The paved areas of airports (excluding the landing areas and taxiways, which have specific aircraft support requirements), and the undeveloped buffer zones around airports are potential sites for BMPs. Paved areas not used by aircraft could use permeable pavement and rainwater from buildings and paved areas could be routed to infiltration basins, bioswales, and subsurface infiltration galleries. None of the proposed structural BMPs would result in the construction of structures of significant height or generating significant glare or distracting light. Larger regional or centralized BMPs, such as treatment facilities or larger aboveground detention basins would not be permitted within the landing and takeoff flight paths. However, some structural BMPs, such as detention basins that store water for a period of time or constructed wetlands that would increase or improve wildlife habitat, could be constructed on or near airports and could result in attracting wildlife. Deer and birds are known wildlife hazards to airports. If the proposed project is at or near an airport, this could increase hazards to aircraft from wildlife. The FAA Advisory Circular No: 150/5200-33B provides specific guidance on development projects for new stormwater management facilities and artificial marshes. Implementation of Mitigation Measure HAZ-3 for all BMPs that are within the airport land use plan area, regardless of whether the airport receives federal funding, would reduce the potential impact to less than significant. Mitigation Measure: HAZ-3: Implementing Agencies shall require that those BMPs that are within an airport land use plan area are compatible with criteria specified in FAA Advisory Circular No: 150/5200-33B (FAA, 2007). If the proposed BMP is within the minimum separation criteria, the Implementing Agency shall consult with the airport and collaboratively evaluate whether the potential increase in wildlife hazards can be mitigated. Significance Determination: Less than significant with mitigation (The application of this mitigation measure to specific BMP types and categories are identified in Table 3.7-1.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no new facilities that would require additional or new use of hazardous materials. Therefore, this impact would have no impact relative to airports. Mitigation Measures: None required Significance Determination: Less than significant IA County Flood Control District 3.7-21 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials Impact 3.7-6: The proposed program could impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. Structural (Regional, Centralized, and Distributed) BMPs Construction activities associated with implementation of structural BMPs may include installations of pipelines or other infrastructure within roadway rights-of-way. These construction activities could potentially result in temporary lane or roadway closures or block access to roadways and driveways for emergency vehicles. Such construction -related impacts, although temporary, could potentially impair implementation of, or physically interfere with, an adopted emergency response plan or emergency evacuation plan. Impacts to access would be possible during the construction of larger scale regional or centralized BMPs, and less likely for the smaller -scale distributed BMPs. Notification to emergency services providers would ensure that emergency responsiveness was not impaired. Once installed, the BMPs would have no effect on emergency response plans or evacuations plans. Mitigation Measure: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no new facilities that would require additional or new use of hazardous materials. Therefore, this impact would have no impact relative to emergency response plans or emergency evacuation plans. Mitigation Measures: None required Significance Determination: Less than significant Impact 3.7-7: The proposed program could expose people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands. Structural (Regional, Centralized, and Distributed) BMPs The grading of unimproved areas could require the use of mechanized equipment with internal combustion engines. The equipment would include excavators, backhoes, drilling rigs, and support trucks. Parts of the engines and exhaust systems could get hot enough to ignite dry vegetation and cause a wildfire and expose people or structures to significant risk. Most of the BMPs are likely to be distributed BMPs constructed within developed urban areas with no possibility for wildfires. However, some regional and centralized BMPs could be IA County Flood Control District 3.7-22 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials constructed in rural undeveloped areas. Larger -scale centralized BMP treatment facilities could be built in previously undeveloped areas, since the urban areas are largely built out. As discussed in the Setting section, the CAL FIRE fire hazard severity zone maps identify areas within the EWMP with high and very high fire hazard severity categories. Structural BMPs conducted within these areas would have the added potential of causing wildfires. However, the requirements of the DOT and California Vehicle Code for spark arrester protection on vehicles would reduce the potential risk. Therefore, adherence to federal and state regulations would reduce the potential impacts from wildfires to less than significant. No mitigation measures would be required. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. As a result, there would be no new facilities that would have the potential to create a risk of wildfire. Therefore, this impact would have no impact relative to wildfires. Mitigation Measures: None required Significance Determination: Less than significant Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs BMPs would be constructed throughout the watersheds. Most of the distributed BMPs would be small in scale and would not result in cumulatively significant impacts due to increased hazards from construction or operation. However, the combination of BMPs throughout the region would change the flow paths of stormwater and urban runoff that currently occurs in the region, resulting in the retention of pollutants generally within the soil of the BMPs that use soil for filtration and retention. Mitigation Measure HAZ-1 would reduce the potential for concentrations of these pollutants to result in localized hazardous conditions at individual BMP locations. Mitigation Measure HAZ-2 would mitigate the accumulation of contaminants in soil at BMPs. Cumulatively, throughout the region, the retention and treatment of pollutants within each watershed and the reduction of pollutant loading in waterways will substantially benefit water and sediment quality of the region's habitats, rivers, and beaches. Therefore, the project's potential contribution to cumulative effects on hazards and hazardous materials is considered beneficial. IA County Flood Control District 3.7-23 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials Mitigation Measures: HAZ-1 and HAZ-2 Significance Determination: Less than significant with mitigation. (The application of this mitigation measure to specific BMP types and categories are identified in Table 3.7-1.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no new facilities that would contribute to cumulative impacts. Mitigation Measures: None required Significance Determination: Less than significant IA County Flood Control District 3.7-24 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Repent 3. Environmental Setting, Impacts, and Mitigation Measures 3.7 Hazards and Hazardous Materials TABLE 3.7-1 SUMMARY OF HAZARDS IMPACTS REQUIRING MITIGATION MEASURES Thresholds of Transport, use Impair or disposal of Accumulation of Hazardous Located on Vicinity of implementation Yes No hazardous hazardous emissions near hazardous airport or of emergency Exposure to Cumulative Structural BMPs materials materials schools materials site airstrip response plan wildland fires Impacts Yes No No Yes and Use Applicable Centralized BMP HAZA and HAZ- Mitigation Measures: None Required HAZA HAZA HAZ-2 HAZ-3 None Required None Required 2 Regional BAPS Regional Retention and No Yes Yes Yes Yes No No Yes Infiltration Regional Capture, Detention No Yes Yes Yes Yes No No Yes and Use Centralized BMP Bio -filtration No Yes Yes Yes Yes No No Yes Constructed Wetlands No Yes Yes Yes Yes No No Yes Treatment/Low-Flow Diversions No Yes Yes Yes Yes No No Yes Creek, River, Estuary No Yes Yes Yes Yes No No Yes Restoration Distributed BAPS Site -Scale Detention No Yes Yes Yes Yes No No Yes LID — Infiltration/Filtration BMPs No Yes Yes Yes Yes No No Yes — Porous Pavement, Green Streets, Bioswale/Filter Strips, downspout disconnects LID— Green Infrastructure— No Yes Yes Yes Yes No No Yes Capture and Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes Flow-through Treatment BMPs No Yes Yes Yes Yes No No Yes Source -Control Treatment No Yes Yes Yes Yes No No Yes BMPs (catch basin inserts/screens, hydrodynamic separators, gross solids removal devices) Low -Flow Diversion No Yes Yes Yes Yes No No Yes NOTE: These conclusions are based on typical size and function of BMPs. IA County Flood Control District 3.7-25 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.8 Hydrology and Water Quality This section describes the existing hydrology and water quality conditions within the project area and evaluates whether the proposed program would result in significant hydrology or water quality impacts. 3.8.1 Environmental Setting Surface Water Climate and Precipitation The 12 Enhanced Watershed Management Program (EWMP) Areas are located within Los Angeles County (County). The coastal mountains and plains within this region have a mediterranean climate with mild rainy winters and warm dry summers, while the inland slopes and basins tend to experience more extreme temperatures and less precipitation. These variations of climate within the region can be attributed to variable topography. Higher elevations generally receive more precipitation than nearby areas at lower elevations. Prevailing winds from the west and northwest carry moist air from the Pacific Ocean inland until it is forced upward by the Santa Monica, San Gabriel, or Santa Susanna Mountains. The resulting rainfall occurs mostly during discrete, episodic events between November and March. Annual precipitation can vary significantly between drought and flood conditions; periodic and occasionally severe droughts and floods within the area are well-documented (LARWQCB, 1994), and the potential for extreme precipitation (maximum intensity of precipitation for periods of 12 hours or longer which might be expected at intervals of ten to 100 years) is greater in portions of the San Gabriel Mountains than practically anywhere else in the continental United States (WERC, 2014). Average annual rainfall within the Los Angeles Basin is approximately 14.5 inches, though local averages can vary considerably depending on location within the basin (WERC, 2012). Los Angeles County Watersheds As shown in Figure 3.8-1, the portion of Los Angeles County covered in this Program Environmental Impact Report (PEIR) is divided into distinct watersheds, including: the Los Angeles River, San Gabriel River, Rio Hondo, Santa Clara River north of the Santa Susana Mountains, Dominguez Channel, and coastal drainages stretching from Malibu to Palos Verdes, including Ballona Creek. The 12 EWMP areas were identified as portions of these greater watersheds that contain impaired water bodies needing structural Best Management Practices (BMPs) to comply with stormwater discharge permit requirements. IA County Flood Control District 3.8-1 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report Ventura OWatershed Boundary 1 - Ballon Creek - 2 - Beach Cities - 3 - Dominguez Channel 4 - Malibu Creek 5 - Marina Del Rey - 6 - North Santa Monica Bay - 7 - Palos Verdes Peninsula 8 - Rio Hondo/San Gabriel River 9 - Santa Monica Bay Jurisdictions 2+3 - 10 - Upper LA River - 11 - Upper San Gabriel River - 12 - Upper Santa Clara River SOURCE: ESRI. Kern Santa Clara Rlvai Los Angeles Los Angeles RNer U San Bernardino Orange 0 7` 8 I I Miles LA County PEIR EWMP. 140474 Figure 3.8-1 Watersheds and EWMP Groups 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Los Angeles River The 51 -mile Los Angeles River stretches from its headwaters in the upper San Fernando Valley to its mouth in San Pedro Bay, draining the Santa Susana and San Gabriel Mountains and San Fernando Valley. Following several catastrophic and deadly floods in the early 1900s, the U.S. Army Corps of Engineers channelized and armored the river levees and numerous tributaries with concrete to mitigate future flooding concerns. The channelization of this stream, completed in the 1960s, ended ongoing flooding concerns and provided land for the construction of homes and businesses within the previous floodplain. San Gabriel River The San Gabriel River is bound by the San Gabriel Mountains to the north, San Bernardino to the east, Los Angeles River to the west, and Pacific Ocean to the south. The San Gabriel River flows 58 miles south until its confluence with the Pacific Ocean. Major tributaries to the San Gabriel River include Walnut Creek, San Jose Creek, Coyote Creek, and numerous storm drains entering from the 19 cities that the San Gabriel River passes through. Much of the channel above the Whitter Narrows is unlined. Storm flows are diverted from the riverbed into four different spreading grounds by dams for ground water recharge. The 10 -mile segment below Whittier Narrows is a concrete -lined channel. Rio Hondo The Rio Hondo watershed is a subwatershed of the Los Angeles River watershed and is also linked to the adjacent San Gabriel River watershed. This link reflects both natural hydrologic processes and human intervention. Historically, the Los Angeles and San Gabriel Rivers were wide, shallow rivers consisting of a braided series of channels that would periodically intermingle following large storm events. Today, the rivers have been engineered into three channels created to bring water from the San Gabriel to the Rio Hondo, making the Rio Hondo serve as an outlet for the San Gabriel River. Dominguez Channel Named for the Juan Jose Dominguez family who owned a tract of 75,000 acres of land (Rancho San Pedro) from the Los Angeles River west to the Pacific Ocean in the late 1700s, the channel is a 15.7 -mile -long waterway that drains a 110 square miles. The headwaters begin in Hawthorne and eventually empty into the East Basin of the Port of Los Angeles. Today, the Dominguez Channel watershed is 96 percent developed. Santa Clara River The Santa Clara River watershed encompasses approximately 1,030 square miles. The Upper Santa Clara River watershed is located primarily within both Ventura (243 square miles) and Los Angeles County (786 square miles), as well as a very small portion of Kern County. The Santa Clara River is one of the few natural river systems remaining in Southern California originating in the Angeles National Forest and flowing westward for approximately 84 miles to the Pacific Ocean. Throughout its length, the river crosses through farmland, undeveloped lands, and urban areas. The lower Santa Clara River watershed is located primarily within Ventura County and out of the study area for this project. a County Flood Control District 3.8-3 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Coastal Drainages All along the Los Angeles County coastline, distinct drainages flow from uplands to the ocean. In Malibu, these drainages within the Santa Monica Mountains are generally short, steep, and relatively natural channels. Malibu Creek drains a wide area that includes areas within and north of the Santa Monica Mountains. In the urbanized areas along Santa Monica Bay, the streams have been channelized. Ballona Creek is a 9 -mile -long waterway that drains the Santa Monica Mountains on the north and the Baldwin Hills on the south. Ballona Creek flows through Culver City until emptying into Santa Monica Bay between Marina del Rey and Playa del Rey. Following damaging flooding events, the Los Angeles County Flood Control District (LACFCD) concreted Ballona Creek and its tributaries during the 1930s. The Ballona Wetlands at the mouth of the creek are one of the last significant coastal wetland areas in Los Angeles County. EWMP Groups The proposed program has been divided into 12 EWMP Areas that have been organized by watershed groups that share comparable conditions. The key linkages that were used to distinguish the various EWMP groups were percentage of open space and urbanization, similar focus on the types and percentage of BMPs, and common hydrologic conditions. The following summaries are the general characteristics of the watersheds within the EWMP groups and the overall strategies for BMP implementation that reflect these characteristics. The 12 EWMPs are consolidated into six watershed areas that are grouped by similar watershed characteristics. This summary provides additional detail on the hydrologic features and strategies for the distribution and locations of potential and priority BMPs. Figures are referenced and provided for each of the six consolidated watershed areas and also provide hydrologic features and the locations and distribution of planned and priority regional/centralized BMPs. The priority BMPs are a subset of the planned BMPs and have been selected as priority projects based on a screening assessment of the planned projects. Priority projects will be implemented before additional planned projects. Distributed BMPs are planned to be implemented throughout the urbanized areas of the EWMPs. The following summaries of the six watershed areas also highlight the linkage between the BMP strategies with hydrologic conditions in these watersheds that provide a basis to assess potential environmental impacts presented in the assessment section. 1. South Santa Monica Bay EWMP Watersheds (Figure 3.8-2) (Marina del Rey, Ballona Creek, Beach Cites, South Santa Monica Bay Jurisdictional Group 2 and 3, and Peninsula Cities EWMP groups) — These watersheds are dominated by urbanized beach communities with high-density residential and commercial land uses throughout the watershed. Key BMP strategies in these watersheds are to address dry- and wet -weather flows that may impact beach water quality through bacteria loading. Other water quality priorities include trash, marine debris, metals, and toxics. The BMP strategy includes low -flow diversions (LFDs) to comply with dry -weather metals and bacteria Total Maximum Daily Loads (TMDLs). Although large regional and centralized retention and infiltration BMPs will be part of the pollutant load reduction strategy, the predominate structural BMP will be smaller distributed BMPs such as bioinfiltration, media filtration and flow-through BMPs located in street rights-of-way, parking lots, landscaped areas, IA County Flood Control District 3.8-4 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources and as part of green streets and buildings. Due to the high ground water near the shore, capture and reuse regional projects or treatment BMP opportunities will be preferred. The receiving waters for the South Santa Monica Bay include the Pacific Ocean, the Ballona Creek, and the Marina del Rey Harbor. The Ballona Creek is channelized through the urbanized area of the Ballona Watershed. The Ballona Wetlands received muted tidal flow from Ballona Creek that is tidally influenced (see the photograph below). Channelized Ballona Creek and Ballona Wetland Marina del Rey EWMP — Because of the tidal influence of the marina to most of the watershed, regional projects will be located near the upstream end of the watershed, where groundwater depths are favorable. The tidally influenced areas will consist of mostly treatment distributed BMPs including bioinfiltration or tree wells. Ballona Creek EWMP — Regional infiltration BMPs will be well distributed throughout the watershed and will be incorporated with distributed BMPs consisting mostly of treatment BMPs such as green streets. LFDs may also be pursued to comply with dry - weather TMDL requirements. Beach Cities EWMP — The watershed includes a portion of the Beach Cities EWMP that drains to the Pacific Ocean. The Beach Cities will focus their efforts on regional projects near the outlet on the Beach similar to the Hermosa Beach Infiltration Trench or the Torrance infiltration basins. Where regional projects are infeasible, distributed projects such as green streets will be implemented. Santa Monica Bay J2/3 — Many efforts have already been completed for the Santa Monica Bay J2/J3 watershed, including LFDs and reuse facilities. The group will investigate the possibility of more regional projects that are able to capture and reuse the flow. Remaining areas will be subject to distributed BMPs. Peninsula Cities — The Peninsula Cities area (SMB J7) is mostly anti -degradation sites, so there will not be many control measures in this subwatershed. a County Flood Control District 3.8-5 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources 2. Northern Coastal EWMP Watersheds (Figure 3.8-3) (Malibu Creek and North Santa Monica Bay Coastal Watershed EWMP groups) — These watersheds are characterized by lower -density development along the coast and the larger creeks with greater open space and park areas inland. There is increased development in the upper areas of the Malibu Creek watershed. Receiving waters in these watersheds are largely unlined and riparian corridors remain. Water quality priorities include bacteria, toxics, trash, and nutrients as well as benthic community impairments. Key BMP strategies are to address bacteria loading to the beaches and inland waters, but because of the lower development and largely decentralized infrastructure, LFDs are not the only strategy to address this priority issue. In addition to LFDs, larger centralized BMPs that include detention and infiltration and detention and filtration will be used for Municipal Separate Storm Sewer System (MS4) outfalls that are in close proximity to the receiving waters. Smaller distributed BMPs that include biofiltration, media filtration, green streets, and flow-through BMPs will be used in greater percentage than larger centralized BMPs and would be located in developed areas as retrofit BMPs. Marie Canyon Low -Flow Diversion — Malibu Creek 3. Upper San Gabriel Watershed (Figure 3.8-4) — This watershed is characterized by higher -density development in the lower watershed area and lower -density development and open space in the upper watersheds where the foothills to the San Gabriel Mountains begin. The priority pollutants in these watersheds include selenium in dry -weather flows and metals in storm flows in Coyote Creek. These watersheds are further differentiated by the importance of groundwater recharge basins that are supplied by a series of reservoirs further upstream in the mountains. The San Gabriel River is unlined in the upper watershed and conveys controlled non -storm and storm flows to recharge basins and downstream sections of the river. a County Flood Control District 3.8-6 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Upper San Gabriel River The BMP strategy in these watersheds focus more on regional and centralized retention and infiltration BMPs that take advantage of the favorable groundwater recharge characteristics of this area. These BMPs are located near or adjacent to the river. This watershed includes stream restoration that uses natural unlined tributaries and centralized bioinfiltration BMPs in parks and open spaces with favorable subsurface soils that promote higher infiltration rates. Distributed smaller BMPs are located in urbanized areas as retrofits in existing developments and streets. 4. Upper Los Angeles River Watershed and Rio Hondo/San Gabriel Watershed (Figure 3.8-5) — These watersheds traverse a large diverse area of the Los Angeles Basin with characteristics of Upper San Gabriel in the farthest upper reaches near the foothills, but, for most part, these watersheds are characterized by greater urbanization similar to the Ballona Creek watershed. The greater urbanization also results in additional priority pollutants compared to the Upper San Gabriel watershed and includes nutrients, trash, metals, bacteria, and sediment impacted by metals and organic compounds (DDT, PCBs, PAHs). The Rio Hondo/San Gabriel EWMP is characterized by increasing urbanization south of the foothills and industrial and commercial development along the I-210 corridor. The strategy for the locations and types of BMP is to use remaining available sites for retention and infiltration that takes advantage of the favorable infiltration rates of this area, including the existing groundwater recharge basins near the San Gabriel River. Los Angeles River IA County Flood Control District 3.8-7 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources The Los Angeles River is approximately 51 miles long, and five of six reaches lie within the Upper Los Angeles River EWMP. The natural hydrology of the Los Angeles River watershed has been altered by channelization and the construction of dams and flood control reservoirs. The Los Angeles River and many of its tributaries are lined with concrete for most or all of their length. Soft -bottom segments of the Los Angeles River occur where groundwater upwelling prevents armoring of the river bottom. Because of the greater extent and number of pollutant priorities, the BMP strategy in the Upper Los Angeles River watershed and Rio Hondo watershed includes well over a hundred planned regional and centralized retention and infiltration BMPs that take advantage of the favorable groundwater recharge characteristics in defined areas of the watershed. Also planned are centralized treatment wetlands and bioinfiltration BMPs in parks and open spaces with favorable subsurface soils that promote higher infiltration rates. The BMP strategy also includes distributed smaller BMPs located throughout the urbanized areas of the watershed as retrofits in existing developments and streets. LFDs to comply with dry - weather bacteria TMDLs will also be included. 5. Dominguez Channel Watersheds (Figure 3.8-6) (Dominguez Channel EWMP and Beach Cities EWMP— This watershed includes the Dominquez Channel EWMP and a portion of the Beach Cities EWMP that drains to Dominquez Channel. This watershed is differentiated by a larger area of industrial land use. Because of the high density of development and industrial land uses, large regional and centralized infiltration -type BMPs will be limited. The structural BMP strategy will be more LFDs, both large (centralized) and small (distributed), located at MS4 outfalls near the channelized Dominguez Chanel. The other BMP strategy is the use of smaller distributed BMPs that include the low -impact development (LID) type of BMPs, such as green streets and biofiltration BMPs. These distributed BMPs will be retrofit type BMPs that treat runoff from already developed properties and are located in street rights-of-way, parking lots, and limited open areas on public and private parcels. Distributed flow-through treatment BMPs will also be the other predominant BMP that will be retrofitted to the existing MS4 systems. Dominquez Channel IA County Flood Control District 3.8-5 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources 6. Upper Santa Clara River Watershed (Figure 3.8-7) — The Santa Clara River watershed is distinctive in that it is predominantly open space—nearly 90 percent of the watershed is open space with approximately 88 percent being undeveloped. The watershed contains one of the last remaining natural rivers in Southern California. In years of significant rainfall, ephemeral springs and year-round flows exist in some tributaries and natural upstream areas. Flows in Santa Clara River reaches that pass through the EWMP area are predominantly storrnwater runoff during wet -weather months and water reclamation plant effluent discharges in the drier months. Upper Santa Clara River Priority pollutants in this watershed are bacteria, nutrients, and chloride. In the source assessments for the nutrients TMDL and the chloride TMDL for the Santa Clara River, the storm drain system is not considered the primary source of these pollutants. Lake Elizabeth is also subject to a trash TMDL. The EWMP will evaluate potential MS4 nutrients and chlorides contributions and serve as the implementation plan for the bacteria TMDL. BMP strategies for this watershed are likely to include a focus more on regional and centralized detention and infiltration BMPs and less on filtration -type BMPs, which are not as effective at addressing bacteria. IA County Flood Control District 3.8-9 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. 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Perrenial Stream M Industrial TranspolrUMM 0 CCOMMI oa Mcl o Utilities ® � El 010M Md m11 M oM7>1ar91 Ullian - oOrpreffS addi�iand ❑Maafion 0 o7fiffi@r M oO MM-MlI n 1404,74 Figure 3.8-4 ■ Irji[:[1fi�F--Gil [F -Iii G[cll 1'.F3i [iT.%'IiG�6il'Af i=•Fillllll:D�GIfdi76F1Ti1Gr&iiiIIT�F21F-fifil :fi7 i=-fii TFFII = u ii • e:f'� r 0 9 0 0 CLand Use jr 7r .I 11 iir11iF-Ti•;ilciiiF.-rrn.mrI IIrIF il Crmin VFGF6 ■ PF:➢: 1 1 GrC[1fi I1Tr'7cir_ r:[ Ur-- F.Ir'[ill Ara . 140474 Figure 3.8-5 :D6ifii7 Ci lilligGFF561T7F9FfI ril : -i : iii few 21 • Mdo fn es Res o • • Res L • � A • • • • E M A • •p r r • U • E • O l I ominguez Chan O • ®� .✓ B e - ar • 0 t...l dif• • • • Rere g a .gg in ez harm • t C Land Use r • 11 CC ofiingI&FOOMFIeslderitlal Hydrologic Features 11M:utG+Fam5ty19feslde'HltaI • DBfathf 0 o0the77 Brealrl "�.• • M ❑oreriimD•CtScce ....`. — [IC4nn Mr M EIMMMr WWAS s • . • owe M [Facilities • —•••--Sire'am Education o BfertEWStream M Military. Installattorts • 0 -industrial 0 CTransportatian ® M oCommunicatia®i Md oltalities 11 ComWd M El LhWn ❑opr®faod M oRoanation owe T ot 0 EIVLMr El COMMUMn "Potential Distributed BMP not shown - predominantly located in urbanized areas T EzLand Use L-1 EISIngla;FarrWiResidential ■ 5UN a i;FI PI Residential _ ■ cr_.r.7Frn oris - ■ •G it i. C:Iia: FEIIF.6GI ElEdUMIldn Frindummal ■11 . dfi::GGf711 .G li linfilTF:G6fi{cll F. finl nilli�F offixedOmlu:riaFruF:rrnrrnzir,� EillirkedUItien Open RMMWMn Agriculture ■I . . UnderCOMMUMn . 1404,74 Figure 3.8-7 ■ �sf:Cilfi:F-Gi7 Fa nl Ff rl P.F3S [il.%1iGCil9.f i=•F311111 :D,Gifdi76'.�1Ti1Gr&i7iIgMF-li Cil :67 rT :1 : u 6 • i*ni 1 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Effects of Urbanization on Streamflows Prior to urbanization in the mid to late 1800s, surface water hydrology within the Los Angeles Basin was dominated by natural processes of watershed runoff and recharge. During the winter rainy season, runoff from the watershed would feed stream flows and recharge groundwater aquifers in the lower alluvial portions of the basin. As the intensity,) frequency, and duration of winter rains decreased, stream flows would recede in response to decreased watershed runoff. In many locations, especially smaller streams, portions of streambeds would seasonally go dry (ephemeral), with surface flows only reestablished by the return of winter rains. In other streams, near -surface groundwater would maintain base flows throughout the summer, supporting wetland and floodplain habitats. During the summer, coastal streams would typically form freshwater - brackish lagoons at creek mouths behind sand berms built by summer wave action; these lagoons also supported seasonal aquatic habitats. �- A% Pre -Development Hydrology is characterized by dry -weather flows fed by groundwater seepage fed by recharge during the rainy season. Some creeks and rivers are ephemeral and dry up in the dry season. Most of the historic hydrologic processes have been fundamentally changed throughout the Los Angeles Basin due to urbanization. The replacement of native soils with largely impermeable surfaces such as concrete and asphalt has dramatically altered storm hydrographs (graph showing the flow rate in a stream or channel over the storm event) as shown in Figure 3.8-8, increasing runoff rates and flood volumes that have to be safely routed away from people, homes, businesses, and infrastructure. Floodplain and wetland habitats that formerly provided water quality treatment and groundwater recharge functions have been largely eliminated from the landscape, accelerating the transport of flows from higher to lower areas of the watersheds. Figure 3.8-8 presents a comparison of the predevelopment and development conditions and impacts to hydrology. The effect that is shown in Figure 3.8-8 to the hydrograph from urbanization is called hydromodification. Hydromodifrcation reduces base -flow (groundwater flow into streams) and increases peak discharge rates into streams and rivers. Figure 3.8-8 also shows the effect of the hydrograph when BMPs such as retention basin are implemented that capture urbanized storm flows and release these flows under reduced flows to return the hydrograph close to predevelopment conditions. a County Flood Control District 3.8-17 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Effect of Urbanization on an Before urbanization Time LA County PER EWMP . 140474 Figure 3.8-8 Example Stream Hydrograph and Hydrograph after Implementation of Retention -Type BMP In addition, urbanization can increase dry -weather flows in local streams that were historically ephemeral as a result of irrigation runoff and wastewater treatment plant discharges. Naturally occurring dry -weather flows in the San Gabriel River and Los Angeles River are also influenced by the management of upstream dams and reservoirs that impound flows from winter storm events and then distribute these flows to recharge basins and to treatment facilities as part of the water supply system. These flows are managed through periodic dam releases and downstream intake systems. Figure 3.8-9 provides the locations of dams and reservoirs in the Los Angeles region. IA County Flood Control District 3.8-18 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report After urbanization —without detention M basins ro L U Controlled outflow E from detention basin 9 m or flood-controi reservoir Effect of Urbanization on an Before urbanization Time LA County PER EWMP . 140474 Figure 3.8-8 Example Stream Hydrograph and Hydrograph after Implementation of Retention -Type BMP In addition, urbanization can increase dry -weather flows in local streams that were historically ephemeral as a result of irrigation runoff and wastewater treatment plant discharges. Naturally occurring dry -weather flows in the San Gabriel River and Los Angeles River are also influenced by the management of upstream dams and reservoirs that impound flows from winter storm events and then distribute these flows to recharge basins and to treatment facilities as part of the water supply system. These flows are managed through periodic dam releases and downstream intake systems. Figure 3.8-9 provides the locations of dams and reservoirs in the Los Angeles region. IA County Flood Control District 3.8-18 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 1 - Ballon Creek Kern 2 - Beach Cities 3 - Dominguez Channel c -- - - -- — - — - — — - — -- — — — - — — - -- — — — — 4 - Malibu Creek 5 - Marina Del Rey \ 6 - North Santa Monica Bay 7 - Palos Verdes Peninsula \ i °•••^°"p B - Rio Hondo/San Gabriel River 9 - Santa Monica Bay Jurisdictions 2+3 10 - Upper LA River I 11 - Upper San Gabriel River V "• 12 -Upper Santa Clara River Ir �•• ` • -11fle Rock \ - ..•. Los Angeles f� I Ventura �) Pa. n Alsorvor I I I I Gneno 0.-Prank.,Werdugo ReservoirI r k* - . ,...v 1 �rv• I ® .o.a RaIrks Rock .•n VReaI R. Canyon opX % • ,.,.• 11�.. ® r.rd al� Rvservc San III Park Bernardino ®., ��r� RI IF rF— Ionian V.rd.. Reservoirs o-� Rivers/Streams Dam o e Miles SOURCE: ESRI; Los Angeles CountyGIS Orange LA County PEIR EWMP. 140474 Figure 3.8-9 System of Dams and Reservoirs in LA Basin 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources In the late 1990s, some Permittees along the Santa Monica Bay coast began to implement LFDs, which divert dry season flows from storm drains into the sanitary sewer system for treatment and disposal or reuse. Over 20 LFDs are currently in use within Los Angeles County; though most are along the SMB shorelineThe location of existing low flow diversions along the Santa Monica Bay coastline are shown on Figure 3.8-10.. Collectively, these LFDs divert a large volume of polluted urban runoff during each dry season, and they have proven to be one of the most effective tools for improving coastal water quality (LA Stormwater, 2014). The EWMPs include a suite of new LFDs and improvements to existing LFDs that will further increase the volume of dry -weather (and, in some cases, year-round) flows diverted for treatment. The installation/upgrades of these LFDs could potentially increase the amount of water available for recycling, reuse, and groundwater recharge. Surface Water Quality Surface water quality in Los Angeles is largely influenced by the intensive urban land uses of the region. Key sources of surface water contamination include landscape irrigation runoff conveying sediment, nutrients, pesticides, metals, oil and grease, and pathogens to receiving waters. Other dry -weather runoff from industrial activities can add organic compounds and petroleum hydrocarbons. The State Water Resources Control Board (SWRCB) has identified stream segments in each of the EWMP Areas that are considered impaired under the Clean Water Act (CWA) in the State Section 303d list. Table 3.8-1 lists the major streams on the Section 303d list within the EWMP areas. A water body is placed on the State §303d list when the receiving water does not meet applicable water quality standards listed in the Basin Plan and determined not to be supporting the beneficial uses associated with the applicable water quality standard. Once placed on the State §303d list, the water body or segment is then subject to the development of a TMDL. Appendix F provides a list of the current TMDLs and the references to existing TMDL Implementation Plans. TABLE 3.8-1 MAJOR IMPAIRED WATER BODIES IN THE STUDY AREA Water Body/Reach Name Pollutant/Stressor Potential Source Ballona Creek Dominguez Channel (lined portion above Vermont Avenue) Dominguez Channel (unlined portion below Vermont Avenue) Los Angeles River (Reaches 1-6) Cadmium, Coliform Bacteria, Copper (dissolved), Cyanide, Lead, Selenium, Toxicity, Trash, Viruses (enteric), and Zinc Unspecified or unknown point and nonpoint sources. Ammonia, Copper, Diazinon, Indicator Unspecified or unknown point and Bacteria, Lead, Toxicity, and Zinc nonpoint sources. Ammonia, Benthic Community Effects, Benzo(a)pyrene (3,4 -Benzopyrene -7- d), Benzo[a]anthracene, Chlordane (tissue), Chrysene (Cl-C4),Cobfomt Bacteria, DDT (tissue & sediment), Dieldrin (tissue), Lead (tissue), PCBs (Polychlorinated biphenyls), Phenanthrene, Pyrene, Sediment Toxicity, Zinc (sediment) Ammonia, Cadmium, Coliform Bacteria, Copper (dissolved), Cyanide, Diazinon, Lead, Nutrients (algae), Oil, Trash, Zinc (dissolved), pH, and Selenium. Unspecified or unknown point and nonpoint sources. Urban Runoff, Unspecified or unknown point and nonpoint sources. IA County Flood Control District 3.8-20 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Water Body/Reach Name Pollutant/Stressor Potential Source Malibu Creek Benthic-Macroinvertabrate Bioassessments, Coliform Bacteria, Fish Barriers, Invasive Species, Nutrients (algae),Scum/Foam- unnatural, Sedimentation/Siltation, Selenium, Sulfates, Trash. Rio Hondo (Reaches 1 and 2) San Gabriel River (Reaches 1-3 and East Fork) Santa Clara River (Reaches 1, 3, 5, 6, 7, and 11) Coliform Bacteria, Copper, Lead, Toxicity, Trash, Zinc, pH, Cyanide Coliform Bacteria, pH, Cyanide, Lead, Indicator Bacteria, Trash Toxicity, Ammonia, Chloride, Total Dissolved Solids (TDS), Coliform Bacteria, Iron, Chlorpyrifos, Copper, Diazinon, Boron, Specific Conductance, Sulfates. Urban Runoff, Unspecified or unknown point and nonpoint sources, Hydromodification, Waste Storage And Disposal, Recreation Areas And Activities, Groundwater Related, Atmospheric Deposition, Municipal Wastewater, and Agriculture Urban Runoff, Unspecified or unknown point and nonpoint sources. Urban Runoff, Unspecified or unknown point and nonpoint sources SOURCE: RWQCB, 2014. Available online at: http://www.waterboards.ca.gov/water_issues/programs/tmdl/integmted2010.shtml Existing Stormwater Recharge In Southern California's and climate, stormwater is increasingly viewed as a critical component of the region's water supply. The nexus between stormwater and groundwater has been recognized since the early 20th century, when groundwater recharge facilities began to be constructed along the San Gabriel River and other basins (see Groundwater, below). According to the Metropolitan Water District, approximately 55 percent of water supplies in Southern California are imported; 45 percent are supplied by local groundwater basins that are recharged naturally from rainfall and through constructed recharge facilities (MWD, 2010). As described further in this section, stormwater recharge facilities currently augment local groundwater supplies in the region by an estimated 477,000 acre-feet per year (MWD, 2014). One of the primary goals of the EWMP program is to increase the amount of stormwater that is recharged into groundwater, particularly in portions of the Central Basin that experience a high degree of hydraulic connectivity between surface water and groundwater. Infiltration BMPs proposed within the EWMPs are expected to increase the rates and amounts of groundwater recharge—the degree to which these increase is dependent upon project -specific attributes such as size, location, and the size of the contributing watershed. Groundwater Groundwater Basins Los Angeles County is located in the South Coast Hydrologic Region (HR), as described by the Department of Water Resources Groundwater Bulletin 118 (2003). The South Coast HR is divided into numerous smaller groundwater basins and subbasins; the two largest and most critical among them are the Central Basin and the West Coast Basin. Figure 3.8-10 displays the boundaries of these basins. IA County Flood control District 3.8-21 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report I 1 - Ballon Creek Kern 2 - Beach Cities 3 - Dominguez Channel -- — - — - - - - - --- - - — - - - - - -- — — — — 4 - Malibu Creek 5 - Marina Del Rey 6 - North Santa Monica Bay 7 - Palos Verdes Peninsula i B - Rio Hondo/San Gabriel River A L� 9 - Santa Monica Bay Jurisdictions 2+3 10 -Upper LA River I 11 - Upper San Gabriel River 5 12 -Upper Santa Clara River Ventura ® Groundwater Basins Rivers/Streams o e I I Miles SOURCE: ESRI; Los Angeles County GIS f. Orange LA County PEIR EWMP. 140474 Figure 3.8-10 Groundwater Basins within the EWMP Areas II i -" Los Angeles i SYLMAR V I BASIN -.. y SAN " FERNANDO.' VERDUGO UPPER SAN -- SABA BASIN GABRIEL ' I 1 CANYON .1 ® ' LOWBRIEL RAYMOND GABRIEL -s }�F(LAREMONT EAGLE BASIN CANYON OL, ENDORA - PoQiRI[L XEIGXiS S�Ai, ROCK BASIN BASIN-. BASIN ® BASIN WAY HILL t BASIN POMONA -°AI It"t HOLLYWOOD' MAIN SAN SANOIMAS BASIN " BASIN - GABRIEL BASIN FASIN SPADRA CHINO SANTA BASIN BASIN MONICA BASIN - PUENTE BASIN 'k ® San �s LAHASRA' ����oyi. J zBernardino CENTRAL -".S - BASIN BASIN — ®� IN TI WEST LL TI COAST BASIN SOURCE: ESRI; Los Angeles County GIS f. Orange LA County PEIR EWMP. 140474 Figure 3.8-10 Groundwater Basins within the EWMP Areas 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources The 140 -square -mile West Coast Basin underlies much of the Beach Cities, Dominguez Channel, and Marina del Rey EWMP Areas. The 270 -square -mile Central Basin underlies portions of the Los Angeles River, Upper San Gabriel, and SGR/Rio Hondo EWMP areas. The Central and West Coast Basins are characterized by aquifers that are generally confined by relatively impermeable clay layers over most of the area (DWR, 1961), with the exception of the Montebello and Los Angeles Forebays in the Central Basin. Groundwater generally flows from east to west across the Main San Gabriel Basin, then southward into the Central Basin through the Montebello Forebay. Within all groundwater basins, groundwater flow directions are generally controlled by engineered recharge operations and groundwater pumping from the hundreds of wells distributed across the area (Shelton et al., 2001; Dawson et al., 2003). Stormwater recharge facilities currently augment local groundwater supplies in the region by an estimated 477,000 acre-feet per year (MWD, 2014). Due to the pumping depressions that exist in the Central and West Coast Basins, very little groundwater discharges or leaves the basins as subsurface outflow. Recharge to the Central Basin occurs primarily by engineered recharge of stormwater, imported water, and reclaimed water along the upper reaches of the San Gabriel River and the Rio Hondo via the San Gabriel River Water Conservation System. This system is a series of dams, spreading grounds and instream recharge systems that facilitate groundwater recharge into the Main San Gabriel Basin and Montebello Forebay of the Central Basin. The system is comprised of four dams (Cogswell, San Gabriel, Morris, and Santa Fe) and three spreading grounds (San Gabriel Canyon, Sante Fe, and San Gabriel) on the San Gabriel River, as well as inflatable dams meant to pond water along the river's unlined stretch of the river. The system also includes one dam (Whittier Narrows) — and one spreading ground (Rio Hondo) along the Rio Hondo. Collectively, the Rio Hondo and San Gabriel River spreading grounds are referred to as the Montebello Forebay Spreading Grounds, or MFSG. Recycled water has been also delivered for recharge in the Montebello Forebay since 1962. Finally, the Central Basin includes one seawater intrusion barrier, the Alamitos Gap Seawater Intrusion Barrier (AGB), fed by treated imported water along with advanced water treatment recycled water. Recharge to the West Coast Basin occurs primarily by injection of imported water and reclaimed water into wells of the seawater intrusion barrier and by underflow from the Central Basin. The Dominguez Channel Spreading Grounds (DGSG) are located along the Los Angeles River near the boundary between the West Coast and Central Basins. The sources of water for the spreading grounds are controlled flows from the Los Angeles River low -flow channel and uncontrolled flows from storm drains. The West Coast Basin includes two seawater intrusion barriers, the West Coast Basin Seawater Intrusion Barrier (WCBB) and Dominguez Gap Seawater Intrusion Barrier, also fed by treated imported water and advanced water treatment recycled water. The EWMP areas overlie various groundwater basins as summarized in Table 3.8-2, most of which are adjudicated and managed by court -stipulated Watermasters. The Watermasters monitor groundwater production and participate in groundwater remediation programs. IA County Flood Control District 3.8-23 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources TABLE 3.8-2 GROUNDWATER BASINS WITHIN THE EWMP AREAS EWMP Groundwater Basin Adjudicated? Watermaster Ballona Creek Santa Monica Basin No None Santa Monica Bay Hollywood Basin No None Central Basin Yes CB Beach Cities West Coast Basin Yes WCB Dominguez Channel West Coast Basin Yes WCB Malibu Creek None No None Marina Del Rey Santa Monica Basin No None North Santa Monica Bay None No None Palos Verdes Peninsula None No None San Gabriel and Rio Hondo Main San Gabriel Basin Yes MSGB Santa Monica Bay Santa Monica Basin No None West Coast Basin Yes WCB Upper Los Angeles River San Fernando Basin Yes ULARA Main San Gabriel Basin Yes MSGB Central Basin Yes CB Upper San Gabriel Upper San Gabriel Yes MSGB Upper Santa Clara River East Subbasin No None WCB - West Coast Basin Watermaster CB - Central Basin Watermaster MSGB - Main San Gabriel Basin Watermaster ULARA - Upper Los Angeles River Area Watermaster SOURCE: DWR, Bulletin 118 Groundwater Qualify In general, groundwater in the main producing aquifers of the West Coast and Central basins is of good quality. Localized areas of marginal to poor quality water exist, primarily at the basin margins where seawater intrusion occurred in the past and also in mostly shallow groundwater near environmental release sites. Groundwater has also been impacted by industrial activities that have introduced highly mobile man-made organic compounds such as solvents and fuel additives. These contaminated groundwater plumes are well documented. Areas of these contaminant plumes are designated to restrict recharge activities that may create an increased driver for contaminant migration. Between the 1900s and 1950s, groundwater was an important factor in urbanization of the West Coast and Central basins. Excessive overpumping in the basins caused severe overdraft (i.e., lowered groundwater levels) and created a hydraulic gradient that resulted in seawater intrusion, which contaminated the coastal groundwater aquifers. To address this problem and halt the intrusion, three seawater intrusion barriers were constructed (discussed previously). While the water injection activities at the barriers were successful in halting further seawater intrusion, these efforts could not address the seawater that had already intruded into the Central and West Coast Basins before the barriers were constructed. These large plumes of saline water, referred to as "saline plumes," are trapped inland of the injection wells, thereby degrading significant volumes IA County Flood Control District 3.8-24 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources of groundwater with high concentrations of chloride and total dissolved solids (TDS) and decreasing the ability of affected aquifers to provide groundwater storage. Groundwater quality in the Central and West Coast Basins also reflects current and historical land uses. As a highly urban area, commercial and industrial activities have resulted in contamination due to leaking aboveground and underground storage tanks, leaking sewer and oil pipelines, spills, and illegal discharges. Many groundwater contamination plumes consist of priority contaminants such as petroleum fuels and additives (e.g., methyl tert-butyl ether), solvents (e.g., trichloroethylene and perchloroethylene), herbicides (e.g., atrazine, simazine, prometon), and other hazardous/toxic substances (e.g., arsenic, perchlorate). Groundwater contamination within the central, West Coast, and adjacent basins is discussed in depth in the California Groundwater Ambient Monitoring and Assessment's 2012 summary report (USGS and SWRCB, 2012). In general, contaminated plumes are typically found in shallow groundwater. However, as the aquifers and confining layers in these alluvial basins are typically interfingered,' the quality of groundwater in the deeper production aquifers is threatened by the migration of pollutants from the upper aquifers. 3.8.2 Regulatory Setting Federal Clean Water Act The Federal Water Pollution Control Act (33 U.S.C. 1251 et. sec.) as amended by the Federal Water Pollution Control Act Amendments of 1972, also known as the CWA, states that the discharge of pollutants to waters of the United States from any point source is unlawful, unless the discharge is in compliance with a National Pollutant Discharge Elimination System (NPDES) permit. Amendments to the CWA added a section that established a framework for regulating municipal and industrial (M&I) stormwater discharges under the NPDES program. On November 16, 1990, the U.S. Environmental Protection Agency (USEPA) published final regulations, under the 1987 CWA Amendments, that establish application requirements for stormwater permits. Clean Water Act Section 402 CWA Section 402 regulates discharges to surface waters of the United States through the NPDES program. In California, the USEPA authorizes the SWRCB to oversee the NPDES program through the Regional Water Quality Control Boards (RWQCBs). In September 2004, the RWQCB adopted Time Schedule Order No. R8-2004-0067, which requires the Sanitation District to achieve full secondary treatment by December 31, 2012. The Sanitation District has since carried out improvement projects of existing facilities and constructed new facilities to achieve secondary treatment standards by the year 2012 (RWQCB, 2004). Stormwater discharges are also regulated under CWA Section 402.Construction activities disturbing one acre of land or greater must be covered under the SWRCB General Construction Activity Stormwater Permit. The permit requires preparation of a Stormwater Pollution 1 Interfinger means to grade or pass from one material (typically fine-grained) into another (typically coarse-grained) through a series of interpenetrating wedge-shaped layers. This can result in hydraulic connection between fine and coarse grounded layers. LA County Flood Control District 3.8-25 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Prevention Plan (SWPPP) for construction activities. A SWPPP prepared in compliance with the General Permit describes the site, erosion and sediment controls, runoff water quality monitoring, means of waste disposal, implementation of approved local plans, control of post -construction sediment and erosion control measures and maintenance responsibilities, and non-stormwater management controls. Dischargers are also required to inspect construction sites before and after storms to identify stormwater discharge from construction activity, and to identify and implement controls where necessary. Clean Water Act Section 303(d) Section 303(d) of the CWA requires that each state identify water bodies or segments of water bodies that are "impaired" (i.e., do not meet one or more of the water quality standards established by the state). These waters are identified in the Section 303(d) list as waters that are polluted and need further attention to support their beneficial uses. Once the water body or segment is listed, the state is required to establish TMDL for the pollutant. A TMDL is the maximum amount of a pollutant that a water body can receive and still meet the water quality standards. Typically, TMDL is the sum of the allowable loads of a single pollutant from all contributing point and nonpoint sources. On October 11, 2011, the USEPA approved a revised list of water quality limited segments (herein referred to as the 303(d) list) prepared by the RWQCB for California's 2008 through 2010. Table 3.8-1 summarizes the main impaired water bodies within the study area that are included on the RWQCB 2008 CWA Section 303(d) list that was revised on July 7, 2009. Clean Water Act Section 401 Section 401 of the federal CWA requires that any activity, including the crossing of rivers or streams during road, pipeline, or transmission line construction, that might result in discharges of dredged or fill material into a state water body, be certified by the RWQCB. This certification ensures that the proposed activity does not violate state or federal water quality standards. Clean Water Act Section 404 Wetlands are generally considered to be areas that are periodically or permanently inundated by surface water or groundwater, and support vegetation adapted to life in saturated soil. Wetlands are recognized as important features on a regional and national level due to their high inherent value to fish and wildlife, use as storage areas for storm and floodwaters, and water recharge, filtration, and purification functions. Technical standards for delineating wetlands have been developed by the ACOE which generally defines wetlands through consideration of three criteria: hydrology, soils, and vegetation. Under Section 404 of the CWA, the ACOE is responsible for regulating the discharge of dredged or fill material into waters of the United States. The term "waters of the United States" includes wetlands and non -wetland bodies of water that meet specific criteria as defined in the Code of Federal Regulations. State Porter -Cologne Water Quality Act The Porter -Cologne Act (Division 7 of the California Water Code) provides the basis for water quality regulation within California and defines water quality objectives as the limits or levels of IA County Flood Control District 3.8-26 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources water constituents that are established for reasonable protection of beneficial uses. The SWRCB administers water rights, water pollution control, and water quality functions throughout the State, while the RWQCB conducts planning, permitting, and enforcement activities. The Porter - Cologne Act requires the RWQCB to establish water quality objectives, while acknowledging that water quality may be changed to some degree without unreasonably affecting beneficial uses. Beneficial uses, together with the corresponding water quality objectives, are defined as standards, per Federal regulations. Therefore, the regional plans form the regulatory standards for meeting State and federal requirements for water quality control. Changes in water quality are only allowed if the change is consistent with the maximum beneficial use designated by the State, does not unreasonably affect the present or anticipated beneficial uses, and does not result in water quality less than that prescribed in the water quality control plans. California Ocean Plan The SWRCB regulates water quality in the Pacific Ocean through regulatory standards and objectives outlined in the Water Quality Control Plan, Ocean Waters of California (commonly referred to the Ocean Plan) (SWRCB, 2012). The Ocean Plan identifies beneficial uses of ocean waters and provides water quality objectives that are protective of these uses. The plan provides objectives for bacteriological, physical, chemical, biological, and radioactive characteristics, as well as general requirements for the management of waste discharges to the Pacific Ocean. The USEPA relies upon the water quality objectives of the Ocean Plan for the purposes of regulating discharges from point sources that discharge into the Pacific (e.g. W WTP ocean outfalls) as well as the water quality of streams and channels that flow into the ocean. In 1974, the SWRCB designated 34 regions along the coast of California as Areas of Special Biological Significance (ASBS) under Resolution Number 74-28 (SWRCB, 1974a). These ASBS are "areas designated by the SWRCB as ocean areas requiring protection of species or biological communities to the extent that alteration of natural water quality is undesirable" (SWRCB, 2012b). A portion of the Pacific off of the North Santa Monica Bay coastline from Laguna Point to Latigo Point offshore is designated as ASBS 24. In March 2012, the SWRCB adopted the General Exception (SWRCB, 2012b), which exempts certain listed dischargers. The conditions in the General Exception are designed to protect beneficial uses of the receiving water, yet allow continuation of essential public services, such as flood control, slope stability, erosion prevention, maintenance of the natural hydrologic relationship between terrestrial and marine ecosystems, public health and safety, public recreation and coastal access, commercial and recreational fishing, navigation, and essential military operations (national security) (SWRCB, 2012b). The General Exception designates the LACFCD, the City of Malibu and the California Department of Transportation (Caltrans) as dischargers to ASBS 24, and the California The General Exception authorizes these dischargers to discharge into ASBS 24, provided that it: • Complies with the NPDES MS4 Permit. IA County Flood Control District 3.8-27 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources • Includes an ASBS Compliance Plan that shall be included as part of the Permittees' primary policy, planning, and implementation documents for municipal NPDES Stormwater Permit compliance. Proposed Trash Amendments to California Ocean Plan The SWRCB has proposed to amend the California Ocean Plan and the forthcoming Inland Surface Waters, Enclosed Bays, and Estuaries Plan to address trash in waterways, including waterways regulated by the Los Angeles County MS4 (SWRCB, 2014). The proposed Trash Amendments would be incorporated into the MS4 Permit and: • Establish a narrative water quality objective for trash. • Establish a prohibition of discharge of trash. • Provide implementation requirements for permitted stormwater dischargers and other discharges. • Set a time schedule for compliance. • Provide a framework for monitoring and reporting requirements. A central element of the proposed Trash Amendments is a compliance approach that utilizes land use to target high trash generating areas (priority land uses), such as high-density residential, industrial, and commercial, mixed urban, and public transportation land uses. Within this land use- based approach, the SWRCB proposes two alternative compliance tracks (i.e., the Permittee must choose to comply with one of the tracks). Under Track 1, a Permittee could elect to install a network of full capture systems in the storm drains located in priority land uses for MS4s and the entire facility for IGP/CGP. Under Track 2, a Permittee could use any combination of controls (structural and/or institutional), as long as they can demonstrate that the combination of controls performs as well as Track 1. The SWRCB can extend this deadline by up to three years if Permittees implement regulatory source controls, such as product bans. National Pollutant Discharge Elimination Program The NPDES permit program is administered in the State of California by the RWQCBs, and was first established under the authority of the CWA to control water pollution by regulating point sources that discharge pollutants into waters of the United States. If discharges from industrial, municipal, and other facilities go directly to surface waters, those project applicants must obtain permits. An individual NPDES permit is specifically tailored to a facility. A general NPDES permit covers multiple facilities within a specific activity category such as construction activities. A general permit applies with same or similar conditions to all dischargers covered under the general permit. General Dewatering Permit The SWRCB also has issued General Waste Discharge Requirements (WDRs) under Order No. R8-2003-0061, NPDES No. CAG 998001 (Dewatering General Permit) governing non- storrnwater construction -related discharges from activities such as dewatering, water line testing, and sprinkler system testing. The discharge requirements include provisions mandating notification, testing, and reporting of dewatering and testing -related discharges. The General IA County Flood Control District 3.8-28 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources WDRs authorize such construction -related discharges so long as all conditions of the permit are fulfilled. Construction General Permit The Construction General Permit (CGP) requires the development and implementation of an SWPPP that includes specific BMPs designed to prevent pollutants from contacting stormwater and keep all products of erosion from moving off-site into receiving waters. The SWPPP BMPs are intended to protect surface water quality by preventing the off-site migration of eroded soil and construction -related pollutants from the construction area. Routine inspection of all BMPs is required under the provisions of the CGP. In addition, the SWPPP is required to contain a visual monitoring program, a chemical monitoring program for nonvisible pollutants, and a sediment monitoring plan if the site discharges directly to a water body listed on the 303(d) list for sediment. In the project area, the CGP is implemented and enforced by the Los Angeles Regional Water Quality Control Board (LARWQCB), which administers the stormwater permitting program. Dischargers are required to electronically submit a Notice of Intent (NOI) and permit registration documents (PRDs) to obtain coverage under this CGP. Dischargers are responsible for notifying the LARWQCB of violations or incidents of noncompliance, as well as for submitting annual reports identifying deficiencies of the BMPs and how the deficiencies were corrected. Municipal Stormwater Permitting (MS4) The State's Municipal Stormwater Permitting Program regulates stormwater discharges from Municipal Separate Storm Sewer Systems (MS4s). MS4 Permits were issued in two phases. Phase I was initiated in 1990, under which the RWQCBs adopted NPDES stormwater permits for medium (serving between 100,000 and 250,000 people) and large (serving more than 250,000 people) municipalities. As part of the Phase II, the SWRCB adopted a General Permit for small MS4s (serving less than 100,000 people) and non-traditional small MS4s including governmental facilities such as military bases, public campuses, and hospital complexes. The Permittees' 2012 MS4 Permit (Order No. R4-2012-0175; NPDES Permit No. CAS004001) requires Permittees to develop Enhanced Watershed Management Plans to ensure they are not causing or contributing to exceedances of water quality objectives or impairments of beneficial uses in the receiving waters of the Los Angeles region. The EWMPs are the subject of this PEIR. Local Regulations Los Angeles Regional Water Quality Control Plan The preparation and adoption of water quality control plans (Basin Plans) is required by the California Water Code (Section 13240) and supported by the CWA. Section 303 of the CWA requires states to adopt water quality standards which "consist of the designated uses of the navigable waters involved and the water quality criteria for such waters based upon such uses." According to Section 13050 of the California Water Code, Basin Plans consist of a designation or establishment for the waters within a specified area of beneficial uses to be protected, water quality objectives to protect those uses, and a program of implementation needed for achieving the objectives. Because beneficial uses, together with their corresponding water quality objectives, can a County Flood Control District 3.8-29 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources be defined per Federal regulations as water quality standards, the Basin Plans are regulatory references for meeting the State and Federal requirements for water quality control. Beneficial uses for water bodies in the EWMP Areas are summarized in Appendix F. County of Los Angeles Stormwater Pollution Control Requirements for Construction Activities To comply with the Phase II General Construction Permit, the County of LA has established a set of BMPs with which all permitted construction activities on unincorporated county lands must comply. The BMPs, which are based on the state's Stormwater Best Management Practices Handbook (2003), are as follows: • Eroded sediments and other pollutants must be retained on site and may not be transported from the site via sheetflow, swales, area drains, natural drainage courses or wind. • Stockpiles of earth and other construction related materials must be protected from being transported from the site by the forces of wind or water. • Fuels, oils, solvents and other toxic materials must be stored in accordance with their listing and are not to contaminate the soil and surface waters. All approved storage containers are to be protected from the weather. Spills must be cleaned up immediately and disposed of in a proper manner. Spills may not be washed into the drainage system. • Non-stormwater runoff from equipment and vehicle washing and any other activity shall be contained at the project site. • Excess or waste concrete may not be washed into the public way or any other drainage system. Provisions shall be made to retain concrete wastes on site until they can be disposed of as solid waste. • Trash and construction related solid wastes must be deposited into a covered receptacle to prevent contamination of rainwater and dispersal by wind. • Sediments and other materials may not be tracked from the site by vehicle traffic. The construction entrance roadways must be stabilized so as to inhibit sediments from being deposited into the public way. Accidental depositions must be swept up immediately and may not be washed down by rain or other means. • Any slopes with disturbed soils or denuded of vegetation must be stabilized so as to inhibit erosion by wind and water. The Los Angeles County Department of Public Works may identify and require additional BMPs, as appropriate. City of Los Angeles Development Construction Model Program The City of LA's Development Construction Model Program addresses NPDES Phase II requirements on construction sites within incorporated City lands. BMPs for construction (as well as source control and treatment) are detailed in the City's Reference Guide for Stormwater Best Practices (LADPW, 2000). The BMPs are consistent with those developed by the state and IA County Flood Control District 3.8-30 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources county, and include erosion and sedimentation control measures, site management practices, materials and waste management, and general preventive maintenance and inspection. Stormwater Pollution Control Requirements for Other Cities in the County of Los Angeles Other cities within the County also have stormwater pollution control requirements and associated BMPs; their content is similar to those described in this section for the County and City of Los Angeles. County of Los Angeles Low Impact Development Manual The County of Los Angeles (County) prepared the 2014 Low Impact Development Standards Manual (LID Standards Manual, County of Los Angeles, 2014b) to comply with the requirements of the 2012 MS4 Permit. The LID Standards Manual provides guidance for the implementation of stormwater quality control measures in new development and redevelopment projects in unincorporated areas of the County with the intention of improving water quality and mitigating potential water quality impacts from stormwater and non-stormwater discharges. The LID Standards Manual addresses the following objectives and goals: • Lessen the adverse impacts of stormwater runoff from development and urban runoff on natural drainage systems, receiving waters, and other water bodies. • Minimize pollutant loadings from impervious surfaces by requiring development projects to incorporate properly -designed, technically -appropriate BMPs and other LID strategies. • Minimize erosion and other hydrologic impacts on natural drainage systems by requiring development projects to incorporate properly -designed, technically appropriate hydromodification control development principles and technologies. City of Los Angeles Low Impact Development Manual In November 2011, the City of Los Angeles adopted the Stormwater Low Impact Development Ordinance #181899 with the stated purpose of: • Requiring the use of LID standards and practices in future developments and redevelopments to encourage the beneficial use of rainwater and urban runoff • Reducing stormwater/urban runoff while improving water quality • Promoting rainwater harvesting • Reducing off-site runoff and providing increased groundwater recharge • Reducing erosion and hydrologic impacts downstream • Enhancing the recreational and aesthetic values in our communities The City of Los Angeles institutionalized the use of LID techniques for development and redevelopment projects. Subsequent to the adoption of the Stormwater LID Ordinance, the City prepared the Development Best Management Practices Handbook, Low Impact Development Manual, dated June 2011, to describes the required BMPs (City of Los Angeles, 2011). a County Flood Control District 3.8-31 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Low Impact Development Manuals for Other Cities in the County of Los Angeles Some of the other cities within the County also have LID ordinances and manuals. Their content is similar to the LID manuals described in this section for the County and City of Los Angeles. City General Plans The numerous cities encompassed by the EWMP project area all have their own respective city General Plans, some of which may contain policies that address water quality and hydrology. As implementation of the individual structural BMP projects proceed, specific policies and objectives pertaining to water quality and hydrology from applicable city General Plans will be identified and evaluated on a project -by -project basis during subsequent California Environmental Quality Act (CEQA) environmental processes. 3.8.3 Impact Analysis The proposed project's potential impacts were assessed using the California Environmental Quality Act (CEQA) Guidelines Appendix G Checklist. The following sections discuss the key issue areas identified in the CEQA Guidelines with respect to the project's potential hydrology and water quality impacts. Thresholds of Significance For the purposes of this PEIR and consistency with Appendix G of the CEQA Guidelines, applicable local plans, and agency and professional standards, the project would have a significant impact on aesthetic resources if it would: • Violate any water quality standards or waste discharge requirements. • Otherwise substantially degrade water quality. • Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted). • Substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river, or by other means, in a manner that would result in substantial erosion or siltation on- or off-site. • Substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river or, by other means, substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site. • Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. IA County Flood Control District 3.8-32 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources • Place housing within a 100 -year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other authoritative flood hazard delineation map. • Place within a 100 -year flood hazard area structures that would impede or redirect flood flows. • Expose people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam. • Expose people or structures to a significant risk of loss, injury, or death involving inundation by seiche, tsunami, or mudflow. Program Impact Discussion Water Quality Standards, Waste Discharge Requirements, and Further Degradation of Water Quality Impact 3.8-1: The proposed project would violate water quality standards or waste discharge requirements or further degrade water quality. Structural (Regional, Centralized, and Distributed) BMPs Construction Construction, demolition, and renovation activities associated with the installation of some BMPs, particularly larger centralized and regional BMPs, could lead to ground disturbance and polluted runoff. However, as described above, the NPDES CGP requires that any actions that disturb an acre or more of ground must develop an SWPPP to prevent the transport of polluted runoff. SWPPPs will most likely be necessary for the construction of regional and centralized BMPs, particularly those that are larger, multi -benefit projects such as greenway redevelopments. Projects under an acre in size, which will include most distributed BMPs, must comply with NPDES Phase II requirements and incorporate construction BMPs mandated by the jurisdiction within which the project falls. Compliance with the CGP would ensure that the construction of BMPs would have no temporary or permanent impact to water quality. Operation The structural BMPs are designed to reduce the transport of pollutants in stormwater, thereby helping Permittees improve water quality. The EWMP structural BMPs that have stormwater retention and infiltration as a function are designed to reverse the impacts from urbanization on the natural hydrograph and water quality. The widespread implementation of distributed BMPs with these functions in urban areas of all the EWMP groups will significantly reduce stormwater flow volumes and pollutant loading to creeks and rivers. The increased infiltration of stormwater from the widespread implementation of these projects will have the effect of increasing recharge to the groundwater, reducing peak storm flows and altering the hydrograph toward more natural conditions. By retaining stormwater flows and either infiltrating or releasing these flows closer to the natural conditions, the stream hydrographs will be less impacted by the urbanization. The increase in infiltration of stormwater from these BMPs will also raise groundwater levels and increase groundwater seepage to creeks and rivers following storm events. Runoff reduction measures and LFDs under the EWMP will significantly reduce dry -weather "nuisance" flows that have altered formerly ephemeral systems to perennial creeks and streams. a County Flood Control District 3.8-33 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Distributed BMPs, although on a smaller parcel or site scale, would also be designed to collect and treat stormwater to reduce the loading of the smaller amounts of contaminants transported by their relatively smaller receiving areas. This would reduce contaminant loading to receiving waters compared with existing conditions while capturing contaminants in filter media. The vegetation and microbial activity in soil would work to biodegrade the typical fuels, oil, and grease in local urban runoff. As discussed in the Project Description (Section 2.0), the identification of water quality priorities is required in Section VI.C.5.a of the MS4 permit as part of EWMP development. Appendix F provides a listing of the water quality priorities for each EWMP. As highlighted in this prioritization process, pollutants under a TMDL have higher priority and will be addressed under the timelines defined in the TMDLs. This highlights that the EWMP is a continuation of water quality improvement efforts by the Permittees under existing TMDLs through adopted TMDL Implementation Plans. BMP types that are assessed in this PEIR therefore include BMPs under various stages of implementation and planning to meet TMDL waste load allocations. Once constructed, the structural BMPs would provide source control treatment of stormwater runoff prior to discharge to receiving waters whether on a site-specific (distributed structural BMPs), local (centralized structural BMPs), or regional (regional structural BMPs) basis. These structural BMPs would provide improved water quality through infiltration and treatment (e.g., filtration, settling, sedimentation, sorption, straining, and biological or chemical transformations) that would minimize the off-site transport of typical urban runoff pollutants. Implementation of the proposed BMPs would have no adverse impacts to surface water quality. Mitigation Measures: None required Significance Determination: Less than significant impact Non -Structural (Institutional) BMPs Non-structural BMPs policies, actions, and activities intended to prevent pollutants from entering stomwater runoff, thus eliminating the source of the pollutants. These BMPs would not involve any earthwork disturbance or construction activities, and similar to the Structural BMPs, once implemented, would aid in minimizing off-site discharge of urban runoff pollutants. As a result, they would have no adverse impact on water quality standards or waste discharge requirements. Mitigation Measures: None required Significance Determination: No impact Groundwater Impact 3.8-2: The proposed project would result in higher groundwater levels and could potentially affect groundwater quality, IA County Flood Control District 3.8-34 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Structural (Regional, Centralized, and Distributed) BMPs Water Levels Regional BMPs would recharge stormwater into the groundwater basin and could raise local groundwater levels following major storm events. Distributed infiltration BMPs would typically be too small to have a measureable effect on local groundwater levels. Groundwater basins in southern Los Angeles County are adjudicated and managed for beneficial uses. Increased capture of stormwater is a key element to integrated water supply planning in Southern California. The increased water supplies captured by the infiltration basins through the EWMP areas would be a beneficial impact of the projects. In areas with shallow groundwater tables or impermeable soils, recharge could result in mounding that affects subsurface infrastructure such as building or bridge foundations. This would be a potential impact of regional BMPs that recharge large volumes of captured stormwater, but could also occur for distributed BMPs in areas with limited permeability. For example, the EWMP Areas of Malibu Creek, Northern Santa Monica Bay, and Palos Verdes are located in areas where no significant groundwater basin occurs. In addition, the West Coast Basin consists of a series of aquitards near the surface that prevent surface water percolation into the productive aquifers. Infiltration BMPs in these areas would result in shallow infiltration followed by lateral movement and seepage to nearby areas that could include creek cuts, areas of lower elevation, or basements and underground vaults. Mitigation Measure HYDRO -1 requires Permittees to evaluate the suitability of BMP locations for groundwater recharge. Infiltration BMPs would not be suitable in areas of low permeability where subsurface structures could be adversely affected by groundwater mounding. Groundwater Quality Infiltration of stormwater runoff could increase contaminant loading in shallow soils and groundwater. Some contaminants found in stormwater runoff (e.g., oil, grease, metals) adsorb onto surficial soils and remain within a few feet of the surface, while other more soluble contaminants (e.g., fuels, nitrate, phosphate) may be entrained to deeper soils or migrate all the way to the groundwater. Over a long period of time, concentrations of these contaminants could increase resulting in contaminated soils and groundwater. Pre-treatment of source water in areas with the potential for heavy contaminant loading would be implemented as a required design feature for regional and centralized BMPs to assist in reducing long-term loading. In addition, non-structural source control BMPs would help reduce contaminant loading over time. The LID standards for the County of Los Angeles and the various cities participating in the EWMP provide protocols for designing regional and centralized BMPs that minimize the potential for contaminant loading. Compliance with these protocols and implementation of Mitigation Measure HYDRO -2 which would require the implementing agencies to evaluate the need for pretreatment at each infiltration BMP, impacts to groundwater quality would be less than significant. Proposed projects that recharge the shallow aquifers have the potential to mobilize shallow contamination and alter groundwater flow directions. Within the urbanized areas of the County, legacy groundwater contamination is prevalent resulting from overlying uses such as industrial operations and underground storage of fuels. A few major contamination areas have rendered the a County Flood Control District 3.8-35 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources groundwater basins unusable for potable uses. In particular, groundwater contamination plumes exist in the southeast corner of the San Fernando Groundwater Basin, the Main San Gabriel Basin, and the East Subbasin in Santa Clarita. Each of these areas are undergoing remedial actions to improve groundwater quality. The infiltration of large volumes of water in certain areas could modify these existing contaminant plumes. If these infiltration facilities were located over contaminated groundwater plumes, groundwater flow patterns could be modified such that contaminated groundwater migrates into areas that are not currently contaminated or pushed away from existing treatment systems. Mitigation Measure HYDRO -3 would require that infiltration BMPs would be required to evaluate site conditions and the existence of contaminated groundwater plumes during planning stages prior to construction of infiltration galleries, trenches, and basins. Mitigation Measures: HYDRO -1: Prior to approving an infiltration BMP, the Permittee shall conduct an evaluation of the suitability of the BMP location. Appropriate infiltration BMP sites should avoid areas with low permeability where recharge could adversely affect neighboring subsurface infrastructure. HYDRO -2: Prior to approving an infiltration BMP, the Permittee shall identify pretreatment technologies, type, and depth of filtration media; depth to groundwater; and other design considerations necessary to prevent contaminants from impacting groundwater quality. The design shall consider storrnwater quality data within the BMP's collection area to assess the need and type of treatment and filtration controls. Local design manuals and ordinances requiring minimum separation distance to groundwater shall also be met as part of the design. HYDRO -3: Prior to the installation of an infiltration BMP, the Permittee shall conduct a database review for contaminated groundwater sites within a quarter mile of the proposed infiltration facility. The Permittee shall identify whether any contaminated groundwater plumes are present and whether coordination with the local and state environmental protection overseeing agency and responsible party is warranted prior to final design of infiltration facility. Significance Determination: Less than significant with mitigation (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.8- 3.) Non -Structural (Institutional) BMPs Non-structural BMPs policies, actions, and activities are primarily intended to prevent pollutants from entering stormwater runoff, thus eliminating the source of the pollutants. However, within Planning and Land Use Programs, there would be encouragement for implementation of LID strategies which not only improve water quality but also include on-site infiltration which can increase groundwater levels. Most non-structural institutional BMPs are implemented to meet IA County Flood Control District 3.8-36 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Minimum Control Measure (MCM) requirements in the MS4 permit. As discussed above, increased infiltration from local LID drainage features are not as likely to result in substantive increases in groundwater levels and therefore would have a less than significant impact on groundwater supplies. Mitigation Measures: None required Significance Determination: Less than significant Drainage Pattern Alteration Resulting in Erosion or Siltation Impact 3.8-3: The proposed project could substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river, or by other means, in a manner that would result in substantial erosion or siltation on- or off-site, Structural (Regional, Centralized, and Distributed) BMPs The proposed structural BMPs would be designed to minimize off-site discharge of urban runoff pollutants including siltation and sedimentation. Many of the structural BMPs would include on- site infiltration of stormwater runoff which would also be effective in minimizing erosion or transport of sedimentation into receiving waters. Through increased infiltration prior to discharge into receiving waters, flows within existing streams or rivers would receive reduced stormwater flow volumes thereby decreasing flow energies. As a result, the potential for erosion or siltation within existing streams or rivers would be reduced and the potential impact less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs Non-structural BMPs policies, actions, and activities are primarily intended to prevent pollutants from entering stormwater runoff largely through the use of drainage features that either infiltrate or detain stormwater runoff on-site. Drainage patterns would change through implementation of these non-structural institutional BMPs that are implemented to meet Minimum Control Measure (MCM) requirements in the MS4 permit. MCMs are considered a subset of institutional BMPs. These BMPs are not constructed, but within Planning and Land Use policies there would be encouragement for implementation of LID strategies which include on-site infiltration and/or detaining peak flows that would minimize off-site flows as well as the potential for erosion and off-site siltation. As discussed previously, increased infiltration from local LID drainage features minimize the potential for erosion and therefore there would be a less than significant impact related to erosion and siltation. Mitigation Measures: None required Significance Determination: Less than significant a County Flood Control District 3.8-37 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Drainage Pattern Alteration Resulting in Flooding Impact 3.8-4: The project could substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river or, by other means, substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site. Structural (Regional, Centralized, and Distributed) BMPs The proposed structural BMPs include features that would increase stormwater retention and encourage on-site infiltration to reverse the impacts from urbanization on the natural hydrograph. The widespread implementation of distributed BMPs with these functions in urban areas of all the EWMP groups will significantly reduce stormwater flow volumes especially during peak storm flow events as indicated by the figure shown in Impact 3.8-3. Larger retention and infiltration regional and centralized BMPs will also have a beneficial effect on regional hydrology through delayed discharge to avoid the spike in peak flows currently experienced. By retaining stormwater flows and either infiltrating or releasing these flows closer to the natural hydrograph, the change in drainage patterns would result in reduced peak flows and as a result a reduced potential for flooding on- or off-site. Therefore, the potential impact would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs Non-structural BMPs policies, actions, and activities are primarily intended to prevent pollutants from entering stormwater runoff and include drainage features that infiltrate or detain storrnwater runoff on-site. Drainage patterns would change through implementation of these non-structural institutional BMPs, however implementation of LID strategies which include on-site infiltration that would minimize off-site flows as well as the potential for erosion and off-site siltation. As discussed above, increased infiltration from local LID drainage features are minimize the potential for erosion and therefore would be a less than significant impact. Mitigation Measures: None required Significance Determination: Less than significant Stormwater Drainage Systems Impact 3.8-5: The proposed project could create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. IA County Flood Control District 3.8-38 ESA / 140379 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Structural (Regional, Centralized, and Distributed) BMPs The proposed structural BMPs whether regional, centralized or distributed would have an overall effect of reducing off-site stormwater flows through on-site infiltration and detention. As a result of having a net effect of reducing stormwater runoff volumes, there would be a less -than - significant effect on the capacity of existing or planned stormwater drainage systems. The structural BMPs would also provide improvements to water quality of receiving waters as that is the primary purpose of these BMPs and have proven effective in reducing potential sources of polluted runoff for a less than significant impact. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs The non-structural BMPs would similarly provide the policies, actions, and activities to encourage the use of drainage features that either infiltrate or detain stormwater runoff on-site. Drainage patterns would change through implementation of these non-structural institutional BMPs but would be designed to improve water quality and reduce stormwater flow volumes. Therefore, the potential impact to the capacity of drainage systems would be less than significant as well as the potential to provide additional sources of polluted runoff. Mitigation Measures: None required Significance Determination: Less than significant Flood Hazards: Housing Impact 3.8-6: The project could place housing within a 100 -year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other authoritative flood hazard delineation map. Structural (Regional, Centralized, and Distributed) BMPs The proposed structural BMPs would not include the construction of any housing and therefore there would be no impact related to placement of housing in a flood hazard area. Mitigation Measures: None required Significance Determination: No impact Non -Structural (Institutional) BMPs Similar to above, the non-structural BMPs would not include the construction of any housing and therefore there would be no impact related to placement of housing in a flood hazard area. Mitigation Measures: None required Significance Determination: No impact a County Flood Control District 3.8-39 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Flood Hazards: Structures Impact 3.8-7: The project could place within a 100 -year flood hazard area structures that would impede or redirect flood flows. Structural (Regional, Centralized, and Distributed) BMPs In general, the majority of the structural BMPs would consist of either features with a very low profile in terms of having any effect on flood flows (e.g., drainage swales, infiltration trenches, galleries, ponds, planter boxes and pervious pavement) or features that are subterranean (e.g., cisterns, detention basins, dry wells). However, structural BMPs could include above ground detention basins. Above ground detention basins would be required to adhere to any local flood zone construction permitting requirements such that they would not be impede or redirect flood flows. As a result, the impact of structural BMPs would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs Non-structural BMPs would not include the construction of any structures and therefore there would be no impact related to impeding or redirecting flood flows. Mitigation Measures: None required Significance Determination: No impact Flood Hazards: Levee or Dam Failure Impact 3.8-8: The proposed project could expose structures to a significant risk of loss, including flooding as a result of the failure of a levee or dam, Structural (Regional, Centralized, and Distributed) BMPs The majority of the structural BMPs would consist of features with a very low profile and would be designed to aid in the conveyance of runoff and high flows. Structural BMPs could also include above ground detention basins. Above ground detention basins would not be staffed and not likely to be susceptible to substantive damage in the event of a catastrophic failure of a levee or dam based on the general characteristics of how above ground detention basins are constructed. As a result, the impact of structural BMPs would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant IA County Flood Control District 3.840 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources Non -Structural (Institutional) BMPs Non-structural BMPs would not include the construction of any structures and therefore there would be no impact related to failure of a levee or dam. Mitigation Measures: None required Significance Determination: No Impact Tsunami, Seiche or Mudflow Impact 3.8-9: The proposed project could place structures in areas subject to inundation by seiche, tsunami, or mudflow. Structural (Regional, Centralized, and Distributed) BMPs The project area includes coastal areas and areas that are adjacent to enclosed bodies of water that could be subject to seiche, tsunami, or mudflow. As described above the majority of these BMP facilities consist of either subterranean improvements or low profile features that are generally not considered susceptible to substantive damage from these hazards. Larger above ground improvements such as centralized or regional detention basins, could be located in areas that are within seiche, tsunami, or mudflow hazard areas. However, these structures would not be staffed and any potential damage that they might incur would likely be relatively easily repaired. As a result, the potential impact to structures subject to inundation by seiche, tsunami, or mudflow would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs Non-structural BMPs would not include the construction of any structures and therefore there would be no impact related to inundation by seiche, tsunami, or mudflow. Mitigation Measures: None required Significance Determination: No impact Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs The EWMPs span numerous watersheds within Los Angeles County. Implementation of the proposed structural BMPs, together with past, present, and other reasonably foreseeable future projects across the different watersheds of the region would result in improved stormwater quality and reduced non storm flows. As BMPs are incrementally installed, the Los Angeles region will experience reduced dry -weather runoff, a more natural hydrology, and improved receiving water a County Flood Control District 3.841 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources quality. In addition, new infiltration projects will incrementally augment groundwater drinking water supplies. Although the increased infiltration projects may increase pollutant loads to groundwater aquifers, pretreatment systems coupled with regional groundwater management lead by the local Watermasters will ensure that the beneficial uses of groundwater basins are not significantly impaired. Implementation of the EWMPs will beneficially impact local surface water quality and groundwater supplies. Mitigation Measures: None required Significance Determination: Less than significant IA County Flood Control District 3.8-42 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.8 Hydrological Resources 308.4 Summary of Impact Assessment Table 3.8-3 on the following page shows a summary of the structural BMPs requiring mitigation TABLE 3.8.3 SUMMARY OF HYDROLOGICAL RESOURCE IMPACTS REQUIRING MITIGATION MEASURES Regional BMPs Thresholds of Significance Regional Detention and No Yes No Surface No No Storm Infiltration Tsunami, Water Drain Flood Seiche, Cumulative Structural BMPs Quality Groundwater Erosion System Hazards Mudflows Impacts Centralized BMP HYDRO -1; Bioinfiltration No Yes Applicable None HYDRO -2; None None None None None Mitigation Measures: Required HYDRO -3 Required Required Required Required Required Regional BMPs Regional Detention and No Yes No No No No No Infiltration Regional Capture, No Yes No No No No No Detention and Use Centralized BMP Bioinfiltration No Yes No No No No No Constructed Wetlands No Yes No No No No No Treatment/LFDs No Yes No No No No No Creek, River, Estuary No Yes No No No No No Restoration Distributed BMPs Site Scale Detention No Yes No No No No No LID— No Yes No No No No No I of Itration/Filtration BMPs — Porous Pavement, Green Streets, Bioswale/Filter Strips, downspout disconnects LID — Green No No No No No No No Infrastructure — Capture and Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes Flow-through Treatment No No No No No No No BMPs Source Control No No No No No No No Treatment BMPs (catch basin inserts/screens, hydrodynamic separators, gross solids removal devices) Low -Flow Diversions No No No No No No No NOTE: These conclusions are based on typical size and locations of BMPs. IA County Flood Control District 3.843 ESA / 140379 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture This section describes and discusses existing land uses and agricultural resources that may be affected by the proposed program in the Enhanced Watershed Management Program (EWMP) areas of Los Angeles County (County) and considers the compatibility of the proposed program with relevant land use plans and policies. The analysis identifies potential impacts that may result from implementing the proposed program and evaluates their significance. Applicable plans and policies related to land use and agriculture are presented and potential impacts and mitigation measures, if needed, are identified. 3.9.1 Environmental Setting Regional Setting The proposed program is located in Los Angeles County, which covers an area of about 4,083 square miles and comprises 88 cities and approximately 2,650 square miles of unincorporated areas. The majority of the County is highly urbanized and consists of several cities, communities and unincorporated areas. The proposed projects are located in multiple jurisdictions of Los Angeles County; these include Los Angeles County Flood Control District (LACFCD), the County of Los Angeles, and the following cities: Los Angeles, Beverly Hills, Culver City, Inglewood, Santa Monica, West Hollywood, Hawthorne, El Segundo, Lomita, Baldwin Park, Covina, Glendora, Industry, La Puente, Malibu, Calabasas, Agoura Hills, Westlake Village, Hidden Hills, Santa Clarita, Rancho Palos Verdes, Palos Verdes Estates, Rolling Hills Estates, Redondo Beach, Hermosa Beach, Torrance, Manhattan Beach, Arcadia, Azusa, Bradbury, Duarte, Monrovia, Sierra Madre, Alhambra, Burbank, Glendale, Hidden Hills, La Canada Flintridge, Montebello, Monterey Park, Pasadena, Rosemead, San Gabriel, San Marino, South Pasadena, and Temple City (see Figure 1-1). Each of these jurisdictions have independent planning documents that guide the development of urban, agricultural, and other land uses within their jurisdictional boundaries. Existing Land Use Characterization Land uses within the County are widely varied and include open space, residential, commercial, mixed-use, public and semi-public, and industrial land uses. The proposed program would be located in various watersheds across Los Angeles County that span multiple jurisdictions with varying land use regulations. The existing land uses within each watershed are summarized in this section by EWMP group and are based upon information from the Southern California Association of Government (SCAG) and the EWMP Work Plans. The EWMP agencies have no jurisdiction over the land that is owned by the State of California (i.e., California Department of Fish and Wildlife, the State Lands Commission, and the California Department of Transportation) or the U.S. Government. a County Flood Control District 3.9-1 ESA 1140494 Enhanced Watershed Management Programs January 2015 Dreg Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Ballona Creek The Ballona Creek EWMP area covers the Ballona Creek Watershed. The Permittees within this EWMP are: the Cities of Beverly Hills, West Hollywood, Los Angeles, Inglewood, Culver City, Santa Monica; the County of Los Angeles; and LACFCD. The Ballona Creek Watershed comprises the cities of Beverly Hills, Culver City, and West Hollywood and parts of Inglewood, Los Angeles and Santa Monica as well as small unincorporated areas of Los Angeles County. Collectively, the Municipal Separate Stormwater Sewer Systems (MS4) Permittees in the Ballona Creek Watershed have jurisdiction over 123 square miles or 96 percent of the total watershed area. A breakdown of areas by MS4 Permittees is provided in Table 3.9-1. 1/_1:1111411 IIII :El IINL/etyOki 44:S4VEN1:1 b1:IgDJli!IDY.-IN:F_\r1611Oki 1:1111P72 Agency Land Area (Acres) Percent of EWMP Area City of Los Angeles 65,272.89 83.21% County of Los Angeles 3,164.76 4.03% City of Beverly Hills 3,618.95 4.61% City of Culver City 3,125.00 3.98% City of Inglewood 1,907.72 2.43% City of West Hollywood 1,135.00 1.45% City of Santa Monica 217.31 0.28% Total 78,441.63 100.00% SOURCE: Ballona Creek EWMP Work Plan, 2014. The population in the Ballona Creek Watershed is approximately 1.6 million people (LADPW, 2004). The predominant land use in the Ballona Creek Watershed is residential, representing 63.7 percent of the total land area, including multi -family residential uses covering 18 percent of the area. Although open space areas represent 16.7 percent, this category may include parks and other open areas not generally open to the public, including vacant land and golf courses (LADPW, 2004). Commercial, public, light industrial, other urban and unknown land uses represents 19.6 percent of the total land area. Figure 3.9-1 shows land uses in the Ballona Creek Watershed and the location of planned and priority regional/centralized Best Management Practices (BMPs). The location of distributed BMPs would be throughout the urbanized areas of the watershed. a County Flood Control District 3.9-2 ESA 1140474 Enhanced Watershed Management Programs January 2015 Dreg Program Environmental Impact Report Single -Family Residential Multi -Family Residential Other Residential - General Office _ Commercial and Services Facilities Education - Military Installations _ Industrial Transportation, Communications, and Utilities Mixed Commercial and Industrial _ Mixed Urban Open Space and Recreation _ Agriculture Vacant Water - Under Construction Potential Distributed BMP not shown - predon SOURCE: ESRI; SCAG RLY — \ RILLS • LO® NGELES • • 7 VTA MONICA �� • areas Ballon Creek WMG Q Participating Permittees • Potential BMPs (Regional and Centralized)` 3T HOLLYWOOD R Is _ SANGE 5 1 • �H T 0 2 I I Miles LA County PEIR EWMP . 140474 Figure 3.9-1 Land Use in the Ballona Creek Watershed Management Group 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Beach Cities The Beach Cities EWMP area covers portions of two watersheds: Santa Monica Bay Watershed (Jurisdictional Group [JG] 5 and JG6) and the Dominguez Channel Watershed. The Permittees within this EWMP are: the Cities of Redondo Beach, Manhattan Beach, Hermosa Beach, and Torrance; and the LACFCD. Figure 3.9-2 shows land uses in the Beach Cities EWMP area and the location of planned and priority regional/centralized BMPs. The location of distributed BMPs would be throughout the urbanized areas of the watershed. The western portion of the Beach Cities EWMP area consists of approximately 7,840 acres of land that drains to Santa Monica Bay. This accounts for 38.4 percent of the total Beach Cities Watershed Management Group area, and includes portions of the cities of Manhattan Beach, Redondo Beach, and Torrance and the entirety of the City of Hermosa Beach. The northeastern portion of the Beach Cities EWMP area is tributary to Dominguez Channel (including the Torrance Carson Channel) and comprises approximately 7,380 acres of land. This watershed accounts for 36.1 percent of the total Beach Cities EWMP area, and includes portions of the cities of Manhattan Beach, Redondo Beach, and Torrance. Storm drains from the Cities of Manhattan Beach and Redondo Beach drain through the City of Lawndale before discharging to Dominguez Channel. Torrance's MS4 discharges directly to the Dominguez Channel and Torrance Carson Channel (Torrance Lateral). The southeastern portion of the Beach Cities EWMP area is tributary to Machado Lake (including Wilmington Drain) and comprises approximately 5,182 acres of land. This watershed accounts for 25.5 percent of the total Beach Cities EWMP area. All but 1.2 acres (0.02 percent) of this area is within the City of Torrance. The City of Redondo Beach owns the remainder of the area, though no Redondo Beach catch basins or MS4 are tributary to Machado Lake. LACFCD is not responsible for land within the Beach Cities EWMP area, but does own and maintain infrastructure within all three watersheds. A breakdown of areas by MS4 Permittee is provided in Table 3.9-2. TABLE 3.9-2 BEACH CITIES WATERSHED LAND AREA DISTRIBUTION Dominguez Machado Agency SMB Watershed (acres) Channel Watershed (acres) Lake Watershed (acres) Total EWMP Area (acres) Percent of EWMP Area Redondo Beach 2,614 1,217 1 3,832 19% Manhattan Beach 2,078 350 - 2,428 12% Hermosa Beach 832 - - 832 4% City of Torrance 2,314 5,812 5,181 13,307 65% Total 7,837 77379 5,782 20,399 100% SOURCE: Beach Cities EWMP Work Plan, 2014. a County Flood Control District 3.9-4 ESA 1140474 Enhanced Watershed Management Programs January 2015 Dreg Program Environmental Impact Report Pacific Ocea O Beach Cities WMG Q Participating Permittees Transportation, Communications, and Utilities Mixed Commercial and Industrial Mixed Urban Open Space and Recreation Agriculture Vacant Water Under Construction SOURCE: ESRI; SCAG itralized)' T o t I I Miles LA County PEIR EWMP. 140474 Figure 3.9-2 Land Uses in the Beach Cities Watershed Management Group Single -Family ResidentiE Multi -Family Residential Other Residential General Office Commercial and Service Facilities Education - Military Installations Industrial O Beach Cities WMG Q Participating Permittees Transportation, Communications, and Utilities Mixed Commercial and Industrial Mixed Urban Open Space and Recreation Agriculture Vacant Water Under Construction SOURCE: ESRI; SCAG itralized)' T o t I I Miles LA County PEIR EWMP. 140474 Figure 3.9-2 Land Uses in the Beach Cities Watershed Management Group 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Dominguez Channel The Dominguez Channel EWMP area covers portions of the Dominguez Channel Watershed and the Machado Lake and the Los Angeles/Long Beach Harbor subwatersheds. The Dominguez Channel EWMP addresses approximately 36,410 acres, or 47.45 percent of the total 133 -square - mile watershed. The Permittees within this EWMP are: the Cities of El Segundo, Hawthorne, Inglewood, Lomita, and Los Angeles; the County of Los Angeles; and the LACFCD. A breakdown of areas by MS4 Permittee and other agencies is provided in Table 3.9-3. Figure 3.9- 3 shows land use in the Dominguez Channel EWMP area and the location of planned and priority regional/centralized BMPs. The location of distributed BMPs would be throughout the urbanized areas of the watershed. Table 3.9-4 provides the land use breakdown within the Dominguez Channel EWMP. TABLE 3.9-3 DOMINGUEZ CHANNEL WATERSHED LAND AREA DISTRIBUTION Agency Area in Machado Lake Watershed (acres) Area in Dominguez Channel Watershed (acres) Area in LA/LB Harbors Watershed (acres) Total Area in EWMP (acres) Percent of EWMP Area City of EI Segundo 0 1,252.18 0 1,252.18 3.44% City of Hawthorne 0 3,891.91 0 3,891.91 10.69% City of Inglewood 0 3,884.28 0 3,884.27 10.67% City of Lomita 58.3 1,227.70 SOURCE: Dominguez Channel EMWP Work Plan, 2014. 3.26% City of Los Angeles 1,998.42 19,243.25 11,258.12 19,243.20 52.85% Los Angeles County 1,250.87 6,755.77 134.23 8,140.87 22.36% SOURCE: Dominguez Channel EMWP Work Plan and Notice of Intent, 2014. TABLE 3.9-4 DOMINGUEZ CHANNEL WATERSHED LAND USE Agency Total Area (acres) Percent of EWMP Area Agriculture 0.2 0.3% Commercial 10.7 18.4% Industrial 9.1 15.7% Multi -Family Residential 8.3 14.2% Single Family Residential 16.1 27.7% Open 4.6 7.8% Other Urban 9.3 15.9 Total 58.3 100% SOURCE: Dominguez Channel EMWP Work Plan, 2014. LA County Flood Control District 3.9-6 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report Pacific Ocean Dominguez Channel COWatershed Management Group 'anticipating Permittees 'otential BMPs (Regional and lentralized)' SOURCE: ESRI; SCAG o z lim I Miles LA County PEIR EWMP. 140474 Figure 3.9-3 Land Use in the Dominguez Channel Watershed Management Group Single -Family Resi( Multi -Family Reside Other Residential General Office Commercial and Se Facilities Education Military Installations _ Industrial Transportation, Con Utilities Mixed Commercial Mixed Urban Open Space and Ri WL Agriculture Vacant Water Under Construction SOURCE: ESRI; SCAG o z lim I Miles LA County PEIR EWMP. 140474 Figure 3.9-3 Land Use in the Dominguez Channel Watershed Management Group 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Malibu Creek The Malibu Creek Watershed EWMP area covers the majority of the Malibu Creek Watershed. The Permittees within this EWMP are: the Cities of Agoura Hills, Calabasas, Hidden Hills, and Westlake Village; the County of Los Angeles; and the LACFCD. Malibu Creek Watershed land uses are 81 percent vacant, 11 percent residential, 2 percent open space and recreation, 2 percent commercial and public, 1 percent transportation and utilities, and Ipercent mixed-use (LADPW, 2005a). The Malibu Creek Watershed EWMP area is approximately 32,992 acres, which is approximately 46.7 percent of the total area in the Malibu Creek Watershed. A breakdown of areas by MS4 Permittee and other agencies is provided in Table 3.9-5. Figure 3.94 shows land use in the Malibu Creek Watershed EWMP area and the location of planned and priority regional/centralized BMPs. The location of distributed BMPs would be throughout the urbanized areas of the watershed. TABLE 3.9-5 MALIBU CREEK WATERSHED LAND AREA DISTRIBUTION Agency Total Area (acres) Percent of EWMP Area City of Agoura Hills 5,178 15.7% City of Calabasas 4,941 15.0% City of Hidden Hills 105 0.3% City of Westlake Village 3,540 10.7% County of Los Angeles 19,228 58.3% SOURCE: Malibu Creek EMWP Work Plan, 2014. a County Flood Control District 3.9-5 ESA 1140474 Enhanced Watershed Management Programs January 2015 Dreg Program Environmental Impact Report Q Malibu Creek WMG Q Participating Permittees • Potential BMPs (Reoional and Centralized)' Single -Family Residential Multi -Family Residential Other Residential General Office in Commercial and Services Facilities Education Industrial Transportation, Communications, and Utilities Mixed Commercial and Industrial Open Space and Recreation Agriculture Vacant Water Under Construction not SOURCE: ESRI; SCAG areas T o z I I Miles LA County PEIR EWMP . 140474 Figure 3.9-4 Land Use in the Malibu Creek Watershed Management Group 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Marina del Rey The Marina del Rey EWMP area covers the Marina del Rey Watershed. The Permittees within this EWMP are: the Cities of Los Angeles and Culver City; the County of Los Angeles; and LACFCD. Land uses within the Marina del Rey Watershed are 52 percent residential, 46 percent commercial and 2 percent open space (LADPW, 2014a). A breakdown of areas by MS4 Permittee and other agencies is provided in Table 3.9-6. Figure 3.9-5 shows land use in the Marina del Rey Watershed EWMP area and the location of planned and priority regional/centralized BMPs. The location of distributed BMPs would be throughout the urbanized areas of the watershed. Table 3.9-7 provides the land use breakdown within the Marina del Rey Watershed. TABLE 3.9-6 MARINA DEL REY WATERSHED LAND AREA DISTRIBUTION a County Flood Control District 3.9-10 ESA 1140474 Enhanced Watershed Management Programs January 2015 Dreg Program Environmental Impact Report Total Area Percent of Agency (acres) EWMP Area City of Los Angeles 971.3 69% City of Culver City 42.2 3% County of Los Angeles 395.7 28% Total 1,409 100% SOURCE: Marina del Rey EMWP Work Plan, 2014. TABLE 3.9-7 MARINA DEL REY WATERSHED LAND USE City of County of City of Culver Los Angeles Los Angeles Total Area Agency (acres) (acres) (acres) (acres) Single -Family Residential 6.8 230.6 0.3 237.7 Multi -Family Residential 0 229.4 156.9 386.3 Institutional/Public Facilities 0 83.7 4.2 87.9 Commercial and Services 24.3 122.3 122.0 268.6 Industrial/Mixed with Industrial 0 27.7 0 27.7 Transportation/Road 11.1 246.4 39.8 297.3 Developed Recreation/Marina Parking 0 0.9 43.3 44.2 Beach 0 0 8.2 8.2 Water 0 30.3 13.5 43.8 Vacant 0 0 7.6 7.6 Total 42.2 971.3 395.7 1,409 SOURCE: Marina del Rey EMWP Work Plan, 2014. a County Flood Control District 3.9-10 ESA 1140474 Enhanced Watershed Management Programs January 2015 Dreg Program Environmental Impact Report Q Marina Del Rey WMG Q Participating Permittees Priority Projects Pacific Ocean Single -Family Residential Multi -Family Residential Other Residential General Office Commercial and Services Facilities Education Industrial Mixed Commercial and Industrial Mixed Urban Open Space and Recreation Vacant Water Under Construction SOURCE: ESRI; SCAG 0 2,000 I I Feet LA County PEIR EWMP . 140474 Figure 3.9-5 Land Use in the Marina del Rey Watershed Management Group 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture North Santa Monica Bay The North Santa Monica Bay EWMP area covers the north region of the Santa Monica Bay Watershed QGl and JG4 and a portion of JG9) within the city of Malibu's borders. The Permittees within this EWMP are: the City of Malibu; County of Los Angeles; and LACFCD. The North Santa Monica Bay EWMP area encompasses 55,121 acres. The North Santa Monica Bay EWMP area is over 93 percent vacant land. The EWMP Group land use breakdowns by JG and watershed are shown in Table 3.9-8. Figure 3.9-6 shows land uses in the North Santa Monica Bay EWMP area and the location of planned and priority regional/centralized BMPs. The location of distributed BMPs would be throughout the urbanized areas of the watershed. TABLE 3.9-8 NORTH SANTA MONICA BAY WATERSHED LAND USE Agency JG1/Zuma Canyon JGI/Solstice Canyon JG1ISanta Monica Beach JGI/Garapito Creek JG1&4 Arroyo Sequit ColdCreek- Malibu Creek Total Area (acres) Vacant 89.0% 87.7% 91.7% 94.9% 96.5% 95.8% 93.1% Agricultural 1.9% 0.7% 0.0% 0.6% 0.9% 0.7% 0.8% Commercial 0.5% 0.6% 0.8% 0.2% 0.2% 0.2% 0.4% Single Family 7.7% 8.8% 7.0% 4.1% 2.2% 3.0% 5.0% Residential Multi -Family 0.5% 0.7% 0.4% 0.2% 0.1% 0.2% 0.3% Residential Industrial 0.1% 0A% 0.0% 0.0% 0.0% 0.2% 0.1% Education 0.3% 1.4% 0.0% 0A% 0.0% 0.0% 0.3% SOURCE: North Santa Monica Bay EMWP Work Plan, 2014. a County Flood Control District 3.9-12 ESA 1140474 Enhanced Watershed Management Programs January 2015 Dreg Program Environmental Impact Report COUNTY 27 zs COUNTY COUNTY z� • MALIBU RFs MALIBU" Single -Family Residential Multi-Family Residential Other Residential - General Office • ` Commercial and Services Facilities Education Pacific Ocean • Potential BMPs (Regional and Centralized)* Industrial Transportation, Communications, and Utilities Co North Santa Monica Bay WMG Open Space and Recreation Participating Permittees MrL Agnculture Vacant 0 2 Water iiiiiiI Under Construction Miles Potential Distributed BMP not shown - predominantly located in urbanized areas SOURCE: ESRI; SCAG LA County PEIR EW MP . 140474 Figure 3.9-6 Land Uses in the North Santa Monica Bay Watershed Management Group 3. Environmental Settinq, Impacts, and Mitigation Measures This page intentionally left blank LA County Flood Control District 3.9-14 ESA 1140474 Enhanced Watershed Management Programs January2015 Dreg Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Peninsula Cities The Peninsula Cities EWMP area covers most of the Santa Monica Bay Watershed JG7, the Los Angeles/Long Beach Harbor Watershed, and the Machado Lake Watershed. The Permittees within this EWMP are: the Cities of Rancho Palos Verdes, Palos Verdes Estates, and Rolling Hills Estates; the County of Los Angeles; and LACFCD. The Santa Monica Bay Watershed accounts for 63 percent (14.2 square miles) of the total Peninsula watershed management group area, and includes portions of the cities of Palos Verdes Estates, Rancho Palos Verdes, and Rolling Hills Estates. The Los Angeles Harbor subwatershed accounts for 15 percent (3.4 square miles) of the total Peninsula watershed management group area, and includes portions of the cities of Rancho Palos Verdes and Rolling Hills Estates. The Machado Lake subwatershed accounts for 22 percent (4.9 square miles) of the total Peninsula watershed management group area, and includes portions of the cities of Palos Verdes Estates, Rancho Palos Verdes, and Rolling Hills Estates and the County of Los Angeles. Table 3.9-9 provides the Peninsula EWMP area identified by watershed and agency. Figure 3.9-7 shows land uses in the Palos Verdes Peninsula EWMP area and the location of planned and priority regional/centralized BMPs. The location of distributed BMPs would be throughout the urbanized areas of the watershed. TABLE 3.9-9 PALOS VERDES PENINSULA LAND AREA DISTRIBUTION Agency Santa Monica Bay (Square Miles) Machado Lake (Square Miles) Los Angeles Harbor (Square Miles) Total EWMP Area Rancho Palos Verdes 9.35 1.07 3.02 13.5 Palos Verdes Estates 4.35 0.39 0 4.8 Rolling Hills Estates 0.46 2.78 0.34 3.6 County of Los Angeles 0 0.70 0 0.7 Total 14.2 4.9 3.4 22.6 SOURCE: Palos Verdes Peninsula EMWP Work Plan, 2014 IA County Flood Control District 3.9-15 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report • • • 4 R%LL1 FHILLS 4?ALOS�E•DES /,TES • o• ESTATES • a �.•-;�• yy Hawthorne • e` �� OUNT� • • ,�. � • ROLLING SILLS • • 0 • ESTATES - • • j ® • 4W ® • • • • • • n n RANCHO PALOS VERDES • d • Single -Family Residential — - �� 0 • • Multi -Family Residential - - Other Residential General Office Commercial and Services ' - Facilities��' Education I.7 Military Installations 0 Palos Verdes Peninsula WMG Industrial Q Participating Permittees Transportation, Communications, and Utilities Pacific Ocean • Potential BMPs (Regional and Centralized)` Open Space and Recreation 11 Agriculture Vacant 0 I I Under Construction Miles `Potential Distributed BMP not shown - predominantly located in urbanized areas LA County PEIR EWMP . 140474 SOURCE: ESRI; SCAG Figure 3.9-7 Land Uses in the Palos Verdes Peninsula EWMP Agencies 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Rio Hondo/San Gabriel River The Rio Hondo/San Gabriel River EWMP area covers portions of the Los Angeles and San Gabriel River watersheds. The Permittees within this EWMP are: the Cities of Arcadia, Azusa, Bradbury, Duarte, Monrovia, and Sierra Madre; the County of Los Angeles; and LACFCD. Table 3.9-10 provides the size and percentage of each participating member's jurisdiction within the group and the percent contribution to the Los Angeles River and/or San Gabriel River Watersheds. The area included in the Rio Hondo/San Gabriel River EWMP encompasses approximately 41 square miles of predominately residential and open space land use and excludes areas in the Angeles National Forest. Of the total Los Angeles River and San Gabriel River Watershed areas, the Rio Hondo/San Gabriel River EWMP members have jurisdiction over 4 and 3 percent of the total watersheds, respectively. Table 3.9-11 depicts the watershed land use categories within the Rio Hondo/San Gabriel River EWMP area. Figure 3.9-8 shows land uses in the Rio Hondo/ San Gabriel River EWMP area and the location of planned and priority regional/centralized BMPs. The location of distributed BMPs will be throughout the urbanized areas of the watershed. TABLE 3.9-10 RIO HONDO/SAN GABRIEL RIVER LAND AREA DISTRIBUTION Vacant Area Inside Percent in Agricultural 1.1 8 Rio Hondo/ Rio Hondo/ Percent in Percent in 19.3 San Gabriel San Gabriel Los Angeles San Gabriel Industrial River River River River Agency (square miles) Watershed Watershed Watershed Arcadia 11 27 99 1 Azusa 9 22 0 100 Bradbury 2 5 41 59 Duarte 4 0 37 63 Monrovia 8 19 99 1 Sierra Madre 3 7 100 0 Los Angeles County 4 10 54 46 SOURCE: Rio Hondo/San Gabriel River EMWP Work Plan, 2014. TABLE 3.9-11 RIO HONDO/SAN GABRIEL RIVER WATERSHED LAND USE Area Agency (square miles) Percentage Vacant 9.9 3 Agricultural 1.1 8 Commercial 3.5 3 Single Family Residential 19.3 7 Multi -Family Residential 2.8 7 Industrial 2.8 47 Education 1.1 1 Transportation 0.7 24 Total 41.2 100 SOURCE: Rio Hondo/San Gabriel River EMW P Work Plan, 2014. IA County Flood Control District 3.9-17 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report SIERRA MADRE ARCADIA AZUSA Potential Distributed BMP not shown - predominantly located in urbanized areas SOURCE: ESRI; SCAG LA County PEIR EWMP . 140474 Figure 3.9-8 Land Uses in the Rio Hondo / San Gabriel River Watershed Management Group Single -Family Residential Industrial Rio Hondo/San Gabriel River WMG Multi -Family Residential Transportation, Communications, and Utilities Q Participating Permittees Other Residential Mixed Commercial and Industrial General Office Open Space and Recreation Potential BMPs (Regional and Centralized)' Commercial and Services Agriculture Facilities Vacant 0 I I Education Water Mlles Military Installations Under Construction Potential Distributed BMP not shown - predominantly located in urbanized areas SOURCE: ESRI; SCAG LA County PEIR EWMP . 140474 Figure 3.9-8 Land Uses in the Rio Hondo / San Gabriel River Watershed Management Group 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Santa Monica Bay Jurisdictional Groups 2 & 3 The Santa Monica Bay EWMP area covers the central region of the Santa Monica Bay Watershed (JG2 and JG3) and includes the urbanized Dockweiler and Santa Monica subwatersheds, as well as natural open space located in the Castle Rock, Pulga Canyon, Temescal Canyon, and Santa Monica Canyon subwatersheds. The Permittees within this EWMP include the Cities of Los Angeles, Santa Monica, and El Segundo; the County of Los Angeles; and LACFCD. The Santa Monica Bay EWMP Group area covers 34,362 acres. Approximately 49 percent of the Santa Monica Bay EWMP Group area is open space, and approximately 93 percent of the open space is located the northern subwatersheds and approximately 7 percent is located in the Dockweiler subwatershed. Approximately 67 percent of the Santa Monica Bay EWMP Group area is pervious according to geographic information system (GIS) data from the Los Angeles County Department of Public Works, the large majority of which comes from the northern -most subwatersheds of Castle Rock, Pulga Canyon, Temescal Canyon, and Santa Monica Canyon. Table 3.9-12 provides the size and percentage of each participating member's jurisdiction within the watershed. Figure 3.9-9 shows land uses in the Santa Monica Bay EWMP area and the location of planned and priority regional/centralized BMPs. The location of distributed BMPs would be throughout the urbanized areas of the watershed. TABLE 3.9.12 SANTA MONICA BAY LAND AREA DISTRIBUTION Agency Land area (acres) Percent of EWMP Area City of Los Angeles 18,934.64 75.02% City of Santa Monica 4,987.47 19.76% City of EI Segundo 1,185.63 4.70% Los Angeles County 130.40 0.52% SOURCE: Santa Monica Bay EMWP Work Plan, 2014 IA County Flood Control District 3.9-19 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report Q Santa Monica Bay Watershed Juridictions 2 & 3 WMG r, Par}icinatinn PP.rrnittee5 Single Family Residential Multi -Family Residential Other Residential General Office Commercial and Services Facilities Education Industrial Transportation, Communications, and Utilities Mixed Commercial and Industrial Mixed Urban Open Space and Recreation Agriculture Vacant Water Under Construction SOURCE: ESRI; SCAG 's (Regional and Centralized)' T Mei.. LA County PEIR EWMP. 140474 Figure 3.9-9 Land Use in the Santa Monica Bay Watershed Jurisdictions 2 and 3 Watershed Management Group 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Upper Los Angeles River The Upper Los Angeles River EWMP area covers the upper reaches of the Los Angeles River Watershed. The Permittees within this EWMP are: the Cities of Alhambra, Burbank, Calabasas, Glendale, Hidden Hills, La Canada Flintridge, Los Angeles, Montebello, Monterey Park, Pasadena, Rosemead, San Gabriel, San Marino, South Pasadena, and Temple City; the County of Los Angeles; and LACFCD. The area included in the Upper Los Angeles River Watershed EWMP is approximately 479 square miles, or 57.43 percent of the total watershed area. Table 3.9-13 provides the size and percentage of each participating member's jurisdiction within the watershed. Figure 3.9-10 shows land uses in the Upper Los Angeles River EWMP area and the location of planned and priority regional/centralized BMPs. The location of distributed BMPs would be throughout the urbanized areas of the watershed. TABLE 3.9.13 UPPER LOS ANGELES RIVER LAND AREA DISTRIBUTION Agency Land area (acres) Percent of EWMP Area City of Los Angeles 18,934.64 75.02% City of Alhambra 4,884.31 1.60% City of Burbank 11,095.20 3.62% City of Calabasas 4,005.68 1.31% City of Glendale 19,587.50 6.40% City of Hidden Hills 961.03 0.31% City of La Canada Flintridge 5,534.46 1.81% City of Montebello 5,356.38 1.75% City of Monterey Park 4,951.51 1.62% City of Pasadena 14,805.30 4.84% City of Rosemead 3,310.87 1.08% City of San Gabriel 2,644.87 0.86% City of San Marino 2,409.64 0.79% City of South Pasadena 2,186.20 0.71% City of Temple City 2,576.50 0.84% Los Angeles County 40,553.34 13.25% SOURCE: Upper Las Angeles River EMW P Work Plan, 2014. IA County Flood Control District 3.9-21 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report COUNTY f� r r10 � AN FERNANDO HIDDEN HILLS\ rE7o CALABASASS rt — Single -Family Residential Multi -Family Residential Other Residential General Office Commercial and Services I Facilities Education _ Military Installafions — Industrial Tmnsportafion, Communications, and Utilities Mixed Commercial and Industrial Mixed Urban i� Open Space and Recreation Agriculture Vacant Water Under Construction Potential Distributed BMP not shown - predominantf SOURCE: ESRI; SCAG L0 14 EL£3 t6'l • �' `t ` `� LACANADA y ` FONTAINE • •HIT 1� 40VNiY 06URBANK%ENDALE G_ PASADENA N SOUTH J ®A EASADE&A TEMPLE CITY AN IE LOSANGELES ALHAMBRA � j SROSEMEAD MOP ..COV ON, SRE MpµxseELld 0 rI- � SANGELES Upper Los Angeles River WMG Q Participating Permittees • • Potential BMPs (Regional and 0 7` 4 I I Miles areas LA County PEIR EWMP . 140474 Figure 3.9-10 Land Use in the Los Angeles River Watershed Watershed Management Group 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Upper San Gabriel River The Upper San Gabriel River EWMP area covers portions of the San Gabriel River Watershed. The Permittees within this EWMP are: the Cities of Baldwin Park, Covina, Glendora, Industry, and La Puente; the County of Los Angeles; and LACFCD. Table 3.9-14 provides the size and percentage of each participating member's jurisdiction within the watershed. Figure 3.9-11 shows land uses in the Upper San Gabriel River EWMP area. TABLE 3.9-14 UPPER SAN GABRIEL RIVER LAND AREA DISTRIBUTION Agency Land area (acres) Percent of EWMP Area City of Baldwin Park 4,335 6.3% City of Covina 4,481 6.5% City of Glendora 9,307 13.5% City of Industry 7,647 11.1% City of La Puente 2,207 3.2% Los Angeles County 40,812 59.4% SOURCE: Upper San Gabriel River EMWP Work Plan, 2014 Upper Santa Clara River The Upper Santa Clara River EWMP area covers approximately 121,423 acres the Upper Santa Clara River Watershed. The Permittees within this EWMP are the City of Santa Clarita; the County of Los Angeles; and LACFCD. Land uses within the Santa Clara River Watershed include residential, commercial, agricultural and undeveloped land (LADPW, 2014b). Within the 500 -year river flood plain, the most prevalent land use is open space (62 percent), followed by agriculture (29 percent). The remaining land uses can be considered developed and/or urbanized and make up less than 10 percent of the total (LADPW, 2005b). Of the total watershed area, the City of Santa Clarita and County of Los Angeles have jurisdiction over 46 percent of the land area. Table 3.9-15 provides the size and percentage of each participating member's jurisdiction within the watershed. Figure 3.9-12 shows land uses in the Upper Santa Clara River Watershed EWMP area. TABLE 3.9-15 UPPER SANTA CLARA RIVER LAND AREA DISTRIBUTION Agency Land area (acres) Percent of EWMP Area City of Santa Clarita 39,451 32.5% Los Angeles County 81,972 67.5% Total EWMP Area 1217423 100% SOURCE: Upper Santa Clara River EMWP Work Plan, 2014. IA County Flood Control District 3.9-23 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report Q Upper San Gabriel River WMG Q Participating Permittees • Potential BMPs (Regional and Centralized)' o z Miles ilr 02 not shown -predominantly located in urbanized areas SOURCE: ESRI; SCAG Single -Family Residential Multi -Family Residential Other Residential General Office Commercial and Services Facilities Education Military Installations Industrial Transportation, Communications, and Utilities Mixed Commercial and Industrial 7 Mixed Urban Open Space and Recreation Agriculture Vacant Water Under Construction LA County PEIR EWMP . 140474 Figure 3.9-11 Land Use in the Upper San Gabriel River Watershed Management Group • Single -Family Residential Multi -Family Residential Other Residential Upper Santa Clara W MG General Office Q Participating Permittees Commercial and Services • Potential BMPs (Regional and Centralized)* — - Facilities T Education Military Installations 0 6 Industrial Mlles Transportation, Communications, and Utilities Doti Distributed BMP not shown - predominantly located in urbanized areas SOURCE: ESRI Mined Commercial and Industrial Mined Urban flUm Open Space and Recreation Agriculture _ Vacant Water Under Construction Undevelopable Unknown LA County PEIR EWMP . 140474 Figure 3.9-12 Land Use in Upper Santa Clara River Watershed Management Group 3. Environmental setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Habitat Conservation Plan There is one adopted habitat conservation plan area within the EWMP watershed areas: the Palos Verdes Peninsula Natural Communities Conservation Plan (NCCP)/Habitat Conservation Plan (HCP). The Palos Verdes Peninsula NCCP/HCP is within the Palos Verdes Peninsula EWMP area. The Palos Verdes Peninsula NCCP/HCP covers the city of Rancho Palos Verdes, which is approximately 8,600 acres. The Rancho Palos Verdes City Council adopted the NCCP/HCP in 2004. The City of Rancho Palos Verdes NCCP Subarea Plan (Subarea Plan) was prepared to maximize benefits to wildlife and vegetation communities while accommodating appropriate economic development within the city and region pursuant to the requirements of the NCCP Act and Section 10(a) of the Endangered Species Act (URS, 2004). The Subarea Plan provides for the comprehensive management and conservation of multiple species. The subarea is unique in that it contains healthy concentrations of coastal sage scrub habitat (approximately 1,000 acres) and a number of coastal sage scrub species that are not found in other Southern California coastal sage scrub communities. Agriculture The County of Los Angeles contains very little agricultural or forest land, as the majority of the land is urbanized. The watersheds in the northwestern corner of the County along the coast contain land designated as Farmland of Local Potential by the California Department of Conservation. This type of land is primarily located in the North Santa Monica Bay Coastal and the Malibu Creek Watersheds, with some located within the Upper Los Angeles River Watershed and the Upper Santa Clara River Watershed. The Upper Santa Clara River Watershed, covering the northwestern and northernmost borders of the County, contains large areas of Grazing Land and Farmland of Local Potential, and tiny pockets of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland. The only Williamson Act contracts in effect in Los Angeles County are for land on Santa Catalina Island (Los Angeles County, 2014), which is not located within the EWMP group areas. To the north of the Los Angeles River EWMP group is the Angeles National Forest, which offers outdoor activities such as hiking trails, campgrounds, and picnic areas. Angeles National Forest covers approximately 1,024 square miles just outside of the highly urbanized cities of Los Angeles County. While it is very close, it is not inside the Los Angeles River EWMP group boundary. IA County Flood Control District 3.9-26 ESA 11404]4 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture 3.9.2 Regulatory Setting State California Coastal Commission The California Coastal Commission (CCC) is a state agency that works in conjunction with local cities and counties to plan and regulate the use of land and water in the coastal zone. The coastal zone covers the entire shoreline of California and varies in width depending on the region. The CCC regulates development activities in the coastal zone. The CCC was established by the California Coastal Act of 1976. Local Coastal Programs (LCPs) are approved by the CCC to allow local jurisdictions to guide development in the coastal zone. LCPs require a Coastal Development Permit (CDP) for development in the coastal zone. Southern California Association of Governments Regional Comprehensive Plan SCAG is the federally mandated Metropolitan Planning Organization representing six counties: Los Angeles, Imperial, Orange, Riverside, San Bernardino, and Ventura. The SCAG Regional Comprehensive Plan addresses important regional issues such as housing, traffic/transportation, water, and air quality and serves as an advisory planning document to support and encourage local agencies in their planning efforts. California Farmland Mapping and Monitoring Program The California Department of Conservation, under the Division of Land Resource Protection, has established the Farmland Mapping and Monitoring Program. The Farmland Mapping and Monitoring Program monitors the conversion of the state's farmland to and from agricultural use and reports on the amount of land converted from agricultural to non-agricultural use. The Farmland Mapping and Monitoring Program maintains an inventory of state agricultural land and updates its "Important Farmland Series Maps" every 2 years (California Department of Conservation, 2007). Important farmlands are divided into the following five categories on Farmland Mapping and Monitoring Program maps based on their suitability for agriculture: • Prime Farmland. Prime Farmland is land with the best combination of physical and chemical characteristics able to sustain long-term production of agricultural crops. This land has produced irrigated crops at some time within the four years prior to the mapping date. • Farmland of Statewide Importance. Farmland of Statewide Importance island that meets the criteria for Prime Farmland but with minor shortcomings such as greater slopes or lesser soil moisture capacity. • Unique Farmland. Unique Farmland has even lesser quality soils and produces the state's leading agricultural crops. This land is usually irrigated but also includes non -irrigated orchards and vineyards. IA County Flood Control District 3.9-27 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture • Farmland of Local Importance. Farmland of Local Importance is land that is important to the local agricultural economy as determined by each county's board of supervisors and a local advisory committee. • Grazing Land. Grazing Land is land on which the existing vegetation is suited to the grazing of livestock. Local County of Los Angeles Low Impact Development Manual The County of Los Angeles (County) prepared the 2014 Low Impact Development Standards Manual (LID Standards) to comply with the requirements of the National Pollutant Discharge Elimination System (NPDES) MS4 Permit for stormwater and non-stormwater discharges from the MS4 within the coastal watersheds of Los Angeles County (CAS004001, Order No. R4-2012- 0175), referred to as the 2012 MS4 Permit (County of Los Angeles, 2014b). The LID Standards provide guidance for the implementation of stormwater quality control measures in new development and redevelopment projects in unincorporated areas of the County with the intention of improving water quality and mitigating potential water quality impacts from stormwater and non-stormwater discharges. The November 2013 LID Ordinance became effective December 5, 2013. City of Los Angeles Low Impact Development Manual In November 2011, the City of Los Angeles adopted the Stormwater Low Impact Development (LID) Ordinance #181899) with the stated purpose of: • Requiring the use of LID standards and practices in future developments and redevelopments to encourage the beneficial use of rainwater and urban runoff • Reducing stormwater/urban runoff while improving water quality • Promoting rainwater harvesting • Reducing offsite runoff and providing increased groundwater recharge • Reducing erosion and hydrologic impacts downstream • Enhancing the recreational and aesthetic values in our communities The City of Los Angeles institutionalized the use of LID techniques for development and redevelopment projects. Subsequent to the adoption of the Stormwater LID Ordinance, the City prepared the Development Best Management Practices Handbook, Low Impact Development Manual, dated June 2011, to describe the required BMPs (City of Los Angeles, 2011). Other Cities LID Various other cities within the County also have LID standards or guidance. The goals, objectives, and content of the LID document are similar to that of the County and City of Los Angeles, and are not referenced here. IA County Flood Control District 3.9-28 ESA 11404]4 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture County of Los Angeles General Plan A General Plan is a basic planning document that, alongside the zoning code, governs development in a city or county. The State requires each city and county to adopt a General Plan with seven mandatory elements: land use, open space, circulation, housing, noise, conservation, and safety, along with any number of optional elements as appropriate. The proposed EWMPs would be subject to local plans and policies of the areas in which they are located. Because this is a high-level assessment of projects spanning the entire County, this Program Environmental Impact Report (PEIR) will only discuss County -level goals and policies relating to the overall program. The County of Los Angeles is currently updating their General Plan from the version adopted in 1980; the new comprehensive plan is expected to be complete by late 2014. Below are land use and agriculture goals and policies from both the existing General Plan and the Draft General Plan 2035 (as of August 2014) which relate to the proposed program. Existing General Plan, Adopted 1980 Goal — Conserve Resources and Enhance Environmental Quality: Increasing pressures for urban expansion into outlying areas of significant ecological and scenic resources require that effective measures be taken to conserve and enhance our most valuable natural assets. Policy 20: Establish land use controls that afford effective protection for significant ecological and habitat resources, and lands of major scenic value. Policy 21: Protect identified Potential Agricultural Preserves by discouraging inappropriate land division and allowing only use types and intensities compatible with agriculture. Policy 22: In non -urban areas outside of Potential Agricultural Preserves, encourage the retention and expansion of agriculture by promoting compatible land use arrangements and providing technical assistance to involved farming interests. Policy 23: In urban areas, encourage the retention of economically viable agricultural production, e.g., high value crops such as strawberries, cut flowers, nursery stock, etc., through the identification and mitigation of significant adverse impacts resulting from adjacent new development. Goal — Improve the Land Use Decision -Making Process: The manner in which land use decisions are made must address cumulative social, economic and environmental effects, and ensure opportunity for citizen participation. Policy 29: Improve the land use decision-making process by closely monitoring and evaluating the cumulative impacts of individual projects and by modernizing development regulations IA County Flood Control District 3.9-29 ESA 11404]4 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Goal — Improve Inter -Agency Coordination in Land Use Planning: There is a growing need to more effectively coordinate the land use planning activities of local, regional, State, and federal agencies in Los Angeles County. Policy 30: Promote improved interjurisdictional coordination of land use policy matters between the County, cities, adjacent counties, special districts, and regional and subregional agencies. Policy 31: Ensure that cities have a voice in land use decisions within their adopted spheres of influence. Draft General Plan, Drafted 2014 Goal LU 2: Community-based planning efforts that implement the General Plan and incorporate public input, and regional and community level collaboration. Policy LU 2.8: Coordinate with the Los Angeles County Department of Public Works and other infrastructure providers to analyze and assess infrastructure improvements that are necessary for plan implementation. Goal LU 8: Well-designed and healthy places that support a diversity of built environments. Policy LU 8.2: Design development adjacent to natural features in a sensitive manner to complement the natural environment. Policy LU 8.4: Promote environmentally sensitive and sustainable design. Goal M-7: Transportation networks that minimizes negative impacts to the environment and communities. Policy M 7.1: Encourage the use of natural systems to treat stormwater and rainwater runoff. Policy M 7.2: Minimize roadway runoff through the use of permeable surface materials, such as porous asphalt and concrete materials, wherever feasible. Goal C/NR-5: Protected and useable local surface water resources. Policy C/NR 5.1: Support the LID philosophy, which seeks to plan and design public and private development with hydrologic sensitivity, including limits to straightening and channelizing natural flow paths, removal of vegetative cover, compaction of soils, and distribution of naturalistic BMPs at regional, neighborhood, and parcel -level scales. Policy C/NR 5.2: Require compliance by all County departments with adopted Municipal Separate Storm Sewer System (MS4), General Construction, and point source NPDES permits. IA County Flood Control District 3.9-30 ESA 11404]4 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Policy C/NR 5.3: Actively engage with stakeholders in the formulation and implementation of surface water preservation and restoration plans, including plans to improve impaired surface water bodies by retrofitting tributary watersheds with LID types of BMPs. Policy C/NR 5.4: Actively engage in implementing all approved Enhanced Watershed Management Programs/Watershed Management Programs and Coordinated Integrated Monitoring Programs/Integrated Monitoring Programs or other County -involved TMDL implementation and monitoring plans. Policy C/NR 5.6: Minimize point and non -point source water pollution. Policy C/NR 5.7: Actively support the design of new and retrofit of existing infrastructure to accommodate watershed protection goals, such as roadway, railway, bridge, and other—particularly—tributary street and greenway interface points with channelized waterways. Goal C/NR-6: Protected and usable local groundwater resources, Policy C/NR 6.1: Support the LID philosophy, which incorporates distributed, post - construction parcel -level stormwater infiltration as part of new development. Policy C/NR 6.2: Protect natural groundwater recharge areas and regional spreading grounds. Policy C/NR 6.3: Actively engage in stakeholder efforts to disperse rainwater and stormwater infiltration BMPs at regional, neighborhood, infrastructure, and parcel -level scales. Policy C/NR 6.5: Prevent stormwater infiltration where inappropriate and unsafe, such as in areas with high seasonal groundwater, on hazardous slopes, within 100 feet of drinking water wells, and in contaminated soils. Goal C/NR 7: Protected and healthy watersheds, Policy C/NR 7.1: Support the LID philosophy, which mimics the natural hydrologic cycle using undeveloped conditions as a base, in public and private land use planning and development design. Policy C/NR 7.2: Support the preservation, restoration and strategic acquisition of open space to preserve natural streams, drainage paths, wetlands, and rivers, which are necessary for the healthy function of watersheds. Policy C/NR 7.3: Actively engage with stakeholders to incorporate the LID philosophy in the preparation and implementation of watershed and river master plans, ecosystem restoration projects, and other related natural resource conservation aims, and support the implementation of existing efforts, IA County Flood Control District 3.9-31 ESA 11404]4 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture including Watershed Management Programs and Enhanced Watershed Management Programs. Policy C/NR 7.4: Promote the development of multi -use regional facilities for storrnwater quality improvement, groundwater recharge, detention/attenuation, flood management, retaining non-stormwater runoff, and other compatible uses.. City General Plans The numerous cities encompassed by the EWMP area all have their own respective city General Plans, which may contain policies that address land use and agriculture. As implementation of the individual structural BMP projects proceed, specific policies and objectives pertaining to land use and agriculture from applicable city General Plans will be identified and evaluated on a project - by -project basis during subsequent CEQA environmental processes. 3.9.3 Impact Assessment The proposed program's potential impacts have been assessed using the CEQA Guidelines Appendix G Checklist. The following sections discuss the key issue areas identified in the CEQA Guidelines with respect to the program's potential effect to agricultural resources and land use. Threshold of Significance For the purposes of this PEIR and consistency with Appendix G of the CEQA Guidelines, the program would have a significant impact on land uses if it would: • Physically divide an established community. • Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect. • Conflict with any applicable habitat conservation plan or natural community conservation plan. The program would have a significant impact on agriculture land uses if it would: • Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use. • Conflict with existing zoning for agricultural use, or a Williamson Act contract. • Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)). • Result in the loss of forest land or conversion of forest land to non -forest use. LA County Flood Control District 3.9-32 ESA 11404]4 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture • Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non -forest use. The significance determination for the above -listed impact thresholds is based on both short-term and long-term impacts of project implementation. Project Impact Discussion Division of an Established Community Impact 3.9-1: The proposed program could physically divide an established community. Structural (Regional, Centralized, and Distributed) BMPs Distributed BMPs are most likely to be implemented in high-density urban, commercial, industrial, and transportation areas where they would either replace or improve upon existing stormwater infrastructure. These types of BMPs are generally "retrofit' type projects that replace existing impervious surfaces with pervious surfaces such as bioinfiltration cells, bioswales, porous pavement, and filter strips that tie into existing stormwater management systems. These projects may also augment the existing stormwater management systems with additional inlet screens, filter media systems, sediment removal systems, and diversions to sanitary sewer lines. Ground disturbance for distributed BMPs is typically less than 1 to 2 acres in extent, but may extend in some limited applications up to 5 acres where space is available, generally on municipally owned lands such as parks and schools, which would not divide a community. Centralized structural BMPs collect, store, treat, and filter stormwater from multiple parcels and much larger drainage areas. Like centralized BMPs, regional BMPs can be implemented in a broad range of land use types, from high-density urban to open space, and can have multiple benefits (habitat, recreation, aesthetics, etc.). Centralized and regional structural BMPs require greater footprints for construction and implementation. However, the installation of these larger BMPs would not physically divide an established community as they would be implemented primarily on existing sidewalks, streets, parks, and city -owned lands. The BMPs would augment the physical structure of established communities, blending in as part of the existing landscape; enhancing water quality of existing communities. Additionally, much of the implementation would consist of the retrofitting of already -established stormwater infrastructure, and would not physically divide an established community. No impact would occur. Mitigation Measures: None required Significance Determination: No impact Non -Structural (Institutional) BMPs The non-structural BMPs associated with the proposed program would not consist of structural components; these BMPs would include programs, actions, and activities to eliminate pollutants from stormwater runoff, none of which would contribute to the physical division of a community. Therefore, non-structural BMPs would not have a physical impact on the built environment. IA County Flood Control District 3.9-33 ESA 11404]4 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Mitigation Measures: None required Significance Determination: No impact Land Use Plan, Policy or Regulation Confliction Impact 3.9-2: The proposed program could conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the program (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect. Structural (Regional, Centralized, and Distributed) BMPs Structural BMPs would be located throughout Los Angeles County, spanning multiple jurisdictions within varying land uses. Each BMP would be subject to land use zoning and General Plan designations adopted by the local municipality or the County. Implementing agencies will identify appropriate locations based on the local zoning codes. Some BMPs may require easements, conditional use permits, variances, or General Plan amendments. Approval by local jurisdictions of these land use conditions would ensure consistency with local plans. The structural BMPs associated with the proposed program would complement the Los Angeles County's LID Ordinance that became effective December 5, 2013. The LID Standards provide guidance for the implementation of stormwater quality control measures in new development and redevelopment projects in unincorporated areas of the County with the intention of improving water quality and mitigating potential water quality impacts from stormwater and non-stormwater discharges. The proposed EWMP Program would implement LID techniques throughout the urbanized landscape via the implementation of distributed BMPs, as such; the implementation of structural BMPs would support implementation of the County's LID Ordinance. The structural BMPs associated with the proposed program would complement the Los Angeles County's land use goals and policies for the built environment including conserving resources and enhancing environmental quality (goal from 1980 General Plan), creating well-designed and healthy places that support a diversity of built environments (Goal LU 8), supporting transportation networks that minimize negative impacts to the environment and communities, which includes encouraging the use of natural systems to treat stormwater runoff, and minimizing roadway runoff through the use of permeable surface materials wherever feasible, protecting local surface water resources (Goal C/NR 5), protecting local groundwater sources (Goal C/NR 6), and creating protected and healthy watersheds (Goal C/NR 7). These goals would be supported by the proposed project because they would not change land uses and would implement BMPs to support protection of important water resources in a way that would minimize the impact of the land use on the environment. The proposed water conservation and water quality projects included as part of the proposed program would align with the County LID standards, which call for projects to mimic naturally occurring runoff conditions, as best as possible. IA County Flood Control District 3.9-34 ESA 11404]4 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Implementation of BMPs to enhance water quality in the region would not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect. Mitigation Measures: None required Significance Determination: No impact Non -Structural (Institutional) BMPs Non-structural BMPs associated with the proposed program include policies, actions and activities intended to prevent pollutants from entering stormwater runoff, thus eliminating the sources of the pollutants. The non-structural BMPs would not physically change the built environment, and would implement further policies and actions to protect stormwater runoff from pollution. Mitigation Measures: None required Significance Determination: No impact Habitat Conservation Plan Or Natural Community Conservation Plan Confliction Impact 3.9-3: The proposed program could conflict with any applicable habitat conservation plan or natural community conservation plan. Structural (Regional, Centralized, and Distributed) BMPs Only one HCP/NCCP has been adopted within the EWMP areas. The City of Rancho Palos Verdes NCCP Subarea Plan (Subarea Plan) was prepared to maximize benefits to wildlife and vegetation communities while accommodating appropriate economic development within the city and region pursuant to the requirements of the NCCP Act and Section 10(a) of the ESA (URS, 2004). The BMPs would be located primarily in high-density urban, commercial, industrial, and transportation areas, where they would either replace or improve upon existing stormwater infrastructure. BMPs proposed within the HCP/NCCP would be required to comply with the adopted plan. This would include avoiding impacts to coastal sage scrub habitat. The goals of the EWMP and the HCP are consistent and conflicts would be avoided through site placement, BMP type, and City of Rancho Palos Verde approval. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs The non-structural BMPs associated with the proposed program are program- and policy -based and do not involve physical structures, so they would not introduce any physical impacts to the built environment. The project areas is located primarily in developed areas of Los Angeles IA County Flood Control District 3.9-35 ESA 11404]4 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture County, and would not take place within an HCP, NCCP, or any other conservation plan -covered area. There would be no impact. Mitigation Measures: None required Significance Determination: No impact Agricultural and Forestry Resources Impact 3.9-4: The proposed program could convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use. The proposed program could involve other changes in the existing environment which, due to their location or nature, could result in conversion of agricultural land to non-agricultural use or conversion of forest land to non -forest use, Structural (Regional, Centralized, and Distributed) BMPs Only small areas of Designated Prime, Unique and Important Farmlands exist within the EWMP area, limited to the Santa Clara and Malibu Watersheds. The structural BMPs associated with the proposed program would not convert any Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural uses because the BMPs would be located primarily in high-density urban, commercial, industrial, and transportation areas where they would either replace or improve upon existing stormwater infrastructure. The construction of structural BMPs would primarily focus on the retrofitting of existing infrastructure, and would be located on existing streets, sidewalks, and parks. The larger regional and centralized projects would be located in parks and open space areas that may be adjacent to or on farmland. However, none of the BMPs would replace designated Prime, Unique, or Important Farmland. There would be no impact to farmland. Mitigation Measures: None required Significance Determination: No impact Non -Structural (Institutional) BMPs Non-structural BMPs would consist of policies and programs that would not be physically constructed and would not involve or contribute to the conversion of agricultural land to non- agricultural uses. There would be no impact. Mitigation Measures: None required Significance Determination: No impact IA County Flood Control District 3.9-36 ESA 11404]4 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Existing Agricultural Zoning or Williamson Act Contract Confliction Impact 3.9-5: The proposed program could conflict with existing zoning for agricultural use, or a Williamson Act contract. Structural (Regional, Centralized, and Distributed) BMPs The structural BMPs associated with the proposed program would be constructed on urbanized land primarily on streets, sidewalks, and in parks or other city -owned lands, and would therefore not conflict with existing land zoned for agricultural use. There are no Williamson Act contracts within the project area. As a result, there would be no impacts to existing agricultural zoning or land under the Williamson Act contract. Mitigation Measures: None required Significance Determination: No impact Non -Structural (Institutional) BMPs The non-structural BMPs associated with the proposed program would not require any physical construction and would be implemented in primarily urbanized areas; therefore, they would have no impact on agriculturally -zoned land. There are no Williamson Act contracts within the project area. Mitigation Measures: None required Significance Determination: No impact Forest Land Confliction Impact 3.9-6: The proposed program could conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)). The proposed program could result in the loss of forest land or conversion of forest land to non -forest use. Structural (Regional, Centralized, and Distributed) BMPs The structural BMPs associated with the proposed program would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production, and would not result in the loss of forest land or conversion of forest land to non - forest land because there is no land within the EWMP groups zoned as forest land or timberland. The structural BMPs would be constructed and implemented primarily on urbanized land primarily on streets, sidewalks, and in parks or other city -owned lands, and would therefore have no impact on forest land, timberland, or timberland zoned Timberland Production. Mitigation Measures: None required Significance Determination: No impact IA County Flood Control District 3.9-37 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture Non -Structural (Institutional) BMPs The non-structural BMPs associated with the proposed program would not involve any physical construction and would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production. Implementation of the non-structural BMPs would not result in the loss of forest land or conversion of forest land to non -forest use. Mitigation Measures: None required Significance Determination: No impact Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs No land use planning impacts have been identified in this analysis as a result of the structural BMPs associated with the proposed program because the EWMPs would be implemented in already established urban areas. BMP locations would be required to be consistent with local zoning and General Plan designations. Furthermore, the BMPs would be supportive of LID Ordinance goals and objectives. The incremental effect on cumulative land use and planning during construction and operation of the proposed program would be less than significant. Therefore, the contribution is not cumulatively considerable and would not result in a cumulative impact on land use and planning. Furthermore, the proposed program would not impact agricultural and forest lands since structural BMPs would be implemented largely in urbanized areas and focus on improving existing facilities. Therefore, the contribution is not cumulatively considerable and would not result in a cumulative impact on agricultural resources. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs No land use planning impacts have been identified in this analysis as a result of the non-structural BMPs associated with the proposed EWMPs because there is no physical construction associated with these BMPs. The non-structural BMPs will consist of policies, actions, and activities to help prevent pollutants from entering stormwater runoff. They will likely provide improvements to existing land uses because their primary goal will be to improve water quality. One major purpose of the non-structural BMPs is to meet Minimum Control Measure (MCM) requirements in the MS4 Permit. Therefore, the proposed program is not cumulatively considerable and would not result in a cumulative impact on land use and planning. Furthermore, the proposed program would not impact agricultural and forest lands since there would be no physical construction associated with these BMPs. Therefore, the non-structural BMPs are not cumulatively considerable and would not result in a cumulative impact on agricultural resources. Mitigation Measures: None required Significance Determination: Less than significant IA County Flood Control District 3.9-38 ESA 11404]4 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.9 Land Use and Agriculture 3.9.4 Summary of Impact Assessment Table 3.9-16 shows a summary of the structural BMPs requiring mitigation. IA County Flood Control District 3.9-39 ESA 11404]4 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures TABLE 3.9-16 SUMMARY OF LAND USE AND AGRICULTURE IMPACTS REQUIRING MITIGATION MEASURES Draft Program Environmental Impact Report CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Thresholds of Significance Land Use Plan, Division of an Policy or Habitat Agricultural and Existing Agricultural Established Regulation Conservation Plan Forestry Zoning or Williamson Act Forest Land Cumulative Structural BMPs Community Confliction Confliction Resources Contract Confliction Confliction Impacts None None Applicable Mitigation Measures: None Required None Required None Required None Required None Required Required Required Regional Bill Regional Detention and Infiltration No No No No No No No Regional Capture, Detention, and Use No No No No No No No Centralized BMP Bioinfiltration No No No No No No No Constructed Wetlands No No No No No No No Treatment/Low-Flow Diversions No No No No No No No Creek, River, Estuary Restoration No No No No No No No Distributed BMPs Site -Scale Detention No No No No No No No LID — Infiltration/Filtration BMPs — Porous No No No No No No No Pavement, Green Streets, Bioswale/Filter Strips, Downspout Disconnects LID— Green Infrastructure — Capture and No No No No No No No Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes Flow-through Treatment BMPs No No No No No No No Source Control Treatment BMPs (catch No No No No No No No basin inserts/screens, hydrodynamic separators, gross solids removal devices ) Low -Flow Diversions No No No No No No No NOTE: These conclusions are based on typical BMP size and location. LA County Flood Control District 3.9-40 ESA 11404]4 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT 3. Environmental Setting, Impacts, and Mitigation Measures 3,10 Noise This section evaluates the potential for noise and groundbome vibration impacts to result from implementation of the proposed Enhanced Watershed Management Program (EWMP). This includes the potential for the proposed program to result in impacts associated with a substantial temporary and/or permanent increase in ambient noise levels in the vicinity of the proposed program; exposure of people in the vicinity of the proposed program to excessive noise and groundbome vibration levels; and whether this exposure is in excess of applicable, established standards in the EWMP areas of Los Angeles County (County). Mitigation measures to reduce potential noise and vibration impacts are identified, where warranted. 3A 0A Pdncip0es of Noose and Vibration Noise Principles and Descriptors Noise is generally defined as unwanted sound, traveling in the form of waves from a source and exerting a sound pressure level (referred to as sound level) that is measured in decibels (dB), which is the standard unit of sound amplitude measurement. The dB scale is a logarithmic scale that describes the physical intensity of the pressure vibrations that make up any sound, with 0 dB corresponding roughly to the threshold of human hearing and 120 to 140 dB corresponding to the threshold of pain. Pressure waves traveling through air exert a force registered by the human ear as sound. Sound pressure fluctuations can be measured in units of hertz (Hz), which correspond to the frequency of a particular sound. Typically, sound does not consist of a single frequency, but rather a broad band of frequencies varying in levels of magnitude. When all the audible frequencies of a sound are measured, a sound spectrum is plotted consisting of a range of frequency spanning 20 to 20,000 Hz. The sound pressure level, therefore, constitutes the additive force exerted by a sound corresponding to the sound frequency/sound power level spectrum. The typical human ear is not equally sensitive to all frequencies of the audible sound spectrum. As a consequence, when assessing potential noise impacts, sound is measured using an electronic filter that deemphasizes the frequencies below 1,000 Hz and above 5,000 Hz in a manner corresponding to the human ear's decreased sensitivity to extremely low and extremely high frequencies. This method of frequency weighting is referred to as A -weighting and is expressed in units of A -weighted decibels (dBA). A -weighting follows an international standard methodology of frequency deemphasis and is typically applied to community noise measurements. Some representative noise sources and their corresponding A -weighted noise levels are shown in Figure 3.10-1. LA County Flood Control District 3.10-1 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report PUBLIC REACTION NOISE LEVEL (d BA, Leq ) COMMON INDOOR NOISE LEVELS COMMON OUTDOOR NOISE LEVELS 110 Rock Band — — — — — — — — — — — — — — — — — — — — — — — — — — — Jet Flyover at 1000 Fl. 100 — — — — — — — — — — — — — — — — — — — — — — — — — — — Inside Subway Train (New York) LOCAL COMMITTEE ACTIVITY WITH Gas Lawn Mower at 3 Ft. INFLUENTIAL OR LEGAL ACTION 4 Times As Loud 00 --------------------------- LETTERS OF PROTEST Food Blender at 3 Ft. Diesel Truck at 50 Fl. Garbage Disposal of 3 Ft. Noisy Urban Daytime Twice As Loud -110.80 — ------ ----- COMPLAINTS LIKELY Shouting at 3 Ft. Vacuum Cleaner at 10 Ft. Gas Lawn Mower at 100 Ft. REFERENCE 70 --------------------------- COMPLAINTS POSSIBLE Commercial Area Heavy Traffic of 300 Ft. 1l2 As Loud 60 — — — — — — — — — — — — — — — — — — — — 30 — — — — — — COMPLAINTS RARE Large Business Office 114 As Loud 50 --Dishwasher Next Room --------Quiet Urban Daytime ------ ACCEPTANCE 40 Quiet Urban Nighttime --Small Theater, Large-------- ----- Conference Room (Background) Library Quiet Suburban Nighttime 30 — — — — — — — — — — — — — — — — — — — — — — — — — — — SOURCE: ESA Concert Hall (Background) Quiet Rural Nighttime 20 — — — — — — — — — — — — — — — — — — — — — — — — — — Broadcast and Recording Studio 10 — — — — — — — — — — — — — — — — — — — — — — — — — — Threshold of Hearing 0 -------------------------- SOURCE: ------------------------- — LA County PEIR EWMP. 140474 Figure 3.10-1 Effects of Noise on People 3. Environmental Setting, Impacts, and Mitigation Measures Noise Exposure and Community Noise An individual's noise exposure is a measure of noise over a period of time. A noise level is a measure of noise at a given instant in time. The noise levels presented in Figure 3.10-1 are representative of measured noise at a given instant in time; however, they rarely persist consistently over a long period of time. Rather, community noise varies continuously over a period of time with respect to the contributing sound sources of the community noise environment. Community noise is primarily the product of many distant noise sources, which constitute a relatively stable background noise exposure, with the individual contributors unidentifiable. The background noise level changes throughout a typical day, but does so gradually, corresponding with the addition and subtraction of distant noise sources such as traffic. What makes community noise constantly variable throughout a day, besides the slowly changing background noise, is the addition of short duration, single -event noise sources (e.g., aircraft flyovers, motor vehicles, sirens), which are readily identifiable to the individual. These successive additions of sound to the community noise environment change the community noise level from instant to instant, thus requiring that noise exposure be measured over a period of time to legitimately characterize a community noise environment and evaluate cumulative noise impacts. This time -varying characteristic of environmental noise is described using statistical noise descriptors. The most frequently used noise descriptors are summarized below: Leg: The LeQ, or equivalent sound level, is used to describe noise over a specified period of time in terms of a single numerical value; the LeQ of a time -varying signal and that of a steady signal are the same if they deliver the same acoustic energy over a given time. The LeQ may also be referred to as the average sound level. Losc,: The maximum, instantaneous noise level experienced during a given period of time. Lnun: The minimum, instantaneous noise level experienced during a given period of time. L50: The noise level that is equaled or exceeded 50 percent of the specified time period. The L50 represents the median sound level. Lgo: The noise level that is equaled or exceeded 90 percent of the specified time period. The L90 is generally considered to be representing the background or ambient level of a noise environment. Ldn: Also termed the day -night average noise level (DNL), the Ldn is the average A -weighted noise level during a 24-hour day, obtained after an addition of 10 dBA to measured noise levels between the hours of 10:00 P.M. and 7:00 A.M. to account nighttime noise sensitivity. CNEL: CNEL, or Community Noise Equivalent Level, is the average A -weighted noise level during a 24-hour day that is obtained after an addition of 5 dBA to measured noise levels between the hours of 7:00 P.M. and 10:00 P.M. and after an addition of 10 dBA to noise levels between the hours of 10:00 P.M. and 7:00 A.M. to account for noise sensitivity in the evening and nighttime, respectively. LA County Flood Control District 3.10-3 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures Effects of Noise on People Noise is generally loud, unpleasant, unexpected, or undesired sound that is typically associated with human activity that is a nuisance or disruptive. The effects of noise on people can be placed into four general categories: • Subjective effects (e.g., dissatisfaction, annoyance) • Interference effects (e.g., communication, sleep, and learning interference) • Physiological effects (e.g., startle response) • Physical effects (e.g., hearing loss) Although exposure to high noise levels has been demonstrated to cause physical and physiological effects, the principal human responses to typical environmental noise exposure are related to subjective effects and interference with activities. Interference effects of environmental noise refer to those effects that interrupt daily activities and include interference with human communication activities, such as normal conversations, watching television, telephone conversations, and interference with sleep. Sleep interference effects can include both awakening and arousal to a lesser state of sleep. With regard to the subjective effects, the responses of individuals to similar noise events are diverse and are influenced by many factors, including the type of noise, the perceived importance of the noise, the appropriateness of the noise to the setting, the duration of the noise, the time of day and the type of activity during which the noise occurs, and individual noise sensitivity. Overall, there is no completely satisfactory way to measure the subjective effects of noise, or the corresponding reactions of annoyance and dissatisfaction on people. A wide variation in individual thresholds of annoyance exists, and different tolerances to noise tend to develop based on an individual's past experiences with noise. Thus, an important way of predicting a human reaction to a new noise environment is the way it compares to the existing environment to which one has adapted (i.e., comparison to the ambient noise environment). In general, the more a new noise level exceeds the previously existing ambient noise level, the less acceptable the new noise level will be judged by those hearing it. With regard to increases in A -weighted noise level, the following relationships generally occur: • Except in carefully controlled laboratory experiments, a change of 1 dBA cannot be perceived. • Outside of the laboratory, a 3 dBA change in noise levels is considered to be a barely perceivable difference. • A change in noise levels of 5 dBA is considered to be a readily perceivable difference. • A change in noise levels of 10 dBA is subjectively heard as doubling of the perceived loudness. These relationships occur in part because of the logarithmic nature of sound and the decibel system. The human ear perceives sound in a nonlinear fashion; hence, the decibel scale was developed. LA County Flood Control District 3.10-4 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures Because the decibel scale is based on logarithms, two noise sources do not combine in a simple additive fashion, but rather logarithmically. For example, if two identical noise sources produce noise levels of 50 dBA, the combined sound level would be 53 dBA, not 100 dBA. Noise Attenuation Stationary point sources of noise, including stationary mobile sources such as idling vehicles, attenuate (lessen) at a rate between 6 dBA for hard sites and 7.5 dBA for soft sites for each doubling of distance from the reference measurement. Hard sites are those with a reflective surface between the source and the receiver, such as asphalt or concrete surfaces or smooth bodies of water. No excess ground attenuation is assumed for hard sites and the change in noise levels with distance (drop-off rate) is simply the geometric spreading of the noise from the source. Soft sites have an absorptive ground surface such as soft dirt, grass, or scattered bushes and trees. In addition to geometric spreading, an excess ground attenuation value of 1.5 dBA (per doubling distance) is normally assumed for soft sites. Line sources (such as traffic noise from vehicles) attenuate at a rate between 3 dBA for hard sites and 4.5 dBA for soft sites for each doubling of distance from the reference measurement (Caltrans, 1998). Fundamentals of Vibration As described in the Federal Transit Administration's (FTA's) Transit Noise and Vibration Impact Assessment (FTA, 2006), groundbome vibration can be a serious concern for nearby neighbors of a transit system route or maintenance facility, causing buildings to shake and rumbling sounds to be heard. In contrast to airborne noise, groundbome vibration is not a common environmental problem. It is unusual for vibration from sources such as buses and trucks to be perceptible, even in locations close to major roads. Some common sources of groundbome vibration are trains, buses on rough roads, and construction activities such as blasting, pile -driving, and operation of heavy earthmoving equipment. There are several different methods that are used to quantify vibration. The peak particle velocity (PPV) is defined as the maximum instantaneous peak of the vibration signal. The PPV is most frequently used to describe vibration impacts to buildings. The root mean square (RMS) amplitude is most frequently used to describe the effect of vibration on the human body. The RMS amplitude is defined as the average of the squared amplitude of the signal. Decibel notation (VdB) is commonly used to measure RMS. The relationship of PPV to RMS velocity is expressed in terms of the "crest factor," defined as the ratio of the PPV amplitude to the RMS amplitude. PPV is typically a factor of 1.7 to 6 times greater than RMS vibration velocity (FTA, 2006). The decibel notation acts to compress the range of numbers required to describe vibration. Typically, groundbome vibration generated by man-made activities attenuates rapidly with distance from the source of the vibration. Sensitive receptors for vibration include structures (especially older masonry structures), people (especially residents, the elderly, and sick), and vibration -sensitive equipment. The effects of groundbome vibration include movement of the building floors, rattling of windows, shaking of items on shelves or hanging on walls, and rumbling sounds. In extreme cases, the vibration can cause damage to buildings. Building damage is not a factor for most LA County Flood Control District 3.10-5 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures projects, with the occasional exception of blasting and pile -driving during construction. Annoyance from vibration often occurs when the vibration levels exceed the threshold of perception by only a small margin. A vibration level that causes annoyance will be well below the damage threshold for normal buildings. The FTA measure of the threshold of architectural damage for conventional sensitive structures is 0.2 in/sec PPV (FTA, 2006). In residential areas, the background vibration velocity level is usually around 50 VdB (approximately 0.0013 in/sec PPV). This level is well below the vibration velocity level threshold of perception for humans, which is approximately 65 VdB. A vibration velocity level of 75 VdB is considered to be the approximate dividing line between barely perceptible and distinctly perceptible levels for many people (FTA, 2006). 301002 Environmental Setting Existing Noise Sources As the EWMP areas are located throughout Los Angeles County, existing noise levels in the EWMP areas would consist of various noise sources typically associated with highly urbanized environments. These noise sources commonly include, but are not limited to, traffic, construction work, commercial operations, human activities, emergency vehicles, aircraft overflights, etc. Of these sources, transportation -related noise associated with vehicular traffic is generally the constant, dominating noise source that comprises an urban environment's ambient noise levels. Vehicular traffic creates noise on roads and highways in residential, commercial, industrial, and mixed-use areas. Aside from vehicular traffic on roadways, other transportation -related noise sources include rail/urban transit systems and airports, which are also located throughout the County. Noise generated by stationary sources in an urban environment are generally associated with heating, ventilating, and air conditioning (HVAC) equipment for residential and commercial uses as well as other similar and larger mechanical stationary equipment for industrial uses. The use of larger -capacity stationary mechanical equipment by industrial uses generally results in higher noise levels in industrial -zoned areas when compared with residential or retail areas. Existing Groundborne Vibration Levels Aside from periodic construction work that may occur throughout the County where the EWMP areas are located, other sources of groundborne vibration in the County include heavy-duty vehicular travel (e.g., refuse trucks, delivery trucks, and transit buses) on local roadways. Trucks and buses traveling at a distance of 50 feet typically generate groundborne vibration velocity levels of around 63 VdB (approximately 0.006 in/sec PPV), and these levels could reach 72 VdB (approximately 0.0 16 in/sec PPV) where trucks pass over bumps in the road (FTA, 2006). In terms of PPV levels, a heavy-duty vehicle traveling at a distance of 50 feet can result in a vibration level of approximately 0.001 inch per second. Sensitive Receptors Noise -sensitive receptors are locations where people reside or where the presence of unwanted sound could adversely affect or disrupt the types of activities associated with the land use at the LA County Flood Control District 3.10-6 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures location. Land uses such as residences, hotels, schools, rest homes, libraries, churches, and hospitals are generally more sensitive to noise than commercial and industrial land uses. As such, these types of land uses are considered to be noise -sensitive receptors. Given that the majority of the County is highly urbanized with a variety of land use types (e.g., open space, residential, commercial, mixed-use, public and semi-public, and industrial uses), and that the proposed program would be located in various watersheds across the County that span multiple jurisdictions, existing noise -sensitive uses such as residences, schools, guest lodging, hospitals, churches, parks, etc. would be located within and in proximity to the EWMP areas. As described in Section 3.9, Land Use and Agriculture, of this Program Environmental Impact Report (PEIR), many of the EWMP areas, including Ballona Creek, Beach Cities, Dominguez Channel, and Marina del Rey, have residential uses as the predominant land use. 301003 Regulatory Setting Federal Federal Noise Standards There are no federal noise standards that directly regulate environmental noise related to the construction or operation of the proposed program. With regard to noise exposure and workers, the Office of Safety and Health Administration (OSHA) regulations safeguard the hearing of workers exposed to occupational noise. Federal regulations also establish noise limits for medium and heavy trucks (more than 4.5 tons, gross vehicle weight rating) under 40 Code of Federal Regulations (CFR), Part 205, Subpart B. The federal truck pass -by noise standard is 80 dBA at 15 meters from the vehicle pathway centerline. These controls are implemented through regulatory controls on truck manufacturers. Federal Transit Authority Vibration Standards The FTA has adopted vibration standards that are used to evaluate potential building damage impacts related to construction activities. The vibration damage criteria adopted by the FTA are shown in Table 3.10-1. TABLE 3.10-1 CONSTRUCTION VIBRATION DAMAGE CRITERIA Building Category PPV (in/sec) I. Reinforced concrete, steel or timber (no plaster) 0.5 II. Engineered concrete and masonry (no plaster) 0.3 III. Non -engineered timber and masonry buildings 0.2 IV. Buildings extremely susceptible to vibration damage 0.12 SOURCE: FTA, 2006. In addition, the FTA has also adopted standards associated with human annoyance for groundborne vibration impacts for the following three land -use categories: Vibration Category 1 — High Sensitivity, Vibration Category 2 — Residential, and Vibration Category 3 — Institutional. LA County Flood Control District 3.10-7 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Pmgram Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures The FTA defines Category 1 as buildings where vibration would interfere with operations within the building, including vibration -sensitive research and manufacturing facilities, hospitals with vibration -sensitive equipment, and university research operations. Vibration -sensitive equipment includes, but is not limited to, electron microscopes, high-resolution lithographic equipment, and normal optical microscopes. Category 2 refers to all residential land uses and any buildings where people sleep, such as hotels and hospitals. Category 3 refers to institutional land uses such as schools, churches, other institutions, and quiet offices that do not have vibration -sensitive equipment, but still have the potential for activity interference. Under conditions where there are an infrequent number of events per day, the FTA has established thresholds of 65 VdB for Category 1 buildings, 80 VdB for Category 2 buildings, and 83 VdB for Category 3 buildings.1 Under conditions where there are an occasional number of events per day, the FTA has established thresholds of 65 VdB for Category 1 buildings, 75 VdB for Category 2 buildings, and 78 VdB for Category 3 buildings? No thresholds have been adopted or recommended for commercial and office uses. State California Department of Health Services Noise Standards The California Department of Health Services (DHS) has established guidelines for evaluating the compatibility of various land uses as a function of community noise exposure. These guidelines for land use and noise exposure compatibility are shown in Table 3.10-2. In addition, Section 65302(f) of the California Government Code requires each county and city in the State to prepare and adopt a comprehensive long-range general plan for its physical development, with Section 65302(g) requiring a noise element to be included in the general plan. The noise element must: (1) identify and appraise noise problems in the community; (2) recognize Office of Noise Control guidelines; and (3) analyze and quantify current and projected noise levels. The State of California also establishes noise limits for vehicles licensed to operate on public roads. For heavy trucks, the State pass -by standard is consistent with the federal limit of 80 dBA. The State pass -by standard for light trucks and passenger cars (less than 4.5 tons, gross vehicle rating) is also 80 dBA at 15 meters from the centerline. These standards are implemented through controls on vehicle manufacturers and by legal sanction of vehicle operators by state and local law enforcement officials. I "Infrequent events" is defined by the FTA as being fewer than 30 vibration events of the same kind per day. 2 "Occasional events" is defined by the FTA as between 30 and 70 vibration events of the same source per day. LA County Flood Control District 3.10-8 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental TABLE 3.10-2 COMMUNITY NOISE EXPOSURE (Ldn OR CNEL) and Mitigation Measures a Normally Acceptable: Specified land use is satisfactory, based upon the assumption that any buildings involved are of normal conventional construction without any special noise insulation requirements. b Conditionally Acceptable: New construction or development should be undertaken only after a detailed analysis of the noise reduction requirements is made and needed noise insulation features included in the design. Conventional construction, but with closed windows and fresh air supply systems or air conditioning will normally suffice. c Normally Unacceptable: New construction or development should generally be discouraged. If new construction or development does proceed, a detailed analysis of the noise reduction requirements must be made and needed noise insulation features included in the design. d Clearly Unacceptable: New construction or development should generally not be undertaken. SOURCE: Office of Planning and Research, State of California Genera Plan Guidelines, October 2003 (in coordination with the California Department of Health Services). State Vibration Standards There are no state vibration standards applicable to the proposed program. Moreover, according to the California Department of Transportation's (Caltrans') Transportation and Construction Vibration Guidance Manual (2013), there are no official Caltrans standards for vibration. However, this manual provides guidelines for assessing vibration damage potential to various types of buildings, ranging from 0.08 to 0.12 in/sec PPV for extremely fragile historic buildings, ruins, and ancient monuments to 0.50 to 2.0 in/sec PPV for modern industrial/commercial buildings. The vibration criteria for structural damage and human annoyance established in Caltrans' Transportation and Construction Vibration Guidance Manual (2013) are shown in Tables 3.10-3 and 3.10-4, respectively. LA County Flood Control District 3.10-9 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report Normally Conditionally Normally Clearly Land Use Acceptablea Acceptableb Unacceptablec Unacceptabled Single-family, Duplex, Mobile Homes 50-60 55-70 70-75 above 75 Multi -Family Homes 50-65 60-70 70-75 above 75 Schools, Libraries, Churches, 50-70 60-70 70-80 above 80 Hospitals, Nursing Homes Transient Lodging — Motels, Hotels 50-65 60-70 70-80 above 75 Auditoriums, Concert Halls, 50-70 --- above 70 Amphitheaters Sports Arena, —' 50-75 --- above 75 Outdoor Spectator Sports Playgrounds, Neighborhood Parks 50 - 70 -- 67-75 above 75 Golf Courses, Riding Stables, 50-75 -- 70-80 above 80 Water Recreation, Cemeteries Office Buildings, Business and 50-70 67-77 above 75 --- Professional Commercial Industrial, Manufacturing, Utilities, 50-75 70-80 above 75 -- Agriculture a Normally Acceptable: Specified land use is satisfactory, based upon the assumption that any buildings involved are of normal conventional construction without any special noise insulation requirements. b Conditionally Acceptable: New construction or development should be undertaken only after a detailed analysis of the noise reduction requirements is made and needed noise insulation features included in the design. Conventional construction, but with closed windows and fresh air supply systems or air conditioning will normally suffice. c Normally Unacceptable: New construction or development should generally be discouraged. If new construction or development does proceed, a detailed analysis of the noise reduction requirements must be made and needed noise insulation features included in the design. d Clearly Unacceptable: New construction or development should generally not be undertaken. SOURCE: Office of Planning and Research, State of California Genera Plan Guidelines, October 2003 (in coordination with the California Department of Health Services). State Vibration Standards There are no state vibration standards applicable to the proposed program. Moreover, according to the California Department of Transportation's (Caltrans') Transportation and Construction Vibration Guidance Manual (2013), there are no official Caltrans standards for vibration. However, this manual provides guidelines for assessing vibration damage potential to various types of buildings, ranging from 0.08 to 0.12 in/sec PPV for extremely fragile historic buildings, ruins, and ancient monuments to 0.50 to 2.0 in/sec PPV for modern industrial/commercial buildings. The vibration criteria for structural damage and human annoyance established in Caltrans' Transportation and Construction Vibration Guidance Manual (2013) are shown in Tables 3.10-3 and 3.10-4, respectively. LA County Flood Control District 3.10-9 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitiqation Measures TABLE 3.10-3 CALTRANS VIBRATION DAMAGE POTENTIAL THRESHOLD CRITERIA Maximum PPV (in/sec) Continuous/Frequent Structure and Condition Transient Sources Intermittent Sources Extremely fragile historic buildings, ruins, ancient monuments 0.12 0.08 Fragile buildings 0.2 0.1 Historic and some old buildings 0.5 0.25 Older residential structures 0.5 0.3 New residential structures 1.0 0.5 Modern industrial/commercial buildings 2.0 0.5 NOTE: Transient sources create a single isolated vibration event, such as blasting or drop balls. Continuous/frequent intermittent sources include impact pile -drivers, pogo -stick compactors, crack and -seat equipment, vibratory pile drivers, and vibratory compaction equipment. SOURCE: Caltrans, Transportation and Construction Vibration Guidance Manual, September 2013. TABLE 3.10-4 CALTRANS VIBRATION ANNOYANCE POTENTIAL CRITERIA Maximum PPV (in/sec) Continuous/Frequent Structure and Condition Transient Sources Intermittent Sources Barely perceptible 0.04 0.01 Distinctly perceptible 0.25 0.04 Strongly perceptible 0.9 0.10 Severe 2.0 0.4 NOTE: Transient sources create a single isolated vibration event, such as blasting or drop balls. Continuous/frequent intermittent sources include impact pile -drivers, pogo -stick compactors, crack and -seat equipment, vibratory pile drivers, and vibratory compaction equipment. SOURCE: Caltrans, Transportation and Construction Vibration Guidance Manual, September 2011 Local County of Los Angeles General Plan Noise Element The California Government Code Section 65302(g) requires that a noise element be included in the General Plan of each county and city in the state. The Noise Element of the County of Los Angeles General Plan was established as a planning tool to develop strategies and action programs that address the multitude of noise sources and issues throughout the County. The noise guidelines used by the County are based on the community noise compatibility guidelines established by the State of California DHS (refer to Table 3.10-2), as described above. Specific regulations that implement these guidelines are set forth in the Los Angeles County Municipal Code as discussed below. LA County Flood Control District 3.10-10 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Selling, Impacts, and Mitigation Measures County of Los Angeles Municipal Code Chapter 12.08, Noise Control, of the County of Los Angeles Municipal Code serves as the Noise Ordinance for the County and establishes noise standards to control unnecessary, excessive, and annoying noise and vibration in the County. Within Chapter 12.08 of the Los Angeles County Code, Section 12.08.380 assigned the following noise zones for receptor properties in the County: 1. Noise Zone 1 —Noise -sensitive areas 2. Noise Zone 2 — Residential properties 3. Noise Zone 3 — Commercial properties 4. Noise Zone 4 — Industrial properties With respect to operational noise, Section 12.08.390 of the Noise Ordinance established exterior noise levels that should be applied to all receptor properties within a designated noise zone in the County. These exterior noise levels are shown in Table 3.10-5. TABLE 3.10.5 COUNTY OF LOS ANGELES EXTERIOR NOISE STANDARDS BY NOISE ZONES Designated Noise Zone Land Use Noise Zone (Receptor Property) Time Interval Exterior Noise Level (dBA) I Noise -sensitive area Anytime 45 10:00 P.M. to 7:00 45 A.M. (nighttime) II Residential properties 7:00 A.M. to 10:00 50 P.M. (daytime) 10:00 P.M. to 7:00 55 A.M. (nighttime) III Commercial properties 7:00 A.M. to 10:00 60 P.M. (daytime) IV Industrial properties Anytime 70 SOURCE: County of Los Angeles Ordinance No. 11743, Section 12.08.390. The exterior noise levels shown in Table 3.10-5 are meant to be further applied as noise standards based on the duration of the noise; i.e., the louder the noise, the shorter the time it is allowed to last. The Noise Ordinance uses a number of noise metrics to define the permissible noise levels. These metrics include L50, 1,25, L8.3, L1,7, and Lmm,, and are based upon a 1 -hour timeframe which indicates exceedances of 50, 25, 8.3, and 1.7 percent of the time, plus the maximum sound level during that time period. The following noise standards should be applied to the exterior noise levels provided in Table 3.10-5: • Standard No. 1 shall be the exterior noise level that may not be exceeded for a cumulative period of more than 30 minutes in any hour. Standard No. 1 shall be the applicable noise IA County Flood Control District 3.10-11 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitiqation Measures level from Table 3.10-5; or, if the ambient L50 exceeds the forgoing level, then the ambient L50 becomes the exterior noise level for Standard No. 1. • Standard No. 2 shall be the exterior noise level that may not be exceeded for a cumulative period of more than 15 minutes in any hour. Standard No. 2 shall be the applicable noise level from Table 3.10-5 plus 5 dB(A); or, if the ambient L25 exceeds the forgoing level, then the ambient L25becomes the exterior noise level for Standard No. 2. • Standard No. 3 shall be the exterior noise level that may not be exceeded for a cumulative period of more than 5 minutes in any hour. Standard No. 3 shall be the applicable noise level from Table 3.10-5 plus 20 dB(A); or, if the ambient L8,3 exceeds the forgoing level, then the ambient L8.3becomes the exterior noise level for Standard No. 3. • Standard No. 4 shall be the exterior noise level that may not be exceeded for a cumulative period of more than one minute in any hour. Standard No. 4 shall be the applicable noise level from Table 3.10-5 plus 15 dB(A); or, if the ambient Lt.7 exceeds the forgoing level, then the ambient L1.7 becomes the exterior noise level for Standard No. 4. • Standard No. 5 shall be the exterior noise level that may not be exceeded for any period of time. Standard No. 5 shall be the applicable noise level from Table 3.10-5 plus 20 dB(A); or, if the ambient Lo exceeds the forgoing level, then the ambient Lo becomes the exterior noise level for Standard No. 5. Section 12.08.400 of the Noise Ordinance also established interior noise standards for dwelling units in the County based on the allowable interior noise levels shown in Table 3.10-6. TABLE 3.10-6 COUNTY OF LOS ANGELES INTERIOR NOISE STANDARDS FOR DWELLING UNITS Designated Allowable Interior Noise Zone Land Use Time Interval Noise Level (dBA) Multifamily 10:00 P.M. to 7:00 A.M. 40 All Residential 7:00 A.M. to 10:00 P.M. 45 SOURCE: County of Los Angeles Ordinance No. 11743, Section 12.08.400. As indicated in Section 12.08.400, no person is allowed to operate or cause to be operated within a dwelling unit any source of sound, or allow the creation of any noise, that causes the noise level when measured inside a neighboring receiving dwelling unit to exceed the following standards: Standard No. 1. The applicable interior noise level from Table 3.10-6 for cumulative period of more than 5 minutes in any hour. • Standard No. 2. The applicable interior noise level from Table 3.10-6 plus 5 dB(A) for a cumulative period of more than 1 minute in any hour. Standard No. 3. The applicable interior noise level from Table 3.10-6 plus 10 dB(A) or the maximum measured ambient noise level for any period of time. IA County Flood Control District 3.10-12 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Selling, Impacts, and Mitigation Measures With respect to construction noise in the County, Section 12.08.440 of the Noise Ordinance prohibits the operation of any tools or equipment used between weekday hours of 7:00 P.M. and 7:00 A.M., or at any time on Sundays or holidays, that will create a noise disturbance across a residential or commercial real -property line. The only exceptions would be emergency work or public safety projects (Section 12.08.0570, part 5, exemption H, Public Health and Safety Activities) or by variance issued by the health officer. Additionally, both the working hours and maximum levels of equipment and activity noise that are allowable from both mobile and stationary equipment in the County are defined by land use and shown in Table 3.10-7. TABLE 3.10-7 COUNTY OF LOS ANGELES CONSTRUCTION NOISE STANDARDS Residential Structures Single -Family Multi -Family Semi-Residential/Commercial Allowable Work Dates Mobile Stationary Mobile Stationary Mobile Stationary &Hours Equipment' Equipment" Equipment' Equipment" Equipment' Equipment" Daily 7:00 A.M. to 75 dBA 60 dBA 80 dBA 65 dBA 85 dBA 70 dBA 8:00 P.M.` Daily 8:00 P.M. to 60 dBA 50 dBA 64 dBA 55 dBA 70 dBA 60 dBA 7:00 A.M." Business Structures Daily° 85 dBA ' Represents maximum noise levels for nonscheduled, intermittent, short-term operation (less than 10 days). ° Represents maximum noise level for repetitively scheduled and relative) long-term operation (periods of 10 days or more). ` Exception for Sundays and legal holidays. d Includes all day Sunday and legal holidays. SOURCE: County of Los Angeles Ordinance No. 11743, Section 12.08.440. County of Los Angeles Groundborne Vibration Regulation With respect to vibration, the County Noise Ordinance identifies a presumed perception threshold of 0.01 inches per second over the range of 1 to 100 hertz . Section 12.08.560 of the County Noise Ordinance prohibits the operation of any device that creates vibration above the vibration perception threshold of any individual at or beyond the property boundary of the source if on private property, or at 150 feet (46 meters) from the source if on a public space or public right-of- way. City General Plans and Municipal Codes The EWMP areas associated with the proposed program are located in multiple jurisdictions of Los Angeles County, which aside from the County also includes 46 cities. Each of these cities has their own independent General Plan and municipal code that regulates noise levels from various sources within their jurisdictional boundaries. Given that a project -level analysis for each structural BMP proposed in the EWMPs is beyond the scope of this PEIR, an extensive listing of IA County Flood Control District 3.10-13 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures the noise policies and regulations of each of the participating Permittees is not provided in this PEIR. 3,10°4 Impact Assessment The proposed program's potential impacts have been assessed using the California Environmental Quality Act (CEQA) Guidelines Appendix G Checklist. The following sections discuss the key issue areas identified in the CEQA Guidelines with respect to the proposed program's potential effect due to noise and vibration. Thresholds of Significance For the purposes of this PEIR and consistency with Appendix G of the CEQA Guidelines, the proposed program would have a significant noise impact if it would: • Result in exposure of persons to, or generation of, noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. • Result in exposure of persons to, or generation of, excessive groundborne vibration or groundborne noise levels. • Result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project. • Result in a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project. • For a project located within an airport land use plan area, or, where such a plan has not been adopted, in an area within 2 miles of a public airport or public use airport, expose people residing or working in the area to excessive noise levels. • For a project located in the vicinity of a private airstrip, expose people residing or working in the project area to excessive noise levels. Program Impact Discussion Noise Levels Standard Exceedance Impact 3.10-1: The proposed program could result in exposure of persons to, or generation of, noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. Structural (Regional, Centralized, and Distributed) BMPs Construction Implementation of the proposed program would involve the installation of structural control measures that would be constructed as BMPs to reduce the impact of stormwater and non- storrnwater on receiving water quality within the EWMP areas. Construction of the various structural BMPs proposed in the EWMP is anticipated to occur intermittently over the program implementation period. The proposed locations of individual BMPs are subject to change throughout the EWMP planning process. Definitive construction equipment lists, material lists, LA County Flood Control District 3.10-14 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Selling, Impacts, and Mitigation Measures construction methods, construction schedules, and workforce details would be developed in the future as specific structural BMP projects are finalized according to the EWMPs. The construction noise impacts associated with each individual structural BMP project would be short-term in nature and limited to the period of time when construction activity is taking place for that particular project. Construction activity noise levels at and near each structural BMP construction site would fluctuate depending on the particular type, number, and duration of usage of various pieces of construction equipment. Generally, development at each BMP construction site may require the use of heavy construction equipment for activities such as site preparation, grading and excavation, and the physical development of the structural BMP. Development activities could also involve the use of smaller power tools, generators, and other sources of noise. During each stage of development for each individual structural BMP project, there would be a different mix of equipment operating and noise levels would vary based on the amount and type of equipment in operation and the location of the activity. The USEPA has compiled data for outdoor noise levels for typical construction activities. These data are presented in Table 3.10-8. The noise levels shown in Table 3.10-8 represent composite noise levels associated with typical construction activities, which take into account both the number of pieces and spacing of heavy construction equipment that are typically used during each phase of construction. These noise levels would diminish rapidly with distance from the construction site at a rate of approximately 6 dBA per doubling of distance. For example, a noise level of 84 dBA LeQ measured at 50 feet from the noise source to the receptor would reduce to 78 dBA LeQ at 100 feet from the source to the receptor, and reduce by another 6 dBA Leq to 72 dBA LeQ at 200 feet from the source to the receptor. Table 3.10-9 shows the typical maximum and average noise levels produced by various types of construction equipment. TABLE 3.10-8 TYPICAL OUTDOOR CONSTRUCTION NOISE LEVELS Construction Phase Noise Level (dBA, Lem`' Ground Clearing 84 Excavation 89 Foundations 78 Erection 85 Finishing 89 a Average noise levels correspond to a distance of 50 feet from the noisiest piece of equipment associated with a given phase of construction and 200 feet from the rest of the equipment associated with that phase. SOURCE: USEPA, 1971. IA County Flood Control District 3.10-15 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitiqation Measures TABLE 3.10-9 TYPICAL NOISE LEVELS FROM CONSTRUCTION EQUIPMENT Construction Equipment Maximum Noise Level (dBA, Lma, at 50 feet ) Average Noise Level (dBA, L,q at 50 feet)' Air Compressor 78 74 Backhoe 78 74 Chain Saw 84 77 Compactor (Ground) 83 76 Concrete Mixer Truck 79 75 Concrete Pump Truck 81 74 Concrete Saw 90 83 Crane 81 73 Dozer 82 78 Dump Truck 77 73 Excavator 81 77 Generator 82 79 Flat -Bed Truck 74 70 Front End Loader 79 75 Grader 85 81 Jack Hammer 89 82 Pavement Scarafier 90 83 Paver 77 74 Pneumatic Tool 85 82 Pumps 81 78 Roller 80 73 Scraper 84 80 Tractor 84 80 Vacuum Street Sweeper 82 72 Vibratory Concrete Mixer 80 73 Welder/Torch 74 70 a The average noise levels for the construction equipment at 50 feet were calculated from the maximum noise levels using the usage factors for each piece of equipment provided in the FHWA's RCNM. SOURCE: FHWA, 2006. As shown in Table 3.10-8, excavation activities can typically generate noise levels of 89 dBA LeQ at 50 feet from the construction noise source. Given the urbanized environment of many of the EWMP areas, many of the structural BMP projects would be constructed in proximity or adjacent to existing land uses, including those that are noise -sensitive uses. The construction activities for each structural BMP project would temporarily expose their respective existing off-site surrounding land uses to increased noise levels while construction activities are ongoing. This would be most applicable to the distributed BMPs, which are most likely to be implemented in LA County Flood Control District 3.10-16 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures high-density urban, commercial, industrial, and transportation areas where they will either replace or improve upon existing stormwater infrastructure. While the larger centralized and regional structural BMP projects (which require a larger footprint than the distributed BMPs) would occur mostly in existing open space areas that may have greater buffer distances to nearby surrounding land uses, there may still be incidences where a proposed centralized or regional structural BMP site could be located directly adjacent to an existing noise -sensitive land use. Where a proposed structural BMP site is located adjacent or in proximity to existing land uses, the construction activities at the structural BMP site would expose these off-site land uses to increased temporary and intermittent noise levels that are substantially greater than existing ambient noise levels in the area. While construction noise levels may be exempt from the noise regulations of most of the implementing agencies, there may also be instances where some of the implementing agencies have their own established numerical noise standard for construction noise levels, such as the County of Los Angeles, City of Los Angeles, and the City of El Segundo. Although it is generally anticipated that construction of the structural BMPs would comply with such construction noise standards, there may be scenarios where these local numerical noise standards could potentially be exceeded. As a result, under these conditions, construction noise impacts would be potentially significant. Mitigation Measure NOISE -1 would reduce construction noise impacts, requiring construction activities to be conducted in accordance with the applicable local noise regulations and standards, the implementation of noise reduction devices and techniques during construction activities, and advance notification to the surrounding noise -sensitive receptors of a structural BMP site about upcoming construction activities and their hours of operation. This would serve to reduce the construction -related noise levels at nearby receptors to the maximum extent feasible. However, as discussed previously, for implementing agencies that have established numerical noise standards for construction activities, there may be circumstances where the construction activities for a particular structural BMP project may exceed established thresholds.. Because of the possibility that certain structural BMP projects may exceed noise levels established by their respective local jurisdictions, this impact would be significant and unavoidable. Operation As discussed previously, the majority of the distributed, centralized, and regional structural BMPs would operate passively in the sense that they would not require the use of mechanized stationary equipment for their operation; however, it is anticipated that some of the centralized and regional structural BMPs would require the use of irrigation pump stations and associated components to divert the collected stormwater. At these structural BMP sites, operational noise levels would result from operation of the pumps and associated components. However, as a stationary noise source, the pumping equipment used at a structural BMP site would be required to comply with the applicable exterior noise standards and/or regulations established by the implementing agency that has jurisdiction over the site. Additionally, it is anticipated that many of the irrigation pumps would be located belowground and all other noise -producing components (e.g., generators) would be enclosed. As such, the noise levels generated by on-site pumps and associated components at structural BMP sites associated with the project would not exceed or violate noise standards and regulations established by implementing agencies in the EWMP areas. Mitigation Measure NOISE -2 would be implemented to ensure that the operational noise levels occurring at structural LA County Flood Control District 3.10-17 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures BMP sites that employ stationary mechanized equipment would be required to adhere and comply with the local noise standards established by the responsible implementing agency. Thus, with implementation of Mitigation Measure NOISE -2, operational noise impacts would be less than significant. Mitigation Measures: NOISE -1: The implementing agencies shall implement the following measures during construction as needed: • Include design measures necessary to reduce the construction noise levels to where feasible. These measures may include noise barriers, curtains, or shields. • Place noise -generating construction activities (e.g., operation of compressors and generators, cement mixing, general truck idling) as far as possible from the nearest noise -sensitive land uses. • Locate stationary construction noise sources as far from adjacent noise -sensitive receptors as possible. • If construction is to occur near a school, the construction contractor shall coordinate the with school administration in order to limit disturbance to the campus. Efforts to limit construction activities to non -school days shall be encouraged. • For the centralized and regional BMP projects located adjacent to noise -sensitive land uses, identify a liaison for these off-site sensitive receptors, such as residents and property owners, to contact with concerns regarding construction noise and vibration. The liaison's telephone number(s) shall be prominently displayed at construction locations. • For the centralized and regional BMP projects located adjacent to noise -sensitive land uses, notify in writing all landowners and occupants of properties adjacent to the construction area of the anticipated construction schedule at least 2 weeks prior to groundbreaking. NOISE -2: All structural BMPs that employ mechanized stationary equipment that generate noise levels shall comply with the applicable noise standards established by the implementing agency with jurisdiction over the structural BMP site. The equipment shall be designed with noise -attenuating features (e.g., enclosures) and/or located at areas (e.g., belowground) where nearby noise -sensitive land uses would not be exposed to a perceptible noise increase in their noise environment. LA County Flood Control District 3.10-18 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental selling, Impacts, and Mitigation Measures Significance Determination: Significant and unavoidable with mitigation for construction; less than significant with mitigation for operations. (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.10-11.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts related to construction noise. Mitigation Measures: None required Significance Determination: No impact Groundborne Vibration Impact 3.10-2: The proposed program could result in exposure of persons to, or generation of, excessive groundborne vibration, Structural (Regional, Centralized, and Distributed) BMPs Construction of many of the structural BMP projects would include activities such as site preparation, grading, and excavation, which would have the potential to generate low levels of groundbome vibration. Persons residing and working in an area located in proximity to a structural BMP site could be exposed to some degree of groundborne vibration or groundborne noise levels related to construction activities. Ground vibrations from construction activities only rarely reach the levels that can damage structures, but they can be perceived in the audible range and be felt in buildings very close to a construction site. Construction activities for the various structural BMP projects would have the potential to impact their respective nearby land uses. Given the urbanized environment of the County, the potential exists for construction of a structural BMP project, especially the distributed structural BMPs that would most likely be implemented in existing high-density areas, to be located within 25 feet of an adjacent noise -sensitive land use. Consequently, existing off-site receptors that are located immediately adjacent to these structural BMP sites could be exposed to some degree of groundbome vibration. The various PPV and RMS velocity (in VdB) levels for the types of construction equipment that could operate during the construction of the structural BMP projects are identified in Table 3.10-10. Based on the information presented in Table 3.10-11, vibration velocities could reach as high as approximately 0.089 -inch -per -second PPV at 25 feet from the operation of a large bulldozer. This corresponds to an RMS velocity level (in VdB) of 87 VdB at 25 feet from the large bulldozer. For the types of construction methods required to construct the various structural BMPs, vibration levels at nearby sensitive receptors would not approach the Caltrans damage thresholds presented in Table 3.10-3. Although some vibration may be experienced locally, vibration -related impacts from implementation of structural BMPs would be less than significant. LA County Flood Control District 3.10-19 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures TABLE 3.10-10 VIBRATION VELOCITIES FOR CONSTRUCTION EQUIPMENT Construction Equipment PPV at 25 feet (inches/second) RMS at 25 feet (VdB) Large Bulldozer 0.089 87 Loaded Trucks 0.076 86 Jackhammer 0.035 79 Small Bulldozer 0.003 58 SOURCE: FTA, 2006. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPS As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts related to groundborne vibration or noise. Mitigation Measures: None required Significance Determination: No impact Permanent Ambient Noise Levels Increase Impact 3.10-3: The proposed program could result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project, Structural (Regional, Centralized, and Distributed) BMPs Given that the majority of the distributed, centralized, and regional structural BMPs would operate in a passive manner (i.e., would not require the use of mechanized stationary equipment) after their construction, no operational noise levels would be generated by these structural BMPs. However, it is anticipated that that some of the centralized and regional structural BMPs would require the use of irrigation pump stations and associated components to divert the collected stormwater. At these structural BMP sites, noise levels generated from the long-term operation of the pumps and associated components could result in increased noise levels in the surrounding noise environment. However, as discussed under Impact 3.10-1, the pumping equipment used at a structural BMP site would be required to comply with the applicable exterior noise standards and/or regulations established by the implementing agency that has jurisdiction over the site. In addition, many of the irrigation pumps would primarily be located belowground and all other noise -producing components (e.g., generators) would be enclosed. Furthermore, with implementation of Mitigation Measure NOISE-I,which would require the stationary mechanized equipment employed at each structural BMP site to comply with the local noise LA County Flood Control District 3.10-20 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures standards established by the responsible implementing agency with jurisdiction over the site, and for the equipment to be designed and located in a manner such that neighboring sensitive land uses would not be exposed to a perceptible noise increase in their environment (Mitigation Measure NOISE -2), this impact would be less than significant. Mitigation Measures: Implementation of Mitigation Measures NOISE -1 and NOISE -2 Significance Determination: Less than significant with mitigation (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.10-11.) Non -Structural (Institutional) BMPS As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPS do not include the operation of new facilities. Consequently, there would be no impacts related to a substantial permanent increase in ambient noise levels resulting from implementation of the non- structural BMPS. Mitigation Measures: None required Significance Determination: No impact Temporary Ambient Noise Levels Increase Impact 3.10-4: The proposed program could result in a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project. Structural (Regional, Centralized, and Distributed) BMPS During construction of the distributed, centralized, and regional structural BMPS, temporary or periodic increases in noise levels in and around each structural BMP site would result from the operation of construction equipment. As discussed in Impact 3.10-1, the construction activities for each individual structural BMP project would expose their respective nearby existing land uses to increased noise levels. Where a structural BMP site is located within 25 feet of an existing noise -sensitive land use, the resulting constriction noise levels at that existing land use could reach as high as 95 dBA L,q during excavation activities, which would result in a substantial noise increase over existing ambient noise levels at that existing land use. Although implementation of Mitigation Measure NOISE -1 would reduce construction noise levels associated with the proposed program to the maximum extent feasible, under circumstances where future structural BMP sites are located immediately adjacent to existing sensitive land uses, the noise impacts related to a substantial temporary or periodic increase in ambient noise levels above levels existing without the structural BMPS would remain significant. Therefore, this impact for the proposed program would be significant and unavoidable. The identification of a significant and unavoidable program -level impact in this PEIR for the proposed program, however, does not preclude the finding of future less -than -significant impacts for individual structural BMP projects. LA County Flood Control District 3.10-21 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures Mitigation Measures: Implementation of Mitigation Measure NOISE -1 Significance Determination: Significant and unavoidable with mitigation (The application of this mitigation measure to specific BMP types and categories are identified in Table 3.10-11.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts related to a substantial temporary or periodic increase in ambient noise levels resulting from implementation of the non-structural BMPs. Mitigation Measures: None required Significance Determination: No impact Exposure of Excessive Airport Noise Levels Impact 3.10-5: For a project located within an airport land use plan area, or, where such a plan has not been adopted, in an area within 2 miles of a public airport or public use airport, implementation of the proposed program could expose people residing or working in the area to excessive noise levels. Structural (Regional, Centralized, and Distributed) BMPs The Distributed, Centralized, and Regional structural BMPs that would be implemented as part of the proposed program would serve to reduce the impact of stormwater and non-stormwater on receiving water quality and address the water quality priorities as defined by the MS4 Permit. While some of these structural BMPs could potentially occur at paved areas of airports (excluding the landing areas and taxiways, which have specific aircraft support requirements) and the undeveloped buffer zones around airports, no permanent residents or workers would be introduced to these areas under the proposed program. While maintenance and inspection of the structural BMPs would occur, these activities would only occur periodically and would be minimal during project operations. Therefore the proposed program would not introduce permanent future residents or workers to the structural BMP areas and as such would not expose persons to excessive airport -related noise levels. Exposure to airport noise would be a less than significant impact. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts related to the exposure of people to excessive noise levels associated with a public airport or public use airport. Mitigation Measures: None required LA County Flood Control District 3.10-22 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Selling, Impacts, and Mitigation Measures Significance Determination: No impact Exposure of Persons to Excessive Private Airstrip Noise Levels Impact 3.10-6: For a project located in the vicinity of a private airstrip, the proposed program could expose people residing or working in the project area to excessive noise levels. Structural (Regional, Centralized, and Distributed) BMPs As discussed under Impact 3.10-5 above, the proposed program would not introduce permanent future residents or workers to the structural BMP areas. Thus, while future structural BMP sites could be located in the vicinity of private airstrips, no persons would be exposed to excessive airstrip -related noise levels. Exposure to airstrip -related noise would be a less than significant impact. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts related to the exposure of people to excessive noise levels associated with a private airstrip. Mitigation Measures: None required Significance Determination: No impact Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs Noise and vibration are both defined as localized phenomena that significantly reduce in magnitude as distance from the source increases. The structural BMPs associated with the proposed program would be constructed in multiple jurisdictions of Los Angeles County, which aside from the County also includes 46 cities and LACFCD. As such, these structural BMP projects would be generally spread over a large geographic area within the County. These structural BMPs in combination with other current and planned projects in the County would result in an increase in construction -related noise levels, which would temporarily increase the ambient noise levels of the existing noise environment in areas where a construction project would occur. This would result in significant and unavoidable impacts for construction, but less than significant for operation. Mitigation Measures: Implementation of Mitigation Measures NOISE -1 and NOISE -2 LA County Flood Control District 3.10-23 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures Significance Determination: Significant and unavoidable with mitigation for construction; Less than significant for operation. (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.10-11.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no new facilities that would contribute to cumulative noise impacts. As such, no impacts related to cumulative noise would occur. Mitigation Measures: None required Significance Determination: No impact LA County Flood Control District 3.10-24 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Selling, Impacts, and Mitigation Measures Summary of Impact Assessment Table 3.10-11 shows a summary of the structural BMPs requiring mitigation. TABLE 3.10-11 SUMMARY OF NOISE IMPACTS REQUIRING MITIGATION MEASURES Regional BMPs Applicable Mitigation Measures: Exceed Noise Standards NOISE -1; NOISE- 2 Thresholds of Significance Ambient Vibration Noise None Required NOISE -1 Exposure to Airport Noise None Required Cumulative Impacts NOISE -1; NOISE -2 Regional Detention and Yes Yes Yes No Yes Infiltration Regional Capture, Yes Yes Yes No Yes Detention and Use Centralized BIVP Bioinfiltration Yes Yes Yes No Yes Constructed Wetlands No No No No No Treatment/Low Flow No No No No No Diversions Creek, River, Estuary No No No No No Restoration Distributed BMs Site Scale Detention No No No No No LID — Infiltration/Filtration No No No No No BMPs — Porous Pavement, Green Streets, Bioswale/Filter Strips, downspout disconnects LID— Green Infrastructure No No No No No — Capture and Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes Flow through Treatment No No No No No BMPs Source Control Treatment No No No No No BMPs (catch basin inserts/screens, hydrodynamic separators, gross solids removal devices) Low Flow Diversions No No No No No NOTE: These conclusions are based on typical size and function of BMPs. LA County Flood Control District 3.10-25 ESA 1140379 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.11 Population and Housing and Environmental Justice This section examines the existing population, housing, and employment conditions in Los Angeles County (County) as a whole. Data presented in this section was obtained from two U.S. Census Bureau data sets: 2010 census files and 2008-2012 American Community Survey (ACS) 5 -year estimates. According to Section 15382 of the California Environmental Quality Act (CEQA) Guidelines, "An economic or social change by itself shall not be considered a significant impact on the environment." Socioeconomic characteristics should be considered in an Environmental Impact Report (EIR) only to the extent that they create adverse impacts on the physical environment. 3.11.1 Environmental Setting Population The proposed program is located in Los Angeles County, which has a population of approximately 10,017,068 people (U.S. Census Bureau, 2013). Like much of the Southern California region, Los Angeles County has experienced a population increase over the past decade. Between 2000 and 2012, the County experienced a growth rate of 3.8 percent, roughly two and a half times below the rest of the Southern California Association of Governments (SLAG) Region (10.4 percent) (SCAG, 2013). The County's population is estimated to grow to 11,353,000 by 2035 (SCAG, 2012). Demographics According to the 2008-2012 ACS 5 -year estimates data, the racial breakdown of Los Angeles County's population is as follows: • 27.8 percent White • 47.7 percent Hispanic or Latino of any race • 13.7 percent Asian • 8.2 percent Black/African American • 0.2 percent American Indian and Alaska Native • 0.2 percent Native Hawaiian and Other Pacific Islander 2.2 percent Other (two or more races; some other race) The general distribution of demographics around the County based on 2010 census data shows that the Hispanic and Black/African American populations are most highly concentrated within the center of the County's coastal basin, with the Black/African American population most highly concentrated within the cities of Baldwin Hills, Inglewood, Compton, and Carson. White populations within the County are most concentrated along the coastal western County boundary from Malibu down to Palos Verdes and along the coastal southern County boundary from Long Beach to Los Alamitos. The White populations are also concentrated along the Santa Monica Mountains and northern County limits, interspersed with mainly Hispanic and Asian populations IA County Flood Control District 3.11-1 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.11 Population and Housing and Environmental Justice in the central San Fernando Valley. Concentrations of the Asian populations exist around South San Gabriel and North El Monte, as well as around mid -city Los Angeles, Westwood, Torrance, and Norwalk (Cable, 2013). Income In the County of Los Angeles, the median household income is $56,241 according to the 2008- 2012 ACS 5 -Year Estimates data. Between the years of 2000 and 2012, the median household income for the County increased by an average of $11,691 annually. Median household income levels vary widely by census tract throughout the County, with lower-income tracts primarily located in central, east, and south Los Angeles. Other lower-income census tracts lie in the northern edges of the County, including some in the cities of Palmdale and Lancaster. The median household annual income for all cities/Permittees included in the 12 EWMP areas ranges from $41,538 in the City of Industry to over $250,000 in the City of Hidden Hills. This represents over a $200,000 range in the EWMP areas. The cities'/Permittees' median household income is $75,350, which is almost $20,000 higher than the County median household income level. TABLE 3.11-1 2014 LOS ANGELES COUNTY AREA MEDIAN HOUSEHOLD INCOME CLASSIFICATION IN U.S. DOLLARS 2 persons in household 3 persons in household 4 persons in household Extremely low income 20,500 23,050 25,600 Very low income 34,200 38,450 42,700 Low Income' 54,650 61,500 68,300 Median Income 51,850 58,300 64,800 Moderate Income 62,200 70,000 77,750 "Low income exceeding median income is an anomaly just for LA County due to HUD historical high cost adjustments to median. Household lower-income figures are derived based on very -low income figures not adjusted by HUD to account for any exceptions. SOURCE: California Department of Community Development, 2014 Median household income varies greatly throughout Los Angeles neighborhoods. "High" median household income levels are concentrated mostly along the western boundary of the County along the coast and in Santa Clarita bordering Ventura County. These areas include the majority of the Upper Santa Clara River, Malibu Creek, North Santa Monica Bay, Beach Cities, and Palos Verdes Peninsula EWMP areas, along with parts of the Santa Monica Bay Jurisdictions 2 and 3 and the Ballona Creek EWMP areas. "Low" median household income areas are concentrated in the southern center of the County, and include parts of the Upper Los Angeles River, Ballona Creek, and Dominguez Channel EWMP areas. "Medium" median household income areas are more evenly interspersed throughout the County (Los Angeles Times, 2014). IA County Flood Control District 3.11-2 ESA / 140674 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.11 Population and Housing and Environmental Justice Housing There are approximately 3,441,416 housing units in Los Angeles County, with an average household size of 3.19 for owner -occupied units and 2.84 for renter -occupied units (U.S. Census Bureau, 2008-2012). As for housing tenure, 47.3 percent of County units are owner -occupied and 52.7 percent are renter -occupied units. The County homeowner vacancy rate is 1.7 percent and the rental vacancy rate is 4.5 percent; these vacancy rates are much lower than the national rates (2.3 percent of homeowners and 7.5 percent of rentals). Vacancy rates are an indicator of housing market balance in the County, where high vacancy rates demonstrate low demand and/or high prices, and low vacancy rates demonstrates high demand and/or low prices in the housing market. The County's vacancy rates are relatively low compared to the national level, indicating a relatively high demand for housing in the region. 3.11.2 Regulatory Setting Federal Executive Order 12898 outlines federal actions to address environmental justice in minority populations and low-income populations. Executive Order 12898 states that agencies shall identify and address disproportionately high and adverse human health or environmental effects on minority and low-income populations. A new working group was created to develop strategies for programs and policies regarding minority and low-income populations to: promote enforcement of all health and environmental statutes, improve research and data collection in relation to health and environment, identify different patterns of consumption of natural resources, and ensure greater public participation. Local County of Los Angeles General Plan A General Plan is a basic planning document that, alongside the zoning code, governs development in a city or county. The State requires each city and county to adopt a General Plan with seven mandatory elements: land use, open space, circulation, housing, noise, conservation, and safety, along with any number of optional elements as appropriate. The proposed EWMPs would be subject to the local plans and policies of the areas in which they are located. Because this Program Environmental Impact Report (PEIR) is a high-level assessment of projects spanning the entire County, it will discuss only the County -level goals and policies relating to the overall program. Housing Element (2014-2021) The Housing Element is a required section of the General Plan, and serves to address the existing and projected housing needs of a city or county, including their share of the regional housing need. State law requires each local government agency to update their Housing Element every 5 years, and submit it to the State Department of Housing and Community Development for review. Los Angeles County's Housing Element was updated most recently in early 2014 for the 2014-2021 planning period. This policy guide analyzes the housing needs of the unincorporated areas of the County, and its primary focus is to ensure decent, safe, sanitary, and affordable IA County Flood Control District 3.11-3 ESA / 140674 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.11 Population and Housing and Environmental Justice housing for current and future residents in those areas. The following are the goals and policies from the Los Angeles County Housing Element that relate to the proposed program. Goal 5: Neighborhoods that protect the health, safety, and welfare of the community, and enhance public and private efforts to maintain, reinvest in, and upgrade the existing housing supply. Policy 5.2: Maintain adequate neighborhood infrastructure, community facilities, and services as a means of sustaining the overall livability of neighborhoods. Goal 6: An adequate supply of housing preserved and maintained in sound condition, and located within safe and decent neighborhoods. Policy 6.4: Maintain and improve community facilities, public housing services, and infrastructure, where necessary, to enhance the vitality of older, low income neighborhoods. City General Plans The EWMP areas associated with the proposed program are located in multiple jurisdictions of Los Angeles County, which, aside from the County, also includes 46 cities. Each of these cities has their own independent General Plan and municipal code that regulates housing. Given that a project -level analysis for each structural Best Management Practice (BMP) proposed in the EWMPs is beyond the scope of this PEIR, an extensive listing of the housing policies and regulations of each of the participating Permittees is not provided in this PEIR. 3.11.3 Impacts Assessment Thresholds of Significance For the purposes of this PEIR and consistency with Appendix G of the CEQA Guidelines, the project would have a significant impact on population and housing if it would: • Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure). • Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere. • Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere. Implementation of the proposed project may result in a potentially significant impact to environmental justice if the projects would: • Affect the health or environment of minority or low-income populations disproportionately. IA County Flood Control District 3.11-4 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.11 Population and Housing and Environmental Justice Program Impact Discussion Impact 3.11-1: Implementation of the proposed program could induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure). Structural (Regional, Centralized, and Distributed) BMPs The structural BMPs associated with the proposed program would be installed to treat existing water quality impairments and would not induce population growth in the EWMP areas, either directly or indirectly. The structural BMPs are not habitable structures and would not provide new homes or businesses. In addition, the structural BMPs would generally be located within existing urbanized areas that do not have structural BMPs to treat existing runoff, the implementation of structural BMPs within existing stormwater infrastructure would not indirectly induce growth as the BMPs do not provide growth opportunities, as occurs with the extension of roads or other infrastructure. The construction work force anticipated to support implementation of the proposed projects would be drawn from the local Los Angeles region workforce and would not require housing. Because of the relatively short construction durations (typically less than one year) of the various types of structural BMPs and large available construction workforce in the Los Angeles Region, it is assumed that construction workers would not have to travel far or add traffic to roads outside of the vicinity of the project sites. In addition, while one of the main goals of the EWMP is to increase infiltration and potentially increase recharge of stormwater into the groundwater basin, the amount of water potentially recharged would not be enough to indirectly support population growth. This potential additional recharge would contribute to local water supplies, but would not alter population demographics. Therefore, there would be no impact on population growth, either directly or indirectly. Mitigation Measures: None required Significance Determination: No impact Non -Structural (Institutional) BMPs Non-structural BMPs consist of policies, actions, and activities aimed at preventing pollutants from entering stormwater runoff, therefore, no physical impacts would occur in the EWMP areas. Non-structural BMPs would not include any direct or indirect population growth -inducing measures. There would be no impact. Mitigation Measures: None required Significance Determination: No impact Impact 3.11-2: Implementation of the proposed program could displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere. IA County Flood Control District 3.11-5 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.11 Population and Housing and Environmental Justice Structural (Regional, Centralized, and Distributed) BMPs The proposed program and implementation of associated structural BMPs would not impact existing housing or necessitate construction of additional or replacement housing elsewhere. Structural BMPs may be constructed on private parcels, but would not displace existing housing or necessitate replacement housing elsewise. Although a property owner may decide to modify the structures on their property, that a structural BMP would not displace existing housing. Distributed BMPs are most likely to be implemented in high-density urban, commercial, industrial, and transportation areas where they would either replace or improve upon existing stormwater infrastructure. These types of BMPs are generally "retrofit' type projects that replace existing impervious surfaces with pervious surfaces such as bioinfiltration cells, bioswales, porous pavement, and filter strips that tie into existing stormwater management systems. These projects may also augment the existing stormwater management systems with additional inlet screens, filter media systems, sediment removal systems, and diversions to sanitary sewer lines. Ground disturbance for distributed BMPs is typically less than 1 to 2 acres in extent, but may extend in some limited applications up to 5 acres where space is available. Any new construction would be implemented along sidewalks and streets, in parks, and on publicly owned lands and would have no direct impact on existing homes. If projects are implemented in residential areas or streets, the projects would likely provide an improvement to the community in terms of aesthetic appearance. Mitigation Measures: None required Significance Determination: No impact Non -Structural (Institutional) BMPs The implementation of non-structural BMPs would not displace housing, as they do not involve structural elements and would not have a direct physical impact on the environment, as no construction or maintenance activities would be required. There would be no impact. Mitigation Measures: None required Significance Determination: No impact Impact 3.11-3: Implementation of the proposed program could displace substantial numbers of people, necessitating the construction of replacement housing elsewhere. Structural (Regional, Centralized, and Distributed) BMPs The currently planned program and implementation of associated structural BMPs would not displace any housing or people. Structural BMPs would generally be implemented along sidewalks and streets, in parks, and on publicly owned lands and would have no direct impact on existing homes or residents. Future regional and centralized structural BMPs under the EWMP may include private property, schools, and universities. These potential future structural BMPs are not anticipated to result in displacement of existing housing. IA County Flood Control District 3.11-6 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.11 Population and Housing and Environmental Justice Mitigation Measures: None required Significance Determination: No impact Non -Structural (Institutional) BMPs The implementation of non-structural BMPs would not displace any people, as they do not consist of structural improvements that would have a physical impact on the environment. No construction or maintenance activities would be required. There would be no impact. Mitigation Measures: None required Significance Determination: No impact Impact 3.11-4: Implementation of the proposed program could affect the health or environment of minority or low-income populations disproportionately. Structural (Regional, Centralized, and Distributed) BMPs Structural BMPs would be located throughout the County and cities based on water quality priorities and site suitability, factors of which include space, soil type, proximity/connectivity to other BMPs, etc. Structural BMPs are not expected to be concentrated in any one area or city in particular within the EWMP areas. The structural BMPs are expected to be located on public lands (e.g., schools, parks, sidewalks, and road rights-of-way) throughout the EWMP areas and would be designed to capture, convey, and/or filter stormwater and surface runoff. The structural BMPs would treat surface water runoff in a manner that would not result in human contact with surface flows that are potentially harmful to health. Structural BMPs would not disproportionately affect the health or environment of minority or low-income populations. Impacts would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant impact Non -Structural (Institutional) BMPs Similar to structural BMPs, non-structural BMPs are expected to be implemented throughout the County area, with no concentration in any area in particular. Non-structural BMPs would consist of policies and measures taken to prevent surface water pollution, and by their non-structural and preventative nature are not expected to introduce a threat to the environmental or public health, much less a disproportionate threat to minority or low-income populations. Street sweeping is a non-structural BMP that requires temporary parking restrictions to allow for effective collection and removal of debris and sediment from the streets. Curb parking spaces tend to be used more in higher -density, predominantly rental communities. Prior to implementation of increased street sweeping activities to improve effectiveness of these measures, the impact on street parking would be assessed and frequency of restriction on street parking assessed to avoid impacts to IA County Flood Control District 3.11-7 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.11 Population and Housing and Environmental Justice these communities that rely more heavily on street parking for residences and small businesses. Impacts would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant impact Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs The proposed program would involve implementation of structural BMPs that would capture and/or infiltrate, filter, divert, or treat stormwater runoff. Structural BMPs would result in the improvement of existing stormwater infrastructure and stormwater quality, and would therefore not result in a direct or indirect increase in population or housing. Structural BMPs would be installed along sidewalks and streets and in other public areas, and would not displace existing people or housing. There would be no impacts to population and housing; therefore, there would be no cumulative impacts to population and housing. Mitigation Measures: None required Significance Determination: No impact Non -Structural (Institutional) BMPs Non-structural BMPs consist of policies, actions, and activities aimed at preventing pollutants from entering stormwater runoff, there would not be physical impact to the environment. Non- structural BMPs would not include any direct or indirect population growth -inducing measures, and would not displace existing people or housing. There would be no impacts to population and housing; therefore, there would be no cumulative impacts to population and housing. Mitigation Measures: None required Significance Determination: No impact IA County Flood Control District 3.11-8 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.11 Population and Housing and Environmental Justice 3.11 e4 Summary of Impact Assessment Table 3.11-2 shows a summary of the structural BMPs requiring mitigation. TABLE 3.11-2 SUMMARY OF POPULATION AND HOUSING IMPACTS REQUIRING MITIGATION MEASURES Thresholds of Significance Structural BMPs Applicable Mitigation Measures: Population Growth None Required Displaced Housing None Required Displaced Population None Required Disproportionate Impact on Minority Populations None Required Cumulative Impacts None Required Regional BMs Regional Retention and No No No No No Infiltration Regional Capture, Detention and No No No No No Use Centralized BMP Biofiltration No No No No No Constructed Wetlands No No No No No Treatment/Low-Flow Diversions No No No No No Creek, River, Estuary Restoration No No No No No Distributed BMs Site Scale Detention No No No No No LID — Infiltration/Filtration BMPs— No No No No No Porous Pavement, Green Streets, Bioswale/Filter Strips, downspout disconnects LID— Green Infrastructure— No No No No No Capture and Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes Flow-through Treatment BMPs No No No No No Source Control Treatment BMPs No No No No No (catch basin inserts/screens, hydrodynamic separators, gross solids removal devices) Low -Flow Diversions No No No No No NOTE: These conclusions are based on Typical size and function of BMPs. IA County Flood Control District 3.11-9 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3,12 Public Services and Recreation This section addresses potential impacts on public services and recreational resources that could occur as a result of implementation of the proposed program. The public services addressed in this section include law enforcement services, fire protection services, and schools. 301201 Environmental Setting Public Services Fire Protection The Los Angeles County Fire Department (LACFD) serves unincorporated areas as well as many of the cities within the County; 21 of these cities are participating Permittees within the Enhanced Watershed Management Program (EWMP) areas. These cities include Hawthorne, West Hollywood, Malibu, Palos Verdes Estates, Rancho Palos Verdes, Rolling Hills Estates, Azusa, Bradbury, Duarte, Calabasas, Hidden Hills, La Canada Flintridge, Rosemead, San Gabriel, Temple City, Baldwin Park, Covina, Glendora, Industry, La Puente, and Santa Clarita (LACFD, 2013). LACFD employs approximately four thousand emergency personnel and works out of 170 fire stations across the County. In addition to fire suppression, the LACFD also provides fire prevention services, emergency medical services, hazardous materials services, and urban search and rescue services. LACFD is organized into three different emergency operations bureaus, the North, Central, and East Regional Operations Bureau. The North Regional Operations Bureau includes 43 fire stations serving communities in the Antelope and Santa Clarita Valleys. The Central Regional Operations Bureau includes 51 fire stations serving communities in the central Los Angeles portions of the County. It also includes the Lifeguard Division based in Venice, which helps protect millions of annual visitors along 74 miles of the Pacific Coast. The East Regional Operations Bureau includes 76 fire stations servicing communities within the east side of the County (LACFD, 2013). Under a mutual -aid pact covering federal forestlands, responsibility for nonstructural fires within the National Forest belongs to the U.S. Forest Service (USFS), while LACFD has the primary mission of suppressing structure fires. In addition, they have an automatic -aid agreement that allows the closest municipality to provide an initial response to fires that may occur in a part of another municipality. The LACFD has several standards to maintain adequate fire protection within their service area (Los Angeles County, 2014). The current standards for response times are: • 5 minutes or less for response times for urban areas • 8 minutes or less for suburban areas • 12 minutes or less for rural areas LACFD has designated lands in Los Angeles County with regard to their potential for wildland fires. These designations, determined by the County Forester, are based on an area's accessibility, IA County Flood Control District 3.12-1 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.12 Public Services and Recreation amount and type of vegetative cover, water availability, and topography. LACFD uses three wildland fire hazard designations: Moderate Fire Hazard, High Fire Hazard, and Very High Fire Hazard. Areas in Los Angeles County that are not designated within a fire hazard zone are not considered to be subject to wildland fire hazards (Los Angeles County, 2014). The following 26 EWMP participating Permittees run city -owned fire departments: Beverly Hills, Culver City, Inglewood, Santa Monica, Hermosa Beach, Manhattan Beach, Redondo Beach, Torrance, El Segundo, Agoura Hills, Westlake Village, Culver City, Malibu, Arcadia, Monrovia, Sierra Madre, Alhambra, Burbank, Glendale, Los Angeles, Montebello, Monterey Park, Pasadena, Rosemead, San Marino, and South Pasadena, (LACFD, 2013). Police Protection The Los Angeles County Sheriff s Department (LASD) provides law enforcement services to more than one million people living within 90 unincorporated communities and to more than four million residents living within 40 contract cities. In addition, LASD provides law enforcement services to nine community colleges, Metro, and 48 Superior Courts (Los Angeles County, 2014). LASD comprises 11 divisions, including 3 patrol divisions and the Office of Homeland Security. In addition to proactive enforcement of criminal laws, the LASD also provides investigative, traffic enforcement, accident investigation, and community education functions. Cities within the EWMP areas that contract with LASD for their police services include West Hollywood, Agoura Hills, Calabasas, Hidden Hills, Malibu, Westlake Village, Rancho Palos Verdes, Rolling Hills Estates, Rolling Hills. Duarte, Bradbury, Monrovia, Santa Clarita, Industry, La Puente, Glendora, Covina, Baldwin Park, Temple City, East Pasadena, Rosemead, La Canada Flintridge, Hidden Hills, and Calabasas. LASD staff has indicated that an officer -to -population ratio of 1 officer to every 1,000 residents provides the desired level of service for its service area (Los Angeles County, 2014). The LASD also has established an optimal service response time of 10 minutes or less for emergency response incidents (a crime that is presently occurring and is a life -or -death situation), 20 minutes or less for priority response incidents (a crime or incident that is currently occurring but is not a life -or -death situation), and 60 minutes or less for routine response incidents (a crime that has already occurred and is not a life -or -death situation). These response times represent the range of time required to handle a service call, which is measured from the time a call is received until the time a patrol car arrives at the incident scene. Response time is variable, particularly because the nearest responding patrol car may be located anywhere within the station's patrol area and may not necessarily respond directly from the station itself (Los Angeles County, 2014). Nineteen cities within the EWMP areas run their own city police departments; these cities are Beverly Hills, El Segundo, Culver City, Inglewood, Santa Monica, Los Angeles, Hermosa Beach, Manhattan Beach, Torrance, Hawthorne, Arcadia, San Marino, South Pasadena, San Gabriel, Burbank, Monterey Park, Montebello, Glendale, and Alhambra. IA County Flood Control District 3.12-2 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.11 Public Services and Recreation Schools Within the County there are more than two thousand public schools (not including colleges) that serve over 1.5 million students. The County's role in developing and managing educational facilities and programs is limited. However, the Los Angeles County Office of Education (LACOE) serves as a regional education agency and an intermediary between the local school districts and the California Department of Education. LACOE supports 80 public school districts and numerous other educational agencies within the County (LACOE, 2014). The largest public school district in the County is Los Angeles Unified School District (LAUSD), which has a service area of over 720 square miles and includes the City of Los Angeles, 31 smaller municipalities, and unincorporated areas. LAUSD has more than nine hundred schools and 640,000 students (LAUSD, 2014). There are several other smaller school districts in the EWMP study area. Table 3.12-1 lists the school districts in each EWMP area. Figure 3.12-1 shows the schools located throughout the EWMP areas, distinguishing between elementary schools, middle schools, high schools, and colleges; other schools such as pre-schools, colleges, and other types of education facilities are not shown. Watershed Management Group Ballona Creek Beach Cities Dominguez Channel Malibu Creek Marina del Rey North Santa Monica Bay TABLE 3.12-1 SCHOOL DISTRICTS IN EWMP AREAS Cities/Permittees Beverly Hills, Culver City, Inglewood, Los Angeles, Santa Monica, West Hollywood, County, LACFCD School Districts Beverly Hills USD, Culver City USD, Los Angeles USD, Santa Monica -Malibu USD, Hermosa Beach, Manhattan Beach, Redondo Hermosa Beach City School District, Manhattan Beach, Torrance, LACFCD Beach USD, Redondo Beach USD, Torrance USD, EI Segundo, Hawthorne, Inglewood, Los Angeles, LA County, LACFCD Agoura Hills, Calabasas, Hidden Hills, Westlake Village, LA County, LACFCD Culver City, Los Angeles, LACFCD, LA County LA County, LACFCD, Malibu EI Segundo USD, Hawthorne School District, Inglewood USD, Los Angeles USD, Las Virgenes USD, Los Angeles USD Culver City USD, Los Angeles USD Los Angeles USD, Santa Monica -Malibu USD, Palos Verdes Peninsula Palos Verdes Estates, Rancho Palos Verdes, Palos Verdes Area USD, Palos Verdes Peninsula Rolling Hills Estates, LA County, LACFCD USD, Los Angeles USD Rio Honda/San Gabriel River Arcadia, Azusa, Bradbury, Duarte, Monrovia, Arcadia USD, Duarte USD, Monrovia USD, Los County, LACFCD, Sierra Madre Angeles USD, Pasadena USD Santa Monica Bay Los Angeles, EI Segundo, Santa Monica, LA Los Angeles USD, el Segundo USD, Santa County, LACFCD Monica -Malibu USD Upper LA River Upper San Gabriel River Upper Santa Clare River USD: Unified School District SOURCE: Google, 2014. Alhambra, Burbank, Calabasas, Glendale, Hidden Hills, La Canada Flintridge, Los Angeles, Montebello, Monterey Park, Pasadena, Rosemead, San Gabriel, San Marino, South Pasadena, Temple City, LA County, LAFCD Baldwin Park, Covina, Glendora, Industry, La Puente, LACFCD, LA County LA County, LACFCD, Santa Clarita Alhambra USD, Burbank USD, Las Virgenes USD, La Canada USD, Los Angeles USD, Montebello USD, Pasadena USD, Rosemead School District, San Gabriel USD, San Marino USD, South Pasadena USD, Temple City USD Baldwin Park USD, Covina -Valley USD, Glendora USD, Los Angeles USD, Hacienda La Puente USD Los Angeles USD, Newhall School District IA County Flood Control District 3.12-3 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Ventura 0 It 8 Miles SOURCE: ESRI. Kern A m .14) •„.a'` �z a. o Elementary Schools • Middle Schools • High Schools EWMP Boundaries 1 - Ballon Creek - 2 - Beach Cities - 3 - Dominguez Channel 4 - Malibu Creek 5 - Marina Del Rey 6 - North Santa Monica Bay i_ 7 - Palos Verdes Peninsula 8 - Rio Hondo/San Gabriel River 9 - Santa Monica Bay Jurisdictions 2+3 10 - Upper LA River 11 -Upper San Gabriel River 12 - Upper Santa Clara River rz Los Angeles / u r � / \sw� ..��., ® San Bernardino r' �I PP /A f ,,,A / �A Orange LA County PEIR EWMP. 140474 Figure 3.12-1 Public School Locations 3. Environmental Settinq, Impacts, and Mitigation Measures 3.11 Public Services and Recreation Parks and Recreational Resources The County of Los Angeles Department of Parks and Recreation owns, operates, and maintains nearly 174 parks and recreational facilities (LADPR, 2014). The local park system encompasses approximately 609 total acres, and includes community parks (10 to 20 acres in size), neighborhood parks (3 to 10 acres in size), pocket parks (less than 3 acres in size), and park nodes (small pieces of open space that provide breaks to the urban landscape). Local parks serve neighborhoods within a maximum of a 2 -mile radius of the park. The regional park system makes up 68,986 acres and includes regional parks (greater than 100 acres), community regional parks (20 to 100 acres), and special -use facilities (single -use facilities serving greater recreational or cultural needs). The parks in the regional park system provide service for areas within a 20- to 25 - mile radius. Other recreational facilities available to County residents include trails, multi -benefit parks, school sites, city parks and facilities, private recreational facilities, and greenways (Los Angeles County, 2014). The County goal for the provision of parkland is 4 acres of local parkland per 1,000 residents of the population in the unincorporated areas, and 6 acres of regional parkland per 1,000 residents of the total population of Los Angeles County (Los Angeles County, 2014). Section 21.24.340 of the County Code has a standard of 3 acres of local and 5 acres of regional parkland per 1,000 residents. According to County estimates, there are currently a total of 1,066,414 people living in the unincorporated areas. This means that for every 1,000 residents there are a total of approximately 0.57 acres of local parkland, resulting in a local parkland deficit; the current acreage of available local parkland does not meet the County's goal for recreational facilities (Los Angeles County, 2014). In addition to the 609 acres of local parkland, there is a total of 68,986 acres of regional parkland in Los Angeles County at this time. For every 1,000 residents in Los Angeles County, there is a total of approximately 7 acres of regional parkland. There is a surplus of regional parkland, which exceeds the County's goal for regional parkland (Los Angeles County, 2014). Figure 3.12-2 shows the County parks present within the EWMP areas. Many of the cities/Permittees within the EWMP areas have city -owned and -operated parks. Given that a project -level analysis for each structural Best Management Practice (BMP) proposed in the EWMPs is beyond the scope of this Program Environmental Impact Report (PEIR), an extensive listing of each of the participating Permittees' parklands is not provided in this PEIR. 3°12°2 Regulatory Setting Local Los Angeles County General Plan State law requires every city and county to include an Open Space Element in their General Plan. Both the existing and draft County of Los Angeles General Plan include a Parks and Recreation Element that discusses recreational facilities available within the County boundaries, and goals and policies addressing the growing and diverse recreation needs of the region. The following are the parks and recreation goals and policies. IA County Flood Control District 3.12-5 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Parks 1 -Allen J. Martin Park 2 -Amelia Maybeny Park 3 -Atlantic Avenue Park 4 -Awards Heights Park 5 - Bassetl Perk 6 - Belvedere Perk 7 - Cry Terrace Park 8 - Dalton Park 9 - Eugene A. Obregon Paul 10 - Franklin D. Roosevelt Park 11 - McNees Park 12 - Rlmgrove Park 13 - Ruben E Salazar Park Ventura 14 -San Angeb Park 15-Saybrcok Park 16 -Sorensen Park 17 -Sunshine Perk 18 - Valleydak Perk 19 - Mona Park 20 - Del Aire Park 21 - Ray Commercial Perk 22 - East Rancho Dominguez Park 23 - Lennox Park 24 - Mary M. Bethune Park 25 -George W. Carver Park 26 - Enterprise Park LACounly Parks' 0 Participating Permittees EWMP Boundaries 1 - Ballon Creek - 2 - Beach Cities - 3 - Dominguez Channel 4 - Malibu Creek 5 - Marina Del Rey - 6 - North Santa Monica Bay - 7 - Palos Verdes Peninsula 8 - Rio Hondo/San Gabriel River 9 - Santa Monica Bay Jurisdictions 2+3 - 10 - Upper IA River - 11 - Upper San Gabriel River - 12 - Upper Santa Clara River SOURCE: ESRI. 27 - Ear in Magic Johnson Paris 28 - Helen Keller Park 29-Leders Park 30 -Col. Leon H. Washington Park 31 -Ted Watkins Park 32-Countrywood Park 33 -Thomas S. Boom Park 34 -Petroleums Park 35 - Los Robles Park 36 - Maximum Park 37 - William Steinmetz Perk 38 - Bill Eleven Park 39 - Rowland Heights Park 40 -Gloria Hear Perk 41-Traimiew Park 42-Cemlyn Rosas Park 43 -Pathfinder Perk 44 -Loma Alta Park 45-Chares C. Farnsworth Park 46-Chares White Perk 47 -Pestes Sports Complex 48 -Del Valle Park 49 -Hasley Canyon Park 50 -Charter Oak Park 51 -Pamela Park 52 -Concede Valley Park (14) MI n Los Angeles ME" 0 1 0 13 3 1 d ®30 (til0 ® n +6 ,u 55 631 31 ° 372519 6 36 1 59 31 33 63 -Two Strike Park 54 - MlchilliMa Perk 55 - Walnut Creek Park Be - Val Veda Park 57 - EI Carise Park Be - Versions Park 59 -Alondra Park 60 -ANens Park 61 - Deane Dana - Friendship Park 62 -Gunn Avenue Park (Adventure Park) 63 -Jesse Crams Park 64 -Arcadia Park 65RolPark San Bernardino Orange o T 8 I Miles LA County PEIR EWMP. 140474 Figure 3.12-2 County Park Locations 3. Environmental Settinq, Impacts, and Mitigation Measures 3.11 Public Services and Recreation Existing General Plan 1980 Goal: Provide Outdoor Recreation Areas. Policy 27: Provide low intensity outdoor recreation in areas of scenic and ecological value compatible with protection of these natural resources. Policy 28: Develop local parks in urban areas as part of urban revitalization projects, wherever possible. Draft General Plan 2035 Goal P/R 1: Enhanced active and passive park and recreation opportunities for all users. Policy P/R 1.4: Promote efficiency by building on existing recreation programs. Policy P/R 1.5: Ensure that County parks and recreational facilities are clean, safe, inviting, usable and accessible. Goal P/R 2: Enhanced multi -agency collaboration to leverage resources. Policy P/R 2.5: Support the development of multi -benefit parks and open spaces through collaborative efforts among entities such as cities, the County, state, and federal agencies, private groups, schools, private landowners, and other organizations. State law also requires the inclusion of a Safety Element that addresses environmental hazards and other safety concerns and aims to reduce the potential risk of death, injury, and economic damage resulting from natural and man-made hazards. The following presents the goals and policies in the existing and draft County of Los Angeles General Plan Safety Element. Existing General Plan 1980 Goal: Strengthen County short-term emergency response and long-term recovery capability. Policy 27: Strengthen the capability of County agencies to effectively respond to earthquake and non -earthquake induced emergencies. Policy 28: Upgrade regional heavy rescue capability including mobilization operations and resource management. Policy 29: Encourage critical facilities to maintain and regularly update emergency response plans identifying safety procedures, disaster control capabilities, and evacuation procedures such as drills and exercises. Policy 30: Upgrade interagency and multijurisdictional communications, planning and decision making to ensure efficient and integrated emergency response capability. IA County Flood Control District 3.12-7 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.12 Public Services and Recreation Policy 31: Promote improved cooperation with nonprofit and private sector emergency response organizations. Policy 35: Strengthen emergency communication systems and improve cooperation between the media and emergency response agencies. Goal: Continue to promote research on and mapping of natural and urban hazards: and improve safety information systems for planning, emergency response management and hazard mitigation. Policy 37: Encourage research that will lead to the detailed mapping of ground response (microzonation) of Los Angeles County. Draft General Plan 2035 Goal S 3: An effective regulatory system that prevents or minimizes personal injury, loss of life, and property damage due to fire hazards. Policy S 3.9: Adopt by reference the County of Los Angeles Fire Department Strategic Fire Plan, as amended. Goal S 4: Effective County emergency response management capabilities. Policy S 4.1: Ensure that residents are protected from the public health consequences of natural or man-made disasters through increased readiness and response capabilities, risk communication, and the dissemination of public information. Policy S 4.2: Support County emergency providers in reaching their response time goals. Policy S 4.3: Coordinate with other County and public agencies, such as transportation agencies and health care providers on emergency planning and response activities, and evacuation planning. Policy S 4.5: Ensure that there are adequate resources, such as sheriff and fire services, for emergency response. Los Angeles County Strategic Fire Plan LACED provides fire, safety, and emergency medical services to the unincorporated areas, as well as to several cities in the County. Their strategic plan is updated yearly and includes department goals and policies the department implements to ensure safety of residents and to carry out the County's public safety mission. City General Plans and Municipal Codes The EWMP areas associated with the proposed program are located in multiple jurisdictions of Los Angeles County, which, aside from the County, also includes 46 cities. Each of these cities has their own independent General Plan and municipal code that regulates public service levels IA County Flood Control District 3.12-8 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.11 Public Services and Recreation and recreation resources within their jurisdictional boundaries. Given that a project -level analysis for each structural BMP proposed in the EWMPs is beyond the scope of this PEIR, an extensive listing of the public service and recreation policies and goals of each of the participating Permittees is not provided in this PEIR. 3,12,3 Impact Assessment The proposed program's potential impacts were assessed using the California Environmental Quality Act (CEQA) Guidelines Appendix G Checklist. The following sections discuss the key issue areas identified in the CEQA Guidelines with respect to the proposed program's potential effects on public services and recreational resources. Thresholds of Significance For the purposes of this PEIR and consistency with Appendix G of the CEQA Guidelines, the project would have a significant impact on public services if the project would: Result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the following public services: o Fire protection o Police protection o Schools o Parks o Other public facilities Implementation of the proposed project may result in a potentially significant impact to recreational resources if the projects would: Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. Include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment. Program Impact Discussion Fire Protection Services Impact 3.12-1: The proposed program could result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered governmental fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for fire protection services. IA County Flood Control District 3.12-9 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.12 Public Services and Recreation Structural (Regional, Centralized, and Distributed) BMPs Distributed BMPs are most likely to be implemented in high-density urban, commercial, industrial, and transportation areas where they would either replace or improve upon existing stormwater infrastructure. These types of BMPs are generally "retrofit' -type projects that replace existing impervious surfaces with pervious surfaces such as bioinfiltration cells, bioswales, porous pavement, and filter strips that tie into existing stormwater management systems. These projects may also augment the existing stormwater management systems with additional inlet screens, filter media systems, sediment removal systems, and diversions to sanitary sewer lines. Ground disturbance for distributed BMPs is typically less than 1 to 2 acres in extent, but may extend in some limited applications up to 5 acres where space is available. Centralized structural BMPs use similar elements to the types of BMPs used in distributed structural BMPs, but also collect, store, treat, and filter stormwater from multiple parcels and much larger drainage areas. Like centralized BMPs, regional BMPs can be implemented in a broad range of land use types, from high-density urban to open space, and can have multiple benefits (habitat, recreation, aesthetics, etc.). Centralized and regional structural BMPs require greater footprints for construction and implementation. Regional and centralized BMPs have similar construction methods. The structural BMPs associated with the proposed program would be installed to treat existing water quality impairments and would not contribute to an increased need for fire protection services. The structural BMPs are not habitable structures, would not be constructed with flammable materials, and would not require fire protection services. Because of the relative scale of these infrastructure improvements, the construction of the various structural BMPs are not expected to result in the need for new or physically altered fire protection facilities. However, construction of new structural BMPs in streets, sidewalks, parkland, or other facilities (these may include public service facilities such as police stations, fire stations, and municipal maintenance yards) within existing high-density urban, commercial, industrial, and transportation areas, as well as associated staging areas, could temporarily disrupt the provision of fire services, resulting in potentially significant impacts. Implementation of Mitigation Measure PS -1 (construction noticing) would reduce potential impacts to a less -than -significant level. Mitigation Measure: PS -1: The Permittee implementing the EWMP project shall provide reasonable advance notification to service providers such as fire, police, and emergency medical services as well as to local businesses, homeowners, and other residents adjacent to and within areas potentially affected by the proposed EWMP project about the nature, extent, and duration of construction activities. Interim updates should be provided to inform them of the status of the construction activities. Significance Determination: Less than significant with mitigation (The application of this mitigation measure to specific BMP types and categories are identified in Table 3.12-2.) Non -Structural (Institutional) BMPs The non-structural BMPs associated with the proposed program would consist of standards and policies related to development and maintenance activities in mostly urban areas. The non - IA County Flood Control District 3.12-10 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft program Environmental Impact Report 3. Environmental Seainq, Impacts, and Mitigation Measures 3.11 Public Services and Recreation structural BMPs would not contribute to an increase in population within the project area, and would therefore not result in the need for new or physically altered fire protection facilities. There would be no impact. Mitigation Measures: None required Significance Determination: No impact Police Protection Services Impact 3.12-2: The proposed program could result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered governmental police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for police protection services. Structural (Regional, Centralized, and Distributed) BMPS The structural BMPs associated with the proposed program would not contribute to an increase in population requiring police protection services. The structural BMPs are not habitable structures; they include mostly unobtrusive structures such as bioswales, pervious pavement, and bioretention areas and are not expected to be of a nature that would require police protection services. Larger -size regional and centralized BMPs could be located in public open spaces such as parks and large parking lots, but would not result in an increased need for police services. Centralized BMPs may include larger -scale diversion and treatment systems that may require added security systems to protect operating systems. These added security systems will be part of the design process and operation and maintenance of these facilities. The structural BMPs would therefore not result in the need for new or physically altered police protection facilities, as there would be no increase in the demand for police protection services. Mitigation Measure: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPS Consisting of standards and activities designed to protect surface water quality, the non-structural BMPs associated with the proposed program are not expected to result in substantial increases of criminal activity and would not result in the need for new or physically altered police protection facilities. There would be no impact. Mitigation Measures: None required Significance Determination: No impact IA County Flood Control District 3.12-11 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.12 Public Services and Recreation Schools Impact 3.12-3: The proposed program could result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered schools, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for schools, Structural (Regional, Centralized, and Distributed) BMPs The structural BMPs associated with the proposed program would consist of structures such as bioinfiltration cells, bioswales, porous pavement and filter strips, low -flow diversions, detention ponds, treatment wetlands, and stream/creek restoration projects; it would not increase the population in the project area, so it would not generate additional students. However, some of the structural BMPs may be installed on school facilities, on or under large grassy fields typically found on school sites. Large open space areas that can be found on school sites offer potential opportunities for infiltration and recharge areas. Such impacts would be analyzed on a site- specific basis as projects are brought forward and will be reviewed under a subsequent CEQA process. However, because of the short construction period of the types of structural BMPs under consideration, construction activities would not be anticipated to significantly affect the operation of existing school facilities such that new or physically altered facilities would be required. In addition, the long-term operation of the structural BMPs would not likely affect the operation of existing school facilities because of the relatively small scale and design of these structural BMPs. Impacts would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs The non-structural BMPs would consist of standards and activities designed to protect surface water quality, and would not increase population within the project area. Therefore, these BMPs would not result in the need for new or physically altered school facilities. There would be no impact. Mitigation Measures: None required Significance Determination: No impact Increased Use of Recreational Facilities Impact 3.12-4: The proposed program could increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated, Structural (Regional, Centralized, and Distributed) BMPs The structural BMPs would not contribute to an increase in population and an associated increase in existing recreational facilities that could result in physical deterioration of existing facilities. IA County Flood Control District 3.12-12 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.11 Public Services and Recreation Some of the structural BMPs associated with the proposed program are anticipated to be located on existing parkland, as these open space areas offer ample area for potential subsurface spreading and infiltration. During the construction of such infrastructure, certain parts of selected parks and recreational facilities would temporarily be removed from service. Bike lanes and other linear recreational resources may also be affected by construction activities. Therefore, the construction of structural BMPs could temporarily limit the usage of the parks on which they are located, thereby potentially temporarily increasing the use at adjacent parks. Such temporary limits on access to parks and recreational resources may create increased demand on other parks and recreational resources within the EWMP area. Once constructed, the structural BMPs would be in -ground or compatible with open space uses. The structural BMPs would operate passively and consist of mostly unobtrusive structures such as bioinfiltration cells, bioswales, porous pavement and filter strips, low -flow diversions, detention ponds, treatment wetlands, and stream/creek restoration projects. Construction periods for each BMP are expected to be relatively short, typically several months to a year. Because the construction will be temporary, the physical deterioration of park and recreational facilities to which recreational activities were diverted would not be substantial. The structural BMPs operated as part of the proposed program would be compatible with recreational and park -set activities; therefore, no impacts would occur during operation. Thus, construction and operation of structural BMPs would not increase the use of adjacent recreational facilities in such a way that would physically deteriorate them. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPS The non-structural BMPs associated with the proposed program would include programs that would lead to the establishment of various standards and/or physical maintenance activities, such as street sweeping. These BMPs would be preventative of water quality degradation and would not directly result in population growth or displace any existing recreational resources that would thereby result in the increased use of neighborhood or regional recreational resources. Therefore, they would not result in physical deterioration of existing facilities. There would be no impact. Mitigation Measures: None required Significance Determination: No impact Inclusion of Recreational Facilities Impact 3.12-5: The proposed program could include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. Structural (Regional, Centralized, and Distributed) BMPS IA County Flood Control District 3.12-13 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.12 Public Services and Recreation The structural BMPs associated with the proposed program would not require the construction or expansion of recreational facilities, although some BMPs may be located within existing parks or would create new public park space. Implementation of these BMPs would not increase the population and would therefore not create a need for the construction of new or expansion of existing recreational facilities. The structural BMPs constructed and operated as part of the proposed program, if it is approved, would be located on existing recreational facilities and would be compatible with recreational uses during operation. Therefore, the BMPs would not impact parkland in such a way that would require its expansion or the creation of new parkland. Impacts would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs The non-structural BMPs associated with the proposed program would not include recreational facilities. Non-structural BMPs would consist of programs and policies that would include development guidelines and activities designed to prevent surface water quality degradation, and would not specifically result in the construction of new or expansion of existing recreational facilities. There would be no impact. Mitigation Measures: None required Significance Determination: No impact Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs BMPs would be constructed throughout the watersheds. None of the facilities individually or cumulatively would increase population; require additional police, fire, or emergency services; or result in construction of new schools. Most of the distributed BMPs would be small in scale and would not result in cumulatively significant impacts to public services. Similarly, the larger regional and centralized BMPs would not result in cumulatively significant impacts to public services, but may instead provide multiple benefits by increasing public open space in urban areas. Therefore, the program's potential contribution to cumulative effects on public services and recreation is considered less than significant. Mitigation Measures: Mitigation Measure PS -1 (The application of this mitigation measure to specific BMP types and categories is identified in Table 3.12-2.) Significance Determination: Less than significant with mitigation IA County Flood Control District 3.12-14 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3.11 Public Services and Recreation Non -Structural (Institutional) BMPS The non-structural BMPs associated with the proposed program would not result in impacts to public services or recreational facilities, as these BMPs will not consist of any physical construction. There would be no impact. Mitigation Measures: None required Significance Determination: No impact IA County Flood Control District 3.12-15 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.12 Public Services and Recreation 3.12.4 Summary of Impact Assessment Table 3.12-2 shows a summary of the structural BMPs requiring mitigation. TABLE 3.12.2 SUMMARY OF PUBLIC SERVICES AND RECREATION IMPACTS REQUIRING MITIGATION MEASURES Structural BMPs Thresholds of Adverse Adverse None physical physical Adverse impacts due impacts physical to new or due to new impacts altered fire or altered due to new protection police or altered facilities facilities schools Increased use of recreational facilities Construction of recreational facilities Cumulative Impacts Applicable None None None None Mitigation Measures: PS -1 Required Required Required Required PS -1 Regional BMPs Regional Retention and Yes No No No No Yes Infiltration Regional Capture, Yes No No No No Yes Detention and Use Centralized BAP Biofiltration Yes No No No No Yes Constructed Wetlands Yes No No No No Yes TreatmenULow-Flow Yes No No No No Yes Diversions Creek, River, Estuary Yes No No No No Yes Restoration Distributed BAPS Site Scale Detention Yes No No No No Yes LID — Infiltration/Filtration Yes No No No No Yes BI — Porous Pavement, Green Streets, Bioswale/Filter Strips, downspout disconnects LID— Green Infrastructure Yes No No No No Yes — Capture and Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes Flow-through Treatment Yes No No No No Yes BI Source Control Treatment Yes No No No No Yes BI (catch basin inserts/screens, hydrodynamic separators, gross solids removal devices) Low -Flow Diversions Yes No No No No Yes NOTE: These conclusions are based on typical size and function of BMPs. IA County Flood Control District 3.12-16 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental selling, Impacts, and Mitigation Measures 3,13 Transportation and Circulation This section discusses the setting, regulatory framework, and impacts and mitigation measures regarding traffic and transportation services in the Enhanced Watershed Management Program (EWMP) areas. Temporary impacts related to construction of Best Management Practices (BMPs) have been identified and analyzed throughout the section. 301301 Environmental Setting Regional and Local Roadways The network of regional and local roadways in the potentially affected areas of the EWMP areas consists of interstate freeways (e.g., I-405, I-710, and I-210), state highways (e.g., State Route [SR] 1, and SR 60), and numerous local roads that are under the jurisdiction of a particular city or Los Angeles County Department of Public Works. Local roads provide access to the individual project work sites and also provide a connection between local land uses and major thoroughfares. Public Transportation Public transit service is provided by various agencies in the study area; for example, the Los Angeles County Metro, Torrance Transit, and the Los Angeles Department of Transportation Transit Service. Buses serve local and regional needs for public transportation with varying frequencies. Bicycle and Pedestrian Transportation The regional network of bicycle facilities includes a variety of Class I (bicycle paths), Class II (bicycle lanes, striped in roads), and Class III (bicycle routes without striping) bikeways within the cities and communities in the EWMP study areas. Pedestrian facilities consist of sidewalks and intersection crosswalks in built-up areas. Truck Routes Cities often develop a truck route plan, which designates truck routes to provide contractors with the preferred travel roadways to and from connecting local roadways. For example, the cities of Torrance and Los Angeles have such plans. Los Angeles County has a similar system of truck routes for unincorporated areas. 301302 Regulatory Setting State California Department of Transportation The California Department of Transportation (Caltrans) is responsible for planning, designing, constructing, operating, and maintaining all state highway and interstate freeway systems. As a result, any change to the state roadway system requires an Encroachment Permit from Caltrans. IA County Flood Control District 3.13-1 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.13 Transportation and Circulation Caltrans' construction practices require temporary traffic control planning "during any time the normal function of a roadway is suspended" (Caltrans, 2012). In addition, Caltrans has the discretionary authority to issue special permits for the movement of vehicles/loads exceeding statutory limitations on the size, weight, and loading of vehicles contained in Division 15 of the California Vehicle Code. Requests for such special permits require the completion of an application for a Transportation Permit. The California Highway Patrol is notified about transportation of oversize/overweight loads. In addition to maintaining highways, and general regulations and laws dealing with licensing, traffic signage, and other noncommercial driver requirements, state laws and regulations also govem motor carriers on roadways within the state. Local County and City Land Use Regulations and Ordinances Local regulations and ordinances vary widely in the program area. Traffic -related policies included in General Plans typically concern traffic resulting from project operation rather than project construction. However, some local jurisdictions incorporate restrictions to their General Plans that pertain to construction activities in or through their jurisdictional areas, such as assigning truck traffic routes or requiring the development of Traffic Control Plans. 3,133 Impact Assessment Approach and Methods This section assesses the transportation impacts that could result from the implementation of the proposed structural and non-structural BMPs. Because of the geographic scale of the program area and the range of actions that fall within the scope of the proposed program, this impact assessment was conducted at a programmatic level. Assumptions regarding the types of transport and the types of roads used to haul materials were used to assess the overall significance of program impacts. In determining the level of significance, the assessment assumed that the implementation of the proposed BMPs would comply with relevant federal, state, and local laws, regulations, ordinances, and guidance. It is assumed that supplemental project -level analysis of transportation -related impacts (e.g., traffic safety analysis of heavy vehicles traveling on, and turning onto and off of, local roads) would be required for site-specific structural BMPs prior to commencement of construction activity. Thresholds of Significance The California Environmental Quality Act (CEQA) defines a significant effect on the environment as a substantial, or potentially substantial, adverse change in the physical conditions of the area affected by a project. An impact related to transportation would be considered significant if it would result in any of the following, which are from Appendix G of the CEQA Guidelines: • Conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non -motorized travel and relevant LA County Flood Control District 3.13-2 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.13 Transportation and Circulation components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit. • Conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways. • Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks. • Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g. farm equipment). • Result in inadequate emergency access. • Conflict with adopted policies, plans or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities. The following discussion of environmental impacts is limited to those potential impacts that could result in some level of potentially significant environmental change, as defined by CEQA. The project site is located in the County of Los Angeles, which has established level -of -service standards and a congestion management program that are intended to monitor and address long- term traffic impacts resulting from future development, but do not apply to temporary impacts associated with construction projects (bullet 2 in the list of guidelines). In addition, implementation of the proposed program would not affect air traffic patterns of airports in the program area (bullet 3 above). Also, implementation of the proposed program would not directly or indirectly eliminate existing or planned alternative transportation corridors or facilities (bicycle paths, lanes, bus turnouts, etc.), include changes in policies or programs that support alternative transportation, or construct facilities in locations in which future alternative transportation facilities are planned (bullet 6 in the list of guidelines). Therefore, no impact would occur under these three categories, and these categories are not discussed further within this section. Program Impact Discussion Effects on Performance of the Traffic Circulation System Impact 3.13-1: The proposed program could intermittently and temporarily increase traffic levels and traffic delays due to vehicle trips generated by construction workers and construction vehicles on area roadways. Structural (Regional, Centralized, and Distributed) BMPs Implementation of the proposed program would involve the installation of structural control measures that would be constructed as BMPs to reduce the impact of stormwater and non- storrnwater on receiving water quality within the EWMP areas. The construction activities for the proposed distributed, centralized, and regional structural BMPs would generally require similar processes such as removal of existing aboveground and/or surface materials, ground disturbance (e.g., site preparation and grading), and construction of the structural control measure. The intensity and nature of the construction activity required for the different structural BMPs would vary, and the number of vehicle trips generated by that activity would similarly vary. A general description of the anticipated construction activities that would be required for each of the various LA County Flood Control District 3.13-3 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.13 Transportation and Circulation types of distributed, centralized, and regional structural BMPs are provided in Chapter 2.0, Project Description, of this Program Environmental Impact Report (PEIR). Construction activities of the various structural BMPs proposed in the EWMPs are anticipated to occur intermittently in the future, and would be subject to change, as the EWMPs are also planning documents that will be revised periodically to reflect new data, further modeling, emerging technologies, and results of BMP assessments. As such, the proposed locations of individual BMPs are subject to change throughout the EWMP process. Definitive construction equipment lists, material lists, construction methods, construction schedules, and workforce details would be developed in the future as specific structural BMP projects are finalized according to the EWMPs. Vehicle trips would be generated primarily by construction workers commuting to and from the BMP work sites, and by trucks hauling materials and equipment to and from the sites. Construction equipment would be delivered to and removed from each site as needed. The construction traffic impacts associated with each individual structural BMP project would be short-term in nature and limited to the period of time when construction activity is taking place for that particular project. The primary off-site impacts resulting from the movement of construction trucks would include a short-term and intermittent lessening of roadway capacities due to the slower movements and larger turning radii of the trucks compared to passenger vehicles. Drivers could experience delays if they were traveling behind a heavy truck. The added traffic would be most apparent on the local roadways serving the facility sites. Although project - related traffic would be temporary, supplemental project -level analysis of potential site-specific impacts could determine that addition of project -generated traffic would be considered substantial in relation to traffic flow conditions on local roadways. For this program -level assessment, this impact is considered potentially significant. To reduce the potential construction traffic impacts associated with the structural BMP projects, Mitigation Measure TRAF-1 would be implemented; it would require all construction activities to be conducted in accordance with an approved construction traffic control plan. This would serve to reduce the construction -related traffic impacts to the maximum extent feasible. Thus, through the environmental review and development permit process, subsequent project -specific analysis by implementing agencies would be needed to determine specific required elements of the traffic control plans. Mitigation Measures: TRAF-1: For projects that may affect traffic, implementing agencies shall require that contractors prepare a construction traffic control plan. Elements of the plan should include, but are not necessarily limited to, the following: • Develop circulation and detour plans to minimize impacts to local street circulation. Use haul routes minimizing truck traffic on local roadways to the extent possible. • To the extent feasible, and as needed to avoid adverse impacts on traffic flow, schedule truck trips outside of peak morning and evening commute hours. LA County Flood Control District 3.13-4 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.13 Transportation and Circulation • Install traffic control devices as specified in Caltrans' Manual of Traffic Controls for Construction and Maintenance Work Zones where needed to maintain safe driving conditions. Use flaggers and/or signage to safely direct traffic through construction work zones. • Coordinate with facility owners or administrators of sensitive land uses such as police and fire stations, hospitals, and schools. Provide advance notification to the facility owner or operator of the timing, location, and duration of construction activities. Significance Determination: Less than significant with mitigation (The application of this mitigation measure to specific BMP types and categories are identified in Table 3.13-1.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts related to transportation and traffic. Mitigation Measures: None required Significance Determination: No impact Traffic Safety Hazards Impact 3.13-2: Construction of the proposed program could potentially cause traffic safety hazards for vehicles, bicyclists, and pedestrians on public roadways, and could increase traffic hazards due to possible road wear. Structural (Regional, Centralized, and Distributed) BMPs The construction activities for the proposed distributed, centralized, and regional structural BMPs would not alter the physical configuration of the existing roadway network serving the area, and would not introduce unsafe design features. Impacts would be less than significant... Curb and traffic flow designs would be subject to the design requirements imposed by local Departments of Traffic. Freeways, major arterials, and collectors are designed to accommodate a mix of vehicle types, including heavy trucks needed for temporary construction activities; therefore, impacts to traffic safety would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts related to transportation and traffic. LA County Flood Control District 3.13-5 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.13 Transportation and Circulation Mitigation Measures: None required Significance Determination: No impact Inadequate Emergency Access Impact 3.13-3: The proposed program could result in inadequate emergency access during construction. Structural (Regional, Centralized, and Distributed) BMPs Construction trucks generated by the individual structural BMP projects would interact with other vehicles on project area roadways, including emergency vehicles, but would not alter the physical configuration of the existing roadway network serving the area. As such, while individual emergency vehicles could be slowed if travelling behind a slow-moving truck, per vehicle code requirements, vehicles must yield to emergency vehicles using a siren and red lights. Lane closures would be subject to local Departments of Traffic requiring coordination with emergency providers. This potential impact is considered to be less than significant. Mitigation Measures: None required Significance Determination: Less than significant impact Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no impacts related to transportation and traffic. Mitigation Measures: None required Significance Determination: No impact Cumulative Impact Discussion Impact 3.13-4: Construction of the proposed program could contribute to cumulative impacts to traffic and transportation (traffic congestion, traffic safety, and emergency vehicle access). Structural (Regional, Centralized, and Distributed) BMPs The geographic scope of potential cumulative traffic impacts includes access routes to regional and local roadways used for haul routes and construction equipment/vehicle access throughout the project area. Given the dispersion of individual structural BMP project construction vehicle trips over the study area, and the fact that the trips would occur over the course of each workday, the project -related traffic on any one roadway during any hour of the day would not be substantial, and the contribution to cumulative traffic conditions would be less than significant. LA County Flood Control District 3.13-6 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.13 Transportation and Circulation However, constructing the structural BMPs could result in intermittent and temporary traffic - related impacts in the cumulative context. Traffic impacts include temporary increases in traffic congestion and increased potential for traffic safety hazards. The project has the potential to contribute to potentially significant cumulative construction -related impacts as a result of (1) cumulative projects (such as land development projects) that generate increased traffic at the same time on the same roads as would the proposed program, causing increased congestion and delays; and (2) infrastructure projects in roads that would be used by project construction workers and trucks, which could delay project -generated vehicles past the work zones of those other projects. The structural BMPs associated with the proposed program would be constructed in multiple jurisdictions of Los Angeles County, which aside from the County also includes 46 cities and LACFCD. As such, these structural BMP projects would be generally spread over a large geographic area within the County. These structural BMPs, in combination with other current and planned projects in the County, would result in an increase in construction -related traffic levels, which would temporarily increase the levels of congestion on roadways in areas where a construction project would occur. However, each construction project occurring in the multiple municipalities of the County would be subject to the applicable regulations (e.g., traffic control plans) established by their respective municipalities. Nonetheless, temporary increases in traffic would occur as a result of construction activities under the proposed program along with other related project construction activities in the County. Where a related project is located in proximity to a structural BMP site and is constructed concurrently with the structural BMP, the combined construction traffic levels could have a cumulative effect on nearby roadways. Thus, under circumstances where these simultaneous construction activities would occur in proximity to roads with existing congestion, the cumulative traffic impacts related to a substantial temporary or periodic increase in ambient traffic levels could be cumulatively considerable. However, with implementation of traffic control plans for each project that has the potential to increase traffic, including circulation and detour plans, traffic control devices, and scheduling (to the extent feasible) truck trips outside of peak morning and evening commute hours (as identified in Mitigation Measure TRAF-1) the project's contribution to the cumulative impacts from construction would be minimal. Once constructed, no impacts to traffic would result. Therefore, the contribution of structural BMPs to cumulative traffic conditions is less than significant. Mitigation Measures: Implementation of Mitigation Measure TRAF-1 Significance Determination: Less than significant with mitigation (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.13-1.) Non -Structural (Institutional) BMPs As discussed in Chapter 2.0, Project Description, non-structural/institutional BMPs do not include the construction of new facilities. Consequently, there would be no cumulative impacts related to transportation and traffic. Mitigation Measures: None required LA County Flood Control District 3.13-7 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.13 Transportation and Circulation Significance Determination: No impact 301304 Summary of Impact Assessment Table 3.13-1 shows a summary of the structural BMPs requiring mitigation. TABLE 3.13.1 SUMMARY OF TRANSPORTATION AND CIRCULATION IMPACTS REQUIRING MITIGATION MEASURES Structural BMPs Applicable Mitigation Measures: Traffic Circulation TRAF-1 Thresholds of Significance Traffic Emergency Safety Access None None Required Required Cumulative Impacts TRAF-1 Regional BMPs Regional Detention and Infiltration Yes No No Yes Regional Capture, Detention and Use Yes No No Yes Centralized BMPs Bioinfiltration Yes No No Yes Constructed Wetlands No No No No Treatment/Low-Flow Diversions No No No No Creek, River, Estuary Restoration No No No No Distributed BNPs Site Scale Detention No No No No LID — Infiltration/Filtration BMPs— Porous No No No No Pavement, Green Streets, Bioswale/Filter Strips, downspout disconnects LID — Green Infrastructure — Capture and No No No No Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes Flow-through Treatment BMPs No No No No Source Control Treatment BMPs (catch No No No No basin inserts/screens, hydrodynamic separators, gross solids removal devices) Low -Flow Diversions No No No No NOTE: These conclusions are based on typical size of BMPs and the need for hauling materials off-site during construction. LA County Flood Control District 3.13-8 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report 3. Environmental Settinq, Impacts, and Mitigation Measures 3,14 Utilities, Service Systems, and Energy This section discusses existing utilities and service systems in the County of Los Angeles, presents the associated regulatory framework, and provides an analysis of potential impacts to utilities and service systems that would result from implementation of the proposed program. Public utilities and utility systems in the program area include: water, wastewater, stormwater, solid waste, and energy. The following discussion describes existing utilities and service systems in the program area. 301401 Environmental Setting Water Agencies Several water agencies participate in delivering water from its source to retail customers and households in Los Angeles County. Water supplies include local surface and groundwater, imported surface water, captured and recharged stormwater, and recycled water. The California Department of Water Resources operates and maintains the State Water Project that imports water from the Sacramento River Delta to Southern California. The Metropolitan Water District (Metropolitan) buys imported State Water Project water, imports water from the Colorado River through the Colorado River Aqueduct, and wholesales water to its member agencies. Other water wholesalers in Los Angeles County include the Central Basin Municipal Water District, West Basin Municipal Water District, Upper San Gabriel Valley Municipal Water District, Castaic Lake Water Agency, Las Virgenes Municipal Water District, Three Valleys Municipal Water District, and Antelope Valley—East Kern Water Agency. Water wholesalers provide water to retail customers; some are agencies of cities or counties, some are private companies, and some are special districts. There are several water purveyors that supply water to the Enhanced Watershed Management Program (EWMP) areas of Los Angeles County (Los Angeles County, 2014), as listed in Table 3.14-1. According to Metropolitan, approximately 55 percent of water supplies in Southern California are imported, and 45 percent are supplied by local groundwater basins that are recharged naturally from rainfall and through constructed recharge facilities (MWD, 2010). Local supplies fluctuate in response to variations in rainfall. Stormwater recharge facilities currently augment local groundwater supplies in the region by an estimated 477,000 acre-feet per year (MWD, 2014). Studies have estimated about 1 million acre-feet per year of stormwater in the region is not captured (MWD, 2014). The largest stormwater detention and recharge facilities in Los Angeles County are located along the San Gabriel River in the City of Pico Rivera. These facilities, shown in Figure 3.14-1, Water Recharge Facilities, were constructed in the 1930s when the river levees were significantly improved. These groundwater recharge facilities are also used to recharge recycled water conveyed from the Los Coyote Hills Treatment Plant. IA County Flood Control District 3.14-1 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems TABLE 3.14-1 EWMP AREA WATER PURVEYORS Group Name Permittees Involved Ballona Creek Beverly Hills, Culver City, Inglewood, Los Angeles, Santa Monica, West Hollywood, Los Angeles County, LACFCD Beach Cities Watershed Hermosa Beach, Manhattan Beach, Redondo Management Group Beach, Torrance, LACFCD Dominguez Channel EI Segundo, Hawthorne, Inglewood, Los Watershed Management Angeles, Lomita, Los Angeles County, Group LACFCD Malibu Creek Watershed Agoura Hills, Calabasas, Hidden Hills, Westlake Village, Los Angeles County, LACFCD Marina Del Rey Culver City, Los Angeles, Los Angeles County, LACFCD North Santa Monica Bay Los Angeles County, Malibu, LACFCD Coastal Watersheds Palos Verdes Peninsula Palos Verdes Estates, Rancho Palos Verdes, EWMP Agencies Rolling Hills Estates, Los Angeles County, LACFCD Rio Hondo/San Gabriel River Arcadia, Azusa, Bradbury, Duarte, Monrovia, Water Quality Group Los Angeles County, Sierra Madre, LACFCD Water Agency Beverly Hills Public Works; Central Basin Municipal Water District; West Basin Municipal Water District; Santa Monica Public Works; LADWP West Basin Municipal Water District; Torrance Public Works West Basin Municipal Water District; LADWP Las Virgenes Municipal Water District West Basin Municipal Water District; LADWP West Basin Municipal Water District; Los Angeles County Waterworks Districts West Basin Municipal Water District Three Valleys Municipal Water District; Upper San Gabriel Valley Municipal Water District Santa Monica Bay Watershed Los Angeles, EI Segundo, Santa Monica, Los West Basin Municipal Water District; Jurisdictions 2 and 3 Angeles County, LACFCD LADWP; Santa Monica Public Works Upper Los Angeles River Alhambra, Burbank, Calabasas, Glendale, Watershed Hidden Hills, La Canada Flintridge, Los Angeles, Montebello, Monterey Park, Pasadena, Rosemead, San Gabriel, San Marino, South Pasadena, Temple City, Los Angeles County, LACFCD Upper San Gabriel River Upper Santa Clara River Watershed Baldwin Park, Covina, Glendora, Industry, La Puente, Los Angeles County, LACFCD Los Angeles County, Santa Clarita, LACFCD Alhambra Public Works Department; Burbank Water and Power; Foothill Municipal Water District; Glendale Water and Power; Crescenta Valley Water District; Las Virgenes Municipal Water District; LADWP; Central Basin Municipal Water District; Upper San Gabriel Valley Municipal Water District; California -American Water Company Upper San Gabriel Valley Municipal Water District Santa Clattle Water Division IA County Flood Control District 3.14-2 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 1 - Ballona Creek Kern 2 - Beach Cities 3 - Dominguez Channel C -- --- - - - - - - -- — - — - _ - - - - - - - — — — — — 4 - Malibu Creek -- \ 5 - Marina Del Rey �V A y 6 -North Santa Monica Bay \ 7 - Palos Verdes Peninsula \`\ ( 8 - Rio Hondo/San Gabriel River 1 9 - Santa Monica Bay Jurisdictions 2+3 \ ( ( 10 - Upper LA River 11 - Upper San n l River 12 -Upper Santaa Clara River v I Los Angeles (I jjj Ventura LOPEZr JTOI Ate' ���`® \TUJUNGA GALLERY TUJUNGA} DALTON �ti} SA�ANYORELHOMPSOrc�CK. ® ARROYO SSC 1 i i _4 F �EATON�� ' HEADWORKS/ �)",��� SAN GA pM l •.1.,r—RER) f � RIOONDO i COAST ASINN�, SAN GABRIEL � RI OWER) ( San Bernardino \\ ® .- r r � �F- 1 DOMINGUEZIGAiP, r,r � _ Orange f Major Water Recharge Facilities .t Rivers/Streams 0 It 8 I I \ Miles SOURCE: ESRI; Los Angeles County GIS LA County PEI EWMP . 140474 Figure 3.14-1 Water Recharge Facilities 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems Wastewater Several wastewater agencies participate in providing wastewater collection and treatment for the EWMP areas. The EWMP areas fall within the Sanitation Districts of Los Angeles County, the City of Los Angeles Bureau of Sanitation, and Las Virgenes Municipal Water District wastewater system service areas. The Sanitation Districts are a partnership of 24 independent special districts that serve the wastewater and solid waste management needs of approximately 5.5 million people in Los Angeles County (County). The Sanitation Districts' service area covers approximately 824 square miles and encompasses 78 cities and unincorporated territory within the County. Within the Sanitation Districts' service area, there are approximately 9,500 miles of sewers that are owned and operated by the cities and County that are tributary to the Sanitation Districts' wastewater collection system. The Sanitation Districts own, operate, and maintain approximately 1,400 miles of sewers, ranging from 8 to 144 inches in diameter, that convey approximately 500 million gallons per day of wastewater to 11 wastewater treatment plants. Included in the Sanitation Districts' wastewater collection system are 48 active pumping plants located throughout the County. In the interest of promoting better health and safety protection for those who engage in water contact activities in coastal areas bordered by the Sanitation Districts service area, the Sanitation Districts have consented, where justified, to accept the diversion of dry -weather urban runoff into the sewer system. The agencies responsible for the stormwater collection system are required to obtain permits from the Sanitation Districts, install equipment to remove gross solids, provide the means for measuring flow, and pay appropriate fees. The City of Los Angeles Bureau of Sanitation provides wastewater treatment to the City of Los Angeles, as well as several unincorporated areas next to the City of Los Angeles. The Bureau of Sanitation operates and maintains its own wastewater collection and treatment systems with over 6,500 miles of sewers that serve more than four million residential and business customers in Los Angeles and 29 contracting cities and agencies. These sewers are connected to the City of Los Angeles' four wastewater and water reclamation plants that process an average of 550 million gallons of wastewater each day of the year. The City of Los Angeles Department of Public Works have implemented several low -flow diversion systems along the coast that divert urban dry -weather runoff and other types of non-stormwater from the storm drain system into the sewer system for treatment by the City of Los Angeles Hyperion Sewer Treatment Plant. Some of the low -flow diversion systems are being upgraded and, to convey the increased diverted stormwater flows from the low -flow diversion systems to the Hyperion Treatment Plant, the Coastal Interceptor Relief Sewer (CIRS) was constructed to provide additional capacity to the existing sewer system. Las Virgenes Municipal Water District and the Triunfo Sanitation District (that serves a portion of Ventura County) share a service area in the Malibu Creek watershed. The Tapia Water Reclamation Facility and the Rancho Las Virgenes Composting Facility are owned by the Las Virgenes — Triunfo Joint Powers Authority and operated by Las Virgenes Municipal Water District personnel. IA County Flood Control District 3.14-4 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems Table 3.14-2 lists the major municipal wastewater treatment plants in the EWMP areas. Each of these facilities provides treatment for daily wastewater flows and is designed with augmented hydraulic capacity to receive and discharge peak flows that enter the system during storm events. TABLE 3.14-2 EWMP AREA WASTEWATER TREATMENT PLANTS Average Daily Rated Capacity Flow 2013 Water Reclamation Plants (WRP) (mgd) (mgd) Hyperion 450 362 Joint Water Pollution Control Plant (JWPCP) 400 264 La Canada WRP 0.2 0.1 Los Angeles/Glendale WRP 20 20 Long Beach WRP 25 17 Los Coyotes WRP 37.5 21 Saugus WRP 6.2 5.2 San Jose Creek WRP 100 63 Tapia WRF 16 9.5 Tillman WRP 80 67 Whittier Narrows WRP 15 8.6 Valencia WRP 21.6 15.7 Inge! = million gallons per day SOURCES: Sanitation Districts of Los Angeles County website: http://www.laosd.org/wastewater/wwfacilities/default.asp; Los Angeles County, 2014; Santa Cladta, 2010; LACED, 2014). Stormwater The Los Angeles County Flood Control District (LACFCD) encompasses more than 3,000 square miles, 85 cities, and approximately 2.1 million land parcels. It includes the vast majority of drainage infrastructure within incorporated and unincorporated areas in every watershed, including 500 miles of open channel, 2,800 miles of underground storm drains, and an estimated 120,000 catch basins. In addition to the County maintaining regional storm drain structures, many of the cities within the EWMP study areas maintain storm drains within their respective city boundaries. A low -flow diversion is a structural system that diverts potentially polluted, dry -weather flow to be treated, usually at a sewage treatment plant, before being discharged into the ocean. Several coastal cities have installed low -flow diversion systems that divert dry -weather flows to local treatment plants. For example, the City of Santa Monica operates the Santa Monica Urban Runoff Recycling Facility (SMURRF), which treats dry -weather runoff water (from excessive irrigation, spills, construction sites, pool draining, car washing, the washing down of paved areas, and some initial wet -weather runoff) prior to discharging to the ocean. An average of 500,000 gallons per IA County Flood Control District 3.14-5 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems day (gpd) of urban runoff generated in parts of the cities of Santa Monica and Los Angeles is treated by conventional and advanced treatment systems at the SMURRF. The runoff water is diverted from the City of Santa Monica's two main storm drains (Pier, Pico-Kenter) into the SMURRF and treated to remove pollutants such as trash, sediment, oil, grease, and pathogens (Santa Monica, 2014). In addition, LACFCD owns and operates 20 low -flow diversions in the Santa Monica Bay coast which divert low flows to the sanitary sewer system; these low -flow diversions also capture trash and floating debris in a trash well (LACFCD, 2013). Solid Waste Management Trash discarded on land frequently makes its way into streams, creeks, rivers, and eventually the ocean as rain storms wash it into gutters and storm drains. Types of trash generated by human activity that frequently pollute waterways include cigarette butts, paper, fast food containers, plastic grocery bags, cans and bottles, used diapers, construction site debris, industrial preproduction plastic pellets, old tires, appliances, and more. Trash is a significant pollutant of California's waters that adversely affects beneficial uses, including but not limited to uses that support aquatic life, wildlife, and public health (SWRCB, 2014). The EWMP areas are served by various landfills and recycling centers operated by cities, the County, and private facility operators. Sanitation Districts of Los Angeles County (LACSD) serves the solid waste management needs of a large portion of Los Angeles County with several landfills, recycle centers, materials recovery/transfer facilities, and energy recovery facilities (LACSD, 2014). The two operational landfill sites are the Calabasas Landfill, located near Agoura Hills, and the Scholl Canyon Landfill, located in the Glendale. Other solid waste collection facilities operated by LACSD include the Puente Hills Materials Recovery Facility, the Downey Area Recycling and Transfer Facility, South Gate Transfer Station, the Commerce Refuse -to -Energy Facility, and the Southeast Resource and Recovery Facility. The City of Los Angeles Bureau of Sanitation collects refuse, recyclables, yard trimmings, and other bulky items from more than 750,000 homes and operates the Central LA Recycling and Transfer Station, which temporarily stores refuse and transports it to the nearest landfill. The City of Los Angeles has closed its five landfills and now uses Sunshine Canyon landfill for refuse disposal. Many of the participating cities within the EWMP study areas contract with landfills outside of Los Angeles County for disposal. Energy In 2012, the County of Los Angeles used 69,277.09 million kilowatt-hours (kWh) (CEC, 2014). Southern California Edison (SCE) provides electricity for the majority of the County. The Los Angeles Department of Water and Power provides over 23 million megawatt -hours (MWh) for the 1.4 million customers in the City of Los Angeles and Owens Valley (LADWP, 2013). LADWP is the third largest California electric utility in terms of consumption, behind Pacific Gas & Electric and SCE (LADWP, 2013). Both LADWP and SCE continue to increase efforts to use additional renewable energy resources. Local, state, and federal mandates require levels of renewable energy as a percentage of electricity sales. Senate Bill (SB) 2 (1X) set renewable IA County Flood Control District 3.14-6 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems energy targets of 20 percent for years 2011-2013, 25 percent by 2016, and 33 percent by 2020 and thereafter. 301402 Regulatory Setting State California Health and Safety Code The California Health and Safety Code, Division 104, Part 12, Chapter 5, Article 2, Section 116815, requires all pipes carrying recycled water to be colored purple or wrapped in purple tape. This requirement stems from a concern in cross contamination and potential public health risks similar to those discussed for Title 17 (Public Health) of the California Code of Regulations. It is also discussed in the California Health Laws Related to Recycled Water (the Purple Book). Protection of Underground Infrastructure The California Government Code Section 4216-4216.9 "Protection of Underground Infrastructure" requires an excavator to contact a regional notification center (e.g., Underground Services Alert or Dig Alert) at least two days prior to excavation of any subsurface installations. Any utility provider seeking to begin a project that could damage underground infrastructure can call Underground Service Alert, the regional notification center for Southern California, which would in turn notify the utilities of potentially buried lines within 1,000 feet of the project excavation. Representatives of the utilities are then required to mark the specific location of their facilities within the work area prior to the start of excavation activities in the area. California Integrated Waste Management Act of 1989 The California Integrated Waste Management Act of 1989 (Public Resources Code, Division 30) enacted through AB 939 emphasizes conservation of natural resources through reduction, recycling, and reuse of solid waste. AB 939 requires that all cities and counties divert 25 percent of solid waste streams from landfills by 1995 and 50 percent by 2000. In accordance with AB 939, each local agency must submit an annual report to the California Integrated Waste Management Board summarizing its progress in diverting disposed of solid waste. 2005 California Energy Action Plan II The California Energy Commission's California Energy Action Plan II is the state's principal energy planning and policy document. The plan identifies state-wide energy goals, describes a coordinated implementation plan for state energy policies, and identifies specific action areas to ensure that California's energy is adequate, affordable, technologically advanced, and environmentally sound. In accordance with this plan, the first priority actions to address California's increasing energy demands are energy efficiency and demand response (i.e., reduction of customer energy usage during peak periods in order to address system reliability and support the best use of energy infrastructure). Additional priorities include the use of renewable sources of power and distributed generation (i.e., the use of relatively small power IA County Flood Control District 3.14-7 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems plants near or at centers of high demand). To the extent that these actions are unable to satisfy the increasing energy and capacity needs, clean and efficient fossil -fired generation is supported. The Energy Action Plan II includes the following energy efficiency action specific to water supply systems: • Identify opportunities and support programs to reduce electricity demand related to the water supply system during peak hours and opportunities to reduce the energy needed to operate water conveyance and treatment systems. California Urban Water Management Planning Act of 1983 Section 10610 of the California Water Code establishes the Urban Water Management Planning Act. The act states that every publicly and privately owned urban water service provider that serves 3,000 or more customers or that supplies over 3,000 acre-feet of water annually is required to prepare an Urban Water Management Plan (UWMP) every 5 years. The goal of an UWMP is to ensure a reliable level of water service sufficient to meet the needs of customers during normal, dry, and multiple dry years. NPDES Construction General Permit Construction associated with the proposed program would disturb more than one acre of land surface for centralized and regional structural Best Management Practices (BMPs) (and possibly for those distributed structural BMPs larger than one acre), affecting the quality of stormwater discharges into waters of the United States. The proposed program would therefore be subject to the National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Order 2009-0009- DWQ, NPDES No. CAS000002, Construction General Permit [CGP]), as amended by Order 2010-0014-DWQ and Order 2012-0006-DWQ). The CGP regulates discharges of pollutants in stormwater associated with construction activity to waters of the United States from construction sites that disturb one or more acres of land surface, or that are part of a common plan of development or sale that disturbs more than one acre of land surface. The CGP requires the development and implementation of a Stormwater Pollution Prevention Plan (SWPPP) that includes specific BMPs designed to prevent pollutants from contacting stormwater and keep all products of erosion from moving off-site into receiving waters. The SWPPP BMPs are intended to protect surface water quality by preventing the off-site migration of eroded soil and construction -related pollutants from the construction area. The CGP and SWPPPs are described in more detail in Section 3.8, Hydrology and Water Quality. Statewide Water Quality Control Plans for Trash The State Water Board proposes to adopt Amendments to Statewide Water Quality Control Plans to Control Trash (Trash Amendments) to the California Ocean Plan and the forthcoming Inland Surface Waters, Enclosed Bays, and Estuaries Plan. The proposed Trash Amendments will include six elements: (1) water quality objective, (2) prohibition of discharge, (3) implementation provisions, (4) time schedule, (5) time extension option for State Water Board consideration, and a County Flood Control District 3.14-8 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems (6) monitoring and reporting requirements. The project objective for the proposed Trash Amendments is to provide statewide consistency for the State Water Board's regulatory approach to protect aquatic life and public health beneficial uses, and reduce environmental issues associated with trash in state waters, while focusing limited resources on high -trash -generating areas (SWRCB, 2014). Local Los Angeles County Municipal Separate Storm Sewer System Permit The current Municipal Separate Storm Sewer System (MS4) Permit for Los Angeles County (Order No. R4-2012-0175) became effective December 28, 2012 and contains requirements that are necessary to improve efforts to reduce the discharge of pollutants in stormwater runoff to the maximum extent practicable and achieve water quality standards. Illicit Connections and Illicit Discharge Elimination Program The MS4 Permit requires Permittees to continue to implement an Illicit Connection and Illicit Discharge (IC/ID) Program to detect, investigate, and eliminate IC/IDs to its MS4. Each Permittee must have adequate legal authority to prohibit IC/IDs to the MS4 and enable enforcement capabilities to eliminate the source of IC/IDs. The IC/ID Program includes at least the following major program components: a) An up-to-date map of the MS4 facilities b) Procedures for conducting source investigations for IC/IDs c) Procedures for eliminating the source of WADS d) Procedures for public reporting of IDs e) Spill response plan i) IC/IDs education and training for staff Enhanced Watershed Management Programs The MS4 Permit allows Permittees the flexibility to develop EWMPs to implement the requirements of the Permit on a watershed scale through customized strategies, control measures, and BMPs. Participation in an EWMP is voluntary and allows a Permittee to address the highest watershed priorities, including complying with the requirements of Receiving Water Limitations and Total Maximum Daily Load Provisions. Customized strategies, control measures, and BMPs will be implemented on a watershed basis, where applicable, through each Perrnittee's stormwater management program and/or collectively by all participating Permittees through an EWMP. An EWMP comprehensively evaluates opportunities, within the participating Permittees' collective jurisdictional area in a Watershed Management Area, for collaboration among Permittees and other partners on multi -benefit regional projects that, wherever feasible, retain (i) all non- stormwater runoff and (ii) all stormwater runoff from the 85th percentile, 24-hour storm event for the drainage areas tributary to the projects, while also achieving other benefits including flood control and water supply, among others. An EWMP shall ensure that existing requirements to comply with technology-based effluent limitations and core requirements (e.g., including IA County Flood Control District 3.14-9 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems elimination of nonstormwater discharges of pollutants through the MS4, and controls to reduce the discharge of pollutants in stormwater to the maximum extent practicable) are not delayed. County of Los Angeles Low Impact Development Manual The County of Los Angeles prepared the 2014 Low Impact Development Standards Manual (LID Standards) to comply with the requirements of the NPDES MS4 Permit for stormwater and non- stormwater discharges from the MS4 within the coastal watersheds of Los Angeles County (CAS004001, Order No. R4-2012-0175), referred to as the 2012 MS4 Permit. The LID Standards provide guidance for the implementation of stormwater quality control measures in new development and redevelopment projects in unincorporated areas of the County with the intention of improving water quality and mitigating potential water quality impacts from stormwater and non-stormwater discharges. The November 2013 LID Ordinance became effective December 5, 2013. City of Los Angeles Low Impact Development Manual In November 2011, the City of Los Angeles adopted the Storrnwater Low Impact Development (LID) Ordinance #181899 with the stated purpose of: • Requiring the use of LID standards and practices in future developments and redevelopments to encourage the beneficial use of rainwater and urban runoff • Reducing stormwater/urban runoff while improving water quality • Promoting rainwater harvesting • Reducing offsite runoff and providing increased groundwater recharge • Reducing erosion and hydrologic impacts downstream • Enhancing the recreational and aesthetic values in our communities The City of Los Angeles institutionalized the use of LID techniques for development and redevelopment projects. Subsequent to the adoption of the Stormwater LID Ordinance, the City prepared the Development Best Management Practices Handbook, Low Impact Development Manual, dated June 2011, which describes the required BMPs (City of Los Angeles, 2011). Other Cities LID Various other cities within the County also have LID standards or guidance. The goals, objectives, and content of the LID document are similar to that of the County and City of Los Angeles and are not referenced here. Los Angeles County Construction and Demolition Debris Recycling and Reuse Program On January 1, 2011, Los Angeles County adopted the Green Building Standards Code, which sets forth recycling requirements for construction and demolition projects in the unincorporated areas of Los Angeles County. These requirements apply to any project requiring a construction, demolition or grading permit. According to the requirements, nonresidential construction projects a County Flood Control District 3.14-10 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems consisting of commercial, industrial, or retail structures, as well as all tenant improvements, irrespective of the square footage, must recycle a minimum of 65 percent of the debris generated by weight (Los Angeles County, 2014). Los Angeles County General Plan The County of Los Angeles is currently updating their 1980 General Plan; the new comprehensive General Plan was expected to be adopted by late 2014, but is still pending approval. The following are utilities and service systems goals and policies relating to the proposed program from the existing General Plan's Water and Waste Management Element, and the Draft General Plan 2035 (as of September 2014) Public Services and Facilities Element. Existing General Plan 1980: Goal — Reduce Service Deficiencies: Major deficiencies include the lack of water in aquifers and the shortage of solid waste landfill capacity. Technological advancements may reduce reliance on landfills. Goal — Reduce Detrimental Impacts on Natural and Man Made Environments: Adverse effects on the natural, social and man-made environment arising from water and waste management development must be anticipated and mitigated where they cannot be avoided. Draft General Plan 2014: Goal PS/F 1: A coordinated, reliable, and equitable network of public facilities that preserves resources, ensures public health and safety, and keeps pace with planned development. Goal PS/F 3: Increased local water supplies through the use of new technologies. Policy PS/F 3.1: Increase the supply of water through the development of new sources, such as recycled water, gray water, and rainwater harvesting. Policy PS/F 3.2: Support the increased production, distribution and use of recycled water, gray water, and rainwater harvesting to provide for groundwater recharge, seawater intrusion barrier injection, irrigation, industrial processes and other beneficial uses. Goal PS/F 4: Reliable sewer and urban runoff conveyance treatment systems. Policy PS/F 4.1: Encourage the planning and continued development of efficient countywide sewer conveyance treatment systems. Goal PS/F 5: Adequate disposal capacity and minimal waste and pollution. Policy PS/F 5.1: Maintain an efficient, safe and responsive waste management system that reduces waste while protecting the health and safety of the public. IA County Flood Control District 3.14-11 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems Goal PS/F 6: A County with adequate public utilities. Policy PS/F 6.1: Ensure efficient and cost-effective utilities that serve existing and future needs. City General Plans The numerous cities encompassed by the EWMP area all have their own respective city General Plans, some of which may contain policies that address public utilities. As implementation of the individual structural BMP projects proceed, specific policies and objectives pertaining to public utilities from applicable city General Plans will be identified and evaluated on a project -by - project basis during subsequent California Environmental Quality Act (CEQA) environmental processes. 301403 Impact Assessment The proposed program's potential impacts have been assessed using the CEQA Guidelines Appendix G Checklist. The following sections discuss the key issue areas identified in the CEQA Guidelines with respect to the program's potential effect to utilities and service systems. Thresholds of Significance For the purposes of this Program Environmental Impact Report (PEIR) and consistency with Appendix G of the CEQA Guidelines, applicable local plans, and agency and professional standards, the proposed program would have a significant effect on utilities and service systems if it would: • Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board (RWQCB). • Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. • Require or result in the construction of new stormwater drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. • Have sufficient water supplies available to serve the project from existing entitlements and resources, or would require new or expanded water supply resources or entitlements. • Result in a determination (by the wastewater treatment provider that serves or may serve the project) that it has inadequate capacity to serve the project's projected demand in addition to the provider's existing commitments. • Be served by a landfill with insufficient permitted capacity to accommodate the project solid waste disposal needs. • Not comply with federal, state, and local statutes and regulations related to solid waste. IA County Flood Control District 3.14-12 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems • Cause a substantial increase in overall or per capita energy consumption or cause wasteful or unnecessary consumption of energy. • Require construction of new sources of energy supplies or additional energy infrastructure capacity, the construction of which could cause significant environmental effects. • Conflict with applicable energy efficiency policies or standards. Program Impact Discussion Wastewater Treatment Impact 3.14-1: Implementation of the proposed program could exceed wastewater treatment requirements of the applicable RWQCB or result in the construction of new treatment facilities or expansion of existing facilities if the wastewater treatment provider has inadequate capacity to serve the proposed program. Structural (Regional, Centralized, and Distributed) BMPs The proposed program would involve the construction of structural BMPs intended to treat storrnwater and non-stormwater runoff. The structural BMPs that fall under this category include green infrastructure/LID, of which there are many subtypes, including bioretention and biofiltration, permeable pavement, and bioswales, flow-through treatment BMPs, source -control BMPs, infiltration BMPs, capture -and -use BMPs, bioinfiltration BMPs, treatment facilities and low -flow diversions, constructed wetlands, and other multi -benefit flood management projects. The implementation of the proposed program would comply with the MS4 Permit issued by the RWQCB. Existing discharge permits for individual facilities such as publically owned treatment works, or for general actions such as construction and industrial activities, would not be affected by the implementation of proposed structural BMPs. Each Permittee would be required to comply with existing discharge permit limitations, as is the case under existing conditions. Implementation of facilities meant to improve water quality and meet water quality objectives of the MS4 Permit would be consistent with RWQCB discharge requirements. (See Section 3.8.4, Hydrology and Water Quality, for a discussion on construction -related water quality impacts.) The construction of structural BMPs would vary significantly based on the location, size, and configuration of the BMP. Construction methods may include removal or retrofitting of above- ground infrastructure or local soils in relatively compact areas, requiring the hauling of demolished material. Excavation may be necessary for subsurface structure installations such as dry/wet wells, underdrain, flow-through treatment BMPs, infiltration BMPs, capture -and -use BMPs, and treatment facilities. However, many of these structural BMPs would have a relatively small footprint of a few acres or much less. Some of the centralized BMPs would require larger areas of excavation for installation of infiltration and detention basins and other subsurface facilities and may be a few acres to several tens of acres. Most structural BMPs would be constructed in developed areas, including parking lots, roads, or sidewalks, and would not require new treatment facilities or expansion of existing facilities. Treatment provided by most of the structural BMPs would be from soil infiltration. However, IA County Flood Control District 3.14-13 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems some BMPs, in particular low -flow diversion systems, would be designed to convey dry -weather flows to a newly constructed treatment system, or to an existing wastewater treatment facility. Some of these facilities would be small and constructed in close proximity to the water course. The implementing agency would be required to evaluate the location of these facilities to ensure compatible land uses, but otherwise these new treatment facilities would be constructed as part of the water quality improvement project. Other low -flow diversion systems would divert dry -weather flows to existing wastewater treatment plants. As part of the design for these types of projects, the implementing agency would be required to evaluate the available dry -weather capacity of the existing treatment facility and to evaluate whether the additional flow could be accommodated within the existing system and under the existing discharge requirements. The wastewater treatment provider would be a lead agency in evaluating impacts to their facility. If additional capacity is required, or additional treatment processes are required to meet discharge limitations, the implementing agency would evaluate these elements as part of the proposed low -flow diversion project. Implementation of these low -flow diversion projects would require the cooperation and approval of the wastewater treatment provider under the discharge permit limitations. The operational purpose of the structural BMPs associated with the proposed EWMPs is to meet the surface water treatment requirements of the Los Angeles RWQCB for stormwater and non- stormwater discharges. The main functions of the structural BMPs would be to infiltrate, treat, and store runoff to help reduce the impact of stormwater and non-stormwater discharges on receiving water quality, which would not produce wastewater during operation. Therefore, the structural BMPs would be designed to meet wastewater treatment requirements of the RWQCB permit. Impacts would be less than significant. Construction requiring ground disturbance could encounter buried utilities including wastewater conveyance infrastructure. As part of the project design, Implementing Agencies would be required to identify the potential for underground utilities and determine whether they would need to be relocated to accommodate the BMP. As standard construction practices require, Implementing Agencies would conduct an underground utility search prior to excavation and would coordinate with utility providers in advance to ensure no disruption in services to the utility customers. Impacts to wastewater infrastructure would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs The non-structural BMPs associated with the proposed program would include programs and policies that would entail development guidelines and activities designed to prevent surface water quality degradation. Examples include construction stormwater management programs, municipal pollutant reduction programs, IC/ID detection programs, smart growth planning and LID practices, and public education programs. These BMPs would not increase local populations and would not contribute to an increased generation of wastewater exceeding wastewater treatment IA County Flood Control District 3.14-14 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems requirements of the RWQCB. Consequently, the structural BMPs would not require construction or the expansion of any water or wastewater treatment facilities. There would be no impact. Mitigation Measures: None required Significance Determination: No impact Stormwater Facilities Impact 3.14-2: The proposed program could require or result in the construction of new stormwater drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. Structural (Regional, Centralized, and Distributed) BMPs The proposed program consists of improvements to existing storm drainage facilities as well as new storm drain facilities within the EWMP program areas. New facilities proposed would likely be installed within existing sidewalks, streets, parks, municipally owned lands, or drainage easements. Storm drainage capacity would be verified during design as applicable, and temporary retention facilities may be used until such time as adequate downstream storm drainage facilities are constructed and operational. This PEIR contains an analysis on the potential environmental effects that might result from the installation of storm drainage facilities identified in the proposed EWMPs. No additional analysis is required under this impact discussion. Mitigation Measures: None required Significance Determination: Less than significant Non -Structural (Institutional) BMPs The non-structural BMPs associated with the proposed EWMPs would involve policies, actions, and activities and would not require construction of new stormwater drainage facilities or expansion of existing facilities. There would be no impact. Mitigation Measures: None required Significance Determination: No impact Water Supply Impact 3.14-3: The proposed program could require new or expanded water supply resources or entitlements or require or result in the construction of new water facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. Structural (Regional, Centralized, and Distributed) BMPs Implementation of the EWMPs would not increase water demands. Construction of the majority of the structural BMPs would require some minor water usage for dust control and concrete washout activities. However, the construction periods for BMPs are expected to be relatively IA County Flood Control District 3.14-15 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems short, lasting several months to a year. Therefore, water demand during construction is not expected to be substantial enough to require new or expanded water supply resources. Some of the BMPs would augment local water supplies through enhanced stormwater recharge. Impacts to the existing water supplies are anticipated to be beneficial as a result of the stormwater and non- stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. No adverse impacts related to new or expanded water supply resources or entitlements would occur. Construction requiring ground disturbance could encounter buried utilities including water supply infrastructure. As part of the project design, Implementing Agencies would be required to identify the potential for underground utilities and determine whether they would need to be relocated to accommodate the BMP. As standard construction practices require, Implementing Agencies would conduct an underground utility search prior to excavation and would coordinate with utility providers in advance to ensure no disruption in services to the utility customers. Impacts to water supply infrastructure would be less than significant. Local surface water contributes little to the regional water supply; local agriculture relies mostly on groundwater and imported water. Throughout Los Angeles County, stormwater flows are captured for recharge by LACFCD where suitable detention and infiltration facilities are available. These captured flows augment groundwater supplies, but are not directly diverted for beneficial uses such as drinking water. Dry -weather flows are also captured in some areas for groundwater recharge. Construction of BMPs to detain stormwater and dry -weather flows may reduce flows downstream, thereby reducing access to beneficial uses downstream. Under California law, the State Water Resources Control Board (SWRCB), Division of Water Rights, is responsible for issuing appropriation permits pursuant to Division 2, Part 2 of the California Water Code. The SWRCB maintains a list of water diversion rights issued since the 1920s in Los Angeles County (http://www.waterboards.ca.lzov/waterrilzhts/board decisions/adopted orders/ decisions/county.shtml). If installation of BMPs (detention, infiltration, and low -flow diversions) would reduce water available to downstream diverters such that their water rights would be impinged, this would be a significant impact of the Program. However, much of the existing diversion permits for Los Angeles County involve streams that are fed by groundwater seepage. These flows, to the extent they still remain, would not be adversely affected by the installation of BMPs since they are fed by natural sources. The urbanization of the County has resulted in channelization of many drainages that are owned and managed by LACFCD. In areas with natural unimproved streams, such as in the Santa Clara River watershed and Malibu watershed where surface water diversions may be more common, stormwater flows are conveyed downstream quickly. Any detention of storm flows upstream would not substantially reduce storm flows downstream or significantly impede access to storm flow. Dry -weather flows in coastal streams and foothills are largely fed by groundwater seepage or wastewater discharges. These flows would not be affected by infiltration BMPs. However, implementation of Mitigation Measure UTIL-1 would ensure that downstream water rights would not be affected by upstream diversions. Mitigation Measure: IA County Flood Control District 3.14-16 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems UTIL-1: Prior to approval of BMPs, implementing agencies shall evaluate the potential for impacts to downstream beneficial uses, including surface water rights. Implementing agencies shall not approve BMPs that result in preventing access to previously appropriated surface water downstream. Significance Determination: Less than significant (The application of this mitigation measure to specific BMP types and categories are identified in Table 3.14-3.) Non -Structural (Institutional) BMPs The non-structural BMPs associated with the proposed program would include programs and policies that would entail development guidelines and activities designed to prevent surface water quality degradation; they would not increase water demand. Some non-structural BMPs would result in water conservation of existing water sources. For example, the Malibu Creek EWMP would implement the Citywide Smart Irrigation Control System, which calls for the installation of a smart irrigation control system using evapotranspiration technology. This system would be put into place at all City of Calabasas -owned facilities, street medians, and parkways. Replacement of irrigation controllers is projected to reduce irrigation runoff that is associated with overwatering of landscaped areas. The City uses 66,431 gallons of water on annual basis for landscape irrigation. It is anticipated that with the new system, the City would save between 13,300 to 16,600 gallons of water, which also translates to approximately 5,000 to 7,000 gallons of reduction in runoff. Therefore, they would not require new or expanded water supply resources or entitlements. Mitigation Measures: None required Significance Determination: No impact Solid Waste Impact 3.14-4: The proposed program could be served by a landfill with insufficient permitted capacity to accommodate the project solid waste disposal needs or the project could not comply with federal, state, and local statutes and regulations related to solid waste. Structural (Regional, Centralized, and Distributed) BMPs Construction activities associated with the structural BMPs would include excavation and demolition of some existing infrastructure, which would produce solid waste requiring disposal in the nearest landfill. The largest potential source of solid waste during construction would be excavated soil. While it is expected that most clean soil would be recycled, reused offsite, or stockpiled and reused as backfill, this analysis assumes that a portion of soil would be disposed in landfills. The exact quantity of waste materials to be disposed of in nearby landfills (which includes construction debris, demolition materials, and excavation spoils) would not be known until each project undergoes a detailed evaluation as part of separate, project -level CEQA review. Recycling and reuse of construction and demolition material has been shown to considerably reduce the amount of debris sent to landfills. The County of Los Angeles and many participating cities have construction and demolition debris recycling and reuse programs. According the IA County Flood Control District 3.14-17 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems County of Los Angeles, except under unusual circumstances, it is feasible to recycle or reuse at least 50 percent or construction and demolition debris (RWQCB, 2008). Development of a waste management or recycling plan (Mitigation Measure UTIL-2) would reduce this impact. Some of the EWMPs, including the Dominguez Channel EWMP and the Upper Santa Clara River EWMP, are required to implement trash Total Maximum Daily Limits (TMDLs) and associated trash removal structural BMPs. Two types of source -control BMPs for trash are illustrated in Section 2.0, Project Description: catch basin inserts, which use nets, screens, fabric, or similar filtration media to separate sediment and gross solids from stormwater, and hydrodynamic separators, which use screens, baffles, or vertical flow to separate sediment and gross solids from storrnwater. The Upper Santa Clara River EWMP plans to implement trash removal BMPs for 79 storm drains in a commercial/industrial park (County of Los Angeles) and 110 storm drain inlets in a commercial/industrial park (City of Santa Clarita). The Dominguez Channel EWMP plan primarily proposes the installation of catch opening screen covers and inserts in those structures found in the Santa Monica Bay, Machado Lake, and Dominguez Channel watersheds of the City of Los Angeles. The catch basin opening screen covers are coarse screens that are installed in the catch basin openings and prevent trash from entering the City storm drain system. Each catch basin opening screen cover has a self -opening device activated by a predetermined street gutter flow to disengage its locking mechanism. The catch basin inserts are perforated screens that are installed inside the catch basin in front of the outlet pipe of the catch basin. The EPA -approved Trash TMDLs for the EWMP areas require annual determination of trash discharges. The TMDLs also require compliance monitoring calculations of the Trash Daily Generation Rate. These monitoring efforts allow permitting agencies to track and monitor the amounts being sent to landfills. The volume of trash removed from the regional waterways is small when compared to daily trash collection and disposal quantities in the highly urbanized Los Angeles County. The new trash collection would be accommodated with existing and planned trash disposal facilities. Based on landfill capacity in the Los Angeles region, there appears to be ample availability to receive trash that would be collected as part of compliance with the Malibu Creek and Machado Lake Trash TMDLs (RWQCB, 2007; 2008). Impacts related to insufficient permitted landfill capacity from implementation of the proposed program is anticipated be less than significant. The program would comply with all federal, state, and local statutes and regulations related to solid waste, including the Los Angeles County Construction and Demolition Debris Recycling and Reuse Program. Impacts regarding noncompliance solid waste regulations would be less than significant. Mitigation Measure: UTIL-2: Implementing agencies shall encourage construction contractors to recycle construction materials and divert inert solids (asphalt, brick, concrete, dirt, fines, rock, sand, soil, and stone) from disposal in a landfill, where feasible. Implementing agencies a County Flood Control District 3.14-18 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems shall incentivize construction contractors with waste minimization goals in bid specifications where feasible. Significance Determination: Less than significant (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.14-3.) Non -Structural (Institutional) BMPs The non-structural BMPs associated with the proposed EWMPs would not involve the construction of new facilities that would generate a new solid waste disposal need. However, the non-structural BMPs would include a broad range of municipal practices such as street cleaning, landscape management, storm drain operation, and more, which produce debris and trash for disposal. Regular street sweeping is one of the most cost-effective non-structural BMPs used to remove sediment, metals, petroleum products, trash, and vegetation that accumulate on streets. Maintaining a regular street sweeping schedule reduces the buildup of trash on streets and prevents trash from entering catch basins and the storm drain system. Street sweeping can also improve the appearance of roadways and urban areas. Based on the existing and planned trash disposal and recycling facilities available to the Los Angeles region, the additional solid waste would not exceed disposal capacity or require additional disposal facilities. As a result, impacts related to insufficient permitted landfill capacity would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Energy Impact 3.14-5: Construction and operation of the proposed program would require additional energy use that could result in wasteful consumption, affect local and regional energy supplies, or conflict with applicable energy efficiency policies or standards. Structural (Regional, Centralized, and Distributed) BMPs Construction of BMPs would require use of non-renewable energy in the form of gasoline and diesel to power construction equipment. However, use of this fuel for construction would not be at such a large scale that it could be seen as wasteful or as affecting local or regional energy supplies. Impacts to energy supplies for construction would be less than significant. Construction requiring ground disturbance could encounter buried or overhead utilities including electric or gas conveyance infrastructure. As part of the project design, Implementing Agencies would be required to identify the potential for underground utilities and determine whether they would need to be relocated to accommodate the BMP. As standard construction practices require, Implementing Agencies would conduct an underground utility search prior to excavation and would coordinate with utility providers in advance to ensure no disruption in services to the utility customers. Impacts to electric or gas infrastructure would be less than significant. IA County Flood Control District 3.14-19 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems Some of the centralized and regional structural BMPs may require the installation of pump stations and ancillary components that would be electrically powered. Operation of the proposed pump station facilities would require new connections to the local electrical transmission system. Plans for the pump station facilities have not been finalized, and thus the energy requirements for operation of the proposed pump stations have not been determined. Operation of the pump stations may be variable in response to seasonal fluctuations. Energy for the pump stations would be provided by LADWP and SCE. Electricity is generated and made available to Southern California from generating facilities and transmission lines located throughout the western United States. LADWP and SCE would be responsible for delivering the energy needed for the proposed structural BMPs. The proposed program would include implementation of energy efficient equipment, such as pumps and lighting, which would minimize the energy requirements of the proposed pump stations. The use of energy anticipated for the proposed program is minor when compared to the County -wide use of electricity. In addition, the proposed program would be supporting water conservation efforts and water quality requirements of the MS4 Permit, which would not result in wasteful consumption, affect local and regional energy supplies, or conflict with applicable energy efficiency policies or standards. Impacts to energy supplies for operation would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs Structural BMPS constructed to treat, infiltrate, and/or store storrnwater and non-storrnwater throughout the watershed would not generate wastewater or require wastewater treatment. However, low -flow diversion BMPs would install localized treatment facilities or use existing wastewater treatment systems to treat and discharge dry -weather flows. Use of these treatment systems throughout the region would result in cumulatively improved water quality and local impacts during construction, but would not result in adverse cumulative impacts from operation or construction. Cumulative impacts would be less than significant. The proposed program consists of improvements to existing storm drainage facilities as well as new storm drain facilities within the EWMP program areas. This PEIR contains an analysis on the potential environmental effects that might result from the installation of storm drainage facilities identified in the proposed EWMPs. Cumulative impacts to storm drain facilities would be less than significant. Impacts to the existing water supplies are anticipated to be beneficial as a result of the stormwater and non-stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. Mitigation Measure UTIL-1 would require that implementing agencies evaluate impacts to downstream beneficial uses, including surface water rights prior to BMP approval. No adverse a County Flood Control District 3.14-20 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems cumulative impacts related to new or expanded water supply resources or entitlements would occur. Construction and operation of the structural BMPs would generate solid waste; however, landfills serving the program area are expected to have sufficient capacity to accommodate the amount of waste generated. Development of a waste management or recycling plan (Mitigation Measure UTIL-2) would reduce this impact. Disposal of the solid waste generated during construction and operation would comply with all pertinent regulations and statutes. All other projects implemented in the area would also be required to comply with federal, state, and local solid waste regulations and statutes. Cumulative impacts would be less than significant. The use of energy anticipated for the proposed program is minor when compared to the County- wide use of electricity. The proposed program would use energy-efficient equipment and would not result in wasteful consumption. Cumulative impacts would be less than significant. Mitigation Measures: Implement Mitigation Measure UTIL-1 and Mitigation Measure UTIL-2 Significance Determination: Less than significant (The application of these mitigation measures to specific BMP types and categories are identified in Table 3.14-3.) Non -Structural (Institutional) BMPs The non-structural BMPs associated with the proposed program would generally have no impact on utilities and service systems. The non-structural BMPs would not require construction and would not require water or wastewater treatment or expanded water supply sources. However, the non-structural BMPs would include street cleaning, landscape management, and storm drain operation, which produce debris and trash for disposal. Based on landfill capacity for the Los Angeles region, there appears to be ample availability to receive trash that would be collected with street cleaning throughout the EWMPs in addition to all other projects implemented in the program area. As a result, cumulative impacts related to insufficient permitted landfill capacity would be less than significant. Mitigation Measures: None required Significance Determination: Less than significant IA County Flood Control District 3.14-21 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 3. Environmental Setting, Impacts, and Mitigation Measures 3.14 Utilities and Service Systems 301404 Summary of Impact Assessment Table 3.14-3 shows a summary of the structural BMPs requiring mitigation. TABLE 3.14-3 SUMMARY OF UTILITIES AND SERVICE SYSTEM IMPACTS REQUIRING MITIGATION MEASURES Thresholds of Significance Wastewater Facilities and Discharge Stormwater Solid Cumulative Structural BMPs Requirements Facilities Water Supply Waste Energy Impacts Applicable Mitigation None None UTIL-1; Measures: None Required Required UTIL-1 UTIL-2 Required UTIL-2 Regional BMPs Regional Detention and No No Yes Yes No Yes Infiltration Regional Capture, No No Yes Yes No Yes Detention and Use Centralized BNP Bioinfiltration No No Yes Yes No Yes Constructed Wetlands No No Yes No No Yes Treatment/Low-Flow No No Yes No No Yes Diversions Creek, River, Estuary No No Yes No No No Restoration Distributed BK/Ps Site -Scale Detention No No Yes No No No LID— No No Yes No No No Infiltration/Filtration BIvPs — Porous Pavement, Green Streets, Bioswale/Filter Strips, downspout disconnects LID — Green No No Yes No No No Infrastructure — Capture and Use—Cisterns, Rain Barrels, Green Roofs, Planter Boxes Flow-through Treatment No No No No No No BMPs Source Control No No No Yes No Yes Treatment BMPs (catch basin inserts/screens, hydrodynamic separators, Gross Solids -Removal Devices) Low flow diversions No No No Yes No Yes NOTE: These conclusions are based on typical need for excavation, generation of construction debris, and trash collection LA County Flood Control District 3.14-22 ESA 1140474 Enhanced Watershed Management Programs January 2015 Draft Program Environmental Impact Report CHAPTER 4 Cumulative Impacts 4A Introduction This chapter presents CEQA requirements for cumulative impact analysis and analyzes the potential for the proposed program to have significant cumulative effects when combined with other past, present, and reasonably foreseeable future projects in each resource area's cumulative geographic scope. This section provides the requirements for cumulative impact analysis. Cumulative impacts for the proposed program when combined with other reasonable and foreseeable future projects in the area are organized by resource topic and analyzed below. CEQA Guidelines Section 15130(a) requires that an EIR discuss the cumulative impacts of a project when the project's incremental effect is "cumulatively considerable," meaning that the project's incremental effects are considerable when viewed in connection with the effects of past, current, and probable future projects. A consideration of actions included as part of a cumulative impact scenario can vary by geographic extent, time frame, and scale. They are defined according to environmental resource issues and the specific significance level associated with potential impacts. CEQA Guidelines 15130(b) requires that discussions of cumulative impacts reflect the severity of the impacts and their likelihood of occurrence. The CEQA Guidelines note that the cumulative impacts discussion does not need to provide as much detail as is provided in the analysis of project -only impacts and should be guided by the standards of practicality and reasonableness and focus on the cumulative impact to which the identified other projects contribute rather than the attributes of other projects which do not contribute to the cumulative impacts. CEQA Analysis Requirements CEQA requires that an EIR assess the cumulative impacts of a project with respect to past, current, and probable future projects within the region. CEQA Guidelines (Section 15355) define cumulative effects as "two or more individual effects that, when considered together, are considerable or which compound or increase other environmental impacts. The cumulative impact from several projects result from the incremental impacts of the proposed program when added to other closely related, and reasonably foreseeable, future projects." Pertinent guidance for cumulative impact analysis is given in Section 15130 of the CEQA Guidelines: • An EIR shall discuss cumulative impacts of a project when the project's incremental effect is "cumulatively considerable", (i.e., the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the a County Flood Control District 4-1 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 4.0 Cumulative effects of current projects, and the effects of probable future projects, (including those outside the control of the lead agency, if necessary). • An EIR should not discuss impacts that do not result in part from the project evaluated in the EIR. • A project's contribution is less than cumulatively considerable, and thus not significant, if the project is required to implement or fund its fair share of a mitigation measure or measures designed to alleviate the cumulative impact. • The discussion of impact severity and likelihood of occurrence need not be as detailed as for effects attributable to the project alone. In addition, the CEQA Guidelines Section 15130(b) allows for the use of two alternatives methods to determine the scope of projects for the cumulative impact analysis: • List Method - A list of past, present, and probable future projects producing related or cumulative impacts, including, if necessary, those projects outside the control of the agency. • Regional Growth Projections Method - A summary of projects contained in an adopted general plan or related planning document or in a prior environmental document which has been adopted or certified, which described or evaluated regional or area wide conditions contributing to the cumulative impact (Section 15130). The analysis of cumulative effects in this PEIR utilizes a combination of the list and regional growth projections methods and focuses on the effects of concurrent construction and operation of the proposed EWMP projects along with the regional growth anticipated in each of the following Participating Permittee's jurisdictional areas: LACFCD, County of Los Angeles, and the following 46 cities: Los Angeles, Beverly Hills, Culver City, Inglewood, Santa Monica, West Hollywood, Hawthorne, El Segundo, Lomita, Baldwin Park, Covina, Glendora, Industry, La Puente, Malibu, Calabasas, Agoura Hills, Westlake Village, Hidden Hills, Santa Clarita, Rancho Palos Verdes, Palos Verdes Estates, Rolling Hills Estates, Redondo Beach, Hermosa Beach, Torrance, Manhattan Beach, Arcadia, Azusa, Bradbury, Duarte, Monrovia, Sierra Madre, Alhambra, Burbank, Glendale, Hidden Hills, La Canada Flintridge, Montebello, Monterey Park, Pasadena, Rosemead, San Gabriel, San Marino, South Pasadena, and Temple City (refer to Figure 2-1). Each of these jurisdictions have independent planning documents that guide the development of urban, agricultural and other land uses within their jurisdictional boundaries. 4.2 Related Projects Geographic Scope Cumulative impacts are assessed for related projects within a similar geographic area. This geographic area may vary, depending upon the issue area discussed and the geographic extent of the potential impact. For example the geographic area associated with construction noise impacts LA County Flood Control District 4-2 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 4.0 Cumulative is limited to areas directly adjacent to construction sites, whereas the geographic area that is affected by construction -related air emissions may include the larger air basin. Construction impacts associated with increased noise, dust, erosion, and access limitations tend to be localized but could be exacerbated if other development or improvement projects are occurring within the same or adjacent locations as the proposed program. Geographically, the proposed program is located in the Los Angeles basin. For the purposes of this analysis, the PEIR considered planned EWMP projects within the service area of LACFCD and all participating permittees, along with the adopted general plans or related planning documents for the EWMP areas, when evaluating potential cumulative impacts due to construction and operation of the proposed program. The planned EWMP projects are listed in Table 4-1, shown on Figure 4-1, Planned EWMP Projects and detailed further in Section 2.0, Project Description. Project Timing In addition to the geographic scope, cumulative impacts also take into consideration the timing of related projects relative to the proposed program. The implementation schedule is particularly important for construction -related impacts; for a group of projects to generate cumulative construction impacts, they must be temporally as well as spatially proximate. The EWMP projects that will be included in the proposed EWMPs along with other reasonably foreseeable future projects in the EWMP areas may or may not occur simultaneously. However, this analysis assumes some the EWMP projects and other local projects would be implemented concurrently, between 2015 and 2035. Type of Projects Considered As described throughout Chapter 3 of this PEIR, the impacts associated with implementation of the proposed program include both short-term, temporary construction -related impacts and long- term impacts related to program operation. Cumulative Construction Impacts Cumulative effects could result when considering the effects of the proposed program in combination with the effects of other construction projects in the area. For this PEIR, the analysis of cumulative construction impacts assumes that throughout the EWMP areas, planned future development projects will be on-going simultaneously with the proposed program, including other local major residential construction, small-scale construction project, and projects that have not yet been identified. Cumulative Operational Impacts Cumulative effects could result when considering the effects of the proposed program in combination with the effects of operating other projects in the EWMP areas. LA County Flood Control District 4-3 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEAJORK PRODUCT 4.0 Cumulative TABLE 4-1 EWMP PROJECTS Map Number Project Name BMP Type Project Sponsor Project Implementation 6 Phase IV Trash TMDL Distributed Dominguez Channel Installation of CB covers began the Implementation Summer of 2013. 3 Citywide Smart Irrigation Control Distributed Malibu Creek Unknown System 5 Wildlife Road Storm Drain Distributed North Santa Monica Construction was scheduled to begin Improvements Bay Coastal March 2014 and continue through August Watersheds 2014 2 Model Equestrian Center Distributed Palos Verdes Completion anticipated June 2015 Peninsula 4 Brandon Street and Green Street Distributed Upper LA River Construction Spring 2014 to Fall 2014 Improvements Project 7 Avocado Heights Multiuse Trail Distributed Upper San Gabriel Constructed Project River 1 Trash removal BMPs Distributed Upper Santa Clara Planned Implementation Date July 2015 River 13 Phase II of the Mar Vista Centralized Ballona Creek Phase II is expected to be completed by Recreation Center Stormwater December 2014. BMP Project 16 Manhattan Beach Greenbelt Centralized Beach Cities WMG The project construction was completed Infiltration System February 19, 2013. 18 Oxford Basin Multi -Use Centralized Marina Del Rey LACFCD anticipates the project to Enhancement Project commence construction by the end of this year or early 2015. 12 Lindero Parkway Improvements Centralized Malibu Creek Construction of the proposed improvements is expected to commence either Spring 2015 or early Summer 2015. 14 Broad Beach Biofiltration Project Centralized North Santa Monica June 2014 (Completion of Construction) Bay Coastal Watersheds 19 San Ramon Canyon Stormwater Centralized Palos Verdes Anticipated to be Completed June 2015. Flood Reduction Project Peninsula 11 Monrovia Station Square/Transit Centralized Rio Honda - San Planned Implementation Date Spring Village Multi -Benefit Park and Gabriel River 2015. Greenway Project 17 Metro Gold Line Infiltration Centralized Rio Honda - San Planned Implementation Date Spring Project Gabriel River 2016. 15 Penmar Water Quality Centralized Santa Monica Bay Phase II — expected completion by Spring Improvement Project (Phase I Jurisdictions 2+3 2015. and Phase II) 10 Humboldt Greenway Project Centralized Upper LA River Under Construction 8A -8C Torrance Stormwater Basin Regional Beach Cities WMG Construction was scheduled for Spring Recharge and Enhancement 2014. Project 9 Malibu Legacy Park Pump Regional North Santa Monica Anticipated to be completed June 2015. Station Improvements Bay Coastal Watersheds SOURCES: EWMP Work Plans, 2014. LA County Flood Control District 4-4 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report Distributed BMPs ® Malibu Legacy Park Pump Station Improvements O Trash removal BMPs Centralized BMPs 0 Model Equestrian Center Q Humboldt Greemeay, Project 0 Citywide Smart Irrigation Control System Q Monrovia Station Square/rrensit Village Mulfi-Benefit Park and Greenway Project ® Brandon Street and Green Street Improvements Project ® Lindero Parkway Improvements © Wildlife Road Storm Drain Improvements ® Phase 11 of Me Mar Vista Recreation Center Stomiwater BMP Project Phase IV Trash TMDL Implementation (D Broad Beach Biofiltration Project ® Avocado Heights Muffil Trail Project ® Penmar Water Quality Improvement Project (Phase I and Phase 11) Regional BMPB ® Manhattan Beach Greenbelt Infiltration System ® Torrance Stonnwater Basin Recharge and Enhancement Project - Entmdero Basin iiii Metro Gdtl Line InflVatbn Project ® Torrance Stonnwater Basin Recharge and Enhancement Project -Amis Basin ® Oxford Basin Multi -Use Enhancement Project ® Torrance Stonnwater Basin Recharge and Enhancement Project - Hennetta Basin ® San Ramon Canyon Stormwater Flood Reduction Project 0 Participating Permittees — Storm Drains EWMP Boundaries 1 - Ballon Creek - 2 - Beach Cities - 3 - Dominguez Channel - 4 - Malibu Creek - 5 - Marina Del Rey - 6 - North Santa Monica Bay - 7 - Palos Verdes Peninsula 8 - Rio Hondo/San Gabriel River 9 - Santa Monica Bay Jurisdictions 233 - 10 - Upper LA River - 11 - Upper San Gabriel River - 12 - Upper Santa Clara River SOURCE: ESRI. 10 Los Angeles Q F 4 San Bernardino Orange 0 7` 8 I Miles LA County PEI EWMP. 140474 Figure 4-1 Planned EWMP Projects 4.0 Cumulative 4.3 Plan Consistency General Plans Construction of structural BMPs and adoption of non-structural BMPs would occur throughout each of the EWMP areas, encompassing 84 cities and large areas of unincorporated Los Angeles County. Each city has adopted land use plans and zoning codes covering development within their jurisdictions. Many cities including the City of Los Angeles have adopted LID ordinances that promote new development of storm flow retention and water quality BMPs. Each implementing agency would be required to evaluate the consistency of each BMP with local zoning codes. Compliance with city codes for placement of BMPs would ensure that the cumulative impact of installing multiple BMPs throughout the County would not conflict with local plans and policies. The Los Angeles County General Plan includes land use designations covering development throughout the County. Section 3.9 Land Use and Agriculture provides a list of goals and policies in the Los Angeles County General Plan that promote storm water quality infrastructure. The installation of multiple BMPs throughout the County would be consistent with the County General Plan goals promoting LID infrastructure and improved storm water quality. Section 3.3 Biological Resources identifies the regional conservation planning efforts throughout the County including critical habitat, significant ecological areas, habitat conservation planning areas, and regional, state and federal parks. The goals of enhanced water quality and a more natural hydrology encouraged by the proposed program are consistent with the habitat conservation goals of each of these plans. Furthermore, the Permit describes the Watershed Management Program optional compliance approach as providing more opportunities for multi -benefit projects that would encourage goals of recreation and habitat value creation as part of the BMP. The proposed program would be consistent with regional General Plan goals and policies. Resource Management Plans In addition to the municipalities and County, resource management agencies mitigate cumulative effects of development on the environment. Several regional agencies including SCAQMD, Water Replenishment District, LARWQCB, Department of Toxic Substances Control, wildlife agencies, Coastal Conservancy, Coastal Commission, National Parks, National Forest Service, Santa Monica Mountains Conservancy, and Metropolitan Water District of Southern California manage resources cumulatively impacted by regional development. Each of these resource managers prepare resource management plans to mitigate potentially significant cumulative impacts. Consistency with these management plans minimizes impacts to cumulative impacts. Table 4-2 lists major resource management agencies and identifies where consistency with resource management plans is discussed in the PEIR. The proposed program would be consistent with regional resource management plans. LA County Flood Control District 4-6 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 4.0 Cumulative TABLE 4-2 KEY REGIONAL RESOURCE MANAGEMENT AND/OR PROTECTION AGENCIES Agency SCAQMD Water Replenishment District RWQCB Department of Toxics Substances Control Wildlife agencies (CDFW, USFWS, NMFS) Coastal Conservancy and Coastal Commission National Parks and Forest Service Management Plan Where Discussed in PEIR Air Quality Management Plan Section 3.2 Groundwater Basins Master Plan Section 3.8 Basin Plan Section 3.8 CUPA Section 3.7 Critical Habitat Designations, NCCP/HCPs Section 3.3 Ocean Plan Section 3.8 Forest and Parks Plans Section 3.9 Santa Monica Mountains Conservancy Santa Monica Mountains Comprehensive Plan Section 3.3 SOURCE: Environmental Science Associates. 4.4 Cumulative Impacts and Mitigation Measures For some impact issue areas (i.e., air quality, traffic, and water supply), the cumulative setting is defined by specific regional boundaries (air basin, regional roadway network, etc.) or projected regional or area -wide conditions, contributing to cumulative impacts. For the remaining impact issue areas, the cumulative setting is based on development anticipated within the vicinity of the EWMP project. The impact analysis in Chapter 3 includes a discussion of cumulative impacts for each resource area. Table 4-3 summarizes the conclusions of the cumulative analysis in Chapter 3. As shown in the table, implementation of the BMPs would result in cumulative significant impacts to air quality, cultural resources, and noise. IA County Flood Control District Enhanced Watershed Management Programs Draft Environmental Impact Report 4-7 CONFIDENTIAL—ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT ESA / 140474 January2015 4.0 Cumulative TABLE 4-3 SUMMARY OF CUMULATIVE IMPACT ANALYSIS Issue Area Significance Determination Aesthetics (Cumulative) LSM Air Quality (Cumulative) SU Biological Resources (Cumulative) LSM Cultural Resources (Cumulative) SU Geology and Soils/Mineral Resources (Cumulative) LSM Greenhouse Gas Emissions (Cumulative) LTS Hazards and Hazardous Materials (Cumulative) LSM Hydrology and Water Quality (Cumulative) LSM Land Use and Planning/Agriculture (Cumulative) LTS Noise (Cumulative) SU Population and Housing (Cumulative) LTS Public Services/Recreation (Cumulative) LTS Traffic and Transportation(Cumulative) LSM Utilities and Service Systems (Cumulative) LSM LTS = Less than Significant LSM = Less than Significant with Mitigation SU = Significant and Unavoidable SOURCE: ESA 2014. IA County Flood Control District 4-8 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report CHAPTER 5 Growth -Inducement Potential This chapter analyzes the growth -inducement potential and associated secondary effects of growth impacts of the proposed program, as required by the California Environmental Quality Act (CEQA). 5.1 CEQA Requirements The CEQA Guidelines require that an Environmental Impact Report (EIR) evaluate the growth - inducing impacts of a proposed action (Section 15126.2[d]). A growth -inducing impact is defined by the CEQA Guidelines as: [Discuss the way in which a proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Included in this are projects which would remove obstacles to population growth (a major expansion of a wastewater treatment plant might, for example, allow for more construction in service areas). Increases in the population may tax existing community service facilities, requiring construction of new facilities that could cause significant environmental effects. Also discuss the characteristic of some projects which may encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively. It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment. A project can have direct and/or indirect growth -inducement potential. Direct growth inducement would result if a project involved construction of new housing. A project can have indirect growth -inducement potential if it would establish substantial new permanent employment opportunities (e.g., commercial, industrial, or governmental enterprises) or if it would involve a substantial construction effort with substantial short-term employment opportunities and indirectly stimulate the need for additional housing and services to support the new employment demand. Similarly, under CEQA, a project would indirectly induce growth if it would remove an obstacle to additional growth and development, such as removing a constraint on a required public service. An example of this indirect effect would be the expansion of a wastewater treatment plant, which might allow for more development in service areas. Under CEQA, growth is not considered necessarily detrimental or beneficial. Based on the CEQA definition above, assessing the growth -inducement potential of the proposed program involves answering the question: "Would implementation of the proposed program a County Flood Control District 55-1 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 5 Growth and Cumulative directly or indirectly support economic expansion, population growth, or residential construction?" Stormwater is typically not one of the chief public services needed to support urban development; however, water supply is needed to support urban development. Additional water supply would play a role in supporting additional growth in the Enhanced Watershed Management Program (EWMP) areas, but it would not be the single impetus to such growth. In addition, factors such as the General Plans and policies of the cities and Los Angeles County (County) and/or the availability of wastewater disposal capacity, public schools, and transportation services also influence business and residential or population growth in the EWMP areas. Economic factors, in particular, greatly affect development rates and locations. 5.2 Methodology Growth inducement may result in adverse impacts if the growth is not consistent with the land use plans and growth management plans and policies for the area affected. Local land use plans provide for land use development patterns and growth policies that allow for the orderly expansion of urban development supported by adequate urban public services, such as water supply, roadway infrastructure, sewer service, and solid waste service. A project that would induce "disorderly" growth that is in conflict with local land use plans could indirectly cause additional adverse environmental impacts and impacts to other public services. Thus, it is important to assess the degree to which the growth accommodated by a project would or would not be consistent with applicable land use plans. To determine direct growth -inducement potential, the proposed program was evaluated to verify whether an increase in population or employment, or the construction of new housing would occur as a direct or indirect result of the program. If either of these scenarios occurred, the proposed program could result in direct growth -inducement within the EWMP areas. 5.3 Growth -Inducement Potential and Significant and Irreversible Effects The proposed program intends to improve stormwater quality through implementation of both structural and non-structural Best Management Practices (BMPs), with the goal of complying with the requirements of the National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit to reduce the impact of stormwater and non-stormwater on receiving water quality within the EWMP areas. Structural BMPs would include BMPs categorized as distributed, centralized, or regional. Distributed structural BMPs treat runoff close to the source and are typically implemented at a single- or few -parcel level. Centralized structural BMPs treat runoff from multiple parcels. Regional structural BMPs are larger in scale, and are meant to retain and/or treat the 85th percentile storm over 24 hours from a contributing area. The major functions of these three types of structural BMPs are infiltration, treatment, and storage; they may be used individually or in combination with one another. Although there would be construction involved, the structural BMPs would largely be implemented in urbanized areas including streets, sidewalks, parking lots, and parks. a County Flood Control District 5-2 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 5 Growth and Cumulative The proposed program is not a land use project and its implementation would not introduce new residential or commercial buildings or any other growth -inducing land uses. The structural BMPs would augment the physical structure of established communities, blending in as part of the existing landscape and enhancing the water quality of existing communities. As a result, the proposed program would not induce population growth. The proposed program would expand stormwater capture abilities, increasing groundwater recharge and improving the quality of stormwater runoff into receiving waters in the Los Angeles region. The program would not include construction of residential or commercial buildings and thus would not increase the demand for or require new public services and utilities facilities (including water supply, fire protection and other emergency services, public education, and parks and recreation facilities). The nature of the proposed program is to increase stormwater recharge and improve stormwater quality; such activities would not result in increased economic activity or population growth in the EWMP areas. And the amount of water recharged as part of the proposed program is anticipated to support existing water supply needs and reduce dependence on imported water supplies. The non-structural BMPs associated with the proposed program consist of policies, actions, and activities intended to prevent pollutants from entering stormwater runoff, thus eliminating the source of the pollutants. Examples include irrigation control, covered trash receptacles, replacement of brake pads and lead in wheel weights, pet waste cleanup stations, street sweeping, catch basin cleaning, and downspout disconnect programs, all aiming to prevent and/or reduce runoff and/or pollution close to the source. These BMPs would not include construction activities and would not result in direct or indirect growth -inducement within the EWMP areas. 5.4 Secondary Effects of Growth Implementation of the proposed program would not result in a direct or indirect increase in population or employment. The proposed program itself, therefore, is not growth -inducing and would not induce secondary effects of growth. While one of the main goals of the EWMPs is to increase infiltration and potentially increase recharge of stormwater into the groundwater basin, the amount of water potentially recharged would not be enough to indirectly support population growth and is intended to support existing water supply needs. This potential additional recharge would contribute to local water supply needs but would not alter population demographics. Therefore, there would be no secondary effects of growth. 5.5 Significant Irreversible Environmental Changes CEQA Guidelines 21100(b) (2) and 15126.2(b) require that any significant effect on the environment that would be irreversible if the project is implemented must be identified. A project would generally result in a significant irreversible impact if: • Primary and secondary impacts (such as roadway improvements that provide access to previously inaccessible areas, etc.) would commit future generations to similar uses. • The project would involve a large commitment of nonrenewable resources. a County Flood Control District 5-3 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 5 Growth and Cumulative • The project would involve uses in which irreversible damage could result from any potential environmental accidents associated with the project. In accordance with Section 21100(b)(2)(B) of CEQA and Sections 15126(c) and 15126.2(c) of the CEQA Guidelines, the purpose of this section is to identify significant irreversible environmental changes that would be caused by implementation of the proposed program. Construction and operational impacts associated with implementation of the program would result in an irretrievable and irreversible commitment of natural resources through the use of fossil fuels and construction materials. Operation of the program would incrementally increase power consumption associated with stormwater BMPs requiring pump stations. The program's incremental increased use of these resources, however, would not significantly increase the overall commitment of resources associated with stormwater and would in fact increase conservation of other valuable resources. The proposed program would involve only minor incremental use of nonrenewable resources and would locate facilities primarily on lands already developed. Furthermore, since the implementing agencies would implement the mitigation measures identified in this Program Environmental Impact Report in concert with other ongoing stewardship and watershed protection activities, implementation of the proposed program would not result in significant irreversible environmental changes. When completed, the proposed program would provide a high level of water quality protection as well as increase water conservation throughout the EWMP areas. a County Flood Control District 5-4 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report CHAPTER 6 Alternatives Analysis 6A Introduction According to the California Environmental Quality Act (CEQA) Guidelines, an Environmental Impact Report (EIR) must describe a reasonable range of alternatives to a proposed project that could feasibly attain most of the basic project objectives, and would avoid or substantially lessen any of the proposed project's significant environmental effects. This alternatives analysis summarizes the alternatives screening process conducted to identify feasible alternatives to the proposed Enhanced Watershed Management Programs (EWMPs). Information to select an "environmentally superior alternative," which may be the proposed program, is also provided in this chapter. Section 15126.6(f) of the CEQA Guidelines provides direction on the required alternatives analysis: "The range of alternatives required in an FIR is governed by a `rule of reason' that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project. The range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision making." An FIR need not consider every conceivable alternative to a project. Rather, the alternatives must be limited to ones that meet the project objectives, are feasible, and would avoid or substantially lessen at least one of the significant environmental effects of the project. "Feasible" means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors. Section 15126.6(b) of the CEQA Guidelines states that an FIR: must identify ways to mitigate or avoid the significant effects that a project may have on the environment, the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or could be more costly." a County Flood Control District 6-1 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 6. Alternatives Section 15126.6 (d) of the CEQA Guidelines provides further guidance on the extent of alternatives analysis required: "The FIR shall include sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project. A matrix displaying the major characteristics and significant environmental effects of each alternative may be used to summarize the comparison. If an alternative would cause one or more significant effects in addition to those that would be caused by the project as proposed, the significant effects of the alternative shall be discussed, but in less detail than the significant effects of the project as proposed." The EIR must briefly describe the rationale for selection and rejection of alternatives and the information the Lead Agency relied on when making the selection. It also should identify any alternatives considered but rejected as infeasible by the lead agency during the scoping process and briefly explain the reasons for the exclusion. Alternatives may be eliminated from detailed consideration in the FIR if they fail to meet most of the project objectives, are infeasible, or do not avoid any significant environmental effects. Section 15126.6(e)(1) of the CEQA Guidelines also requires that the "no project" alternative be addressed in this analysis. The purpose of evaluating the "no project" alternative is to allow decision -makers to compare the potential consequences of the proposed program with the consequences that would occur without implementation of the proposed program. Finally, an FIR must identify the environmentally superior alternative. The "no project" alternative may be environmentally superior to the proposed program based on the minimization or avoidance of physical environmental impacts. However, the "no project" alternative must also achieve the project objectives in order to be selected as the environmentally superior alternative. CEQA Guidelines Section 15126.6(e)(1) requires that if the environmentally superior alternative is the "no project" alternative, the EIR shall identify an environmentally superior alternative among other alternatives. 6.2 Review of Proposed Program Goals and Objectives The alternatives presented in this chapter were analyzed for their abilities to reduce significant program impacts and meet the objectives of the proposed program, which are: • To collaborate among agencies (Permittee jurisdictions) across the watershed to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the Municipal Separate Storm Sewer System (MS4) Permit. • To develop watershed -wide Enhanced Watershed Management Programs (EWMPs) that would, once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff in a cost-effective manner. • To reduce the impact of stormwater and non-storrnwater on receiving water quality. a County Flood Control District 6-2 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 6. Alternatives 6.3 Review of Significant Environmental Impacts CEQA Guidelines Sections 21100(b) (2) and 15126.2(b) require that any significant and unavoidable effect on the environment must be identified. In addition, CEQA Guidelines 15093(a) allows the decision-making agency to determine if the benefits of a proposed project outweigh the unavoidable adverse environmental impacts of implementing the project. The Lead Agency can approve a project with unavoidable adverse impacts if it prepares and adopts a "Statement of Overriding Considerations" setting forth the specific reasons for making such a judgment. Unavoidable adverse impacts identified in this Program Environmental Impact Report (PEIR) are discussed in this section. For each of the unavoidable adverse impacts, the Los Angeles County Flood Control District (LACFCD) must prepare and adopt a Statement of Overriding Considerations if the program is approved. Chapters 3 and 4 provide analyses of potentially significant impacts that could result from implementation of the proposed program. Table 6-1 identifies the potentially significant and unavoidable impacts associated with implementation of the proposed program. The range of alternatives required to be evaluated in an EIR is limited to those alternatives that would avoid or substantially lessen any significant effects of the proposed program and could feasibly attain most of the program objectives. 6.4 Program -Level Alternatives Analysis In accordance with the CEQA `Yule of reason," an EIR is required to consider a range of alternatives that permit a reasoned choice and that are "limited to ones that would avoid or substantially lessen any of the significant effects of the project' (CEQA Guidelines Section 15126.6(f)). The Lead Agency conducted an alternatives screening process to identify feasible alternatives to the proposed program. The screening process for identifying viable alternatives included consideration of the following criteria: • Ability to meet the program objectives • Ability to reduce significant environmental effects of the proposed program • Economic and engineering feasibility Based on these criteria, the Lead Agency has identified the following alternatives: • No Program Alternative • Non -Structural Best Management Practices (BMPs) Only Program Alternative • Distributed Structural BMPs Only Program Alternative (no centralized and regional) a County Flood Control District 6-3 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 6. Alternatives TABLE 6-1 SUMMARY OF PROGRAM IMPACT ANALYSIS Significance Issue Area Determination Aesthetics LSM Air Quality (Construction) SU Air Quality (Operation) LTS Air Quality (Cumulative Construction) SU Biological Resources (Direct and Cumulative) LSM Cultural Resources SU Cultural Resources (Cumulative) SU Geology and Soils/Mineral Resources (Direct and Cumulative) LSM Greenhouse Gas Emissions LTS Hazards and Hazardous Materials (Direct and Cumulative) LSM Hydrology and Water Quality (Direct and Cumulative) LSM Land Use and Planning/Agriculture (Direct and Cumulative) LTS Noise (Construction) SU Noise (Operation) LTS Noise (Cumulative) SU Population and Housing and Environmental Justice LTS (Direct and Cumulative) Public Services/Recreation (Direct and Cumulative) LTS Traffic and Transportation (Direct and Cumulative) LSM Utilities and Service Systems (Direct and Cumulative) LSM Growth Inducement (Direct/Indirect) LTS LTS = Less than Significant LSM = Less than Significant with Mitigation SU = Significant and Unavoidable SOURCE: ESA 2014. 6,4.1 No Program Alternative The CEQA Guidelines require an analysis of the specific alternative of "no project" (CEQA Guidelines, Section 15126.6). Specifically, the CEQA Guidelines state that "[t]he purpose of describing and analyzing a `no project' alternative is to allow decision makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project." The "no project" alternative is not necessarily the same as the baseline used to determine the environmental impacts of the proposed program. The analysis of the no project alternative includes the existing baseline environmental conditions as well as "what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services" (CEQA Guidelines, Section 15126.6 (e)(2)). The analysis of impacts related to the no project alternative includes projecting what would reasonably be expected to occur "in the foreseeable future if the project were not approved." IA County Flood Control District 6-4 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 6. Alternatives The No Program Alternative (please note: for the sake of this EWMP, this PEIR will use the term "No Program Alternative") would result in the non -implementation of the EWMP approach allowed in the MS4 Permit. Although this would not necessarily result in noncompliance with MS4 Permit since preparation of the EWMPs is an optional compliance method, each Permittee would be required to reach water quality objectives for MS4 discharges on their own, with no clear compliance strategy. The collaborative approach outlined in the MS4 Permit would not be available to each Permittee. Under the No Project Alternative, each Permittee would construct BMPs necessary to achieve compliance, some of which would be similar to the proposed alternative. This includes the construction of distributed, centralized, and regional BMPs necessary to achieve local discharge compliance. Ability to Meet Program Objectives The No Program Alternative would not meet the EWMP objective to collaborate among agencies across the watershed to promote more cost-effective and multi -beneficial water quality improvement projects, but it would meet the other objectives to remove or reduce pollutants from dry- and wet -weather urban runoff and reduce the impact of stormwater and non-stormwater on receiving water quality through implementation of structural and non-structural BMPs. The No Project Alternative would not necessarily avoid the potential environmental impacts that would occur as a result of implementing the EWMPs, as compliance with the MS4 Permit is still required. However, to achieve compliance with the MS4 Permit, each of the BMPs would need to be installed rapidly to avoid permit violations. There would be less coordination within each watershed, which could result in inefficient or redundant BMPs based on municipal boundaries rather than watershed boundaries. Potential impacts of this alternative are discussed in the following pages. Aesthetics Under the No Project Alternative, each Permittee would implement BMPs within their jurisdictions that would result in aesthetic modifications similar to the proposed alternative. The impacts to aesthetics throughout the watershed would be site specific, similar to the proposed alternative. [Similar impacts] Air Quality Air emissions resulting from the construction of BMPs under the No Project Alternative would be similar to the proposed alternative since both alternatives would require installation of similar types of BMPs requiring similar types of construction methods. However, because the programs would need to be installed rapidly and because more BMPs would likely be required as a result of the inefficiencies of municipal boundaries, slightly more construction emissions would result. [Slightly greater impacts] a County Flood Control District 6-55 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 6. Alternatives Biological Resources Impacts to biological resources would be similar to the proposed alternative. The potential impacts to biological resources throughout the watershed would be site specific, but the BMP locations would be similar to those identified under the proposed alternative. [Similar impacts] Cultural Resources Impacts to cultural resources would be similar to the proposed alternative. The potential impacts to cultural resources throughout the watershed would be site specific, but the BMP locations would be similar to those identified under the proposed alternative. [Similar impacts] Geology and Soils/Mineral Resources Impacts to geological and mineral resources would be similar to the proposed alternative since impacts would be site specific and within similar locations. [Similar impacts] Greenhouse Gases Construction of the BMPs would result in only minor greenhouse gas (GHG) emissions. GHG emissions would be similar to the proposed alternative since similar BMPs would be constructed. In terms of the cumulative impact to global climate change, the impact would be similar to the proposed alternative. [Similar impacts] Hazards and Hazardous Waste Impacts to hazards and hazardous waste would be similar to the proposed alternative since impacts would be site specific and within similar locations. Localized subsurface contamination could be affected by any of the BMP types and individual projects would be subject to similar preconstruction evaluations to assess suitability of the location. [Similar impacts] Hydrology and Water Quality Achieving water quality objectives required in the MS4 Permit immediately would be difficult under the No Program Alternative since the permit does not allow for an installation grace period outside of the EWMP. The potential for noncompliance with the MS4 Permit under this alternative would result in a significant impact compared to that of the proposed alternative. [Greater impacts] Land Use Planning/Agriculture Impacts to land use would be similar to the proposed alternative since impacts would be site specific and within similar locations. [Similar impacts] Noise Noise resulting from the construction of BMPs under the No Project Alternative would be similar to the proposed alternative since both alternatives would require installation of similar types of BMPs requiring similar types of construction methods in similar locations. [Similar impact] a County Flood Control District 6-6 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 6. Alternatives Population and Housing Impacts to population and housing would be similar to the proposed alternative since impacts would be site specific and within similar locations. [Similar impact] Recreation Impacts to recreation would be similar to the proposed alternative since impacts would be site specific and within similar locations. [Similar impact] Transportation and Circulation Impacts to transportation and circulation would be similar to the proposed alternative since impacts would be site specific and within similar locations. [Similar impacts] Utilities and Service Systems Impacts to utilities and service systems would be similar to the proposed alternative since impacts would be site specific and within similar locations. [Similar impacts] 6.4,2 Non -Structural BMPs Only Project Alternative The Non -Structural BMPs Only Project Alternative would involve implementation of the proposed program and its associated non-structural BMPs only. No structural BMPs would be implemented as the significant and unavoidable impacts are generally related to construction activities associated with the structural BMPs. For example, the significant and unavoidable air quality, noise, and cultural resources impacts would be avoided through implementation of non- structural BMPs only because non-structural BMPs would not result in construction activities. The proposed program would focus on implementation of policies, actions, and activities that are intended to prevent pollutants from entering stormwater runoff, thus eliminating the source of the pollutants. Ability to Meet Program Objectives The Non -Structural BMPs Only Project Alternative would avoid the potential environmental impacts that would occur as a result of implementing the proposed program. While these measures would help to improve water quality in the EWMP areas, sole reliance on these non- structural BMPs may not provide the level of water quality treatment needed to meet the water quality objectives of the Regional Water Quality Control Board Basin Plan and as required by the MS4 Permit. The Non -Structural BMPs Only Project Alternative may not meet the objectives of the proposed program to collaborate among agencies to promote more cost-effective and multi - beneficial water quality improvement projects because Non -Structural BMPs are generally implemented individually in each jurisdiction, so collaboration efforts for cost-effective solutions diminishes with implementation of non-structural BMPs only. Nonetheless, potential impacts of this alternative are discussed in the following pages. a County Flood Control District 6-7 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 6. Alternatives Impact Analysis Aesthetics The Non -Structural BMPs Only Project Alternative would avoid construction impacts identified in the proposed alternative. However, many BMPs, such as green -streets and grassy swales, would improve local aesthetics. The Non -Structural BMPs Only Project Alternative would minimize this multi-purpose benefit of the project. [Greater impacts] Air Quality The Non -Structural BMPs Only Project Alternative would avoid construction impacts identified in the proposed alternative. The elimination of construction emissions throughout the region would result in the use of fewer off-road vehicles and fewer emissions. [Fewer impacts] Biological Resources The Non -Structural BMPs Only Project Alternative would avoid direct impacts to biological resources from construction. Although dry -weather flows would be reduced under this alternative, relying solely on non-structural BMPs would be less effective than the combination of BMPs planned in the proposed alternative. Impacts to biological resources would be less under the Non -Structural BMPs Only Project Alternative. [Fewer impacts] Cultural Resources The Non -Structural BMPs Only Project Alternative would avoid construction impacts, resulting in fewer impacts to cultural resources. [Fewer impacts] Geology and Soils/Mineral Resources The Non -Structural BMPs Only Project Alternative would avoid construction impacts and infiltration impact, resulting in fewer impacts to geological resources. The potential for increased unstable soils from infiltration would be reduced under this alternative. [Fewer impacts] Greenhouse Gases The Non -Structural BMPs Only Project Alternative would avoid construction impacts identified in the proposed alternative. The elimination of construction emissions throughout the region would result in fewer GHG emissions. [Fewer impacts] Hazards and Hazardous Waste The Non -Structural BMPs Only Project Alternative would avoid construction impacts and infiltration impact, resulting in fewer impacts to hazards. The potential for increased mobilization of contamination in soils would be reduced under this alternative. [Fewer impacts] Hydrology and Water Quality The water quality benefit provided by the structural BMPs would be eliminated under this alternative. Achieving water quality objectives required in the MS4 Permit with no structural a County Flood Control District 6-6 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 6. Alternatives BMPs would be unlikely. The potential for non-compliance with the MS4 Permit under this alternative would result in a significant impact of the alternative. [Greater impacts] Land Use Planning/Agriculture The Non -Structural BMPs Only Project Alternative would avoid construction impacts and infiltration impact, resulting in fewer impacts to land uses and agriculture. [Fewer impacts] Noise The Non -Structural BMPs Only Project Alternative would avoid construction impacts and infiltration impact, resulting in fewer impacts to noise. [Fewer impacts] Population and Housing The avoidance of construction would not affect population and housing. Impacts would be similar to the proposed alternative. [Similar impacts] Recreation The avoidance of construction would not affect recreation. Impacts would be similar to the proposed alternative. [Similar impacts] Transportation and Circulation The avoidance of construction would reduce impacts to transportation and circulation. Impacts would be less than the proposed alternative. [Fewer impacts] Utilities and Service Systems The avoidance of construction and increased infiltration would reduce impacts to utilities and service systems. Impacts would be less than the proposed alternative. [Fewer impacts] 6,4e3 Distributed Structural and Non -Structural BMPs Only Program Alternative (No Centralized or Regional) The Distributed Structural BMPs Only Project Alternative would involve implementation of the proposed program and only its associated distributed structural BMPs and non-structural BMPs. Since much of the impacts of program implementation would occur during construction of the large-scale regional and centralized BMPs, this alternative would result in fewer construction impacts than the proposed project. Ability to Meet Program Objectives The Distributed Structural BMPs Only Program Alternative would meet the objectives of the proposed program to collaborate among agencies to promote more cost-effective and multi - beneficial water quality improvement projects. However, because distributed structural BMPs tend to be smaller in nature and typically are distributed widely throughout the watershed, more BMPs may be necessary to meet water quality objectives in the MS4 Permit. The ability to meet a County Flood Control District 6-9 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 6. Alternatives the water quality objectives would be less certain under this alternative. Potential impacts of this alternative are discussed in the following pages. Impact Analysis Aesthetics Constructing more distributed BMPs and no large-scale regional or centralized BMPs would result in similar aesthetics impacts on the regional level within each watershed. Although more widely dispersed projects would result in more locations being subjected to short-term construction activities, post -construction impacts would largely be beneficial, since green -streets and small-scale grassy swales would be installed that generally would improve local character in urban settings. In addition, any adverse post -construction impacts to local aesthetics from the larger BMPs would be avoided. [Fewer impacts] Air Quality Constructing fewer large-scale BMPs would result in fewer daily emissions. Although construction of more widely dispersed small-scale BMPs may increase the number of construction projects, the smaller size would result in the use of fewer off-road vehicles and fewer emissions. [Fewer impacts] Biological Resources Constructing fewer large-scale BMPs would result in impacts similar to biological resources as the proposed alternative. Impacts to biological resources from construction of BMPs would be site specific regardless of the type of program being implemented. The potential to reduce surface flows supporting riparian and wetland resources would be similar to the proposed alternative. [Similar impacts] Cultural Resources Constructing fewer large-scale BMPs, but more small-scale BMPs would have similar impacts to cultural resources as the proposed alternative. Impacts to cultural resources would be site specific regardless of the type of project being implemented. [Similar impacts] Geology and Soils/Mineral Resources Impacts to geological and mineral resources would be similar to the proposed alternative since impacts would be site specific regardless of the type of BMPs being built. [Similar impacts] Greenhouse Gases Construction of the BMPs would result in only minor GAG emissions. Constructing fewer large- scale BMPs would result in fewer GAG emissions overall, but in terms of the cumulative impact to global climate change, the impact would be similar to the proposed alternative. [Similar impacts] a County Flood Control District 6-10 ESA / 140474 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 6. Alternatives Hazards and Hazardous Waste Impacts to hazards and hazardous waste would be similar to the proposed alternative since impacts would be site specific regardless of the type of BMPs being built. Localized subsurface contamination could be affected by any of the BMP types and individual projects would be subject to similar preconstruction evaluations to assess suitability of the location. [Similar impacts] Hydrology and Water Quality The water quality benefit provided by the large-scale regional BMPs would be eliminated under this alternative. Achieving water quality objectives required in the MS4 Permit with a greater number of small-scale BMPs may be unlikely if larger regional BMPs are not constructed. The potential for noncompliance with the MS4 Permit under this alternative would result in a significant impact compared to that of the proposed alternative. [Greater impact] Land Use Planning/Agriculture Construction of a greater number of BMPs would have greater impacts to land uses within each watershed since more projects would be required. The large-scale BMPs would be located in areas with sufficient developable space. Eliminating use of these large open -space areas would disperse land use acquisition and compatibility impacts throughout the watershed. Impacts would be greater under this alternative. [Greater impacts] Noise Construction of more BMPs would subject a greater number of people to temporary construction noise. However, impacts from the longer-term construction of large BMPs would be avoided. Since impacts would be site specific, impacts from construction noise would be similar to the proposed alternative. [Similar impacts] Population and Housing Construction of more small-scale BMPs and fewer large-scale BMPs would have similar effects to population and housing as the proposed alternative. [Similar impacts] Recreation Construction of more small-scale BMPs and fewer large-scale BMPs would have similar effects to recreation within the watersheds. Impacts would be site specific under either alternative. [Similar impacts] Transportation and Circulation Construction of more small-scale BMPs and fewer large-scale BMPs would have similar effects to transportation and circulation within the watersheds. Smaller projects would have shorter duration impacts to roadways, but would occur in more locations. Impacts would be site specific under either alternative. [Similar impacts] a County Flood Control District 6-11 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 6. Alternatives Utilities and Service Systems Construction of more small-scale BMPs and fewer large-scale BMPs would have similar effects to utilities and service systems as the proposed alternative. Construction impacts would be site specific. [Similar impacts] 6.5 Comparison of Alternatives This section provides a summary comparison of the alternatives relative to the proposed program, with respect to their ability to meet program objectives and their relative environmental impacts compared to the proposed program. Table 6-2 summarizes the ability of the proposed program, the No Program Alternative, the Non -Structural BMPs Only Project Alternative, and the Distributed Structural and Non -Structural BMPs Only Project Alternative to meet the program objectives; it also summarizes the environmental impacts of these alternatives relative to the proposed program. 6.6 Alternatives Suggested in Scoping Several alternatives were suggested in comment letters received during the Notice of Preparation (NOP) Scoping process. These comments are included in Appendix A. One comment letter from Dr. Tom Williams representing the Sierra Club suggested that the PEIR include an assessment of several funding mechanism alternatives, including: Single Parcel Fee Assessment, Parcel Area Fee Assessment, Hybrid Parcel Area Fee Assessment, Zero Discharge Assessment, and Large Parcel Assessment. These suggested alternatives would not lessen any significant environmental impacts of the Program and were therefore not considered in this PEIR. Although CEQA allows for discussion of economic impacts and project costs as measures of feasibility, the funding mechanisms required to implement projects are generally not susceptible to environmental analysis. For these reasons, these suggested alternatives were not evaluated as program alternatives for CEQA compliance. In addition to the fee assessment alternatives, the comment suggested a Full Capture and Recharge of Flows Greater than 100 cfs Alternative. This suggested alternative was rejected from further consideration because of the infeasibility of capturing all storm flows in Los Angeles County. The retention basins required to retain all storm flows in the County would be unrealistic, requiring most of the developed land in the County to be accomplished. The comment may have been suggesting full capture of all flows less than 100 cfs, but, again, this alternative was rejected from further consideration for the same reason: that the retention basins needed to retain and recharge all flows in Los Angeles County waterways less than 100 cfs would require enormous areas of undeveloped lands that are currently developed. Furthermore, groundwater recharge is only feasible in certain areas of the County because of the poor percolation capacity of surfrcial soils in some areas. The accumulation of subsurface clay lenses creates recharge barriers in many places of the County, making retention and recharge of large quantities of stormwater infeasible in these locations. a County Flood Control District 6-12 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 6. Alternatives TABLE 6-2 ABILITY OF PROJECT ALTERNATIVES TO MEET PROJECT OBJECTIVES 6.7 Environmentally Superior Alternative CEQA requires that an EIR identify the environmentally superior alternative(s) of a project other than the proposed program or the "no project' alternative (CEQA Guidelines Section 15126.6 (e)(2)). As stated at the beginning of this chapter, the purpose of this alternatives analysis is to consider a reasonable range of alternatives that could feasibly attain most of the basic project objectives and avoid or substantially lessen significant program impacts. IA County Flood Control District 6-13 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report Proposed Program No Project Non -Structural BMPs Only Distributed Structural/Non- Structural BMPs Only Project Objectives To collaborate among agencies (Permittee jurisdictions) across the watershed to promote more cost-effective and multi -beneficial water Yes No No No quality improvement projects to comply with the MS4 Permit. To develop watershed -wide EWMPs that will, once implemented, remove or reduce Yes No No No pollutants from dry- and wet -weather urban runoff in a cost-effective manner. To reduce the impact of stormwater and non- Yes Yes No Yes stormwater on receiving water quality. Environmental Impacts Aesthetics LSM Similar Greater Fewer Air Quality (construction/operation) SU/LTS Similar Fewer Similar Biology LSM Similar Fewer Similar Cultural Resources SU Similar Fewer Similar Geology/Mineral Resources LSM Similar Fewer Similar Greenhouse Gases LTS Similar Fewer Similar Hazards and Hazardous Materials LSM Similar Fewer Similar Hydrology and Water Quality LSM Greater Greater Greater Land Use/Agriculture LTS Similar Similar Greater Noise (construction/operation) SU/LTS Similar Fewer Similar Public Services/Recreation LTS Similar Similar Similar Population and Housing and Environmental LTS Similar Similar Similar Justice Transportation and Traffic LSM Similar Fewer Similar Utilities and Service Systems LSM Similar Fewer Similar LTS = Less than Significant LSM = Less than Significant with Mitigation SU = Significant and Unavoidable 6.7 Environmentally Superior Alternative CEQA requires that an EIR identify the environmentally superior alternative(s) of a project other than the proposed program or the "no project' alternative (CEQA Guidelines Section 15126.6 (e)(2)). As stated at the beginning of this chapter, the purpose of this alternatives analysis is to consider a reasonable range of alternatives that could feasibly attain most of the basic project objectives and avoid or substantially lessen significant program impacts. IA County Flood Control District 6-13 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report 6. Alternatives The No Program Alternative would require that individual Permittees design and construct BMPs locally to achieve MS4 Permit compliance. As a result, impacts from construction of large and small BMPs would be similar to the proposed alternative. None of the significant and unavoidable impacts of the proposed alternative would be avoided by this alternative. Furthermore, since the ability to achieve compliance with MS4 Permit water quality objectives would be reduced if each Permittee were on their own, impacts to water quality would be greater under this alternative. The Distributed Structural BMPs Only Alternative would result in construction of an increased number of distributed BMPs, but would avoid construction and operational impacts associated with the large-scale centralized and regional BMPs. Many of the significant and unavoidable impacts of the proposed alternative would be avoided or substantially minimized under this alternative, including construction impacts involving noise and air emissions. However, since the ability to achieve compliance with MS4 Permit water quality objectives would be reduced without the larger -scale centralized and regional BMPs, impacts to water quality would be greater under this alternative. The Non -Structural BMPs Only Alternative would avoid all of the significant and unavoidable impacts associated with construction of the structural BMPs. In addition, nearly all of the impacts associated with the proposed alternative would be avoided, including impacts from infiltration to neighboring subsurface structures, mobilization of contaminants, and site-specific impacts to cultural and biological resources. However, since the ability to achieve compliance with MS4 Permit water quality objectives would be substantially reduced, impacts to water quality would be greater under this alternative, and compliance with the MS4 Permit would be unlikely. Even though this alternative would avoid significant and unavoidable impacts of construction and operation of structural BMPs, the failure to meet water quality objectives and achieve MS4 Permit compliance would outweigh the avoidance of the other impacts. In order to reduce overall potential impacts, the EWMPs will emphasize the use of non-structural BMPs that include true source control measures , e.g. reduction of copper in brake pads through enacted state-wide legislation. Furthermore, as discussed, due to the difficultly of locating larger regional BMPs, the use of distributed BMPs with a lower potential for impact will be emphasized in the EWMPs as well. 6-16, As a result, since the proposed alternative would provide the best chance of achieving regional water quality objectives, it is considered the environmentally superior alternative. a County Flood Control District 6-14 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Environmental Impact Report CHAPTER 7 Organizations and Persons Contacted 7A Participating Permittees County of Los Angeles Department of Public Works Gregg BeGell, P.E. — Project Manager Technical Staff: TJ Moon Jolene Guerrero Genevieve Osmena Bruce Hamamoto City of Los Angeles Department of Public Works Mr. Huub Cox Participating EWMP Group Representatives 1. Dominguez Channel — Alfredo Magallanes, City of Los Angeles 2. Peninsula Cities — Andy Winje, Rancho Palos Verdes 3. Upper Los Angeles River - Alfredo Magallanes , City of Los Angeles 4. Marina del Rey — Bruce Hamamoto, County of Los Angeles 5. Santa Monica Bay Jurisdictional Group 2 & 3 — Huub Cox, City of Los Angeles 6. Beach Cities — Elaine Jeng, Redondo Beach 7. Ballona Creek — Huub Cox, City of Los Angeles 8. Santa Clara — Heather Merenda, Santa Clarita 9. Rio Hondo/San Gabriel River — Jane Carlson, Sierra Madre 10. Malibu Creek Watershed — Alex Farassati, City of Calabasas 11. North Santa Monica Bay Coastal Watersheds — Jennifer Brown, Malibu 12. Upper San Gabriel River — Jolene Guerrero, County of Los Angeles 7.2 NOP and Distribution List Refer to Appendix A for a copy of the Notice of Preparation and distribution/mailing list. IA County Flood Control District 7-1 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report CHAPTER 8 Report Preparers 8.1 Lead Agency Los Angeles County Flood Control District 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 Gregg BeGell, P.E. — Project Manager Technical Staff: Jolene Guerrero TJ Moon Bruce Hamamoto Genevieve Osmena 8.2 Draft PER Environmental Science Associates 626 Wilshire Boulevard, Suite 1100 Los Angeles, California 90017 Tom Barnes — Project Director David Pohl — Project Manager Laura Rocha — Deputy Project Manager Technical Staff: Greg Ainsworth Megan Rhode Paige Anderson, CESSWI Denise Russell Madeleine Bray, M.A., R.P.A. Eric Schniewind Michael Burns, CHG Kevin Smith Courtney Casey Monica Strauss Hunter Connell Christina Toms Dustin Dirks Linda Uehara Jack Hutchison, P.E. Michael Williams May Lau Terrance Wong Jason Nielsen Weston Solutions, Inc. 5817 Dryden Place, Suite 101 Carlsbad, CA 92008 Andrea Crumpacker — Project Manager IA County Flood Control District 8-1 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report CHAPTER 9 References Introduction and Project Description Ballona Creek Watershed Management Group, Enhanced Watershed Management Program (EWMP) Final Work Plan, prepared by City of Beverly Hills, City of Culver City, City of Los Angeles, City of Inglewood, City of Santa Monica, City of West Hollywood, County of Los Angeles, and Los Angeles County Flood Control District, June 2014. Ballona Creek Watershed Management Group, Revised Notice of Intent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, December 2013. Beach Cities Watershed Management Group, Enhanced Watershed Management Program (EWMP) Work Plan, prepared by City of Hermosa Beach, City of Manhattan Beach, City of Redondo Beach, City of Torrance, and Los Angeles County Flood Control District, June 2014. Beach Cities Watershed Management Group, Notice of Intent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, December 2013. California Environmental Protection Agency State Water Resources Control Board, official website, http://www.waterboards.ca.gov/losangeles/, accessed July 29, 2014. California Regional Water Quality Control Board Los Angeles Region, Waste Discharge Requirements for Municipal Separate Storm Sewer System (MS4) Discharges Within the Coastal Watersheds of Los Angeles County, Order NO. R4-2012-0175, NPDES Permit NO. CAS00400I. December 2012. Center for Watershed Health (CWH). 2014. Elmer Avenue Neighborhood Retrofit Project. http://watershedhealth.org/programsandproj ects/was.aspx?search—elmer Dominguez Channel Watershed Management Area Group, Enhanced Watershed Management Program Work Plan, prepared by City of Los Angeles, County of Los Angeles, City of Hawthorne, City of Inglewood, City of El Segundo, City of Lomita, and Los Angeles County Flood Control District, June 2014. Dominguez Channel Watershed Management Area Group, Notice of Intent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, June 2013. Los Angeles County Department of Public Works. 2007. A New Water Treatment System Targets Bacteria at One of the State's "Worst" Beaches for Water Quality. http://ladpw.org/apps/news/pdf/2380_2627.pdf IA County Flood Control District 9-1 ESA / 140474 Enhanced Watershed Management programs January2015 Draft program Environmental Impact Report 9. References Malibu Creek Watershed Group, Revised Notice of Intent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, June 2013. Malibu Creek Watershed Management Group, Enhanced Watershed Management Program Work Plan, prepared for City of Calabasas, City of Agoura Hills, City of Westlake Village, City of Hidden Hills, County of Los Angeles and Los Angeles County Flood Control District, June 2014. Marina del Rey Enhanced Watershed Management Agencies, Marina del Rey Enhanced Watershed Management Program Work Plan, prepared for County of Los Angeles, Los Angeles County Flood Control District, City of Los Angeles, and City of Culver City, June 2014. Marina del Rey Watershed Group, Revised Notice of Intent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, March 2014. North Santa Monica Bay Coastal Watersheds EWMP Group, Enhanced Watershed Management Program (EWMP) Work Plan, prepared by City of Malibu, County of Los Angeles, and Los Angeles County Flood Control District, June 2014. North Santa Monica Bay Coastal Watersheds, Notice of Intent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, March 2014. Palos Verdes Peninsula EWMP Agencies, Notice of Intent: Peninsula Enhanced Watershed Management Plan, June 2013. Palos Verdes Peninsula Watershed Management Group, Palos Verdes Peninsula Enhanced Watershed Management Program Work Plan, June 2014. Rio Hondo/San Gabriel River Water Quality Group, Enhanced Watershed Management Program Work Plan, prepared for City of Arcadia, City of Azusa, City of Bradbury, City of Duarte, City of Monrovia, City of Sierra Madres, County of Los Angeles, and Los Angeles County Flood Control District, June 2014. Rio Hondo/San Gabriel River Water Quality Group, Notice of Intent: Enhanced Watershed Management Program (EWMP), June 2013. Santa Monica Bay Watershed (J2, J3), Notice of Intent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, December 2013. Santa Monica Bay Watershed Jurisdictions 2 & 3, Enhanced Watershed Management Program Work Plan, prepared by City of Los Angeles, Los Angeles County Flood Control District, County of Los Angeles, City of Santa Monica, and City of El Segundo, June 2014. Upper Los Angeles River Watershed Group, Notice of Intent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, June 2013. IA County Flood Cenral District 9-2 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 9. References Upper Los Angeles River Watershed Management Group, prepared by City of Alhambra, City of Burbank, City of Calabasas, City of Glendale, City of Hidden Hills, City of La Canada Flintridge, City of Los Angeles, City of Montebello, City of Monterey Park, City of Pasadena, City of Rosemead, City of San Gabriel, City of San Marino, City of South Pasadena, City of Temple City, County of Los Angeles, and Los Angeles County Flood Control District, Enhanced Watershed Management Program Work Plan, June 2014. Upper San Gabriel River EWMP Group, Draft Enhanced Watershed Management Program Work Plan, prepared for City of Baldwin Park, City of Covina, City of Glendora, City of Industry, City of La Puente, County of Los Angeles, and Los Angeles County Flood Control District, June 2014. Upper San Gabriel River EWMP Group, Notice of Intent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, June 2013. Upper Santa Clara River Watershed Management Group, Enhanced Watershed Management Program — Work Plan, prepared for City of Santa Clarita, County of Los Angeles, and Los Angeles County Flood Control District, June 2014. Upper Santa Clara River Watershed Management Group, Notice of Intent: Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program, June 2013. Aesthetics California Department of Transportation, California Scenic Highway Mapping System (2014). Available online at: http://www.dot.ca.gov/hq/LandArch/scenic_highways/scenic_hwy.htm. Accessed September 29, 2014. City of Malibu, General Plan, 1995. City of Agoura Hills, General Plan, 2010. Los Angeles County Department of Public Works, Los Angeles River Master Plan, June 1996. Final Dominguez Watershed Management Master Plan, April 2004. , San Gabriel River Corridor Master Plan, June 2006. Los Angeles County Department of Regional Planning, 1980. Existing Adopted General Plan. Available Online: http://planning.lacounty.gov/generalplan/existing, accessed September 29, 2014. 2014. 2014 Draft General Plan 2035. Available online: http://planning.lacounty.gov/generalplan/draft20l4, accessed September 29, 2014. Los Angeles Regional Water Quality Control Board (LARWQCB), State of the Watershed — Report on Surface Water Quality Santa Clara River Watershed, November 2006. IA County Flood Cenral District 9-3 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 9. References State of the Watershed – Report on Surface Water and Sediment Quality The Dominguez Channel and Los Angeles/Long Beach Harbors Watershed Management Area, October 2008. State of the Watershed – Report on Surface Water Quality Santa Monica Bay Watershed Management Area, November 2011. United States Environmental Protection Agency Region IX, Ballona Creek Wetlands Total Maximum Daily Loads for Sediment and Invasive Exotic Vegetation, March 26, 2012. Air Quality California Air Resources Board (CARB). 2014a. California Greenhouse Gas Inventory for 2000- 2012 — by Category as Defined in the 2008 Scoping Plan. Available: <http://www.arb.ca.gov/cc/inventory/data/tables/ghg_inventory_scopingplan_00-12_2014- 03-24.pdf> 2014b. Proposed First Update to the Climate Change Scoping Plan: Building on the Framework. February. . 2013a. Ambient Air Quality Standards. Last revised: June 4, 2013. Available: <http://www.arb.ca.gov/research/aaqs/aags2.pdf>. Accessed: August 7, 2014. .2013b. Aerometric Data Analysis and Management System. Available: <http://www.arb.ca.gov/adam/welcome.htrnl>. Accessed: August 7, 2014. . 2013c. Area Designation Maps/State and National. Available: <www.arb.ca.gov/desig/adm/adm.htm/>. Accessed August 7, 2014. . 2011. Final Supplement to the AB 32 Scoping Plan Functional Equivalent Document. Available: <hftp://www.arb.ca.gov/cc/scopingplan/document/final_ supplement_ to_sp_fed.pdf>. .2009a. The California Almanac of Emissions and Air Quality – 2009 Edition. Available: http://www.arb.ca.gov/aqd/almanac/almanac09/almanacO9.htrn. 2009b. Climate Change Scoping Plan: A Framework for Change, available online: http://www.arb.ca.gov/cc/scopingplan/document/adopted_ scoping_plan.pdf, published December 2008, amended version included errata and Board requested modifications posted May 11, 2009. . 2007. Expanded List of Early Action Measures To Reduce Greenhouse Gas Emissions In California Recommended For Board Consideration. . 2004.2004 Revision to the California State Implementation Plan for Carbon Monoxide Updated Maintenance Plan for Ten Federal Planning Areas. July 22. CEC. 2006. Inventory Greenhouse Gas Emissions and Sinks: 1990 to 2004. Staff Final Report. CEC-600-2006-013-SF. December 2006. a County Flood Cenral District 9-4 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 9. References Los Angeles County General Plan. 2014. Available: http://planning.lacounty.gov/assets/upl/project/gp_2035 Chapter8_2014.pdf South Coast Air Quality Management District (SCAQMD). 2013. Final 2012 Air Quality Management Plan. February. Biological Resources California Department of Fish and Wildlife (CDFW). 2014. California Natural Diversity Database (CNDDB). Wildlife Habitat Data Analysis Branch, Habitat Conservation Division, CDFW, Sacramento, CA. September. California Native Plant Society. 2014. Rare and Endangered Plant Inventory. Accessed September 24, 2014. County of Los Angeles, Department of Public Works. 2012a. The Greater Los Angeles County Open Space for Habitat and Recreation Plan (Integrated Regional Water Management Plan Update — 2012). June 2012. County of Los Angeles, Department of Regional Planning. 2012b. References to the SEA Program in the Adopted 1980 General Plan. March 5. U.S. Fish and Wildlife Service. 2014a. Critical Habitat Fact Sheet. Accessed on September 25, 2014 at http://www.fws.gov/midwest/endangered/saving/CriticalHabitatFactSheet.html. July 16. . 2014b. Critical Habitat Portal. Accessed on September 25, 2014 at http://ecos.fws.gov/crithab/. . 2014c. Trust Resources List (Endangered Species Act Species List for Los Angeles County). Available at http://ecos.fws.gov/ipac/. Accessed on September 24, 2014. South Coast Wildlands. 2008. South Coast Missing Linkages: A Wildland Network for the South Coast Ecoregion. Produced in cooperation with partners in the South Coast Missing Linkages Initiative. Available online at http://www.scwildlands.org. Cultural Resources Altschul, Jeffrey, H., Anne Q. Stoll, Donn R. Grenda, and Richard Ciolek-Torrello, editors, At The Base Of The Bluff Archaeological Inventory And Evaluation Along Lower Centinela Creek, Marina Del Rey, California, Playa Vista Monograph Series Test Excavation Report 4, Statistical Research Inc, Tucson, Arizona, April 2003. Arnold, Jeanne E., Michael Walsh and Sandra E. Hollimon, The Archaeology of California. Journal of Archaeological Research 12(1):1-73, 2004. Axelrod, D.I.1950. The Piru Gorge flora of southern California. Carnegie Inst. Wash. Publ.590: 159-214. a County Flood Cenral District 9-5 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 9. References Bean, L.J., and C.R. Smith, Gabrielino, in California, edited by R.F. Heizer, pp. 538-549 Handbook of North American Indians, Vol. 8, W. C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C., 1978. 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Rancho Palos Verdes, Natural Communities Conservation Planning Subarea Plan, July 29, 2004. a County Flood Cenral District 9-17 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 9. References Noise California Department of Transportation (Caltrans). 1998. Technical Noise Supplement. October. Caltrans. 2013. Transportation and Construction Vibration Guidance Manual. September. County of Los Angeles, Municipal Code. 1973. Part 3 — Community Noise Criteria and Part 4 — Specific Noise Restrictions. Available at http://library.municode.com/index.aspx?clientld=16274. Accessed September 24, 2014. Federal Interagency Committee On Noise (FICON). 1992. Federal Agency Review of Selected Airport Noise Analysis Issues. August. Federal Highway Administration (FHWA). 2006. FHWA Construction Roadway Noise Model User's Guide. Final Report. January. Federal Transit Administration (FTA). 2006. Transit Noise and Vibration Impact Assessment. May. 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Accessed at http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?src=CF on November 18, 2014. .2008-2012. American Community Survey 5 -Year Estimates. Selected Economic Characteristics. Accessed at http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview. xhtml?pid=ACS_ 12 _5YR DP03&prodType=table on 26 August 2014. . 2010. Profile of General Population and Housing Characteristics: 2010. Public Services / Recreation Google. 2014. General Search: "School Districts in Los Angeles." Accessed November 20, 2014. Los Angeles County Department of Regional Planning (Los Angeles County). 1980. Existing Adopted General Plan. Available Online: http://planning.lacounty.gov/generalplan/existing, accessed September 4, 2014. . 2014. 2014 Draft General Plan 2035. Available online: http://planning.lacounty.gov/generalplan/draft20l4, accessed September 4, 2014. 2014. Los Angeles County General Plan Update Draft EIR. June 2014. Los Angeles County Department of Parks and Recreation (LADPR). 2014. "Parks." Accessed at http://parks.lacounty.gov/wps/portal/dpr/AboutUs/Directors_ Message on November 18, 2014. Los Angeles County Fire Department (LACoFD). 2013. Strategic Plan. Available Online: http://www.fire.lacounty.gov/wp-content/uploads/2014/02/LACFD Strategic- Plan-2012—Web.pdf, accessed September 4, 2014. Los Angeles County Office of Education (LACOE). 2014. LACO Brochure. Accessed at http://www.lacoe.edu/Portals/0/LACOE/LACOE_Brochure_2014.pdf on November 18, 2014. IA County Flood Cenral District 9-19 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 9. References Los Angeles Unified School District (LAUSD). 2014. About the Los Angeles Unified School District. Accessed at http://achieve.lausd.net/about on September 17, 2014. 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Accessed at http://www.beverlyhills. org/cbhfiles/storage/files/filebank/9152-- Urban%20Water%2OManagement%2OPlan%202010_8-30-11.pdf on October 2, 2014 City of Los Angeles. 2014. Accessed at http://www.lastormwater.org/about-us/program- description/ on September 19, 2014. . 2009. Water Quality Compliance Master Plan for Urban Runoff, May 2009. Accessed at http://www.lastormwater.org/wp-content/files_mf/wgcmpur.pdf on November 17, 2014. City of Santa Clarita, One Valley One Vision Draft Program EIR, September 2010. http://www.santa- clarita.com/FileCenter/Extemal/EMIOVOV/Draft/3_17_UtilitieslnfraO9l4lO.pdf on October 8, 2014. Crescenta Valley Water District (CVWD). 2014. About Us. Accessed at http://www.cvwd.com/About-Us.aspx on September 17, 2014. . 2013. 2010 Urban Water Management Plan. Revised October 2013. Accessed at http://www.cvwd.com/Resources/Documents/2010%20U WMP%20revised%202013 %2OFi nal.pdf on September 17, 2014. Foothill Municipal Water District website: http://www.fmwd.com/About-Us.aspx Las Virgenes Municipal Water District website: http://www.lvmwd.com/your-water/wastewater- services a County Flood Cenral District 9-20 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 9. References Los Angeles County Department of Regional Planning, 1980. Existing Adopted General Plan. Available Online: http://planning.lacounty.gov/generalplan/existing, accessed September 11, 2014. . 2014. 2014 Draft General Plan 2035. Available online: http://planning.lacounty.gov/generalplan/draft20l4, accessed September 4, 2014. 2014. Los Angeles County General Plan Update Draft EIR. June 2014. Los Angeles County Department of Public Works (LADPW). 2014. "What is the Flood Control District?" Accessed at http://dpw.lacounty.gov/lacfcd/sediment/dcon/352.pdf on September 19, 2014. Los Angeles County Flood Control District, Annual Report Attachment O, Total Maximum Daily Load (TMDL) Report on Monitoring, 2013. Accessed at: http://ladpw. org/wmd/npdesrsa/annualreport/2013%5 CLACFCD%5 CAttachments%5 CAtt ach%200%20-%20FCD%20TMDL%20Reporting.pdf, on November 17, 2014. Los Angeles County Department of Water and Power (LADWP), 2013. 2013 Final Power Integrated Resource Plan, December 2013. Los Angeles County. Construction and Demolition Debris Recycling and Reuse Program. Accessed at http://dpw.lacounty.gov/epd/cd/ on September 29, 2014. Los Angeles County. Water Agencies. Accessed at http://www.lacounty.gov/wps/portal/!ut/p/b0/04_Sj 9CPykssyOxPLMnMzOvMAfGjzOItDC DAyMIkOM3AyMfVItTT 1NjIwNdQvyDbUREABWgQfA! !/? 1 dmy&page=lac.home.gove mment.hidden&urile=wcm%3Apath%3 A/lacounty+content/lacounty+site/home/govemme nt/water+agencies on September 17, 2014. Los Angeles County Sanitation Districts (LACSD). 2014. Solid Waste Facilities. Accessed at http://lacsd.org/solidwaste/swfacilities/default.asp on October 2, 2014. 2012. Clearwater Program, Executive Summary, Final. November 2012. Metropolitan Water District (MWD). 2014. About MWD. Updated February 11, 2014. Accessed at http://www.mwdh2o.com/mwdh2o/pages/about/about0l.html on September 11, 2014. 2014. Regional Progress Report, February 2014. 2010. The Regional Urban Water Management Plan, November 2010. Regional Water Quality Control Board, Substitute Environmental Documents for the Malibu Creek Watershed Trash TMDL, 2008. Accessed at http://www.waterboards.ca.gov/losangeles/board_ decisions/basin plan amendments/techni cal_documents/63_New/08_0214/MCW%20Trash%20SED%20021408.pdf on October 2, 2014. . Substitute Environmental Documents for the Machado Lake Trash TMDL, 2007. Accessed at a County Flood Cenral District 9-21 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report 9. References http://www.waterboards.ca.gov/losangelesiboard_decisions/basin plan_amendments/techni cal_documents/2007-006/SED_Machado_Lake.pdf on October 2, 2014. San Gabriel Basin Water Quality Authority (WQA). 2014. About Us. Accessed at http://www.wga.com/sample-page/ on September 17, 2014. State Water Resources Control Board (SWRCB). 2012. Water Board's Structure Accessed at http://www.waterboards.ca.gov/about—us/water-boards—Structure/ on September 19, 2014. . 2014. Accessed at http://www.waterboards.ca.gov/water issues/programs/trash—control/ on October 9, 2014. Walnut Valley Water District (WV WD). 2014. Meet the District. Accessed at http://wvwd.com/index.php?option=com_content&view=article&id=2&Itemid=3 on September 17, 2014. Water Replenishment District of Southern California (WRD). 2014. About the Water Replenishment District. Accessed at http://www.wrd.org/about/about-water-replenishment- district.php on September 17, 2014. West Basin Municipal Water District (WBMWD). 2014. About West Basin. Accessed at http://www.westbasin.org/about-west-basin on September 17, 2014. U.S. Environmental Protection Agency Region IX, Total Maximum Daily Load for Trash Ballona Creek and Wetland, 2002. Accessed at http://ofmpub.epa.gov/watersIO/attains_impaired waters.show—tmdl—document?p_tmdI do c blobs id=60783 on October 2, 2014. IA County Flood Cenral District 9-22 ESA / 140674 Enhanced Watershed Management Programs January2015 Draft Program Environmental Impact Report Appendix A Notice of Preparation r ESA J Notice of Preparation Date August 29, 2014 To: California Office of Planning and Research, Responsible and Trustee Agencies and Interested Parties Subject: Notice of Preparation of a Draft Program Environmental Impact Report Project: Enhanced Watershed Management Programs Lead Agency: Los Angeles County Flood Control District Review Period: August 29, 2014 through September 29, 2014 The Los Angeles County Flood Control District (LACFCD) will be the Lead Agency and will prepare a Program Environmental Impact Report (PEIR) for the project identified in this notice. We need to know the views of you or your agency as to the scope and content of the environmental information which is germane to your agency's statutory responsibilities in connection with the proposed project. This Notice of Preparation (NOP) has been prepared to notify agencies and interested parties that the LACFCD is beginning preparation of a PEIR pursuant to the California Environmental Quality Act (CEQA) for its proposed Enhanced Watershed Management Programs (EWMPs, or "program"). The Los Angeles County Flood Control Act was adopted by the State Legislature in 1915 and established the LACFCD and empowered it to provide flood risk management, water conservation, and recreation and aesthetic enhancement within its boundaries. The LACFCD is governed as a separate entity by the Board of Supervisors of the County of Los Angeles and is operated by the County's Department of Public Works. The LACFCD encompasses more than 3,000 square miles, 85 cities, and approximately 2.1 million land parcels. The LACFCD, the County of Los Angeles, and 84 incorporated cities within Los Angeles County (collectively referred to as Permittees) are covered under a Municipal Separate Storm Sewer System (MS4) Permit (Order No. R4-2012-0175; National Pollutant Discharge Elimination System (NPDES] Permit No. CAS004001) for the discharge of urban runoff to waters of the United States. The purpose of the MS4 Permit is to ensure Permittees are not causing or contributing to exceedances of water quality objectives or impairments of beneficial uses in the receiving waters of the Los Angeles region. The 2012 MS4 Permit for Los Angeles County gives Permittees the option of implementing an innovative approach to Permit compliance through development of EWMPs. The LACFCD and participating Permittees have opted to exercise this option and have submitted 12 separate Notices of Intent (NOls) for the development of 12 EWMPs in their respective watershed groups to the Los Angeles Regional Water Quality Control Board (LARWQCB). The LARWQCB is responsible for approval of the EWMPs in compliance with the MS4 Permit. Implementation of the EMWPs would occur following approval by the LARWQCB. The preparation of the 12 separate EWMPs will be a collective effort among the LACFCD and the applicable agencies in each respective EWMP. The 12 EWMPs will vary for each watershed group, but will generally provide the opportunity for Permittees to customize their stormwater programs to achieve compliance with applicable receiving water limitations (RWLs) and water -quality -based effluent limits (WQBELs) in accordance with the MS4 Permit through implementation of stormwater best management practices (BMPs) or watershed control measures. BMPs vary in function and type, with each BMP providing unique design characteristics and benefits from implementation. The overarching goal of BMPs in the EWMP is to reduce the impact of stormwater and non-stormwater on receiving water Enhanced Watershed Management Programs ESA 1140474 Notice of Preparation August 2014 quality and address the water quality priorities as defined by the MS4 Permit. The development of each EWMP will involve the evaluation and selection of multiple BMP types, including nonstructural (institutional) and distributed, centralized, and regional structural watershed control measures, that will be implemented to meet compliance goals and strategies under the 2012 MS4 Permit. The LACFCD, as a regional agency charged with conserving stormwater for use in our local water supply, has a vested interest in increasing opportunities for stormwater capture and groundwater recharge. The LACFCD has flood control infrastructure in each of the EWMP areas and is participating in all 12 EWMPs. The LACFCD will be working with the applicable Permittees and other stakeholders in all 12 EWMP watersheds to develop the EWMPs, which will be implemented by the Permittees that have jurisdiction within each EWMP area. The Permittees implementing the projects defined in the EWMPs, or "implementing agencies," will vary between EWMPs and individual projects. The LACFCD will be an implementing agency only on those projects for which it has been identified in an EWMP as a responsible implementing party. Project Location: The proposed program would be located in several watersheds of Los Angeles County and would include the following enhanced watershed management groups: Ballona Creek, Beach Cities, Dominguez Channel, Malibu Creek, Marina del Rey, North Santa Monica Bay Coastal Watersheds (NSMBCW), Palos Verdes Peninsula, Rio Hondo/San Gabriel River Water Quality Group (RH/SGRWQG), Santa Monica Bay, Upper Los Angeles River, Upper San Gabriel River, and Upper Santa Clara River. The project area is indicated in Figure 1. Broad Range of Potential Benefits from EWMPs: If implemented, the proposed EWMP-generated benefits would include: • Improved Water Quality • Reduction in Impairment of Water Bodies for Designated Beneficial Uses Promotion of Water Conservation and Supply Enhanced Recreation Opportunities • Support for Public Education Opportunities Improved Local Aesthetics • Management of Flood Risks Public Comments: The LACFCD is soliciting the views of interested persons and agencies as to the scope and content of the environmental information to be evaluated in the PEIR. In accordance with CEQA, agencies are requested to review the project description in this NOP and provide their comments on environmental issues related to the statutory responsibilities of the agency. The PEIR will be used by LACFCD's governing Board, the Los Angeles County Board of Supervisors, when considering approval of the proposed EWMPs as well as for any related discretionary approvals. Due to the time limits mandated by state law, all comments to the NOP are due no later than September 292 2014. Please send your comments to the address shown below. Include a return address or email address and a contact name in your agency with your comments. Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 (626)300-3298 gbegell@dpw.lacounty.gov This NOP and other PEIR information, as it becomes available, can be accessed at: www.LACoH20sheds.com Enhanced Watershed Management Programs 1 ESA 1140474 Notice of Preparation August 2014 Scoping Meetings: Three scoping meetings will be held to receive public comments regarding the scope and content of the PEIR. The scoping meetings will include a brief presentation providing an overview of the proposed program and the CEQA process. After the presentation, oral comments will be accepted. Written comment forms will be supplied for those who wish to submit comments in writing at the scoping meeting. Written comments also may be submitted anytime during the NOP review period. The scoping meetings will be held as follows: DATE: Tuesday, September 9, 2014 TIME: 6:00 P.M. LOCATION: Chace Park Community Room TBD 13650 Mindanao Way Marina del Rey, CA 90292 DATE: Wednesday, September 10, 2014 TIME: 6:00 P.M. LOCATION: County of Los Angeles Department of Public Works 900 South Fremont Avenue First Floor Conference Room C Alhambra, CA 91803 DATE: Monday, September 15, 2014 TIME: 6:30 P.M. LOCATION: K Dalton Room Community Center 119 W Palm Ave Monrovia, CA 91016 Enhanced Watershed Management Programs ESA 1140474 Notice of Preparation August 2014 Figure 1: Overview EWMP Groups Enhanced Watershed Management Programs 4 ESA 1140474 Notice of Preparation August 2014 Beverly Hills, Culver City, Inglewood, Los Angeles, Santa Monica, West Hollywood, Ballona Creek IA County, LACFCD Beach Cities Watershed - Hermosa Beach, Manhattan Beach, Redondo Beach, Torrance, LACFCD Mana ement Grou Dominguez Channel Watershed - EI Segundo, Hawthorne, Inglewood, Los Angeles, Lomita, IA County, LACFCD Management Group - Malibu Creek Watershed Agoura Hi Its, Calabasas, Hidden Hills, Westlake Village, LA County, LACFCD _ Marina del Rey Culver City, Los Angeles, LACounty, LACFCD North Santa Monica Bay Coastal - LACounty, Malibu, LACFCD Watersheds Palos Verdes Peninsula EWMP - Palos Verdes Estates, Rancho Palos Verdes, Rolling Hills Estates, LACounty, LACFCD Agencies Rio Hondo/San Gabriel River Water Arcadia, Azusa, Bradbury, Duarte, Monrovia, LA County, Sierra Madre, LACFCD Quality Group - Santa Monica Bay Watershed Los Angeles, EI Segundo, Santa Monica, LACounty, LACFCD Jurisdictions 2 &3 Alhambra, Burbank, Calabasas, Glendale, Hidden Hills, La Canada Flintridge, Los Upper Los Angeles River Watershed Angeles, Montebello, Monterey Park,Pasadena, Rosemead,San Gabriel,San Marina South Pasadena Temple City, LACounty,LACFCD - Upper San Gabriel River Baldwin Park,Covina,Glendora,Industry, La Puente, LACounty, LACFCD - Upper Santa Clara River Watershed LACounty,Santa Clarice, LACFCD t i I i \t SA,NTACLAR4 RIVER WATERSHED I \ \ I 1 ( 1.0SAWIE1.1 s H11 I If It 117'HS111'0 1 S LA'T 110 1('.I r IJI) HATI RS'11tiD 3AN GABRIEL RIVER WATERS111I> f r Pacific Ocean --_-- Northern Boundary LACFCD i J DO iN(,v -rz QWatershed Boundary r,�J EFIA:\W L r' WATERSIIL]) Los Angeles County Boundary _ � N Area Outside Los Angeles County _;,-\ 0 6 12 Miles Jurisdictional Boundaries m in _. r' ESRITenain Imagery Sources: Esn, USGS, NOAA Enhanced Watershed Management Programs 4 ESA 1140474 Notice of Preparation August 2014 I . Introduction The LACFCD along with other applicable Permittees have submitted NOIs to the LARWQCB to develop EWMPs for 12 watershed groups, in accordance with the 2012 MS4 Permit, Order No. R4-2012-0175. The LARWQCB is responsible for approval of the final EWMPs in compliance with the MS4 Permit. Implementation of the EMWPs would occur following approval of the final plan. To begin preparing the EWMPs, the Permittees collaborated on, developed, and submitted Draft Work Plans to the LARWQCB, outlining the proposed approach to preparation of each of their respective EWMPs. The primary approach to each of the EWMPs, as identified in the Draft Work Plans, includes identifying community -friendly, cost-effective methods of reducing urban runoff pollution and incorporating distributed and centralized structural and nonstructural watershed control measures for a multi -pollutant, multi -benefit approach. The EWMPs will also evaluate multi -benefit regional projects that will retain (through infiltration or capture and reuse) the stormwater quality design volume (85" percentile storm for 24 hours) for the runoff from the contributing drainage area. The proposed project includes the potential nonstructural (institutional) and distributed, centralized, and regional structural watershed control measures described in the Draft Work Plans and detailed in the EWMPs currently under preparation. These measures will be evaluated in the PEIR. The PEIR will provide a program -level assessment of the overall permit compliance effort, focusing particularly on the structural watershed control measures proposed in each of the 12 EWMP areas. 1.1 Project Location The proposed program includes several watershed management groups of Los Angeles County, which include the following EWMP groups: Ballona Creek, Beach Cities, Dominguez Channel, Malibu Creek, Marina del Rey, North Santa Monica Bay Coastal Watersheds (NSMBCW), Palos Verdes Peninsula, Rio Hondo/San Gabriel River Water Quality Group (RH/SGRWQG), Santa Monica Bay, Upper Los Angeles River, Upper San Gabriel River, and Upper Santa Clara River. The geographic scope covered by each of these 12 EWMPs is described in further detail below and shown in Figure 1. • Ballona Creek —The Ballona Creek EWMP area covers the Ballona Creek watershed. The Permittees within this EWMP are the Cities of Beverly Hills, West Hollywood, Los Angeles, Inglewood, Culver City, Santa Monica, and West Hollywood; County of Los Angeles; and LACFCD. • Beach Cities —The Beach Cities EWMP area covers portions of three watersheds: Santa Monica Bay Watershed Jurisdictional Group (SMB JG) 5 & 6, Dominguez Channel Watershed, and Machado Lake Watershed. The Permittees within this EWMP are the Cities of Redondo Beach, Manhattan Beach, Hermosa Beach, and Torrance; and the LACFCD. • Dominguez Channel — The Dominguez Channel EWMP area covers portions of three watersheds: Dominguez Channel Watershed, the Machado Lake Watershed, and the Los Angeles/Long Beach Harbors Watershed. The Permittees within this EWMP are the Cities of El Segundo, Hawthorne, Inglewood, Lomita, and Los Angeles; County of Los Angeles; and the LACFCD. • Malibu Creek —The Malibu Creek Watershed (MCW) EWMP area covers the majority of the MCW. The Permittees within this EWMP are the Cities of Agoura Hills, Calabasas, Hidden Hills, , and Westlake Village; County of Los Angeles; and the LACFCD. Enhanced Watershed Management Programs `J ESA 1140474 Notice of Preparation August 2014 • Marina del Rey — The Marina del Rey EWMP area covers the Marina del Rey Watershed. The Permittees within this EWMP are the Cities of Los Angeles and Culver City; County of Los Angeles; and LACFCD. • North Santa Monica Bay — The NSMBCW EWMP area covers the SMB JG 1, SMB JG 4, and a portion of Malibu Creek within the City of Malibu's borders. The Permittees within this EWMP are the City of Malibu; County of Los Angeles; and LACFCD. • Palos Verdes Peninsula — The Palos Verdes Peninsula watershed management area covers most of the SMB JG7, the Los Angeles Harbor subwatershed, and the Machado Lake subwatershed. The Permittees within this EWMP are the Cities of Rancho Palos Verdes, Palos Verdes Estates, and Rolling Hills Estates; County of Los Angeles; and LACFCD. • Rio Hondo/San Gabriel River —The RH/SGRWQG EWMP area covers portions of the Los Angeles and San Gabriel River watersheds. The Permittees within this EWMP are the Cities of Arcadia, Azusa, Bradbury, Duarte, Monrovia, and Sierra Madre; County of Los Angeles; and LACFCD. • Santa Monica Bay — The Santa Monica Bay EWMP area covers the central region of the Santa Monica Bay Watershed (SMB JG2 and SMB JG3) and includes the urbanized Dockweiler and Santa Monica subwatersheds, as well as natural open space located in the Castle Rock, Pulga Canyon, Temescal Canyon, and Santa Monica Canyon subwatersheds. The Permittees within this EWMP include the Cities of Los Angeles, Santa Monica, and El Segundo; County of Los Angeles; and LACFCD. • Upper Los Angeles River — The Upper Los Angeles River EWMP area covers the upper reaches of the Los Angeles River Watershed. The Permittees within this EWMP are the Cities of Alhambra, Burbank, Calabasas, Glendale, Hidden Hills, La Canada Flintridge, Los Angeles, Montebello, Monterey Park, Pasadena, Rosemead, San Gabriel, San Marino, South Pasadena, and Temple City; County of Los Angeles; and LACFCD. Upper San Gabriel River — The Upper San Gabriel River EWMP area covers portions of the San Gabriel River Watershed. The Permittees within this EWMP are the Cities of Baldwin Park, Covina, Glendora, Industry, and La Puente; County of Los Angeles; and LACFCD. Upper Santa Clara River — The Upper Santa Clara River EWMP area covers the Upper Santa Clara River Watershed. The Permittees within this EWMP are the City of Santa Clarita; County of Los Angeles; and LACFCD. Enhanced Watershed Management Programs b ESA 1140474 Notice of Preparation August 2014 2. Background 2.1 StormwaterMater Quality MS4 discharges consist of stormwater and non-stormwater generated from municipal land uses that are ultimately discharged into surface waters throughout the region. The MS4 system includes curbs and gutters, man-made channels, catch basins, and storm drains throughout the Los Angeles region. Discharges may adversely affect receiving surface water quality with pollutants such as bacteria, nutrients (nitrogen and phosphorus), aluminum, copper, lead, zinc, diazinon, and cyanide. Aquatic toxicity, particularly during wet weather, is also a concern. Stormwater and non-stormwater discharges of debris and trash are also a pervasive water quality problem in the Los Angeles region. Pollutants in stormwater and non-stormwater may have damaging effects on both human health and aquatic ecosystems. Water quality assessments conducted by the LARWQCB have identified impairment of beneficial uses of water bodies in the Los Angeles region possibly caused or contributed to by pollutant loading from municipal stormwater and non-stormwater discharges. The MS4 Permit described below is designed to reduce pollutant loads into local surface waters. 2.2 Total Maximum Daily Loads The federal Clean Water Act (CWA), Section 303(d), requires states to identify waters that do not meet water quality standards despite the treatment by pollution -control technology. States are required not only to identify these "water quality limited segments" but also to prioritize such waters for the purpose of developing Total Maximum Daily Loads (TMDLs). A TMDL is defined as the "sum of the individual waste load allocations (WLAs) for point sources and load allocations for nonpoint sources and natural background" (40 CFR 130.2), such that the capacity of the water body to assimilate constituent loads (the loading capacity) is not exceeded. A TMDL represents an amount of pollution that can be released into a specific water body without causing a decline in water quality and impairment of beneficial uses. The TMDL also allocates the loads among current and future pollutant sources to the water body and forms the basis for WQBELs and RWLs assigned in NPDES permits. LARWQCB and United States Environmental Protection Agency (USEPA) have established 33 TMDLs that identify Los Angeles County MS4 discharges as one of the pollutant sources causing or contributing to these water quality impairments. 2.3 MS4 Permit On November 8, 2012, the LARWQCB adopted the fourth NPDES MS4 Permit (Order No. R4-2012- 0175) for discharges from the MS4 within the coastal watersheds of Los Angeles County. The MS4 Permit became effective on December 28, 2012. The 2012 MS4 Permit establishes the waste discharge requirement for stormwater and non-stormwater discharges within the watersheds of Los Angeles County. The MS4 Permit identifies conditions, requirements, and programs that municipalities must comply with to protect regional water resources from adverse impacts associated with pollutants in stormwater and urban runoff. The MS4 Permit contains effluent limitations, RWLs, Minimum Control Measures (MCMs), TMDL provisions, and outlines the process for developing watershed management programs, including the EWMP. Enhanced Watershed Management Programs 7 ESA 1140474 Notice of Preparation August 2014 The 2012 MS4 Permit includes provisions that allow Permittees to voluntarily choose to implement an EWMP to achieve permit compliance with RWLs. The intent of the EWMP is to comprehensively evaluate opportunities, within the participating Permittees' collective jurisdictional boundaries, for collaboration among Permittees and other partners on multi -benefit regional projects that, wherever feasible, retain non-stormwater runoff and also address flood control and/or water supply. Twelve EWMP groups have formed to implement a collaborative approach to meeting the requirements of the 2012 MS4 Permit. 3. Enhanced Watershed Management Plans The MS4 Permittees listed in Figure 1 submitted 12 NOIs for the development of 12 EWMPs to the LARWQCB. The 12 NOIs were approved by the LARWQCB. The 12 EWMPs being developed in Los Angeles County for the applicable watersheds have been a collaborative effort by the various EWMP agencies. The EWMPs provide for their respective areas a comprehensive stormwater management plan that optimizes the stormwater and financial resources under the stewardship of the EWMP groups. The EWMPs include multi -benefit stormwater management projects that may also provide environmental, aesthetic, recreational, water supply, and/or other community enhancements in a cost-effective manner. To begin preparing the EWMPs, the Permittees collaborated on, developed, and submitted Draft Work Plans to the LARWQCB, outlining the proposed approach to preparation of each of their respective EWMPs. The EWMP Work Plans establish the basis for the EWMPs. The EWMP Draft Work Plans describe the path that MS4 Permittees propose to complete the Watershed Management Program requirements of the 2012 MS4 Permit. In accordance with the provisions of the MS4 permit, the work plans describe the following steps to EWMP development: 1. Identification of water quality priorities, including evaluation of existing water quality conditions, classification of pollutants, assessment of known and suspected pollutant sources in the watershed, and prioritization of water quality issues in the watershed 2. Characterization of existing and potential control measures within the watershed 3. Addressing the approach to incorporate reasonable assurance analysis (RAA) in the optimization of watershed control measures The LARWQCB is responsible for approval or denial of the EWMPs in compliance with the MS4 Permit. Implementation of the EMWPs would occur following approval by the LARWQCB. 4. EWMP Watershed Control Measures The MS4 Permit requires Permittees to identify strategies, control measures, and BMPs that will be implemented. Improvements to water quality will be achieved through implementation of watershed control measures that consist of both structural and nonstructural BMPs. BMPs vary in function and type, with each BMP providing unique design characteristics and benefits from implementation. Opportunities for BMP implementation are driven by locations where BMPs are feasible/desirable. The overarching goal of BMPs in the EWMPs is to reduce the impact of stormwater and non-stormwater on receiving water quality and to address water conservation and the water quality priorities. The development of the Enhanced Watershed Management Programs $ ESA 1140474 Notice of Preparation August 2014 EWMPs will involve the evaluation and selection of multiple BMP types, as described in the following pages. 4.1 Structural BMPs Structural BMPs involve the construction of a physical control measure to alter the hydrology and/or water quality of incoming stormwater or non-stormwater. The three major functions for structural BMPs are infiltration, water quality treatment, and storage, as follows: • Infiltration – Runoff is directed to percolate into the underlying soils. Infiltration generally reduces the volume of runoff and increases groundwater recharge. • Water quality treatment – Pollutants are removed through various unit processes, including filtration, settling, sedimentation, sorption, straining, and biological or chemical transformations. • Storage – Runoff is captured, stored (detained), and slowly released into downstream waters. Storage can reduce the peak flow rate from a site, but does not directly reduce runoff volume. There are three categories of structural BMPs—regional, centralized, and distributed; they are defined by the runoff area treated by the BMP and the required retention volume in accordance with the Permit. Structural BMPs fall under a variety of subcategories that correspond to their function and water quality benefit. Each of these three categories is described below. 4.1.1 Regional Structural BMPs "Regional EWMP projects" are defined by the MS4 Permit as multi -benefit regional projects that, wherever feasible, retain all non-stormwater runoff and all stormwater runoff from the 85th percentile, 24-hour storm event for the contributing drainage area, while also achieving other benefits such as flood control and/or water supply. Examples of regional structural BMPs include: • Infiltration BMPs o Surface Infiltration BMPs (Infiltration Basins, Infiltration Trenches, Infiltration Galleries, and Bioretention-implemented as single or multiple types) o Multi -Directional Infiltration BMPs (Dry Wells, Hybrid Bioretention, and Dry Wells) • Detention Basins (promote settling out of larger particles) • Capture and Use BMPs (underground cisterns, storage, and use as irrigation) Regional BMPs include infiltration facilities that promote groundwater recharge and detention facilities that encourage settling of larger particles in stormwater flows. Infiltration and detention regional BMPs can be either constructed as open -surface basins or subsurface galleries. Capture and Use BMPs collect and use stormwater where applicable for purposes such as irrigation. All of these BMP types must retain the required design storm volume without release into the MS4 or receiving waters. Opportunities for Regional BMPs will be identified and evaluated within and across subwatersheds, with focus on the multi -benefit potential for capture and reuse of wet -weather flows within variable drainage areas. Availability of public land will be the first criteria for identifying the location and type of BMP. Potential project locations may include areas with open spaces, whether they are within parks, large parking lots, or vacant spaces. Enhanced Watershed Management Programs y ESA 1140474 Notice of Preparation August 2014 Regional BMPs that may be included in the EWMPs will be identified and described further in the PEIR. 4.1.2 Centralized Structural BMPs Centralized structural BMPs are constructed structural practices intended to treat runoff from a contributing area of multiple parcels. Generally, centralized structural BMPs are installed on large public parcels or adjacent to storm drain outfalls and receiving waters. Some examples of centralized structural BMPs include the following: • Bioinfiltration BMPs (Bioretention with underdrain, bioinfiltration, highflow biotreatment, and raised underdrain, vegetated swales, filter strips—implemented as single or multiple types) • Constructed wetlands (aboveground and belowground) • Treatment BMPs/Low-flow diversion • Creek/river/floodplain/estuary restoration 4.1.3 Distributed Structural BMPs Distributed structural BMPs are constructed structural practices intended to treat runoff close to the source and are typically implemented at a single- or few -parcel level. The following list includes common distributed BMPs that can be implemented at the parcel level: • Site scale detention (dry/wet detention ponds, detention chambers) • Green infrastructure/Low Impact Development (LID) o Biofiltration o Bioretention o Porous/permeable pavers o Green streets o Infiltration BMPs o Bioswales/buffer strips o Planter boxes o Rainfall harvesting (green roofs, rain barrels, and cisterns) • Flow -Through Treatment BMPs o Media/cartridge filters o High-flow biotreatment • Source Control Treatment BMPs o Catch basin inserts/screens o Hydrodynamic separators o Gross solids removal devices (GSRDs) o Low flow diversions Enhanced Watershed Management Programs 10 ESA 1140474 Notice of Preparation August 2014 4.2 Institutional BMPs/ Non -Structural Control Measures These are policies, actions, and activities which are intended to prevent pollutants from entering stormwater runoff, thus eliminating the source of the pollutants. Most institutional BMPs are implemented to meet Minimum Control Measure (MCM) requirements in the MS4 permit; MCMs are considered a subset of institutional BMPs. MCMs do not involve construction of facilities that physically remove pollutants, but may involve costs associated with the procurement and installation of items such as signage or spill response kits. The six categories of MCMs outlined in the MS4 permit are as follows: • Development Construction Program • Planning and Land Development Program • Industrial Commercial Facilities Control Program • Illicit Connections and Illicit Discharges Detection and Elimination Program • Public Agency Activities Program • Public Information and Participation Program Nonstructural BMPs or Institutional Controls are often implemented as programs or strategies which seek to prevent and/or reduce runoff and/or pollution close to the source. Nonstructural BMPs include but are not limited to: • hrigation control (runoff reduction) and water -efficient landscaping • Brake pad replacement • Covered trash receptacles • Replacement of lead in wheel weights, or reduction in the copper content of brake pads • Pet waste cleanup stations • Street sweeping • Catch basin cleaning • Downspout disconnect program The MS4 permit allows Permittees to customize MCMs to address high-priority water quality goals within their watersheds. Customization can range from eliminating an MCM (with the exception of the Planning and Land Development Program requirement), proposing actions within an MCM to target specific water quality issues, and increasing or decreasing activities within an MCM (with appropriate justification). Because the LACFCD does not have jurisdictional authority for ordinance and code enactment or enforcement, they are limited in application of MCMs for Public Information and Participation Programs. 5. Potential Environmental Impacts The LACFCD is considering having the PEIR evaluate the following preliminary listing of potential environmental issues. The environmental issues to be addressed will be finalized after the close of the public comment period and comments on the NOP are received. Enhanced Watershed Management Programs t t ESA 1140474 Notice of Preparation August 2014 The PEIR will focus on potential effects that could result from implementation of the projects and management actions identified in each EWMP. The PEIR will assess the physical changes to the environment that would likely result from the construction and operation of EWMP projects, including direct, indirect, and cumulative impacts. Potential impacts are summarized below. The PEIR will identify mitigation measures if necessary to minimize potentially significant impacts of each EWMP. The PEIR is anticipated to evaluate, at a minimum, the following preliminary listing of environmental issues. Aesthetics Potential direct and indirect impacts could occur both during construction and after the proposed EWMP facilities are built and operating. Potential issues associated with aesthetics in relation to the proposed EWMP BMPs could include obstruction of high-quality or important views during either construction or operation of EWMP BMPs, impacts to local character, or construction of facilities incompatible with local recreation facilities or open -space areas. The PEIR will identify the potential visible physical changes to the natural and man-made environment, including the addition of new BMPs into the viewshed (temporary and permanent) and the removal of other components from the view (i.e., blocking of views). The PEIR will also identify the potential effects of the proposed EWMP BMPs on the existing light, glare, shadow, and shade environments. Air Quality Construction and operation of EWMP projects could cause air emissions. Air emissions could result from construction equipment exhaust, ground disturbance during construction, material hauling, construction employee -commute travel, vehicle operational maintenance trips, and vehicle trips associated with any increases in employment. Operation of some of the proposed EWMP facilities may potentially generate emissions associated with energy use. The PEIR will evaluate the effects of construction and operational activities on air quality and also will develop mitigation measures if necessary to reduce potential impacts. Biological Resources Implementation of the EWMP projects could occur within existing sensitive habitats. The projects could result in changes to wildlife habitat, disruption of natural movement corridors, fragmentation or isolation of wildlife habitats, and disturbance of sensitive species during construction or operation. In particular, reduced flows in downstream segments resulting from runoff retention could alter riparian and aquatic habitats. The PEIR will evaluate the potential for such facilities to impact biological resources and will also discuss local ordinances and state and federal regulations governing biological resources. Cultural Resources The proposed EWMP BMPs would require construction of structural BMPs which could be above and/or below ground. Issues regarding cultural resources during construction activities could include disturbance of known or unknown archeological sites, paleontological resources, and/or human remains where groundbreaking activities occur as well as disturbance or alteration of structures with historical importance. The PEIR will assess the potential effects of the proposed EWMP BMPs on cultural resources, including archaeological, paleontological, and Native American resources. Mitigation measures will be identified if necessary to reduce the level of impact where possible. Geology, Soils, and Seismicity Southern Los Angeles County is a seismically active region. The proposed EWMP BMPs would require construction of structural BMPs that could be subject to potential seismic and geologic hazards, including Enhanced Watershed Management Programs 12 ESA 1140474 Notice of Preparation August 2014 ground shaking, liquefaction, soil stability conditions, soil erosion rates, expansive soils, and landslides. Policies provided in the County's General Plan and applicable standard County requirements will be evaluated as to their effect of mitigating or avoiding any potentially significant effects. The PEIR will identify mitigation measures if necessary to reduce potential adverse effects to proposed facilities. Greenhouse Gas Emissions Implementation of proposed EWMP BMPs could result in the generation of greenhouse gas (GHG) emissions associated with construction and operations. The PEIR will estimate construction -related emissions and long-term operational emissions, including total CO2 -equivalent emissions for evaluating the effects of GHGs. The PEIR will examine the project's effects on global climate change and evaluate consistency of the project with the State's GHG emissions reduction goals. Hazards and Hazardous Materials Excavation during construction of proposed EWMP BMPs could uncover contaminated soils or hazardous substances that pose a substantial hazard to human health or the environment. Construction activities could result in the release of hazardous materials. Potential hazards will be evaluated and assessed by reviewing the data collected by the California State Water Resources Control Board (SWRCB) GeoTracker and the California Department of Toxic Substances Control (DTSC) Envirostor databases. The policies provided in the County's General Plan and any standard County requirements will be evaluated as to their effect of mitigating or avoiding any potentially significant effects. The PEIR will evaluate the potential for EWMP projects to result in the release of hazardous materials. Mitigation measures will be proposed if necessary to reduce any significant effects of the project that may involve hazardous material issues to ensure that any hazards encountered during construction would be handled in accordance with applicable regulations. Hydrology and Water Quality Implementation of the proposed EWMP BMPs may change local drainage patterns at construction sites, which could affect the volume, quality, and rates of surface runoff that in turn could affect local surface water resources. Considered cumulatively, the proposed EWMP facilities may also change regional drainage patterns, which could affect the hydrology, hydraulics, and/or water quality of streams, rivers, and other receiving waters. The PEIR will identify relevant federal, state, and local regulations and agencies, including provisions of the federal Clean Water Act, the state Porter -Cologne Water Quality Control Act, and the permitting and regulatory authority of the RWQCB. The PEIR will identify stormwater quality protection measures required during construction and operation of proposed facilities. The PEIR also will evaluate potential impacts to flood control capacity and develop mitigation strategies if necessary to avoid significant impacts. Implementation of the proposed EWMP BMPs would likely result in increased infiltration and recharge in various locations throughout the EWMP watersheds. Such activities could affect local groundwater levels and water quality. The PEIR will evaluate potential effects of increased storm water recharge and will identify mitigation measures if necessary to ensure that potentially necessary significant impacts are reduced or avoided. Land Use and Recreation Implementation of the proposed EWMP BMPs would include implementation of structural BMPs throughout the EWMP watershed areas. Issues associated with land use and planning could result from construction of new BMPs from the proposed EWMP. Issues associated with these components could Enhanced Watershed Management Programs 13 ESA 1140474 Notice of Preparation August 2014 include compatibility with adjacent land uses or zoning designations, consistency with relevant land use policies, and access to adjacent land during new construction or repairs of existing flood control or recharge facilities. The PEIR will evaluate the compatibility of the proposed EWMP BMPs with existing and planned land uses within the EWMP watershed areas. Noise Implementation of the proposed EWMP BMPs would require implementation of structural BMPs that would potentially generate noise and vibration. Construction activities that could be a significant source of noise and vibrations include trucking operations, use of heavy construction equipment (e.g., graders, cranes, and fromend loaders), pile driving activities, and blasting. Fixed sources of noise may include pumps and motors at pump stations. Construction noise and vibration impacts related to the proposed EWMP facilities will be evaluated at a program level. The PEIR will recommend mitigation strategies to ensure that proposed EWMP projects implemented by local agencies comply with local noise policies and ordinances. Population and Housing/Growth Inducement Implementation of the proposed EWMP BMPs will include implementation of structural and nonstructural BMPs that would improve water quality and increase stormwater infiltration. The proposed EWMP BMPs are unlikely to affect population and housing or induce growth. In addition, construction of the proposed EWMP BMPs or alteration of current facilities is not anticipated to lead to displacement or interruption of operation of businesses during construction. The PEIR will, however, identify current population and employment projections and identify local planning jurisdictions with the authority to approve growth and mitigate secondary effects of growth. Public Services Implementation of the proposed EWMP BMPs is unlikely to affect demand for public services, or, by itself, to require new or expanded facilities for public service providers. Potential issues related to the construction and operation of the proposed EWMP facilities include disruption or impediment of fire, police, or other emergency services to areas/facilities where proposed EWMP facilities would be constructed or operated. However, the PEIR will assess the potential for the proposed EWMP BMPs to affect police and fire protection services, schools, parks, and recreational facilities, such that new or expanded buildings or structures may be required that would, in turn, affect the environment. Traffic and Transportation Construction of the proposed EWMP BMPs could affect traffic on local roadways as a result of vehicle trips associated with hauling of material and equipment, road closures and detours, increased demand for parking to serve construction workers, and increase in traffic hazards caused by construction activities. The PEIR will evaluate the potential for additional construction vehicles, lane closures, or road closures to impact traffic and circulation. The PEIR will identify mitigation strategies to reduce any potential effects. Utilities and Energy Potential issues related to the construction and operation of the proposed BMPs include the disruption or impediment of service to areas where the proposed BMPs would be constructed or operated. Existing and projected regional supplies, demands, and facilities will be described along with any existing constraints, deficiencies, or service issues for the proposed EWMP BMPs. The PEIR will evaluate the project's potential to affect utilities and will identify mitigation measures to minimize the effects. Enhanced Watershed Management Programs 14 ESA 1140474 Notice of Preparation August 2014 Implementation of the proposed EWMP BMPs would also result in implementation of watershed control measures that may potentially increase the amount of energy required locally to operate some of these BMPs. The PEIR will evaluate potential energy consumption associated with implementation of structural and nonstructural BMPs. Enhanced Watershed Management Programs 15 ESA 1140474 Notice of Preparation August 2014 State Clearinghouse Attn: CEQA Review County of Los Angeles, Board ofSupervisors, 1s` District Office of Planning and Research County of Los Angeles, Department of Attn: Gloria Molina 1400 10th Street, Room 222 Regional Planning Administration Sacramento, CA 95814 320 W. Temple St., 13th Floor Hall 500 of of Temple St, n 856 Los Angeles, CA 90012 Los Angeles, CA 90012 Los Angeles Regional Water Quality Control Board Attention: Mr. Samuel Unger, P.E. 320 West 4th Street, Suite 200 Los Angeles, CA 90013 State Water Resources Control Board ATTN: CEQA Review 1001 1 Street Sacramento, CA 95814 US Environmental Protection Agency Office of Water (4100T) ATTN: CEQA Review 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460 ATTN: CEQA Review County of Los tlngeles, Board of Environmental Planning Team Supervisors, 2 District Metropolitan Water District of So. California Attn: Mark Ridley-Thomas 700 North Alameda Street Hall of Administration Los Angeles, CA 90012-2944 500 W. Temple St, RM 866 Los Angeles, CA 90012 ATTN: General Manager Central Basin Municipal Water District 6252 Telegraph Road Commerce, CA 90040-2512 ATTN: General Manager West Basin Municipal Water District 17140 South Avalon Boulevard, Suite 210 Carson, CA 90746-1296 California Environmental Protection Agency ATTN: General Manager (Ca1EPA) Water Replenishment District ATTN: CEQA Review 4040 Paramount Boulevard 1001 1 Street Lakewood, CA, 90712 Sacramento, CA 95812-2815 U.S. Army Corp of Engineers ATTN: CEQA Review 915 Wilshire Blvd., Suite 1101 Los Angeles, CA 90017 California Department of Fish and Wildlife — CEQA Review South Coast Region 3883 Ruffin Road San Diego, CA 92123 California Department of Fish and Wildlife CEQA Program 1416 Ninth Street, Suite 1260 Sacramento, CA 95814 ATTN: CEQA Review US Fish and Wildlife Service Pacific Southwest (Region 8) 2800 Cottage Way, Room W-2606 Sacramento, California 95825-1846 South Coast Air Quality District ATTN: CEQA Review 21865 Copley Drive Diamond Bar. CA 91765 Department of Toxic Substances ATTN: CEQA Review 9211 Oakdale Avenue Chatsworth, CA 91311-6505 Caltrans District 7 ATTN: CEQA Review 100 S. Main Street Los Angeles, CA 90012 Southern California Association of Governments CEQA Intergovernmental Review 818 West 7th St, 12th floor Los Angeles, CA 90017 County of Los Angeles, Board of Supervisors, 3rd District Attn: Zev Yaroslaysky Hall of Administration 500 W. Temple St, RM 821 Los Angeles, CA 90012 County of Los Angeles, Board of Supervisors, 4'" District Attn: Don Knabe Hall of Administration 500 W. Temple St, RM 822 Los Angeles, CA 90012 County of Los Angeles, Board of Supervisors, 5'" District Attn: Michael D. Antonovich Hall of Administration 500 W. Temple St, RM 869 Los Angeles, CA 90012 Attn: CEQA Review Los Angeles County Public Health 5050 Commerce Dr. Baldwin Park, CA 91706 Attn: CEQA Review Planning Department Sanitation Districts of Los Angeles County 1955 Workman Mill Road Whittier, CA 90607-2301 Charles C. Holloway Manager, Environmental Affairs Los Angeles Dept of Water and Power 111 N. Hope Street Los Angeles,CA 90051-0100 ATTN: General Manager Las Virgenes Municipal Water District 4232 Las Virgenes Road Calabasas, CA 91302-1994 ATTN: General Manager ATTN: General Manager ATTN: General Manager Foothill Municipal Water District Three Valleys Municipal Water District Upper San Gabriel Valley Municipal 4536 Hampton Road 1021 E Miramar Ave. Water District La Canada, CA 91011 Claremont, CA 91711-2052 602 E. Huntington Drive, Suite B Monrovia, CA, 91016 Attention: Shahram Kharaghani City of Los Angeles Department of Public Attention: Daniel Cartagena BALLONA CREEK Works/Bureau of Sanitation, Watershed City of Beverly Hills Protection Division 455 North Rexford Drive 1149 S. Broadway Beverly Hills, CA 90210 Los Angeles, CA 90015 Attention: Sharon Perlstein Attention: Lauren Amimoto Attention: Charles D. Herbertson City of West Hollywood City of Inglewood City of Culver City e Department of Transportation and Public Public Works Department 9770 Culver Blvd., 2 Floor Works 1 Manchester Blvd Culver City, CA 90232-0507 8300 Santa Monica Boulevard Inglewood, CA 90301 West Hollywood, CA 90069-6216 Attention: Rick Valte Attention: Gary Hildebrand City of Santa Monica Los Angeles County Flood Control Attn: CEQA Review Public Works Department District/Department of Public Works Mar Vista Recreation Center Civil Engineering Division Watershed Management Division, 11`" 11430 Woodbine St 14373 4'%i Street, Suite 300 Floor/900 South Fremont Avenue Los Angeles, CA 90066 Santa Monica, CA 90401 Alhambra, CA 91803-1331 Attn: Raul Saenz City of Manhattan Beach Attn: Elaine Jeng BEACH CITIES City Hall City of Redondo Beach 1400 Highland Avenue 415 Diamond Street, PO Box 270 Manhattan Beach, CA 90266-4795 Redondo Beach, CA 90277-0270 Attn: John C. Dettle Attn: CEQA Review Attn: Frank Senteno City of Torrance City of Los Angeles City of Hermosa Beach 20500 Madrona Avenue Department of Parks and Recreation Civic Center Torrance, CA 90503 211 N. Figueroa St. Suite 1550 1315 Valley Drive Los Angeles, CA 90012 Hermosa Beach, CA 90254-3885 Attn: Doug Krauss City of Hawthorne Attn: LiFan Xu DOMINGUEZ CHANNEL Hawthorne City Hall City of EI Segundo 4455 W. 126th Street 350 Main Street Hawthorne, CA 90250 EI Segundo, CA 90245 Attn: CEQA Review Attention: Angela George City of Lomita County of Los Angeles Lomita City Hall Department of Public Works/Watershed 24300 Narbonne Avenue Management Division, 11 Floor Lomita, CA USA 90717 900 South Fremont Avenue Alhambra, CA 91803-1331 Attn: CEQA Review MALIBU CREEK Las Virgenes Municipal Water District 4232 Las Virgenes Rd Calabasas, CA 91302 Attn: Alex Farassati City of Calabasas 100 Civic Center Way Calabasas, CA 91302 Attn: Kelly Fisher City of Agoura Hills 30001 Ladyface Court Agoura Hills, CA 91301 Attn: Rob DuBoux City of Malibu 23825 Stuart Ranch Road Malibu, California 90265-4861 Attn: CEQA Review California Department of Parks and Rec. 1416 9th St Sacramento, CA 95814 Joe Bellomo Attn: Joe Bellomo Attn: CEQA Review City of Westlake Village City of Hidden Hills Ventura County Watershed Protection 31200 Oak Crest Or 6165 Spring Valley Road District Westlake Village, CA 91361 Hidden Hills, CA 91302 800 South Victoria Avenue Ventura, California 93009-1610 u _f'I1-il.►_r17qW3:7 PALOS VERDES Attn: CEQA Review Palos Verdes Land Conservancy 916 Silver Spur Rd Ste 207 Rolling Hills, CA 90274 Attn: CEQA Review LA County Parks 433 S Vermont Ave FI 4 Los Angeles, CA 90020 RIO HONDO / SAN GABRIEL Attn: Carl E. Hassel City of Azusa 213 E. Foothill Blvd. Azusa, CA 91702 Attn: CEQA Review Metro Gold Line Foothill Extension Construction Authority 406 East Huntington Drive, Suite 202 Monrovia, California 91016 Attention: Gail Farber County of Los Angeles Department of Public Works 900 South Fremont Avenue, 12'" Floor Alhambra, CA 91803-1331 Attn: CEQA Review Malibu Creek Watershed Council 30000 Mulholland Hwy, Agoura Hills CA 91301 Attn: CEQA Review Planning Department Sanitation Districts of LA County 1955 Workman Mill Road Whittier, CA 90607-4998 Attn: Allan Rigg City of Palos Verdes Estates 340 Palos Verdes Dr West, Palos Verdes Estates, CA 90274 Attn: CEQA Review Heal the Bay 1444 9th Street Santa Monica, CA 90401 Attn: CEQA Review San Gabriel Valley Council of Governments 1000 S. Fremont Avenue Unit 42 Alhambra, CA 91803 Attn: Michelle Keith City of Bradbury 600 Winston Avenue Bradbury, CA 91008 Attn: Bruce Iman City of Sierra Madre Public Works Department 232 West Sierra Madre Boulevard Sierra Madre, CA 91024 Attn: Stephanie Katsouleas SANTA MONICA BAY City of EI Segundo 350 Main Street EI Segundo, CA 90245 Attn: Jennifer Brown City of Malibu 23825 Stuart Ranch Road Malibu, California 90265-4861 Attn: Gregg Grammer City of Rolling Hills Estates 4045 Palos Verdes Drive North Rolling Hills Estates , California 90274 Attn: Andy Winje City of Rancho Palos Verdes 30940 Hawthorne Blvd, Rancho Palos Verdes, CA 90275 Attn: Heather Maloney City of Monrovia 600 South Mountain Avenue Monrovia, CA 91016-3611 Attn: Vanessa Hevener City of Arcadia 11800 Goldring Road Post Office Box 60021 Arcadia, CA 91066- Attn: Rafael Casillas City of Duarte 1600 Huntington Drive Duarte, CA 91010-2592 Attn: Elroy Kiepke Attn: John Hunter UPPER LOS ANGELES RIVER Willdan Engineering John L Hunter and Associates 13187 Crossroads Pkwy N, La Puente, CA 6131 Orangethorpe Ave Ste 350 91746 Buena Park, CA Attn: David Dolphin City of Alhambra 111 South First Street Alhambra, CA 91801 Attn: Steve Freeland City of Hidden Hills 6165 Spring Valley Road Hidden Hills, CA 91302 Attn: Amy Ho City of Monterey Park 320 West Newmark Avenue Monterey Park, CA 91754-2896 Attn: Elroy Kiepke City of Rosemead 8838 E. Valley Boulevard PO Box 399 Rosemead, CA 91770 Attn: Kevin Sales City of San Marino 2200 Huntington Drive San Marino, CA 91108 UPPER SAN GABRIEL RIVER Attn: John D. Ballas City of Industry 15625 Stafford St City of Industry, CA 91744 Attn: Alvin Cruz City of Burbank Public Works Department 150 N. Third St Burbank, CA 91502 Attn: Edward Hitti City of La Canada Flintridge 1327 Foothill Blvd La Canada Flintridge, CA 91011 Attn: Shin Furukawa City of South Pasadena Office of the City Manager 1414 Mission Street South Pasadena, CA 91030 Attn: CEQA Review City of San Fernando San Fernando City Hall, 117 Macneil Street, San Fernando, CA 91340 Attn: Mark Persico City of Temple City 9701 Las Tunas Drive Temple City, CA 91780-2249 Attn: Daniel Wall City of Baldwin Park 14403 East Pacific Avenue Baldwin Park, California 91706 Attn: Vivian Castro City of Covina Covina City Hall 125 E. College Street Covina, CA 91723-2199 Attn: CEQA Review UPPER SANTA CLARITA RIVER City of Santa Clarita 23920 Valencia Boulevard Santa Clarita CA 91355 Attn: Maurice Oillataguerre City of Gendale 633 East Broadway, Room 209 Glendale, CA 91206-4385 Attn: Norma Salinas City of Montebello 1600 West Beverly Boulevard Montebello, CA 90640-3932 Attn: Stephen Walker City of Pasadena 100 North Garfield Avenue N. 306 PO Box 7115 Pasadena, CA 91109-7215 Attn: Daren Grilley City of San Gabriel PO Box 130 San Gabriel, CA 91778-0130 Attn: David A. Davies City of Glendora 116 E. Foothill Blvd Glendora, CA 91741-3380 Attn: John Di Mario La Puente City Hall City of La Puente 15900 Main Street La Puente CA 91744 Appendix B Scoping Report and Comment Letters r ESA J LOS ANGELES COUNTY FLOOD CONTROL DISTRICT ENHANCED WATERSHED MANAGEMENT PROGRAMS PROGRAM EIR Scoping Report Introduction and EWMP Overview The Los Angeles County Flood Control District (LACFCD) is the Lead Agency for the proposed Enhanced Watershed Management Programs (EWMPs) Environmental Impact Report. The Los Angeles County Flood Control Act was adopted by the State Legislature in 1915 and established the LACFCD and empowered it to provide flood risk management, water conservation, and recreation and aesthetic enhancement within its boundaries. The LACFCD, the County of Los Angeles, and 84 incorporated cities within Los Angeles County (collectively referred to as Permittees) are covered under a Municipal Separate Storm Sewer System (MS4) Permit (Order No. R4-2012-0175; National Pollutant Discharge Elimination System [NPDES] Permit No. CAS004001) for the discharge of urban runoff to waters of the United States. The purpose of the MS4 Permit is to ensure Permittees are not causing or contributing to exceedances of water quality objectives or impairments of beneficial uses in the receiving waters of the Los Angeles region. The 2012 MS4 Permit for Los Angeles County gives Permittees the option of implementing an innovative approach to MS4 Permit compliance through development of EWMPs. The LACFCD, along with participating Permittees, has opted to exercise this option and has submitted 12 separate Notices of Intent (NOIs) for the development of 12 EWMPs in their respective watershed groups to the Los Angeles Regional Water Quality Control Board (LARWQCB). The intent of the EWMP is to comprehensively evaluate opportunities for collaboration on multi -benefit regional projects that retain non-stormwater runoff and also address flood control and/or water supply within the participating Permittees' collective jurisdictional boundaries. The LARWQCB is responsible for approval of the EWMPs in compliance with the MS4 Permit. Implementation of the EMWPs would occur following approval by the LARWQCB. The primary goals and objectives of the EWMPs are: • To collaborate among agencies (Permittee jurisdictions) across the watershed to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the MS4 Permit; • To develop watershed -wide EWMPs that will, once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff in a cost-effective manner; and • To reduce the impact of stormwater and non-stormwater on receiving water quality. Following the adoption of the MS4 permit by the RWQCB, Permittees in each EWMP area formed Watershed Management Groups (WMGs) to collaborate on the development of EWMPs. The proposed program includes several watershed management groups of Los Angeles County, covering the following EWMP areas: Ballona Creek, Beach Cities, Dominguez Channel, Malibu Creek, Marina del Rey, North Santa Monica Bay, Palos Verdes Peninsula, Rio Honda/San Gabriel River, Santa Monica Bay, Upper Los Angeles River, Upper San Gabriel River, and Upper Santa Clara River. Notice of Preparation Pursuant to Section 15082 of CEQA Guidelines, the lead agency is required to send a Notice of Preparation (NOP) stating that an EIR will be prepared to the State Office of Planning and Research (OPR), responsible and trustee agencies, and federal agencies involved in funding or approving the project. The NOP must provide sufficient information in order for responsible agencies to make a meaningful response. At a minimum, the NOP must include a description of the project, location of the project, and probable environmental effects of the project (CEQA Guidelines, Section 15082(a)(1)). Within 30 days after receiving the NOP, responsible and trustee agencies and OPR shall provide the lead agency with specific detail about the scope and content of the environmental information related to that agency's area of statutory responsibility that must be included in the draft EIR (CEQA Guidelines, Section 15082(b)). A Notice of Preparation (NOP) was published by the LACFCD on August 29, 2014. The NOP was circulated to federal, state, and local agencies, as well as other interested parties, for a period of 30 days. The NOP was made available in print and electronic form, and the LACFCD accepted comments on the NOP for a 30 -day period, closing on September 29, 2014. In addition, an email notification regarding the availability of the NOP was sent to over 700 interested EWMP stakeholders. Reports of email notification deliveries and bounce -backs are located in Attachment 3. A lack of comments from interested parties prompted LACFCD to extend the public comment period an additional 30 days; it ultimately closed on October 29, 2014. Additionally, the LACFCD posted a Twitter message regarding the comment period extension, and uploaded a recording of the Scoping Meeting Presentation to the project website, to augment the public outreach activities. The NOP was also made available on the project website: www.LACoH2Osheds.com. The NOP discussed the purpose of the EWMPs and their management strategies, identified the EWMP Study Areas, and provided a brief and preliminary list of environmental issue areas that could be impacted. Table 1-1 provides a list of the commenters that sent comments on the NOP. The comment letters are located in Attachment 9. TABLE 1-1 NOP COMMENTERS Date Name Organization 1 10/16/2014 2 10/23/2014 3 10/28/2014 4 10/29/2014 5 10/27/2014 6 10/23/2014 7 09/29/2014 8 10/29/2014 9 10/29/2014 10 10/08/2014 11 09/29/2014 12 09/24/2014 Enrique Huerta At -Large Stakeholder (Downey, CA) Enrique Huerta At -Large Stakeholder (Downey, CA) George Ball Citizen Jane Williams Los Angeles County Arboretum Kenneth Hill Los Angeles County Arboretum Foundation, President Marsha Perez Citizen, Los Angeles County Arboretum Rex Frankel Ballona Ecosystem Education Project, Director Rex Frankel Ballona Ecosystem Education Project, Director Tom Williams Sierra Club, Water Committee Elizabeth Byrne Debreu Los Angeles Arboretum Foundation Dianna Watson Department of Transportation Deirdre West Metropolitan Water District Date Name Organization 13 09/25/2014 Katy Sanchez NAHC 14 09/29/2014 Douglas Fay Citizen 15 09/29/2014 Donna Murray Citizen 16 09/29/2014 Joyce Dillard Citizen 17 10/03/2014 Patricia McPherson Grassroots Coalition 18 10/14/2014 Jane Forentinus Citizen 19 10/29/2014 Dale Carter Arboretum volunteer and docent 20 08/29/2014 Scott Morgan State Clearinghouse Scoping Meetings Pursuant to CEQA Guidelines Section 15083, the LACFCD held three public scoping meetings on September 9, 10, and 15 of 2014 to receive comments on the NOP. The purpose of the meetings was to present the proposed EWMPs to the interested stakeholders and receive public input regarding the proposed scope of the PEIR analysis. Attendees were provided an opportunity to voice comments or concerns regarding potential effects of the program. The Scoping Meeting Presentation (Attachment 4), Sign -In Sheets (Attachment 5), and summary of verbal comments made at the meetings (Attachment 6) are found in this report. The next formal opportunity for the public to comment on the proposed project will occur when the Draft PEIR is distributed for a 45 -day review period, anticipated to occur between January and March of 2015. Attachments to this Report This Scoping Report contains documents pertinent to the scoping process. The following items are included: Attachment 1: Notice of Preparation Attachment 2: Notice of Completion Attachment 3: Summary of NOP Availability Emails Attachment 4: Scoping Meeting Presentation Attachment 5: Scoping Meeting Sign -In Sheets Attachment 6: Scoping Meeting Public Comments Attachment 7: State Clearinghouse Distribution of NOP Attachment 8: Comment Period Extension Letter Attachment 9: Public Comment Letters Received Attachment 1 Notice of Preparation r ESA J Notice of Preparation Date August 29, 2014 ORIGINAL FILED AUG 2 9 2014 LOS ANGELES, COUNTY CLERK To: California Office of Planning and Research, Responsible and Trustee Agencies and Interested Parties Subject: Notice of Preparation of a Draft Program Environmental Impact Report Project: Enhanced Watershed Management Programs Lead Agency: Los Angeles County Flood Control District Review Period: August 29, 2014 through September 29, 2014 The Los Angeles County Flood Control District (LACFCD) will be the Lead Agency and will prepare a Program Environmental Impact Report (PEIR) for the project identified in this notice. We need to know the views of you or your agency as to the scope and content. of the environmental information which is germane to youragency's statutory responsibilities in connection with the proposed project. This Notice of Preparation (NOP) has been prepared to notify agencies and interested parties that the LACFCD is beginning preparation of a PEIR pursuant to the California Environmental Quality Act (CEQA) for its proposed Enhanced Watershed Management Programs (EWMPs, or "program"). The Los Angeles County Flood Control Act was adopted by the State Legislature in 1915 and established the LACFCD and empowered it to provide flood risk management, water conservation, and recreation and aesthetic enhancement within.its boundaries. The LACFCD is governed as a separate entity by the Board of Supervisors of the County of Los Angeles and is operated by the County's Department of Public Works. The LACFCD encompasses more than 3,000 square miles, 85 cities, and approximately 2.1 million land parcels. The LACFCD, the County of Los Angeles, and 84 incorporated cities within Los Angeles County (collectively referred to as Permittees) are covered under a Municipal Separate Storm Sewer System (MS4) Permit (Order No. R4-2012-0175; National Pollutant Discharge Elimination System (NPDESj Permit No. CAS004001) for the discharge of urban runoff to waters of the United States. The purpose of the MS4 Permit is to ensure Permittees are not causing or contributing to exceedances of water quality objectives or impairments of beneficial uses in the receiving waters of the Los Angeles region. The 2012 MS4 Permit for Los Angeles County gives Permittees the option of implementing an innovative approach to Permit compliance through development of EWMPs. The LACFCD and participating Permittees have opted to exercise this option and have submitted 12 separate Notices of Intent (NOls) for the development of 12 EWMPs in their respective watershed groups to the Los Angeles Regional Water Quality Control Board (LARWQCB). The LARWQCB is responsible for approval of the EWMPs in compliance with the MS4 Permit. Implementation of the EMWPs would occur following approval by the LARWQCB. The preparation of the 12 separate EWMPs will be a collective effort among the LACFCD ?#d the applicable agencies in each respective EWMP. The 12 EWMPs will vary for each watershed group, but will generally provide the opportunity for Permittees to customize their stormwater programs to achieve compliance with applicable receiving water limitations (RWLs) and water -quality -based effluent limits (WQBELs) in accordance with the MS4 Permit through implementation of stormwater best management practices (BMPs) or watershed control measures. BMPs vary in function and type, with each BMP providing unique design characteristics and benefits from implementation. The. overarching goal of BMPs in the EWMP is to reduce the impact of stormwater and non-stormwater on receiving water Enhanced Watershed Management Programs 1 ESA 1140474 Notice of Preparabon Au" 2014 Notice of Preparation Date August 29, 2014 To: California Office of Planning and Research, Responsible and Trustee Agencies and Interested Parties Subject: Notice of Preparation of a Draft Program Environmental Impact Report Project: Enhanced Watershed Management Programs Lead Agency: Los Angeles County Flood Control District Review Period: August 29, 2014 through September 29, 2014 The Los Angeles County Flood Control District (LACFCD) will be the Lead Agency and will prepare a Program Environmental Impact Report (PEIR) for the project identified in this notice. We need to know the views of you or your agency as to the scope and content of the environmental information which is germane to your agency's statutory responsibilities in connection with the proposed project. This Notice of Preparation (NOP) has been prepared to notify agencies and interested parties that the LACFCD is beginning preparation of a PEIR pursuant to the California Environmental Quality Act (CEQA) for its proposed Enhanced Watershed Management Programs (EWMPs, or "program"). The Los Angeles County Flood Control Act was adopted by the State Legislature in 1915 and established the LACFCD and empowered it to provide flood risk management, water conservation, and recreation and aesthetic enhancement within its boundaries. The LACFCD is governed as a separate entity by the Board of Supervisors of the County of Los Angeles and is operated by the County's Department of Public Works. The LACFCD encompasses more than 3,000 square miles, 85 cities, and approximately 2.1 million land parcels. The LACFCD, the County of Los Angeles, and 84 incorporated cities within Los Angeles County (collectively referred to as Permittees) are covered under a Municipal Separate Storm Sewer System (MS4) Permit (Order No. R4-2012-0175; National Pollutant Discharge Elimination System (NPDES] Permit No. CAS004001) for the discharge of urban runoff to waters of the United States. The purpose of the MS4 Permit is to ensure Permittees are not causing or contributing to exceedances of water quality objectives or impairments of beneficial uses in the receiving waters of the Los Angeles region. The 2012 MS4 Permit for Los Angeles County gives Permittees the option of implementing an innovative approach to Permit compliance through development of EWMPs. The LACFCD and participating Permittees have opted to exercise this option and have submitted 12 separate Notices of Intent (NOls) for the development of 12 EWMPs in their respective watershed groups to the Los Angeles Regional Water Quality Control Board (LARWQCB). The LARWQCB is responsible for approval of the EWMPs in compliance with the MS4 Permit. Implementation of the EMWPs would occur following approval by the LARWQCB. The preparation of the 12 separate EWMPs will be a collective effort among the LACFCD and the applicable agencies in each respective EWMP. The 12 EWMPs will vary for each watershed group, but will generally provide the opportunity for Permittees to customize their stormwater programs to achieve compliance with applicable receiving water limitations (RWLs) and water -quality -based effluent limits (WQBELs) in accordance with the MS4 Permit through implementation of stormwater best management practices (BMPs) or watershed control measures. BMPs vary in function and type, with each BMP providing unique design characteristics and benefits from implementation. The overarching goal of BMPs in the EWMP is to reduce the impact of stormwater and non-stormwater on receiving water Enhanced Watershed Management Programs ESA 1140474 Notice of Preparation August 2014 quality and address the water quality priorities as defined by the MS4 Permit. The development of each EWMP will involve the evaluation and selection of multiple BMP types, including nonstructural (institutional) and distributed, centralized, and regional structural watershed control measures, that will be implemented to meet compliance goals and strategies under the 2012 MS4 Permit. The LACFCD, as a regional agency charged with conserving stormwater for use in our local water supply, has a vested interest in increasing opportunities for stormwater capture and groundwater recharge. The LACFCD has flood control infrastructure in each of the EWMP areas and is participating in all 12 EWMPs. The LACFCD will be working with the applicable Permittees and other stakeholders in all 12 EWMP watersheds to develop the EWMPs, which will be implemented by the Permittees that have jurisdiction within each EWMP area. The Permittees implementing the projects defined in the EWMPs, or "implementing agencies," will vary between EWMPs and individual projects. The LACFCD will be an implementing agency only on those projects for which it has been identified in an EWMP as a responsible implementing party. Project Location: The proposed program would be located in several watersheds of Los Angeles County and would include the following enhanced watershed management groups: Ballona Creek, Beach Cities, Dominguez Channel, Malibu Creek, Marina del Rey, North Santa Monica Bay Coastal Watersheds (NSMBCW), Palos Verdes Peninsula, Rio Hondo/San Gabriel River Water Quality Group (RH/SGRWQG), Santa Monica Bay, Upper Los Angeles River, Upper San Gabriel River, and Upper Santa Clara River. The project area is indicated in Figure 1. Broad Range of Potential Benefits from EWMPs: If implemented, the proposed EWMP-generated benefits would include: • Improved Water Quality • Reduction in Impairment of Water Bodies for Designated Beneficial Uses Promotion of Water Conservation and Supply Enhanced Recreation Opportunities • Support for Public Education Opportunities Improved Local Aesthetics • Management of Flood Risks Public Comments: The LACFCD is soliciting the views of interested persons and agencies as to the scope and content of the environmental information to be evaluated in the PEIR. In accordance with CEQA, agencies are requested to review the project description in this NOP and provide their comments on environmental issues related to the statutory responsibilities of the agency. The PEIR will be used by LACFCD's governing Board, the Los Angeles County Board of Supervisors, when considering approval of the proposed EWMPs as well as for any related discretionary approvals. Due to the time limits mandated by state law, all comments to the NOP are due no later than September 292 2014. Please send your comments to the address shown below. Include a return address or email address and a contact name in your agency with your comments. Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 (626)300-3298 gbegell@dpw.lacounty.gov This NOP and other PEIR information, as it becomes available, can be accessed at: www.LACoH20sheds.com Enhanced Watershed Management Programs 1 ESA 1140474 Notice of Preparation August 2014 Scoping Meetings: Three scoping meetings will be held to receive public comments regarding the scope and content of the PEIR. The scoping meetings will include a brief presentation providing an overview of the proposed program and the CEQA process. After the presentation, oral comments will be accepted. Written comment forms will be supplied for those who wish to submit comments in writing at the scoping meeting. Written comments also may be submitted anytime during the NOP review period. The scoping meetings will be held as follows: DATE: Tuesday, September 9, 2014 TIME: 6:00 P.M. LOCATION: Chace Park Community Room TBD 13650 Mindanao Way Marina del Rey, CA 90292 DATE: Wednesday, September 10, 2014 TIME: 6:00 P.M. LOCATION: County of Los Angeles Department of Public Works 900 South Fremont Avenue First Floor Conference Room C Alhambra, CA 91803 DATE: Monday, September 15, 2014 TIME: 6:30 P.M. LOCATION: K Dalton Room Community Center 119 W Palm Ave Monrovia, CA 91016 Enhanced Watershed Management Programs ESA 1140474 Notice of Preparation August 2014 Figure 1: Overview EWMP Groups Enhanced Watershed Management Programs 4 ESA 1140474 Notice of Preparation August 2014 Beverly Hills, Culver City, Inglewood, Los Angeles, Santa Monica, West Hollywood, Ballona Creek IA County, LACFCD Beach Cities Watershed - Hermosa Beach, Manhattan Beach, Redondo Beach, Torrance, LACFCD Mana ement Grou Dominguez Channel Watershed - EI Segundo, Hawthorne, Inglewood, Los Angeles, Lomita, IA County, LACFCD Management Group - Malibu Creek Watershed Agoura Hi Its, Calabasas, Hidden Hills, Westlake Village, LA County, LACFCD _ Marina del Rey Culver City, Los Angeles, LACounty, LACFCD North Santa Monica Bay Coastal - LACounty, Malibu, LACFCD Watersheds Palos Verdes Peninsula EWMP - Palos Verdes Estates, Rancho Palos Verdes, Rolling Hills Estates, LACounty, LACFCD Agencies Rio Hondo/San Gabriel River Water Arcadia, Azusa, Bradbury, Duarte, Monrovia, LA County, Sierra Madre, LACFCD Quality Group - Santa Monica Bay Watershed Los Angeles, EI Segundo, Santa Monica, LACounty, LACFCD Jurisdictions 2 &3 Alhambra, Burbank, Calabasas, Glendale, Hidden Hills, La Canada Flintridge, Los Upper Los Angeles River Watershed Angeles, Montebello, Monterey Park,Pasadena, Rosemead,San Gabriel,San Marina South Pasadena Temple City, LACounty,LACFCD - Upper San Gabriel River Baldwin Park,Covina,Glendora,Industry, La Puente, LACounty, LACFCD - Upper Santa Clara River Watershed LACounty,Santa Clarice, LACFCD t i I i \t SA,NTACLAR4 RIVER WATERSHED I \ \ I 1 ( 1.0SAWIE1.1 s H11 I If It 117'HS111'0 1 S LA'T 110 1('.I r IJI) HATI RS'11tiD 3AN GABRIEL RIVER WATERS111I> f r Pacific Ocean --_-- Northern Boundary LACFCD i J DO iN(,v -rz QWatershed Boundary r,�J EFIA:\W L r' WATERSIIL]) Los Angeles County Boundary _ � N Area Outside Los Angeles County _;,-\ 0 6 12 Miles Jurisdictional Boundaries m in _. r' ESRITenain Imagery Sources: Esn, USGS, NOAA Enhanced Watershed Management Programs 4 ESA 1140474 Notice of Preparation August 2014 I . Introduction The LACFCD along with other applicable Permittees have submitted NOIs to the LARWQCB to develop EWMPs for 12 watershed groups, in accordance with the 2012 MS4 Permit, Order No. R4-2012-0175. The LARWQCB is responsible for approval of the final EWMPs in compliance with the MS4 Permit. Implementation of the EMWPs would occur following approval of the final plan. To begin preparing the EWMPs, the Permittees collaborated on, developed, and submitted Draft Work Plans to the LARWQCB, outlining the proposed approach to preparation of each of their respective EWMPs. The primary approach to each of the EWMPs, as identified in the Draft Work Plans, includes identifying community -friendly, cost-effective methods of reducing urban runoff pollution and incorporating distributed and centralized structural and nonstructural watershed control measures for a multi -pollutant, multi -benefit approach. The EWMPs will also evaluate multi -benefit regional projects that will retain (through infiltration or capture and reuse) the stormwater quality design volume (85" percentile storm for 24 hours) for the runoff from the contributing drainage area. The proposed project includes the potential nonstructural (institutional) and distributed, centralized, and regional structural watershed control measures described in the Draft Work Plans and detailed in the EWMPs currently under preparation. These measures will be evaluated in the PEIR. The PEIR will provide a program -level assessment of the overall permit compliance effort, focusing particularly on the structural watershed control measures proposed in each of the 12 EWMP areas. 1.1 Project Location The proposed program includes several watershed management groups of Los Angeles County, which include the following EWMP groups: Ballona Creek, Beach Cities, Dominguez Channel, Malibu Creek, Marina del Rey, North Santa Monica Bay Coastal Watersheds (NSMBCW), Palos Verdes Peninsula, Rio Hondo/San Gabriel River Water Quality Group (RH/SGRWQG), Santa Monica Bay, Upper Los Angeles River, Upper San Gabriel River, and Upper Santa Clara River. The geographic scope covered by each of these 12 EWMPs is described in further detail below and shown in Figure 1. • Ballona Creek —The Ballona Creek EWMP area covers the Ballona Creek watershed. The Permittees within this EWMP are the Cities of Beverly Hills, West Hollywood, Los Angeles, Inglewood, Culver City, Santa Monica, and West Hollywood; County of Los Angeles; and LACFCD. • Beach Cities —The Beach Cities EWMP area covers portions of three watersheds: Santa Monica Bay Watershed Jurisdictional Group (SMB JG) 5 & 6, Dominguez Channel Watershed, and Machado Lake Watershed. The Permittees within this EWMP are the Cities of Redondo Beach, Manhattan Beach, Hermosa Beach, and Torrance; and the LACFCD. • Dominguez Channel — The Dominguez Channel EWMP area covers portions of three watersheds: Dominguez Channel Watershed, the Machado Lake Watershed, and the Los Angeles/Long Beach Harbors Watershed. The Permittees within this EWMP are the Cities of El Segundo, Hawthorne, Inglewood, Lomita, and Los Angeles; County of Los Angeles; and the LACFCD. • Malibu Creek —The Malibu Creek Watershed (MCW) EWMP area covers the majority of the MCW. The Permittees within this EWMP are the Cities of Agoura Hills, Calabasas, Hidden Hills, , and Westlake Village; County of Los Angeles; and the LACFCD. Enhanced Watershed Management Programs `J ESA 1140474 Notice of Preparation August 2014 • Marina del Rey — The Marina del Rey EWMP area covers the Marina del Rey Watershed. The Permittees within this EWMP are the Cities of Los Angeles and Culver City; County of Los Angeles; and LACFCD. • North Santa Monica Bay — The NSMBCW EWMP area covers the SMB JG 1, SMB JG 4, and a portion of Malibu Creek within the City of Malibu's borders. The Permittees within this EWMP are the City of Malibu; County of Los Angeles; and LACFCD. • Palos Verdes Peninsula — The Palos Verdes Peninsula watershed management area covers most of the SMB JG7, the Los Angeles Harbor subwatershed, and the Machado Lake subwatershed. The Permittees within this EWMP are the Cities of Rancho Palos Verdes, Palos Verdes Estates, and Rolling Hills Estates; County of Los Angeles; and LACFCD. • Rio Hondo/San Gabriel River —The RH/SGRWQG EWMP area covers portions of the Los Angeles and San Gabriel River watersheds. The Permittees within this EWMP are the Cities of Arcadia, Azusa, Bradbury, Duarte, Monrovia, and Sierra Madre; County of Los Angeles; and LACFCD. • Santa Monica Bay — The Santa Monica Bay EWMP area covers the central region of the Santa Monica Bay Watershed (SMB JG2 and SMB JG3) and includes the urbanized Dockweiler and Santa Monica subwatersheds, as well as natural open space located in the Castle Rock, Pulga Canyon, Temescal Canyon, and Santa Monica Canyon subwatersheds. The Permittees within this EWMP include the Cities of Los Angeles, Santa Monica, and El Segundo; County of Los Angeles; and LACFCD. • Upper Los Angeles River — The Upper Los Angeles River EWMP area covers the upper reaches of the Los Angeles River Watershed. The Permittees within this EWMP are the Cities of Alhambra, Burbank, Calabasas, Glendale, Hidden Hills, La Canada Flintridge, Los Angeles, Montebello, Monterey Park, Pasadena, Rosemead, San Gabriel, San Marino, South Pasadena, and Temple City; County of Los Angeles; and LACFCD. Upper San Gabriel River — The Upper San Gabriel River EWMP area covers portions of the San Gabriel River Watershed. The Permittees within this EWMP are the Cities of Baldwin Park, Covina, Glendora, Industry, and La Puente; County of Los Angeles; and LACFCD. Upper Santa Clara River — The Upper Santa Clara River EWMP area covers the Upper Santa Clara River Watershed. The Permittees within this EWMP are the City of Santa Clarita; County of Los Angeles; and LACFCD. Enhanced Watershed Management Programs b ESA 1140474 Notice of Preparation August 2014 2. Background 2.1 StormwaterMater Quality MS4 discharges consist of stormwater and non-stormwater generated from municipal land uses that are ultimately discharged into surface waters throughout the region. The MS4 system includes curbs and gutters, man-made channels, catch basins, and storm drains throughout the Los Angeles region. Discharges may adversely affect receiving surface water quality with pollutants such as bacteria, nutrients (nitrogen and phosphorus), aluminum, copper, lead, zinc, diazinon, and cyanide. Aquatic toxicity, particularly during wet weather, is also a concern. Stormwater and non-stormwater discharges of debris and trash are also a pervasive water quality problem in the Los Angeles region. Pollutants in stormwater and non-stormwater may have damaging effects on both human health and aquatic ecosystems. Water quality assessments conducted by the LARWQCB have identified impairment of beneficial uses of water bodies in the Los Angeles region possibly caused or contributed to by pollutant loading from municipal stormwater and non-stormwater discharges. The MS4 Permit described below is designed to reduce pollutant loads into local surface waters. 2.2 Total Maximum Daily Loads The federal Clean Water Act (CWA), Section 303(d), requires states to identify waters that do not meet water quality standards despite the treatment by pollution -control technology. States are required not only to identify these "water quality limited segments" but also to prioritize such waters for the purpose of developing Total Maximum Daily Loads (TMDLs). A TMDL is defined as the "sum of the individual waste load allocations (WLAs) for point sources and load allocations for nonpoint sources and natural background" (40 CFR 130.2), such that the capacity of the water body to assimilate constituent loads (the loading capacity) is not exceeded. A TMDL represents an amount of pollution that can be released into a specific water body without causing a decline in water quality and impairment of beneficial uses. The TMDL also allocates the loads among current and future pollutant sources to the water body and forms the basis for WQBELs and RWLs assigned in NPDES permits. LARWQCB and United States Environmental Protection Agency (USEPA) have established 33 TMDLs that identify Los Angeles County MS4 discharges as one of the pollutant sources causing or contributing to these water quality impairments. 2.3 MS4 Permit On November 8, 2012, the LARWQCB adopted the fourth NPDES MS4 Permit (Order No. R4-2012- 0175) for discharges from the MS4 within the coastal watersheds of Los Angeles County. The MS4 Permit became effective on December 28, 2012. The 2012 MS4 Permit establishes the waste discharge requirement for stormwater and non-stormwater discharges within the watersheds of Los Angeles County. The MS4 Permit identifies conditions, requirements, and programs that municipalities must comply with to protect regional water resources from adverse impacts associated with pollutants in stormwater and urban runoff. The MS4 Permit contains effluent limitations, RWLs, Minimum Control Measures (MCMs), TMDL provisions, and outlines the process for developing watershed management programs, including the EWMP. Enhanced Watershed Management Programs 7 ESA 1140474 Notice of Preparation August 2014 The 2012 MS4 Permit includes provisions that allow Permittees to voluntarily choose to implement an EWMP to achieve permit compliance with RWLs. The intent of the EWMP is to comprehensively evaluate opportunities, within the participating Permittees' collective jurisdictional boundaries, for collaboration among Permittees and other partners on multi -benefit regional projects that, wherever feasible, retain non-stormwater runoff and also address flood control and/or water supply. Twelve EWMP groups have formed to implement a collaborative approach to meeting the requirements of the 2012 MS4 Permit. 3. Enhanced Watershed Management Plans The MS4 Permittees listed in Figure 1 submitted 12 NOIs for the development of 12 EWMPs to the LARWQCB. The 12 NOIs were approved by the LARWQCB. The 12 EWMPs being developed in Los Angeles County for the applicable watersheds have been a collaborative effort by the various EWMP agencies. The EWMPs provide for their respective areas a comprehensive stormwater management plan that optimizes the stormwater and financial resources under the stewardship of the EWMP groups. The EWMPs include multi -benefit stormwater management projects that may also provide environmental, aesthetic, recreational, water supply, and/or other community enhancements in a cost-effective manner. To begin preparing the EWMPs, the Permittees collaborated on, developed, and submitted Draft Work Plans to the LARWQCB, outlining the proposed approach to preparation of each of their respective EWMPs. The EWMP Work Plans establish the basis for the EWMPs. The EWMP Draft Work Plans describe the path that MS4 Permittees propose to complete the Watershed Management Program requirements of the 2012 MS4 Permit. In accordance with the provisions of the MS4 permit, the work plans describe the following steps to EWMP development: 1. Identification of water quality priorities, including evaluation of existing water quality conditions, classification of pollutants, assessment of known and suspected pollutant sources in the watershed, and prioritization of water quality issues in the watershed 2. Characterization of existing and potential control measures within the watershed 3. Addressing the approach to incorporate reasonable assurance analysis (RAA) in the optimization of watershed control measures The LARWQCB is responsible for approval or denial of the EWMPs in compliance with the MS4 Permit. Implementation of the EMWPs would occur following approval by the LARWQCB. 4. EWMP Watershed Control Measures The MS4 Permit requires Permittees to identify strategies, control measures, and BMPs that will be implemented. Improvements to water quality will be achieved through implementation of watershed control measures that consist of both structural and nonstructural BMPs. BMPs vary in function and type, with each BMP providing unique design characteristics and benefits from implementation. Opportunities for BMP implementation are driven by locations where BMPs are feasible/desirable. The overarching goal of BMPs in the EWMPs is to reduce the impact of stormwater and non-stormwater on receiving water quality and to address water conservation and the water quality priorities. The development of the Enhanced Watershed Management Programs $ ESA 1140474 Notice of Preparation August 2014 EWMPs will involve the evaluation and selection of multiple BMP types, as described in the following pages. 4.1 Structural BMPs Structural BMPs involve the construction of a physical control measure to alter the hydrology and/or water quality of incoming stormwater or non-stormwater. The three major functions for structural BMPs are infiltration, water quality treatment, and storage, as follows: • Infiltration – Runoff is directed to percolate into the underlying soils. Infiltration generally reduces the volume of runoff and increases groundwater recharge. • Water quality treatment – Pollutants are removed through various unit processes, including filtration, settling, sedimentation, sorption, straining, and biological or chemical transformations. • Storage – Runoff is captured, stored (detained), and slowly released into downstream waters. Storage can reduce the peak flow rate from a site, but does not directly reduce runoff volume. There are three categories of structural BMPs—regional, centralized, and distributed; they are defined by the runoff area treated by the BMP and the required retention volume in accordance with the Permit. Structural BMPs fall under a variety of subcategories that correspond to their function and water quality benefit. Each of these three categories is described below. 4.1.1 Regional Structural BMPs "Regional EWMP projects" are defined by the MS4 Permit as multi -benefit regional projects that, wherever feasible, retain all non-stormwater runoff and all stormwater runoff from the 85th percentile, 24-hour storm event for the contributing drainage area, while also achieving other benefits such as flood control and/or water supply. Examples of regional structural BMPs include: • Infiltration BMPs o Surface Infiltration BMPs (Infiltration Basins, Infiltration Trenches, Infiltration Galleries, and Bioretention-implemented as single or multiple types) o Multi -Directional Infiltration BMPs (Dry Wells, Hybrid Bioretention, and Dry Wells) • Detention Basins (promote settling out of larger particles) • Capture and Use BMPs (underground cisterns, storage, and use as irrigation) Regional BMPs include infiltration facilities that promote groundwater recharge and detention facilities that encourage settling of larger particles in stormwater flows. Infiltration and detention regional BMPs can be either constructed as open -surface basins or subsurface galleries. Capture and Use BMPs collect and use stormwater where applicable for purposes such as irrigation. All of these BMP types must retain the required design storm volume without release into the MS4 or receiving waters. Opportunities for Regional BMPs will be identified and evaluated within and across subwatersheds, with focus on the multi -benefit potential for capture and reuse of wet -weather flows within variable drainage areas. Availability of public land will be the first criteria for identifying the location and type of BMP. Potential project locations may include areas with open spaces, whether they are within parks, large parking lots, or vacant spaces. Enhanced Watershed Management Programs y ESA 1140474 Notice of Preparation August 2014 Regional BMPs that may be included in the EWMPs will be identified and described further in the PEIR. 4.1.2 Centralized Structural BMPs Centralized structural BMPs are constructed structural practices intended to treat runoff from a contributing area of multiple parcels. Generally, centralized structural BMPs are installed on large public parcels or adjacent to storm drain outfalls and receiving waters. Some examples of centralized structural BMPs include the following: • Bioinfiltration BMPs (Bioretention with underdrain, bioinfiltration, highflow biotreatment, and raised underdrain, vegetated swales, filter strips—implemented as single or multiple types) • Constructed wetlands (aboveground and belowground) • Treatment BMPs/Low-flow diversion • Creek/river/floodplain/estuary restoration 4.1.3 Distributed Structural BMPs Distributed structural BMPs are constructed structural practices intended to treat runoff close to the source and are typically implemented at a single- or few -parcel level. The following list includes common distributed BMPs that can be implemented at the parcel level: • Site scale detention (dry/wet detention ponds, detention chambers) • Green infrastructure/Low Impact Development (LID) o Biofiltration o Bioretention o Porous/permeable pavers o Green streets o Infiltration BMPs o Bioswales/buffer strips o Planter boxes o Rainfall harvesting (green roofs, rain barrels, and cisterns) • Flow -Through Treatment BMPs o Media/cartridge filters o High-flow biotreatment • Source Control Treatment BMPs o Catch basin inserts/screens o Hydrodynamic separators o Gross solids removal devices (GSRDs) o Low flow diversions Enhanced Watershed Management Programs 10 ESA 1140474 Notice of Preparation August 2014 4.2 Institutional BMPs/ Non -Structural Control Measures These are policies, actions, and activities which are intended to prevent pollutants from entering stormwater runoff, thus eliminating the source of the pollutants. Most institutional BMPs are implemented to meet Minimum Control Measure (MCM) requirements in the MS4 permit; MCMs are considered a subset of institutional BMPs. MCMs do not involve construction of facilities that physically remove pollutants, but may involve costs associated with the procurement and installation of items such as signage or spill response kits. The six categories of MCMs outlined in the MS4 permit are as follows: • Development Construction Program • Planning and Land Development Program • Industrial Commercial Facilities Control Program • Illicit Connections and Illicit Discharges Detection and Elimination Program • Public Agency Activities Program • Public Information and Participation Program Nonstructural BMPs or Institutional Controls are often implemented as programs or strategies which seek to prevent and/or reduce runoff and/or pollution close to the source. Nonstructural BMPs include but are not limited to: • hrigation control (runoff reduction) and water -efficient landscaping • Brake pad replacement • Covered trash receptacles • Replacement of lead in wheel weights, or reduction in the copper content of brake pads • Pet waste cleanup stations • Street sweeping • Catch basin cleaning • Downspout disconnect program The MS4 permit allows Permittees to customize MCMs to address high-priority water quality goals within their watersheds. Customization can range from eliminating an MCM (with the exception of the Planning and Land Development Program requirement), proposing actions within an MCM to target specific water quality issues, and increasing or decreasing activities within an MCM (with appropriate justification). Because the LACFCD does not have jurisdictional authority for ordinance and code enactment or enforcement, they are limited in application of MCMs for Public Information and Participation Programs. 5. Potential Environmental Impacts The LACFCD is considering having the PEIR evaluate the following preliminary listing of potential environmental issues. The environmental issues to be addressed will be finalized after the close of the public comment period and comments on the NOP are received. Enhanced Watershed Management Programs t t ESA 1140474 Notice of Preparation August 2014 The PEIR will focus on potential effects that could result from implementation of the projects and management actions identified in each EWMP. The PEIR will assess the physical changes to the environment that would likely result from the construction and operation of EWMP projects, including direct, indirect, and cumulative impacts. Potential impacts are summarized below. The PEIR will identify mitigation measures if necessary to minimize potentially significant impacts of each EWMP. The PEIR is anticipated to evaluate, at a minimum, the following preliminary listing of environmental issues. Aesthetics Potential direct and indirect impacts could occur both during construction and after the proposed EWMP facilities are built and operating. Potential issues associated with aesthetics in relation to the proposed EWMP BMPs could include obstruction of high-quality or important views during either construction or operation of EWMP BMPs, impacts to local character, or construction of facilities incompatible with local recreation facilities or open -space areas. The PEIR will identify the potential visible physical changes to the natural and man-made environment, including the addition of new BMPs into the viewshed (temporary and permanent) and the removal of other components from the view (i.e., blocking of views). The PEIR will also identify the potential effects of the proposed EWMP BMPs on the existing light, glare, shadow, and shade environments. Air Quality Construction and operation of EWMP projects could cause air emissions. Air emissions could result from construction equipment exhaust, ground disturbance during construction, material hauling, construction employee -commute travel, vehicle operational maintenance trips, and vehicle trips associated with any increases in employment. Operation of some of the proposed EWMP facilities may potentially generate emissions associated with energy use. The PEIR will evaluate the effects of construction and operational activities on air quality and also will develop mitigation measures if necessary to reduce potential impacts. Biological Resources Implementation of the EWMP projects could occur within existing sensitive habitats. The projects could result in changes to wildlife habitat, disruption of natural movement corridors, fragmentation or isolation of wildlife habitats, and disturbance of sensitive species during construction or operation. In particular, reduced flows in downstream segments resulting from runoff retention could alter riparian and aquatic habitats. The PEIR will evaluate the potential for such facilities to impact biological resources and will also discuss local ordinances and state and federal regulations governing biological resources. Cultural Resources The proposed EWMP BMPs would require construction of structural BMPs which could be above and/or below ground. Issues regarding cultural resources during construction activities could include disturbance of known or unknown archeological sites, paleontological resources, and/or human remains where groundbreaking activities occur as well as disturbance or alteration of structures with historical importance. The PEIR will assess the potential effects of the proposed EWMP BMPs on cultural resources, including archaeological, paleontological, and Native American resources. Mitigation measures will be identified if necessary to reduce the level of impact where possible. Geology, Soils, and Seismicity Southern Los Angeles County is a seismically active region. The proposed EWMP BMPs would require construction of structural BMPs that could be subject to potential seismic and geologic hazards, including Enhanced Watershed Management Programs 12 ESA 1140474 Notice of Preparation August 2014 ground shaking, liquefaction, soil stability conditions, soil erosion rates, expansive soils, and landslides. Policies provided in the County's General Plan and applicable standard County requirements will be evaluated as to their effect of mitigating or avoiding any potentially significant effects. The PEIR will identify mitigation measures if necessary to reduce potential adverse effects to proposed facilities. Greenhouse Gas Emissions Implementation of proposed EWMP BMPs could result in the generation of greenhouse gas (GHG) emissions associated with construction and operations. The PEIR will estimate construction -related emissions and long-term operational emissions, including total CO2 -equivalent emissions for evaluating the effects of GHGs. The PEIR will examine the project's effects on global climate change and evaluate consistency of the project with the State's GHG emissions reduction goals. Hazards and Hazardous Materials Excavation during construction of proposed EWMP BMPs could uncover contaminated soils or hazardous substances that pose a substantial hazard to human health or the environment. Construction activities could result in the release of hazardous materials. Potential hazards will be evaluated and assessed by reviewing the data collected by the California State Water Resources Control Board (SWRCB) GeoTracker and the California Department of Toxic Substances Control (DTSC) Envirostor databases. The policies provided in the County's General Plan and any standard County requirements will be evaluated as to their effect of mitigating or avoiding any potentially significant effects. The PEIR will evaluate the potential for EWMP projects to result in the release of hazardous materials. Mitigation measures will be proposed if necessary to reduce any significant effects of the project that may involve hazardous material issues to ensure that any hazards encountered during construction would be handled in accordance with applicable regulations. Hydrology and Water Quality Implementation of the proposed EWMP BMPs may change local drainage patterns at construction sites, which could affect the volume, quality, and rates of surface runoff that in turn could affect local surface water resources. Considered cumulatively, the proposed EWMP facilities may also change regional drainage patterns, which could affect the hydrology, hydraulics, and/or water quality of streams, rivers, and other receiving waters. The PEIR will identify relevant federal, state, and local regulations and agencies, including provisions of the federal Clean Water Act, the state Porter -Cologne Water Quality Control Act, and the permitting and regulatory authority of the RWQCB. The PEIR will identify stormwater quality protection measures required during construction and operation of proposed facilities. The PEIR also will evaluate potential impacts to flood control capacity and develop mitigation strategies if necessary to avoid significant impacts. Implementation of the proposed EWMP BMPs would likely result in increased infiltration and recharge in various locations throughout the EWMP watersheds. Such activities could affect local groundwater levels and water quality. The PEIR will evaluate potential effects of increased storm water recharge and will identify mitigation measures if necessary to ensure that potentially necessary significant impacts are reduced or avoided. Land Use and Recreation Implementation of the proposed EWMP BMPs would include implementation of structural BMPs throughout the EWMP watershed areas. Issues associated with land use and planning could result from construction of new BMPs from the proposed EWMP. Issues associated with these components could Enhanced Watershed Management Programs 13 ESA 1140474 Notice of Preparation August 2014 include compatibility with adjacent land uses or zoning designations, consistency with relevant land use policies, and access to adjacent land during new construction or repairs of existing flood control or recharge facilities. The PEIR will evaluate the compatibility of the proposed EWMP BMPs with existing and planned land uses within the EWMP watershed areas. Noise Implementation of the proposed EWMP BMPs would require implementation of structural BMPs that would potentially generate noise and vibration. Construction activities that could be a significant source of noise and vibrations include trucking operations, use of heavy construction equipment (e.g., graders, cranes, and fromend loaders), pile driving activities, and blasting. Fixed sources of noise may include pumps and motors at pump stations. Construction noise and vibration impacts related to the proposed EWMP facilities will be evaluated at a program level. The PEIR will recommend mitigation strategies to ensure that proposed EWMP projects implemented by local agencies comply with local noise policies and ordinances. Population and Housing/Growth Inducement Implementation of the proposed EWMP BMPs will include implementation of structural and nonstructural BMPs that would improve water quality and increase stormwater infiltration. The proposed EWMP BMPs are unlikely to affect population and housing or induce growth. In addition, construction of the proposed EWMP BMPs or alteration of current facilities is not anticipated to lead to displacement or interruption of operation of businesses during construction. The PEIR will, however, identify current population and employment projections and identify local planning jurisdictions with the authority to approve growth and mitigate secondary effects of growth. Public Services Implementation of the proposed EWMP BMPs is unlikely to affect demand for public services, or, by itself, to require new or expanded facilities for public service providers. Potential issues related to the construction and operation of the proposed EWMP facilities include disruption or impediment of fire, police, or other emergency services to areas/facilities where proposed EWMP facilities would be constructed or operated. However, the PEIR will assess the potential for the proposed EWMP BMPs to affect police and fire protection services, schools, parks, and recreational facilities, such that new or expanded buildings or structures may be required that would, in turn, affect the environment. Traffic and Transportation Construction of the proposed EWMP BMPs could affect traffic on local roadways as a result of vehicle trips associated with hauling of material and equipment, road closures and detours, increased demand for parking to serve construction workers, and increase in traffic hazards caused by construction activities. The PEIR will evaluate the potential for additional construction vehicles, lane closures, or road closures to impact traffic and circulation. The PEIR will identify mitigation strategies to reduce any potential effects. Utilities and Energy Potential issues related to the construction and operation of the proposed BMPs include the disruption or impediment of service to areas where the proposed BMPs would be constructed or operated. Existing and projected regional supplies, demands, and facilities will be described along with any existing constraints, deficiencies, or service issues for the proposed EWMP BMPs. The PEIR will evaluate the project's potential to affect utilities and will identify mitigation measures to minimize the effects. Enhanced Watershed Management Programs 14 ESA 1140474 Notice of Preparation August 2014 Implementation of the proposed EWMP BMPs would also result in implementation of watershed control measures that may potentially increase the amount of energy required locally to operate some of these BMPs. The PEIR will evaluate potential energy consumption associated with implementation of structural and nonstructural BMPs. Enhanced Watershed Management Programs 15 ESA 1140474 Notice of Preparation August 2014 Attachment 2 Notice of Completion r ESA J Notice of Completion & Environmental Document Transmittal Mail to: State Clearinghouse, P. O. Box 3044, Sacramento, CA 95812-3044 (916) 445-0613 I SCH # For Hand Delivery/Streel Address 1400 Tenth Street, Sacramento, CA 95814 Project Title: Enhanced Watershed Management Programs (EWMP) Program EIR Lcad Agency Los Angeles County Flood Control District (LACFCD) Contact Person: Gregg BeGell Mailing Address: 900 South Fremont Avenue, 1 ith Floor Phone: (626) 300.3298 city: Alhambra Zip: 9203 County: Los Angeles — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — Project Location: County Los Angeles t i:y/Neare=t Community: Greater Los Angeles Area Cross Streets: Throughout Los Angeles County iip Code- Other Lat. / Long.: Other N� Other W Total Acres: Various Assessor's Parcel No.. Various throughout Los Angeles County Section: Various 'Twp. Various Range Various Buse Various Within 2 Miles: State I lwys # 1, 2, 19, 27, 47, 60, 90, 91, 101, 103, 107, 187 Waterways: Ballona Creek, Los Angeles River, San Gabriel River, Santa Clara River, Malibu Creek, Dominguez Channel, Santa Monica Bay and Marina del Rey Airports: LAX, Burbanktr:� — houl LA County Schools: Throughout LA County -----------------RECE-IV- ------------------ Document Type: CEQA: ® NOP ❑ Draft EIR �r�S 2 Q g011,Nf:'.PA; ❑❑ NO[ Other: ❑❑ Joint Document ❑ Early Cons ❑ SupplementtSub. ent il,RL 7 EA Final Document ❑ Neg Dec (Prior SCI I No.) C] Draft EIS ❑ Other El Mil Neg Dec Other STATEfJEAggffpME ❑ rONSI — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — Local Action Type: ❑ General Plan Update ❑ Specific flan ❑ Rezone ❑ Annexation ❑ General Plan Amendment ❑ Master Plan ❑ Prezone ❑ Redevelopment ❑ General Plan Element ❑ Planned Unit Development ❑ Use Permit ❑ Coastal Permit ❑ Community Plan ❑ Site Plan ❑ Land Division (Subdivision, etc.) ® Other: MS4 Compliance Projects — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — Development Type: ❑ Residential: Units Acres El Water Facilities: Type Stonnwater MGD ❑ Office: Sq.ft. Acres Employees ❑ Transportation: 'type ❑ Commercial:Sq.ft. Acres Employees ❑ Mining: Mineral ❑ Industrial: Sq.ft. Acres Employees ❑ Power: Type MW ❑ Educational ❑ Waste Trealment:Type MGD ❑ Recreational ❑ Hazardous Waste:Type ❑ Other: — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — Project Issues Discussed in Document: ® Aesthetic/Visual ❑ Fiscal ® Recreation/Parks ® Vegetation ® Agricultural Land ® Flood Plain/Flooding ❑ Schools/Universities ® Water Quality ® Air Quality ❑ Forest Land/Fire I lazard ❑ Septic Systems ® Water Supply/Groundwater ® Archeological/Historical ® Geologic/Seismic ❑ Sewer Capacity ® Wetland/Riparian ® Biological Resources ® Minerals 9 Soil Erosion/Compaction/Grading ® Wildlife ❑ Coastal Zone El Noise ❑ Solid Waste ❑ Growth Inducing ® Drainage/Absorption ® Population/Housing Balance ®'Toxic/I lazardous ® Land Use ❑ Economic/Jobs ED Public Services/Facilities ® Traffic/Circulation ® Cumulative Effects ® Other Cultural Resources — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — Present Land Use/Zoning/General Plan Designation: Various land uses throughout the County. — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — Project Description: (please use a separate page if necessary) The development of the EWMP will involve the evaluation and selection of multiple watershed control measures or best management practices (BMP) types including non-structural and distributed, centralized and regional structural BMPs. These BMPs will be implemented to meet compliance goals and strategies under the 2012 MS4 Permit. Structural BMPs involve the construction of a physical control measure to alter the hydrology and/or water quality of incoming stormwater or non-stormwater The three major functions for structural BMPs are infiltration, water quality treatment, and storage. There are three categories of structural BMPs, defined by the runoff area treated by the BMP and the required retention volume in accordance with the Permit. "Regional EWMP projects' are defined by the MS4 Permit as mulli-benefit regional projects that, wherever feasible, retain all non -storm water runoff and all storm water runoff from the 85th percentile, 24-hour storm event for the contributing drainage areas while also achieving other benefits including flood control andlor water supply. These structural BMPs are defined as "regional" BMPs based on this Permit retention requirement. Example of regiona structural BMPs include infiltration BMPs, detention basins and capture and use BMPs. Centralized structural BMPs capture and treat stormwaler from a contributing area of multiple parcels, and include bio -infiltration BMPs, constructed wetlands, and creeklstream restoration pro,ects. Generally, centralized BMPs are installed on large public parcels or adjacent to storm drain outfalls and receiving waters. Distributed structura BMPs are constructed structural practices intended to (real runoff close to the source and are typically implemented at a single- or few -parcel level. Reviewing Agencies Checklist Lead Agencies may recommend State Clearinghouse distribution by marking agencies below with and "X". If you have already sent your document to the agency please denote that with an "S". Air Resources Board Boating & Waicrways. Department of California Highway Patrol CaWire S Cattrans District N 7 _ Caltrans Division of Aeronautics _ Caltrans Planning (I leadquarters) Central Valley Flood Protection Board Coachella Valley Mountains Conservancy Coastal Commission Colorado River Board Conservation, Department of Corrections, Department of _ Della Protection Commission Education, Department of Energy Commission S Fish & Game Region 9 South Coast Region Food & Agriculture, Department of General Services, Department of S Health Services, Department of Housing & Community Development Integrated Waste Management Board Office of Emergency Services Office of Historic Preservation Office of Public School Construction S Parks & Recreation _ Pesticide Regulation, Depaaiment of Public Utilities Commission S Regional WQCB N 4 Resources Agency S.F. Ray Conservation & Development Commission X San Gabriel & Lower L.A. Rivers and Muss Conservancy San Joaquin River Conservancy X Santa Monica Mountains Conservancy State Lands Commission SWRCB: Clean Water Grants X SWRCB: Water Quality SWRCB: Water Rights Tahoe Regional Planning Agency S Toxic Substances Control, Department of Water Resources, Department of S Other County of Los Angeles, Board of Supervisors Disl I, 2, 3, 4, 3 Local Public Review Period (too be filled in by lead agency) SUAL ig Date $ / �j J 7io/l Ending Date %/�/ AV fY Lead Agency (Complete if applicable): Consulting Firm: Environmental Science Associates Applicant Los Angeles County Flood Control District (LAC It CD) Address 626 Wilshire Blvd. Address: 900 S Fremont Ave CitylStatel%ip: I.os Angcics?CA 90017 City/State.7ip: Alhambra/CA/91803 Contact. David Pohl Phone. 626-458-4300 Phone: (213) 599=1300 Signature of Lead Agency Representative:. Date: Authority cited. Section 21083, Public Resources Code Oeference Section 21061, Public Resources Code. Attachment 3 Summary of NOP Availability Emails r ESA J Email address - other Ilee@dpw.lacounty.gov diane.marcussen@altadenatowncouncil.org alfredo.magallanes@lacity.org angeles.chapter@sierraclub.org srobinson@jlha.net rasmusjb@bv.com andrea.crumpacker@westonsolutions.com rlaveaga@cityofpasadena.net twest@carollo.com bobbigold@ucla.edu info@adtowncounciI.com atwater.richard@gmaii.com dbloome@treepeople.org petra.schneider@netzero.net sandiaennis@castaicareatowncouncil.org tmm@arroyoseco.org greg.good@lacity.org cicwater@gmail.com mklee@jlha.net tavalos@dpw.lacounty.gov andyw@rpv.com lenny@lcwstewards.org tlee@cityofinglewood.org maria.agustin@dot.ca.gov environment@asnc.us razz.berry@verizon.net kcurtis@portla.org jthorsen@malibucity.org danielle.sevilla@gmail.com davejohnson@sgvmwd.com winter@theriverproject.org jsamson@larivercorp.com jkitz@mountainstrust.org Email Lists Source Name Created At Updated At Opened At LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/15/20149:46am LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/12/20146:03pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 9/12/20145:36pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 9/12/20145:11pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/12/2014 12:36pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/11/2014 7:10pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/11/2014 3:48pm LACK EWMP PEIRS,MIG eNews External 10/10/2013 10:56 8/29/201414:55 9/11/201412:32pm LACK EWMP PEIRS,CWCB Updates 2/8/2013 17:43 8/29/201414:55 9/11/201411:16am LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/10/20148:01pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/10/20148:00pm LACK EWMP PEIRS,CWCB Updates 2/12/2013 13:54 8/29/201414:18 9/10/20145:37pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/10/2014 5:06pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 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8/29/201414:42 9/8/20141:05pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 9/8/201412:22pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/8/2014 11:28am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/8/2014 9:44am LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 9/6/20144:20pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/5/2014 9:08pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/5/2014 2:36pm First name Black & Veatch Weston Solutions So CA Water Committee - Stormwater task force TreePeople Port of Los Angeles The River Project johng@sccwrp.org jgamble@lvmwd.com pherzog@surfrider.org stevenmwilliams99@gmail.com steve.wiIIiams@rcdsmm.org jsk1.2007@gmail.com jguerrer@dpw.lacounty.gov mike@watershedhealth.org mvoong@waterboards.ca.gov diIlardjoyce@yahoo.com adrienne@southcoastbotanicgarden.org ch ristine.frey@Iacity.org elaine.jeng@redondo.org ddolphin@cityofalhambra.org mgalvez@jlha.net info@wearemdr.com wetiandact@earthIink.net afarassati@cityofcaIabasas.com rmechsner@westranchtowncouncil.com hamid.tadayon@lacity.org Ieclairejp@cdmsmith.com sho@paramountcity.com g.wolfberg@verizon.net jhendra@rcdsmm.org drennanmd@bv.com michael.scaduto@lacity.org richard.haimann@hdrinc.com charlie.yu@lacity.org amho@montereypark.ca.gov adelgado@fs.fed.us cstevens@rcdsmm.org jpereira@cwecorp.com kjames@heaIthebay.org kharrel@cwecorp.com LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/5/2014 1:11pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/5/2014 11:41am LACK EWMP PEIRS,CWCB Updates 2/12/2013 13:54 8/29/2014 14:18 9/4/2014 8:57pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/4/20148:44pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/4/20148:44pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/4/2014 8:37pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/4/2014 7:20pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/4/2014 5:34pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/4/2014 5:25pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/4/2014 2:39pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/4/2014 1:57pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/4/2014 1:31pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/4/2014 12:38pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/4/2014 12:28pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/4/2014 1:52am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/4/2014 1:10am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/3/2014 5:35pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/3/2014 5:26pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/3/2014 5:18pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/3/2014 5:00pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 9/3/20144:17pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/3/2014 3:34pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/3/2014 3:16pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/3/2014 1:39pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/3/2014 12:57pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/3/2014 12:53pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/201414:42 9/3/201412:10pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 9/3/201412:04pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 9/3/201411:17am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/3/2014 2:27am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/3/2014 1:47am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 11:16pm LACK EWMP PEIRS,CWCB Updates 2/8/2013 17:43 8/29/2014 14:18 9/2/2014 8:08pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 6:55pm Surf Rider Council for Watershed Health LARWQCB D� IMILviii Black & Veatch HDR Heal the Bay smoraleschoate@santafesprings.org michael.affeldt@lacity.org gold@ioes.ucla.edu education@coloradolagoon.org editor@coloradolagoon.org ajirik@portla.org seth—riley@nps.gov mhall@glacvcd.org lynn.rodriguez@ventura.org douglaspfay@aol.com bjensen@valleyconnect.com blake@watershedhealth.org info@rcdsmm.org gosmena@dpw.lacounty.gov victor.ruiz@Iacity.org csarabia@pvplc.org davidthomas@vrsd.com ewelina.mutkowska@ventura.org friends@coloradolagoon.org tpiasky@bialay.org obrownson@larivercorp.com katy_delaney@nps.gov denise—kamradt@nps.gov barbara.romero@lacity.org cgeorge@malibucity.org bra i @ cityofi nglewood.org chanes.herbertson@culvercity.org melissa.guerrero@mrca.ca.gov farhana.mohamed@lacity.org chien.pei.yu@dot.ca.gov shokoufe.marashi@lacity.org jiII.taylor@ccc.ca.gov kvivanti@lakewoodcity.org Ieighannek@westbasin.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 6:55pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 6:05pm LACK EWMP PEIRS,LAFCD Public Health 12/20/2012 17:29 8/29/2014 14:18 9/2/2014 5:57pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/2/20145:34pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/2/20145:23pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/2/2014 5:16pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 5:10pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 5:09pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 5:06pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/2/20144:50pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/2/20144:48pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/2/20144:37pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/2/20144:33pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/2/20144:29pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/2/20144:13pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/2/20144:07pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 3:50pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 3:06pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 2:43pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/2/2014 2:33pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/2/2014 2:28pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 2:07pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 1:55pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 1:20pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 1:11pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 1:09pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 1:08pm LACK EWMP PEIRS,MIG eNews External 10/10/2013 11:15 8/29/201414:18 9/2/201412:56pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 12:55pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/2/2014 12:54pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 12:52pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 12:35pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 12:28pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 12:27pm UCLA Institute of the Environment & Sustainability Port of Los Angeles Building Industry Association Los Angeles Conservation Corps Mountains Recreation & Conservation Authority DOT Div 7, Division of Design dcartagena@beverlyhills.org LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/2/2014 12:21pm bhamamo@dpw.lacounty.gov LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 12:13pm chair@lbsurfrider.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 9/2/201412:01pm nutritwarehouse@yahoo.com LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 9/2/201411:59am jennifer@lancasterbiology.com LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 9/2/201411:58am bromley.eugene@epa.gov LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 11:44am jdettle@torrnet.com LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/2/2014 11:42am Irocha@esassoc.com LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 11:39am sperlstein@weho.org LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/2/2014 11:35am lenise.marrero@lacity.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 11:35am sabrina.rivera@aecom.com LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 11:33am megan.whalen@lacity.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 11:20am cmccullough@jlha.net LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 11:19am joshua.carvalho@smgov.net LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/2/2014 11:15am kendrick.okuda@lacity.org Added by you 8/29/201414:55 9/2/2014 11:10 9/2/2014 11:04am mtripp@bh.lacounty.gov LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 9/2/201411:04am dkrauss@cityofhawthorne.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 11:01am ys@cityofrh.net LACK EWMP PEIRS,MIG eNews External 10/10/2013 11:24 8/29/201414:55 9/2/201410:58am susan.shu@lacity.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:53am nadiac@rpv.com LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:50am info@amigosdelosrios.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:42am dsharpton@mountainstrust.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:36am pmarkle@lacsd.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:34am tony.li@lacity.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:34am dawn.petschauer@lacity.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:33am sbirosik@waterboards.ca.gov LACK EWMP PEIRS,CWCB Updates 2/8/2013 17:43 8/29/201414:55 9/2/201410:29am ioannice.lee@lacity.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:28am juan.benitez@lacity.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:25am zora.baharians@lacity.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 9/2/201410:23am javier.solis@lacity.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:17am Icelaya@ci.agoura-hills.ca.us LACK EWMP PEIRS,CWCB Updates 2/8/2013 17:43 8/29/201414:55 9/2/201410:06am vijay.desai@lacity.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:04am henry.yuan@lacity.org LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:02am jeichler@citruscollege.edu LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:00am City of Beverly Hills City of West Hollywood City of Santa Monica taraneh.nik-khah@lacity.org wjohnson@dpw.lacounty.gov hubertus.cox@lacity.org kaden.young@culvercity.org roulene.diego@lacity.org jon.ball@lacity.org marsa.chan@lacity.org member@tnc.org bineris@hotmail.com kjsery@aol.com codyender@gmail.com rene.a.vermeeren@usace.army.mil dmuelIer@downeyca.org ctwilliams20l2@yahoo.com ksusilo@geosyntec.com montgomerylizzy@gmail.com adel.hagekhaliI@lacity.org kkemmler@scc.ca.gov coconnell@westranchtowncouncil.com jim.lamm@baIIonacreek.org kellyquick@castaicareatowncouncil.org tmoon@dpw.lacounty.gov Iakesidemedia@earthIink.net dlippman@lvmwd.com mark.capelIi@noaa.gov jhignite@charter.net djacobs@ucla.edu ehuerta28@gmail.com cristorey@charter.net info@pacpaIicc.org lisaf@ ba I lonafriends.org aIison[inder@yahoo.com dan@covina.com ian@aquatechnex.com LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:00am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 10:00am LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/2/20149:42am LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/2/2014 9:26am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 9:25am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 9:13am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 9:10am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 9:08am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 12:42am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/2/2014 12:04am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/1/2014 10:44pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/1/2014 9:22pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/1/2014 9:00pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/1/2014 5:22pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 9/1/2014 5:09pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 9/1/20144:34pm LACK EWMP PEIRS,CWCB Updates 2/8/2013 17:43 8/29/2014 14:55 9/1/2014 2:31pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 9/1/2014 1:22am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/31/2014 11:17pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/31/20147:19pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/31/2014 5:25pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 8/31/2014 1:50pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/31/2014 1:38pm LACK EWMP PEIRS,CWCB Updates 2/8/2013 17:43 8/29/201414:55 8/31/20149:58am LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/31/20143:43am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/31/2014 1:13am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/31/201412:39am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/2014 11:40pm LACK EWMP PEIRS,sbX eNewsletter,sbX 12/18/2009 18:16 8/29/2014 14:55 8/30/2014 11:08pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/2014 6:27pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/30/20146:19pm LACK EWMP PEIRS,GoodsMovement 4/20/2009 17:31 8/29/2014 14:55 8/30/2014 5:45pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/30/20145:32pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/30/20143:53pm Culver City USACE Geosyntec Ballona Creek Renaissance County of Los Angeles/ Friends of Ballona Wetlands Ms. Alison ksander@usc.edu rexfrankel@yahoo.com retamoser@gmail.com Irapp@lakewoodcity.org craig.collins@silverlakereservoirs.org salbers@rcdsmm.org karen@longbeachmarine.org Iesliepurcell@gmail.com martykreisler@castaicareatowncounci1.org robert.thiel@cox.net patrickatwater@gmail.com bdingman@lvmwd.com njohn@lawa.org naturetrust@earthIink.net nicoleshu7l8@gmaii.com david.a.ford@sce.com clarkdeblasio@gmail.com chair@surfrider-southbay.org stevefreee@gmail.com wernerdesign@verizon.net camswift@pacbell.net gardens@rodsatt.com sean.anderson@csuci.edu wrigleyisgoinggreen@hotmaiI.com mstevens@kinneticlabs.net reymundo@usgvmwd.org robert.vega@lacity.org ggreene@cwecorp.com jeffpreach @castaicareatowncounciLorg pamela.hirneisen@lacity.org wing.tam@lacity.org rcdsmm.edu@gmaii.com jbellomo@willdan.com annette@expogreenway.org LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 8/30/2014 2:44pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/2014 1:57pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/2014 1:33pm LACK EWMP PEIRS,MIG eNews External 10/10/2013 11:15 8/29/201414:55 8/30/20141:19pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/201414:55 8/30/20141:06pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/2014 1:01pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/2014 12:50pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/2014 12:45pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/201411:45am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/201411:36am Added by you 8/29/2014 14:55 8/30/2014 11:24 8/30/201411:23am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/201410:35am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/20141:35am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/2014 12:34am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/2014 12:24am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/2014 12:11am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/30/2014 12:00am LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 11:41pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 11:10pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 11:02pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 10:54pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 10:54pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 10:19pm LACK EWMP PEIRS,I-710 Interested Per; 7/26/2012 15:45 8/29/201414:55 8/29/2014 10:12pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 10:09pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20149:57pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 8/29/20149:48pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 8/29/20149:43pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 8/29/20149:29pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20149:16pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 9:16pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20149:12pm LACK EWMP PEIRS,CWCB Updates 2/12/2013 13:54 8/29/201414:55 8/29/20148:58pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/29/20148:54pm USC Ballona Creek Renaissance djohns@crpd.org garcia.crysta1.1990@gmaiI.com angelica.hernandez@sen.ca.gov ghildeb@dpw.lacounty.gov ninh.hong@lacity.org cunguyen@dpw.lacounty.gov khostert@swwc.com rwatson@rwaplanning.com travislongcore@losangelesaudubon.org johngrap@ucla.edu skennedy@enfact.net oaksrus@verizon.net dkoo@waterboards.ca.gov spincetl@ioes.ucia.edu ghanraha@caIIutheran.edu IIamonte@maIibucity.org rod.merl@smgov.net jbrown@malibucity.org jsimes@usbr.gov shane@usgvmwd.org ccash@paramountcity.com sgroner@sga-inc.net traci.minamide@Iacity.org svalor@santamonicabay.org tim.pershing@asm.ca.gov crivers@cwecorp.com dragos@blue-tomorrow.com migueI@gdmIonline.com gbrideau@therobertgroup.com miguel@dakeluna.com fwu@dpw.lacounty.gov bsaito@lacorps.org ysim@dpw.lacounty.gov [alexanderson@dpw.lacounty.gov LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20148:46pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20148:42pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 8:29pm LACK EWMP PEIRS,LAFCD Public Health 12/20/2012 17:49 8/29/2014 14:18 8/29/2014 8:28pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20148:28pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/29/20148:14pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20148:04pm LACK EWMP PEIRS,I-710 Interested Per; 6/12/2013 15:01 8/29/2014 14:55 8/29/2014 8:03pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/29/20148:00pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20148:00pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:58pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:53pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:49pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/29/20147:43pm Added by you 8/29/2014 14:55 8/29/2014 19:43 8/29/2014 7:43pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:42pm LACK EWMP PEIRS,MIG eNews External 10/10/2013 11:18 8/29/201414:55 8/29/20147:39pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:39pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/29/20147:38pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:38pm LACK EWMP PEIRS,I-710 Master,1-710 C 6/29/2010 18:24 8/29/2014 14:55 8/29/2014 7:36pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:31pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:30pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:30pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:29pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:25pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 8/29/20147:24pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/201414:42 8/29/20147:23pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 8/29/20147:23pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:23pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/29/20147:22pm LACK EWMP PEIRS,CWCB Updates 2/12/2013 13:54 8/29/201414:18 8/29/20147:21pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/29/20147:20pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/29/20147:19pm Director of Operations/Manager of Watersheds, LADW IW.A1 ]ri9� The Audubon Society UCLA Institute of the Environment & Sustainability l Raymond The Green Coalition LAD W P Los Angeles Conservation Corps LAD W P LAD W P jennifer@la-bike.org belindafaustinos@gmail.com aosheagreenfield@bialay.org eileen. k.takata @ usace.army.m it susie.santilena@lacity.org jmaret@dfg.ca.gov tcontreras@fs.fed.us nancy@watershedhealth.org mgbrown@bialay.org gpidwb@gmail.com judithdavies66@gmail.com dwayman@scc.ca.gov jdougall@lvmwd.com kristy@watershedhealth.org helsleyn@gmail.com kfisher@ci.agoura-hills.ca.us info@hiIIsforeveryone.org wendy.dinh@lacity.org jbiggs@brwncald.com vice president@asnc.us michelle.mattson@westonsoIutions.com fbarros@usc.edu president@asnc.us gusm@westbasin.org kim@saveourbeach.org mkbartl@gmail.com eric.vuong@lacity.org jon@expogreenway.org elopez@wrd.org ggaIindo@lapuentewater.com troy.ezeh@lacity.org snissman@lacbos.org domingo.orosco@lacity.org javier@bikesgv.org LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/29/20147:18pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:17pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 8/29/20147:15pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/201414:42 8/29/20147:09pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 8/29/20147:09pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:09pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 7:05pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/29/20147:04pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:04pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:02pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:01pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20147:00pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:59pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 6:58pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/2014 6:58pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 6:58pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 6:57pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:56pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:54pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:52pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/2014 14:42 8/29/2014 6:51pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/29/20146:49pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:49pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:46pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:46pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:46pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/201414:55 8/29/2014 6:45pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/29/20146:44pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:44pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 6:44pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:43pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:42pm LACK EWMP PEIRS,CWCB Updates 2/8/2013 17:43 8/29/2014 14:55 8/29/2014 6:41pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 6:41pm Los Angeles County Bicycle Coalition USACE Council for Watershed Health Weston Solutions USC Ballona Creek Renaissance cleanlb@haIloworld.org stephanieebia@castaicareatowncouncil.org dflores@rmcwater.com trisham@aol.com gderas@pico-rivera.org srapoport@waterboards.ca.gov bryan.truong@lacity.org ramon.barajas@lacity.org vivian.marquez@lacity.org dpedersen@lvmwd.com irina_irvine@nps.gov anne—dove@nps.gov g3owll@gmail.com Ihempe@lynwood.ca.us rbryden@dpw.lacounty.gov dpelser@cityofwhittier.org azya.jackson@lacity.org jbrickey@jlha.net anthony.spina@noaa.gov rick.valte@smgov.net bthom pson@willdan.com ogalang@brwncald.com pavlova.vitaIe@waterboards.ca.gov sarah@landspaces.net LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 6:40pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:39pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:39pm LACK EWMP PEIRS Added by you 8/29/2014 14:18 8/29/201415:39 8/29/20146:38pm LACK EWMP PEIRS,CWCB Updates 2/8/2013 17:43 8/29/2014 14:55 8/29/2014 6:37pm LACK EWMP PEIRS,CWCB Updates 2/8/2013 17:43 8/29/201414:18 8/29/2014 6:37pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/2014 6:37pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 6:37pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 6:37pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 6:37pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 6:37pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:35pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:35pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 6:35pm LACK EWMP PEIRS,LAFCD Public Health 12/20/2012 17:49 8/29/201414:18 8/29/20146:34pm LACK EWMP PEIRS,CWCB Updates 2/8/2013 17:43 8/29/201414:55 8/29/20146:34pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:34pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:34pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:34pm LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 8/29/20146:33pm LACK EWMP PEIRS Added by you 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 6:33pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201418:36 8/29/20146:33pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:33pm LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 8/29/20146:32pm LARWQCB LAD W P City of Santa Monica Oliver Email address - other dave.jones@ch2mhill.com dfleming@westranchtowncouncil.com amousavi@infeng.org rwinter@westranchtowncouncil.com btoqe@westranchtowncouncil.com Email Lists LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS Source Name Added by you Added by you Added by you Added by you Added by you jzimmerman@westranchtowncouncil.com LACK EWMP PEIRS Added by you debbie@downtownsm.org LACK EWMP PEIRS Added by you dave.weshoff@sfvaudobon.org jeanette@grassrootscoalation.org gregg@ci.rol ling. hi Ilsestates.ca.us virginia.wei@iadwp.com tatiana@lawaterkeeper.org alexander.vasquez@lacity.org chris.demonbun@lacity.org clayton.yoshida@lacity.org david.cheung@lacity.org emerverto.cheng@lacity.org megan.whalen@lacity.org ninh.hong@lacity.org pamela.hirneisen@lacity.org robert.vega@lacity.org rnezhad@ennncald.com roxana.marashi@lacity.org sergio.u.perez@lacity.org shahram.kharagani@lacity.org tfinney@ pa rks.lacounty.gob arne_anselm@ventura.org peter@epa.gov rick.bush@noaa.gov acervantes@sogate.org mpestrella@dpw.lacounty.gov phong@bos.lacounty.gov nancy@watershedhealth.org LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS LACK EWMP PEIRS Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you Added by you LACK EWMP PEIRS Added by you LACK EWMP PEIRS,I-710 Master,I-710 ESW LACK EWMP PEIRS,CWCB Updates LACK EWMP PEIRS Added by you LACK EWMP PEIRS Added by you Created At 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:18 8/29/2014 14:18 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:18 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 7/19/2010 14:48 2/12/2013 13:54 8/29/2014 14:18 8/29/2014 14:18 Updated At 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:42 8/29/2014 14:42 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:42 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:55 8/29/2014 14:18 8/29/2014 14:42 8/29/2014 14:42 Bounce Reason First name Undeliverable Mailbox full Undeliverable Mailbox full Mailbox full Mailbox full Undeliverable Undeliverable The Audubon Society Undeliverable Ballona Creek Renaissance Undeliverable Undeliverable Non-existent Los Angeles Waterkeeper Other Other Other Vacation / Auto reply Other Vacation / Auto reply Vacation / Auto reply Vacation / Auto reply Vacation / Auto reply Undeliverable Other Other Other Undeliverable Non-existent Non-existent Vacation / Auto reply Non-existent Arturo Non-existent Assistant Director, LADWP Non-existent LA County Board of Supervisorial District 2 Vacation / Auto reply Council for Watershed Health mike@watershedhealth.org LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 bishop.john@epa.gov LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 josephine.r.axt@usace.army.mil LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 feldman@uci.edu LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 titushz@bv.com LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 steven.finton@culvercity.org LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 sarahh@sbcglobal.net LACK EWMP PEIRS Added by you 8/29/201414:18 8/29/201414:42 andy.niknafs@water.ladwp.com LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 hcike@ularawatermaster.com LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 tony@watermaster.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 armando.yanez@asm.ca.gov LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 barbarailor@gmail.com LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 chrism@iwa.com LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 claudia.goytia@asm.ca.gov LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 damian.skinner@culvercity.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 david.mcneill@nOspam.bhc.ca.gov LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 dawnfaulconer@castaicareatowncouncil.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 hmaldonedo@parks.lacounty.gov LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 jeff.r.catalano@lacity.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 landtrust@ballona.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 johnkunak@castaicareatowncouncil.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 julie.sauter@lacity.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 khaberson@tvmwd.com LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 kluoe@lacsd.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 kmcgowan@geosyntec.com LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 kendrick.okuda@lacity.org Added by you 8/29/201414:55 9/2/201411:10 kristamjohnson@sox.net LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 twatts@seyfarth.com LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 motto@geosyntec.com LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 raulleon@lacity.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 robinkirkel@yahoo.com LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 ryan.thiha@lacity.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 shah riar.eftekharzadeh@aecom.com LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 stefanie.smith@lacity.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 Vacation /Auto reply Non-existent Non-existent Non-existent Non-existent Non-existent Non-existent Non-existent Non-existent Non-existent Non-existent Non-existent Non-existent Mailbox full Non-existent Non-existent Non-existent Non-existent Vacation / Auto reply Non-existent Non-existent Vacation / Auto reply Non-existent Non-existent Non-existent Vacation / Auto reply Non-existent Non-existent Non-existent Other Non-existent Vacation / Auto reply Non-existent Vacation / Auto reply Council for Watershed Health USEPA Region 9 USACE UC -Irvine Black & Veatch Culver City Ballona Creek Renaissance stevemyrter@cityofsignalhill.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 tom.gibson@lacity.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 ayala_z@sgusd.kl2.ca.us LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 cfelixso@ucla.edu LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 contact@thecvcouncil.com LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 davidw@epamail.epa.gov LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 deborah@waterboards.ca.gov LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 development@treepeople.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 information@coyotehills.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 jkitz@mountainstrust.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 kbelzer@fionahuttonassoc.com LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 margie_steigerwald@nps.gov LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 mikeb@unitedwater.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 rdagit@rcdsmm.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 steveh@unitedwater.org LACK EWMP PEIRS Added by you 8/29/201414:55 8/29/201414:55 Iiangbing1001@hotmail.com LACK EWMP PEIRS Added by you 8/29/201415:39 8/29/201415:39 Non-existent Vacation / Auto reply Non-existent Other Non-existent Non-existent Non-existent Non-existent Non-existent Other Non-existent Non-existent Blocked Non-existent Blocked Non-existent Attachment 4 Scoping Meeting Presentation r ESA J Enhanced Watershed Management Programs LV5 HII(J. U1U5 IiVUI]Ly rIVVU VVIIIfVI UI5LIAUL tember Welcome and Introductions Los Angeles County Flood Control District (LACFCD) - Gregg BeGell, P.E., Project Manager - TJ Moon Weston Solutions, Inc. - Andrea Crumpacker Environmental Science Associates - Environmental Consultant: ESA • Tom Barnes, Project Director • David Pohl, Project Manager 2 Scoping Meeting Agenda Municipal Separate Storm Sewer System (MS4) Discharge Permit - Enhanced Watershed Management Program (EWMP) - LACFCD Role California Environmental Quality Act (CEQA) Overview and Process Issues to be analyzed in the Program Environmental Impact Report (PEIR) CEQA Schedule Receive Public Comments 3 MS4 Permit Compliance Project Purpose: MS4 Permit Compliance (R4-2012-0175) - Each Permittee is responsible for its local MS4 compliance - Permit compliance through EWMPs • 12 NOls submitted to LARWQCB • Collectively prepared by participating Permittees - Los Angeles Regional Water Quality Control Board (LARWQCB) approves EWMPs 4 Enhanced Watershed Management Program (EWMP) Identify Watershed Control Measures — Structural Best Management Practices (BMPs) — Non -Structural BMPs Reasonable Assurance Analysis Priority Ranking Implementation by each participating Permittee 5 MS4 EWMP Participating Permittees -a- SANTA CLARA RIVER WATERSH LOS RIVER KA Pacific Ocean Northern Boundary LACFCD QWatershed Boundary I Los Angeles County Boundary Area Outside Los Angeles County Jurisdictional Boundaries Ar W N 0 6 12 I —�;!t��_ Miles �F ` ESRI Terrain Imagery Sources: Esri, USGS, NOAA MS4 EWMP Participating Permittees M Upper Santa Clara River Watershed I LA County, Santa Clarita, LACFCD Beverly Hills, Culver City, Inglewood, Los Angeles, Santa Ballona Creek Monica, West Hollywood, LA County, LACFCD Beach Cities Watershed Hermosa Beach, Manhattan Beach, Redondo Beach, Torrance, Management Group LACFCD Dominguez Channel Watershed EI Segundo, Hawthorne, Inglewood, Los Angeles, Lomita, LA Management Group County, LACFCD Agoura Hills, Calabasas, Hidden Hills, Westlake Village, LA Malibu Creek Watershed County, LACFCD Marina Del Rey Culver City, Los Angeles, LA County, LACFCD North Santa Monica Bay Coastal LA County, Malibu, LACFCD Watersheds Palos Verdes Peninsula EWMP Palos Verdes Estates, Rancho Palos Verdes, Rolling Hills Agencies Estates, LA County, LACFCD Rio Hondo/San Gabriel River Water Arcadia, Azusa, Bradbury, Duarte, Monrovia, LA County, Sierra Quality Group Madre, LACFCD Santa Monica Bay Watershed Los Angeles, EI Segundo, Santa Monica, LA County, LACFCD Jurisdictions 2 & 3 Alhambra, Burbank, Calabasas, Glendale, Hidden Hills, La Canada Flintridge, Los Angeles, Montebello, Monterey Park, Upper Los Angeles River Watershed Pasadena, Rosemead, San Gabriel, San Marino, South Pasadena, Temple City, LA County, LACFCD Baldwin Park, Covina, Glendora, Industry, La Puente, LA County, Upper San Gabriel River LACFCD Upper Santa Clara River Watershed I LA County, Santa Clarita, LACFCD California Environmental Quality Act (CEQA) Y Y Y Identifies potential impacts to the environment Informs the public and decision makers about potential environmental impacts Identifies ways to avoid or reduce potential impacts Overview — Why is LACFCD leading this PEIR? LACFCD operates and maintains flood control facilities in all 12 EWMP Groups LACFCD has vested interest in increasing opportunities for stormwater capture and groundwater recharge LACFCD will be working with Permittees and other stakeholders in all 12 EWMP watersheds to identify potential projects The proposed projects may have an environmental impact Overview - Role of Permittees EWMPs will be implemented by the Permittees with jurisdiction in EWMP area The Permittees implementing the proposed projects, or "Implementing Agencies," will vary between EWMPs and individual projects 10 Proposed Project Objectives Achieve Water Quality Performance goals through EWMP implementation Regional Compliance with the MS4 Permit — Coordinated implementation of compliance strategies — Watershed -specific compliance strategies Environmentally Responsible Opportunities — Beneficial flood control, water supply, and habitat Watershed Control Measures Structural BMPs or Physical Control Measures - Infiltration - Water quality treatment - Storage Categories of Structural BMPs - Regional - Centralized - Distributed Non -Structural BMPs Infiltration and Pesrol: P!ryi K.}] Pr F -rnl-Lktmiieteeril 12 Regional EWMP Projects Retain all runoff from the 85th percentile, 24-hour storm event for tributary drainage area - Infiltration BMPs - Retention basins - Capture and Use BMPs May include use of public lands with open space areas, e.g., parks, large parking lots, or vacant space 13 meSt C. - Wil. All Sun Valley Park Drain and ,Infiltration System s_5M"WM ' T�apeMMs [onh - r Ita� 6 ` & .. _ 'a x 4 J IV d w v , _301 �Tly Q1Pi � i � I SUN VALLEY PARK 4:fm2of I t y _ PI }' Ll f F ., dc W 1 Centralized Structural BMPs Constructed structural practices intended to treat runoff from a contributing area of multiple parcels • Generally installed on large public parcels or adjacent to storm drain outfalls and receiving waters Examples: — Bio -filtration BMPs — Constructed wetlands — Treatment BMPs low -flow diversion — Creek/River restoration 17 ■ �. Sit e i •� 1 ti. :mreTraw �y Its pot r y� 4 All A, -r A'S 17",; 'p r ti. :mreTraw �y Its pot r y� 4 All A, -r A'S 17",; '. PepperdineId '. University Residential Tract - Approximate 077 Drainage Course X Project Site ;W, Marie CanyorLF-D l ,*vy -� amp -I LI *40 rJ i U U Distributed Structural BMPs Constructed BMPs that treat runoff close to the source and typically implemented at a single- or few -parcel level Green Infrastructure / Low Impact Development — Biofiltration — Infiltration BMPs — Bioretention — Bioswales / buffer strips — Green streets — Rainfall harvesting — Porous / permeable pavers — Planter boxes Flow -Through Treatment BMPs — Media / Cartridge filters — High-flow biotreatment Source Control Treatment BMPs — Catch basin inserts / screens — Hydrodynamic separators — Gross solids removal devices 22 Distributed Structural BMP Proposed Projects Typical distributed site -scale detention schematic (arrows indicate water pathways). Typical distributed bioretention and biofiltration schematic showing underdrain option (arrows indicate water pathways). Typical distributed rainfall harvest schematic (arrows indicate water pathways). 23 Before Non -Structural BMPs Prevent and/or reduce runoff and/or pollution close to the source Nonstructural BMPs part of overall EWMP implementation program — Examples: • Irrigation control • Covered trash receptacles • Replacement of brake pads & lead in wheel weights • Pet waste cleanup stations • Street sweeping • Catch basin cleaning • Downspout disconnect program .s. 25 Program -Level Assessment Program assessment for LACFCD to submit EWMPs to LARWQCB - LARWQCB Responsible Agency for Approving EWMPs Used to evaluate a plan or program that has multiple components or actions - Focuses on the Effects of Implementing EWMPs Individual projects will be reviewed as they are further developed to determine what if any further review under CEQA is necessary 26 CEQA Process for an EIR 27 Issues to be Analyzed in the PEIR • Aesthetics • Air Quality • Agriculture and Forestry Biological Resources Cultural Resources • Geology, Soils & Seismicity • Greenhouse Gas Emissions Hazards & Hazardous Materials Mandatory Findings of Significance Hydrology & Water Quality Land Use and Planning • Mineral Resources • Noise Population & Housing Public Services • Recreation • Traffic & Transportation Utilities & Energy Alternatives Cumulative Projects 28 PEIR Schedule Estimate August - September October - December January - March • 30 -Day public review of Notice of Preparation • Three scoping meetings • Draft PEIR preparation • 45 -Day public review period for PEIR • Public review meetings March Response to Comments • Final PEIR preparation April • Submission to Board of Supervisors for consideration of project approval and certification of PEIR 29 sable/Milestone • 30 -Day public review of Notice of Preparation • Three scoping meetings • Draft PEIR preparation • 45 -Day public review period for PEIR • Public review meetings March Response to Comments • Final PEIR preparation April • Submission to Board of Supervisors for consideration of project approval and certification of PEIR 29 NOP Comments Comment 5:00 PM period closes September 29, 2014 by NOP and other project information can be downloaded from www.LACoH20sheds.com Submit Comments - At scoping meeting: verbal or written comments - Or mail or email comments no later than September 29th to: Gregg BeGell, P.E. County of Los Angeles Department of Public Works 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 gbegell(c')dpw.lacounty.gov 9M Attachment 5 Scoping Meeting Sign -In Sheets r ESA J EWMP PEIR Scoping Meeting September 9, 2014 6-8PM Burton Chace Park -13650 Mindanao Way, Marina del Rey VL0p0co2 SIGN -IN SHEET r Please Sign In (kindly print) �cay�b Name Phone Address, City, Zip Code 1. E- it AddreSs Z. i5 I E-mail Address 3. E-mail address 4. E-mail address 5. E-mail address 6. E-mail address 7. E-mail address 8. E-mail address 9. E-mail address 10. E-mail address EWMP PEIR Scoping Meeting September 9, 2094 6-8PM LAC Dept. of Public Works -900 South Freemont Ave. Conf Rm. C, Alhambra C�Jijiwz q1"b"SIGN-INSHEETPlease Sign In (kindly pent) Name Phone Address, City, Zip Code 1. il'J�cc� (4s rj t®3 -Zs9s E-mail address AmoL4sa. ,' �� e 2. mace iv G.Zd 4r� E-mail address j f ticr ' ev 3. C,4fJ/�. a �W�.c.r� �{(�p (JCIiv/1N" 1 M ,/� vl/C4 iY I V LU Email address 1 G,C ce jv&;' t . Cis ✓� 4• �Aw� 0V #-1iy3 � �1l 191-I� 11 fti/IONTCutca ' E-mail address 5. Gir-k E-mail address 6. E-mail address 7. E-mail address 8. E-mail address 9, E-mail address 10. E-mail address EWMP PEIR Scoping Meeting September 15, 2014 6:30-8:30PM Monrovia Community Center, K. Dalton Rm.-119 W. Palm Ave., Monrovia FL°0pco� a SIGN -IN SHEET r c 0 Please Sign In (kindly print) Name Phone Address, City,. Zip Code 1 1A,^ A7h`�YVvyj � ( 1 \6 E-mail address 2. f r `�`1� Tel 4y L yeGr�pS 1402 E-mail address 3. E-mail address �^ 41 a. akj1 J 4 C� - `! i - � %� S . Fri+=_�474Loj` Aof, /� q .r /i/ t E-mail address <� `S {�(. tlyU ILW? l O'A. rj 10 I !!j E-mail address , l e. 26� C:.l�.wli.rza cr�% ,�,,��q. � %�Dw,� i�n� I W ' E-mail address 4yM"�r �.,�j 5•'2Loln joi 7. E-mail address 8. E-mail address 9. E-mail address 10. E-mail address Attachment 6 Scoping Meeting Public Comments r ESA J EWMP PEIR Scoping Meeting Burton Chace Park, Marina del Rey September 9, 2014 Comments and questions following the presentation by Tom Barnes, Project Director from Environmental Services, Inc. • Will this program require 12 environmental impact reports (EIRs), one for each of the 12 watershed within the LACFCD that will be participating in the development of an Enhanced Watershed Management Plan (EWMP) or just one EIR for all 12 watersheds? o Only one EIR will be required. • How does the EWMP relate to the TDML plans? Will this effort end up replacing the TDML implementation plans that have been developed for each of these 12 watersheds? o That question cannot be answered at this time. • Each watershed has a specific pollutant type and a TMDL implementation plan designed to address that pollutant. Given the variety of different problem pollutants in each of these watersheds, the EWMP should not replace the TMDL implementation plans. Are these TMDL implementation plans now on hold while this EWMP is being developed? • The reason there is no one else here tonight is that there are no specific projects being presented for us to analyze. Over the years, the same set of water quality improvement objectives are presented in every meeting but never with any specific projects. We need to know specifically what is being planned. The EIRs are just words but give us nothing specific. • Regarding the Santa Monica Bay Plan, the City of LA did not meet water quality objectives. From 2006, the City has had 8 years to comply with the consent decree but it has never reached the mandated goals. We heard that it would take the equivalent of 25 Hyperion Treatment Plants to achieve these water quality goals, and at a tremendous cost. So, how can you ask for public input without presenting us specific projects to review including the costs associated with those projects? Today, we have agencies with plans that are never implemented and taxing us without telling us what we are paying for. • You can have no plans without public involvement but there can be no meaningful public involvement without specifics. • Questions that should be addressed during these meetings: Will the Plan (or proposed project?) comply with the TMDL implementation plans and what will it really cost to implement? We have heard costs as high as $150 billion for LA County to fully meet is water quality goals and that $3 billion is being spent on the Ballona Creek treatment wetlands. People want to know what bang what they are really going to get for their buck since they have been repeatedly disappointed by past programs. • You are heading into years of litigation from people who actually would support this project, if you do not provide more specific project information. The piece meal approach to solving these water quality projects does not cut it. Over the years we have seen politically motivated plans developed for each city council district rather than comprehensive plans that can realistically achieve the objectives of the Clean Water Act. What is needed now is for you to make a list of projects a part of the Notice of Preparation (NOP) and not wait for the EIR. • What we want to know and it needs to be included in the EIR are the environmental impacts from specific projects. What we want to see is a plan that is designed to actually comply with the Clean Water Act and to see that funding is available for that plan, to see those dollars actually spent on the projects, and result in actual, tangible cleaning up of our water. • If you already have a projects lined up, where can I go to see that list of projects? o A link is available which we will send to you. • The process is faulty if the NOP does not contain a list of projects from the very start of this process. o The reason we are doing it this way is that the EWMP programs is being designed to launch the whole compliance effort. LA County Flood Control District Enhanced Watershed Management Programs PEIR Scoping Meeting September 9, 2014, 6pm Oral Public Comments Mr. Rex Frankel: • How many EIRs will be involved? • Is this a replacement for TMDL implementation plans? • Are implementation plans on hold? • There are no projects to comment on — this is why there is nobody here at the meeting • Ballona Wetlands is a concern... is that an EWMP project? • Has the City of LA made progress in implementing plans? • Has had 8 years under consent decree, but there are no specific projects • Public needs to know associated costs • How can we comment without specifics? • Ballona project is a primary concern • You are proposing taxes without specifics... therefore there will be no public involvement • What is it going to cost?? • Is Ballona going to be a water quality urban runoff dump? • Specifics should be available in the NOP EWMP PEIR Scoping Meeting Notes Monrovia Community Center September 15, 2014 Comments and questions from meeting attendees following the presentation. • Do each of the 12 individual EWMP watershed areas have their own public process? o This environmental process is being conducted by the Flood Control District for their use to clear EWMP related projects. Each watershed can use the one being developed by the Flood Control District or create their own for a specific project. • Are individual projects being identified in the EIR? o A list of projects with descriptions will be developed that that will be included in the final document. It will be a live document during the time of submittal. The analysis focuses on project types because the projects will vary. • Is the MS4 permit in response to regulation? o It is in response to the Clean Water Act for municipalities. • Will funding be identified through this process for some of the projects that may be implemented? o CEQA does not address cost unless it is related to change in the environment. • If one wishes to advocate for particular projects within an EWMP what is the process to do this. o Write/include in your comment through EWMP process or through the permittee • Will criteria vary from watershed to watershed, or will the same criteria be used for all? • Is there interaction between this project and reclamation? How does this relate to recycled water? Do you talk to each other? • Education should be part of the evaluation criteria. The value of education should be priority. LA County Flood Control District Enhanced Watershed Management Programs PER Scoping Meeting September 15, 2014, 6pm Oral Public Comments • Does each EWMP have its own public process? • Will individual projects be identified in EIR? • Is M54 permit response (?) to legal action? • Is funding attached to this process? • How do I advocate for a project? o Through EWMP team? o Or EIR team? • Are criteria the same for each watershed? • How does this relate to recycled water programs? • Is educational value of a project a high priority? It should be. Attachment 7 State Clearinghouse Distribution of NOP r ESA J pQOF PIANti.�4Y (04;X STATE OF CALIFORNIAOF Governors Office of Planning and Research State Clearinghouse and Planning unit Ken Alex Edmund G. Broom Sr. Director Governor Vr Notice of Preparation t t August 29, 2014d} y S 1 0 9 `' t To: Reviewing Agencies Re: Enhanced Watershed Management Programs (EWMP) Program EIR SCH# 2014081106 Attached for your review and comment is the Notice of Preparation (NOP) for the Enhanced Watershed Management Programs (EWMP) Program EIR draft Environmental Impact Repoli (EIR). Responsible agencies must transmit their comments on the scope and content of the NOP, focusing on specific information related to their own statutory responsibility, within 30 days of receipt of the NOP from the Lead A enc . This is a courtesy notice provided by the State Clearinghouse with a reminder for you to comment in a timely marmer. We encourage other agencies to also respond to this notice and express their concerns early in the environmental review process. Please direct your comments to: Gregg BeGell Los Angeles County Flood Control District 900 South Fremont Avenue, 11th Floor Alhambra, CA 91803 with a copy to the State Clearinghouse in the Office of Planning and Research. Please refer to the SCH number noted above in all correspondence concerning this project. If you have any questions about the enviromnental document review process, please call the State Clearinghouse at (916) 445-0613. Sincerely, y Scot orgazi Director, State Clearinghouse Attachments cc: Lead Agency 1400 TENTH STREET P.O. BOR 3044 SACRAMENTO, C_ALIFORNLA 95512-3044 TEL (916) 445-0613 FAX (916) 323-3018 www opnca.gov Document Details Report State Clearinghouse Data Base SCH# 2014081106 Project Title Enhanced Watershed Management Programs (EWMP) Program EIR Lead Agency Los Angeles County Flood Control District Type NOP Notice of Preparation Description The development of the EWMP will involve the evaluation and selection of multiple watershed control measures or best management practices (BMP) types including non-structural and distributed, centralized and regional structural BMPs. These BMPs will be implemented to meet compliance goals and strategies under the 2014 MS4 Permit. Structural BMPs involve the construction of a physical control measure to alter the hydrology and/or water quality of incoming stormwater or non-stormwater. The three major functions for structural BMPs are infiltration, water quality treatment, and storage. These are three categories of structural BMPs, defined by the runoff area treated by the BMP and the required retention volume in accordance with the Permit. Lead Agency Contact Name Gregg BeGell Agency Los Angeles County Flood Control District Phone 626 300 3298 Fax email Address 900 South Fremont Avenue, 11th Floor City Alhambra State CA Zip 91803 Project Location County Los Angeles City Los Angeles, City of Region Cross Streets Throughout Los Angeles County Lat/Long Parcel No. Various Township Range Section Base Proximity to: Highways Various Airports LAX, Burbank Railways Various Waterways Various ' Schools Various Land Use Various land uses throughout the County Project Issues AestheticNisual; Agricultural Land; Air Quality; Archaeologic -Historic; Biological Resources; Drainage/Absorption; Flood Plain/Flooding; Geologic/Seismic; Minerals; Noise; Population/Housing Balance; Public Services; Recreation/Parks; Soil Erosion/Compaction/Grading; Toxic/Hazardous; Traffic/Circulation; Water Quality; Vegetation; Water Supply; Wetland/Riparian; Wildlife; Cumulative Effects; Other Issues Reviewing Resources Agency; Coachella Valley Mountains Conservancy; Department of Parks and Recreation; Agencies Department of Water Resources; Department of Fish and Wildlife, Headquarters; Department of Fish and Wildlife, Marine Region; Native American Heritage Commission; Santa Monica Bay Restoration; Caltrans, District 7; Air Resources Board; State Water Resources Control Board, Division of Water Quality; State Water Resources Control Board, Division of Water Rights; Regional Water Quality Control Board, Region 4; San Gabriel & Lower Los Angeles Rivers & Mountains Conservancy; Santa Monica Mountains Conservancy Date Received 08/29/2014 Start of Review 08/29/2014 End of Review 09/29/2014 T r�• C _ mo O C O m 0 N U c t o L L O U U C ° v v T U T C N Y ^ m N V LL= K N Lu >Cc m k (p c v oc 0 m> m m% m ca ° o y m y U m° U M C C U c 2 m c C eF anm Nm Mau m« v m'✓, m y� m>' 3p m 3 m p m o' 3 m15 anCOd y C3 '� r U U° U c N U m Uay Um d'Uti U(Y U f1 .�> U U OCA Q=m O0 0 a0 d0 0 M O m U Qm CJo t S c L71 0 O. a li fL N¢ m 2' C 6' m CL m CL ❑ O U > O C 0 �r❑ Oi m o com m mo m m o m m� a .c ❑Uz❑wUm❑U�®U ❑ M 0 � ❑U❑v�v� ❑ -! a N� Q N d' m k� � o c c c c m m U U O o y >. 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O i C C y O y p L c W z w 2 waIPII, a 3 - y m e U a m o cE a boa a Nc a_=o tuc `N' -6o C7 0 0mc m m w om 0 ` >m m $r50 ° so'� N %.� N Quti� O u `��c m m O ONS u m 9r 3 0 3ti 3m •>ZU EWUE �iUo.>, li `—^y N""3 vUJ mcc cd o ad O od p ad > ad y :° m ad c '_° `° W N o p p r- a v R m 0 0 «. c N « E m 75 O u m 0 m y me m� h ymo m m9 •o 0..0 N o mwm wua v E'cm w o m N.9 wo= W.v m iiU LL.� 'w��a ii F -2d ii=�U 0aM O "2< mom a¢w�n DUs � N OUB OviU ca (D 2❑ ❑ ❑ ❑ O❑ ❑ ❑ 73 71 71 0 c c c N c a 0 a O a W C O U O o - o •ic c E u �. 3 v m N m 2 c LL u m u c o m 3 2 y N y m N U c 0Nc r°, ow ¢ 0m wo ymo _:oc my Om z oEa m Qo Ea_ N 6o Ms mi°..� gy=m¢ at U= c.�.p1 un >0T IEw� >'U8�C7 o' -mac �'Y �12 m y::y oE@ Om °cy LLLL yy umd ay °oi0 m.:moom `m ..°N IaIa m U y m u m0 � O w w m0� mm u". Ld o c c ry w w� LLm?� a u m m vouc2 �a o - m>iZ ®UU W UL Cl LU UUw UO U o.� Oaf 0 0 0 U ��w 006 ❑ O:Kz OU W ii❑ O �Z ❑ ® ❑ ❑ ❑ ❑ Cl ❑ OWIn❑ ❑ LL ❑ Attachment 8 Comment Period Extension Letter r ESA J 1* Dear Stakeholder and Interested Party, The Los Angeles County Flood Control District (LACFCD) has extended the public comment period for the Notice of Preparation (NOP) of a Program Environmental Impact Report (PEIR) for proposed Enhanced Watershed Management Programs (EWMP). The extended NOP comment period will end October 29, 2014. The LACFCD is soliciting feedback from interested persons and agencies as to the scope and content of the environmental information to be evaluated in the PEIR. Comments may be submitted by regular mail or email to the address provided below. Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 (626)300-3298 gbegell@dpw.lacounty.gov As Lead Agency, LACFCD has developed the NOP to notify Responsible and Trustee Agencies and interested parties that the LACFCD is preparing the PEIR for the proposed project. The Notice of Preparation (NOP) for the PEIR as well as an audio presentation describing the process can be accessed at: www.LACoH2Osheds.com. The audio presentation has been added to the web -site for those that were not able to attend the three Scoping Meetings held in September. The LACFCD, the County of Los Angeles, and 84 incorporated cities within Los Angeles County (collectively referred to as Permittees) are covered under federal clean water regulations ("permits") for the discharge of urban runoff to waters of the United States. Under the 2012 Municipal Separate Storm Sewer System (MS4) Permit for Los Angeles County, Permitees have the option of implementing an innovative approach to Permit compliance through development of EWMPs. The LACFCD, along with participating cities, has opted to exercise this option through the development of 12 EWMPs in their respective watershed groups. These EWMPs will identify structural and non-structural strategies to achieve permit compliance. The EWMPs will be submitted to the Los Angeles Regional Water Quality Control Board (LARWQCB) for approval. Implementation of the EMWPs would occur following approval by the LARWQCB. We will continue to keep you informed of the process. Attachment 9 Public Comment Letters Received r ESA J October 16, 2014 Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 (626)300-3298 gbegell@dpw.lacounty.gov Enrique Huerta At -Large Stakeholder 7345 Nada Street Downey, CA 90242 ehuerta28@gmail.com (323)573-0129 RE: Public Comments: Notice of Preparation of a Draft Program Environmental Impact Report for Enhanced Watershed Management Programs Dear Mr. BeGell: Thank you for your efforts on the Notice of Preparation (NOP) for the Draft Program Environmental Impact Report for the Enhanced Watershed Management Programs (EWMP). I am confident your work will result in an informative and precise first tier final Program Environmental Report (PEIR) that is adequate, complete, and a good faith effort at full disclosure. The purpose of my comments, per Section 15168(c)(5) of the 2014 California Environmental Quality Act (CEQA) Statute and Guidelines, is to assist in the creation of a PEIR "that deals with the effects of the program as specifically and comprehensively as possible." Additionally, I realize that by doing "a good and detailed analysis of the program, many subsequent activities could be found to be within the scope of the project described in the program EIR, and no further environmental documents would be required." I recognize and appreciate the herculean task involved for the Flood Control District and it is my sincere attempt to keep my comments relevant to the NOP. As such, I have attempted to draft my comments in a reader -friendly manner that identify the issue and propose a feasible solution(s). My comments only address the content of the NOP. COMMENTS ON THE CONTENT OF THE NOP 1. Introduction (Page No. 2) Please elaborate on the approval process. It would be informative if the role between the Los Angeles County Flood Control District (LACFCD) and the Los Angeles Regional Water Quality Control Board (LARWQCB) is further explained. The introduction does a good job explaining the steps involved in the EWMP process, but lacks clarity on the connection between the PEIR and LARWQCB. In particular, the sentence in mind states, "The LARWQCB is responsible for approval of the EWMPs in compliance with the MS4 Permit. Implementation of the EMWPs would occur following approval by the LARWQCB." If the LARWQCB approves the EWMPs then who adopts the final PEIR? How does this PEIR fit into the responsibilities and mandates of the LARWQCB? All 12 of the EWMPs specify a date when the final EWMPs will be submitted (June 2015) to the LARWQCB, but no mention is made about the PEIR. Will the Lead Agency submit a EWMP packet on behalf of all 12 EWMPS and will the PEIR be a part of that packet? In addition, the NO1 submitted to the LARWQCB by each Watershed Management Group (WMG) span two programs: the EWMPs 'and' Coordinated Integrated Monitoring Programs (CIMP). Does this PEIR also analyze the CIMP? (Page 5) The opening paragraph states that "The primary approach to each of the EWMPs, as identified in the Draft Work Plans, includes identifying community -friendly, cost- effective methods of reducing urban runoff pollution and incorporating distributed and centralized structural and nonstructural watershed control measures for a multi -pollutant, multi -benefit approach." However, a review of all 12 EWMPs indicates that there was no cost/benefit analysis completed to substantiate the "cost-effectiveness" of these methods. Please identify any additional documentation supporting this claim. (Page No. 5) Please clarify the use of the term "project." The final sentence in the first paragraph states, "The EWMPs will also evaluate multi -benefit regional projects that will retain (through infiltration or capture and reuse) the stormwater quality design volume (85th percentile storm for 24 hours) for the runoff from the contributing drainage area." Evaluating, I'm assuming site -level projects with regional benefits, at the PEIR level increases the dissonance between the goal of an EIR, as Section 21002.1(d) of the CEClA Statute states, "to consider the effects, both individual and collective, of all activities involved in a project," and the inherent collective geographic scope of the PEIR. I reviewed all 12 of the EWMPs and CIMPs. All 12 of the EWMPs do not identify projects currently in the works and no analysis is provided. The EWMPs seem to be evaluating plans and policies. Clarification of the term project would be beneficial in order to clearly understand the scope of this PEIR. In addition, Section 21003 states that, "All persons and public agencies involved in the environmental review process be responsible for carrying out the process in the most efficient, expeditious manner in order to conserve the available financial, governmental, physical, and social resources with the objective that those resources may be better applied toward the mitigation of actual significant effects on the environment." In an effort to avoid the possibility of imposing an unfunded mandate on local cities and/or non-profit groups to undertake the second tier of this PEIR, the prudent use of public funds, and to promote a second tier CEClA process that is streamlined, I feel it would be beneficial to incorporate an analysis of current projects in the "pipeline." This is critical because a review of the Greater Los Angeles County Integrated Regional Water Management (IRWM) database reveals over 190 water resources projects with regionally -significant benefits in the pipeline (Appendix A). The IRWM is a funding mechanism that encourages regional and local collaboration in the design of sustainable water resources infrastructure. To date, regional agencies, cities, non -profits and community representative groups, have collaborated and submitted project proposals of regional significance. Not all of these projects incorporate BMPs, per say (many do), and many have already been deemed categorically exempt. Additional vetting would need to take place in order to identify projects in-line with a low impact development ideal to collaborate and integrate compliance strategies that are based on a multi -pollutant approach with a focus on green infrastructure that maximize the retention and use of urban runoff as a resource for recharging aquifers and for irrigation and other uses. If this nexus to analyze the impacts of regional projects is deemed reasonably feasible, further vetting of the projects would be required to understand their CEQA status. The question is who conducts this analysis, the LACFCD or the WMGs? This is important to figure out since Section 15152(b) of the CEQA Statute and Guidelines states that, "Tiering does not excuse the lead agency from adequately analyzing reasonably foreseeable significant environmental effects of the project and does not justify deferring such analysis to a later tier EIR or negative declaration." (Page 5) The second paragraph states, "The PER will provide a program -level assessment of the overall permit compliance effort, focusing particularly on the structural watershed control measures proposed in each of the 12 EWMP areas." The project list on Appendix A identifies projects aiming to implement watershed control measures throughout Los Angeles County. Many of these projects are categorically exempt, have concluded their own environmental assessment or already constructed, however, the database (L.A. County Water Plan) where I retrieved these does not clearly indicate this information. Furthermore, none of the 12 EWMPs under consideration undertook this task to see how the proposed physical changes within their EWMP may or may not comply with the goals and objectives of their 13 respective plans and policies. In an effort to, as Section 15152© describes, "avoid deferring the potential significant impacts to the second tier and possibly preventing the adequate identification of significant effects of the planning approval at hand," it may be worthwhile to include this list in the PEIR analysis or have the WMGs revise their draft plans to incorporate this analysis. 1.1 Project Location The description of the location could be augmented by elaborating on the environmental context. That is, adding maps identifying the tributaries, rivers, channels, etc. within the 12 watersheds could increase understanding of the local watershed functional characteristics. This detailed information is contained in most of the individual EWMPs. A reference to the website location of each respective EWMP could suffice. Additionally, there is no reference to the types of soils that underlie the 12 EWMPS. The EWMPS provide a summary of these soil characteristics. A reference to the website location of each respective EWMP would be helpful. It is important to know the soil types and their respective infiltration rates in order to understand the feasibility of implementing certain structural BMPs. I realize that this may be covered in more depth under the Geology, Soils and Seismicity category, but there is no clear reference in the accompanying summary. 2. BACKGROUND 2.1 Stormwater/Water Quality (Page 7) The first paragraph states, "Discharges may adversely affect receiving surface water quality with pollutants such as bacteria, nutrients (nitrogen and phosphorus), aluminum, copper, lead, zinc, diazinon, and cyanide. Aquatic toxicity, particularly during wet weather, is also a concern. Stormwater and non-stormwater discharges of debris and trash are also a pervasive water quality problem in the Los Angeles region." It would be beneficial to add the types of pollution stemming from the natural environment (non -anthropogenic), too. What kind of pollutants exists in the soils being eroded from natural settings and vacant parcels of land? 2.2 Total Maximum Daily Loads The final sentence in this paragraph states, "LARWQCB and United States Environmental Protection Agency (USEPA) have established 33 TMDLs that identify Los Angeles County MS4 discharges as one of the pollutant sources causing or contributing to these water quality impairments." Please elaborate on the NPDES permit process. Is there a need for discretionary approval of the EWMPs or PEI by the USE PA? Is there a need for the USE PA to issue a TMDL or other permit? If so, is there a need to do a concurrent Environmental Impact Statement? 2.3 MS4 Permit (Page 8) This section states. "The intent of the EWMP is to comprehensively evaluate opportunities, within the participating Permittees' collective jurisdictional boundaries, for collaboration among Permittees and other partners on multi -benefit regional projects that, wherever feasible, retain non-stormwater runoff and also address flood control and/or water supply." Has the United States Army Corp of Engineers (USACE) been a part of these collaborative efforts? Are any of their existing infrastructure being directly or indirectly impacted by the EWMPs? Is there a need for discretionary approval of the EWMPs or PEIR by the USACE? Is there a need for the USACE to issue a permit related to the EWMPs? If so, is there a need to do a concurrent Environmental Impact Statement? 3. Enhanced Watershed Management Plans As mentioned in the first comment under the Introduction heading, please elaborate on the approval process. Specifically, how the PEIR fits into the LARWQCBs approval of the EWMPs. 4.1.1 Regional Structural BMPs The second paragraph states, "Opportunities for Regional BMPs will be identified and evaluated within and across subwatersheds, with focus on the multi -benefit potential for capture and reuse of wet -weather flows within variable drainage areas." What method and level of detail will be used to identify and evaluate BMPs? This paragraph goes on to state that, "Potential project locations may include areas with open spaces, whether they are within parks, large parking lots, or vacant spaces," indicating that a geographically site-specific analysis is appropriate under this PEIR. Collectively, there is over 190 regional projects identified in Appendix A being proposed by the various members of the WMGs. Based on the site-specific potential project locations stated above, is it feasible to include an analysis of the project list (Appendix A)? Potential Environmental Impacts This section (nor the LACoH2Osheds website) does not reference the completion of an Initial Study per Section 15063©(1). How did the Lead Agency identify the effects determined not to be significant? Is there an explanation of the reasons for determining that potentially significant effects would not be significant? Sincerely, Enrique Huerta, M.S. Appendix A Comment Letter to the LACFCD: Draft PEIR Project Name Project Proponent Project Description The project proposes to construct a 25mgd Seawater Desalination Plant in West Basin's service area for potable water use. First, a Demonstration Plant will be necessary to evaluate the water quality performance and treatment stability, assess efficient energy recovery devices, optimize operational performance utilizing full scale process equipment, and to acquire the necessary data to achieve regulatory compliance and approval. West Basin and its 1 25 mad Sea Water Desalinization West Basin Municipal partners will perform the full battery of water quality analyses Plant in West Basin Water District to ensure that the demonstration project meets all Federal and State Drinking Water Standards. With the knowledge gained by operating the Demonstration Plant, West Basin expects to move forward with the planning, design, and construction of a full scale 25,000 AFY seawater desalination and education facility. West Basin anticipates operating the Demonstration Plant for at least two years while plans are being completed and finalized for the full- scale plant. The Demonstration Facility is in design. The project consists of replacing the older water meters in Waterworks District No. 29. The District maintains approximately 7,700 water meters in Malibu and Topanga. About 40 percent of the meters are older than 15 years and 30 percent are 20 years or older. Meters lose accuracy over time, representing unaccounted water consumption in the District. Older meters typically under -measure water use. Los Angeles County Replacing old water meters with automated meter reading 2 AMR Conversion Project Waterworks District No. (AMR) meters will yield timely, reliable water consumption 29 patterns for detecting leaks and producing accurate customer bills. Higher bills with higher water use volumes will alert District customers about their water consumption habits, which is expected to encourage conservation. The current practice is to replace meters as the meters stop functioning or become unreadable. About 20% of the water meters in Malibu and Topanga have been replaced with AMR meters. The project would extend the existing recycled water line along Agoura Road to serve existing customers who use potable waterfor landscape irrigation. Pipeline forthis project is estimated at 9250 feet of 8 inch pipe and would 3 Agoura Road Gap Recycled Water Las Virgenes Municipal connect to existing recycled water pipelines on both east System Expansion Water District and west sides of the extension. This would connect the gap that exists between Reyes Adobe Road and Lewis Road and improve the system hydraulics and reliability of service to customers. The estimated maximum daily demand for the Agoura Road Extension is 73 gpm. Appendix A Comment Letter to the LACFCD: Draft PER Restore 20 acres at Ague Amarga Reserve, to provide habitat for the Federally threatened Coastal California gnatcatcher, the Federally endangered Palos Verdes blue butterfly, and the rare cactus wren. A one -mile trail in the Reserve continues to the coast. A year-round flow of water is discharged to the head of Lunada Canyon via a County of Los Angeles storm drain; the water then flows below ground Palos Verdes Peninsula through the canyon, the course of an historic blue line 4 Aqua Amarga Lunada Canyon Land Conservancy &City stream, and re-emerges at its confluence with Ague Amarga Habitat Restoration of Rancho Palos Verdes Canyon, also a blue -line stream that flows into the Santa Monica Bay. Invasive plant species provide little water infiltration and threaten to spread to the pristine lower canyon. The project will remove invasive plants, restore 18 acres of riparian and coastal sage scrub; install 2 acres of cactus scrub in highly degraded fuel modification areas; improve trails and add trail signage. Interpretive signage will educate hikers about creating wildlife -friendly fuel modification zone. Stormwater runoff would be diverted from Aliso Creek and from Limekiln Creek and stormwater runoff generated on site will be treated. In addition to providing water quality benefits, the project will result in the creation of self-sustaining riparian woodland vegetation and other re -vegetated areas, as well as providing recreational opportunities to area residents.The site has an area of approx. 11.8 acres and is City of Los Angeles currently used as a flood control facility, provides open 5 Aliso Creek - Limekiln Creek Bureau of Sanitation space, and serves as part of Vanalden Park.Wet weather Restoration Project Watershed Protection runoff and dry weather runoff from an approx. 12,091 acres Division that drains to the confluence of Aliso Creek and Limekiln Creek is going to be captured and conveyed to the project site for treatment.On-site generated flows will also be captured and treated.Proposed BMPs to treat captured water:Low flow channel diversions and pumping:Pre- screening devices, Bioswales, Vegetated detention basins, Landscaping with native upland and riparian species and Installing decomposed granite pathways. Alondra Regional Park is a multi -benefit project that serves disadvantaged communities while meeting IRWMP water management objectives. The entire site is currently an empty 18 -acre lot owned by the City of Compton. This proposal is for Phase I of the project and covers 12 acres on the southern half of the parcel. The park provides recreational opportunities while improving surface water discharges into the Dominguez Channel Watershed. The project site sits low 6 Alondra Regional Park Successor Agency, City of on the drainage area and will capture 1.5AF of stormwater. Compton The park features a swale and daylighted stream to remove nutrients and pollutants that otherwise flow to local waterways. The large biofiltration field will reduce peak flows, improve water quality and occasionally serve as a recreational field. Surface water quality improvements would help the region meet requirements under the Municipal Separate Storm Sewer System Permit. The project also includes native shrubs and trees that will increase habitat for birds, butterfly species and mammals. Appendix A Comment Letter to the LACFCD: Draft PEIR As with the original Decker Canyon Recycled Water Extension pipeline route, this alternate would primarily serve the Malibu Golf Club, the largest potable water user in the LVMWD service area. The 2007 Master Plan advocated that serving the golf course with recycled water could be an important strategy for relieving eventual stress on the Alternative Decker Canyon Las Virgenes Municipal potable system. The longer alternative route used in this Recycled Water Extension Water District project would also serve other demands along the way. In addition to the golf club, significant recycled water demands are expected to come from a new development (Triangle Ranch) and conversion of the existing Medea Valley ranchettes to recycled water use. The project is projected to deliver 459 AF/Y of recycled water, offsetting the same amount of potable demand that would occur if the extension were not built. The project will consist of a diversion, conveyance pipes, a gross solids removal device (GSRD), an irrigation storage tank, and an infiltration gallery. Dry- and wet -weather flows will be diverted from the existing storm drain up to the maximum diversion flow rate and will then enter the storage tank through the conveyance pipe and GSRD. Once the Andrews Park Subsurface storage tank reaches a depth of 1.5 feet, flows will be 8 Storage, Use and Infiltration City of Redondo Beach pumped to be used for onsite subsurface irrigation. When the storage volume of the irrigation tank reaches capacity, Project runoff will flow via an overnow pipe into the infiltration gallery, where the water will infiltrate subsurface soils. When continual flows fill the infiltration gallery and irrigation storage vault to storage capacity, diverted flows will back-up through the diversion piping and prevent additional flow diversion until capacity is freed up due to irrigation use and/or infiltration losses. The Confluence Gateway Greenway Program will restore a 1/3 mile stretch of urban land alongside the Arroyo Seco, in the Arroyo Seco Scenic Byway Corridor, into a riparian greenway and open space park with native landscaping and a bicycle/pedestrian path. Not only would the project embody a first step in enhancing river access and recreation opportunities, it would provide a key link between the 9 Arroyo Seco Confluence Gateway Arroyo Seco Foundation planned Los Angeles River greenways at the confluence and the Metro Rail station in the historic Lincoln Heights neighborhood, thus enabling light rail and bicycle access to the Arroyo Seco and the Los Angeles River. Ultimately, the Arroyo Seco greenway is envisioned to extend to South Pasadena, and this initial segment at the confluence would be an important hub in the regional river parkway and bicycle trail network. Appendix A Comment Letter to the LACFCD: Draft PEIR Naturalize north branch storm drain and restore stream through Sycamore Grove Park. Primary Objectives Addressed by the Project: By re-establishing an urban stream, this project addresses water quality, riparian habitat restoration, groundwater recharge, flood management, and public education. The Sycamore Grove Park site is approximately 800 feet long and 400 feet wide. This 8 -acre 10 Arroyo Seco North Branch Creek Arroyo Seoo Foundation site is located in northeast Los Angeles and situated west of Davliahtina the SR -110 (). This site encompasses Sycamore Grove Park and is bounded by South Avenue 49 to the northeast, the SR 110 to the east, medium density residential uses to the south, and North Figueroa Street to the west. Sycamore Grove Park is a landscaped area consisting of a large lawn, playground, and parking area. The North Branch tributary is contained within a storm drain beneath Sycamore Grove Park. For centuries the waters of Baldwin Lake have sustained human endeavor. A rich historic site, its role began in the Native America period when springs and marsh, precursors to today's lake, supported nearby habitation. In the late 19th Century, Elias Jackson Baldwin chose the Lake as the center for agriculture and land development that shaped the establishment of the east San Gabriel Valley. Today, as the centerpiece of the Los Angeles County Arboretum, the Lake 11 Baldwin Lake Los Angeles Arboretum is an educational and scenic resource serving hundreds of Foundation thousands of visitors. Looking to the future, Baldwin Lake is envisioned as a model for community-based environmental stewardship and regional approaches to water management and conservation. Ideally located at the edge of the Raymond Basin aquifer, the Lake offers great potential as the nexus for water management and ground water recharge for the Arboretum's 127 acres, as well as the surrounding urban watershed. Educational programming that interprets the history of the Lake, particul Project is to implement the valuable uses of stormwater and to improve the water quality in Ballona Creek Watershed. Ballon Creek Low Flow Treatment Facility (LFTF), also known as North Ouffall Treatment Facility (NOTF), is one of several projects proposed in Ballona Creek TMDL Implementation Plans for Bacteria, Metals, and Toxic Pollutants. The LFTF includes a 1 million gallon storage Ballona Creek Water Quality and City of Los Angeles facility and has the capacity to treat up to 150 cis, including 12 Beach Improvement & Beneficial Bureau of Sanitation screening of coarse, fine sediments, and disinfection with Use Project Watershed Protection sodium hypochlorite. NOTF was constructed in 1987 by City Division of Los Angeles. The project proposes to use the existing treatment facility and construct a low -flow diversion structure in Ballona Creek Channel to divert and treat full dry -weather flow and partial wet -weather flow. 65 percent of Ballona Creek Watershed (85 square miles) is located upstream of the Project, with average dry -weather flows ranging from 14 to 25 cfs. Treatment will include coarse screens, sedimentation, filtration, and disinfection. Appendix A Comment Letter to the LACFCD: Draft PEIR The City of Burbank proposes to expand and increase water conservation through the expansion of a comprehensive indoor/outdoor financial incentive program that will result in immediate and sustainable water savings. The proposed Rebate Program to install 1,300 HE toilets, replace 300,000 square feet of turf with native landscapes, capture and reuse rain water 3 million gallons of rain water with rain barrels, 13 Be A Water Saver Water City of Burbank Water and and increase water conservation education efforts will save Conservation Program Power an estimated 500 AF of water annually. Grant funding for the proposed project will facilitate greater water savings by providing funding for greater levels of participation sooner than would be realized under typical funding efforts. Furthermore, these benefits will be realized faster by utilizing a proven system for conservation, a truly ready to proceed project. This project has the potential to double participation levels. This project will consist of planning, design, and construction of approximately 4,625 feet of new 8 -inch PVC and Ductile Iron recycled water pipeline to extend Glendale's recycled water distribution system from the intersection of Flower St. and Grandview Ave. to Bette Davis Park. Approximately 14 Bette Davis Park Water Recycling LADWP 4,300 feet of pipeline will be installed within Glendale's city Project right of way. Through an Agreement with the City of Glendale, this project will be designed and constructed by Glendale's contractors and LADWP will reinburse Glendale for the costs. This will reduce the City's potable demand for non -potable uses. This project will offset up to 75 AFY of potable water with recycled water. This project will upgrade the sluiceway to function as a low level outlet for regulating flows under high reservoir pressure and repair various facility components for the dam. The existing sluice gate at the upstream end is to be replaced with a new heavy duty hydraulic actuated gate, the Big Dalton Sluiceway Los Angeles County Flood sluiceway is to be lined with new pipe for the entire length, 15 Rehabilitation Control District and a throttling valve is to be installed at the outlet. Storm releases through the sluiceway will reduce the rate of sediment accumulation and prevent sediment deposits at the face of the dam. Incoming sediments during storm flows could be routed through the reservoir to restore a more natural sediment transport system and maintain reservoir capacity The proposed project will modify and motorize the diversion box at Big Dalton Spreading Grounds to better control flows taken into the facility. The spreading basins will be reconfigured to increase percolation rates and storage 16 Big Dalton Spreading Grounds Los Angeles County Flood capacity. An intake will be constructed from Little Dalton Improvements Control District Diversion Channel so that additional storm flows can be diverted to the facility. A proposed outlet from Metropolitan Water District's PM -26 imported water line to the Little Dalton Diversion channel will enable imported water to be recharged at the spreading grounds. Appendix A Comment Letter to the LACFCD: Draft PER The project consists of constructing three 18 -inch diameter bypass water pipelines approximately 1,500 feet in length within the areas of active landslides along Pacific Coast Highway. This bypass will serve as a permanent replacement of an existing 30 -inch diameter water pipeline Los Angeles County that has experienced significant breaks resulting in large 17 Bio Rock Bvoass Waterworks District No. water loss. The proposed pipeline will be raised to a shallow 29 trench and protected by a reinforced concrete box covered with steel plates to provide quick access if any leakage occurs. In addition, 18 -inch Flexible Expansion Joints will also be installed at several locations with the areas of the active landslides to prevent damage or rupture of pipelines from ground movement. Los Angeles County Flood Construction of a dam within the spillway at Big Tujunga 18 Big Tuiunga Dam Spillway Dam Control District Dam to increase the maximum storage capacity of the reservoir by approximately 705 acre-feet. The 2009 Station Fire was the largest fire in Angeles National Forest recorded history and burned over 160,000 acres before containment on October 16, 2009. Approximately 87% of the watershed tributary to Big Tujunga Reservoir was affected. On average, a watershed will take five years or more to recover from a forest fire bum. During this time, increased amounts of debris production are anticipated from the denuded ground surface. Based on the 19 Bio Tuiunga Reservoir Sediment Los Angeles County Flood 2010-11 storm season surveys, the total amount of sediment Removal Control District in the Big Tujunga Reservoir is approximately 2 million cubic yards. The County of Los Angeles Department of Public Works on behalf of the Los Angeles County Flood Control District proposes a sediment removal project to permanently remove up to 4.4 mcy of sediment from Big Tujunga Reservoir. Sediment will be excavated and transported using low emission trucks or conveyor belt to Maple Canyon Sediment Placement Site adjacent to Big Tujunga Dam. The project will be completed over four years starting in the sum 20 Boulevard Pit Stormwater Capture LADWP Acquire and develop Boulevard Pit into a multi -use retention Project and recharge facility to enhance stormwater conservation. Branford Spreading Ground has very low percolation rates compared to the Tujunga Spreading Ground directly across the Tujunga Wash Channel. This project will install a pump 21 Branford Spreading Basin Los Angeles County Flood from Branford Spreading Ground to direct water into the Cleanout and Pump Control District Tujunga Spreading Ground leading to more groundwater recharge. In addition, the project will clean out the clogging layer at the bottom of basin, which will also improve percolation rates. Appendix A Comment Letter to the LACFCD: Draft PEIR In partnership with Water Replenishment District of Southern California and it's "Regional and Distributed Stormwater Capture Feasibility Study," the proposed project will design and implement stormwater Best Management Practices (BMPs) in the City of Los Angeles with the primary goals of TMDL compliance and stormwater infiltration. Three levels of BMPs will be developed; local parcel based Low Impact Broadway Neighborhood City of Los Angeles Development (LID) for 8 acres (60 residential parcels), 22 Stormwater Greenway Protect Bureau of Sanitation neighborhood scale LID for 12 acres (3 residential streets and 2 blocks of commercial streets), and a sub -regional scale facility for 30 acres of mixed land uses. The local and neighborhood BMPs will capture and infiltrate all dry -weather flow and up to the ''% inch storm. The sub regional BMP will capture up to the 2 inch storm for 30 acres. The sub regional BMP will also receive dry -weather flows from 228 acres of mixed land uses. Designs will be standardized to remote widespread implementation. Historical records show that an annual average of 625 acre- feet of water passes though Bull Creek. All flows from Bull Creek are lost to the ocean via the Los Angeles River. This 23 Bull Creek Stormwater Capture Los Angeles County Flood project proposes conserving the lost water by diverting flows Control District from the new LADWP facility using a rubber dam and conveying flows through a pipeline to Pacoima Spreading Grounds where it would be captured and recharge the local aquifier. Plan, design, and construct stormwater conveyance facilities for compliance with the Enhanced Surface Water Treatment Rule. Facilities will be designed according to standards adopted by Department of Water Resources, Division of Bull CreekLos Angeles Reservoir Safety of Dams. Improvements include widening a portion of Water Quality Improvement 24 LADWP the Bull Creek Extension Channel, realigning a section Protect downstream of the widening, construction of a new diversion structure and overnow structure, and improvements to inlet structures. The Los Angeles Reservoir spillway will be removed from service. Proposed design facilitates a future stormwater capture program. The Burbank Partnership Water Recycling Project involves the planning, design, and construction of approximately 27,000 feet of recycled water pipelines in the North Hollywood area. The three individual segments that comprise the project are the Chandler Boulevard Bike Path 25 Burbank Partnership Water LADWP segment, the Whitnall Dog Park segment, and the North Recycling Protect Hollywood Park segment. These segments will connect to Burbank's recycled water distribution system at three separate connection points and will be served by recycled water treated at the Burbank Water Reclamation Plant. This project is expected to offset up to 285 AFY of potable water with recycled water. Appendix A Comment Letter to the LACFCD: Draft PEIR The third phase of the City of Burbank's recent recycled water system expansion. As a result of previous phases, over 20 miles of recycled water pipelines have been installed resulting in the distribution of over 2,300 AF of recycled water annually; amounting to 13% of the City's water demand by the end of 2014. The City will continue expanding its recycled water distribution to offset potable Burbank Water and Power water use in this phase by constructing two new recycled 26 Recycled Water System City of Burbank Water and water pipelines known as, the LA Equestrian Center (LAEC) Expansion, Phase 3 Power and the Naomi pipelines. The LAEC is located on the borders of the cities of Burbank and Los Angeles consisting of landscape areas, stables, offices and corrals; the latter requiring dust control with water trucks. The Naomi pipeline would primarily provide recycled water to a very large commercial data center and smaller customers. Completion of these pipelines will increase recycled water distribution by an estimated 61 AFY, resulting in a direct and immediate potable water savings of 61 AF annually. The Desalter currently has the capacity to extract up to 2,000 acre-feet annually of brackish water. In 2003 the old wells at the site were decommissioned and construction began in 2005 for the first replacement well. The facility became operational in 2006 at a reduced capacity using the new well and the original RO unit. The facility has not been operating to its full capacity since it came online again in C Marvin Brewer Desalter West Basin Municipal 2007 because of water quality issues. Funding is also 27 Brackish Groundwater Facility Water District needed to correct the water quality problems in order to get Expansion the facility to its full operating capacity. The proposed 500 AFY capacity expansion will allow the facility to become operational at its full capacity of 2,000 acre-feet per year. The site is already owned by California Water Service Co. and leased by West Basin and is developed as a desalting facility. The expansion will include the installation of a new production well, and the addition of an acid pretreatment unit and a reverse osmosis treatment unit on the existing site. Installation of storm drain catch basin curb screens at all applicable locations citywide. These screens are the stainless variety approved curb by Los Angeles County. The purpose of the curb screens is to stop trash from entering the catch basins which eventually discharge into both the Los Angeles River and Malibu Creek watersheds. By implementing this project, City of Calabasas will be in compliance with the Trash TMDL both for LA River and 28 CITYWIDE STORM DRAIN CITY of CALABASAS Malibu Creek watersheds. Based on studies done, reduction CATCH BASIN CURB SCREENS in trash and debris loadings will also reduce Bacterial and sediment loading in the watershed. By implementing the project, disadvantaged communities downstream of Calabasas in Los Angeles River will benefit from cleaner water. The scope work consists of measuring all catch basin openings, drafting RFP with detailed specifications, soliciting proposals from the list of Los Angeles County's approved venders, negotiating contract, implementation/construction, monitoring and reporting. Appendix A Comment Letter to the LACFCD: Draft PEIR The project will convert a 1.55 acre vacant parcel at the confluence of the Los Angeles River and Caballero Creek into a publicly -accessible natural park with habitat restoration, paths, site furnishings, water quality improvements, waterfront -access, and educational amentities. The design utilizes an innovative mixes low-tech mechanical and biological methods to filter and infiltrate storm waters increases regional water quality. The project 29 Caballero Creek & Los Angeles Mountains Recreation and creates a multi -benefit park that provides ecosystem River Confluence Park Conservation Authority services as well as cultural services, like recreation and eco - tourism. The project concept was developed in partnership with the City and County of Los Angeles who have committed to retain ownership, maintenance and operation responsibilities while allowing the Mountains Recreation and Conservation Authority (MRCA) to oversee design and construction. Nearby Reseda High School will monitor the project and use it for hands-on learning and community service opportunities. This project will consist of design and construction of approximately 8300 feet & 6000 feet of new 4"and 8" PVC recycled water pipeline, respectively. The project also Camino San Rafael Recycled consists of installing a two booster stations. This project will 30 Glendale Water & Power extend Glendale's recycled water distribution system to Water Project provide recycled water for common area irrigation to the Camino San Rafael Homes. This project will offset up to 90 AFY of potable water with recycled water. This will reduce the City's demand on potable water. The Carson Regional Water Recycling Expansion Project includes the expansion of the existing recycled water treatment facility and the construction of several laterals. This is a new demand on the system and will require expansion of treatment process capacity and conveyance to include; lateral pipelines, pump stations, treatment units, 31 Carson Regional Water Recycling West Basin Municipal storage tanks, and waste management facilities. The BP Pro act Water District Refinery requires single -pass reverse osmosis treatment units. BP Refinery is estimating a need of 2,100 acre-feet per year (AFY). The project will be further expanded to serve customers within the City of Los Angeles' jurisdiction for the refineries in the port area. The City will need recycled water to satisfy a use of 9,300 AFY. The City is in the preliminary design stage. Appendix A Comment Letter to the LACFCD: Draft PER 10 The Project will provide a street -end interpretive area on Bull Creek at Chase Street, and install a Stormwater Greenway along Chase Street from the eastern street end on the north side right-of-way to Hayvenhurst, and on the north and south right-of-way to Gothic. Vegetated planters in the parkways will capture and infiltrate street runoff, and will provide storm City of Los Angeles water filtration, and tree shading. The Bull Creek street -end Chase Street Stormwater Bureau of Sanitation, will feature a native landscape as habitat and a recreational 32 Greenway Watershed Protection rest stop along the channel, and will provide an interpretive Division site for wildlife selected and supported by the specific native planting used in the project. A channel diversion from Bull Creek, with a pre -filter and lift station, will transfer runoff through a pipeline to a local Sod Farm where it will be used to irrigate up to 30 -commercial acres. The project will integrate water conservation goals (LADWP), Storm water objectives (BOB), Economic enhancements to city property (LAWA), & public health and recreation benefits. This project will install a chemical treatment system at the Rio Hondo Coastal Spreading Grounds to remove sediment fines from the water and improve the percolation rates. A Percolation Optimization Investigation (POI) report was done by Montgomery Watson Harza (MWH) in 2003 to evaluate the County's spreading grounds and the impact of Los Angeles County Flood suspended solids on percolation rates. The report made a 33 Chemical Study -Rio Hondo Control District number of recommendations and the recommendations will be implemented at the Rio Hondo Flood control facility. The project will install a coagulant chemical feeder and mixer at the grounds intake. This will allow the silt in the stormwater to coagulate and settle prior the cleaner water to flowing into spreading grounds. When this occurs, the spreading grounds will be able to percolate more water, thus conserving and recharging more groundwater. This project will consist of design and construction of approximately 920 feet, 1900 feet & 2100 feet of new 4", 8" and 12" PVC recycled water pipeline, respectively. The Chevy Oaks Recycled Water project also consists of installing a small booster station. 34 Glendale Water & Power This project will extend Glendale's recycled water distribution Project system to provide recycled water for irrigation to the Chevy Oaks Homes. This project will offset up to 30 AFY of potable water with recycled water. This will reduce the City's demand on potable water. At completion of a prior grant, a modest amount of money remained unused. With the acquiesence of the granting agency, the City of Carson purchased 16 rain barrels and set up a website lottery system in order to award them to residents. The response was overwhelming and with no City of Carson, advertising over 100 contestants were disappointed to not 35 City of Carson Rain Barrel Give Development Services receive a rain barrel. This proposal would lead to the Away Phase II Department, Engineering purchase of an additional 1,000 rainbarrels (depending on Services Division cost and grant amount) to restock the lottery reserves. Advertising and management of the program would be provided as part of the City of Carson grant match. More information on Fiskar Rain Barrels is available at http://www2.fiskars.com/Prod uctsNard-and-Garden/Rain- Barrel-Systems 10 Appendix A Comment Letter to the LACFCD: Draft PEIR 11 Upper District in cooperation with the City and Fire Department of Monrovia are submitting this project incorporating both dry and wet weather runoff capture, treatment and storage for the new Regional Training Center. Once collected, the fire training water and the 85th percentile of a 24 hour storm event (as required by the City's City of Monrovia Fire Department - MS4 permit) will be treated before being discharged into 36 Training Center Water Recycling Upper San Gabriel Valley storage holding tanks which will store the treated water for Municipal Water District future reuse by the training facility. The objective is to offset Proiect the use of potable water at the facility, eliminate storm water discharge and capture wet -weather storm water runoff. Finally, if the wet -weather event is larger than the 85th percentile, then provisions are being considered to treat as much of the additional wet -weather storm water runoff via a natural infiltration gallery (bioswale) before being discharged into the City's storm water system. This project will consist of refurbishment and upgrades to the outlet works, tunnels, and repair of various facility components at Cogswell Dam. The project will increase operational effectiveness for Flood control and water conservation. The project will involve: a complete overhaul Cogswell Dam Inlet/Outlet Works Los Angeles County Flood of the dam's entire inlettoutlet works; upgrade on the 37 Control District electrical control equipment; repair of downstream facilities; Rehabilitation Proiect structural repairs on the upstream facing slab; security upgrades; and other various repairs essential for maintaining and operating a flood control facility. The overall project intent is to improve Cogswell Dam for maintaining dam safety, increased efficiency and reliability of Flood control operations, and enhancement of water conservation efforts. The project will acquire 4.87 acres (APN 4455-021-040) of natural undisturbed open space within the existing 1348 - acre Cold Creek Preserve in the Santa Monica Mountains National Recreation Area. The acquisition is part of the state - funded Cold Creek Restoration Plan designed to acquire 539.06 acres to protect the wild and scenic, perennial Cold 38 Cold Creek Diamond Acquisition Mountains Restoration Creek, the habitat linkage between Topanga State Park and Trust Malibu Creek State Park, the values of Los Angeles County's Significant Ecological Area #9, and a future venue for environmental education, research, and recreation. The area includes significant oak, sycamore, and willow communities, supports a range of wildlife including mountain lion, gray fox and raptors. The pure waters once supported the federally -listed endangered southern steelhead trout. This project helps our customer agencies to develop a water conservation, budget -based rate structure for their customers. The project is beneficial to West Basin's cities Conservation Budget Based West Basin Municipal and retail water agencies because it provides a pricing 39 Water District structure that will incentivizes its customers to conserve Tiered Rate Structure water. This pricing method has been used in other parts of the State and has been successsful at reducing water usage and reqarding those who do so with lower rates on their water bill. 11 Appendix A Comment Letter to the LACFCD: Draft PEIR 12 This project would convert the 237th St. Sump (4.5 acre- feet) into a retention infiltration basin BMP for Toxics and Nutrient TMDL compliance and provide open spaces for wildlife habitat. This project would install diversion structures that would divert the first 4.5 acre-feet of stormwater from a 71 acre tributary area away from the system tributary to Conversion of 237th Street Sump Machado Lake (Wilmington Drain) to be retained and Tributary to Machado Lakes for 40 City of Torrance infiltrated in this basin. Trash screens would be installed at Nutrient and Toxics TMDL BMPs the catch basin in the watershed by a separate project. During the dry season the basin would remain an open space for wild life and retain urban run-off and nutrients form 71 acres. By diverting stormwater back into this basin, the City and County storm drain systems would have more capacity during rain events. This project would also increase groundwater recharge. This project consists of repairing corroded and deteriorated sections of aboveground pipeline and developing a Corrosion Monitoring, Control, and Maintenance Program. The Waterworks District 29 transmission water pipeline runs Los Angeles County along the Pacific Coast Highway in Malibu. The proposed 41 Creek Crossings Repairs Waterworks District No. pipeline repairs are located at eight creek crossings attached 29 to bridge structures. The project will significantly prevent future leaks and breaks in the main transmission pipeline which is the primary source of water supply for Malibu and Topanga. The development of a maintenance program is essential to maintaining water supply reliability for the region. The project would harvest stormwater and brackish groundwater for high level treatment and non -potable use around the City, replacing the use of imported potable water. The City would install a 1.3 million gallon storage tank next to the Santa Monica Pier, Deauville lot, to harvest stormwater from the Pier sub -watershed during rain events and brackish groundwater during dry periods. The project would have an optional overflow to an infiltration gallery. A 42 Deauville Distributed Water Reuse Project City of Santa Monica saline extraction well would be installed in sand next to the storage tank. The project would install pre-treatment catch basin inserts in the drainage area or a centralized hydrodynamic separator -screening device to remove trash and debris from stormwater. Modular nanofiltration (NF) and a saltwater reverse osmosis (RD) treatment systems at the site would treat these stored local water resources to high quality for various uses around the City in the existing recycled water system. All concentrated brine by-product would be sent to the sanitary sewer. The Decker Canyon recycled water pump station, pipeline, and tank would furnish recycled water primarily to Malibu Country Club Golf Course and Tract 47962 -Sycamore Canyon Estates near the pump station location and other 43 Decker Canyon Recycled Water Las Virgenes Municipal Water District nearby ranchettes. The project would comprise a high -lift pump station, —23,000 linear feet of pipeline along Westlake System Extension Blvd and Decker Canyon Rd, and a 60 -foot diameter concrete tank near the corner of Decker Canyon Rd and Mulholland Hwy. Approximately 229 AF of recycled water per year would be used by this project. 12 Appendix A Comment Letter to the LACFCD: Draft PEIR 13 The Del Rey Lagoon Water Quality Improvement Project proposes to improve water quality by reducing the source and amount of fecal indicator bacteria in the Del Rey Lagoon and surrounding waterbodies such as the Santa Monica Bay and Dockweiler Beach. Project components include stormdrain systems, vegetated swales, irrigation system retrofit, and drainage modifications. Education and outreach City of Los Angeles to the public will also be included in the project scope. The 44 Del Rev Lagoon Water Quality Bureau of Sanitation vegetated swales are designed to capture, retain, and treat Improvement Project Watershed Protection runoff from the adjacent residential, transportation, and Division landscaped area during dry weather and partially during wet weather. Existing irrigation system will be retrofitted with a smart irrigation system to reduce excessive irrigation runoff, thereby conserving water and reducing flow. Catch basins and storm drains will be installed to capture and divert excess wet -weather flow into the sewer system. Project also includes a nature viewing deck and educational displays that explain local flora -fauna. This project involves the installation of drought -tolerant demonstration gardens at a minimum of five fire stations throughout the West Basin service area. These gardens will replace turf and/or concrete areas that are directly in front of the fire stations in order to provide a maximum visibility to the public. The gardens will be utilizing drought -tolerant and/or native plants that will be designed by professional Demonstration Gardens at Los West Basin Municipal landscape designers that specialize in climate -appropriate 45 Angeles County Fire Department Water District plans and trees. The main goal is to provide water Stations conservation and runoff reduction measures and secondarily to educate the public about the measures so that they can create these spaces at their own homes. West Basin strives to reduce demands by implementing conservation and education programs throughout the communities it serves. This project aims to continue implementing outdoor water conservation/education programs to influence the public to create these spaces in their own homes. This project proposes to conserve stormwater by holding a reservoir pool behind Devil's Gate Dam and diverting the water to Eaton Wash Dam and Eaton Wash Spreading 46 Devil's Gate Dam and Reservoir Los Angeles County Flood Grounds for poststorm groundwater recharge. A pump will Water Conservation Control District be installed in the Devil's Gate Dam reservoir and water will be pumped out and conveyed through over 26,000 feet of pipeline to Eaton Wash Dam where it can be held for recharge at downstream spreading ground facilities. 13 Appendix A Comment Letter to the LACFCD: Draft PER 14 The 2009 Station Fire was the largest fire in Angeles National Forest recorded history and burned over 160,000 acres in the San Gabriel Mountains. Approximately 68% of the watershed tributary to Devil's Gate Reservoir was burned and as a result of the storms that occurred in the two wet seasons after the fire, sediment levels in the reservoir Devil's Gate Reservoir Sediment increased by more than one million cubic yards. The County 47 Los Angeles County Flood of Los Angeles Department of Public Works on behalf of the Removal and Management Project Control District Los Angeles County Flood Control District is planning a sediment removal project of up to 4 million cubic yards. A sediment removal project from behind Devil's Gate Dam is vital to the health of the Arroyo Seco Flood control system. The goal of this project is to restore Flood control capacity and establish a reservoir configuration more suitable for routine maintenance activities. The project will last approximately 5 years with construction starting in 2014. The project will consist of development of a native landscaped greenway and bikeway/pedestrian trail along the north side of the Dominguez Channel, between Vermont Av and Normandie Av. The project will include the following: access/maintenance road improvements for the new/improved bikeway; AC repair and replacement, slurry seal, American Disability Act (ADA) access ramps and 48 Dominguez Channel Greenway Los Angeles County Flood bikeway/pedestrian signage and striping. Landscaping Phase III Control District improvements include landscaping using native and drought - tolerant plants, irrigation, as -needed fencing repair/replacement. Educational/interpretive signage will also be included along the bikeway/pedestrian trail. A study is also recommended to consider additional pedestrian crosswalks with street lamp lighting for added safety. The project is currently on hold until the LACFCD completes a study to address deficiencies in its levees. This project would install Automatic Retracting Screens (ARS) in the 1800 Storm Drain Catch Basins in the City of Carson. The proponents favor ARS to collect trash at street level where the trash can be quickly and cost effectively collected weekly by the existing City Street Sweeping Contractor and eliminates the need for other more costly and difficult to maintain downstream trash control systems. This Dominguez Channel Trash City of Carson, project anticipates the continuing development of local and 49 Reduction Via ARS Installation in Development Services state waterway trash control efforts and alleviates the need Department, Engineering to develop these expensive federal, state and local the City of Carson, CA Services Division requlatory mandates. In comparison to other "downstream" trash control systems, the maintenance status of ARS is easily assessed and visible to the public, which is then able to report those locations where maintenance is warranted. Since ARS systems are located in the street sweeper path, maintenance (trash collection) occurs weekly, the trash stays dry and is less subject to the degradation that generates other pollutants (bacteria). 14 Appendix A Comment Letter to the LACFCD: Draft PEIR 15 The proposed project will increase the percolation within the spreading grounds facility in order to increase groundwater recharge. The preliminary scope includes removing between Dominguez Gap Spreading Los Angeles County Flood 5 to 10 -feet of clay sediment or installing vertical 50 Grounds West Basin Percolation Control District trenches/drains through the poorly draining strata in the Enhancement facility's west basin. Preliminary studies have been conducted including boring samples which will be used to further develop conceptual plans and estimate project benefits. The Duck Farm River Park, once a natural Floodplain, has been disconnected from the natural processes of the river for decades as a result of urbanization & flood management. The Project reintroduces natural systems through a riparian/pocket wetland/seasonal slreambed that improves both habitat and collect, filter & infiltrate stormwater flows onsite, as well as stormwater from the adjacent freeway in collaboration w/Caltrans. The project will transition irrigation 51 Duck Farm River Parkway Phase Watershed Conservation source (annually forecasted to require 19M gallons) from 1 - Water Enhancement Project Authority imported, highly processed potable water to either local groundwater or recycled water as its source of supply. The public will benefit by being reconnected to nature, the river, & from educational & interpretive programming possible at the site. This change in supply will reduce greenhouse gases & the parks carbon footprint. Outdoor classroom & interactive educational experiences with children will inspire local youth to learn more about our watershed, water conservation & sustainability The project will increase the intake and storage capacity of the Eaton Wash Spreading Grounds facility. This will improve the facility's ability to recharge storm water into the groundwater basin, thus greatly increasing the sustainable local groundwater supply that is vital for the region. Los Angeles County Flood Control District will replace the vehicle access slab with a metal grate over the spreading grounds drop intake channel and replace the current 52 Eaton Spreading Grounds Intake Los Angeles County Flood diversion flashboards with an inflatable gate within the intake Improvements Control District channel. These improvements in Eaton Wash Channel will better direct flows into Eaton Wash Spreading Grounds, thereby increasing its intake capacity. Basin 1 will be enlarged to increase the facility's storage capacity. The project will include improvements to the property along Sierra Madre Boulevard that will significantly improve the sustainability, aesthetics, and safety of the public walkway and street view. Two driveway entrances will be improved by increasing the gate set -back fu The dam outlet works rehabilitation project involves the removal of the existing outlet tower and gate house. Once these major components are removed, construction of a Eaton Wash Dam Inlet/Outlet Los Angeles County Flood gate valve, debris racks, hydraulic power system with a 53 Control District block house, control systems, modification of the outlet Works Rehabilitation Project works structure, and rehabilitation of the gate valves will commence. It will provide necessary erosion protection measures and improve water quality during low -flow releases from the dam. 15 Appendix A Comment Letter to the LACFCD: Draft PEIR 16 LADWP is planning to cover the existing Elysian Reservoir in order to meet US EPA water quality regulations. In April 2012, the Board of Water & Power Commissioners certified the Environmental Impact Report and approved the floating cover alternative. The project will install a flexible membrane floating cover over the existing water surface. Also included are supporting infrastructure (piping, valves, liner) and site Elysian Reservoir Water Quality improvements (roadway paving, fencing). The reservoir will 54 LADWP operate in the same manner, providing potable storage for Improvement Project the distribution system. Construction is anticipated to being by 2015. In conjunlion with the project, a Community Parks Fund was established by the Board of Commissioners. The fund is to be used for unspecified public purposes related to community parks. Best efforts will be made to locate enhancements primarily in the Elysian Park area, working together with the community and other City of Los Angeles agencies. The project consists of adding a new emergency water source to supply Waterworks District No. 29 through a new Los Angeles County interconnection along Encinal Canyon Road at the District 55 Encinal Emergency Connection Waterworks District No. boundary with Las Virgenes Municipal Water District 29 (LVMWD). This interconnection would bring water from Metropolitan Water District of Southern California through LVMWD to provide additional supply to the District during emergencies. Three hydrologic areas were studied for the development of satellite recycled water facilities. Foothill Municipal Water District (FMWD) is pursuing the construction of one facility near Berkshire Place in La Canada at this time. This project will treat wastewater using a membrane bioreactor and recharge the product into the groundwater basin using infiltration galleries underneath athletic fields for multi - beneficial uses. Cal Poly Pomona has partnered with FMWD Foothill Municipal Water District Foothill Municipal Water and is developing a model that will also capture stormwater 56 District for recharge using the same infiltration galleries. A Recycled Water Pro act conservation and education component has also been added. Landscaping will be done to showcase drought tolerant plants at both the MBR site and school site. Tours will be available so that students may learn about stormwater capture, groundwater, recycled water, conservation and the watershed since the Arroyo Seco and Hahamongna Park are across the street. This 0.250 MGD plant will save enough energy annually for 80 homes in So. Cal. Divert runoff from a section of the Santa Monica Freeway within the City of Santa Monica, treat and infiltrate within an area near the freeway, either a landscaped area or parking lot. The infiltration zones will be sugared, if necessary to by- pass poor permeable soils. There will be pre-treatment 57 Freeway Runoff Infiltration City of Santa Monica before infiltration to remove trash, oil/grease, sediments. It Demonstration Proiect will be a passive system, i.e. gravity -fed and low into the system. The treatment -infiltration areas will be areas either already with a storm drain in the area, or the creation of new ones to harvest the runoff. The goal will be to keep runoff out of the existing storm drains and out of the storm drain system. 16 Appendix A Comment Letter to the LACFCD: Draft PEIR 17 The Prop O funded phase I, the installation of six bio-swales and 4 dry wells. This watershed in an average rainfall year brings 300 acre feet of water to Glen Oaks Blvd. Phase I was completed in January 2014 and is currently capturing an 59 Glen Oaks Storm Water Caoture Los Angeles estimated 30 acre feet per year leaving approximately 270 Pro act Beautification Team acre feet available for storm water capture. Phase It will consist of an additional eight dry wells for an estimated $625,000, plus the cost of City Services (Design fees, permits and over site), that will capture an additional 40 to 45 acre feet annually. The Glendale Narrows Riverwalk will provide approximately one mile of multi -use recreation along the Los Angeles River. There are several invasive plant species that are prevalent adjacent to the Riverwalk in the Glendale Narrows area of the Los Angeles River. These invasive plant infestations jeopardize the improvements to water quality and degrade habitat for native aquatic, avian, reptile, 59 Glendale Narrows Habitat Council for Watershed amphibian, and invertebrate species. In collaboration with Enhancement Pro act Health the City of Glendale Community Services & Parks Department, the Council for Watershed Health (Council) proposes to develop and manage a 3-4 year restoration project to map, control, and monitor invasive arundo and invasive palm trees in the Riverwalk project area in the Glendale Narrows sections of the Los Angeles River. A native plant propagation and replanting effort is also proposed to reestablish riparian plants. The Goldsworthy Desalter (Desalter) treats water from the saline plume in the West Coast Groundwater Basin for drinking water. The brackish water is treated to meet or exceed municipal drinking water standards through the use of a reverse osmosis system. The existing Desalter produces approximately 2,000 acre-feet of potable drinking water per year. When the Desalter was originally constructed in 2002, it was designed for expansion to over 5000 acre - 60 Goldsworthy Groundwater City of Torrance feet per year of drinking water. In 2012 the Water Desalter Expansion Replenishment District of Southern Califomia had a Feasibility Study for the Expansion of Desalter prepared for and approved by the U. S. Bureau of Reclamation. The expansion would involve the installation of additional reverse osmosis treatment units, construction of two additional source water wells, transmission mains and related appurtenance. The project also diverts waste water away from Santa Monica Bay where discharges cause TMDL violations for bacteria. 17 Appendix A Comment Letter to the LACFCD: Draft PER IV The overarching goal of the GRIP Recycled Water Project is to offset the current use of imported water by providing up to 21,000 acre-feet per year (AFY) of recycled water as a reliable supply source for groundwater basin replenishment via the Montebello Forebay within a reasonable timeframe. The source for the recycled water will be the Los Angeles Groundwater Reliability Water Replenishment County Sanitation Districts' San Jose Creek Water 61 Improvement Project (GRIP) District of Southern Reclamation Plant (SJCWRP). Tertiary treated recycled California water, advanced treated recycled water (microfiltration, reverse osmosis and advanced oxidation), or a combination of the two will be conveyed from the SJCWRP via an existing pipeline or possibly a new pipeline for recharge in the Central Groundwater Basin through the Montebello Forebay Spreading Grounds or potentially a new injection well field. The purpose of the Groundwater System Imrovement Study (GSIS) is to perform an independent study to identify, characterize, and evaluate emerging water quality constituents for the San Fernando Basin (SFB). This will include a comprehensive analysis that will provide recommendations in developing short and long-term 62 Groundwater System LADWP projects, including the design and construction of Improvement Study groundwater treatment facilities, to maximize the use of the groundwater supply in the SFB. As a part of the GSIS, the LADWP will be drilling approxinmately 26 new groundwater monitoring wells, and perform short-term monitoring of existing and new wells, in order to obtain supplemental water quality data necessary for planning the groundwater treatment afcilities in the SFB. Design and construction of groundwater treatment facilities 63 Groundwater Treatment Facilities LADWP in North Hollywwod, Rinaldi-Toluca and Tujunga Wellfields in the San Fernando Basin (SFB), with a treatment capacity of 122,900 acre-feet per year. Construct 4,500 feet of 20" pipeline, pumping station and Hansen Dam Golf Course Water pipe support bridge to deliver recycled water from the 64 LADWP Tillman Plant to the Hansen Dam Golf Course and other Recyclina Project potential future users. Water will be pumped from the Hansen Tank. Hansen Dam, situated adjacent to the Tujunga Wash Channel in the San Fernando Valley, is a vital part of flood control efforts in the Los Angeles River drainage basin. The primary purpose of Hansen Dam is flood control; however the opportunity exists to increase water conservation and water supply through increased water recharge upstream of Hansen Dam Water Conservation Los Angeles County Flood the dam. The current operation of the dam allows for an 65 Control District average annual water conservation of 17,100 acre feet per Project year. The Water Conservation Project, which involves utilizing the existing Debris and Flood Control Pools for water conservation purposes by raising their respective maximum elevations to allow for additional water supply storage, would increase the dam's water conservation ability. This extra supply storage would allow for dam releases to downstream spreading grounds and other facilities to Hansen Dam Water Conservation Change management regime of Hansen Dam to focus on 66 The River Project water conservation by maintaining a water conservation pool and Supply within the reservoir during and subsequent to flood season. IV Appendix A Comment Letter to the LACFCD: Draft PEIR 19 onstruction of a 110 MG buried reservoir along with a 4 MW hydroplant at the former Headworks Spreading Grounds to 67 Headworks East Reservoir LADWP replace the storage capacity lost when Ivanhoe Reservoir is removed from service. Needed to bring the Water System into comliance with state and federal drinking water regulations by the regulatory deadline of November 2014 68 Headworks Ecosystem Restoration LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 69 Herondo Parking Lot and Beach City of Redondo Beach Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Infiltration description 70 Hoover, Toll, & Keppel School Glendale Water & Power Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Recycled Water Project description 71 Humboldt Stormwater Greenwav City of Los Angeles, Bureau ofSanitation/Watershed Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Protection Division description Improvements to Entradero Storm City of Torrance, SMBBB Please refer to the Greater Los Angeles County Integrated Drain Channel for Storm Water 72 TMDL Jurisdictional Regional Water Management OPTI database for a project Infiltration and Habitat Restoration Groups 5 & 6 description 73 Improvements to San Gabriel Azusa Light and Water Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project River Diversion and San Gabriel River Water Committee Canal and description Appurtenances 74 Indirect Reuse Replenishment Upper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Protect Johnny Carson Park Stream Please refer to the Greater Los Angeles County Integrated Restoration and Park 75 City of Burbank Regional Water Management OPTI database for a project Revitalization description Multi -jurisdictional Please refer to the Greater Los Angeles County Integrated 76 Jordan Downs Daylighting Study Agencies -LA City Housing Regional Water Management OPTI database for a project and Public Works description 77 LA River Sixth Street Bridge City of Los Angeles, Bureau of Engineering Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Greenway 78 LVM W D Woodland Hills Golf Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Course Recycled Water Pipeline Extension 79 La Puente Valley County Water Upper San Gabriel Valley Municipal Water District & La Puente Valley County Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description District Recycled Water Project 80 Landscape Irrigation Efficiency West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Program (LIEP) 81 Large Landscape Irrigation SurveyUpper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description and Retrofit Project 82 Las Virgenes Creek Bank Stabilization, Stream Restoration. City of Calabasas Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Fish Migration Enhancement and Trail Connection 83 Live Oak Dam InlettOutlet Rehabilitation Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description 19 Appendix A Comment Letter to the LACFCD: Draft PEIR 84 Live Oak Spreading Grounds Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Improvement Project description 85 Lopez Spreading Grounds Improvement Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 86 Los Angeles River Center and Mountains Recreation and Conservation Authority Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Gardens Green Conference Center 87 Los Angeles River Natural Park City of Los Angeles Bureau ofSanitation/Watershed Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Protection Division description 88 Los Angeles River Revitalization City Los Angeles, u of Engineering Bureau Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Master Plan 32 Mile Channel and Easement Greening 89 Los Angeles State Historic Park LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Water Recycling Pro act description 90 Los Angeles -Burbank Groundwater System Interconnection LADWP /Burbank Water and Power Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 91 Los Angeles -Glendale Groundwater System Interconnection LADWP /Glendale Water and Power Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 92 Lower Los Angeles River Area Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Linear Water Storage Feasibility Study 93 Malibu Civic Center Area Recyled City of Malibu Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Water Delivery Project description 94 Malibu Civic Center Linear Park City of Malibu Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Phase 3 description Malibu Drought Preparedness Please refer to the Greater Los Angeles County Integrated Proiect: Graywater Reuse and 95 City of Malibu Regional Water Management OPTI database for a project Rainwater Harvesting description 96 Malibu Equestrian Center Runoff City of Malibu Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project BMPS description Please refer tot he Greater Los Angeles County Integrated 97 Malibu Rainwater Harvesting City of Malibu Regional Water Management OPTI database for a project description 98 Malibu Road/Malibu Malibu Road/Malibu Colony City of Malibu Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project ater Management Stormdescription 99 Manhattan Strand th City of Manhattan Beach Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Subsurface InfiltratioTrenchStreet o n description 100 Manhattan Wells Improvement LADWP/Water Replenishment District Please refertothe Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 101 Marsh Park, Phase II Mountains Recreation and Conservation Authority Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 102 Medea Creek Restoration at City of Agoura Hills Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Chumash Park description 103 Miller Pit Spreading Basins Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 20 Appendix A Comment Letter to the LACFCD: Draft PER 104 Recycled Water Upper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Project Pro act 105 Milton Street Park and Green Mountains Recreation and Conservation Authority Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Street project - Ballona Creek Please refer to the Greater Los Angeles County Integrated 106 Mission Hills Green Belt The River Project Regional Water Management OPTI database for a project description Please refer to the Greater Los Angeles County Integrated 107 Mission Wells Improvement LADWP Regional Water Management OPTI database for a project description 108 North Hollywood Groundwater and Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Surface Water Benefits Study description 109 North Hollywood Street Enhancement City of Los Angeles Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 110 North Hollywood Transmission Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Corridor Easement Stormwater Cture Study ap 111 North Santa Monica Bay Firecamp 13 LID Retrofit Los Angeles County Deprtment of Public Works Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 112 North Santa Monica Bay Probation Camp Miller LID Retrofit Los Angeles County Department of Public Works Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 113 Northeast Gardena Recycled West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Water Line description 114 Northeast Gardena Storm Water Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Quality Park, Recycled Water Line, and Landscape Makeover 115 Northeast Gardena Water and Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Landscape Makeover. Community Involvement Module 116 Oak Park Green Streets Urban County of Ventura Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Retrofit description 117 Oak Park Medea Creek Restoration Mountains Restoration Trust Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 118 Ocean Friendly Garden (OFG) West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Program 119 Olive Pit Water Conservation Park Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 120 Oxford Retention Basin Multi -Use Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Enhancement Project description 121 Ozone Park Runoff Treatment and Reuse Project City of Santa Monica Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 122 Pacoima Dam Inlet/Outlet Works Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project Rehabilitation Project description Please refer to the Greater Los Angeles County Integrated 123 Pacoima Neighborhood Retrofit The River Project Regional Water Management OPTI database for a project description 21 Appendix A Comment Letter to the LACFCD: Draft PEIR 124 Pacoima Reservoir Sediment Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Removal description 125 Pacoima Spreading Grounds Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Improvements 126 Palos Verdes Peninsula Satellite West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Facilities Study description 127 Palos Verdes Recycled Water West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Lateral description 128 Pasadena Recycled Water Proiect Pasadena Water and Power Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 129 Peck Water Conservation Improvement Pro act Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 130 Puddingstone Diversion Dam Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Inlet/Outlet Works Rehabilitation description 131 Raw Wastewater Diversion to the Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project City of Los Angeles description 132 Recycled Water On -Site Retrofit West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Projects 133 Recycled Water Storage and Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Distribution System Expansion 134 Recycled Water Supply for Palos City of Palos Verdes Estates Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Verdes Golf Course description Water Replenishment Please refer to the Greater Los Angeles County Integrated 135 Recycled Water Turnouts District of Southern Regional Water Management OPTI database for a project California description 136 Regional Water Supply Reliability Puente Basin Water Agency Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Program Phase 1b 137 Residential Indoor Plumbing West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Retrofit Kits description 138 Residential SMART Timer Retrofit West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description "Plus" Program 139 Rio Hondo Coastal Basin Spreading Grounds - Sediment Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Removal from Basins Crescents Valley Water Please refer to the Greater Los Angeles County Integrated 140 Rockhaven Well District and Glendale Regional Water Management OPTI database for a project Water and Power description 141 SMURRF Distributed Water City of Santa Monica Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Reuse Proiect description 142 San Gabriel Coastal Basin Spreading Grounds Improvement Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Proiect 143 San Gabriel Dam Penstock Coatings and Valve Repair Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description 22 Appendix A Comment Letter to the LACFCD: Draft PEIR 144 San Gabriel Valley Water Recycling Project (Phase I - Rose Upper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Hills Expansion) 145 San Gabriel Valley Water Recycling Project - Membrane Upper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Bioreactor Treatment Plant 146 San Jose Creek Water Reclamation Plant East Process County Sanitation Districts of Los Angeles County Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Optimization Project Please refer to the Greater Los Angeles County Integrated 147 San Rafael Creek Restoration Arroyo Seco Foundation Regional Water Management OPTI database for a project description 148 San Ramon Canyon Stormwaler City of Rancho Palos Verdes Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Flood Reduction Project description 149 Santa Anita Dam Seismic Rehabilitation Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 150 Santa Fe Dam Water Conservation Pool Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 151 Santa Fe Spillway Basins Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 152 Sawpit Debris Dam Seismic Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Strengthening Prole ct description City of Los Angeles 153 Septic -To -Sewer Drinking Waterwell Protection Protect Bureau of Sanitation/Wastewater Engineering Services Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Division 154 Sepulveda Basin Sports Complex A1 eles, City of Los ABureau of Engineering Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Multi -Purpose Oben Space Project 155 Sepulveda Basin Sports Complex City of Los Angeles, Bureau of Engineering Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Riparian Buffer Please refer to the Greater Los Angeles County Integrated 156 Sheldon Pit LADWP Regional Water Management OPTI database for a project description 157 Shoestring Park Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 158 Silver Lake Reservoir Bypass & LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Regulator Station description 159 Six Basins and Puente Basin Puente Basin Water Agency Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Integrated Water Supply Project Los Angeles County Please refer to the Greater Los Angeles County Integrated 160 South Coast Botanic Gardens Department of Public Regional Water Management OPTI database for a project Works description 161 South EI Monte Recycled Water Upper San Gabriel Valley Municipal Water District & San Gabriel Valley Water Company Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Expansion Project Package 1 162 South EI Monte Recycled Water Upper San Gabriel Valley Municipal Water District & San Gabriel Valley Water Company Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Expansion Project 23 Appendix A Comment Letter to the LACFCD: Draft PEIR 163 South Los Angeles County Groundwater Pipline Protect Water Replenishment District of Southern California Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 164 South Park Subsurface Infiltration City of Hermosa Beach Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Gallery 165 Southeast Gardena Recycled West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Water Line description 166 Stormwater Diversion to Walnut City of Torrance Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project Avenue Sump description 167 Sun Valley Watershed Rory M. Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Shaw Wetlands Park Protect (a.k.a. Strathern Wetlands Park) 168 Taylor Yard River Park Parcel G2 City of LOS Angeles, Bureau of Engineering Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 169 Terminal Island WRP Advanced LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Water Purification Facility and Distribution System Expansion Proiect Terminal Island WRP Advanced Please refer to the Greater Los Angeles County Integrated Water Purification Facility and 170 LADWP Regional Water Management OPTI database for a project Distribution System Expansion description 171 Thousand Oaks Boulevard and Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Westlake Elementary Recycled Water System Extension 172 Topanga Connection Acquisition Mountains Restoration Trust Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 173 Transfer Station Cover Structure City of Inglewood Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description and Site Improvements 174 Triunfo Community Park and Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Evanstar Park Recycled Water Extension 175 Trunk Sewer Rehabilitation Proiects Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 176 Turfs Up Water Use Efficiency West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Program 177 Valley Generating Station Stormwater Recharge Project LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 178 Van Ness and Slauson Infiltration City of Los Angeles Bureau of Sanitation Watershed Protection Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Best Management Proiect Division description 179 VerdHills Stormwater Protect City of Los Angeles, Bureau Bureau ofugo Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Protection Division description 180 Vermont Avenue Storm Water City of Los Angeles, Bureau of Sanitation/Watershed Protection Division Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Capture and Green Street Beautification Proiect 24 Appendix A Comment Letter to the LACFCD: Draft PEIR 25 Please refer to the Greater Los Angeles County Integrated Council for Watershed 181 Vermont Median Stormwater Park Regional Water Management OPTI database for a project Health description Please refer to the Greater Los Angeles County Integrated Victoria Street CSUDH Water 182 City of Carson Regional Water Management OPTI database for a project Reuse Concept Proposal description Water Replenishment Please refer to the Greater Los Angeles County Integrated 183 WRD Eco Gardener Program District of Southern Regional Water Management OPTI database for a project California description Please refer to the Greater Los Angeles County Integrated Walnut Creek Spreading Basin Los Angeles County Flood 184 Regional Water Management OPTI database for a project Improvements Control District description Please refer to the Greater Los Angeles County Integrated Water Budget Based Rate Las Virgenes Municipal 1$5 Regional Water Management database for a project Implementation Water District description Please refer to the Greater Los Angeles County Integrated West Basin Municipal 186 Water Star Schools Pilot Program Regional Water Management OPTI database for a project Water District description Please refer to the Greater Los Angeles County Integrated San Gabriel County Water 187 Well 15 Regional Water Management OPTI database for a project District description Please refer to the Greater Los Angeles County Integrated 188 Well 7 City of Inglewood Regional Water Management OPTI database for a project description Please refer to the Greater Los Angeles County Integrated 189 Well No. 2 Rehabilitation City of Inglewood Regional Water Management OPTI database for a project description Please refer to the Greater Los Angeles County Integrated Los Angeles County Flood 190 West Coast Basin Barrier Pro act Regional Water Management OPTI database for a project Control District description Westlake Filtration Plant Please refer to the Greater Los Angeles County Integrated es Municipal Laser 191 Enhancement & Backbone Regional Water Management OPTI database for a project Water Dist District Improvements description Please refer to the Greater Los Angeles County Integrated West WeWestward Beach Road st rd B 192 City of Malibu Regional Water Management OPTI database for a project ilt Proiect Bioindescription City of Los Angeles Please refer to the Greater Los Angeles County Integrated Westwood Neighborhood Bureau of Sanitation 193 Regional Water Management OPTI database for a project Greenway Project Watershed Protection Division description Please refer to the Greater Los Angeles County Integrated Whiting St. and EI Segundo Blvd. 194 City of EI Segundo Regional Water Management OPTI database for a project Dry Weather Diversion Structure description Whitnall H WY Powerline Please refer to the Greater Los Angeles County Integrated 195 Easement Stormwater Capture LADWP Regional Water Management OPTI database for a project Proiect description 25 2195 Sherwood Road San Marino, CA 9110& 1 +1t } Ir �} October 28, 2014 Q ° Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works13E�i• 1'+=`'I `� `°'` Project Management Division II.lcrT �� 900 South Fremont, 5" Floor Alhambra, CA 91803 Dear Mr. BeGell, The purpose of this letter is to register my support for the restoration of Baldwin Lake as part of the Enhanced Watershed Management Plan (EWMP) for the Rio Hondo Watershed. The lake has experienced significant deterioration in recent decades as a consequence of surface run-off and its very future is very much at risk. Establishing the restoration of Baldwin Lake as a priority project as part of the EWMP will ensure its status as an important ecological and historic asset for generations to come. Many thanks for attention to this matter. Very truly yours, George L. Ball Paige Anderson To: Tom Barnes Subject: RE: Enhanced Watershed Management Plan From: Jane Williams(mailto:ianeann640vahoo.coml Sent: Wednesday, October 29, 2014 2:16 PM To: Begell, Gregg - Consultant; Osmena, Genevieve Subject: Enhanced Watershed Management Plan As a volunteer at the L.A. County Arboretum, I would like to voice my support for the Enhanced Watershed Management Plan (EWMP) for the Rio Hondo Watershed, in which the Arboretum resides. Every time I set foot in the Arboretum and look around me I see what can only be described as a treasure that belongs to the people of Los Angeles County. The condition of Baldwin Lake, the centerpiece around which the Arboretum exists is deplorable. It is in desperate need of restoration. Please do all that you can to see that this plan is instituted and that, through it, funding may be found to preserve Baldwin Lake. CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Kenneth D. Hill. Ph.D., P.E. 1994 Meadowbrook Rd. Altadena, CA 91001-3404 (626)797-2089 October 27, 2014 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont, 5`h Floor Alhambra, CA 91803 Subject: Baldwin Lake Restoration Los Angeles County Arboretum and Botanic Garden Dear Mr. BeGell: As president of the L.A. County Arboretum Foundation and as a concerned citizen, I encourage you to restore Baldwin Lake at the Arboretum. I am sure you are aware that the lake has environmental significance to Los Angeles County including impact on water conservation and reclamation, regional ecology, educational opportunity, and historical importance. The restoration of Baldwin Lake, including improvements to its function as an urban runoff collection basin, should be considered as a high-priority project within the Rio Hondo Enhanced Watershed Management Plan. Please note the following: Baldwin Lake, with a current capacity of just under four million gallons, if returned to its original depth, would provide over twelve million gallons of storage capacity. With modification, it could also serve as a significant infiltration basin for aquifer recharge. 2. Tule Pond to the north, a canal roughly 600ft. in length, is the point of entry for the urban watershed, feeding directly into Baldwin Lake. Its size, shape and location offer great potential for water quality enhancement through modification as a bioswale. 3. The Lake is a key educational, scenic, wildlife, and historic resource serving over 330,000 visitors per year, including over 16,000 elementary school students on field trips. The project would provide an unrivaled opportunity to educate a broad public about regional water management, home and community water conservation, and the role of the Raymond Basin and other key water resources that sustain us. 4. The Los Angeles Arboretum Foundation, the County's non-profit partner in operating the Arboretum, stands ready to help leverage public dollars to realize the site's unique educational potential. At our recent strategic planning meeting (October 25` ) the restoration of Baldwin Lake was the top priority for the foundation over the next year. In sum, Baldwin Lake offers the ideal project to both enhance watershed function and serve the public with remarkable educational, ecological, and scenic benefits. It is an exceptionally strong candidate for inclusion in the Rio Hondo Enhanced Watershed Management Plan. Sincerely, Kenneth D. Hill, Ph.D., P.E. President, L.A. County Arboretum Foundation RIM Baldwin Lake 2 messages Marsha Perez <marshaaperez@gmail.com> To: gbegell@dwp.lacounty.gov Dear Mr. BeGell, Marsha Perez <marshaaperez@gmail.coi Thu. Oct 23, 2014 at 4:45 I am a frequent visitor to our LA County Arboretum. Here I can find beauty, contentment and sollice for my busy lifestyle. Baldwin Lake is one of our families favorite visiting areas. Here we find the solitude and the different forms of wildfowl very enjoyable. Lately we find that our lake is becoming a disaster! The water is murkey, the banks are crumbling and it has a swamp like look in certain areas. On behalf of my family and many friends and visitors I implore you to take advantage of the opportunity now available to restore the health and beauty of our beloved lake. Thank you for your consideration. Sincerely. Marsha Perez Paige Anderson To: Tom Barnes Subject: RE: ADDITIONAL COMMENTS ON L.A. County Enhanced Watershed Management Program, Notice of Preparation From: Rex Frankel fmailto:rexfrankel(a)vahoo.coml Sent: Monday, September 29, 2014 1:59 PM To: Begell, Gregg - Consultant Subject: L.A. County Enhanced Watershed Management Program, comments on Notice of Preparation COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EIR FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR L.A. COUNTY September 29, 2014, 1:30 pm From Rex Frankel, director, Ballona Ecosystem Education Project, 6038 west 75th street, L.A. CA 90045 310-738-0861, email: rexfrankel(avahoo.com I understand why no one but myself attended the NOP hearing on September 9th in Marina Del Rey. You have no specific projects to analyze for environmental impacts. You are attempting to analyze the environmental impact of words, not specific actions. It is impossible to analyze the impacts of no stated physical projects, just as it is impossible to analyze those unstated projects' impacts on the environmental setting, ie., the proper baseline, because you have no specific locations for these unspecified projects. Thus all you can say is to analyze the entire county. The two most essential parts of an environmental analysis are missing here: specific projects and specific sites. You have the process all backwards here, and thus, commenting on this NOP in any specific manner is impossible. Some background: In 2002, local governments settled lawsuits and agreed to consent decrees and promised to stop violations of bacterial health codes at our beaches by 2021. This agreement gave the public agencies an extension beyond the original deadline of 2013 but only if the projects created new parkland and river corridors that could catch and clean water before it fouled the beaches. In 2006, L.A. City proposed its first big plan under this agreement, an Implementation Plan for the Santa Monica Bay Beaches watersheds. This plan was sent back for redrafting by the RWQCB as it only reached 2% of its target and thus, would not accomplish the goal in the consent decree. Also in 2006, L.A. city proposed the Integrated Resource Plan which mainly focused on building 25 Hyperion -style urban runoff treatment plants which would have cost the average homeowner ratepayer $400 a month. This plan went nowhere. In 2012, the County Supervisors tried to quietly approve a $300 million per year property tax hike to build a non-existent list of runoff cleansing and capturing projects. Howls of opposition arose and that plan went nowhere. The public wanted to know what they were paying for. Now, you are finally starting to design the cleanup plan. But how can you ask the public to weigh in on the scope of the environmental analysis of that plan, when your description of that plan contains no specifics? Your stated plan to defer the environmental analysis of specific project impacts to when each one is up for approval thus ignores the cumulative impacts and therefore is "piecemealing", by starting major momentum of a project that is composed of many necessary parts, yet deferring analysis and the controversy to a multitude of separate EIRs and CEQA documents and public hearings, all the while public input is diffused. We never get to weigh in on whether we like the complete plan because the Program EIR has no specifics to arouse concern and the real project discussion is delayed until much later in a way that requires massive efforts by the public to keep track of the success of the big plan. The people who will pay for this plan want to see the specifics before you raise our taxes to pay for it. We want expanded and unpaved river corridor parks. We do not want the plan to include converting existing wetlands and wildlife habitat into pollution dumps and sumps. We want what we were promised, not a lame compromise that puts the cleanup burden on existing public lands, parks and house front yards. We want a complete plan for us to judge whether it will accomplish its promises and goals before you produce an EIR, not the other way around. Please put me on the notification list for all actions relating to this project. Thank you CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Paige Anderson To: Tom Barnes Subject: RE: ADDITIONAL COMMENTS ON L.A. County Enhanced Watershed Management Program, Notice of Preparation From: Rex Frankel [mailto:rexfrankel(cDvahoo.coml Sent: Wednesday, October 29, 2014 5:28 PM To: Begell, Gregg - Consultant Cc: kathv.knight(a7.verizon.net Subject: ADDITIONAL COMMENTS ON L.A. County Enhanced Watershed Management Program, Notice of Reparation ADDITIONAL COMMENTS ON EWMP NOP: October 29, 2014 The problem I have with a Program EIR for a "program" that is devoid of a list of all necessary specific projects is that it short-circuits the cumulative impacts review plus it facilitates illegal piecemealing of the many TMDL compliance projects. A program EIR can be allowed when the individual and currently unknown specific sub projects have "independent utility", thus building and analyzing them separately has no impact on the effectiveness of the other sub projects, nor does it make it mandatory that these other projects also be approved. That is not the case here. The goal of the EWMP and the sub projects is "to achieve permit compliance with RWLs" (NOP page 7 paragraph 3 and page 8, paragraph 1). Thus, all projects must be approved and successfully achieve their goals or the region will not be in compliance with the 2012 MS4 permit, the Federal Clean Water Act and the NPDES permits. If only some of the projects prove feasible and buildable, the construction of the others will not result in CWA compliance. That begs the question of is this project worthwhile if piecemealed at all? Will the beach only be clean in certain locations along the shore, while others will not be as a treatment strategy proved too expensive or technologically infeasible? If the taxpayers ultimately decide this project is too expensive, but certain parts are already built, does that mean that pulling -the -plug will result in non compliance and thus a waste of the taxpayers' dollars already spent? This s How can the public know if the permits and Clean Water Act will be complied with if the approval of the individual pieces of the compliance strategy are broken up into numerous pieces each receiving their own separate CEQA review? All of this leads me to conclude that the specific projects must be reviewed and approved as part of a master plan project, with the public knowing the full cost of compliance, the full impacts of all projects and alternative policy choices. One specific alternative, distasteful as I find it, would be analysis of only building some projects and also enforcing no -swimming rules for three days after rainfall at beaches. I will repeat the conclusion of my first NOP comments: The people who will pay for this plan want to all of the see the specifics before you raise our taxes to pay for it. We want expanded and unpaved river corridor parks. We do not want the plan to include converting existing wetlands and wildlife habitat into pollution dumps and sumps. We want what we were promised, not a lame compromise that puts the cleanup burden on existing public lands, parks and house front yards. We want a complete plan for us to judge whether it will accomplish its promises and goals before you analyze and mandate it with an EIR, not the other way around. Rex Frankel From: "Begell, Gregg - Consultant" <gbegell(a)dpw.lacountv.gov> To: Rex Frankel <rexfrankel(aa)vahoo.com> Sent: Monday, September 29, 2014 2:26 PM Subject: RE: L.A. County Enhanced Watershed Management Program, comments on Notice of Preparation Rex Thank you for your comments. It will be reviewed for use in the PEIR. Yes, when people think of an EIR they are thinking of a project. This is a Program EIR, the main PEIR document contains some projects as examples but it's a program. We are presently working on the PEIR, check our website for information and details. www.LACoH2Osheds.com. We will be posting the PEIR plus public review meetings on the website. Gregg BeGell P E Project Manager Project Management Division II From: Rex Frankel fmailto:rexfrankel(avahoo.coml Sent: Monday, September 29, 2014 1:59 PM To: Begell, Gregg - Consultant Subject: L.A. County Enhanced Watershed Management Program, comments on Notice of Preparation COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EIR FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR L.A. COUNTY September 29, 2014,1:30 pm From Rex Frankel, director, Ballona Ecosystem Education Project, 6038 west 75" street, L.A. CA 90045 310-738-0861, email: rexfrankel(avahoo.com I understand why no one but myself attended the NOP hearing on September 91" in Marina Del Rey. You have no specific projects to analyze for environmental impacts. You are attempting to analyze the environmental impact of words, not specific actions. It is impossible to analyze the impacts of no stated physical projects, just as it is impossible to analyze those unstated projects' impacts on the environmental setting, ie., the proper baseline, because you have no specific locations for these unspecified projects. Thus all you can say is to analyze the entire county. The two most essential parts of an environmental analysis are missing here: specific projects and specific sites. You have the process all backwards here, and thus, commenting on this NOP in any specific manner is impossible. Some background: In 2002, local governments settled lawsuits and agreed to consent decrees and promised to stop violations of bacterial health codes at our beaches by 2021. This agreement gave the public agencies an extension beyond the original deadline of 2013 but only if the projects created new parkland and river corridors that could catch and clean water before it fouled the beaches. In 2006, L.A. City proposed its first big plan under this agreement, an Implementation Plan for the Santa Monica Bay Beaches watersheds. This plan was sent back for redrafting by the RWQCB as it only reached 2% of its target and thus, would not accomplish the goal in the consent decree. Also in 2006, L.A. city proposed the Integrated Resource Plan which mainly focused on building 25 Hyperion -style urban runoff treatment plants which would have cost the average homeowner ratepayer $400 a month. This plan went nowhere. In 2012, the County Supervisors tried to quietly approve a $300 million per year property tax hike to build a non-existent list of runoff cleansing and capturing projects. Howls of opposition arose and that plan went nowhere. The public wanted to know what they were paying for. Now, you are finally starting to design the cleanup plan. But how can you ask the public to weigh in on the scope of the environmental analysis of that plan, when your description of that plan contains no specifics? Your stated plan to defer the environmental analysis of specific project impacts to when each one is up for approval thus ignores the cumulative impacts and therefore is "piecemealing", by starting major momentum of a project that is composed of many necessary parts, yet deferring analysis and the controversy to a multitude of separate EIRs and CEQA documents and public hearings, all the while public input is diffused. We never get to weigh in on whether we like the complete plan because the Program EIR has no specifics to arouse concern and the real project discussion is delayed until much later in a way that requires massive efforts by the public to keep track of the success of the big plan. The people who will pay for this plan want to see the specifics before you raise our taxes to pay for it. We want expanded and unpaved river corridor parks. We do not want the plan to include converting existing wetlands and wildlife habitat into pollution dumps and sumps. We want what we were promised, not a lame compromise that puts the cleanup burden on existing public lands, parks and house front yards. We want a complete plan for us to judge whether it will accomplish its promises and goals before you produce an EIR, not the other way around. Please put me on the notification list for all actions relating to this project. Thank you CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Draft Enhanced Watershed Management Program - Scoping Comments/Requests TRANSMITTAL DATE: October 29, 2014 TO: Gregg BeGell, P.E. County of Los Angeles, Department of Public Works/LACo Flood Control District 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 gbegell@dpw.lacounty.gov CC: Gloria Molina, LACo Supervisor Micheal Antonovich, LACo Supervisor Sierra Club, Angeles Chapter, Water Committee CCFAC Executive Director FROM: Dr. Tom Williams, Sierra Club, Angeles Chapter, Water Committee Citizens Coalition For A Community 4117 Barrett Road, Los Angeles, CA 90032-1712 ctwilliams20l2@yahoo.com, 323-528-9682 SUBJECT: County of Los Angles, Enhanced Watershed Management Plan Scoping for Programmatic EIR RE: COMMENTS for Enhanced Watershed Management Plan PEIR CS-CH#2014081106 Based on NOP and other project information downloaded from www.LACoH2Osheds.com. Thank you for the opportunities to comment on the Notice of Preparation/Initial Study (NOP/IS) and other Scoping documents related to the proposed LA County Enhanced Watershed Management Plan (EWMP). Also thank you for the extension of the deadline for such comments, I believe it was very helpful for our commenters. I could have continued for many more pages but I have been exhausted by the lack of real effort on the part of the preparers to make the Enhanced Watershed Program project meaningful, adequate, and complete and initially assess its secondary and tertiary impacts for knowledgeable public reviewers. Unfortunately the current NOP/IS and supporting documents appears to be an initial version of the vague program that has been developed by others, rather than a project or even program level DEIR preparation and is in need of major tecchnical additions, editing, technical, and other revisions. The Scoping documents are inadequate and incomplete for the purposes of Scoping, and Scoping documents must updated, revised, and reissued. 11 you need further clarifications and many more comments, I am available for discussions or correspondence with your staff. Dr. TW: Background: 40+ years with Worldwide/California water resources, management plans, water supplies, water distribution and transmission systems, and remote water resources development, with preparation, review, and commenting for 300+ EIRs/EISs/EAs (1972 to Date) and with 30+ years in Parsons and URS Corporations, 12+ years with Dubai Govt./Dubai World, and 6+years with Sierra Club Angeles Chapter (Water, Transportation, and Oil and Gas Comtes) and Citizens Coalition for a Safe Community. Thank you for the opportunity to review and comment. Our comments form two parts: general and specific comments, as shown below for the Section and the two segments. I have tried to provide citations in comment format with Doc./page/paragraph. Where appropriate, text has been inserted from documents and emphasis added usually as bolded/underlines. Comments/Requests are added in bolded/italics. Dr. Tom Williams 323-528-9682 Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests 1. GENERAL COMMENTS 1-1 Scoping and Project/Program Purposes and Needs The Program description for any DE/R or PDE/R must include the basis of the project: Purposes, Needs Goals, Objectives, Absence of clearly defined purposes and need, goals and objectives, and priorities renders both the Program and Projects virtually non -reviewable and thereby inadequate and incomplete for public review and comment. Without purposes and needs/goals and objectives, the public and reviewers cannot be expected to provide reasonable alternatives. NOP/IS p.1/par.2 The purpose of the MS4 Permit is to ensure Permittees are not causing or contributing to exceedances of water quality objectives or impairments of beneficial uses in the receiving waters of the Los Angeles region. 7/3 2.2 States are required not only to identify these "water quality limited segments" but also to prioritize such waters for the purpose of developing Total Maximum Daily Loads (TMDLs). 9/5 4. 1.1 Capture and Use BMPs collect and use stormwater where applicable for purposes such as irrigation. 1/3 The overarching goal of BMPs in the EWMP is to reduce the impact of stormwater and non- stormwater on receiving water 2/1 quality and address the water quality priorities as defined by the MS4 Permit. 2/1 The development of each EWMP will involve the evaluation and selection of multiple BMP types, including nonstructural (institutional) and distributed, centralized, and regional structural watershed control measures, that will be implemented to meet compliance goals and strategies under the 2012 MS4 Permit. 8/7 The overarching goal of BMPs in the EWMPs is to reduce the impact of stormwater and non- stormwater on receiving water quality and to address water conservation and the water quality priorities. 11/3 The MS4 permit allows Permittees to customize MCMs to address high-priority water quality goals within their watersheds. 13/2 The PEIR will examine the project's effects on global climate change and evaluate consistency of the project with the State's GHG emissions reduction goals. Scoping Meeting - Pic 4 Project Purpose: MS4 Permit Compliance (R4-2012-0175) — Each Permittee is responsible for its local MS4 compliance — Permit compliance through EWMPs 12 NOls submitted to LARWQCB Collectively prepared by participating Permittees — Los Angeles Regional Water Quality Control Board (LARWQCB) approves EWMPs 1-2 PEIR Contents 1-2 Total lack of reference to assignment of significance and related mitigation. NOP/IS lacks clear definition and presentation as to potential effects, scopes, and schedules of the program and related projects and their implementation, construction, and operations. As a water resources project, the physical changes represent a small portion of the overall potential effect of the program and projects, and the NOP does not reflect the systemic nature of water resources effects on the environment. The NOP and the PDE/R andd PjDE1Rs must clearly provide a Scope for each basin, schedules, and related environmental sectors, a Schedule for "implementation", construction, and "operations" (?=forever). The PEIR will - "result from implementation of the projects and management actions identified in each EWMP "result from the construction and operation of EWMP projects, "focus on potential effects. "assess the physical changes... including direct, indirect, and cumulative impacts. "identify mitigation measures to minimize potentially significant impacts of each EWMP. "anticipated to evaluate... following preliminary listing of environmental issues. Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests 1-3. Environmental Resources, Setting, and Effects - Employment, Costs, Revenues, and Socieconomics Employment, Costs, Revenues, and Socioeconomics Although mentions are made regarding economic and employment effects related to the Program and its projects, no costs -benefits, financials/funding sources, or other revenues assessments are included in the NOP. Similarly, socioeconomics for major infrastructure programs and projects are closely related to "Environmental Justice" of those receiving benefits and those experiencing adverse effects directly through water -related operations and indirectly through direct/indirect payments for such effects and prospective benefits for those with much largely parcels and incomes. 5/1 The primary approach to each of the EWMPs, as identified in the Draft Work Plans, includes identifying community -friendly, cost-effective methods of reducing urban runoff pollution and incorporating distributed and centralized structural and nonstructural watershed control measures for a multi -pollutant, multi -benefit approach. 8/3 The EWMPs include multi -benefit stormwater management projects that may also provide environmental, aesthetic, recreational, water supply, and/or other community enhancements cost- effective manner. 11/1 Most institutional BMPs are implemented to meet Minimum Control Measure (MCM) requirements in the MS4 permit; MCMs are considered a subset of institutional BMPs. MCMs do not involve construction of facilities that physically remove pollutants, but may involve costs associated with the procurement and installation of items such as signage or spill response kits. 12.3 Air Quality Construction and operation of EW MP projects could cause air emissions... vehicle trips associated with any increases in employment.... 14/3 Population... The PEIR will, however, identify current population and employment projections... 1-4 Controversies Regarding Program/Projects --- Stormwater Fees Since the LACo Board of Supervisors have experienced significant controversy regarding the imposition of parcel fees for stormwater revenue and funding and has further created controversies regarding reassignment of parcel -area fees to parcel only fees, a thorough review of the economic, employment, and environmental justice issues must be addressed and defined for the NOP/IS, As currently understood but avoided in Water agency and County presentations, an increase (e.g., x2+) in LA Co stormwater fees would be applied on a parcel basis (no matter the size of parcel) as being proposed under the 2014 Measure P initiative which has no relationship to stormwater runoff and effects, compared to the current Recreation and Parks 1990s initiative which are based on parcel area (sqft) fees. For stormwater generation, area is directly related stormwater generation (e.g., 5000sgft may generate less runoff than 50,OOOsgft lots). Therefore the NOP has not discussed the socioeconomic effects and related Environmental Justice issues related to the proposed program and the related controversy. A thorough assessment of all related revenue%osts issues must be presented in the PDEIR, including sources of revenues, revenue streams for life -of -project costs (especially for operations, maintenance, and replacements), basis for revenues (by parcel or by parcel -area), and Environmental Justice (which is not mentioned any where in the NOP/IS or presentation). 1-5 Mitigation Measures Inconsistency uses and lack of definitions for most if not all related terms. activities of "develop", identify", "proposed", or "evaluate". to reduce potential, reduce the level, reduce potential adverse effect, any significant effects, to avoid, are reduced or avoided, recommend Vague generalities are presented and are so inconsistently applied within the same or related paragraphs as to render the entire presentation as useless. The PDEIR must clearly present in matrices with links to discussions and appendices the project and program effects (quantifiedd/ranked), levels of significance for each sector/parameter, criteria levels for significances, proposed mitigations/compensations for significant effects, and a quantitative ranking of the effects levels following mitigation/compensation. Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests Lack of Mitigation 1-6 No measures are mentioned for many sectors but no basis could be established for such omissions, and comparable effects could be expected within these sectors similar to those that had need for measures mentioned. 12/2 Aesthetics No mitigation mentioned. 12/4 Biology... No mitigation mentioned. 13/2 Greenhouse Gases No mitigation mentioned. 13/6 Land Use... No mitigation mentioned. 14/4 Public Services... No mitigation mentioned. 15/1 The PEIR will evaluate potential energy consumption associated with implementation of structural and nonstructural BMPs. No mitigation mentioned for Energy 1-7 Mitigation, protection, and other measures and strategies are mentioned along with textual review of environmental sector but without any clear and concise statement of what they are, when they would be used, and how they could affect impacts, effects, and conditions. Mitigation measures in the Scoping NOP/IS are inconsistently mentioned as shown below. Mitigation or compensation is required by CEQA for significant impacts. Although mitigation is mentioned in the NOP/IS, mitigation and compensation are not mentioned in the Scoping Presentation slides; in reverse of "Alternatives", not mentioned in NOP/IS but present once in the Presentation. Various terms - without definitions and consistent uses. Protection measures mitigation strategies significant effects significant impacts potentially necessary significant impacts mitigate secondary effects of growth As lead agency for the program LACo must clearly state the sole responsibility for thorough and consistent implementation in all projects of CEQA compliance and consistency of impact mitigation and compensation (including Environmental Justice and Socioeconomics). The recirculated NOP/IS and PDEIR must provide a thorough presentation of: Definitions of all related terms, Process and quantified analyses for establishing the level of effects, mitigation, and remaining adverse effects and potential subjects of compensation, Consistency of mitigations amongst all watersheds, All current mitigation and compensation measures planned or anticipated by the Program and Project proponents, and Explanation of absence of mitigation or compensation. Examples 12/3 Air Quality ... The PEIR ... will develop mitigation measures if necessary to reduce potential impacts. 12/5 Cultural Resources Mitigation measures will be identified if necessary to reduce the level of impact where possible. 13/1 Geology... The PEIR will identify mitigation measures if necessary to reduce potential adverse effects to proposed facilities. 13/3 Hazards... Mitigation measures will be proposed if necessary to reduce any significant effects of the project ... enountered during construction would be handled in accordance with applicable regulations. 13/4 Hydrology... The PEIR will identify stormwater quality protection measures required during construction and operation of proposed facilities. The PEIR also will evaluate potential impacts to flood control capacity and develop mitigation strategies if necessary to avoid significant impacts. 13/5 The PEIR will evaluate potential effects of increased storm water recharge and will identify mitigation measures if necessary to ensure that potentially necessary significant impacts are reduced or avoided. 14/2 Noise... The PEIR will recommend mitigation strategies to ensure that proposed EWMP projects implemented by local agencies comply with local noise policies and ordinances. 14/3 Population... The PEIR will... identify local planning jurisdictions with the authority to approve growth and mitigate secondary effects of growth. Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests 14/5 Traffic... The PEIR will 14/6 Utilities... The PEIR will 1-8 Alternatives Although the project proponent has chosen to prepare an Environmental Impact Report, no mention is made regarding alternatives in the Initial Study/NOP. Only one reference to alternatives in all available related documents occurs in Slide 28, "Issues to be Analyzed" in the PEIR Scoping Presentation. As the preparer included one reference to Alternatives, complete exclusion of such from the IS/NOP represents an arbitrary and incomplete presentation of CEQA documents. Without a clear concise statement of purposes and needs (goals and objectives, etc.), reasonable alternatives cannot be developed through the public participation and have not been developed by the watershed stakeholders. LA Co must revise and recirculate the NOP. LACo must include a thorough description of Purposes and Needs for the project, quantification of such P&Ns, detailed quantified analyses as to how the Program achieves such P&Ns, basis for development of other alternative programs and projects within each alternative, and an assessment as to the best available alternative. Some prospective alternatives include: Single parcel fee assessment for 20 -plus year full Administration, O&M and replacements; Parcel -Area fee assessment for 20 -plus year full Administration, O&M and replacements; Hybrid Parcel-Area/Runoff fee assessment for 20 -plus year full Administration, O&M and replacements; Zero -Parcel Discharge Assessment and fee adjustment for 20 -plus year full Administration, O&M and replacements; Large -Parcel and Large Discharge Assessment and fee increments for 20 -plus year full Administration, O&M and replacements; Full capture and recharge of flows of >100cfs from all waterways; 1-9 Mitigation Monitoring and Report Plan The Draft Programmatic Environmental Impact Reports must include draft plans for the implementation, monitoring, and enforcements of the Mitigation Monitoring, and Reporting Plan for the Program. Also the PDE/R and draft Programmatic MMR Plan must provide the descriptions and process for funding, staffing, means, monitoring, enforcement, and reporting for the public for the monitoring of all Project - Level activities and compliance which must be subject to noticing/subscriptions, public reviews, and comment as part of the project-DEIR processes and not wait until the "Final E/R" is circulated for projects. 1-10 Scoping Report Because of the poor development of the NOP/IS and lack of coordination between the LACo efforts and those projected for the individual Project DE/Rs and dispersed responsibilities for compliance and responsibilities, following the October 29th deadline for these comments, we request that LACo recirculate the entire NOP/IS, and if not done issue a Scoping Report ass to the LACo responses to comments and the table of contents for the PDE/R in order to establish the level of incorporation provided for the Scoping comments herein. 1-11 As indicated elsewhere many terms have been used and will be used inconsistently in the NOP/IS and Scoping Presentation and has created confusion and such must be avoided in the PDE/R. The PDE/R must contain a single glossary and set of definitions for all terms for the PDE/R, and preparers and editors must assure full and specific compliance and consistency for all usage. Such a glossary may be included as an appendix with proper references throughout the PDE/R. 1-12 Program Compliance and Monitoring The LACo, Department of Public Works, Flood Control District is assumed to be in charge of the EWMP Program and has 12 groups responsible for specific areas and is related to the Los Angeles Regional Water Quality Control Board through the MS4 permit and sub -permits for water quality and flows within the Program regional and Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests area watersheds. No formal agreement has been presented as part of the NOP/1S and discussion seems to differ between the NOP/IS and the Scoping Presentation. As the LACFCD is scoping the PDEIR, reviewers must assume that only the LACo shall answer to the LARWQCB for compliance and monitoring for the next 20 years and that LACo shall have the powers, staffing, expertise, and funding to assure compliance of 12 different agencies/sub- permittees. The Program description of the PDEIR must clearly and concisely present the administrative and operational arrangement and oversight assurance mechanisms to achieve implementation of all aspects of the MS4 permit and sub -permits and any and all CEQA and MS4 permit terms, conditions, mitigations, and compensations which may be related the Program and its projects. All contractual, regulatory, and judicial records must be provided as appendices and referenced within the text. 1-13 During a 20+ year Program, Implementation and Enforcement of all elements for 12+ different plans represent a major quality control/assurance and management and must be provided with adequate enforcement capabilities and support. The LACo, Department of Public Works, Flood Control District is assumed to be in charge of the EWMP Program and has 12 groups responsible for implementation, completion, and enforcement activities related to but in addition to those of the Los Angeles Regional Water Quality Control Board through the MS4 permit and sub -permits for water quality and flows within the Program regional and area watersheds. No formal management and enforcement agreement has been presented as part of the NOP/IS and the Scoping Presentation. As the LACFCD is scoping the PDEIR, reviewers must assume that only the LACo shall answer to the LARWQCB for implementation and enforcements for the next 20 years and that LACo shall have the powers, staffing, expertise, and funding to assure implementation and enforcement with 12 different agencies/sub-permittees. Fundamentally, will LACFCD or LARWQCB assess penalties against the sub -permittees for lack of timely implementation, achievement, and penalties. The Program description of the PDEIR must clearly and concisely present the administrative and operational arrangement and quality-controls/assurance processes to achieve initiation and completion of all aspects of the MS4 permit and sub -permits and assignment of penalties, both financial and organizational for any and all CEQA and MS4 permits which may be related the Program and its projects. The LACFCD must also have the specific powers to assume direct authority over any projects under its responsibilities to the LARWQCB, and such must be documented within the PDEIR and PFEIR as appendices and referenced within the text Environmental Sectors 2-1 No mention is made of "wetlands" which are often not included under either riparian (trees and bushes with dry land beneath) or aquatic habitats (open and standing water). Although this is one of the few specific habitats with federal and special protections, it is not mentioned which indicates the lack of background on the preparers part or a specific avoidance of controversial issues. The current NOP/IS lack competence, adequacy, and completeness for the public and stakeholder to review and comment upon the scope and specificity requireed for the PDEIR and subsequent PjDE1Rs. Revise and recirculate the entire NOP/IS and related documents. The recirculation NOP/IS and the PDEIR must contain a general map of the Program and area maps for each of the projects with the following: all existing delineated riparian, wetlands, and aquatic habitats; related existing upstream and adjacent infiltration, recharge, and liquefaction areas; potential groundwater movement patterns for 1500ft upstream and downstream of wetlands and riparian habitats; and current surface water flows for 1500ft upstream and downstream of wetlands and riparian habitats. 12/4 Biological Resources Implementation of the EWMP projects could occur within existing sensitive habitats... result in changes to wildlife habitat, disruption of natural movement corridors, fragmentation or isolation of wildlife habitats, and disturbance of sensitive species during construction or operation. -could alter riparian and aquatic habitats. The PEIR will evaluate the Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests potential for such facilities to impact biological resources and will also discuss local ordinances and state and federal regulations governing biological resources. 2-2 Geology and Groundwater Slight mention is made of groundwater, infiltration, recharge, and related liquefaction although much of the stormwater reduction must depend upon groundwater storage of captured runoff. The General Plan has not specific policies regarding changing the entire groundwater regime by massive expansion of septic tank/leach field system in another LACo project (i.e., Hauled Water Initiative) and this Programs LID and related recharge systems. No information has been provided as to where recharge/infiltration areas are in relation to liquefaction zones and their drier extensions of alluvium and other permeable soils and bedrock. The recirculation NOP/IS and the PDE/R must contain a general map of the Program and area maps for each of the projects with the following: All geologically potential recharge/infiltration areas, existing recharging project, and proposed recharging areas and of all areas with more than 10 septic tanks per any 100 acres; Currently delineated liquefaction areas and geologically similar surface materials which are not now considered as liquefiable due to lack of high groundwater tables; Known groundwater levels and elevations of stream beds downslope of the groundwater tables; and Anticipated local and project recharging rates. 12/6 5. Geology, Soils, and Seismicity Southern Los Angeles County is a seismically active region. The proposed EWMP BMPs would require construction of structural BMPs that could be subject to potential seismic and geologic hazards, including 13/1 ground shaking, liquefaction, soil stability conditions, soil erosion rates, expansive soils, and landslides. Policies provided in the County's General Plan and applicable standard County requirements will be evaluated as to their effect of mitigating or avoiding any potentially significant effects.... 13/4 Hydrology and Water Quality Implementation of the proposed EWMP BMPs may change local drainage patterns at construction sites .... which could affect the hydrology, hydraulics, and/or water quality of streams, rivers, and other receiving waters ... The PEIR also will evaluate potential impacts to flood control capacity and develop mitigation strategies if necessary to avoid significant impacts. 13/5 Implementation of the proposed EWMP BMPs would likely result in increased infiltration and recharge in various locations throughout the EWMP watersheds. Such activities could affect local groundwater levels and water quality. The PEIR will evaluate potential effects of increased storm water recharge and will identify mitigation measures if necessary to ensure that potentially necessary significant impacts are reduced or avoided. 2-3 Hazards and Groundwater Recharge No mention is made regarding the influence of groundwater movements upon hazards and hazardous materials in the soil/alluvium/bedrock context. Groundwater plumes have cause major expansions of underground contamination from storage tanks and contaminated soil. Contaminated groundwater in the northeastern and western San Fernando Valley and elsewhere are known to be migrating based on the groundwater flows and basin pumping for water supplies. Current LACo policies do not reflect the responsibilities and liabilities of LACo approved watershed plans causing the changes of hazardous materials migration induced by groundwater flows fed by LACo and agency approved recharge/infiltration projects. No information has been provided as to where recharge/infiltration areas, groundwater flows, and known or expected contaminated groundwater and soils, and potential routes for plume migration through extensions of alluvium and other permeable soils and bedrock. The recirculation NOP/IS and the PDEIR must contain a general map of the Program and projects' area maps with the following: Known subsurface contaminated soils and groundwater and active remediation sites; Known pump/treaUuse or pump/treat/recharge projects; Current and expected recharge/infiltration areas; and Known/Expected groundwater migration pathways. 13/3 Hazards and Hazardous Materials Excavation during construction of proposed EWMP BMPs could uncover contaminated soils or hazardous substances that pose a substantial hazard Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests to human health or the environment... The policies provided in the County's General Plan and any standard County requirements will be evaluated as to their effect of mitigating or avoiding any potentially significant effects. 2-4 Socioeconomics (including Total and Disposal incomes, Employment, Existing Infrastructure Costs, and Property and Other Revenues) No information has been provided as to any socioeconomic setting, effects, and mitigation for the program or the projects. The recirculation NOP/IS and the PDEIR must contain an overall socioeconomic review of the Program area and separate project area for each of the projects with the following: Educational, employment, age/gender, and other socioeconomic parameters to characterize the areas for the Program and its projects; Incomes, Current Taxes and Fees, and other Ability -To -Pay parameters to characterize the areas for the Program and its projects; Existing Special Assessment Districts and Other Urban Costs for Local Residents and Property Owners for the Program's and its projects' areas; and State and conditions of existing infrastructure and potential for major future projects in the same Program's and its projects' areas. 2-5 "Environmental Justice" No information has been provided as to any information regarding the setting, effects, and mitigation for the program or the projects related to issues of Environmental Justice. The recirculation NOP/IS and the PDEIR must contain an overall and specific projects' Environmental Justice review of the similar major infrastructure programs and projects as related to those receiving benefits and those experiencing adverse effects directly through water -related operations and indirectly through direct/indirect payments for such effects and prospective benefits for those with much largely parcels and incomes. 2-6 Mitigation Monitoring and Reporting Plan The Draft Programmatic and Draft Project Environmental Impact Reports must include tiered draft plans for the implementation, monitoring, and enforcements of the Mitigation Monitoring, and Reporting Plan which will be subject to public review and comment as part of the DEIR processes and not wait until the "Final EIR" is circulated. Dr. Tom Williams 11/5/2014 ELIZABETH BYRNE DEBREU 777 Arden Road Pasadena, California 91106 October 8, 2014 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont, 51h Floor Alhambra, CA 91803 Via Email: gbegett@dpw.lacounty.gov Re: Restoration of Baldwin Lake Dear Mr. BeGell: I write to urge you to make the restoration of Baldwin Lake a high priority as you lead the effort to create the EWMP for the Rio Hondo Watershed. The restoration of Baldwin Lake, including modifications to the depth of the lake and adaptation of Tule Pond as a bioswale, would enhance Baldwin Lake's water quality and give it a more significant water collection function while simultaneously enhancing its scenic, educational, and historic value at the center of the Los Angeles County Arboretum and Botanic Garden. The restored lake would also provide an exceptional opportunity to educate the public about regional water management, home and community water conservation, and the role of the Raymond Basin and the other water resources in sustaining us. It is a key resource that serves over 330,000 visitors per year, including more than 16,000 elementary school students on field trips. As a member of the board of the Los Angeles Arboretum Foundation, the County's non-profit partner in operating the Arboretum, I stand ready to help leverage public dollars to realize Baldwin Lake's unique potential to provide direct public benefit in a multitude of ways. It is the ideal project both to enhance the watershed function and serve the public with remarkable educational, ecological, and scenic benefits. I respectfully submit that the County include the Baldwin Lake in the Rio Hondo Enhanced Watershed Management Plan. Very truly yours, Elizabeth Byrne Debreu Board Member, Los Angeles Arboretum Foundation STATE OF CALIFORNIA—BUSINESS TRANSPORTATION AND HOUSING AGENCY EDMUND C BROWN Jr.G DEPARTMENT OF TRANSPORTATION DISTRICT 7 -OFFICE OF TRANSPORTATION PLANNING 100 S. MAIN STREET, MS 16 LOS ANGELES, CA 90012 PHONE (213) 897-9140 FAX (213) 897-1337 www.dot.ca.gov September 29, 2014 Mr. Gregg BeGell County of Los Angeles Dept. of Public Works Project Management Division II 900 South Fremont Avenue, 5 h Floor Alhambra, CA 91803 Dear Mr. BeGell: Serious drought. Help save water! Re: Enhanced Watershed Management Programs Notice of Preparation IGR#140912FL Vic.: LANarious watersheds locations Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above referenced project. The proposed project will prepare a Program Environmental Impact Report (PEIR) for the project identified, such as the 12 separate Enhanced Watershed Management Programs (EWMPs); it will be prepared as a collective effort among the Los Angeles County Flood Control District (LACFCD) and the applicable agencies in each respective EWMP. We would like to remind you that storm water run-off is a sensitive issue for Los Angeles and Ventura counties. Please be mindful that projects need to be designed to discharge clean run-off water. Any work to be performed within the State Right-of-way will need an Encroachment Permit and any transportation of heavy construction equipment and/or materials which requires the use of oversized - transport vehicles on State highways will require a Caltrans transportation permit. We recommend that large size truck trips be limited to off-peak commute periods. hl addition, a truck/traffic construction management plan is needed for this project. If you have any questions, please feel free to contact me at (213) 897-9140 or project coordinator Frances Lee at (213) 897-0673 or electronically at frances.leekdot.ca.gov. 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':.% ti _1111.... an f. x th.. �,i• .1:i: F n th•. f 1'_it: a or :z1 r1 E.n :c'- k; r•e u=- "?"-f =- c''' = rcl�=in%- b,:siz. - 3 --''- �i V i,�'F•1G1e rC lei!.1' Zn^•': _zciliti ._ ::r:!u •: zIl a nr• - r: un3 o-' t;:' rout' frcr"I our c - COc.5=. ri":1:: rlc r �cnr_ �houlc c 1.1t v o:i a gra::e v r =�• ts .lc-iCl- .._.� Fick -- `.,�11'pner,'_. ;:•rl e:•:zT�1e 1. -- tFl=� i�. nhnw•n ci. d. Tti _cot -rl_ ::,.il_ F'' r - . 11t='. f.__ - rt- izcc.: - tcl er.C.: a;r i-:t"o t " - - n= rl= - .. rlr1%St r.•-) =r• r:=nn�rt. ciitir.-:a: l:: inq e- _i.• z=-Fme thon. . r't; -=n. r r>th',- 1:T�rZ =rl :s JrL'�r_ r•f 1 •'.1h:: C''l ,=in , h•1==1c EJr true uI• , '_ .. _ t:•l n- ::L -h fc:Ctincs for LEkCL CC-lt tC ttlC F.._; EF%LI a _ ��c. } �: rOnC 7't .-_i: �C' -�� 7`. thr _ - _ Dlt r'•1;:1c Cr :thr.,- l - - 1. r, rC•-:i E_• [:_ ilr.�i F. 1.: -_ .. .... :: ni: =L:,L U!2 il.'1-1==� e:: U.: ��I'I: c.l]. tr. :•:IL'r:l=,`__r .:li:"}'i'" =L_ r".• .: t.l__� �.nd.'�.r=".._..." "c T.11 .'.'_ b[_ :I'�211 = n:'>: -':"r "r: I-; -... `.'f]- --1 t:".-. �Li'_'_..l t':' ."_""R•:i�__ c'}'I ] �" 1C,:' -_Te _ F C•=J,: [: :i'J,"+.`1:-:1"i. '1'�,= 1.'.�:'I, C•_�.^L 1T'`_1:]". %-tile l-1 '_ i✓,. - :,- T: r. We e:`• ura,7�n -�h lli +_ar,' L _ ^P. f I. -r_ __... ..: - } a;?1'I it =r:` u�1:=._ :.-.._ .-...- tt- - vI`.I: t::::r::_ _ at such n e 9' f is t.....: r.: it.h _•_r"t"t-1 :,]__: _ -. i r r :t 'rt. - - idtl _r"e p -on rtv th•-nn:-_v ~.[lblic _-_c t. -."[ a; _-_- r}. :d]uC. i.r _ - f:.. -.-Ch U`:.- of tlU_ �:s•.-r t.`t!: Dir'•:^stn.-: c.%•tan _ c'_rt e,= v)0%:• �:r,d L:.: n•� L:i': :.sic, -:, te-ec`lor"e [::1'] 250, F: ca.yc:•:-._:.- ;t:_-L..-:,e-:ts =cr la" s._ ina, r--.- rr a_zinr .... ner , WLLi _- G- 0 rlUr ^Lt h]]"1 •'.' =.7 7r 1 ]t} e:. L-oLT-,1 ?•3 wltI in i.`is,:i r. r:l .a_:) and i q:'1 d c-1pt-�:•:- r•f the re7u=st,-~r_n•:r:t r -u _ v= succi_ :3. P.1 .;, tirt:te `. ",U mitmea the s.h _tw �= ti -L<: cic•: r]:- oount :.'ill =c: c_-: _hasri<.f-:-t fo: t.})F =ci mL=- ses int"-) i=s }:_ic S ::=n:lt of -�h.� r . ::r!...- will LN bic.", c• __repo!-it..l:r'-- - �hts Lo a ;_ i :, _: r" fcr ..L:t(�I pip, .linr.+< a^,:i at.r: ou_cc: t., t. �r szr-ye _..er a i- suc}r crar.t had not. h;r-r�-: rl h= c.kya-q•:' -��_- th_ .----erlent. _lease noir-: t.tr=t, -- cntr i' r[jciyi' ec Dr- -.i r- p_-c_r:rlrt_ _3rio_ L'a., ;r :]' ='he = .s cm .[lt, an E::==r'.' _ •. '_T.•1 i. T--Ust k1•:: rb = 1 . P: e= _ �: _] . so be ciy:: f r th•_ [51 rr_. ":rI'-: l::nd >e guia• -ir"es `n: _ts ic, % 17 17. creen b:":.t ra; b' ,=_11 -:wed .. _::ir h1e'-opol-tar.' r (2:._...:i nt. ..i""= C]i �:-.�-may:'. fe=lt.ro: = e -:3r o_ "._.. r,ent Z-1 { nc: nt.=r'.'"-=F.•=_=r:. r: oc;: r I F:_ t.. _._ _ - th' in., i7 Les �.�._tE•a - ` S = rti`_r. art', cl _r c�n tE-1_ C 1Pc-_:ir arcs. •.J71 _ '= _. ., n =r._� Ila -1 .? L t, i s .-z: =ter: t tr=.:r' nc%. c- %a _ :._ =a-rctF= _ n,tL:cl 'it.. f rn Ln In - RriL, - 1 xS .� _. ._. f tia'. F..- cr - 1 _r. c:=:F't: t.]cR;: fc•r Il�:lr =,} _ i-• _.n allv � .:c1t:C�:L L:�C: •: i�_Cr:: f•:tr LG L :ir 1Ci:C iiL ai.l tlCnC C:_`'n:T =tom i. 12. J_C .-_ i_t'•t'rl" f .1 lti _ S t :_Ci:l. == u r :i in r-: - - %C, - - wa Ird 1R y•7 c- '-c 111E 1P�' Tl:c ..:R.=_:1CtE'`. �!] tom..--•L-'it F:-_'['lrp S" �Y.s t,._ ti_..t`-r h•r::l,.to and Ic-:_n..: an o; t;•_tro�; l]-.a^'� f e ~c_ .. a--c;:il-c:Q fr, Lr i'iC1f::1- •I atl C. i+_. 'r7 i t Fr itr ntr- e ce pri:.r t.:� .:n•. �- � _ts ..u�;t fcr n^ s F,r ;nrrtj . T'1- E-�wi1' an. pr r it cr ea_.-,i•'n+ r� �` :.hrq:.: qui na ren tha=rime`.cr fen i. c e: =E,•_ It _E -S Uci.w �t:t1.-teG ce Un_'r r•r;;�:- 1 -.L R}`. 6 f�E't ill 1Lc igh'= a•''..'t(D - - C - k=_ nUled u�' a F1'e:_ ith tta�i= of U•art�:: ' Cl �1RC Cllt4:c Lc ilt tCit - '' 4� f `'i:�'e ti f'.1,:'It C- u :;ti Y�'_ : =rrt . ng rr.a•: 1) r. re;i L;• �'e- c ,: ,clita?:. �_•'-ilii `iri Mt `' &_n'= FeE• r- _ -•dC-_'lit .'� lt� I.1 �E... - .i-CiO-Ems: _•�;T e.,+� t=nr:cl ter' :-•clic: tc•a -}lr alir.:nr=. Ltilit's _ _-rtittL'd v, in i t . - e Pro?rrta _i: r2 :]_ of o] 1c `-nts. Ye=.-ne-,= st=>1. -u-n_ i;c1L'in catcz basirLs, marholr> Dower F:o1e C trt1 riGcr o}:os, etc. , shy: n kJc nc:ated alt = -, it __. n'-oa+=. t.i._... ar:d, �_ ca�._r,�r.^tt. L•:e red �clst that pe-manent ll „tCt u Wi th J. TI pug-ic sti ects1:_ w:_1 ch Me pro• :-'__t1':'s la!'1�1t.1E arra c•_1nst.ructec und_•r t h u Mc'zropo1itan L:a=e_ District. t-, 1)�: pliaLed as lar frc:m our piocli::e as passible, bu:. not G1USlo:t:l= r fe'=t F=OT: �hcn ou,LF=rte or oi:r C'. ` hC - Inst -J.). A.at1 On c= u"_i11ti2S Me t r Opo'_ . tan' s it 1p P-1 J.n eL {s ] must h E' n aca oi- n c e w th ML F. r e c u'fr�n rR�-Rt sliorwn on, the• cnclosc ^=ints of Drawings NVr,.C-'�1 [,�� and Lr4j•". 'r Vi fl•_a n" -Ie L'.- '.]!]�. _. i.b 1e We rC-Cti:-fit .- ri'am�rium of once foot c1 ear ancebetw-,e-: t•;=_'tronc!it a_:'s pipe and VOLLr 1=aoi11t TeIP.:,Ore, r�---;_ic•rt Cif M trODD Iitari pipe :a als. b^_. r s'_ired z` t^~ercrossi^gs of its pipe in cin o:,:;i trench. The tenrorar•:r �:,uano=:. tel: -ns must bc' re.-iewew itr.:1 apr%rovea by hf.'=ropol_tar_. c. ..,aterc, ut-=lit-F c=oss'_ncs of tstro�ol to -'s piF lin° r: 1t:1: ;t be as perpor.::i•:u'?ipeliF..c alineT.er_t as practical. Prior to any excavation nu= P' pc lino. :i'r 11 bx^ located rr.an�.all and en'y e�cac•ation wit}1i'I tr:n fee_` of our pi13(?_ i nirst i e acne by il2rrd. This s' -al- bc• not -:°d on the ar:rocriate drawings_ e. utilit-les constructed longitudinally wit'in x'.c t.rc•�rJli to ' , _igtit.:-ai-wa n unt be 10=ted outside t`. e theoretical trench pricrm for uncovering -.a nioeline and mus. b= 1Jr.at. parallel to aria close to its ricghts- c - ay lines as pr:autical. f. Wh-an pipinc is jacked cr instsallc-d in jacked casing or tunnel under Metror..olit.a's pine, there must bc� �.t least two. fcut of ve=t _J clearance �)etwee'n tine bot -ori of Metron0litan's p,irre acid the top of tho jacked r, jaci inti caj 'in7 or tunny 1. We also rccui_e that detail dr,iw=.r:q of the shoring or thebac-L-inc or turz::ol._ng pits be. submittr.a for our review and approval. P;-ovisions :,..._ be ri:ad tc,' grout a::y %r•oids arnund the e^i:terior of the ;ackea ripe, jacked czsinc or tuna. =1. I: the r ic:i.r.g is installed in a jacked casing or tunnel the anr,ula' ,aCr_ between- the piping and the jacked casing or tll71i1e1 rlllst b•=' fillF'd wit}l GrOUt. CCU G�r:l�..t: Yh: f!� _ �C-.::� [ y�'r L,r`_.. [Iti. F C11 2t aerrs'- _.r r.in=:t=u:'ciG" C't:�E:r r,C• _ `_. - rn'..iitnn .._ � j ; r, c - 1 - c'i 'ar n.-.;. -i M�Q--i:er ru-� t: ., =r" ::hr tC:• t- e �.: ,:•.:I- :j'- i•.: ilo,.•ili --`ic rnur,:i -1-ct F'c:'%-n.'." ce `cn ar, i1"r, cam` r h•_lp Gt,, r Hc:•r : L• ir[c cu_ my ".,...i-ntt! rc- '•} Lin cf.e :lan:::•- _-_ ri th'_'lRC" +C•1'_ R= c:]C 511 p' :]I" _ t'"ti'r• . IVB J C'r.,ilt: ; - .•_" Z� , .- i - Oi'��rl::=iC iR•:':5 - 1 -erwa 91V ll.lder'YC:';n[i :.I r:C Yr=r1)_ "•, .0 Z71-_1•.YL'it'- - L:rf:'--'%:ti1_•�Q W' tY•i*' C'.]_1 �: L'-:�c T:1�`.cL,i'Fl nC - �.. _ css='P..E!n''_r ." of rec; an:ur o: r" rc cirrnc rlL2-� p1 ceci it:•-" r ,h%. T: E` _ round c:: F_re t}i• co: dt:i: rnt� ` r r e]:it tc . i:. � ^cli::t _ r�ctic-: C. -• �clL TL n tSE t"ODU itan' SFCGI!f0= t[1 �ne Cr:ii`_oEni to-? rtr�c �:1�tf H trparat n of 'r ter ^:'ii: rl - C e {-D- Cit., •- ti:e Cit': CI 7' L'�i]i'tl' f_r•c,r'i. rld ,i :fir[' SE. I-V 1Cr_'S -3 _ inc�talfDn of srwrra i the ._".�; .-nclic� E's it rE'_ trs. t, 'r:., L e r 1 l Il E'•�.• T. - n:.t: O_ _-Com.'_: �1; •L Coil!:: rTl" i};.�r�, _l c]^ C'i _�L,•C rli:le; 1 71 i tr• rt r-cht - WE v%r Ljo- 5111 RC':r cil^•Trc.._1'•t_N F.. Il`_'f:t j iYniL� - r - rlrCi��"r`"•J n:= �r &n t)Le' 10 C�i.1(7 GI loc:: tiGz:: .� _ _ our F'+.^elirc [sl �}Ee _:,zs sr:::1 l •" r., t L Gc�LL r^ P}.c�liRet n' C'"^i.1t1C:Il. c'_1 �.'R .".___t ❑"`. :jr ln':S =',r []•,]r j. I r;tl:clin: :-f ?•:c.tropcl:-tart's pipoliiiF i = rP�:-i.� ed r._ -wee: a L;til it.•: end h7e_-o_o;li.ta-' pi- 1i is inciicatted on the TDlan tc• be one fno _ c:•r a ('= _ . I i -khe innicat.r < clearernCe _ s between ❑ Eni tw:i feet, pc:th:_l:)q 1:. sllgRes=P•', i'ictr=0-i-an wi-- prc..-ode L recresent-ative -o al:sists other:; in looatin❑ and Ic:nt-f i:iy l:ipc•1ire. Two--wor?:int da_:s no -ice-- re•:: aestc�ci . } e�_uato shcri nr and bracinc i _ <<-cFui •rr_•:i for the f;;Il dcp-h [: i tiv_ -rent` till= the excay.it _on ehr-root he w_tzirt '--ze zon= shown on F: qurx- 4. 'h ]uc`:i-_cn of uti-mics within Met:roolf.t=ti' fee-Drcpe,-,tv and /n- easy=ment hall be _Dial my marked to 1ir%lp Dic-:ent damage durin7 main`-Pnano - or cthc' wuJ ?: cone --- thc- a-ra. Dct.,rta'.:•Lr_ t.a-,c: over b2ried utilit=es should he• rlaced a r-inimu-c of 12 inch es abo:'c the utilitl enr. ::frail- c:oniorri to -,ne-011.0•.ai::G rcc::ireatc-:ts: - i j 4 tits r r ipcline : r. two i nY blue warn enc; _at,e shall be :Tr I) rLtrd ..i. "C'=:'.TS❑?I F3LIFIE1 Fi:TE PIPELINE" 2) Cr_ , ni" , or chc%micc.l . ianline+ F two-inch yellow wa=-ning tare nhr j 11 7,5 imnri-r:ted with.: ^C_=:U:IOti BriRIED F=2ELINE" ':tom d_ air :llama=. 1-iP: A two -'nth gree-: War: inq tape shall he iaprinted wi `_: "CAUTIO`] BURIED P=pLLIhL" 4] Ylectric, street linh_ting, err traffic s.igna'-s cond.u-t.: tW7:�-inch rtd war:i.nc_ tapc° shall be ia: rir.tud wi t�-h: "rl :.0 :ION BUP.IED CONDUIT" 1 Tc-lepi�nn or telev-sior_ =dui=: two-in•cn orange warning tape shall 4x im�rintcd with: "aA=IUN BUL IEC TO:^UTT" :.n rerb t s 1'r If t erc is a cathn3ic "-Otection stat or, or Neto; olitc r--' ; p=pclin[• in thc area cf tltc' ';r[»a�er7 wot k, it- stt 11 :)e lncat.ed i [. a o_:c3V ati-o: . The eraot 1o,.aLL oT tirac` nc o.r bf titin, d^sCri1)tion a: -u prbt ctinn sha]1 kib show cn all 'lcanr_ contan e.rnnolita-'s C all2rDp'icable plans, lien, lccate:i at tetra: ni i`.arl' z lay nyinrcrir.q Sa ite;:i c ar_c Fiit a i+n-_ 7 ut} tine Flar:t, 700 ?:Orth M•o=enc HV•_:nup La Ve_-:•e, f all nrnia 5177r =q=_, • 'telcphonr [71 j -o= thccation: F'-❑ of f_otcctior c:taticIs. Z] If ati inducec:-r_xrrrnt cathn3ic prr'en}ion s rst[ n. .s to be i nStall[�d o:: an, t'.etrnaolitan'� pipeline, pi' CbRtbt Mz. p+r- re E. Finer at (714) 5n3-7.;7: or [131 250-^085, fI• wit r[=:',. _r•tv `, h� orbpos edst.ett :c::.lictE and Bete tine if an, ati 'hit tr' exi ti::g .^-athod c prctE_ _ ior; stctc : itis; 1l as by Mctrcpc:l i tan . ?1 F:ithin M•'xop:.?ita-'n ri(Th ts-of-way, ipel ttcs and carrier riFe; [casin;s] shall be ca,tFd wit:- a_- a:]rjrOved protectivr c•.)ating to Cor -forte to ;Setrnpo-m'an's requir=cnts, and shall be �aintaincd ir, a ne,.t and ordrrl,: oor.c'itian as directed b_: Me ra o-ita The a n. i.lLcati,7n and riori.tcrit:c of cathodic protection or- the Lipcli.ne ar,c^-asi-g shall cop. -Q= theto Title 45 of Crede of i'�deral' kf+gulat' ons, Peart 195, 4] if a nte41 carr:.cr Pine iC3singl is used: Inl Cathodic protection shall be prc:-ided u=" Cf LI Nacr-ficial magne iur a lode [� Y,etch ::howirig the cathocic protection, uetai_s can be 7rC' 1G�:i for the cusiCcm _ i foz-ma r, Rs tlb. , (b) `1'!1e Stc,U. carrier D. -rue shall bE- p-[)tected with a coal tar e7 aam,_1 ccating insid[: ane out in coard2ncc with JAwe C C'3 sneci`_icatian. n- l_ troncktes shall by excavated to co. CAL with the CtLjGSF, COnst=tiotl Safetti• Order_ , !LtinIe o, begir.ninq with Sectia:t:; 1 39 h b h 153 "relic backfill s6hall he placed ir, 8 -inch lifts and shc11 h]l' cc'qua =ed tc 95 nerce-� relative canpaction (A;m^M D698) across roadways and through c_k ororectite es. Trench bac?-i11 elsacahe•e wi11 he c0mpact..+3 to SO tie-x::ent -elati: cospact.on (A$Ti: Iit"•9$) . r.. Cn 1: -)l at 1e I-c:nne• :_i':7 ..•i. _h _he ope tic n of tI Opo tan ter: a::_ bur"._.. within. st:-:=t-s propertle= a-, ;'or ccse �ttt.;. The ]acat'_o s and-lerrat- r,"_: of thr=isN ..an1t:5s shall bP _hovn ❑^ t.hE draw�;-gc,. •Phe =s inga shall note that prier to =ny exca:- =:. in t.`e. area t:.)r cont-rol c, b'_e=_ shall be located and rr.e sure: ch. -'-1 he tak_� k%_ the u=tra^t.or to _-�rctect t -he cah�lec7 it: p_=C-E'. F' ti1��tr'•=�::elitan nen:k7er cf Ur.c-crnt�n:'_ S,�r�-cs T::_ contract= (F'-xca'.ator) .hall LIS-- al 1-eGG-4? 133 `c:.:-: -_ `cr : - {.+ ., lir"' t-311_ _ ley _ _c 48 hours pr -or to starting =vr-°xca.vatio:; worl-, T11 contracto %will hr_: '-a %1.e ro- a ^ v damace to M_5 t=o o1itar's facilitie° as a res:;=t of th_s cnnF-tru:tfon . E. r'�:.ramount F:iaht Fac. il--�Les constructed within M-tronn1ita''� fr properties analn: shall be- suh^ E.•ct "_o the right of N.e'rorol_tan o use it -rF p npr ti and/cNaseraojit�. for the purpose for which thew were acqirLICi. 'f at tLme t:etronoli u=,7tan or it assicns should, it:• ttc+ E:c rcisc: of the=r rights, find it necesz=v to remos.-=_ anv of the fac_lities f=-. the fPe aropertirrc and/o a :r nr.nt.s, such removal and rculacenen- shall be at t.he. cr:p=_.__,_ cl the o n^ of the faciL-4tv. 3. Moc_ficaLion cf Metro •:litrri's Fac-1=ties YTher. manhole, or other of Metrornolitan's facil; ties r..ust bc• modifie.d tri riccormtodate vour construction Or reco-s- tructio;r Me-tropolitan will nodi_v the faci'-=ties wi.th its, forcNs. `_'his ,sho'id be ncted o: t.lLe. conS=uct'_on plari�l. TY r• cstimatef cost t.e p=J orm this nodificatio: will kit+ ❑i Cn tc tion a:3 w w.11 require a deposit for this amount before thy_ Once t --.e depn_ i.t. is received, we will sch=_du[e the war}:_ Our forces will coordinat•. the work with Yo= contractor. our final killing will be based on actual cost incurri[-, and wit- includF materials, ccnstructio;;, tight °cri : t p•'_an rev-ew, insr•ection, and adninistrC:tive overhead churve.s caiculatcd in accorC"ance with Metronc•lita-,'s standard accounting practices, if the cost is Less that; the deposit, a refu::d will be nade; ho::eve-, if the cos= exceeds the cep^s-t, an invoice will be forwarder for payrr.e::t cf additinna- amount. a. x:esid ntial or cormerci al decelc c-: 1: Crcar; �-5 i�d CC�r:C�::t r�_te5 Z' t- tC'plcal-'_:: the p'a storm wale' runoff Nell a-, thr al �•e.arl} stogy n:naff from an area as ino_easin7 '_:1e reaui_ eats - dc ..st.r%- -c of the -em. fcr tosT drain -acili ier. c3. -c _•lr:•pment. All. , throuchout t tc haler f o -r lan:isc: _-.e 1r_1 } yee- olttdno- rio nr_:sti c „; e la `-cn, car washinq , and othr r t r u;cs flnws into the Stozr.. dreinaap c,:stom Tcsuitin in wr�ed abeternez-_, inset' infe tatiDn, - n7strLc sd act ss a. d ^ther nroble;r,s, v-,� - Th=�refare, it is ,e _1_opclt:, Cf s usual prractice nrt. tc: aparo:- ti�.t:-s that. shoe: d-r:c: ar.;r Cf era na7c -rem ccvelopmerts an}o its fee r•rc_re=tie -d or :asNments, - tic carried a h - McLro oiitzn l fe= ,�r 'res:: ❑r dis^ i'--c;cc. :int P - c•: tier; and/or E°aseZcntr., M trnF>:i=tan Wd it insist that Dlzns for cevcloc-r.ent provide that it ba ca--iec b: cl. =,,d conduit o lined cper. chdr_nel ap•roved in c r ting Metropolitan. :.s0 the drainagr_ facilities m ^.tur:t e ; i:tained by others, e.g., city, count;~, ho Downers etc=. the develonIn.eIlt arOonses ChcL-1 ir. "D�idtlnn, `ezturr.s,, ther; t g`'s _ existi^7 d--a4naq,, dr'vercper Shall make previsio;is to r,rpvide fClr Tt'.0 i.y Ce".:•:'Rt and those- changers must be au_rraved :�y in writ.ina. 11. Coni-t_uc-tior� 0-�ordinatie=� 7 Uurinp canst:'uction, ';etropolitan'r: field represer.tat,J' = wi__ make- oe�r,o:ic i=pec ions, We request that a slinulatier, hr added to t;Ie plans or sDe cifications f•r)r r:otification of Of -Metropolitan p._itar , s Uacrations Services Tranch, te-ephonc [ 13} 1�a- , at least two wor9�in dal -S e,ny work in the 1•iC].= irl' of our facilities. � p -'C)` to l ' ine Ln:i3_r:� keStriCti.arls z. netropclitar.'s pipelines and condu_t:: vzzy is structural strcncth, and some are not adc�_uate for i+F:S TC; I -2 l ading_ Therefore, snecific loads ovc- lh_� Specific ^_ctinns of pipe or conduit must lac reviewr%C and approved h•; Nx_tronoli.tan. ?iowevrz, Metropolitan's D4.Daj.ines are typically adequate for AASFITO Ei-20 loading provided that the cover over the pipeline is not less than four feet cr the cover ;s not substar.t'_ally increased. 1f the temp^rary covet nvc�- the peline a nur during consrction ibetween tn;pee= eet, ecuipr%cnt must restricte:', to that c:hich T-pCs es -Dads no greater _::an -y �T:. 1I-10, r -n �'�=- is bc.twc(?n tw_' a_^_3 th'-ee = —t, eC9 ].D•R'•:... ^..115_ t'_ Y" t0 ti:a= of: :, Cater -lar L;-•1 tz-;;ct-tvj:%e tC,.n If the c.-wor __. ]fess thaI: _,. fe^_.t, D.^.--, hand en7,,;.%fit. 'la•: be us•?li. 7t1.o, _f thy. :-D-"•tr&a:t.or p.'ans to__c._ a,:%: rcu�rT.,-t o:e- 3'M-`-tri7t':� 1JtaI1't _❑iv�l-rl�= wnica rvilli-r.00se loads c_rc�at=x" thatl iS1:��:?TD 11-20', 1t w: 11 bc. nc'�C'S52'r'i` tC sllL]r-1xt le of s•act ecuip-nent far our rcvie:: and appro-:-1 at least c•nE �• wc:c}: nr=ar to -� u�;�.. _nr[' re�t�"ir ��-:c req�-irc-•ts -ray ap;:l}- to tf:r_ lu.�dine yL ice'_ in•- o -:ex" :"�c: Sar, D_r•.gr• 1'i:x°.lines ] and c:•` the Orange Count-: FeEd=>: , and ihE Co1^7"aG''C .:l Vit' rt'lleC set. YleacL. contact us for lo:cding rest_'ict"_D"_s on al_ :?] M.,5 t rotiDl'-a s Ti_:1c n•1 b. '"Ry_.i:istinc co:cr Over t�:c pi c1inc: 5i all hr I^.ai -I taiad tln1;'-- Mr-.. t. nonl itas dete-zr. dins at rcoosed changes de not pose a hazard to tI1 intccrit.y o the n 1.inE nr" an nm-edlment to its Ir,ai^tsnancc. 1 Lil�sti_::' a. At _east ZG da s -Orior to thestart of ^.•: d-ilLi-c far rock ercr:: ition blas' inc, or any lilast_tr-, ir. ths vicinity of ^Metrooclitan's f.a^ilities, a two-part peel=min ary cone: t.ual v1a, _;hall bs sunmj.tted to Metropolitan a,, follows: i:. Fart 1 of tnP co::ceatual plan shall inclulul, a r_o,lc>]"_toCZumn::ry D c;ropo=c.J transportation, handling, r;to=ace, ane Ise ❑- Explosions. c . p�.rt. < <::1::] 1 _ ncludd"=. tkle proposed i7eneral concst t for t�'_aetir% _.'Clue inr Can-::ro1�3 of ILCIF3e, fly centro?"1c:3 rock., a bl .sting rklla t., and t c11n_r,uc and arourir3 vibration, 14, CE`s% ii. Why hn-: ==ent.u1 Doc>1-r;?_^.ts fla:•e 3tiot Been =cil trEd c alalia: s ire le.rentirlc the. CalifD zia Enviro=cntal Quality Tact {C ;Q>_Y) -eauire that have an opportunity to cor_sult with tk: , aaenCvT n= consultants are::• :rine an•. en-rironm�::tal doCunentation. til_ are recuired to review and cors icier tl:c e viro::R n'_a'_ e-fccts of he nr^'mac`_ as sten:" in the 'tic-5gativr- Dr- 'a_ tion o3 En-:ironr-lE-tal Impact Report =orycur project Ijafnre Coy.*cittinc �'t�_'t• =':J C:_1ti:I1 .-_, aP•Pr C':'� 'Dtir rE':3ll•'•;t. 17 - -] In order to en urc a7r:.ianc•- with the r P_U vl c.t I4Dj i—nD2-e;Zentlnr7 C�, where t•Iuti: Dnli.tan }•=. nom: th LE_ad A er.cy, the following in nut n-oncdur� to en ,vr _: coT_:•_i n; e the Ac`. r• is _st L bl ___: cc: aJ Metropolitar shay_ 1)•c timn ly .' zdrises an dctFrmir.atint: tha: r Cater rices xeto`"; nn apdi:i lies to the pr . oje�tThe ad - ; , , to U �ictropo-i.tan that it ane o`.r•e_ aQ cis articiratir_ in the �r;ject a fnE' -ecu-ener.ts of CEQ'& corr_,liec w_th k- prior t n1c_roocl tan' � s } r`--r'`opnlitari is to be con_.ulte.: curing the p: r parat.io_, of the Neua ; -_.E. L 1'r �Iet. tin:: nr cJ ^etropolitan i to reviA„ 3rd submit an lr ne•=:ec;sar;• comments on the Necat r.rar. ETF,x'1e Declaration nr d) Metrcnolitan is to index "= ar+.V costs or 1'-2bility arising Out oFLnie� Soi viola -'ion 01 ar.1:o- regtl.ation�, irLoindinc_ but rot lirritA-d to the Cal fornix Env`_-nnnental QUiLlitv Act and its implomr_ntin re^ h. Siher �;7•; i±cnmenta? Docu`er"ts Iiave Tf nvironme.ntal doCLTments havF been prepared for 'rpur project, please turninh us a copy for aar review and filF in a timely manner sp that we May have suffici =evieW alLd corintent. The followent time to ing, steps must also time accomplished:be 1] T=i Fad 2'0ncy is tO advise ASetro�oli.tar. that _y and other agencies part4ciYave in thF pro7ec' w the require- frMts of Com, pr'ar to N"•tro o-itars's participation, =f YOU must afire.. to indc= i_v ;letropalitan of`_icers, engineers, and agents for ar_, costs or its Iia :•flit} arising out nf. ar_}• viola}ion c.f an laws or regulations inclucirg but not limited to -hc Califo-nia Envrronmcntal Qual_t_: Act and its implementing reguIo s 15. ''let -Ono 1itar"' F'an-Re�,°iew Cost a. e.n inceringre;-iew of your prop•nse^ facilities and deve_opments anc the prena-atinn of a l.cttet response L - : _.:1_ . _.,..., r, -. _oil..._..._ = e .r'..,.- �.- se vo:: that !✓.ctrcpo1 t.a^S = eWS an - perio-rred at nfL costo tt' he deE__Ot,e_ ll:i ,,� , .... __.__lit_ re r..us _ be modi Pied whereMetr0a)01 ha 1t;f%ic._ r_ ^.ts. : f nfo ? a =lot a. .a;. _, -, ar. en41'le"ring review an -d lc Iter respo :« _ quires m'. rr_- _-a^ ? T.an-; oul-s Cf effo.t b_; ht�opol-tan t-, rn-r.e tiq.,•_onal=t.ari pr000sec fa__, c: d aclaamer.t is cn= tide with w. -ch was rte. b or _t_. c; f -a ;,11:.1t'-:•, c .f rcQdificatlon`r to l'.'.is] iz mann or othr_' faci' it'es will be red, the:; of _ecus _.11 r:•,_ Mr �r Gp:Jl itan' : costs associated wi-h t` r?. ::•r•njcct rr.•ist be = c'ra1 p'ai'd' by tr_e de:re'_aper, u"le s:: tr.� cc. elcper has S C:;, rights. b. A deposit of funds c:i'_- he recuired fzo7� the _ developer before `ictrocclitan can begin its detailed cr.�ineerinq pl=, review that will e^e^ E hou�i�j%. ^h arou^t Of the rc•cuirrzc dcp^sit will be ceter-mined after a Elm 2 r.- r. f•_ c su'....__.:.dct r--ursory civic°w of t_2e mans f= t:hz� rn-.c :c d de:-e1^amen' _ . -:zfc. tr•>�olitar '_, final bil'_i^ v- l ie has• -d cn c•. -c-t. _:icurrcbd, and will. inc].u'e er.c-r.c —L= _:1a- -- Ie _..�:)=cti-^r;, m�tcria].:. Co �tru:. in aric admin: strati• _ overhead charr_res calcula.e.4 _-- acco-"dance with N.ctrc•olit::�•'�= standar:. account -ng =:.-ces. .f the cost ._, less than the do co :it, a re=Lind wil'_ br, ...=•ie; now(INY-or, -f the co_ -t cxc^ 3s the deposi _, an -n-: 4 will Lc° `or-..-arded fc_ ment cf the additioza'_ a-onn... dti tio&I ceposit, mLv br- -e=ire:l If theL Cost r"evie.W E.'.;<C:E.'.:_ -I%cf a.nuunt of the nit- n' do it We ad:: se vo:: that !✓.ctrcpo1 t.a^S plan rev. eWS an re �onses b:i_;� :i�c:; nfo ? a =lot a. �._._ _...;1P tiq.,•_onal=t.ari w. -ch was rte. b or on be`.alf c; r:•,_ -r, taR = c'ra1 rec-rL - os_� or.'. S C:;, _ Elm 2 r.- r. f•_ c su'....__.:.dct -:zfc. ___:r, •C'�_ t+lir: warrant •.. d1._. 17 E'' -eSS Cr .._ --1...., -:•:r. aitGC::IE.'. L: tC t[:_ �o`r.a e1.. CC1:"vC':C� F=. _, _.. __._.. _..._: C_C^_.lir:. Ilc R.� �..� .._ _... Craw- .._ _.. _. _ __..:n .._G h, _ _::•I"' i�.. �..-�.__tir._ tC:• O.^. a.^ -� Ci� _ r.11r .._ :'l_�.. :. .^. _ .-_ _ the_=fo=_ tt _, rve_:s role t. a_.: ..=_ ...�i~ _,:rr: tD -_•,i' :n estic t__.,..: _✓G r.a ee pr de: t tC ttLaa an; G ams icr rrroje:t. coy_..__. u e _....F1f _ __ d.. _ - 1.4 - 1". A.adional IIFeCZati l Should you requ'_r^ additiara? ?nfcat=cn, please contact: Civil EnQ:neer'r! SuSuhstr7jctures Section hietropc'_itaz Water District Of Southern Ca?i€arn_a P.4. ?3ox 5415 Los Angeles, Califo_nia 90054-0753 (213) 217-6000 ATE 22, leg LJ •9 U' 1 c i C Y ;k �•f � lY�, P �t F _ 41 c -- t LJ •9 U' 1 c i C Y ;k �•f � lY�, P �t F _ 41 `I I NG Fcir,U1:1NE1V7- ST-RUCTURES r7ERMIT7-Ft: M. WG. PE:rxAly PtlV RIGHT OF W.4 r` Nd RJC�F OVERHANG PERITiEr� r I BUILDING FOOTING eUUST NOT AD.I.CCENT ENCROACH INTO fiv RIGHT RIGHT OF WAY Or WAY I I FINISHED - � 5Ur7F.4'CE r jl � ! 1 DEPfiH OF ! FOCTING ! _ TYPICAL I IP I � r i I � M,W.Q PIPELINE I I NDTE w a-W0D PIPELINE SIZE, DEPTH, L 0CA7I0N AND wIDrH OF PERhmNENT RIGHT L,'F h E.,'; 'O oi1.iS'�- J W„Y VARIES. F: G� f—= u„ v Tei I � I « \ -/j \§%I z\J/ \~/\ \ /2 Lk \ ^\ 2C(� z«2% <>>< 62rG f>§R z&§« � \\ / .y : \ « \ -/j \§%I z\J/ \~/\ : \j Lk 2C(� z«2% <>>< 62rG f>§R z&§« / .y Yi r eL ,I .�•I 'i r, i -_ Imo.• .y. a": ImeL Iy - :I d ;t L%; I fVI _ LV 9 Lr r• ' - ' -- ..i .. • .}}; ,: _ SS -C7 -10N I I f{i r 4 NxEXpremolded 1r ezpotrslon AVIV- +Aller Apertures cr dir _ ry m the Engineer,0 otC1 volumB -- not to exceedthe r0lume Of the supporting wZF all Concrete support wall to be placed flgalnst undis- turbed ground I. Supporting wall shall here a firm bearing on the su6grade and against the side of the ezravation. 2_ Premolded exponsian f043r tiller per XSrAf 0-I�l T3 to be used in support for steel pipe only. 3. if trench width is 4 /eel or greater, measured alarng centerline of ,ff w p pipe concrete Vupp art must be canstruCted 4 If trench width is less than 4 feet, cleon sand back- fi1l, CwnpaCted to 90% denslry in Cccardance with the provisions of AS7Af Stondord p-1557_TC may be - used in lieu of the concrete support wall, CPOS5 SECTION `vr7 n J,� c'pNN? CROSS Cf^7ICf c It, pipe r.JNr 5s if 1Pn _?;ii?yIii-- cicn:r!cr is qre_^:: r 11^a^ .R I5 . pip' Cr;. the cc rr o r ^e u!:ii,r I:n^ l: 17No "lrPCf S:,•'?.'CS .Tlrl N' Cl':' The. re 'ripe .r N. fife. 40- .. � 1 -1 C C CXF7 � 75ia7.'7 ,ICl ,. r 1550 Harbor Blvd., ROOM 100 West SACRAMENTO, CA 95691 y wl (916)373,3710 e e ! 3 Fox (916) 373-5471 September 25, 2014 Gregg BeGell Los Angeles County Flood Control District 900 South Fremont Avenue, 11th Floor Alhambra, CA 91803 RE: SCH# 2014081106 Enhanced Watershed Management Programs (EWMP) Program EIR, Los Angeles County Dear Mr. BeGell, The Native American Heritage Commission (NAHC) has reviewed the Notice of Preparation (NOP) referenced above. The California Environmental Quality Act (CEQA) states that any project that causes a substantial adverse change in the ological resources, is a significant effect requiring the preparation of significance of an historical resource, which includes arche an EIR (CEQA Guidelines 15064(b)). To comply with this provision the lead agency is required to assess whether the project will have an adverse impact on historical resources within the area of project effect (APE), and if so to mitigate that effect. To adequately assess and mitigate project -related impacts to archaeological resources, the NAHC recommends the following.. actions: ✓ Contact the appropriate regional archaeological Information Center for a record search. The record search will determine: • If a part or all of the area of project effect (APE) has been previously surveyed for cultural resources. • If any known cultural resources have already been recorded on or adjacent to the APE. • If the probability is low, moderate, or high that cultural resources are located in the APE. • If a survey is required to determine whether previously unrecorded cultural resources are present. ✓ If an archaeological inventory survey is required, the final stage is the preparation of a professional report detailing the findings and recommendations of the records search and field survey. • The final report containing site forms, site significance, and mitigation measurers should be submitted immediately to the planning department. All information regarding site locations, Native American human remains, and associated funerary objects should be in a separate confidential addendum, and not be made available for pubic disclosure. • The final written report should be submitted within 3 months after work has been completed to the appropriate - regional archaeological Information Center. ✓ Contact the Native American Heritage Commission for: A Sacred Lands File Check. USGS 7.5 -minute quadrangle name township range and section required • A list of appropriate Native American contacts for consultation concerning the project site and to assist in the mitigation measures. Native American Contacts List attached ✓ Lack of surface evidence of archeological resources does not preclude their subsurface existence. • Lead agencies should Include in them mitigation plan provisions for the identification and evaluation of accidentally discovered archeological resources, per California Environmental Quality Act (CEQA) Guidelines §15064.5(f). In areas of identified archaeological sensitivity, a certified archaeologist and a culturally affiliated Native American, with knowledge in cultural resources, should monitor all ground -disturbing activities. Lead agencies should include in their mitigation plan provisions for the disposition of recovered cultural items that are not burial associated, which are addressed in Public Resources Code (PRC) §5097.98, in consultation with culturally affiliated Native Americans. • for discovery of Native American human remains in their mitigation plan Lead agencies should include provisions. Health and Safety Code §7050.5, PRC §5097.98, and CEQA Guidelines §15064.5(e), address the process to be followed in the event of an accidental discovery of any human remains and associated grave goods in a location other than a dedicated cemetery. Sincerely, man Katy Sanchez Associate Government Program Analyst CC: State Clearinghouse Native American Contacts Los Angeles County September 25, 2014 Tongva Ancestral Territorial Tribal Nation Gabrielino-Tongva Tribe John Tommy Rosas, Tribal Admin. Bernie Acuna, Co -Chairperson Gabrielino Tongva contact information unavailable Gabrielino tattnlaw@gmail.com (310) 570-6567 Last attempted verification 9/5/14 (310) 428-5690 Cell Gabrieleno/Tongva San Gabriel Band of Mission Indian Gabrielino-Tongva Tribe Anthony Morales, Chairperson Linda Candelaria, Co -Chairperson P.O. Box 693 Gabrielino Tongva contact information unavailable Gabrielino San Gabriel CA 91778 Last attempted verification 9/5/14 GTTribalcouncil Q aol.com (626) 483-3564 Cell (626),286-1262 Fax Gabrielino [Tongva Nation - Sandonne Goad, Chairperson 106 1/2 Judge John Aiso St. Gabrielino Tongva Los Angeles , CA 90012 sgoad @gabrielino-tongva.com (951) 807-0479 Gabrielino Tongva Indians of California Tribal Council Robert F. Dorame, Tribal Chair/Cultural Resources P.O. Box 490 Gabrielino Tongva Bellflower CA 90707 gtongva@verizon.net (562) 761-6417 Voice/Fax (626) 676-1184 Cell Gabrieleno Band of Mission Indians Andrew Salas, Chairperson P.O. Box 393 Gabrielino Covina , CA 91723 gabrielenoindians@yahoo. (626)926-4131 Gabrielino-Tongva Tribe Conrad Acuna contact information unavailable Gabrielino Last attempted verification 9/5114 This list is current only as of the date of this document. Distribution of this list does not relieve any person of statutory responsibility as defined in Section 7050.5 of the Health and Safety Code, Section 5097.94 of the Public Resources Code and Section 5097.96 of the Public Resources Code This list Is only applicable for contacting local Native Americans with regard to cultural resources for the proposed SCH # 2014061106, Enhanced Watershed Management Programs (EW MP) Program EIR, Los Angeles County. Native American Contacts Los Angeles County September 25, 2014 Gabrielino /Tongva Nation Sam Dunlap, Cultural Resources Director P.O. Box 86908 Gabrielino Tongva Los Angeles , CA 90086 samdunlap@earthlink.net (909)262-9351 This list is current only as of the date of this document. Distribution of this list does not relieve any person of statutory responsibility as defined in Section 7050.5 of the Health and Safety Code, Section 5097.94 of the Public Resources Code and Section 5097.96 of the Public Resources Code This list is only applicable for contacting local Native Americans with regard to cultural resources for the proposed SCH # 2014061106, Enhanced Watershed Management Programs (EWMP) Program EIR, Los Angeles County. Laura Rocha From: Begell, Gregg - Consultant <gbegell@dpw.lacounty.gov> Sent: Tuesday, September 30, 2014 7:08 AM To: Crumpacker, Andrea; David Pohl; Bellizia, Thomas W. Subject: FW: COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EIR FOR EWMP'S FOR L.A. COUNTY Another clone Gregg BeGeCCP E Project Manager Project Management Division II From: douglaspfav(yaol.com [mai Ito: douglaspfay(a�aol.corn Sent: Monday, September 29, 2014 9:19 PM To: Begell, Gregg - Consultant Cc: rexfrankel(a)vahoo.com Su bj act: COMMENTS ON NOT] CE OF PREPARATI ON FOR DRAFT PROGRAM EI R FOR EINMPS FOR L.A. COUNTY Dear DWP Representatives and Interested Parties, I understand why no one but Rex Frankel attended the NOP hearing on September V in Marina Del Rey. You have no specific projects to analyze for environmental impacts. You are attempting to analyze the environmental impact of words, not specific actions. It is impossible to analyze the impacts of no stated physical projects, just as it is impossible to analyze those unstated projects' impacts on the environmental setting, ie., the proper baseline, because you have no specific locations for these unspecified projects. Thus all you can say is to analyze the entire county. The two most essential parts of an environmental analysis are missing here: specific projects and specific sites. You have the process all backwards here, and thus, commenting on this NOP in any specific manner is impossible. Some background: In 2002, local governments settled lawsuits and agreed to consent decrees and promised to stop violations of bacterial health codes at our beaches by 2021. This agreement gave the public agencies an extension beyond the original deadline of 2013 but only if the projects created new parkland and river corridors that could catch and clean water before it fouled the beaches. In 2006, L.A. City proposed its first big plan under this agreement, an Implementation Plan for the Santa Monica Bay Beaches watersheds. This plan was sent back for redrafting by the RWOCB as it only reached 2% of its target and thus, would not accomplish the goal in the consent decree. Also in 2006, L.A. city proposed the Integrated Resource Plan which mainly focused on building 25 Hyperion -style urban runoff treatment plants which would have cost the average homeowner ratepayer $400 a month. This plan went nowhere. You also were to include identifying a location(s) adjacent to the Oxford Lagoon Bird Conservation Area where a water treatment and recycling facility could be located. This was intended to be a mandatory component of the future, now current, Oxford Basin Multiuse Enhancement Project. The City of Los Angeles Thatcher Maintenance Yard is an ideal location for a facility that could serve Marina del Rey and the Oxford Triangle neighborhood. The Oxford Basin Project should not proceed, including Prop 84 funding, until a recycled water component is included as promised. In 2012, the County Supervisors tried to quietly approve a $300 million per year property tax hike to build a non-existent list of runoff cleansing and capturing projects. Howls of opposition arose and that plan went nowhere. The public wanted to know what they were paying for. Now, you are finally starting to design the cleanup plan. But how can you ask the public to weigh in on the scope of the environmental analysis of that plan, when your description of that plan contains no specifics? Your stated plan to defer the environmental analysis of specific project impacts to when each one is up for approval thus ignores the cumulative impacts and therefore is "piecemealing", by starting major momentum of a project that is composed of many necessary parts, yet deferring analysis and the controversy to a multitude of separate EIRs and CEQA documents and public hearings, all the while public input is diffused. We never get to weigh in on whether we like the complete plan because the Program EIR has no specifics to arouse concern and the real project discussion is delayed until much later in a way that requires massive efforts by the public to keep track of the success of the big plan. The people who will pay for this plan want to see the specifics before you raise our taxes to pay for it. We want expanded and unpaved river corridor parks. We do not want the plan to include converting existing wetlands and wildlife habitat into pollution dumps and sumps. We want what we were promised, not a lame compromise that puts the cleanup burden on existing public lands, parks and house front yards. We want a complete plan for us to judge whether it will accomplish its promises and goals before you produce an EIR, not the other way around. Please put me on the notification list for all actions relating to this project. Respectfully submitted, Douglas Fay 644 Ashland Ave Apt A Santa Monica, CA 90405 email: douglaspfay(a)aol.com Laura Rocha From: Begell, Gregg - Consultant <gbegell@dpw.lacounty.gov> Sent: Monday, September 29, 2014 4:32 PM To: Crumpacker, Andrea; David Pohl; Tom Barnes Subject: FW: COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EIR FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR L.A. COUNTY A clone of Rex's comment. Cj. regg BeGeCCP E Project Manager Project Management Division II From: Donna Murray [mailto:dlmurrav47C@Qmail. coml Sent: Monday, September 29, 2014 4:28 PM To: Begell, Gregg - Consultant Su bj ect: COMMENTS ON NOTI CE OF PREPARATI ON FOR DRAFT PROGRAM EI R FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR L.A. COUNTY You have no specific projects to analyze for environmental impacts. You are attempting to analyze the environmental impact of words, not specific actions. It is impossible to analyze the impacts of no stated physical projects, just as it is impossible to analyze those unstated projects' impacts on the environmental setting, ie., the proper baseline, because you have no specific locations for these unspecified projects. Thus all you can say is to analyze the entire county. The two most essential parts of an environmental analysis are missing here: specific projects and specific sites. You have the process all backwards here, and thus, commenting on this NOP in any specific manner is impossible. Some background: In 2002, local governments settled lawsuits and agreed to consent decrees and promised to stop violations of bacterial health codes at our beaches by 2021. This agreement gave the public agencies an extension beyond the original deadline of 2013 but only if the projects created new parkland and river corridors that could catch and clean water before it fouled the beaches. In 2006, L.A. City proposed its first big plan under this agreement, an Implementation Plan for the Santa Monica Bay Beaches watersheds. This plan was sent back for redrafting by the RWQCB as it only reached 2% of its target and thus, would not accomplish the goal in the consent decree. Also in 2006, L.A. city proposed the Integrated Resource Plan which mainly focused on building 25 Hyperion -style urban runoff treatment plants which would have cost the average homeowner ratepayer $400 a month. This plan went nowhere. In 2012, the County Supervisors tried to quietly approve a $300 million per year property tax hike to build a non-existent list of runoff cleansing and capturing projects. Howls of opposition arose and that plan went nowhere. The public wanted to know what they were paying for. Now, you are finally starting to design the cleanup plan. But how can you ask the public to weigh in on the scope of the environmental analysis of that plan, when your description of that plan contains no specifics? Your stated plan to defer the environmental analysis of specific project impacts to when each one is up for approval thus ignores the cumulative impacts and therefore is "piecemealing", by starting major momentum of a project that is composed of many necessary parts, yet deferring analysis and the controversy to a multitude of separate EIRs and CEQA documents and public hearings, all the while public input is diffused. We never get to weigh in on whether we like the complete plan because the Program EIR has no specifics to arouse concern and the real project discussion is delayed until much later in a way that requires massive efforts by the public to keep track of the success of the big plan. The people who will pay for this plan want to see the specifics before you raise our taxes to pay for it. We want expanded and unpaved river corridor parks. We do not want the plan to include converting existing wetlands and wildlife habitat into pollution dumps and sumps. We want what we were promised, not a lame compromise that puts the cleanup burden on existing public lands, parks and house front yards. We want a complete plan for us to judge whether it will accomplish its promises and goals before you produce an EIR, not the other way around. Please put me on the notification list for all actions relating to this project. Thank you. Donna Murray 8734 Wiley Post Av Los Angeles, CA 90045 Why this ad?Ads — Laura Rocha From: Begell, Gregg - Consultant <gbegell@dpw.lacounty.gov> Sent: Monday, September 29, 2014 4:41 PM To: Crumpacker, Andrea; Tom Barnes; David Pohl Subject: FW: Comments LACFCD SCH 2014081106 NOP Enhanced Watershed Management Programs due 9.29.2014 Here are a few good comments. Are you filing all the comments into a file or folder such that the County can view all the comments in one place? Gregg BeGeCCT E Project Manager Project Management Division II From: Joyce Dillard[mailto:dillardioviceCcDvahoo.coml Sent: Monday, September 29, 2014 4:30 PM To: Begell, Gregg - Consultant Subject: Comments LACFCD SCH 2014081106 NOP Enhanced Watershed Management Programs due 9.29.2014 The Project Description is listed on the State Clearinghouse site as: The development of the EWMP will involve the evaluation and selection of multiple watershed control measures or best management practices (BMP) types including non-structural and distributed, centralized and regional structural BMPs. These BMPs will be implemented to meet compliance goals and strategies under the 2014 MS4 Permit. Structural BMPs involve the construction of a physical control measure to alter the hydrology and/or water quality of incoming stormwater or non-stormwater. The three major functions for structural BMPs are infiltration, water quality treatment, and storage. These are three categories of structural BMPs, defined by the runoff area treated by the BMP and the required retention volume in accordance with the Permit. Comments: Watershed control measures seems to be the emphasis, but that term is not defined. It seems to exclude Watershed Protection Management Measure in areas applicable to the Coastal Zone Act Reauthorization Amendments which recognizes the impact of land -use activities on estuaries, beaches, marine resources and the ocean. Economically feasible measures and greatest degree of pollutant reduction achievable are terms from that Act. All receiving waters should be identified as to type and federal jurisdiction. The project only allows a build environment in a watershed that should have natural lands, ecosystems and normal watershed characteristics Southern California Bight. Antidegradation procedures should be addressed. including ambient water quality standards and the Alternatives should be presented for non-structural or structural projects. Surrounding land uses and settings should be addressed as should settings such as air space in relationship to bird migratory patterns. Ambient air quality should be included. Other public agencies should be included. US Army Corps of Engineers plays a role in navigable waters as does Caltrans in its responsibility for NPDES compliance. Private parties, such as Lauren Bon (Water Rights Draft Permit A032212) should be included. Baselines should be presented. There should be consistency including applications of the various General Plan and its Elements across jurisdictions. Infrastructure should be addressed including but not limited to age, condition and operations and maintenance. Since federal regulations are enforced involving Clean Water Act Navigable Waters, we question why there is no NEPA document preparation. Joyce Dillard P.O. Box 31377 Los Angeles, CA 90031 Laura Rocha From: Begell, Gregg - Consultant <gbegell@dpw.lacounty.gov> Sent: Monday, October 06, 2014 6:59 AM To: Crumpacker, Andrea; David Pohl Subject: FW: COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EIR FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR LA COUNTY Comment Letter. Gregg BeGeCCP E Project Manager Project Management Division II From: patricia me Pherson[mailto:patriciamcpherson1@verizon.net] Sent: Friday, October 03, 2014 1:27 PM To: Begell, Gregg - Consultant Su bj ect: COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EI R FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR LA COUNTY Grassroots Coalition submits its support of the comments made below by Mr. Rex Frankel. Due on the 29th, GC was in transit from out of state and belatedly requests that its support of the comments below be part of the record. Please also note attachment of imagery of California. Currently, the State Coastal Conservancy and the Dept of Fish and Wildlife have created a preordained outcome for the Ballona Wetlands Restoration. This outcome that has been determined to destroy the freshwater aquifers of Ballona (classified as potential drinking water) without the legal requirements of public participation and transparency of process that the millions of dollars of public bond money set forth in 2004. Such destructive plans to the watershed of the Ballona Valley should not be allowed to proceed. The failure of the state to fully engage the public and provide accountability and transparency of process has led to the dire situation of groundwater removal that CAlifomia and Ballona Wetlands have. htto://www.latim es.com/science/sciencenow/la-sci-sn-california-drought-groundwater- satellite-20141002-story. htm I Thank you, Patricia McPherson, President -Grassroots Coalition COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EIR FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR L.A. COUNTY September 29, 2014,1:30 pm From Rex Frankel, director, Ballona Ecosystem Education Project, 6038 west 75" street, L.A. CA 90045 310-738-0861, email: rexfrankel(a)vahoo.com I understand why no one but myself attended the NOP hearing on September 91" in Marina Del Rey. You have no specific projects to analyze for environmental impacts. You are attempting to analyze the environmental impact of words, not specific actions. It is impossible to analyze the impacts of no stated physical projects, just as it is impossible to analyze those unstated projects' impacts on the environmental setting, ie., the proper baseline, because you have no specific locations for these unspecified projects. Thus all you can say is to analyze the entire county. The two most essential parts of an environmental analysis are missing here: specific projects and specific sites. You have the process all backwards here, and thus, commenting on this NOP in any specific manner is impossible. Some background: In 2002, local governments settled lawsuits and agreed to consent decrees and promised to stop violations of bacterial health codes at our beaches by 2021. This agreement gave the public agencies an extension beyond the original deadline of 2013 but only if the projects created new parkland and river corridors that could catch and clean water before it fouled the beaches. In 2006, L.A. City proposed its first big plan under this agreement, an Implementation Plan for the Santa Monica Bay Beaches watersheds. This plan was sent back for redrafting by the RWQCB as it only reached 2% of its target and thus, would not accomplish the goal in the consent decree. Also in 2006, L.A. city proposed the Integrated Resource Plan which mainly focused on building 25 Hyperion -style urban runoff treatment plants which would have cost the average homeowner ratepayer $400 a month. This plan went nowhere. In 2012, the County Supervisors tried to quietly approve a $300 million per year property tax hike to build a non-existent list of runoff cleansing and capturing projects. Howls of opposition arose and that plan went nowhere. The public wanted to know what they were paying for. Now, you are finally starting to design the cleanup plan. But how can you ask the public to weigh in on the scope of the environmental analysis of that plan, when your description of that plan contains no specifics? Your stated plan to defer the environmental analysis of specific project impacts to when each one is up for approval thus ignores the cumulative impacts and therefore is "piecemealing", by starting major momentum of a project that is composed of many necessary parts, yet deferring analysis and the controversy to a multitude of separate EIRs and CEQA documents and public hearings, all the while public input is diffused. We never get to weigh in on whether we like the complete plan because the Program EIR has no specifics to arouse concern and the real project discussion is delayed until much later in a way that requires massive efforts by the public to keep track of the success of the big plan. The people who will pay for this plan want to see the specifics before you raise our taxes to pay for it. We want expanded and unpaved river corridor parks. We do not want the plan to include converting existing wetlands and wildlife habitat into pollution dumps and sumps. We want what we were promised, not a lame compromise that puts the cleanup burden on existing public lands, parks and house front yards. We want a complete plan for us to judge whether it will accomplish its promises and goals before you produce an EIR, not the other way around. Please put me on the notification list for all actions relating to this project. Thank you Laura Rocha From: Begell, Gregg - Consultant <gbegell@dpw.lacounty.gov> Sent: Tuesday, October 14, 2014 4:06 PM To: Crumpacker, Andrea; David Pohl Subject: FW: Restoration of Baldwin Lake Comment for record Gregg BeGeffT E Project Manager Project Management Division II From: Jane Florentinus [mailto:iava5(Watt.net l Sent: Tuesday, October 14, 2014 1:23 PM To: Begell, Gregg - Consultant Subject: Restoration of Baldwin Lake Hello Mr. BeGell, I am a volunteer and member of the Arboretum located in Arcadia and would like to express my concern for the poor condition of the lake. As a volunteer docent I provide guided walks through the gardens as well as the lake perimeter. Visitors are dismayed and saddened to see the decline of such a great and wonderful treasure in the midst of our urban lifestyle. To have open space in our crowded communities is truly a rarity and must be preserved for future generations to appreciate. Please take my request for restoring the lake to heart. Thank you for reading my message. Jane Florentinus 7140 Hidden Pine Drive San Gabriel, CA 91775 Copy of email sent to G. Osmena Laura Rocha From: Osmena, Genevieve <gosmena@dpw.lacounty.gov> Sent: Monday, November 10, 2014 10:03 AM To: Dale or Miriam Carter Subject: RE: Baldwin Lake/Enhanced Watershed Management Plan Mr. Carter, Thank you for your email regarding Baldwin Lake at the LA Arboretum. I have added your contact information to the stakeholder list for the Rio Hondo/San Gabriel River Water Quality Group to receive notifications of future stakeholder meetings regarding the group's Enhanced Watershed Management Program (EWMP). We anticipate the next stakeholder meeting to occur in early to mid -Spring of next year to discuss the progress of the EWMP process with interested stakeholders. I have also forwarded your email to the group members for their consideration as they continue to discuss and develop their EWMP plan. Thanks again for your comments. Genevieve Osmeha, P.E. County of Los Angeles Department of Public Works East Unincorporated County M54 Permit Compliance Watershed Management Division (626) 458-3978 gosmena@dpw.locoun ty. gov From: Dale or Miriam Carter [mailto:dmcart(a)att.net l Sent: Wednesday, October 29, 2014 5:01 PM To: Begell, Gregg - Consultant; Osmena, Genevieve Cc: Snider Sandy; Schulhof Richard Subject: Baldwin Lake/Enhanced Watershed Management Plan Dear Mr. Begell and Ms. Osmena This message is to encourage you to include the restoration of the Los Angeles County Arboretum's Baldwin Lake as a part of the Enhanced Watershed Management Plan for the Rio Hondo Watershed. To me, the following points emphasize the importance of this lake: It is one of the very few lakes easily accessible to the public in the San Gabriel Valley area, or even the Los Angeles basin It is an important environmental asset to the wildlife that is in or passes through the San Gabriel Valley It has historical significance regarding E.J. Baldwin's life as the founder of the city of Arcadia It has historical significance pertaining to the entertainment industry as a movie and TV location, and consequently is a tourist attraction It is geologically important and interesting as the last (I think) remaining sag pond along the Raymond earthquake fault I encourage you to support restoring and including the lake in whatever watershed management plans evolve. Regards, Dale Carter Arboretum volunteer and docent pQOF PIANti.�4Y (04;X STATE OF CALIFORNIAOF Governors Office of Planning and Research State Clearinghouse and Planning unit Ken Alex Edmund G. Broom Sr. Director Governor Vr Notice of Preparation t t August 29, 2014d} y S 1 0 9 `' t To: Reviewing Agencies Re: Enhanced Watershed Management Programs (EWMP) Program EIR SCH# 2014081106 Attached for your review and comment is the Notice of Preparation (NOP) for the Enhanced Watershed Management Programs (EWMP) Program EIR draft Environmental Impact Repoli (EIR). Responsible agencies must transmit their comments on the scope and content of the NOP, focusing on specific information related to their own statutory responsibility, within 30 days of receipt of the NOP from the Lead A enc . This is a courtesy notice provided by the State Clearinghouse with a reminder for you to comment in a timely marmer. We encourage other agencies to also respond to this notice and express their concerns early in the environmental review process. Please direct your comments to: Gregg BeGell Los Angeles County Flood Control District 900 South Fremont Avenue, 11th Floor Alhambra, CA 91803 with a copy to the State Clearinghouse in the Office of Planning and Research. Please refer to the SCH number noted above in all correspondence concerning this project. If you have any questions about the enviromnental document review process, please call the State Clearinghouse at (916) 445-0613. Sincerely, y Scot orgazi Director, State Clearinghouse Attachments cc: Lead Agency 1400 TENTH STREET P.O. BOR 3044 SACRAMENTO, C_ALIFORNLA 95512-3044 TEL (916) 445-0613 FAX (916) 323-3018 www opnca.gov Document Details Report State Clearinghouse Data Base SCH# 2014081106 Project Title Enhanced Watershed Management Programs (EWMP) Program EIR Lead Agency Los Angeles County Flood Control District Type NOP Notice of Preparation Description The development of the EWMP will involve the evaluation and selection of multiple watershed control measures or best management practices (BMP) types including non-structural and distributed, centralized and regional structural BMPs. These BMPs will be implemented to meet compliance goals and strategies under the 2014 MS4 Permit. Structural BMPs involve the construction of a physical control measure to alter the hydrology and/or water quality of incoming stormwater or non-stormwater. The three major functions for structural BMPs are infiltration, water quality treatment, and storage. These are three categories of structural BMPs, defined by the runoff area treated by the BMP and the required retention volume in accordance with the Permit. Lead Agency Contact Name Gregg BeGell Agency Los Angeles County Flood Control District Phone 626 300 3298 Fax email Address 900 South Fremont Avenue, 11th Floor City Alhambra State CA Zip 91803 Project Location County Los Angeles City Los Angeles, City of Region Cross Streets Throughout Los Angeles County Lat/Long Parcel No. Various Township Range Section Base Proximity to: Highways Various Airports LAX, Burbank Railways Various Waterways Various ' Schools Various Land Use Various land uses throughout the County Project Issues AestheticNisual; Agricultural Land; Air Quality; Archaeologic -Historic; Biological Resources; Drainage/Absorption; Flood Plain/Flooding; Geologic/Seismic; Minerals; Noise; Population/Housing Balance; Public Services; Recreation/Parks; Soil Erosion/Compaction/Grading; Toxic/Hazardous; Traffic/Circulation; Water Quality; Vegetation; Water Supply; Wetland/Riparian; Wildlife; Cumulative Effects; Other Issues Reviewing Resources Agency; Coachella Valley Mountains Conservancy; Department of Parks and Recreation; Agencies Department of Water Resources; Department of Fish and Wildlife, Headquarters; Department of Fish and Wildlife, Marine Region; Native American Heritage Commission; Santa Monica Bay Restoration; Caltrans, District 7; Air Resources Board; State Water Resources Control Board, Division of Water Quality; State Water Resources Control Board, Division of Water Rights; Regional Water Quality Control Board, Region 4; San Gabriel & Lower Los Angeles Rivers & Mountains Conservancy; Santa Monica Mountains Conservancy Date Received 08/29/2014 Start of Review 08/29/2014 End of Review 09/29/2014 T r�• C _ mo O C O m 0 N U c t o L L O U U C ° v v T U T C N Y ^ m N V LL= K N Lu >Cc m k (p c v oc 0 m> m m% m ca ° o y m y U m° U M C C U c 2 m c C eF attnm Nm Mau m« v m'✓, m y� m>' 3p m 3 m p m o' 3 m15 anCOd y C3 '� r U U° U c N U m Uay Um d'Uti U(Y U f1 .�> U U OCA Q=m O0 0 a0 d0 0 M O m U Qm CJo t S c L71 0 O. a li fL N¢ m 2' C 6' m CL m CL ❑ O U > O C 0 �r❑ Oi m o com m mo m m o m m� a .c ❑Uz❑wUm❑U�®U ❑ M 0 � ❑U❑v�v� ❑ -! a N� Q N d' m k� � o c c c c m m U U O o y >. 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Ld o c c ry w w� LLm?� a u m m vouc2 �a o - m>iZ ®UU W UL Cl LU UUw UO U o.� Oaf 0 0 0 U ��w 006 ❑ O:Kz OU W ii❑ O �Z ❑ ® ❑ ❑ ❑ ❑ Cl ❑ OWIn❑ ❑ LL ❑ ELIZABETH BYRNE DEBREU 777 Arden Road Pasadena, California 91106 October 8, 2014 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont, 51h Floor Alhambra, CA 91803 Via Email: gbegett@dpw.lacounty.gov Re: Restoration of Baldwin Lake Dear Mr. BeGell: I write to urge you to make the restoration of Baldwin Lake a high priority as you lead the effort to create the EWMP for the Rio Hondo Watershed. The restoration of Baldwin Lake, including modifications to the depth of the lake and adaptation of Tule Pond as a bioswale, would enhance Baldwin Lake's water quality and give it a more significant water collection function while simultaneously enhancing its scenic, educational, and historic value at the center of the Los Angeles County Arboretum and Botanic Garden. The restored lake would also provide an exceptional opportunity to educate the public about regional water management, home and community water conservation, and the role of the Raymond Basin and the other water resources in sustaining us. It is a key resource that serves over 330,000 visitors per year, including more than 16,000 elementary school students on field trips. As a member of the board of the Los Angeles Arboretum Foundation, the County's non-profit partner in operating the Arboretum, I stand ready to help leverage public dollars to realize Baldwin Lake's unique potential to provide direct public benefit in a multitude of ways. It is the ideal project both to enhance the watershed function and serve the public with remarkable educational, ecological, and scenic benefits. I respectfully submit that the County include the Baldwin Lake in the Rio Hondo Enhanced Watershed Management Plan. Very truly yours, Elizabeth Byrne Debreu Board Member, Los Angeles Arboretum Foundation Laura Rocha From: Osmena, Genevieve <gosmena@dpw.lacounty.gov> Sent: Monday, November 10, 2014 10:03 AM To: Dale or Miriam Carter Subject: RE: Baldwin Lake/Enhanced Watershed Management Plan Mr. Carter, Thank you for your email regarding Baldwin Lake at the LA Arboretum. I have added your contact information to the stakeholder list for the Rio Hondo/San Gabriel River Water Quality Group to receive notifications of future stakeholder meetings regarding the group's Enhanced Watershed Management Program (EWMP). We anticipate the next stakeholder meeting to occur in early to mid -Spring of next year to discuss the progress of the EWMP process with interested stakeholders. I have also forwarded your email to the group members for their consideration as they continue to discuss and develop their EWMP plan. Thanks again for your comments. Genevieve Osmeha, P.E. County of Los Angeles Department of Public Works East Unincorporated County M54 Permit Compliance Watershed Management Division (626) 458-3978 gosmena@dpw.locoun ty. gov From: Dale or Miriam Carter [mailto:dmcart(a)att.net l Sent: Wednesday, October 29, 2014 5:01 PM To: Begell, Gregg - Consultant; Osmena, Genevieve Cc: Snider Sandy; Schulhof Richard Subject: Baldwin Lake/Enhanced Watershed Management Plan Dear Mr. Begell and Ms. Osmena This message is to encourage you to include the restoration of the Los Angeles County Arboretum's Baldwin Lake as a part of the Enhanced Watershed Management Plan for the Rio Hondo Watershed. To me, the following points emphasize the importance of this lake: It is one of the very few lakes easily accessible to the public in the San Gabriel Valley area, or even the Los Angeles basin It is an important environmental asset to the wildlife that is in or passes through the San Gabriel Valley It has historical significance regarding E.J. Baldwin's life as the founder of the city of Arcadia It has historical significance pertaining to the entertainment industry as a movie and TV location, and consequently is a tourist attraction It is geologically important and interesting as the last (I think) remaining sag pond along the Raymond earthquake fault I encourage you to support restoring and including the lake in whatever watershed management plans evolve. Regards, Dale Carter Arboretum volunteer and docent Laura Rocha From: Begell, Gregg - Consultant <gbegell@dpw.lacounty.gov> Sent: Monday, September 29, 2014 4:32 PM To: Crumpacker, Andrea; David Pohl; Tom Barnes Subject: FW: COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EIR FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR L.A. COUNTY A clone of Rex's comment. Cj. regg BeGeCCP E Project Manager Project Management Division II From: Donna Murray [mailto:dlmurrav47C@Qmail. coml Sent: Monday, September 29, 2014 4:28 PM To: Begell, Gregg - Consultant Su bj ect: COMMENTS ON NOTI CE OF PREPARATI ON FOR DRAFT PROGRAM EI R FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR L.A. COUNTY You have no specific projects to analyze for environmental impacts. You are attempting to analyze the environmental impact of words, not specific actions. It is impossible to analyze the impacts of no stated physical projects, just as it is impossible to analyze those unstated projects' impacts on the environmental setting, ie., the proper baseline, because you have no specific locations for these unspecified projects. Thus all you can say is to analyze the entire county. The two most essential parts of an environmental analysis are missing here: specific projects and specific sites. You have the process all backwards here, and thus, commenting on this NOP in any specific manner is impossible. Some background: In 2002, local governments settled lawsuits and agreed to consent decrees and promised to stop violations of bacterial health codes at our beaches by 2021. This agreement gave the public agencies an extension beyond the original deadline of 2013 but only if the projects created new parkland and river corridors that could catch and clean water before it fouled the beaches. In 2006, L.A. City proposed its first big plan under this agreement, an Implementation Plan for the Santa Monica Bay Beaches watersheds. This plan was sent back for redrafting by the RWQCB as it only reached 2% of its target and thus, would not accomplish the goal in the consent decree. Also in 2006, L.A. city proposed the Integrated Resource Plan which mainly focused on building 25 Hyperion -style urban runoff treatment plants which would have cost the average homeowner ratepayer $400 a month. This plan went nowhere. In 2012, the County Supervisors tried to quietly approve a $300 million per year property tax hike to build a non-existent list of runoff cleansing and capturing projects. Howls of opposition arose and that plan went nowhere. The public wanted to know what they were paying for. Now, you are finally starting to design the cleanup plan. But how can you ask the public to weigh in on the scope of the environmental analysis of that plan, when your description of that plan contains no specifics? Your stated plan to defer the environmental analysis of specific project impacts to when each one is up for approval thus ignores the cumulative impacts and therefore is "piecemealing", by starting major momentum of a project that is composed of many necessary parts, yet deferring analysis and the controversy to a multitude of separate EIRs and CEQA documents and public hearings, all the while public input is diffused. We never get to weigh in on whether we like the complete plan because the Program EIR has no specifics to arouse concern and the real project discussion is delayed until much later in a way that requires massive efforts by the public to keep track of the success of the big plan. The people who will pay for this plan want to see the specifics before you raise our taxes to pay for it. We want expanded and unpaved river corridor parks. We do not want the plan to include converting existing wetlands and wildlife habitat into pollution dumps and sumps. We want what we were promised, not a lame compromise that puts the cleanup burden on existing public lands, parks and house front yards. We want a complete plan for us to judge whether it will accomplish its promises and goals before you produce an EIR, not the other way around. Please put me on the notification list for all actions relating to this project. Thank you. Donna Murray 8734 Wiley Post Av Los Angeles, CA 90045 Why this ad?Ads — STATE OF CALIFORNIA—BUSINESS TRANSPORTATION AND HOUSING AGENCY EDMUND C BROWN Jr.G DEPARTMENT OF TRANSPORTATION DISTRICT 7 -OFFICE OF TRANSPORTATION PLANNING 100 S. MAIN STREET, MS 16 LOS ANGELES, CA 90012 PHONE (213) 897-9140 FAX (213) 897-1337 www.dot.ca.gov September 29, 2014 Mr. Gregg BeGell County of Los Angeles Dept. of Public Works Project Management Division II 900 South Fremont Avenue, 5 h Floor Alhambra, CA 91803 Dear Mr. BeGell: Serious drought. Help save water! Re: Enhanced Watershed Management Programs Notice of Preparation IGR#140912FL Vic.: LANarious watersheds locations Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above referenced project. The proposed project will prepare a Program Environmental Impact Report (PEIR) for the project identified, such as the 12 separate Enhanced Watershed Management Programs (EWMPs); it will be prepared as a collective effort among the Los Angeles County Flood Control District (LACFCD) and the applicable agencies in each respective EWMP. We would like to remind you that storm water run-off is a sensitive issue for Los Angeles and Ventura counties. Please be mindful that projects need to be designed to discharge clean run-off water. Any work to be performed within the State Right-of-way will need an Encroachment Permit and any transportation of heavy construction equipment and/or materials which requires the use of oversized - transport vehicles on State highways will require a Caltrans transportation permit. We recommend that large size truck trips be limited to off-peak commute periods. hl addition, a truck/traffic construction management plan is needed for this project. If you have any questions, please feel free to contact me at (213) 897-9140 or project coordinator Frances Lee at (213) 897-0673 or electronically at frances.leekdot.ca.gov. Sincerely, ,' _� DIANNA WATSON Branch Chief, Community Planning & LD IGR Review cc: Scott Morgan, State Clearinghouse "Provide a safe, sustainable, integrated and efficient transportation system to enhance California's economy and livability" Laura Rocha From: Begell, Gregg - Consultant <gbegell@dpw.lacounty.gov> Sent: Tuesday, September 30, 2014 7:08 AM To: Crumpacker, Andrea; David Pohl; Bellizia, Thomas W. Subject: FW: COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EIR FOR EWMP'S FOR L.A. COUNTY Another clone Gregg BeGeCCP E Project Manager Project Management Division II From: douglaspfav(yaol.com [mai Ito: douglaspfay(a�aol.corn Sent: Monday, September 29, 2014 9:19 PM To: Begell, Gregg - Consultant Cc: rexfrankel(a)vahoo.com Su bj act: COMMENTS ON NOT] CE OF PREPARATI ON FOR DRAFT PROGRAM EI R FOR EINMPS FOR L.A. COUNTY Dear DWP Representatives and Interested Parties, I understand why no one but Rex Frankel attended the NOP hearing on September V in Marina Del Rey. You have no specific projects to analyze for environmental impacts. You are attempting to analyze the environmental impact of words, not specific actions. It is impossible to analyze the impacts of no stated physical projects, just as it is impossible to analyze those unstated projects' impacts on the environmental setting, ie., the proper baseline, because you have no specific locations for these unspecified projects. Thus all you can say is to analyze the entire county. The two most essential parts of an environmental analysis are missing here: specific projects and specific sites. You have the process all backwards here, and thus, commenting on this NOP in any specific manner is impossible. Some background: In 2002, local governments settled lawsuits and agreed to consent decrees and promised to stop violations of bacterial health codes at our beaches by 2021. This agreement gave the public agencies an extension beyond the original deadline of 2013 but only if the projects created new parkland and river corridors that could catch and clean water before it fouled the beaches. In 2006, L.A. City proposed its first big plan under this agreement, an Implementation Plan for the Santa Monica Bay Beaches watersheds. This plan was sent back for redrafting by the RWOCB as it only reached 2% of its target and thus, would not accomplish the goal in the consent decree. Also in 2006, L.A. city proposed the Integrated Resource Plan which mainly focused on building 25 Hyperion -style urban runoff treatment plants which would have cost the average homeowner ratepayer $400 a month. This plan went nowhere. You also were to include identifying a location(s) adjacent to the Oxford Lagoon Bird Conservation Area where a water treatment and recycling facility could be located. This was intended to be a mandatory component of the future, now current, Oxford Basin Multiuse Enhancement Project. The City of Los Angeles Thatcher Maintenance Yard is an ideal location for a facility that could serve Marina del Rey and the Oxford Triangle neighborhood. The Oxford Basin Project should not proceed, including Prop 84 funding, until a recycled water component is included as promised. In 2012, the County Supervisors tried to quietly approve a $300 million per year property tax hike to build a non-existent list of runoff cleansing and capturing projects. Howls of opposition arose and that plan went nowhere. The public wanted to know what they were paying for. Now, you are finally starting to design the cleanup plan. But how can you ask the public to weigh in on the scope of the environmental analysis of that plan, when your description of that plan contains no specifics? Your stated plan to defer the environmental analysis of specific project impacts to when each one is up for approval thus ignores the cumulative impacts and therefore is "piecemealing", by starting major momentum of a project that is composed of many necessary parts, yet deferring analysis and the controversy to a multitude of separate EIRs and CEQA documents and public hearings, all the while public input is diffused. We never get to weigh in on whether we like the complete plan because the Program EIR has no specifics to arouse concern and the real project discussion is delayed until much later in a way that requires massive efforts by the public to keep track of the success of the big plan. The people who will pay for this plan want to see the specifics before you raise our taxes to pay for it. We want expanded and unpaved river corridor parks. We do not want the plan to include converting existing wetlands and wildlife habitat into pollution dumps and sumps. We want what we were promised, not a lame compromise that puts the cleanup burden on existing public lands, parks and house front yards. We want a complete plan for us to judge whether it will accomplish its promises and goals before you produce an EIR, not the other way around. Please put me on the notification list for all actions relating to this project. Respectfully submitted, Douglas Fay 644 Ashland Ave Apt A Santa Monica, CA 90405 email: douglaspfay(a)aol.com October 16, 2014 Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 (626)300-3298 gbegell@dpw.lacounty.gov Enrique Huerta At -Large Stakeholder 7345 Nada Street Downey, CA 90242 ehuerta28@gmail.com (323)573-0129 RE: Public Comments: Notice of Preparation of a Draft Program Environmental Impact Report for Enhanced Watershed Management Programs Dear Mr. BeGell: Thank you for your efforts on the Notice of Preparation (NOP) for the Draft Program Environmental Impact Report for the Enhanced Watershed Management Programs (EWMP). I am confident your work will result in an informative and precise first tier final Program Environmental Report (PEIR) that is adequate, complete, and a good faith effort at full disclosure. The purpose of my comments, per Section 15168(c)(5) of the 2014 California Environmental Quality Act (CEQA) Statute and Guidelines, is to assist in the creation of a PEIR "that deals with the effects of the program as specifically and comprehensively as possible." Additionally, I realize that by doing "a good and detailed analysis of the program, many subsequent activities could be found to be within the scope of the project described in the program EIR, and no further environmental documents would be required." I recognize and appreciate the herculean task involved for the Flood Control District and it is my sincere attempt to keep my comments relevant to the NOP. As such, I have attempted to draft my comments in a reader -friendly manner that identify the issue and propose a feasible solution(s). My comments only address the content of the NOP. COMMENTS ON THE CONTENT OF THE NOP 1. Introduction (Page No. 2) Please elaborate on the approval process. It would be informative if the role between the Los Angeles County Flood Control District (LACFCD) and the Los Angeles Regional Water Quality Control Board (LARWQCB) is further explained. The introduction does a good job explaining the steps involved in the EWMP process, but lacks clarity on the connection between the PEIR and LARWQCB. In particular, the sentence in mind states, "The LARWQCB is responsible for approval of the EWMPs in compliance with the MS4 Permit. Implementation of the EMWPs would occur following approval by the LARWQCB." If the LARWQCB approves the EWMPs then who adopts the final PEIR? How does this PEIR fit into the responsibilities and mandates of the LARWQCB? All 12 of the EWMPs specify a date when the final EWMPs will be submitted (June 2015) to the LARWQCB, but no mention is made about the PEIR. Will the Lead Agency submit a EWMP packet on behalf of all 12 EWMPS and will the PEIR be a part of that packet? In addition, the NO1 submitted to the LARWQCB by each Watershed Management Group (WMG) span two programs: the EWMPs 'and' Coordinated Integrated Monitoring Programs (CIMP). Does this PEIR also analyze the CIMP? (Page 5) The opening paragraph states that "The primary approach to each of the EWMPs, as identified in the Draft Work Plans, includes identifying community -friendly, cost- effective methods of reducing urban runoff pollution and incorporating distributed and centralized structural and nonstructural watershed control measures for a multi -pollutant, multi -benefit approach." However, a review of all 12 EWMPs indicates that there was no cost/benefit analysis completed to substantiate the "cost-effectiveness" of these methods. Please identify any additional documentation supporting this claim. (Page No. 5) Please clarify the use of the term "project." The final sentence in the first paragraph states, "The EWMPs will also evaluate multi -benefit regional projects that will retain (through infiltration or capture and reuse) the stormwater quality design volume (85th percentile storm for 24 hours) for the runoff from the contributing drainage area." Evaluating, I'm assuming site -level projects with regional benefits, at the PEIR level increases the dissonance between the goal of an EIR, as Section 21002.1(d) of the CEClA Statute states, "to consider the effects, both individual and collective, of all activities involved in a project," and the inherent collective geographic scope of the PEIR. I reviewed all 12 of the EWMPs and CIMPs. All 12 of the EWMPs do not identify projects currently in the works and no analysis is provided. The EWMPs seem to be evaluating plans and policies. Clarification of the term project would be beneficial in order to clearly understand the scope of this PEIR. In addition, Section 21003 states that, "All persons and public agencies involved in the environmental review process be responsible for carrying out the process in the most efficient, expeditious manner in order to conserve the available financial, governmental, physical, and social resources with the objective that those resources may be better applied toward the mitigation of actual significant effects on the environment." In an effort to avoid the possibility of imposing an unfunded mandate on local cities and/or non-profit groups to undertake the second tier of this PEIR, the prudent use of public funds, and to promote a second tier CEClA process that is streamlined, I feel it would be beneficial to incorporate an analysis of current projects in the "pipeline." This is critical because a review of the Greater Los Angeles County Integrated Regional Water Management (IRWM) database reveals over 190 water resources projects with regionally -significant benefits in the pipeline (Appendix A). The IRWM is a funding mechanism that encourages regional and local collaboration in the design of sustainable water resources infrastructure. To date, regional agencies, cities, non -profits and community representative groups, have collaborated and submitted project proposals of regional significance. Not all of these projects incorporate BMPs, per say (many do), and many have already been deemed categorically exempt. Additional vetting would need to take place in order to identify projects in-line with a low impact development ideal to collaborate and integrate compliance strategies that are based on a multi -pollutant approach with a focus on green infrastructure that maximize the retention and use of urban runoff as a resource for recharging aquifers and for irrigation and other uses. If this nexus to analyze the impacts of regional projects is deemed reasonably feasible, further vetting of the projects would be required to understand their CEQA status. The question is who conducts this analysis, the LACFCD or the WMGs? This is important to figure out since Section 15152(b) of the CEQA Statute and Guidelines states that, "Tiering does not excuse the lead agency from adequately analyzing reasonably foreseeable significant environmental effects of the project and does not justify deferring such analysis to a later tier EIR or negative declaration." (Page 5) The second paragraph states, "The PER will provide a program -level assessment of the overall permit compliance effort, focusing particularly on the structural watershed control measures proposed in each of the 12 EWMP areas." The project list on Appendix A identifies projects aiming to implement watershed control measures throughout Los Angeles County. Many of these projects are categorically exempt, have concluded their own environmental assessment or already constructed, however, the database (L.A. County Water Plan) where I retrieved these does not clearly indicate this information. Furthermore, none of the 12 EWMPs under consideration undertook this task to see how the proposed physical changes within their EWMP may or may not comply with the goals and objectives of their 13 respective plans and policies. In an effort to, as Section 15152© describes, "avoid deferring the potential significant impacts to the second tier and possibly preventing the adequate identification of significant effects of the planning approval at hand," it may be worthwhile to include this list in the PEIR analysis or have the WMGs revise their draft plans to incorporate this analysis. 1.1 Project Location The description of the location could be augmented by elaborating on the environmental context. That is, adding maps identifying the tributaries, rivers, channels, etc. within the 12 watersheds could increase understanding of the local watershed functional characteristics. This detailed information is contained in most of the individual EWMPs. A reference to the website location of each respective EWMP could suffice. Additionally, there is no reference to the types of soils that underlie the 12 EWMPS. The EWMPS provide a summary of these soil characteristics. A reference to the website location of each respective EWMP would be helpful. It is important to know the soil types and their respective infiltration rates in order to understand the feasibility of implementing certain structural BMPs. I realize that this may be covered in more depth under the Geology, Soils and Seismicity category, but there is no clear reference in the accompanying summary. 2. BACKGROUND 2.1 Stormwater/Water Quality (Page 7) The first paragraph states, "Discharges may adversely affect receiving surface water quality with pollutants such as bacteria, nutrients (nitrogen and phosphorus), aluminum, copper, lead, zinc, diazinon, and cyanide. Aquatic toxicity, particularly during wet weather, is also a concern. Stormwater and non-stormwater discharges of debris and trash are also a pervasive water quality problem in the Los Angeles region." It would be beneficial to add the types of pollution stemming from the natural environment (non -anthropogenic), too. What kind of pollutants exists in the soils being eroded from natural settings and vacant parcels of land? 2.2 Total Maximum Daily Loads The final sentence in this paragraph states, "LARWQCB and United States Environmental Protection Agency (USEPA) have established 33 TMDLs that identify Los Angeles County MS4 discharges as one of the pollutant sources causing or contributing to these water quality impairments." Please elaborate on the NPDES permit process. Is there a need for discretionary approval of the EWMPs or PEI by the USE PA? Is there a need for the USE PA to issue a TMDL or other permit? If so, is there a need to do a concurrent Environmental Impact Statement? 2.3 MS4 Permit (Page 8) This section states. "The intent of the EWMP is to comprehensively evaluate opportunities, within the participating Permittees' collective jurisdictional boundaries, for collaboration among Permittees and other partners on multi -benefit regional projects that, wherever feasible, retain non-stormwater runoff and also address flood control and/or water supply." Has the United States Army Corp of Engineers (USACE) been a part of these collaborative efforts? Are any of their existing infrastructure being directly or indirectly impacted by the EWMPs? Is there a need for discretionary approval of the EWMPs or PEIR by the USACE? Is there a need for the USACE to issue a permit related to the EWMPs? If so, is there a need to do a concurrent Environmental Impact Statement? 3. Enhanced Watershed Management Plans As mentioned in the first comment under the Introduction heading, please elaborate on the approval process. Specifically, how the PEIR fits into the LARWQCBs approval of the EWMPs. 4.1.1 Regional Structural BMPs The second paragraph states, "Opportunities for Regional BMPs will be identified and evaluated within and across subwatersheds, with focus on the multi -benefit potential for capture and reuse of wet -weather flows within variable drainage areas." What method and level of detail will be used to identify and evaluate BMPs? This paragraph goes on to state that, "Potential project locations may include areas with open spaces, whether they are within parks, large parking lots, or vacant spaces," indicating that a geographically site-specific analysis is appropriate under this PEIR. Collectively, there is over 190 regional projects identified in Appendix A being proposed by the various members of the WMGs. Based on the site-specific potential project locations stated above, is it feasible to include an analysis of the project list (Appendix A)? Potential Environmental Impacts This section (nor the LACoH2Osheds website) does not reference the completion of an Initial Study per Section 15063©(1). How did the Lead Agency identify the effects determined not to be significant? Is there an explanation of the reasons for determining that potentially significant effects would not be significant? Sincerely, Enrique Huerta, M.S. Appendix A Comment Letter to the LACFCD: Draft PEIR Project Name Project Proponent Project Description The project proposes to construct a 25mgd Seawater Desalination Plant in West Basin's service area for potable water use. First, a Demonstration Plant will be necessary to evaluate the water quality performance and treatment stability, assess efficient energy recovery devices, optimize operational performance utilizing full scale process equipment, and to acquire the necessary data to achieve regulatory compliance and approval. West Basin and its 1 25 mad Sea Water Desalinization West Basin Municipal partners will perform the full battery of water quality analyses Plant in West Basin Water District to ensure that the demonstration project meets all Federal and State Drinking Water Standards. With the knowledge gained by operating the Demonstration Plant, West Basin expects to move forward with the planning, design, and construction of a full scale 25,000 AFY seawater desalination and education facility. West Basin anticipates operating the Demonstration Plant for at least two years while plans are being completed and finalized for the full- scale plant. The Demonstration Facility is in design. The project consists of replacing the older water meters in Waterworks District No. 29. The District maintains approximately 7,700 water meters in Malibu and Topanga. About 40 percent of the meters are older than 15 years and 30 percent are 20 years or older. Meters lose accuracy over time, representing unaccounted water consumption in the District. Older meters typically under -measure water use. Los Angeles County Replacing old water meters with automated meter reading 2 AMR Conversion Project Waterworks District No. (AMR) meters will yield timely, reliable water consumption 29 patterns for detecting leaks and producing accurate customer bills. Higher bills with higher water use volumes will alert District customers about their water consumption habits, which is expected to encourage conservation. The current practice is to replace meters as the meters stop functioning or become unreadable. About 20% of the water meters in Malibu and Topanga have been replaced with AMR meters. The project would extend the existing recycled water line along Agoura Road to serve existing customers who use potable waterfor landscape irrigation. Pipeline forthis project is estimated at 9250 feet of 8 inch pipe and would 3 Agoura Road Gap Recycled Water Las Virgenes Municipal connect to existing recycled water pipelines on both east System Expansion Water District and west sides of the extension. This would connect the gap that exists between Reyes Adobe Road and Lewis Road and improve the system hydraulics and reliability of service to customers. The estimated maximum daily demand for the Agoura Road Extension is 73 gpm. Appendix A Comment Letter to the LACFCD: Draft PER Restore 20 acres at Ague Amarga Reserve, to provide habitat for the Federally threatened Coastal California gnatcatcher, the Federally endangered Palos Verdes blue butterfly, and the rare cactus wren. A one -mile trail in the Reserve continues to the coast. A year-round flow of water is discharged to the head of Lunada Canyon via a County of Los Angeles storm drain; the water then flows below ground Palos Verdes Peninsula through the canyon, the course of an historic blue line 4 Aqua Amarga Lunada Canyon Land Conservancy &City stream, and re-emerges at its confluence with Ague Amarga Habitat Restoration of Rancho Palos Verdes Canyon, also a blue -line stream that flows into the Santa Monica Bay. Invasive plant species provide little water infiltration and threaten to spread to the pristine lower canyon. The project will remove invasive plants, restore 18 acres of riparian and coastal sage scrub; install 2 acres of cactus scrub in highly degraded fuel modification areas; improve trails and add trail signage. Interpretive signage will educate hikers about creating wildlife -friendly fuel modification zone. Stormwater runoff would be diverted from Aliso Creek and from Limekiln Creek and stormwater runoff generated on site will be treated. In addition to providing water quality benefits, the project will result in the creation of self-sustaining riparian woodland vegetation and other re -vegetated areas, as well as providing recreational opportunities to area residents.The site has an area of approx. 11.8 acres and is City of Los Angeles currently used as a flood control facility, provides open 5 Aliso Creek - Limekiln Creek Bureau of Sanitation space, and serves as part of Vanalden Park.Wet weather Restoration Project Watershed Protection runoff and dry weather runoff from an approx. 12,091 acres Division that drains to the confluence of Aliso Creek and Limekiln Creek is going to be captured and conveyed to the project site for treatment.On-site generated flows will also be captured and treated.Proposed BMPs to treat captured water:Low flow channel diversions and pumping:Pre- screening devices, Bioswales, Vegetated detention basins, Landscaping with native upland and riparian species and Installing decomposed granite pathways. Alondra Regional Park is a multi -benefit project that serves disadvantaged communities while meeting IRWMP water management objectives. The entire site is currently an empty 18 -acre lot owned by the City of Compton. This proposal is for Phase I of the project and covers 12 acres on the southern half of the parcel. The park provides recreational opportunities while improving surface water discharges into the Dominguez Channel Watershed. The project site sits low 6 Alondra Regional Park Successor Agency, City of on the drainage area and will capture 1.5AF of stormwater. Compton The park features a swale and daylighted stream to remove nutrients and pollutants that otherwise flow to local waterways. The large biofiltration field will reduce peak flows, improve water quality and occasionally serve as a recreational field. Surface water quality improvements would help the region meet requirements under the Municipal Separate Storm Sewer System Permit. The project also includes native shrubs and trees that will increase habitat for birds, butterfly species and mammals. Appendix A Comment Letter to the LACFCD: Draft PEIR As with the original Decker Canyon Recycled Water Extension pipeline route, this alternate would primarily serve the Malibu Golf Club, the largest potable water user in the LVMWD service area. The 2007 Master Plan advocated that serving the golf course with recycled water could be an important strategy for relieving eventual stress on the Alternative Decker Canyon Las Virgenes Municipal potable system. The longer alternative route used in this Recycled Water Extension Water District project would also serve other demands along the way. In addition to the golf club, significant recycled water demands are expected to come from a new development (Triangle Ranch) and conversion of the existing Medea Valley ranchettes to recycled water use. The project is projected to deliver 459 AF/Y of recycled water, offsetting the same amount of potable demand that would occur if the extension were not built. The project will consist of a diversion, conveyance pipes, a gross solids removal device (GSRD), an irrigation storage tank, and an infiltration gallery. Dry- and wet -weather flows will be diverted from the existing storm drain up to the maximum diversion flow rate and will then enter the storage tank through the conveyance pipe and GSRD. Once the Andrews Park Subsurface storage tank reaches a depth of 1.5 feet, flows will be 8 Storage, Use and Infiltration City of Redondo Beach pumped to be used for onsite subsurface irrigation. When the storage volume of the irrigation tank reaches capacity, Project runoff will flow via an overnow pipe into the infiltration gallery, where the water will infiltrate subsurface soils. When continual flows fill the infiltration gallery and irrigation storage vault to storage capacity, diverted flows will back-up through the diversion piping and prevent additional flow diversion until capacity is freed up due to irrigation use and/or infiltration losses. The Confluence Gateway Greenway Program will restore a 1/3 mile stretch of urban land alongside the Arroyo Seco, in the Arroyo Seco Scenic Byway Corridor, into a riparian greenway and open space park with native landscaping and a bicycle/pedestrian path. Not only would the project embody a first step in enhancing river access and recreation opportunities, it would provide a key link between the 9 Arroyo Seco Confluence Gateway Arroyo Seco Foundation planned Los Angeles River greenways at the confluence and the Metro Rail station in the historic Lincoln Heights neighborhood, thus enabling light rail and bicycle access to the Arroyo Seco and the Los Angeles River. Ultimately, the Arroyo Seco greenway is envisioned to extend to South Pasadena, and this initial segment at the confluence would be an important hub in the regional river parkway and bicycle trail network. Appendix A Comment Letter to the LACFCD: Draft PEIR Naturalize north branch storm drain and restore stream through Sycamore Grove Park. Primary Objectives Addressed by the Project: By re-establishing an urban stream, this project addresses water quality, riparian habitat restoration, groundwater recharge, flood management, and public education. The Sycamore Grove Park site is approximately 800 feet long and 400 feet wide. This 8 -acre 10 Arroyo Seco North Branch Creek Arroyo Seoo Foundation site is located in northeast Los Angeles and situated west of Davliahtina the SR -110 (). This site encompasses Sycamore Grove Park and is bounded by South Avenue 49 to the northeast, the SR 110 to the east, medium density residential uses to the south, and North Figueroa Street to the west. Sycamore Grove Park is a landscaped area consisting of a large lawn, playground, and parking area. The North Branch tributary is contained within a storm drain beneath Sycamore Grove Park. For centuries the waters of Baldwin Lake have sustained human endeavor. A rich historic site, its role began in the Native America period when springs and marsh, precursors to today's lake, supported nearby habitation. In the late 19th Century, Elias Jackson Baldwin chose the Lake as the center for agriculture and land development that shaped the establishment of the east San Gabriel Valley. Today, as the centerpiece of the Los Angeles County Arboretum, the Lake 11 Baldwin Lake Los Angeles Arboretum is an educational and scenic resource serving hundreds of Foundation thousands of visitors. Looking to the future, Baldwin Lake is envisioned as a model for community-based environmental stewardship and regional approaches to water management and conservation. Ideally located at the edge of the Raymond Basin aquifer, the Lake offers great potential as the nexus for water management and ground water recharge for the Arboretum's 127 acres, as well as the surrounding urban watershed. Educational programming that interprets the history of the Lake, particul Project is to implement the valuable uses of stormwater and to improve the water quality in Ballona Creek Watershed. Ballon Creek Low Flow Treatment Facility (LFTF), also known as North Ouffall Treatment Facility (NOTF), is one of several projects proposed in Ballona Creek TMDL Implementation Plans for Bacteria, Metals, and Toxic Pollutants. The LFTF includes a 1 million gallon storage Ballona Creek Water Quality and City of Los Angeles facility and has the capacity to treat up to 150 cis, including 12 Beach Improvement & Beneficial Bureau of Sanitation screening of coarse, fine sediments, and disinfection with Use Project Watershed Protection sodium hypochlorite. NOTF was constructed in 1987 by City Division of Los Angeles. The project proposes to use the existing treatment facility and construct a low -flow diversion structure in Ballona Creek Channel to divert and treat full dry -weather flow and partial wet -weather flow. 65 percent of Ballona Creek Watershed (85 square miles) is located upstream of the Project, with average dry -weather flows ranging from 14 to 25 cfs. Treatment will include coarse screens, sedimentation, filtration, and disinfection. Appendix A Comment Letter to the LACFCD: Draft PEIR The City of Burbank proposes to expand and increase water conservation through the expansion of a comprehensive indoor/outdoor financial incentive program that will result in immediate and sustainable water savings. The proposed Rebate Program to install 1,300 HE toilets, replace 300,000 square feet of turf with native landscapes, capture and reuse rain water 3 million gallons of rain water with rain barrels, 13 Be A Water Saver Water City of Burbank Water and and increase water conservation education efforts will save Conservation Program Power an estimated 500 AF of water annually. Grant funding for the proposed project will facilitate greater water savings by providing funding for greater levels of participation sooner than would be realized under typical funding efforts. Furthermore, these benefits will be realized faster by utilizing a proven system for conservation, a truly ready to proceed project. This project has the potential to double participation levels. This project will consist of planning, design, and construction of approximately 4,625 feet of new 8 -inch PVC and Ductile Iron recycled water pipeline to extend Glendale's recycled water distribution system from the intersection of Flower St. and Grandview Ave. to Bette Davis Park. Approximately 14 Bette Davis Park Water Recycling LADWP 4,300 feet of pipeline will be installed within Glendale's city Project right of way. Through an Agreement with the City of Glendale, this project will be designed and constructed by Glendale's contractors and LADWP will reinburse Glendale for the costs. This will reduce the City's potable demand for non -potable uses. This project will offset up to 75 AFY of potable water with recycled water. This project will upgrade the sluiceway to function as a low level outlet for regulating flows under high reservoir pressure and repair various facility components for the dam. The existing sluice gate at the upstream end is to be replaced with a new heavy duty hydraulic actuated gate, the Big Dalton Sluiceway Los Angeles County Flood sluiceway is to be lined with new pipe for the entire length, 15 Rehabilitation Control District and a throttling valve is to be installed at the outlet. Storm releases through the sluiceway will reduce the rate of sediment accumulation and prevent sediment deposits at the face of the dam. Incoming sediments during storm flows could be routed through the reservoir to restore a more natural sediment transport system and maintain reservoir capacity The proposed project will modify and motorize the diversion box at Big Dalton Spreading Grounds to better control flows taken into the facility. The spreading basins will be reconfigured to increase percolation rates and storage 16 Big Dalton Spreading Grounds Los Angeles County Flood capacity. An intake will be constructed from Little Dalton Improvements Control District Diversion Channel so that additional storm flows can be diverted to the facility. A proposed outlet from Metropolitan Water District's PM -26 imported water line to the Little Dalton Diversion channel will enable imported water to be recharged at the spreading grounds. Appendix A Comment Letter to the LACFCD: Draft PER The project consists of constructing three 18 -inch diameter bypass water pipelines approximately 1,500 feet in length within the areas of active landslides along Pacific Coast Highway. This bypass will serve as a permanent replacement of an existing 30 -inch diameter water pipeline Los Angeles County that has experienced significant breaks resulting in large 17 Bio Rock Bvoass Waterworks District No. water loss. The proposed pipeline will be raised to a shallow 29 trench and protected by a reinforced concrete box covered with steel plates to provide quick access if any leakage occurs. In addition, 18 -inch Flexible Expansion Joints will also be installed at several locations with the areas of the active landslides to prevent damage or rupture of pipelines from ground movement. Los Angeles County Flood Construction of a dam within the spillway at Big Tujunga 18 Big Tuiunga Dam Spillway Dam Control District Dam to increase the maximum storage capacity of the reservoir by approximately 705 acre-feet. The 2009 Station Fire was the largest fire in Angeles National Forest recorded history and burned over 160,000 acres before containment on October 16, 2009. Approximately 87% of the watershed tributary to Big Tujunga Reservoir was affected. On average, a watershed will take five years or more to recover from a forest fire bum. During this time, increased amounts of debris production are anticipated from the denuded ground surface. Based on the 19 Bio Tuiunga Reservoir Sediment Los Angeles County Flood 2010-11 storm season surveys, the total amount of sediment Removal Control District in the Big Tujunga Reservoir is approximately 2 million cubic yards. The County of Los Angeles Department of Public Works on behalf of the Los Angeles County Flood Control District proposes a sediment removal project to permanently remove up to 4.4 mcy of sediment from Big Tujunga Reservoir. Sediment will be excavated and transported using low emission trucks or conveyor belt to Maple Canyon Sediment Placement Site adjacent to Big Tujunga Dam. The project will be completed over four years starting in the sum 20 Boulevard Pit Stormwater Capture LADWP Acquire and develop Boulevard Pit into a multi -use retention Project and recharge facility to enhance stormwater conservation. Branford Spreading Ground has very low percolation rates compared to the Tujunga Spreading Ground directly across the Tujunga Wash Channel. This project will install a pump 21 Branford Spreading Basin Los Angeles County Flood from Branford Spreading Ground to direct water into the Cleanout and Pump Control District Tujunga Spreading Ground leading to more groundwater recharge. In addition, the project will clean out the clogging layer at the bottom of basin, which will also improve percolation rates. Appendix A Comment Letter to the LACFCD: Draft PEIR In partnership with Water Replenishment District of Southern California and it's "Regional and Distributed Stormwater Capture Feasibility Study," the proposed project will design and implement stormwater Best Management Practices (BMPs) in the City of Los Angeles with the primary goals of TMDL compliance and stormwater infiltration. Three levels of BMPs will be developed; local parcel based Low Impact Broadway Neighborhood City of Los Angeles Development (LID) for 8 acres (60 residential parcels), 22 Stormwater Greenway Protect Bureau of Sanitation neighborhood scale LID for 12 acres (3 residential streets and 2 blocks of commercial streets), and a sub -regional scale facility for 30 acres of mixed land uses. The local and neighborhood BMPs will capture and infiltrate all dry -weather flow and up to the ''% inch storm. The sub regional BMP will capture up to the 2 inch storm for 30 acres. The sub regional BMP will also receive dry -weather flows from 228 acres of mixed land uses. Designs will be standardized to remote widespread implementation. Historical records show that an annual average of 625 acre- feet of water passes though Bull Creek. All flows from Bull Creek are lost to the ocean via the Los Angeles River. This 23 Bull Creek Stormwater Capture Los Angeles County Flood project proposes conserving the lost water by diverting flows Control District from the new LADWP facility using a rubber dam and conveying flows through a pipeline to Pacoima Spreading Grounds where it would be captured and recharge the local aquifier. Plan, design, and construct stormwater conveyance facilities for compliance with the Enhanced Surface Water Treatment Rule. Facilities will be designed according to standards adopted by Department of Water Resources, Division of Bull CreekLos Angeles Reservoir Safety of Dams. Improvements include widening a portion of Water Quality Improvement 24 LADWP the Bull Creek Extension Channel, realigning a section Protect downstream of the widening, construction of a new diversion structure and overnow structure, and improvements to inlet structures. The Los Angeles Reservoir spillway will be removed from service. Proposed design facilitates a future stormwater capture program. The Burbank Partnership Water Recycling Project involves the planning, design, and construction of approximately 27,000 feet of recycled water pipelines in the North Hollywood area. The three individual segments that comprise the project are the Chandler Boulevard Bike Path 25 Burbank Partnership Water LADWP segment, the Whitnall Dog Park segment, and the North Recycling Protect Hollywood Park segment. These segments will connect to Burbank's recycled water distribution system at three separate connection points and will be served by recycled water treated at the Burbank Water Reclamation Plant. This project is expected to offset up to 285 AFY of potable water with recycled water. Appendix A Comment Letter to the LACFCD: Draft PEIR The third phase of the City of Burbank's recent recycled water system expansion. As a result of previous phases, over 20 miles of recycled water pipelines have been installed resulting in the distribution of over 2,300 AF of recycled water annually; amounting to 13% of the City's water demand by the end of 2014. The City will continue expanding its recycled water distribution to offset potable Burbank Water and Power water use in this phase by constructing two new recycled 26 Recycled Water System City of Burbank Water and water pipelines known as, the LA Equestrian Center (LAEC) Expansion, Phase 3 Power and the Naomi pipelines. The LAEC is located on the borders of the cities of Burbank and Los Angeles consisting of landscape areas, stables, offices and corrals; the latter requiring dust control with water trucks. The Naomi pipeline would primarily provide recycled water to a very large commercial data center and smaller customers. Completion of these pipelines will increase recycled water distribution by an estimated 61 AFY, resulting in a direct and immediate potable water savings of 61 AF annually. The Desalter currently has the capacity to extract up to 2,000 acre-feet annually of brackish water. In 2003 the old wells at the site were decommissioned and construction began in 2005 for the first replacement well. The facility became operational in 2006 at a reduced capacity using the new well and the original RO unit. The facility has not been operating to its full capacity since it came online again in C Marvin Brewer Desalter West Basin Municipal 2007 because of water quality issues. Funding is also 27 Brackish Groundwater Facility Water District needed to correct the water quality problems in order to get Expansion the facility to its full operating capacity. The proposed 500 AFY capacity expansion will allow the facility to become operational at its full capacity of 2,000 acre-feet per year. The site is already owned by California Water Service Co. and leased by West Basin and is developed as a desalting facility. The expansion will include the installation of a new production well, and the addition of an acid pretreatment unit and a reverse osmosis treatment unit on the existing site. Installation of storm drain catch basin curb screens at all applicable locations citywide. These screens are the stainless variety approved curb by Los Angeles County. The purpose of the curb screens is to stop trash from entering the catch basins which eventually discharge into both the Los Angeles River and Malibu Creek watersheds. By implementing this project, City of Calabasas will be in compliance with the Trash TMDL both for LA River and 28 CITYWIDE STORM DRAIN CITY of CALABASAS Malibu Creek watersheds. Based on studies done, reduction CATCH BASIN CURB SCREENS in trash and debris loadings will also reduce Bacterial and sediment loading in the watershed. By implementing the project, disadvantaged communities downstream of Calabasas in Los Angeles River will benefit from cleaner water. The scope work consists of measuring all catch basin openings, drafting RFP with detailed specifications, soliciting proposals from the list of Los Angeles County's approved venders, negotiating contract, implementation/construction, monitoring and reporting. Appendix A Comment Letter to the LACFCD: Draft PEIR The project will convert a 1.55 acre vacant parcel at the confluence of the Los Angeles River and Caballero Creek into a publicly -accessible natural park with habitat restoration, paths, site furnishings, water quality improvements, waterfront -access, and educational amentities. The design utilizes an innovative mixes low-tech mechanical and biological methods to filter and infiltrate storm waters increases regional water quality. The project 29 Caballero Creek & Los Angeles Mountains Recreation and creates a multi -benefit park that provides ecosystem River Confluence Park Conservation Authority services as well as cultural services, like recreation and eco - tourism. The project concept was developed in partnership with the City and County of Los Angeles who have committed to retain ownership, maintenance and operation responsibilities while allowing the Mountains Recreation and Conservation Authority (MRCA) to oversee design and construction. Nearby Reseda High School will monitor the project and use it for hands-on learning and community service opportunities. This project will consist of design and construction of approximately 8300 feet & 6000 feet of new 4"and 8" PVC recycled water pipeline, respectively. The project also Camino San Rafael Recycled consists of installing a two booster stations. This project will 30 Glendale Water & Power extend Glendale's recycled water distribution system to Water Project provide recycled water for common area irrigation to the Camino San Rafael Homes. This project will offset up to 90 AFY of potable water with recycled water. This will reduce the City's demand on potable water. The Carson Regional Water Recycling Expansion Project includes the expansion of the existing recycled water treatment facility and the construction of several laterals. This is a new demand on the system and will require expansion of treatment process capacity and conveyance to include; lateral pipelines, pump stations, treatment units, 31 Carson Regional Water Recycling West Basin Municipal storage tanks, and waste management facilities. The BP Pro act Water District Refinery requires single -pass reverse osmosis treatment units. BP Refinery is estimating a need of 2,100 acre-feet per year (AFY). The project will be further expanded to serve customers within the City of Los Angeles' jurisdiction for the refineries in the port area. The City will need recycled water to satisfy a use of 9,300 AFY. The City is in the preliminary design stage. Appendix A Comment Letter to the LACFCD: Draft PER 10 The Project will provide a street -end interpretive area on Bull Creek at Chase Street, and install a Stormwater Greenway along Chase Street from the eastern street end on the north side right-of-way to Hayvenhurst, and on the north and south right-of-way to Gothic. Vegetated planters in the parkways will capture and infiltrate street runoff, and will provide storm City of Los Angeles water filtration, and tree shading. The Bull Creek street -end Chase Street Stormwater Bureau of Sanitation, will feature a native landscape as habitat and a recreational 32 Greenway Watershed Protection rest stop along the channel, and will provide an interpretive Division site for wildlife selected and supported by the specific native planting used in the project. A channel diversion from Bull Creek, with a pre -filter and lift station, will transfer runoff through a pipeline to a local Sod Farm where it will be used to irrigate up to 30 -commercial acres. The project will integrate water conservation goals (LADWP), Storm water objectives (BOB), Economic enhancements to city property (LAWA), & public health and recreation benefits. This project will install a chemical treatment system at the Rio Hondo Coastal Spreading Grounds to remove sediment fines from the water and improve the percolation rates. A Percolation Optimization Investigation (POI) report was done by Montgomery Watson Harza (MWH) in 2003 to evaluate the County's spreading grounds and the impact of Los Angeles County Flood suspended solids on percolation rates. The report made a 33 Chemical Study -Rio Hondo Control District number of recommendations and the recommendations will be implemented at the Rio Hondo Flood control facility. The project will install a coagulant chemical feeder and mixer at the grounds intake. This will allow the silt in the stormwater to coagulate and settle prior the cleaner water to flowing into spreading grounds. When this occurs, the spreading grounds will be able to percolate more water, thus conserving and recharging more groundwater. This project will consist of design and construction of approximately 920 feet, 1900 feet & 2100 feet of new 4", 8" and 12" PVC recycled water pipeline, respectively. The Chevy Oaks Recycled Water project also consists of installing a small booster station. 34 Glendale Water & Power This project will extend Glendale's recycled water distribution Project system to provide recycled water for irrigation to the Chevy Oaks Homes. This project will offset up to 30 AFY of potable water with recycled water. This will reduce the City's demand on potable water. At completion of a prior grant, a modest amount of money remained unused. With the acquiesence of the granting agency, the City of Carson purchased 16 rain barrels and set up a website lottery system in order to award them to residents. The response was overwhelming and with no City of Carson, advertising over 100 contestants were disappointed to not 35 City of Carson Rain Barrel Give Development Services receive a rain barrel. This proposal would lead to the Away Phase II Department, Engineering purchase of an additional 1,000 rainbarrels (depending on Services Division cost and grant amount) to restock the lottery reserves. Advertising and management of the program would be provided as part of the City of Carson grant match. More information on Fiskar Rain Barrels is available at http://www2.fiskars.com/Prod uctsNard-and-Garden/Rain- Barrel-Systems 10 Appendix A Comment Letter to the LACFCD: Draft PEIR 11 Upper District in cooperation with the City and Fire Department of Monrovia are submitting this project incorporating both dry and wet weather runoff capture, treatment and storage for the new Regional Training Center. Once collected, the fire training water and the 85th percentile of a 24 hour storm event (as required by the City's City of Monrovia Fire Department - MS4 permit) will be treated before being discharged into 36 Training Center Water Recycling Upper San Gabriel Valley storage holding tanks which will store the treated water for Municipal Water District future reuse by the training facility. The objective is to offset Proiect the use of potable water at the facility, eliminate storm water discharge and capture wet -weather storm water runoff. Finally, if the wet -weather event is larger than the 85th percentile, then provisions are being considered to treat as much of the additional wet -weather storm water runoff via a natural infiltration gallery (bioswale) before being discharged into the City's storm water system. This project will consist of refurbishment and upgrades to the outlet works, tunnels, and repair of various facility components at Cogswell Dam. The project will increase operational effectiveness for Flood control and water conservation. The project will involve: a complete overhaul Cogswell Dam Inlet/Outlet Works Los Angeles County Flood of the dam's entire inlettoutlet works; upgrade on the 37 Control District electrical control equipment; repair of downstream facilities; Rehabilitation Proiect structural repairs on the upstream facing slab; security upgrades; and other various repairs essential for maintaining and operating a flood control facility. The overall project intent is to improve Cogswell Dam for maintaining dam safety, increased efficiency and reliability of Flood control operations, and enhancement of water conservation efforts. The project will acquire 4.87 acres (APN 4455-021-040) of natural undisturbed open space within the existing 1348 - acre Cold Creek Preserve in the Santa Monica Mountains National Recreation Area. The acquisition is part of the state - funded Cold Creek Restoration Plan designed to acquire 539.06 acres to protect the wild and scenic, perennial Cold 38 Cold Creek Diamond Acquisition Mountains Restoration Creek, the habitat linkage between Topanga State Park and Trust Malibu Creek State Park, the values of Los Angeles County's Significant Ecological Area #9, and a future venue for environmental education, research, and recreation. The area includes significant oak, sycamore, and willow communities, supports a range of wildlife including mountain lion, gray fox and raptors. The pure waters once supported the federally -listed endangered southern steelhead trout. This project helps our customer agencies to develop a water conservation, budget -based rate structure for their customers. The project is beneficial to West Basin's cities Conservation Budget Based West Basin Municipal and retail water agencies because it provides a pricing 39 Water District structure that will incentivizes its customers to conserve Tiered Rate Structure water. This pricing method has been used in other parts of the State and has been successsful at reducing water usage and reqarding those who do so with lower rates on their water bill. 11 Appendix A Comment Letter to the LACFCD: Draft PEIR 12 This project would convert the 237th St. Sump (4.5 acre- feet) into a retention infiltration basin BMP for Toxics and Nutrient TMDL compliance and provide open spaces for wildlife habitat. This project would install diversion structures that would divert the first 4.5 acre-feet of stormwater from a 71 acre tributary area away from the system tributary to Conversion of 237th Street Sump Machado Lake (Wilmington Drain) to be retained and Tributary to Machado Lakes for 40 City of Torrance infiltrated in this basin. Trash screens would be installed at Nutrient and Toxics TMDL BMPs the catch basin in the watershed by a separate project. During the dry season the basin would remain an open space for wild life and retain urban run-off and nutrients form 71 acres. By diverting stormwater back into this basin, the City and County storm drain systems would have more capacity during rain events. This project would also increase groundwater recharge. This project consists of repairing corroded and deteriorated sections of aboveground pipeline and developing a Corrosion Monitoring, Control, and Maintenance Program. The Waterworks District 29 transmission water pipeline runs Los Angeles County along the Pacific Coast Highway in Malibu. The proposed 41 Creek Crossings Repairs Waterworks District No. pipeline repairs are located at eight creek crossings attached 29 to bridge structures. The project will significantly prevent future leaks and breaks in the main transmission pipeline which is the primary source of water supply for Malibu and Topanga. The development of a maintenance program is essential to maintaining water supply reliability for the region. The project would harvest stormwater and brackish groundwater for high level treatment and non -potable use around the City, replacing the use of imported potable water. The City would install a 1.3 million gallon storage tank next to the Santa Monica Pier, Deauville lot, to harvest stormwater from the Pier sub -watershed during rain events and brackish groundwater during dry periods. The project would have an optional overflow to an infiltration gallery. A 42 Deauville Distributed Water Reuse Project City of Santa Monica saline extraction well would be installed in sand next to the storage tank. The project would install pre-treatment catch basin inserts in the drainage area or a centralized hydrodynamic separator -screening device to remove trash and debris from stormwater. Modular nanofiltration (NF) and a saltwater reverse osmosis (RD) treatment systems at the site would treat these stored local water resources to high quality for various uses around the City in the existing recycled water system. All concentrated brine by-product would be sent to the sanitary sewer. The Decker Canyon recycled water pump station, pipeline, and tank would furnish recycled water primarily to Malibu Country Club Golf Course and Tract 47962 -Sycamore Canyon Estates near the pump station location and other 43 Decker Canyon Recycled Water Las Virgenes Municipal Water District nearby ranchettes. The project would comprise a high -lift pump station, —23,000 linear feet of pipeline along Westlake System Extension Blvd and Decker Canyon Rd, and a 60 -foot diameter concrete tank near the corner of Decker Canyon Rd and Mulholland Hwy. Approximately 229 AF of recycled water per year would be used by this project. 12 Appendix A Comment Letter to the LACFCD: Draft PEIR 13 The Del Rey Lagoon Water Quality Improvement Project proposes to improve water quality by reducing the source and amount of fecal indicator bacteria in the Del Rey Lagoon and surrounding waterbodies such as the Santa Monica Bay and Dockweiler Beach. Project components include stormdrain systems, vegetated swales, irrigation system retrofit, and drainage modifications. Education and outreach City of Los Angeles to the public will also be included in the project scope. The 44 Del Rev Lagoon Water Quality Bureau of Sanitation vegetated swales are designed to capture, retain, and treat Improvement Project Watershed Protection runoff from the adjacent residential, transportation, and Division landscaped area during dry weather and partially during wet weather. Existing irrigation system will be retrofitted with a smart irrigation system to reduce excessive irrigation runoff, thereby conserving water and reducing flow. Catch basins and storm drains will be installed to capture and divert excess wet -weather flow into the sewer system. Project also includes a nature viewing deck and educational displays that explain local flora -fauna. This project involves the installation of drought -tolerant demonstration gardens at a minimum of five fire stations throughout the West Basin service area. These gardens will replace turf and/or concrete areas that are directly in front of the fire stations in order to provide a maximum visibility to the public. The gardens will be utilizing drought -tolerant and/or native plants that will be designed by professional Demonstration Gardens at Los West Basin Municipal landscape designers that specialize in climate -appropriate 45 Angeles County Fire Department Water District plans and trees. The main goal is to provide water Stations conservation and runoff reduction measures and secondarily to educate the public about the measures so that they can create these spaces at their own homes. West Basin strives to reduce demands by implementing conservation and education programs throughout the communities it serves. This project aims to continue implementing outdoor water conservation/education programs to influence the public to create these spaces in their own homes. This project proposes to conserve stormwater by holding a reservoir pool behind Devil's Gate Dam and diverting the water to Eaton Wash Dam and Eaton Wash Spreading 46 Devil's Gate Dam and Reservoir Los Angeles County Flood Grounds for poststorm groundwater recharge. A pump will Water Conservation Control District be installed in the Devil's Gate Dam reservoir and water will be pumped out and conveyed through over 26,000 feet of pipeline to Eaton Wash Dam where it can be held for recharge at downstream spreading ground facilities. 13 Appendix A Comment Letter to the LACFCD: Draft PER 14 The 2009 Station Fire was the largest fire in Angeles National Forest recorded history and burned over 160,000 acres in the San Gabriel Mountains. Approximately 68% of the watershed tributary to Devil's Gate Reservoir was burned and as a result of the storms that occurred in the two wet seasons after the fire, sediment levels in the reservoir Devil's Gate Reservoir Sediment increased by more than one million cubic yards. The County 47 Los Angeles County Flood of Los Angeles Department of Public Works on behalf of the Removal and Management Project Control District Los Angeles County Flood Control District is planning a sediment removal project of up to 4 million cubic yards. A sediment removal project from behind Devil's Gate Dam is vital to the health of the Arroyo Seco Flood control system. The goal of this project is to restore Flood control capacity and establish a reservoir configuration more suitable for routine maintenance activities. The project will last approximately 5 years with construction starting in 2014. The project will consist of development of a native landscaped greenway and bikeway/pedestrian trail along the north side of the Dominguez Channel, between Vermont Av and Normandie Av. The project will include the following: access/maintenance road improvements for the new/improved bikeway; AC repair and replacement, slurry seal, American Disability Act (ADA) access ramps and 48 Dominguez Channel Greenway Los Angeles County Flood bikeway/pedestrian signage and striping. Landscaping Phase III Control District improvements include landscaping using native and drought - tolerant plants, irrigation, as -needed fencing repair/replacement. Educational/interpretive signage will also be included along the bikeway/pedestrian trail. A study is also recommended to consider additional pedestrian crosswalks with street lamp lighting for added safety. The project is currently on hold until the LACFCD completes a study to address deficiencies in its levees. This project would install Automatic Retracting Screens (ARS) in the 1800 Storm Drain Catch Basins in the City of Carson. The proponents favor ARS to collect trash at street level where the trash can be quickly and cost effectively collected weekly by the existing City Street Sweeping Contractor and eliminates the need for other more costly and difficult to maintain downstream trash control systems. This Dominguez Channel Trash City of Carson, project anticipates the continuing development of local and 49 Reduction Via ARS Installation in Development Services state waterway trash control efforts and alleviates the need Department, Engineering to develop these expensive federal, state and local the City of Carson, CA Services Division requlatory mandates. In comparison to other "downstream" trash control systems, the maintenance status of ARS is easily assessed and visible to the public, which is then able to report those locations where maintenance is warranted. Since ARS systems are located in the street sweeper path, maintenance (trash collection) occurs weekly, the trash stays dry and is less subject to the degradation that generates other pollutants (bacteria). 14 Appendix A Comment Letter to the LACFCD: Draft PEIR 15 The proposed project will increase the percolation within the spreading grounds facility in order to increase groundwater recharge. The preliminary scope includes removing between Dominguez Gap Spreading Los Angeles County Flood 5 to 10 -feet of clay sediment or installing vertical 50 Grounds West Basin Percolation Control District trenches/drains through the poorly draining strata in the Enhancement facility's west basin. Preliminary studies have been conducted including boring samples which will be used to further develop conceptual plans and estimate project benefits. The Duck Farm River Park, once a natural Floodplain, has been disconnected from the natural processes of the river for decades as a result of urbanization & flood management. The Project reintroduces natural systems through a riparian/pocket wetland/seasonal slreambed that improves both habitat and collect, filter & infiltrate stormwater flows onsite, as well as stormwater from the adjacent freeway in collaboration w/Caltrans. The project will transition irrigation 51 Duck Farm River Parkway Phase Watershed Conservation source (annually forecasted to require 19M gallons) from 1 - Water Enhancement Project Authority imported, highly processed potable water to either local groundwater or recycled water as its source of supply. The public will benefit by being reconnected to nature, the river, & from educational & interpretive programming possible at the site. This change in supply will reduce greenhouse gases & the parks carbon footprint. Outdoor classroom & interactive educational experiences with children will inspire local youth to learn more about our watershed, water conservation & sustainability The project will increase the intake and storage capacity of the Eaton Wash Spreading Grounds facility. This will improve the facility's ability to recharge storm water into the groundwater basin, thus greatly increasing the sustainable local groundwater supply that is vital for the region. Los Angeles County Flood Control District will replace the vehicle access slab with a metal grate over the spreading grounds drop intake channel and replace the current 52 Eaton Spreading Grounds Intake Los Angeles County Flood diversion flashboards with an inflatable gate within the intake Improvements Control District channel. These improvements in Eaton Wash Channel will better direct flows into Eaton Wash Spreading Grounds, thereby increasing its intake capacity. Basin 1 will be enlarged to increase the facility's storage capacity. The project will include improvements to the property along Sierra Madre Boulevard that will significantly improve the sustainability, aesthetics, and safety of the public walkway and street view. Two driveway entrances will be improved by increasing the gate set -back fu The dam outlet works rehabilitation project involves the removal of the existing outlet tower and gate house. Once these major components are removed, construction of a Eaton Wash Dam Inlet/Outlet Los Angeles County Flood gate valve, debris racks, hydraulic power system with a 53 Control District block house, control systems, modification of the outlet Works Rehabilitation Project works structure, and rehabilitation of the gate valves will commence. It will provide necessary erosion protection measures and improve water quality during low -flow releases from the dam. 15 Appendix A Comment Letter to the LACFCD: Draft PEIR 16 LADWP is planning to cover the existing Elysian Reservoir in order to meet US EPA water quality regulations. In April 2012, the Board of Water & Power Commissioners certified the Environmental Impact Report and approved the floating cover alternative. The project will install a flexible membrane floating cover over the existing water surface. Also included are supporting infrastructure (piping, valves, liner) and site Elysian Reservoir Water Quality improvements (roadway paving, fencing). The reservoir will 54 LADWP operate in the same manner, providing potable storage for Improvement Project the distribution system. Construction is anticipated to being by 2015. In conjunlion with the project, a Community Parks Fund was established by the Board of Commissioners. The fund is to be used for unspecified public purposes related to community parks. Best efforts will be made to locate enhancements primarily in the Elysian Park area, working together with the community and other City of Los Angeles agencies. The project consists of adding a new emergency water source to supply Waterworks District No. 29 through a new Los Angeles County interconnection along Encinal Canyon Road at the District 55 Encinal Emergency Connection Waterworks District No. boundary with Las Virgenes Municipal Water District 29 (LVMWD). This interconnection would bring water from Metropolitan Water District of Southern California through LVMWD to provide additional supply to the District during emergencies. Three hydrologic areas were studied for the development of satellite recycled water facilities. Foothill Municipal Water District (FMWD) is pursuing the construction of one facility near Berkshire Place in La Canada at this time. This project will treat wastewater using a membrane bioreactor and recharge the product into the groundwater basin using infiltration galleries underneath athletic fields for multi - beneficial uses. Cal Poly Pomona has partnered with FMWD Foothill Municipal Water District Foothill Municipal Water and is developing a model that will also capture stormwater 56 District for recharge using the same infiltration galleries. A Recycled Water Pro act conservation and education component has also been added. Landscaping will be done to showcase drought tolerant plants at both the MBR site and school site. Tours will be available so that students may learn about stormwater capture, groundwater, recycled water, conservation and the watershed since the Arroyo Seco and Hahamongna Park are across the street. This 0.250 MGD plant will save enough energy annually for 80 homes in So. Cal. Divert runoff from a section of the Santa Monica Freeway within the City of Santa Monica, treat and infiltrate within an area near the freeway, either a landscaped area or parking lot. The infiltration zones will be sugared, if necessary to by- pass poor permeable soils. There will be pre-treatment 57 Freeway Runoff Infiltration City of Santa Monica before infiltration to remove trash, oil/grease, sediments. It Demonstration Proiect will be a passive system, i.e. gravity -fed and low into the system. The treatment -infiltration areas will be areas either already with a storm drain in the area, or the creation of new ones to harvest the runoff. The goal will be to keep runoff out of the existing storm drains and out of the storm drain system. 16 Appendix A Comment Letter to the LACFCD: Draft PEIR 17 The Prop O funded phase I, the installation of six bio-swales and 4 dry wells. This watershed in an average rainfall year brings 300 acre feet of water to Glen Oaks Blvd. Phase I was completed in January 2014 and is currently capturing an 59 Glen Oaks Storm Water Caoture Los Angeles estimated 30 acre feet per year leaving approximately 270 Pro act Beautification Team acre feet available for storm water capture. Phase It will consist of an additional eight dry wells for an estimated $625,000, plus the cost of City Services (Design fees, permits and over site), that will capture an additional 40 to 45 acre feet annually. The Glendale Narrows Riverwalk will provide approximately one mile of multi -use recreation along the Los Angeles River. There are several invasive plant species that are prevalent adjacent to the Riverwalk in the Glendale Narrows area of the Los Angeles River. These invasive plant infestations jeopardize the improvements to water quality and degrade habitat for native aquatic, avian, reptile, 59 Glendale Narrows Habitat Council for Watershed amphibian, and invertebrate species. In collaboration with Enhancement Pro act Health the City of Glendale Community Services & Parks Department, the Council for Watershed Health (Council) proposes to develop and manage a 3-4 year restoration project to map, control, and monitor invasive arundo and invasive palm trees in the Riverwalk project area in the Glendale Narrows sections of the Los Angeles River. A native plant propagation and replanting effort is also proposed to reestablish riparian plants. The Goldsworthy Desalter (Desalter) treats water from the saline plume in the West Coast Groundwater Basin for drinking water. The brackish water is treated to meet or exceed municipal drinking water standards through the use of a reverse osmosis system. The existing Desalter produces approximately 2,000 acre-feet of potable drinking water per year. When the Desalter was originally constructed in 2002, it was designed for expansion to over 5000 acre - 60 Goldsworthy Groundwater City of Torrance feet per year of drinking water. In 2012 the Water Desalter Expansion Replenishment District of Southern Califomia had a Feasibility Study for the Expansion of Desalter prepared for and approved by the U. S. Bureau of Reclamation. The expansion would involve the installation of additional reverse osmosis treatment units, construction of two additional source water wells, transmission mains and related appurtenance. The project also diverts waste water away from Santa Monica Bay where discharges cause TMDL violations for bacteria. 17 Appendix A Comment Letter to the LACFCD: Draft PER IV The overarching goal of the GRIP Recycled Water Project is to offset the current use of imported water by providing up to 21,000 acre-feet per year (AFY) of recycled water as a reliable supply source for groundwater basin replenishment via the Montebello Forebay within a reasonable timeframe. The source for the recycled water will be the Los Angeles Groundwater Reliability Water Replenishment County Sanitation Districts' San Jose Creek Water 61 Improvement Project (GRIP) District of Southern Reclamation Plant (SJCWRP). Tertiary treated recycled California water, advanced treated recycled water (microfiltration, reverse osmosis and advanced oxidation), or a combination of the two will be conveyed from the SJCWRP via an existing pipeline or possibly a new pipeline for recharge in the Central Groundwater Basin through the Montebello Forebay Spreading Grounds or potentially a new injection well field. The purpose of the Groundwater System Imrovement Study (GSIS) is to perform an independent study to identify, characterize, and evaluate emerging water quality constituents for the San Fernando Basin (SFB). This will include a comprehensive analysis that will provide recommendations in developing short and long-term 62 Groundwater System LADWP projects, including the design and construction of Improvement Study groundwater treatment facilities, to maximize the use of the groundwater supply in the SFB. As a part of the GSIS, the LADWP will be drilling approxinmately 26 new groundwater monitoring wells, and perform short-term monitoring of existing and new wells, in order to obtain supplemental water quality data necessary for planning the groundwater treatment afcilities in the SFB. Design and construction of groundwater treatment facilities 63 Groundwater Treatment Facilities LADWP in North Hollywwod, Rinaldi-Toluca and Tujunga Wellfields in the San Fernando Basin (SFB), with a treatment capacity of 122,900 acre-feet per year. Construct 4,500 feet of 20" pipeline, pumping station and Hansen Dam Golf Course Water pipe support bridge to deliver recycled water from the 64 LADWP Tillman Plant to the Hansen Dam Golf Course and other Recyclina Project potential future users. Water will be pumped from the Hansen Tank. Hansen Dam, situated adjacent to the Tujunga Wash Channel in the San Fernando Valley, is a vital part of flood control efforts in the Los Angeles River drainage basin. The primary purpose of Hansen Dam is flood control; however the opportunity exists to increase water conservation and water supply through increased water recharge upstream of Hansen Dam Water Conservation Los Angeles County Flood the dam. The current operation of the dam allows for an 65 Control District average annual water conservation of 17,100 acre feet per Project year. The Water Conservation Project, which involves utilizing the existing Debris and Flood Control Pools for water conservation purposes by raising their respective maximum elevations to allow for additional water supply storage, would increase the dam's water conservation ability. This extra supply storage would allow for dam releases to downstream spreading grounds and other facilities to Hansen Dam Water Conservation Change management regime of Hansen Dam to focus on 66 The River Project water conservation by maintaining a water conservation pool and Supply within the reservoir during and subsequent to flood season. IV Appendix A Comment Letter to the LACFCD: Draft PEIR 19 onstruction of a 110 MG buried reservoir along with a 4 MW hydroplant at the former Headworks Spreading Grounds to 67 Headworks East Reservoir LADWP replace the storage capacity lost when Ivanhoe Reservoir is removed from service. Needed to bring the Water System into comliance with state and federal drinking water regulations by the regulatory deadline of November 2014 68 Headworks Ecosystem Restoration LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 69 Herondo Parking Lot and Beach City of Redondo Beach Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Infiltration description 70 Hoover, Toll, & Keppel School Glendale Water & Power Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Recycled Water Project description 71 Humboldt Stormwater Greenwav City of Los Angeles, Bureau ofSanitation/Watershed Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Protection Division description Improvements to Entradero Storm City of Torrance, SMBBB Please refer to the Greater Los Angeles County Integrated Drain Channel for Storm Water 72 TMDL Jurisdictional Regional Water Management OPTI database for a project Infiltration and Habitat Restoration Groups 5 & 6 description 73 Improvements to San Gabriel Azusa Light and Water Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project River Diversion and San Gabriel River Water Committee Canal and description Appurtenances 74 Indirect Reuse Replenishment Upper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Protect Johnny Carson Park Stream Please refer to the Greater Los Angeles County Integrated Restoration and Park 75 City of Burbank Regional Water Management OPTI database for a project Revitalization description Multi -jurisdictional Please refer to the Greater Los Angeles County Integrated 76 Jordan Downs Daylighting Study Agencies -LA City Housing Regional Water Management OPTI database for a project and Public Works description 77 LA River Sixth Street Bridge City of Los Angeles, Bureau of Engineering Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Greenway 78 LVM W D Woodland Hills Golf Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Course Recycled Water Pipeline Extension 79 La Puente Valley County Water Upper San Gabriel Valley Municipal Water District & La Puente Valley County Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description District Recycled Water Project 80 Landscape Irrigation Efficiency West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Program (LIEP) 81 Large Landscape Irrigation SurveyUpper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description and Retrofit Project 82 Las Virgenes Creek Bank Stabilization, Stream Restoration. City of Calabasas Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Fish Migration Enhancement and Trail Connection 83 Live Oak Dam InlettOutlet Rehabilitation Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description 19 Appendix A Comment Letter to the LACFCD: Draft PEIR 84 Live Oak Spreading Grounds Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Improvement Project description 85 Lopez Spreading Grounds Improvement Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 86 Los Angeles River Center and Mountains Recreation and Conservation Authority Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Gardens Green Conference Center 87 Los Angeles River Natural Park City of Los Angeles Bureau ofSanitation/Watershed Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Protection Division description 88 Los Angeles River Revitalization City Los Angeles, u of Engineering Bureau Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Master Plan 32 Mile Channel and Easement Greening 89 Los Angeles State Historic Park LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Water Recycling Pro act description 90 Los Angeles -Burbank Groundwater System Interconnection LADWP /Burbank Water and Power Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 91 Los Angeles -Glendale Groundwater System Interconnection LADWP /Glendale Water and Power Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 92 Lower Los Angeles River Area Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Linear Water Storage Feasibility Study 93 Malibu Civic Center Area Recyled City of Malibu Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Water Delivery Project description 94 Malibu Civic Center Linear Park City of Malibu Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Phase 3 description Malibu Drought Preparedness Please refer to the Greater Los Angeles County Integrated Proiect: Graywater Reuse and 95 City of Malibu Regional Water Management OPTI database for a project Rainwater Harvesting description 96 Malibu Equestrian Center Runoff City of Malibu Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project BMPS description Please refer tot he Greater Los Angeles County Integrated 97 Malibu Rainwater Harvesting City of Malibu Regional Water Management OPTI database for a project description 98 Malibu Road/Malibu Malibu Road/Malibu Colony City of Malibu Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project ater Management Stormdescription 99 Manhattan Strand th City of Manhattan Beach Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Subsurface InfiltratioTrenchStreet o n description 100 Manhattan Wells Improvement LADWP/Water Replenishment District Please refertothe Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 101 Marsh Park, Phase II Mountains Recreation and Conservation Authority Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 102 Medea Creek Restoration at City of Agoura Hills Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Chumash Park description 103 Miller Pit Spreading Basins Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 20 Appendix A Comment Letter to the LACFCD: Draft PER 104 Recycled Water Upper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Project Pro act 105 Milton Street Park and Green Mountains Recreation and Conservation Authority Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Street project - Ballona Creek Please refer to the Greater Los Angeles County Integrated 106 Mission Hills Green Belt The River Project Regional Water Management OPTI database for a project description Please refer to the Greater Los Angeles County Integrated 107 Mission Wells Improvement LADWP Regional Water Management OPTI database for a project description 108 North Hollywood Groundwater and Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Surface Water Benefits Study description 109 North Hollywood Street Enhancement City of Los Angeles Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 110 North Hollywood Transmission Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Corridor Easement Stormwater Cture Study ap 111 North Santa Monica Bay Firecamp 13 LID Retrofit Los Angeles County Deprtment of Public Works Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 112 North Santa Monica Bay Probation Camp Miller LID Retrofit Los Angeles County Department of Public Works Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 113 Northeast Gardena Recycled West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Water Line description 114 Northeast Gardena Storm Water Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Quality Park, Recycled Water Line, and Landscape Makeover 115 Northeast Gardena Water and Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Landscape Makeover. Community Involvement Module 116 Oak Park Green Streets Urban County of Ventura Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Retrofit description 117 Oak Park Medea Creek Restoration Mountains Restoration Trust Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 118 Ocean Friendly Garden (OFG) West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Program 119 Olive Pit Water Conservation Park Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 120 Oxford Retention Basin Multi -Use Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Enhancement Project description 121 Ozone Park Runoff Treatment and Reuse Project City of Santa Monica Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 122 Pacoima Dam Inlet/Outlet Works Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project Rehabilitation Project description Please refer to the Greater Los Angeles County Integrated 123 Pacoima Neighborhood Retrofit The River Project Regional Water Management OPTI database for a project description 21 Appendix A Comment Letter to the LACFCD: Draft PEIR 124 Pacoima Reservoir Sediment Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Removal description 125 Pacoima Spreading Grounds Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Improvements 126 Palos Verdes Peninsula Satellite West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Facilities Study description 127 Palos Verdes Recycled Water West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Lateral description 128 Pasadena Recycled Water Proiect Pasadena Water and Power Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 129 Peck Water Conservation Improvement Pro act Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 130 Puddingstone Diversion Dam Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Inlet/Outlet Works Rehabilitation description 131 Raw Wastewater Diversion to the Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project City of Los Angeles description 132 Recycled Water On -Site Retrofit West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Projects 133 Recycled Water Storage and Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Distribution System Expansion 134 Recycled Water Supply for Palos City of Palos Verdes Estates Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Verdes Golf Course description Water Replenishment Please refer to the Greater Los Angeles County Integrated 135 Recycled Water Turnouts District of Southern Regional Water Management OPTI database for a project California description 136 Regional Water Supply Reliability Puente Basin Water Agency Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Program Phase 1b 137 Residential Indoor Plumbing West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Retrofit Kits description 138 Residential SMART Timer Retrofit West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description "Plus" Program 139 Rio Hondo Coastal Basin Spreading Grounds - Sediment Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Removal from Basins Crescents Valley Water Please refer to the Greater Los Angeles County Integrated 140 Rockhaven Well District and Glendale Regional Water Management OPTI database for a project Water and Power description 141 SMURRF Distributed Water City of Santa Monica Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Reuse Proiect description 142 San Gabriel Coastal Basin Spreading Grounds Improvement Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Proiect 143 San Gabriel Dam Penstock Coatings and Valve Repair Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description 22 Appendix A Comment Letter to the LACFCD: Draft PEIR 144 San Gabriel Valley Water Recycling Project (Phase I - Rose Upper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Hills Expansion) 145 San Gabriel Valley Water Recycling Project - Membrane Upper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Bioreactor Treatment Plant 146 San Jose Creek Water Reclamation Plant East Process County Sanitation Districts of Los Angeles County Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Optimization Project Please refer to the Greater Los Angeles County Integrated 147 San Rafael Creek Restoration Arroyo Seco Foundation Regional Water Management OPTI database for a project description 148 San Ramon Canyon Stormwaler City of Rancho Palos Verdes Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Flood Reduction Project description 149 Santa Anita Dam Seismic Rehabilitation Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 150 Santa Fe Dam Water Conservation Pool Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 151 Santa Fe Spillway Basins Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 152 Sawpit Debris Dam Seismic Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Strengthening Prole ct description City of Los Angeles 153 Septic -To -Sewer Drinking Waterwell Protection Protect Bureau of Sanitation/Wastewater Engineering Services Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Division 154 Sepulveda Basin Sports Complex A1 eles, City of Los ABureau of Engineering Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Multi -Purpose Oben Space Project 155 Sepulveda Basin Sports Complex City of Los Angeles, Bureau of Engineering Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Riparian Buffer Please refer to the Greater Los Angeles County Integrated 156 Sheldon Pit LADWP Regional Water Management OPTI database for a project description 157 Shoestring Park Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 158 Silver Lake Reservoir Bypass & LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Regulator Station description 159 Six Basins and Puente Basin Puente Basin Water Agency Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Integrated Water Supply Project Los Angeles County Please refer to the Greater Los Angeles County Integrated 160 South Coast Botanic Gardens Department of Public Regional Water Management OPTI database for a project Works description 161 South EI Monte Recycled Water Upper San Gabriel Valley Municipal Water District & San Gabriel Valley Water Company Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Expansion Project Package 1 162 South EI Monte Recycled Water Upper San Gabriel Valley Municipal Water District & San Gabriel Valley Water Company Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Expansion Project 23 Appendix A Comment Letter to the LACFCD: Draft PEIR 163 South Los Angeles County Groundwater Pipline Protect Water Replenishment District of Southern California Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 164 South Park Subsurface Infiltration City of Hermosa Beach Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Gallery 165 Southeast Gardena Recycled West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Water Line description 166 Stormwater Diversion to Walnut City of Torrance Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project Avenue Sump description 167 Sun Valley Watershed Rory M. Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Shaw Wetlands Park Protect (a.k.a. Strathern Wetlands Park) 168 Taylor Yard River Park Parcel G2 City of LOS Angeles, Bureau of Engineering Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 169 Terminal Island WRP Advanced LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Water Purification Facility and Distribution System Expansion Proiect Terminal Island WRP Advanced Please refer to the Greater Los Angeles County Integrated Water Purification Facility and 170 LADWP Regional Water Management OPTI database for a project Distribution System Expansion description 171 Thousand Oaks Boulevard and Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Westlake Elementary Recycled Water System Extension 172 Topanga Connection Acquisition Mountains Restoration Trust Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 173 Transfer Station Cover Structure City of Inglewood Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description and Site Improvements 174 Triunfo Community Park and Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Evanstar Park Recycled Water Extension 175 Trunk Sewer Rehabilitation Proiects Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 176 Turfs Up Water Use Efficiency West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Program 177 Valley Generating Station Stormwater Recharge Project LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 178 Van Ness and Slauson Infiltration City of Los Angeles Bureau of Sanitation Watershed Protection Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Best Management Proiect Division description 179 VerdHills Stormwater Protect City of Los Angeles, Bureau Bureau ofugo Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Protection Division description 180 Vermont Avenue Storm Water City of Los Angeles, Bureau of Sanitation/Watershed Protection Division Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Capture and Green Street Beautification Proiect 24 Appendix A Comment Letter to the LACFCD: Draft PEIR 25 Please refer to the Greater Los Angeles County Integrated Council for Watershed 181 Vermont Median Stormwater Park Regional Water Management OPTI database for a project Health description Please refer to the Greater Los Angeles County Integrated Victoria Street CSUDH Water 182 City of Carson Regional Water Management OPTI database for a project Reuse Concept Proposal description Water Replenishment Please refer to the Greater Los Angeles County Integrated 183 WRD Eco Gardener Program District of Southern Regional Water Management OPTI database for a project California description Please refer to the Greater Los Angeles County Integrated Walnut Creek Spreading Basin Los Angeles County Flood 184 Regional Water Management OPTI database for a project Improvements Control District description Please refer to the Greater Los Angeles County Integrated Water Budget Based Rate Las Virgenes Municipal 1$5 Regional Water Management database for a project Implementation Water District description Please refer to the Greater Los Angeles County Integrated West Basin Municipal 186 Water Star Schools Pilot Program Regional Water Management OPTI database for a project Water District description Please refer to the Greater Los Angeles County Integrated San Gabriel County Water 187 Well 15 Regional Water Management OPTI database for a project District description Please refer to the Greater Los Angeles County Integrated 188 Well 7 City of Inglewood Regional Water Management OPTI database for a project description Please refer to the Greater Los Angeles County Integrated 189 Well No. 2 Rehabilitation City of Inglewood Regional Water Management OPTI database for a project description Please refer to the Greater Los Angeles County Integrated Los Angeles County Flood 190 West Coast Basin Barrier Pro act Regional Water Management OPTI database for a project Control District description Westlake Filtration Plant Please refer to the Greater Los Angeles County Integrated es Municipal Laser 191 Enhancement & Backbone Regional Water Management OPTI database for a project Water Dist District Improvements description Please refer to the Greater Los Angeles County Integrated West WeWestward Beach Road st rd B 192 City of Malibu Regional Water Management OPTI database for a project ilt Proiect Bioindescription City of Los Angeles Please refer to the Greater Los Angeles County Integrated Westwood Neighborhood Bureau of Sanitation 193 Regional Water Management OPTI database for a project Greenway Project Watershed Protection Division description Please refer to the Greater Los Angeles County Integrated Whiting St. and EI Segundo Blvd. 194 City of EI Segundo Regional Water Management OPTI database for a project Dry Weather Diversion Structure description Whitnall H WY Powerline Please refer to the Greater Los Angeles County Integrated 195 Easement Stormwater Capture LADWP Regional Water Management OPTI database for a project Proiect description 25 October 23, 2014 Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 (626) 300-3298 gbegell@dpw.lacounty.gov Enrique Huerta At -Large Stakeholder Downey, CA 90242 Los Angeles County ehuerta28@gmail.com (323)573-0129 RE: Public Comment: Notice of Preparation of a Draft Program Environmental Impact Report for Enhanced Watershed Management Programs Dear Mr. BeGell: Thank you for your efforts on the Notice of Preparation (NOP) of the Draft Program Environmental Impact Report for the Enhanced Watershed Management Programs (EWMP). I am confident your work will result in an informative and precise first tier final Program Environmental Report (PEIR) that is adequate, complete, and a good faith effort at full disclosure. The purpose of my comments, per Section 15168(c)(5) of the 2014 California Environmental Quality Act (CEQA) Statute and Guidelines, is to assist in the creation of a PEIR "that deals with the effects of the program as specifically and comprehensively as possible." Additionally, I realize that by doing "a good and detailed analysis of the program, many subsequent activities could be found to be within the scope of the project described in the program EIR, and no further environmental documents would be required." I recognize and appreciate the herculean task involved for the Flood Control District and it is my sincere attempt to keep my comments relevant to the NOP. As such, I have attempted to draft my comments in a reader -friendly manner that identify the issue and, wherever possible, propose a feasible solution. My comments only address the content of the NOP. COMMENTS ON THE CONTENT OF THE NOP 1. Introduction COMMENT No. 1: (Page No. 2) Please elaborate on the approval process. It would be informative if the role between the Los Angeles County Flood Control District (LACFCD) and the Los Angeles Regional Water Quality Control Board (LARWQCB) is further explained. The introduction does a good job explaining the steps involved in the EWMP process, but lacks clarity on the connection between the PEIR and LARWQCB. In particular, the sentence in mind states, "The LARWQCB is responsible for approval of the EWMPs in compliance with the MS4 Permit. Implementation of the EMWPs would occur following approval by the LARWQCB." If the LARWQCB approves the EWMPs then who adopts the final PEIR? How does this PEIR fit into the responsibilities and mandates of the LARWQCB? All 12 of the EWMPs specify a date when the final EWMPs will be submitted (June 2015) to the LARWQCB, but no mention is made about the PEIR. In addition, the NOI submitted to the LARWQCB by each Watershed Management Group (WMG) span two programs: the EWMPs 'and' Coordinated Integrated Monitoring Programs (CIMP). What is a CIMP? Does this PEIR also analyze the CIMP? COMMENT No. 2: (Page 2) Project Location — Please elaborate as to whether the policies and plans of the EWMPs are targeting public property, public right-of-ways, land owned by the LACFCD and/or private property. COMMENT No. 3: (Page 4, Figure 1—Overview of EWMP Groups) The EWMP groups only identify a total of 47 participating cities (Permittees) throughout los Angeles County. However, there are 37 remaining Permittees throughout Los Angeles County that are not part of the EWMP groups. Is this PEIR broad enough in scope for Los Angeles County? How will the remaining 37 cities meet compliance goals and strategies under the 2012 MS4 Permit? COMMENT No. 4: (Page 5) The opening paragraph states that "The primary approach to each of the EWMPs, as identified in the Draft Work Plans, includes identifying community -friendly, cost- effective methods of reducing urban runoff pollution and incorporating distributed and centralized structural and nonstructural watershed control measures for a multi -pollutant, multi -benefit approach." However, a review of all 12 EWMPs indicates that there was no cost/benefit analysis or any modeling completed to substantiate the "cost-effectiveness" of these methods. Please identify any additional documentation supporting this claim. COMMENT No. 5: (Page No. 5) This comment attempts to clarify the scope of the PEIR by asking, "how much information is enough?" Please clarify the use of the term "project." The final sentence in the first paragraph states, "The EWMPs will also evaluate multi -benefit regional projects that will retain (through infiltration or capture and reuse) the stormwater quality design volume (85th percentile storm for 24 hours) for the runoff from the contributing drainage area." Evaluating, site -level projects at the PEIR level creates a lack of agreement between the inherent programmatic and geographic scope of the PER and the site-specific goal of a single -project EIR, as Section 21002.1(d) of the CEQA Statute states, "to consider the effects, both individual and collective, of all activities involved in 'a' project." I reviewed all 12 of the EWMPs and CIMPs and they do not identify projects currently in the works and no analysis is provided. The EWMPs seem to be evaluating plans and policies. Clarification of the term project would be beneficial in order to clearly understand the scope of this PER Providing additional contrast is, Section 21003 which states, "All persons and public agencies involved in the environmental review process be responsible for carrying out the process in the most efficient, expeditious manner in order to conserve the available financial, governmental, physical, and social resources with the objective that those resources may be better applied toward the mitigation of actual significant effects on the environment." In an effort to avoid the possibility of imposing an unfunded mandate on local cities and/or non-profit groups to undertake the second tier of this PEIR, the prudent use of public funds, and to promote a second tier CEQA process that is streamlined, I feel it would be beneficial to incorporate an analysis of current projects in the "pipeline." This is critical because a review of the Greater Los Angeles County Integrated Regional Water Management (IRWM) database reveals over 190 water resources projects with regionally - significant benefits in the pipeline (Attachment A). The IRWM is a funding mechanism that encourages regional and local collaboration in the design of sustainable water resources infrastructure. To date, regional agencies, cities, non -profits and community representative groups, have collaborated and submitted project proposals of regional significance. Not all of these projects incorporate BMPs, per say (many do), and many have already been deemed categorically exempt. Additional vetting would need to take place in order to identify projects in-line with a low impact development ideal to collaborate and integrate compliance strategies that are based on a multi -pollutant approach with a focus on green infrastructure that maximize the retention and use of urban runoff as a resource for recharging aquifers and for irrigation and other uses. 0 If this nexus to analyze the impacts of regional projects is deemed reasonably feasible, further vetting of the projects would be required to understand their CEQA status. The question is who conducts this analysis, the LACFCD or the WMGs? This is important to figure out since Section 15152(b) of the CEQA Statute and Guidelines states that, "Tiering does not excuse the lead agency from adequately analyzing reasonably foreseeable significant environmental effects of the project and does not justify deferring such analysis to a later tier EIR or negative declaration." COMMENT No. 6: (Page 5) The second paragraph states, "The PER will provide a program -level assessment of the overall permit compliance effort, focusing particularly on the structural watershed control measures proposed in each of the 12 EWMP areas." The project list on Attachment A identifies projects aiming to implement watershed control measures throughout Los Angeles County. Many of these projects are categorically exempt, have concluded their own environmental assessment or already constructed, however, the database (L.A. Water Plan) where I retrieved these does not clearly indicate this information. Furthermore, none of the 12 EWMPs under consideration undertook this task to see how the proposed physical changes within their EWMP may or may not comply with the goals and objectives of their respective plans and policies. In an effort to, as Section 15152© describes, "avoid deferring the potential significant impacts to the second tier and possibly preventing the adequate identification of significant effects of the planning approval at hand," it may be worthwhile to include this list of "reasonably foreseeable" regional projects in the PEIR analysis or have the WMGs revise their draft plans to incorporate this analysis. 1.1 Project Location COMMENT No. 7: Refer to Comment No. 2. In addition, the description of the location could be augmented by elaborating on the baseline environmental context. Also, adding maps identifying the tributaries, rivers, channels, etc. within the 12 watersheds could increase understanding of the local watershed functional characteristics. The maps are contained in most of the individual EWMPs. A reference to the website location of each respective EWMP could suffice. Additionally, there is no reference to the types of soils that underlie the 12 EWMPS. The EWMPs provide a summary of these soil characteristics. A reference to the website location of each respective EWMP would be helpful. It is important to know the soil types and their respective infiltration rates in order to understand the feasibility of implementing certain structural BMPs. I realize that this may be covered in more depth under the Geology, Soils and Seismicity category, but there is no clear reference in the accompanying summary. 2. BACKGROUND 2.1 Stormwater/Water Quality COMMENT No. 8: (Page 7) The first paragraph states, "Discharges may adversely affect receiving surface water quality with pollutants such as bacteria, nutrients (nitrogen and phosphorus), aluminum, copper, lead, zinc, diazinon, and cyanide. Aquatic toxicity, particularly during wet weather, is also a concern. Stormwater and non-stormwater discharges of debris and trash are also a pervasive water quality problem in the Los Angeles region." It would be beneficial to add the types of pollution stemming from the natural environment (non -anthropogenic), too. What kind of pollutants exists in the stormwater resulting from the erosion of soil from natural settings and undeveloped vacant parcels of land? 2.2 Total Maximum Daily Loads COMMENT No. 9: A sentence in section reads, "A TMDL is defined as the "sum of the individual waste load allocations (WLAs) for point sources and load allocations for nonpoint sources and natural background" (40 CFR 130.2), such that the capacity of the water body to assimilate constituent loads (the loading capacity) is not exceeded." What currently happens when TMDLs are exceeded? Is there a monetary fine? 2.3 MS4 Permit COMMENT No. 10: (Page 7) This section states, "The MS4 Permit identifies conditions, requirements, and programs that municipalities must comply with to protect regional water resources from adverse impacts associated with pollutants in stormwater and urban runoff." What currently happens if these conditions or requirements are not met by municipalities? Is there a monetary fine? 3. Enhanced Watershed Management Plans COMMENT No. 11: As mentioned in the first comment under the Introduction heading, please elaborate on the approval process. Specifically, how the PEIR fits into the LARWQCBs approval of the EWMPs. Additionally, there's a sentence that states, "The 2012 MS4 Permit includes provisions that allow Permittees to voluntarily choose to implement a EWMP to achieve permit compliance with RWLs." How will permit compliance be verified and who will monitor compliance? 4.1.1 Regional Structural BMPs COMMENT No. 12: The second paragraph states, "Opportunities for Regional BMPs will be identified and evaluated within and across subwatersheds, with focus on the multi -benefit potential for capture and reuse of wet -weather flows within variable drainage areas." What method and level of detail will be used to identify and evaluate BMPs? This paragraph goes on to state that, "Potential project locations may include areas with open spaces, whether they are within parks, large parking lots, or vacant spaces," indicating that a geographically site-specific analysis is appropriate under this PEIR. Collectively, there is over 190 regional projects identified in Attachment A being proposed by the various members of the WMGs. Based on the site-specific potential project locations stated above, is it feasible to include an analysis of the project list (Attachment A)? Potential Environmental Impacts COMMENT No. 13: This section (nor the LACoH2Osheds website) does not reference the completion of an Initial Study per Section 15063©(1), nor provide clarity as to what is not being decided. How did the Lead Agency identify the effects determined not to be significant? Is there an explanation of the reasons for determining that potentially significant effects would not be significant? COMMENT No. 14: The sentence that states, "The PEIR will assess the physical changes to the environment that would likely result from the construction and operation of EWMP projects," does not reference assessing the physical changes that would result from 'maintenance' of said project(s). COMMENT No. 15: Air Quality Category — In an effort to help identify California communities that are disproportionately burdened by multiple sources of pollution, this category should also consider evaluating the air quality data collected by the Office of Environmental Health Hazard Assessment's (OEHHA) California Communities Environmental Health Screening Tool Version 2.0 (CalEnviroScreen 2.0). COMMENT No. 16: Hazards and Hazardous Materials — In an effort to help identify California communities that are disproportionately burdened by multiple sources of pollution, the following sentence, "Potential hazards will be evaluated and assessed by reviewing the data collected by the California State Water Resources Control Board (SWRCB) GeoTracker and the California Department of Toxic Substances Control (DTSC) Envirostor databases," should also consider evaluating the data collected by the OEHHA California Communities Environmental Health Screening Tool Version 2.0 (CalEnviroScreen 2.0). COMMENT No. 17: POPULATION AND HOUSING/GROWTH INDUCEMENT—Assuming that not all cities have the staff or capacity to implement the objectives of the plans and policies of EWMPs, what are some of the unforeseen consequences of minimal to no implementation of BMPs or LID in communities/cities with low median household income? Will these cities bear an unfair burden of paying non-compliance fines? Sincerely, Enrique Huerta, M.S. Attachment A Reasonably Foreseeable Water Resources Projects in LA County - NOP: Draft PEIR, EWMP Project Name Project Proponent Project Description The project proposes to construct a 25mgd Seawater Desalination Plant in West Basin's service area for potable water use. First, a Demonstration Plant will be necessary to evaluate the water quality performance and treatment stability, assess efficient energy recovery devices, optimize operational performance utilizing full scale process equipment, and to acquire the necessary data to achieve regulatory compliance and approval. West Basin and its 1 25 mad Sea Water Desalinization West Basin Municipal partners will perform the full battery of water quality analyses Plant in West Basin Water District to ensure that the demonstration project meets all Federal and State Drinking Water Standards. With the knowledge gained by operating the Demonstration Plant, West Basin expects to move forward with the planning, design, and construction of a full scale 25,000 AFY seawater desalination and education facility. West Basin anticipates operating the Demonstration Plant for at least two years while plans are being completed and finalized for the full- scale plant. The Demonstration Facility is in design. The project consists of replacing the older water meters in Waterworks District No. 29. The District maintains approximately 7,700 water meters in Malibu and Topanga. About 40 percent of the meters are older than 15 years and 30 percent are 20 years or older. Meters lose accuracy over time, representing unaccounted water consumption in the District. Older meters typically under -measure water use. Los Angeles County Replacing old water meters with automated meter reading 2 AMR Conversion Protect Waterworks District No. (AMR) meters will yield timely, reliable water consumption 29 patterns for detecting leaks and producing accurate customer bills. Higher bills with higher water use volumes will alert District customers about their water consumption habits, which is expected to encourage conservation. The current practice is to replace meters as the meters stop functioning or become unreadable. About 20% of the water meters in Malibu and Topanga have been replaced with AMR meters. The project would extend the existing recycled water line along Agoura Road to serve existing customers who use potable waterfor landscape irrigation. Pipeline forthis project is estimated at 9250 feet of 8 inch pipe and would 3 Agoura Road Gap Recycled Water Las Virgenes Municipal connect to existing recycled water pipelines on both east System Expansion Water District and west sides of the extension. This would connect the gap that exists between Reyes Adobe Road and Lewis Road and improve the system hydraulics and reliability of service to customers. The estimated maximum daily demand for the Agoura Road Extension is 73 gpm. Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP Restore 20 acres at Ague Amarga Reserve, to provide habitat for the Federally threatened Coastal California gnatcatcher, the Federally endangered Palos Verdes blue butterfly, and the rare cactus wren. A one -mile trail in the Reserve continues to the coast. A year-round flow of water is discharged to the head of Lunada Canyon via a County of Los Angeles storm drain; the water then flows below ground Palos Verdes Peninsula through the canyon, the course of an historic blue line 4 Aqua Amarga Lunada Canyon Land Conservancy &City stream, and re-emerges al its confluence with Ague Amarga Habitat Restoration of Rancho Palos Verdes Canyon, also a blue -line stream that flows into the Santa Monica Bay. Invasive plant species provide little water infiltration and threaten to spread to the pristine lower canyon. The project will remove invasive plants, restore 18 acres of riparian and coastal sage scrub; install 2 acres of cactus scrub in highly degraded fuel modification areas; improve trails and add trail signage. Interpretive signage will educate hikers about creating wildlife -friendly fuel modification zone. Stormwater runoff would be diverted from Aliso Creek and from Limekiln Creek and stormwater runoff generated on site will be treated. In addition to providing water quality benefits, the project will result in the creation of self-sustaining riparian woodland vegetation and other re -vegetated areas, as well as providing recreational opportunities to area residents.The site has an area of approx. 11.8 acres and is City of Los Angeles currently used as a flood control facility, provides open 5 Aliso Creek - Limekiln Creek Bureau of Sanitation space, and serves as part of Vanalden Park.Wet weather Restoration Project Watershed Protection runoff and dry weather runoff from an approx. 12,091 acres Division that drains to the confiuence of Aliso Creek and Limekiln Creek is going to be captured and conveyed to the project site for treatment.On-site generated flows will also be captured and treated.Proposed BMPs to treat captured water:Low flow channel diversions and pumping:Pre- screening devices, Bioswales, Vegetated detention basins, Landscaping with native upland and riparian species and Installing decomposed granite pathways. Alondra Regional Park is a multi -benefit project that serves disadvantaged communities while meeting IRWMP water management objectives. The entire site is currently an empty 18 -acre lot owned by the City of Compton. This proposal is for Phase I of the project and covers 12 acres on the southern half of the parcel. The park provides recreational opportunities while improving surface water discharges into the Dominguez Channel Watershed. The project site sits low 6 Alondra Regional Park Successor Agency, City of on the drainage area and will capture 1.5AF of stormwater. Compton The park features a swale and daylighted stream to remove nutrients and pollutants that otherwise flow to local waterways. The large biofiltration field will reduce peak flows, improve water quality and occasionally serve as a recreational field. Surface water quality improvements would help the region meet requirements under the Municipal Separate Storm Sewer System Permit. The project also includes native shrubs and trees that will increase habitat for birds, butterfly species and mammals. Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEI R, EWMP As with the original Decker Canyon Recycled Water Extension pipeline route, this alternate would primarily serve the Malibu Golf Club, the largest potable water user in the LVMWD service area. The 2007 Master Plan advocated that serving the golf course with recycled water could be an important strategy for relieving eventual stress on the Alternative Decker Canyon Las Virgenes Municipal potable system. The longer alternative route used in this Recycled Water Extension Water District project would also serve other demands along the way. In addition to the golf club, significant recycled water demands are expected to come from a new development (Triangle Ranch) and conversion of the existing Medea Valley ranchettes to recycled water use. The project is projected to deliver 459 AF/Y of recycled water, offsetting the same amount of potable demand that would occur if the extension were not built. The project will consist of a diversion, conveyance pipes, a gross solids removal device (GSRD), an irrigation storage tank, and an infiltration gallery. Dry- and wet -weather flows will be diverted from the existing storm drain up to the maximum diversion flow rate and will then enter the storage tank through the conveyance pipe and GSRD. Once the Andrews Park Subsurface storage tank reaches a depth of 1.5 feet, flows will be 8 Storage, Use and Infiltration City of Redondo Beach pumped to be used for onsite subsurface irrigation. When the storage volume of the irrigation tank reaches capacity, Project runoff will flow via an overnow pipe into the infiltration gallery, where the water will infiltrate subsurface soils. When continual flows fill the infiltration gallery and irrigation storage vault to storage capacity, diverted flows will back-up through the diversion piping and prevent additional flow diversion until capacity is freed up due to irrigation use and/or infiltration losses. The Confluence Gateway Greenway Program will restore a 1/3 mile stretch of urban land alongside the Arroyo Seco, in the Arroyo Seco Scenic Byway Corridor, into a riparian greenway and open space park with native landscaping and a bicycle/pedestrian path. Not only would the project embody a first step in enhancing river access and recreation opportunities, it would provide a key link between the 9 Arroyo Seco Confluence Gateway Arroyo Seco Foundation planned Los Angeles River greenways at the confluence and the Metro Rail station in the historic Lincoln Heights neighborhood, thus enabling light rail and bicycle access to the Arroyo Seco and the Los Angeles River. Ultimately, the Arroyo Seco greenway is envisioned to extend to South Pasadena, and this initial segment at the confluence would be an important hub in the regional river parkway and bicycle trail network. Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP Naturalize north branch storm drain and restore stream through Sycamore Grove Park. Primary Objectives Addressed by the Project: By re-establishing an urban stream, this project addresses water quality, riparian habitat restoration, groundwater recharge, flood management, and public education. The Sycamore Grove Park site is approximately 800 feet long and 400 feet wide. This 8 -acre 10 Arroyo Seco North Branch Creek Arroyo Seco Foundation site is located in northeast Los Angeles and situated west of Davliahtina the SR -110 (). This site encompasses Sycamore Grove Park and is bounded by South Avenue 49 to the northeast, the SR 110 to the east, medium density residential uses to the south, and North Figueroa Street to the west. Sycamore Grove Park is a landscaped area consisting of a large lawn, playground, and parking area. The North Branch tributary is contained within a storm drain beneath Sycamore Grove Park. For centuries the waters of Baldwin Lake have sustained human endeavor. A rich historic site, its role began in the Native America period when springs and marsh, precursors to today's lake, supported nearby habitation. In the late 19th Century, Elias Jackson Baldwin chose the Lake as the center for agriculture and land development that shaped the establishment of the east San Gabriel Valley. Today, as the centerpiece of the Los Angeles County Arboretum, the Lake 11 Baldwin Lake Los Angeles Arboretum is an educational and scenic resource serving hundreds of Foundation thousands of visitors. Looking to the future, Baldwin Lake is envisioned as a model for community-based environmental stewardship and regional approaches to water management and conservation. Ideally located at the edge of the Raymond Basin aquifer, the Lake offers great potential as the nexus for water management and ground water recharge for the Arboretum's 127 acres, as well as the surrounding urban watershed. Educational programming that interprets the history of the Lake, particul Project is to implement the valuable uses of stormwater and to improve the water quality in Ballona Creek Watershed. Ballona Creek Low Flow Treatment Facility (LFTF), also known as North Ouffall Treatment Facility (NOTF), is one of several projects proposed in Ballona Creek TMDL Implementation Plans for Bacteria, Metals, and Toxic Pollutants. The LFTF includes a 1 million gallon storage Ballona Creek Water Quality and City of Los Angeles facility and has the capacity to treat up to 150 cis, including 12 Beach Improvement & Beneficial Bureau of Sanitation screening of coarse, fine sediments, and disinfection with Use Project Watershed Protection sodium hypochlorite. NOTF was constructed in 1987 by City Division of Los Angeles. The project proposes to use the existing treatment facility and construct a low -flow diversion structure in Ballona Creek Channel to divert and treat full dry -weather flow and partial wet -weather flow. 65 percent of Ballona Creek Watershed (85 square miles) is located upstream of the Project, with average dry -weather flows ranging from 14 to 25 cfs. Treatment will include coarse screens, sedimentation, filtration, and disinfection. Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP The City of Burbank proposes to expand and increase water conservation through the expansion of a comprehensive indoor/outdoor financial incentive program that will result in immediate and sustainable water savings. The proposed Rebate Program to install 1,300 HE toilets, replace 300,000 square feet of turf with native landscapes, capture and reuse rain water 3 million gallons of rain water with rain barrels, 13 Be A Water Saver Water City of Burbank Water and and increase water conservation education efforts will save Conservation Program Power an estimated 500 AF of water annually. Grant funding for the proposed project will facilitate greater water savings by providing funding for greater levels of participation sooner than would be realized under typical funding efforts. Furthermore, these benefits will be realized faster by utilizing a proven system for conservation, a truly ready to proceed project. This project has the potential to double participation levels. This project will consist of planning, design, and construction of approximately 4,625 feet of new 8 -inch PVC and Ductile Iron recycled water pipeline to extend Glendale's recycled water distribution system from the intersection of Flower St. and Grandview Ave. to Bette Davis Park. Approximately 14 Bette Davis Park Water Recycling LADWP 4,300 feet of pipeline will be installed within Glendale's city Project right of way. Through an Agreement with the City of Glendale, this project will be designed and constructed by Glendale's contractors and LADWP will reinburse Glendale for the costs. This will reduce the City's potable demand for non -potable uses. This project will offset up to 75 AFY of potable water with recycled water. This project will upgrade the sluiceway to function as a low level outlet for regulating flows under high reservoir pressure and repair various facility components for the dam. The existing sluice gate at the upstream end is to be replaced with a new heavy duty hydraulic actuated gate, the Big Dalton Sluiceway Los Angeles County Flood sluiceway is to be lined with new pipe for the entire length, 15 Rehabilitation Control District and a throttling valve is to be installed at the outlet. Storm releases through the sluiceway will reduce the rate of sediment accumulation and prevent sediment deposits at the face of the dam. Incoming sediments during storm flows could be routed through the reservoir to restore a more natural sediment transport system and maintain reservoir capacity The proposed project will modify and motorize the diversion box at Big Dalton Spreading Grounds to better control flows taken into the facility. The spreading basins will be reconfigured to increase percolation rates and storage 16 Big Dalton Spreading Grounds Los Angeles County Flood capacity. An intake will be constructed from Little Dalton Improvements Control District Diversion Channel so that additional storm flows can be diverted to the facility. A proposed outlet from Metropolitan Water District's PM -26 imported water line to the Little Dalton Diversion channel will enable imported water to be recharged at the spreading grounds. Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP The project consists of constructing three 18 -inch diameter bypass water pipelines approximately 1,500 feet in length within the areas of active landslides along Pacific Coast Highway. This bypass will serve as a permanent replacement of an existing 30 -inch diameter water pipeline Los Angeles County that has experienced significant breaks resulting in large 17 Bio Rock Bypass Waterworks District No. water loss. The proposed pipeline will be raised to a shallow 29 trench and protected by a reinforced concrete box covered with steel plates to provide quick access if any leakage occurs. In addition, 18 -inch Flexible Expansion Joints will also be installed at several locations with the areas of the active landslides to prevent damage or rupture of pipelines from ground movement. Los Angeles County Flood Construction of a dam within the spillway at Big Tujunga 18 Big Tuiunga Dam Spillway Dam Control District Dam to increase the maximum storage capacity of the reservoir by approximately 705 acre-feet. The 2009 Station Fire was the largest fire in Angeles National Forest recorded history and burned over 160,000 acres before containment on October 16, 2009. Approximately 87% of the watershed tributary to Big Tujunga Reservoir was affected. On average, a watershed will take five years or more to recover from a forest fire bum. During this time, increased amounts of debris production are anticipated from the denuded ground surface. Based on the Bio Tuiunga Reservoir Sediment Los Angeles County Flood 2010-11 storm season surveys, the total amount of sediment 19 Control District in the Big Tujunga Reservoir is approximately 2 million cubic Removal yards. The County of Los Angeles Department of Public Works on behalf of the Los Angeles County Flood Control District proposes a sediment removal project to permanently remove up to 4.4 mcy of sediment from Big Tujunga Reservoir. Sediment will be excavated and transported using low emission trucks or conveyor belt to Maple Canyon Sediment Placement Site adjacent to Big Tujunga Dam. The project will be completed over four years starting in the sum 20 Boulevard Pit Stormwater Capture LADWP Acquire and develop Boulevard Pit into a multi -use retention Project and recharge facility to enhance stormwater conservation. Branford Spreading Ground has very low percolation rates compared to the Tujunga Spreading Ground directly across the Tujunga Wash Channel. This project will install a pump 21 Branford Spreading Basin Los Angeles County Flood from Branford Spreading Ground to direct water into the Cleanout and Pump Control District Tujunga Spreading Ground leading to more groundwater recharge. In addition, the project will clean out the clogging layer at the bottom of basin, which will also improve percolation rates. Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP In partnership with Water Replenishment District of Southern California and it's "Regional and Distributed Stormwater Capture Feasibility Study," the proposed project will design and implement stormwater Best Management Practices (BMPs) in the City of Los Angeles with the primary goals of TMDL compliance and stormwater infiltration. Three levels of BMPs will be developed; local parcel based Low Impact Broadway Neighborhood City of Los Angeles Development (LID) for 8 acres (60 residential parcels), 22 Stormwater Greenway Protect Bureau of Sanitation neighborhood scale LID for 12 acres (3 residential streets and 2 blocks of commercial streets), and a sub -regional scale facility for 30 acres of mixed land uses. The local and neighborhood BMPs will capture and infiltrate all dry -weather flow and up to the ''% inch storm. The sub regional BMP will capture up to the 2 inch storm for 30 acres. The sub regional BMP will also receive dry -weather flows from 228 acres of mixed land uses. Designs will be standardized to remote widespread implementation. Historical records show that an annual average of 625 acre- feet of water passes though Bull Creek. All flows from Bull Creek are lost to the ocean via the Los Angeles River. This 23 Bull Creek Stormwater Capture Los Angeles County Flood project proposes conserving the lost water by diverting flows Control District from the new LADWP facility using a rubber dam and conveying flows through a pipeline to Pacoima Spreading Grounds where it would be captured and recharge the local aquifier. Plan, design, and construct stormwater conveyance facilities for compliance with the Enhanced Surface Water Treatment Rule. Facilities will be designed according to standards adopted by Department of Water Resources, Division of Bull CreekLos Angeles Reservoir Safety of Dams. Improvements include widening a portion of Water Quality Improvement 24 LADWP the Bull Creek Extension Channel, realigning a section Protect downstream of the widening, construction of a new diversion structure and overnow structure, and improvements to inlet structures. The Los Angeles Reservoir spillway will be removed from service. Proposed design facilitates a future stormwater capture program. The Burbank Partnership Water Recycling Project involves the planning, design, and construction of approximately 27,000 feet of recycled water pipelines in the North Hollywood area. The three individual segments that comprise the project are the Chandler Boulevard Bike Path 25 Burbank Partnership Water LADWP segment, the Whitnall Dog Park segment, and the North Recycling Protect Hollywood Park segment. These segments will connect to Burbank's recycled water distribution system at three separate connection points and will be served by recycled water treated at the Burbank Water Reclamation Plant. This project is expected to offset up to 285 AFY of potable water with recycled water. Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP The third phase of the City of Burbank's recent recycled water system expansion. As a result of previous phases, over 20 miles of recycled water pipelines have been installed resulting in the distribution of over 2,300 AF of recycled water annually; amounting to 13% of the City's water demand by the end of 2014. The City will continue expanding its recycled water distribution to offset potable Burbank Water and Power water use in this phase by constructing two new recycled 26 Recycled Water System City of Burbank Water and water pipelines known as, the LA Equestrian Center (LAEC) Expansion, Phase 3 Power and the Naomi pipelines. The LAEC is located on the borders of the cities of Burbank and Los Angeles consisting of landscape areas, stables, offices and corrals; the latter requiring dust control with water trucks. The Naomi pipeline would primarily provide recycled water to a very large commercial data center and smaller customers. Completion of these pipelines will increase recycled water distribution by an estimated 61 AFY, resulting in a direct and immediate potable water savings of 61 AF annually. The Desalter currently has the capacity to extract up to 2,000 acre-feet annually of brackish water. In 2003 the old wells at the site were decommissioned and construction began in 2005 for the first replacement well. The facility became operational in 2006 at a reduced capacity using the new well and the original RO unit. The facility has not been operating to its full capacity since it came online again in C Marvin Brewer Desalter West Basin Municipal 2007 because of water quality issues. Funding is also 27 Brackish Groundwater Facility Water District needed to correct the water quality problems in order to get Expansion the facility to its full operating capacity. The proposed 500 AFY capacity expansion will allow the facility to become operational at its full capacity of 2,000 acre-feet per year. The site is already owned by California Water Service Co. and leased by West Basin and is developed as a desalting facility. The expansion will include the installation of a new production well, and the addition of an acid pretreatment unit and a reverse osmosis treatment unit on the existing site. Installation of storm drain catch basin curb screens at all applicable locations citywide. These screens are the stainless variety approved curb by Los Angeles County. The purpose of the curb screens is to stop trash from entering the catch basins which eventually discharge into both the Los Angeles River and Malibu Creek watersheds. By implementing this project, City of Calabasas will be in compliance with the Trash TMDL both for LA River and 28 CITYWIDE STORM DRAIN CITY of CALABASAS Malibu Creek watersheds. Based on studies done, reduction CATCH BASIN CURB SCREENS in trash and debris loadings will also reduce Bacterial and sediment loading in the watershed. By implementing the project, disadvantaged communities downstream of Calabasas in Los Angeles River will benefit from cleaner water. The scope work consists of measuring all catch basin openings, drafting RFP with detailed specifications, soliciting proposals from the list of Los Angeles County's approved venders, negotiating contract, implementation/construction, monitoring and reporting. Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP The project will convert a 1.55 acre vacant parcel at the confluence of the Los Angeles River and Caballero Creek into a publicly -accessible natural park with habitat restoration, paths, site furnishings, water quality improvements, waterfront -access, and educational amentities. The design utilizes an innovative mixes low-tech mechanical and biological methods to filter and infiltrate storm waters increases regional water quality. The project 29 Caballero Creek & Los Angeles Mountains Recreation and creates a multi -benefit park that provides ecosystem River Confluence Park Conservation Authority services as well as cultural services, like recreation and eco - tourism. The project concept was developed in partnership with the City and County of Los Angeles who have committed to retain ownership, maintenance and operation responsibilities while allowing the Mountains Recreation and Conservation Authority (MRCA) to oversee design and construction. Nearby Reseda High School will monitor the project and use it for hands-on learning and community service opportunities. This project will consist of design and construction of approximately 8300 feet & 6000 feet of new 4"and 8" PVC recycled water pipeline, respectively. The project also Camino San Rafael Recycled consists of installing a two booster stations. This project will 30 Glendale Water & Power extend Glendale's recycled water distribution system to Water Project provide recycled water for common area irrigation to the Camino San Rafael Homes. This project will offset up to 90 AFY of potable water with recycled water. This will reduce the City's demand on potable water. The Carson Regional Water Recycling Expansion Project includes the expansion of the existing recycled water treatment facility and the construction of several laterals. This is a new demand on the system and will require expansion of treatment process capacity and conveyance to include; lateral pipelines, pump stations, treatment units, 31 Carson Regional Water Recycling West Basin Municipal storage tanks, and waste management facilities. The BP Pro act Water District Refinery requires single -pass reverse osmosis treatment units. BP Refinery is estimating a need of 2,100 acre-feet per year (AFY). The project will be further expanded to serve customers within the City of Los Angeles' jurisdiction for the refineries in the port area. The City will need recycled water to satisfy a use of 9,300 AFY. The City is in the preliminary design stage. Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP 10 The Project will provide a street -end interpretive area on Bull Creek at Chase Street, and install a Stormwater Greenway along Chase Street from the eastern street end on the north side right-of-way to Hayvenhurst, and on the north and south right-of-way to Gothic. Vegetated planters in the parkways will capture and infiltrate street runoff, and will provide storm City of Los Angeles water filtration, and tree shading. The Bull Creek street -end Chase Street Stormwater Bureau of Sanitation, will feature a native landscape as habitat and a recreational 32 Greenway Watershed Protection rest stop along the channel, and will provide an interpretive Division site for wildlife selected and supported by the specific native planting used in the project. A channel diversion from Bull Creek, with a pre -filter and lift station, will transfer runoff through a pipeline to a local Sod Farm where it will be used to irrigate up to 30 -commercial acres. The project will integrate water conservation goals (LADWP), Storm water objectives (BOB), Economic enhancements to city property (LAWA), & public health and recreation benefits. This project will install a chemical treatment system at the Rio Hondo Coastal Spreading Grounds to remove sediment fines from the water and improve the percolation rates. A Percolation Optimization Investigation (POI) report was done by Montgomery Watson Harza (MWH) in 2003 to evaluate the County's spreading grounds and the impact of Los Angeles County Flood suspended solids on percolation rates. The report made a 33 Chemical Study -Rio Hondo Control District number of recommendations and the recommendations will be implemented at the Rio Hondo Flood control facility. The project will install a coagulant chemical feeder and mixer at the grounds intake. This will allow the silt in the stormwater to coagulate and settle prior the cleaner water to flowing into spreading grounds. When this occurs, the spreading grounds will be able to percolate more water, thus conserving and recharging more groundwater. This project will consist of design and construction of approximately 920 feet, 1900 feet & 2100 feet of new 4", 8" and 12" PVC recycled water pipeline, respectively. The Chevy Oaks Recycled Water project also consists of installing a small booster station. 34 Glendale Water & Power This project will extend Glendale's recycled water distribution Protect system to provide recycled water for irrigation to the Chevy Oaks Homes. This project will offset up to 30 AFY of potable water with recycled water. This will reduce the City's demand on potable water. At completion of a prior grant, a modest amount of money remained unused. With the acquiesence of the granting agency, the City of Carson purchased 16 rain barrels and set up a website lottery system in order to award them to residents. The response was overwhelming and with no City of Carson, advertising over 100 contestants were disappointed to not 35 City of Carson Rain Barrel Give Development Services receive a rain barrel. This proposal would lead to the Away Phase II Department, Engineering purchase of an additional 1,000 rainbarrels (depending on Services Division cost and grant amount) to restock the lottery reserves. Advertising and management of the program would be provided as part of the City of Carson grant match. More information on Fiskar Rain Barrels is available at http://www2.fiskars.com/Prod uctsNard-and-Garden/Rain- Barrel-Systems 10 Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP 11 Upper District in cooperation with the City and Fire Department of Monrovia are submitting this project incorporating both dry and wet weather runoff capture, treatment and storage for the new Regional Training Center. Once collected, the fire training water and the 85th percentile of a 24 hour storm event (as required by the City's City of Monrovia Fire Department - MS4 permit) will be treated before being discharged into 36 Training Center Water Recycling Upper San Gabriel Valley storage holding tanks which will store the treated water for Municipal Water District future reuse by the training facility. The objective is to offset Proiect the use of potable water at the facility, eliminate storm water discharge and capture wet -weather storm water runoff. Finally, if the wet -weather event is larger than the 85th percentile, then provisions are being considered to treat as much of the additional wet -weather storm water runoff via a natural infiltration gallery (bioswale) before being discharged into the City's storm water system. This project will consist of refurbishment and upgrades to the outlet works, tunnels, and repair of various facility components at Cogswell Dam. The project will increase operational effectiveness for Flood control and water conservation. The project will involve: a complete overhaul Cogswell Dam Inlet/Outlet Works Los Angeles County Flood of the dam's entire inlettoutlet works; upgrade on the 37 Control District electrical control equipment; repair of downstream facilities; Rehabilitation Proiect structural repairs on the upstream facing slab; security upgrades; and other various repairs essential for maintaining and operating a flood control facility. The overall project intent is to improve Cogswell Dam for maintaining dam safety, increased efficiency and reliability of Flood control operations, and enhancement of water conservation efforts. The project will acquire 4.87 acres (APN 4455-021-040) of natural undisturbed open space within the existing 1348 - acre Cold Creek Preserve in the Santa Monica Mountains National Recreation Area. The acquisition is part of the state - funded Cold Creek Restoration Plan designed to acquire 539.06 acres to protect the wild and scenic, perennial Cold 38 Cold Creek Diamond Acquisition Mountains Restoration Creek, the habitat linkage between Topanga State Park and Trust Malibu Creek State Park, the values of Los Angeles County's Significant Ecological Area #9, and a future venue for environmental education, research, and recreation. The area includes significant oak, sycamore, and willow communities, supports a range of wildlife including mountain lion, gray fox and raptors. The pure waters once supported the federally -listed endangered southern steelhead trout. This project helps our customer agencies to develop a water conservation, budget -based rate structure for their customers. The project is beneficial to West Basin's cities Conservation Budget Based West Basin Municipal and retail water agencies because it provides a pricing 39 Water District structure that will incentivizes its customers to conserve Tiered Rate Structure water. This pricing method has been used in other parts of the State and has been successsful at reducing water usage and reqarding those who do so with lower rates on their water bill. 11 Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP 12 This project would convert the 237th St. Sump (4.5 acre- feet) into a retention/infiltration basin BMP for Toxics and Nutrient TMDL compliance and provide open spaces for wildlife habitat. This project would install diversion structures that would divert the first 4.5 acre-feet of stormwater from a 71 acre tributary area away from the system tributary to Conversion of 237th Street Sump Machado Lake (Wilmington Drain) to be retained and Tributary to Machado Lakes for 40 City of Torrance infiltrated in this basin. Trash screens would be installed at Nutrient and Toxics TMDL BMPs the catch basin in the watershed by a separate project. During the dry season the basin would remain an open space for wild life and retain urban run-off and nutrients form 71 acres. By diverting stormwater back into this basin, the City and County storm drain systems would have more capacity during rain events. This project would also increase groundwater recharge. This project consists of repairing corroded and deteriorated sections of aboveground pipeline and developing a Corrosion Monitoring, Control, and Maintenance Program. The Waterworks District 29 transmission water pipeline runs Los Angeles County along the Pacific Coast Highway in Malibu. The proposed 41 Creek Crossings Repairs Waterworks District No. pipeline repairs are located at eight creek crossings attached 29 to bridge structures. The project will significantly prevent future leaks and breaks in the main transmission pipeline which is the primary source of water supply for Malibu and Topanga. The development of a maintenance program is essential to maintaining water supply reliability for the region. The project would harvest stormwater and brackish groundwater for high level treatment and non -potable use around the City, replacing the use of imported potable water. The City would install a 1.3 million gallon storage tank next to the Santa Monica Pier, Deauville lot, to harvest stormwater from the Pier sub -watershed during rain events and brackish groundwater during dry periods. The project would have an optional overflow to an infiltration gallery. A 42 Deauville Distributed Water Reuse Project City of Santa Monica saline extraction well would be installed in sand next to the storage tank. The project would install pre-treatment catch basin inserts in the drainage area or a centralized hydrodynamic separator -screening device to remove trash and debris from stormwater. Modular nanofiltration (NF) and a saltwater reverse osmosis (RD) treatment systems at the site would treat these stored local water resources to high quality for various uses around the City in the existing recycled water system. All concentrated brine by-product would be sent to the sanitary sewer. The Decker Canyon recycled water pump station, pipeline, and lank would furnish recycled water primarily to Malibu Country Club Golf Course and Tract 47962 -Sycamore Canyon Estates near the pump station location and other 43 Decker Canyon Recycled Water Las Virgenes Municipal Water District nearby ranchettes. The project would comprise a high -lift pump station, —23,000 linear feet of pipeline along Westlake System Extension Blvd and Decker Canyon Rd, and a 60 -foot diameter concrete tank near the corner of Decker Canyon Rd and Mulholland Hwy. Approximately 229 AF of recycled water per year would be used by this project. 12 Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP 13 The Del Rey Lagoon Water Quality Improvement Project proposes to improve water quality by reducing the source and amount of fecal indicator bacteria in the Del Rey Lagoon and surrounding waterbodies such as the Santa Monica Bay and Dockweiler Beach. Project components include stormdrain systems, vegetated swales, irrigation system retrofit, and drainage modifications. Education and outreach City of Los Angeles to the public will also be included in the project scope. The 44 Del Rev Lagoon Water Quality Bureau of Sanitation vegetated swales are designed to capture, retain, and treat Improvement Project Watershed Protection runoff from the adjacent residential, transportation, and Division landscaped area during dry weather and partially during wet weather. Existing irrigation system will be retrofitted with a smart irrigation system to reduce excessive irrigation runoff, thereby conserving water and reducing flow. Catch basins and storm drains will be installed to capture and divert excess wet -weather flow into the sewer system. Project also includes a nature viewing deck and educational displays that explain local flora -fauna. This project involves the installation of drought -tolerant demonstration gardens at a minimum of five fire stations throughout the West Basin service area. These gardens will replace turf and/or concrete areas that are directly in front of the fire stations in order to provide a maximum visibility to the public. The gardens will be utilizing drought -tolerant and/or native plants that will be designed by professional Demonstration Gardens at Los West Basin Municipal landscape designers that specialize in climate -appropriate 45 Angeles County Fire Department Water District plans and trees. The main goal is to provide water Stations conservation and runoff reduction measures and secondarily to educate the public about the measures so that they can create these spaces at their own homes. West Basin strives to reduce demands by implementing conservation and education programs throughout the communities it serves. This project aims to continue implementing outdoor water conservation/education programs to influence the public to create these spaces in their own homes. This project proposes to conserve stormwater by holding a reservoir pool behind Devil's Gate Dam and diverting the water to Eaton Wash Dam and Eaton Wash Spreading 46 Devil's Gate Dam and Reservoir Los Angeles County Flood Grounds for poststorm groundwater recharge. A pump will Water Conservation Control District be installed in the Devil's Gate Dam reservoir and water will be pumped out and conveyed through over 26,000 feet of pipeline to Eaton Wash Dam where it can be held for recharge at downstream spreading ground facilities. 13 Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP 14 The 2009 Station Fire was the largest fire in Angeles National Forest recorded history and burned over 160,000 acres in the San Gabriel Mountains. Approximately 68% of the watershed tributary to Devil's Gate Reservoir was burned and as a result of the storms that occurred in the two wet seasons after the fire, sediment levels in the reservoir Devil's Gate Reservoir Sediment increased by more than one million cubic yards. The County 47 Los Angeles County Flood of Los Angeles Department of Public Works on behalf of the Removal and Management Project Control District Los Angeles County Flood Control District is planning a sediment removal project of up to 4 million cubic yards. A sediment removal project from behind Devil's Gate Dam is vital to the health of the Arroyo Seco Flood control system. The goal of this project is to restore Flood control capacity and establish a reservoir configuration more suitable for routine maintenance activities. The project will last approximately 5 years with construction starting in 2014. The project will consist of development of a native landscaped greenway and bikeway/pedestrian trail along the north side of the Dominguez Channel, between Vermont Av and Normandie Av. The project will include the following: access/maintenance road improvements for the new/improved bikeway; AC repair and replacement, slurry seal, American Disability Act (ADA) access ramps and 48 Dominguez Channel Greenway Los Angeles County Flood bikeway/pedestrian signage and striping. Landscaping Phase III Control District improvements include landscaping using native and drought - tolerant plants, irrigation, as -needed fencing repair/replacement. Educational/interpretive signage will also be included along the bikeway/pedestrian trail. A study is also recommended to consider additional pedestrian crosswalks with street lamp lighting for added safety. The project is currently on hold until the LACFCD completes a study to address deficiencies in its levees. This project would install Automatic Retracting Screens (ARS) in the 1800 Stoma Drain Catch Basins in the City of Carson. The proponents favor ARS to collect trash at street level where the trash can be quickly and cost effectively collected weekly by the existing City Street Sweeping Contractor and eliminates the need for other more costly and difficult to maintain downstream trash control systems. This Dominguez Channel Trash City of Carson, project anticipates the continuing development of local and 49 Reduction Via ARS Installation in Development Services state waterway trash control efforts and alleviates the need Department, Engineering to develop these expensive federal, state and local the City of Carson, CA Services Division requlatory mandates. In comparison to other "downstream" trash control systems, the maintenance status of ARS is easily assessed and visible to the public, which is then able to report those locations where maintenance is warranted. Since ARS systems are located in the street sweeper path, maintenance (trash collection) occurs weekly, the trash stays dry and is less subject to the degradation that generates other pollutants (bacteria). 14 Attachment A Reasonably Foreseeable Water Resources Projects in LA County - NOP: Draft PEIR, EWMP 15 The proposed project will increase the percolation within the spreading grounds facility in order to increase groundwater recharge. The preliminary scope includes removing between Dominguez Gap Spreading Los Angeles County Flood 5 to 10 -feet of clay sediment or installing vertical 50 Grounds West Basin Percolation Control District trenches/drains through the poorly draining strata in the Enhancement facility's west basin. Preliminary studies have been conducted including boring samples which will be used to further develop conceptual plans and estimate project benefits. The Duck Farm River Park, once a natural Floodplain, has been disconnected from the natural processes of the river for decades as a result of urbanization & flood management. The Project reintroduces natural systems through a riparian/pocket wetland/seasonal slreambed that improves both habitat and collect, filter & infiltrate stormwater flows onsite, as well as stormwater from the adjacent freeway in collaboration w/Caltrans. The project will transition irrigation 51 Duck Farm River Parkway Phase Watershed Conservation source (annually forecasted to require 19M gallons) from 1 - Water Enhancement Project Authority imported, highly processed potable water to either local groundwater or recycled water as its source of supply. The public will benefit by being reconnected to nature, the river, & from educational & interpretive programming possible at the site. This change in supply will reduce greenhouse gases & the parks carbon footprint. Outdoor classroom & interactive educational experiences with children will inspire local youth to learn more about our watershed, water conservation & sustainability The project will increase the intake and storage capacity of the Eaton Wash Spreading Grounds facility. This will improve the facility's ability to recharge storm water into the groundwater basin, thus greatly increasing the sustainable local groundwater supply that is vital for the region. Los Angeles County Flood Control District will replace the vehicle access slab with a metal grate over the spreading grounds drop intake channel and replace the current 52 Eaton Spreading Grounds Intake Los Angeles County Flood diversion flashboards with an inflatable gate within the intake Improvements Control District channel. These improvements in Eaton Wash Channel will better direct flows into Eaton Wash Spreading Grounds, thereby increasing its intake capacity. Basin 1 will be enlarged to increase the facility's storage capacity. The project will include improvements to the property along Sierra Madre Boulevard that will significantly improve the sustainability, aesthetics, and safety of the public walkway and street view. Two driveway entrances will be improved by increasing the gate set -back fu The dam outlet works rehabilitation project involves the removal of the existing outlet tower and gate house. Once these major components are removed, construction of a Eaton Wash Dam Inlet/Outlet Los Angeles County Flood gate valve, debris racks, hydraulic power system with a 53 Control District block house, control systems, modification of the outlet Works Rehabilitation Project works structure, and rehabilitation of the gate valves will commence. It will provide necessary erosion protection measures and improve water quality during low -flow releases from the dam. 15 Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP 16 LADWP is planning to cover the existing Elysian Reservoir in order to meet US EPA water quality regulations. In April 2012, the Board of Water & Power Commissioners certified the Environmental Impact Report and approved the floating cover alternative. The project will install a flexible membrane floating cover over the existing water surface. Also included are supporting infrastructure (piping, valves, liner) and site Elysian Reservoir Water Quality improvements (roadway paving, fencing). The reservoir will 54 LADWP operate in the same manner, providing potable storage for Improvement Proiect the distribution system. Construction is anticipated to being by 2015. In conjunlion with the project, a Community Parks Fund was established by the Board of Commissioners. The fund is to be used for unspecified public purposes related to community parks. Best efforts will be made to locate enhancements primarily in the Elysian Park area, working together with the community and other City of Los Angeles agencies. The project consists of adding a new emergency water source to supply Waterworks District No. 29 through a new Los Angeles County interconnection along Encinal Canyon Road at the District 55 Encinal Emergency Connection Waterworks District No. boundary with Las Virgenes Municipal Water District 29 (LVMWD). This interconnection would bring water from Metropolitan Water District of Southern California through LVMWD to provide additional supply to the District during emergencies. Three hydrologic areas were studied for the development of satellite recycled water facilities. Foothill Municipal Water District (FMWD) is pursuing the construction of one facility near Berkshire Place in La Canada at this time. This project will treat wastewater using a membrane bioreactor and recharge the product into the groundwater basin using infiltration galleries underneath athletic fields for multi - beneficial uses. Cal Poly Pomona has partnered with FMWD Foothill Municipal Water District Foothill Municipal Water and is developing a model that will also capture stormwater 56 District for recharge using the same infiltration galleries. A Recycled Water Pro act conservation and education component has also been added. Landscaping will be done to showcase drought tolerant plants at both the MBR site and school site. Tours will be available so that students may learn about stormwater capture, groundwater, recycled water, conservation and the watershed since the Arroyo Seco and Hahamongna Park are across the street. This 0.250 MGD plant will save enough energy annually for 80 homes in So. Cal. Divert runoff from a section of the Santa Monica Freeway within the City of Santa Monica, treat and infiltrate within an area near the freeway, either a landscaped area or parking lot. The infiltration zones will be sugared, if necessary to by- pass poor permeable soils. There will be pre-treatment 57 Freeway Runoff Infiltration City of Santa Monica before infiltration to remove trash, oil/grease, sediments. It Demonstration Proiect will be a passive system, i.e. gravity -fed and low into the system. The treatment -infiltration areas will be areas either already with a storm drain in the area, or the creation of new ones to harvest the runoff. The goal will be to keep runoff out of the existing storm drains and out of the storm drain system. 16 Attachment A Reasonably Foreseeable Water Resources Projects in LA County - NOP: Draft PEIR, EWMP 17 The Prop O funded phase I, the installation of six bio-swales and 4 dry wells. This watershed in an average rainfall year brings 300 acre feet of water to Glen Oaks Blvd. Phase I was completed in January 2014 and is currently capturing an 59 Glen Oaks Storm Water Caoture Los Angeles estimated 30 acre feet per year leaving approximately 270 Proiact Beautification Team acre feet available for storm water capture. Phase II will consist of an additional eight dry wells for an estimated $625,000, plus the cost of City Services (Design fees, permits and over site), that will capture an additional 40 to 45 acre feet annually. The Glendale Narrows Riverwalk will provide approximately one mile of multi -use recreation along the Los Angeles River. There are several invasive plant species that are prevalent adjacent to the Riverwalk in the Glendale Narrows area of the Los Angeles River. These invasive plant infestations jeopardize the improvements to water quality and degrade habitat for native aquatic, avian, reptile, 59 Glendale Narrows Habitat Council for Watershed amphibian, and invertebrate species. In collaboration with Enhancement Project Health the City of Glendale Community Services & Parks Department, the Council for Watershed Health (Council) proposes to develop and manage a 3-4 year restoration project to map, control, and monitor invasive arundo and invasive palm trees in the Riverwalk project area in the Glendale Narrows sections of the Los Angeles River. A native plant propagation and replanting effort is also proposed to reestablish riparian plants. The Goldsworthy Desalter (Desalter) treats water from the saline plume in the West Coast Groundwater Basin for drinking water. The brackish water is treated to meet or exceed municipal drinking water standards through the use of a reverse osmosis system. The existing Desalter produces approximately 2,000 acre-feet of potable drinking water per year. When the Desalter was originally constructed in 2002, it was designed for expansion to over 5000 acre - 60 Goldsworthy Groundwater City of Torrance feet per year of drinking water. In 2012 the Water Desalter Expansion Replenishment District of Southern California had a Feasibility Study for the Expansion of Desalter prepared for and approved by the U. S. Bureau of Reclamation. The expansion would involve the installation of additional reverse osmosis treatment units, construction of two additional source water wells, transmission mains and related appurtenance. The project also diverts waste water away from Santa Monica Bay where discharges cause TMDL violations for bacteria. 17 Attachment A Reasonably Foreseeable Water Resources Projects in LA County- NOP: Draft PEIR, EWMP IN The overarching goal of the GRIP Recycled Water Project is to offset the current use of imported water by providing up to 21,000 acre-feet per year (AFY) of recycled water as a reliable supply source for groundwater basin replenishment via the Montebello Forebay within a reasonable timeframe. The source for the recycled water will be the Los Angeles Groundwater Reliability Water Replenishment County Sanitation Districts' San Jose Creek Water 61 Improvement Project (GRIP) District of Southern Reclamation Plant (SJCWRP). Tertiary treated recycled Califomia water, advanced treated recycled water (microfiltration, reverse osmosis and advanced oxidation), or a combination of the two will be conveyed from the SJCWRP via an existing pipeline or possibly a new pipeline for recharge in the Central Groundwater Basin through the Montebello Forebay Spreading Grounds or potentially a new injection well field. The purpose of the Groundwater System Imrovement Study (GSIS) is to perform an independent study to identify, characterize, and evaluate emerging water quality constituents for the San Fernando Basin (SFB). This will include a comprehensive analysis that will provide recommendations in developing short and long-term 62 Groundwater System LADWP projects, including the design and construction of Improvement Study groundwater treatment facilities, to maximize the use of the groundwater supply in the SFB. As a part of the GSIS, the LADWP will be drilling approxinmately 26 new groundwater monitoring wells, and perform short-term monitoring of existing and new wells, in order to obtain supplemental water quality data necessary for planning the groundwater treatment afcilities in the SFB. Design and construction of groundwater treatment facilities 63 Groundwater Treatment Facilities LADWP in North Hollywwod, Rinaldi-Toluca and Tujunga Wellfields in the San Fernando Basin (SFB), with a treatment capacity of 122,900 acre-feet per year. Construct 4,500 feet of 20" pipeline, pumping station and Hansen Dam Golf Course Water pipe support bridge to deliver recycled water from the 64 LADWP Tillman Plant to the Hansen Dam Golf Course and other Recyclina Project potential future users. Water will be pumped from the Hansen Tank. Hansen Dam, situated adjacent to the Tujunga Wash Channel in the San Fernando Valley, is a vital part of flood control efforts in the Los Angeles River drainage basin. The primary purpose of Hansen Dam is flood control; however the opportunity exists to increase water conservation and water supply through increased water recharge upstream of Hansen Dam Water Conservation Los Angeles County Flood the dam. The current operation of the dam allows for an 65 Control District average annual water conservation of 17,100 acre feet per Project year. The Water Conservation Project, which involves utilizing the existing Debris and Flood Control Pools for water conservation purposes by raising their respective maximum elevations to allow for additional water supply storage, would increase the dam's water conservation ability. This extra supply storage would allow for dam releases to downstream spreading grounds and other facilities to Hansen Dam Water Conservation Change management regime of Hansen Dam to focus on 66 The River Project water conservation by maintaining a water conservation pool and Supply within the reservoir during and subsequent to flood season. IN Attachment A Reasonably Foreseeable Water Resources Projects in LA County - NOP: Draft PEIR, EWMP 19 onstruction of a 110 MG buried reservoir along with a 4 MW hydroplane at the former Headworks Spreading Grounds to 67 Headworks East Reservoir LADWP replace the storage capacity lost when Ivanhoe Reservoir is removed from service. Needed to bring the Water System into comliance with state and federal drinking water regulations by the regulatory deadline of November 2014 68 Headworks Ecosystem Restoration LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 69 Herondo Parking Lot and Beach City of Redondo Beach Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Infiltration description 70 Hoover, Toll, &Keppel School Glendale Water & Power Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Recycled Water Protect description 71 Humboldt Stormwater Greenway City of Los Angeles, Bureau ofSanitation/Watershed Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Protection Division description Improvements to Entradero Storm City of Torrance, SMBBB Please refer to the Greater Los Angeles County Integrated Drain Channel for Storm Water 72 TMDL Jurisdictional Regional Water Management OPTI database for a project Infiltration and Habitat Restoration Groups 5 & 6 description 73 Improvements to San Gabriel Azusa Light and Water Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project River Diversion and San Gabriel River Water Committee Canal and description Appurtenances 74 Indirect Reuse Replenishment Upper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Protect Johnny Carson Park Stream Please refer to the Greater Los Angeles County Integrated Restoration and Park 75 City of Burbank Regional Water Management OPTI database for a project Revitalization description Multi -jurisdictional Please refer to the Greater Los Angeles County Integrated 76 Jordan Downs Daylighting Study Agencies -LA City Housing Regional Water Management OPTI database for a project and Public Works description 77 LA River Sixth Street Bridge City of Los Angeles, Bureau of Engineering Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Greenway 78 LVM W D Woodland Hills Golf Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Course Recycled Water Pipeline Extension 79 La Puente Valley County Water Upper San Gabriel Valley Municipal Water District & La Puente Valley County Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description District Recycled Water Project 80 Landscape Irrigation Efficiency West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Program (LIEP) 81 Large Landscape Irrigation SurveyUpper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description and Retrofit Project 82 Las Virgenes Creek Bank Stabilization, Stream Restoration. City of Calabasas Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Fish Migration Enhancement and Trail Connection 83 Live Oak Dam InlettOutlet Rehabilitation Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description 19 Attachment A Reasonably Foreseeable Water Resources Projects in LA County - NOP: Draft PEIR, EWMP 84 Live Oak Spreading Grounds Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Improvement Project description 85 Lopez Spreading Grounds Improvement Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 86 Los Angeles River Center and Mountains Recreation and Conservation Authority Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Gardens Green Conference Center 87 Los Angeles River Natural Park City of Los Angeles Bureau ofSanitation/Watershed Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Protection Division description 88 Los Angeles River Revitalization City Los Angeles, u of Engineering Bureau Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Master Plan 32 Mile Channel and Easement Greening 89 Los Angeles State Historic Park LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Water Recycling Pro act description 90 Los Angeles -Burbank Groundwater System Interconnection LADWP /Burbank Water and Power Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 91 Los Angeles -Glendale Groundwater System Interconnection LADWP /Glendale Water and Power Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 92 Lower Los Angeles River Area Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Linear Water Storage Feasibility Study 93 Malibu Civic Center Area Recyled City of Malibu Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Water Delivery Project description 94 Malibu Civic Center Linear Park City of Malibu Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Phase 3 description Malibu Drought Preparedness Please refer to the Greater Los Angeles County Integrated Proiect: Graywater Reuse and 95 City of Malibu Regional Water Management OPTI database for a project Rainwater Harvesting description 96 Malibu Equestrian Center Runoff City of Malibu Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project BMPS description Please refer tot he Greater Los Angeles County Integrated 97 Malibu Rainwater Harvesting City of Malibu Regional Water Management OPTI database for a project description 98 Malibu Road/Malibu Malibu Road/Malibu Colony City of Malibu Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project ater Management Stormdescription 99 Manhattan Strand th Street City of Manhattan Beach Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Subsurface InfiltratioTrench o n description 100 Manhattan Wells Improvement LADWP/Water Replenishment District Please refertothe Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 101 Marsh Park, Phase II Mountains Recreation and Conservation Authority Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 102 Medea Creek Restoration at City of Agoura Hills Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Chumash Park description 103 Miller Pit Spreading Basins Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 20 Attachment A Reasonably Foreseeable Water Resources Projects in LA County - NOP: Draft PEIR, EWMP 104 Recycled Water Upper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Project Pro act 105 Milton Street Park and Green Mountains Recreation and Conservation Authority Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Street project - Ballona Creek Please refer to the Greater Los Angeles County Integrated 106 Mission Hills Green Belt The River Project Regional Water Management OPTI database for a project description Please refer to the Greater Los Angeles County Integrated 107 Mission Wells Improvement LADWP Regional Water Management OPTI database for a project description 108 North Hollywood Groundwater and Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Surface Water Benefits Study description 109 North Hollywood Street Enhancement City of Los Angeles Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 110 North Hollywood Transmission Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Corridor Easement Stormwater ap Cture Study 111 North Santa Monica Bay Firecamp 13 LID Retrofit Los Angeles County Deprtment of Public Works Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 112 North Santa Monica Bay Probation Camp Miller LID Retrofit Los Angeles County Department of Public Works Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 113 Northeast Gardena Recycled West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Water Line description 114 Northeast Gardena Storm Water Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Quality Park, Recycled Water Line, and Landscape Makeover 115 Northeast Gardena Water and Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Landscape Makeover. Community Involvement Module 116 Oak Park Green Streets Urban County of Ventura Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Retrofit description 117 Oak Park Medea Creek Restoration Mountains Restoration Trust Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 118 Ocean Friendly Garden (OFG) West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Program description 119 Olive Pit Water Conservation Park Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 120 Oxford Retention Basin Multi -Use Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Enhancement Project description 121 Ozone Park Runoff Treatment and ReUse Project City of Santa Monica Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 122 Pacoima Dam Inlet/Outlet Works Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project Rehabilitation Project description Please refer to the Greater Los Angeles County Integrated 123 Pacoima Neighborhood Retrofit The River Project Regional Water Management OPTI database for a project description 21 Attachment A Reasonably Foreseeable Water Resources Projects in LA County - NOP: Draft PEIR, EWMP 124 Pacoima Reservoir Sediment Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Removal description 125 Pacoima Spreading Grounds Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Improvements 126 Palos Verdes Peninsula Satellite West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Facilities Study description 127 Palos Verdes Recycled Water West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Lateral description 128 Pasadena Recycled Water Proiect Pasadena Water and Power Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 129 Peck Water Conservation Improvement Project Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 130 Puddingstone Diversion Dam Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Inlet/Outlet Works Rehabilitation description 131 Raw Wastewater Diversion to the Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project City of Los Angeles description 132 Recycled Water On -Site Retrofit West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Projects 133 Recycled Water Storage and Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Distribution System Expansion 134 Recycled Water Supply for Palos City of Palos Verdes Estates Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Verdes Golf Course description Water Replenishment Please refer to the Greater Los Angeles County Integrated 135 Recycled Water Turnouts District of Southern Regional Water Management OPTI database for a project California description 136 Regional Water Supply Reliability Puente Basin Water Agency Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Program Phase l b 137 Residential Indoor Plumbing West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Retrofit Kits description 138 Residential SMART Timer Retrofit West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description "Plus" Program 139 Rio Hondo Coastal Basin Spreading Grounds - Sediment Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Removal from Basins Crescents Valley Water Please refer to the Greater Los Angeles County Integrated 140 Rockhaven Well District and Glendale Regional Water Management OPTI database for a project Water and Power description 141 SMURRF Distributed Water City of Santa Monica Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Reuse Proiect description 142 San Gabriel Coastal Basin Spreading Grounds Improvement Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Proiect 143 San Gabriel Dam Penstock Coatings and Valve Repair Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description 22 Attachment A Reasonably Foreseeable Water Resources Projects in LA County - NOP: Draft PEIR, EWMP 144 San Gabriel Valley Water Recycling Project (Phase I - Rose Upper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Hills Expansion) 145 San Gabriel Valley Water Recycling Project - Membrane Upper San Gabriel Valley Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Bioreactor Treatment Plant 146 San Jose Creek Water Reclamation Plant East Process County Sanitation Districts of Los Angeles County Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Optimization Project Please refer to the Greater Los Angeles County Integrated 147 San Rafael Creek Restoration Arroyo Seco Foundation Regional Water Management OPTI database for a project description 148 San Ramon Canyon Stormwaler City of Rancho Palos Verdes Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Flood Reduction Project description 149 Santa Anita Dam Seismic Rehabilitation Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 150 Santa Fe Dam Water Conservation Pool Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 151 Santa Fe Spillway Basins Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 152 Sawn it Debris Dam Seismic Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Strengthening Protect description City of Los Angeles 153 Septic -To -Sewer Drinking Waterwell Protection Project Bureau of Sanitation/Wastewater Engineering Services Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Division 154 Sepulveda Basin Sports Complex A1 eles, City of Los ABureau of Engineering Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Multi -Purpose Oben Space Protect 155 Sepulveda Basin Sports Complex City of Los Angeles, Bureau of Engineering Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Riparian Buffer Please refer to the Greater Los Angeles County Integrated 156 Sheldon Pit LADWP Regional Water Management OPTI database for a project description 157 Shoestring Park Council for Watershed Health Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 158 Silver Lake Reservoir Bypass & LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Regulator Station description 159 Six Basins and Puente Basin Puente Basin Water Agency Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Integrated Water Supply Project Los Angeles County Please refer to the Greater Los Angeles County Integrated 160 South Coast Botanic Gardens Department of Public Regional Water Management OPTI database for a project Works description 161 South EI Monte Recycled Water Upper San Gabriel Valley Municipal Water District & San Gabriel Valley Water Company Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Expansion Project Package 1 162 South EI Monte Recycled Water Upper San Gabriel Valley Municipal Water District & San Gabriel Valley Water Company Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project description Expansion Project 23 Attachment A Reasonably Foreseeable Water Resources Projects in LA County - NOP: Draft PEIR, EWMP 163 South Los Angeles County Groundwater Pipline Protect Water Replenishment District of Southern California Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 164 South Park Subsurface Infiltration City of Hermosa Beach Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Gallery 165 Southeast Gardena Recycled West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Water Line description 166 Stormwater Diversion to Walnut City of Torrance Please refer to the Greater Los Angeles County Integrated Regional Water Management database for a project Avenue Sump description 167 Sun Valley Watershed Rory M. Los Angeles County Flood Control District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Shaw Wetlands Park Protect (a.k.a. Strathern Wetlands Park) 168 Taylor Yard River Park Parcel G2 City of Los Angeles, Bureau of Engineering Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 169 Terminal Island WRP Advanced LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Water Purification Facility and Distribution System Expansion Proiect Terminal Island WRP Advanced Please refer to the Greater Los Angeles County Integrated Water Purification Facility and 170 LADWP Regional Water Management OPTI database for a project Distribution System Expansion description 171 Thousand Oaks Boulevard and Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Westlake Elementary Recycled Water System Extension 172 Topanga Connection Acquisition Mountains Restoration Trust Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 173 Transfer Station Cover Structure City of Inglewood Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description and Site Improvements 174 Triunfo Community Park and Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Evanstar Park Recycled Water Extension 175 Trunk Sewer Rehabilitation Proiects Las Virgenes Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 176 Turfs Up Water Use Efficiency West Basin Municipal Water District Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Program 177 Valley Generating Station Stormwater Recharge Project LADWP Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description 178 Van Ness and Slauson Infiltration City of Los Angeles Bureau of Sanitation Watershed Protection Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Best Management Proiect Division description 179 VerdHills Stormwater Protect City of Los Angeles, Bureau Bureau ofugo Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project Protection Division description 180 Vermont Avenue Storm Water City of Los Angeles, Bureau of Sanitation/ Watershed Protection Division Please refer to the Greater Los Angeles County Integrated Regional Water Management OPTI database for a project description Capture and Green Street Beautification Proiect 24 Attachment A Reasonably Foreseeable Water Resources Projects in LA County - NOP: Draft PEIR, EWMP 25 Please refer to the Greater Los Angeles County Integrated Council for Watershed 181 Vermont Median Stormwater Park Regional Water Management OPTI database for a project Health description Please refer to the Greater Los Angeles County Integrated Victoria Street CSUDH Water 182 City of Carson Regional Water Management OPTI database for a project Reuse Concept Proposal description Water Replenishment Please refer to the Greater Los Angeles County Integrated 183 WRD Eco Gardener Program District of Southern Regional Water Management OPTI database for a project California description Please refer to the Greater Los Angeles County Integrated Walnut Creek Spreading Basin Los Angeles County Flood 184 Regional Water Management OPTI database for a project Improvements Control District description Please refer to the Greater Los Angeles County Integrated Water Budget Based Rate Las Virgenes Municipal 1$5 Regional Water Management database for a project Implementation Water District description Please refer to the Greater Los Angeles County Integrated West Basin MunicipalWater 186 Water Star Schools Pilot Program Regional Water Management OPTI database for a project District description Please refer to the Greater Los Angeles County Integrated San Gabriel County Water 187 Well 15 Regional Water Management OPTI database for a project District description Please refer to the Greater Los Angeles County Integrated 188 Well 7 City of Inglewood Regional Water Management OPTI database for a project description Please refer to the Greater Los Angeles County Integrated 189 Well No. 2 Rehabilitation City of Inglewood Regional Water Management OPTI database for a project description Please refer to the Greater Los Angeles County Integrated Los Angeles County Flood 190 West Coast Basin Barrier Pro act Regional Water Management OPTI database for a project Control District description Westlake Filtration Plant Please refer to the Greater Los Angeles County Integrated es Municipal Laser 191 Enhancement & Backbone Regional Water Management OPTI database for a project Water Dist District Improvements description Please refer to the Greater Los Angeles County Integrated West WeWestward Beach Road st rd B 192 City of Malibu Regional Water Management OPTI database for a project It Proiect Bioindescription City of Los Angeles Please refer to the Greater Los Angeles County Integrated Westwood Neighborhood Bureau of Sanitation 193 Regional Water Management OPTI database for a project Greenway Project Watershed Protection Division description Please refer to the Greater Los Angeles County Integrated Whiting St. and EI Segundo Blvd. 194 City of EI Segundo Regional Water Management OPTI database for a project Dry Weather Diversion Structure description Whitnall H WY Powerline Please refer to the Greater Los Angeles County Integrated 195 Easement Stormwater Capture LADWP Regional Water Management OPTI database for a project Proiect description 25 2195 Sherwood Road San Marino, CA 9110& 1 +1t } Ir �} October 28, 2014 Q ° Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works13E�i• 1'+=`'I `� `°'` Project Management Division II.lcrT �� 900 South Fremont, 5" Floor Alhambra, CA 91803 Dear Mr. BeGell, The purpose of this letter is to register my support for the restoration of Baldwin Lake as part of the Enhanced Watershed Management Plan (EWMP) for the Rio Hondo Watershed. The lake has experienced significant deterioration in recent decades as a consequence of surface run-off and its very future is very much at risk. Establishing the restoration of Baldwin Lake as a priority project as part of the EWMP will ensure its status as an important ecological and historic asset for generations to come. Many thanks for attention to this matter. Very truly yours, George L. Ball Laura Rocha From: Begell, Gregg - Consultant <gbegell@dpw.lacounty.gov> Sent: Tuesday, October 14, 2014 4:06 PM To: Crumpacker, Andrea; David Pohl Subject: FW: Restoration of Baldwin Lake Comment for record Gregg BeGeffT E Project Manager Project Management Division II From: Jane Florentinus [mailto:iava5(Watt.net l Sent: Tuesday, October 14, 2014 1:23 PM To: Begell, Gregg - Consultant Subject: Restoration of Baldwin Lake Hello Mr. BeGell, I am a volunteer and member of the Arboretum located in Arcadia and would like to express my concern for the poor condition of the lake. As a volunteer docent I provide guided walks through the gardens as well as the lake perimeter. Visitors are dismayed and saddened to see the decline of such a great and wonderful treasure in the midst of our urban lifestyle. To have open space in our crowded communities is truly a rarity and must be preserved for future generations to appreciate. Please take my request for restoring the lake to heart. Thank you for reading my message. Jane Florentinus 7140 Hidden Pine Drive San Gabriel, CA 91775 Copy of email sent to G. Osmena Paige Anderson To: Tom Barnes Subject: RE: Enhanced Watershed Management Plan From: Jane Williams(mailto:ianeann640vahoo.coml Sent: Wednesday, October 29, 2014 2:16 PM To: Begell, Gregg - Consultant; Osmena, Genevieve Subject: Enhanced Watershed Management Plan As a volunteer at the L.A. County Arboretum, I would like to voice my support for the Enhanced Watershed Management Plan (EWMP) for the Rio Hondo Watershed, in which the Arboretum resides. Every time I set foot in the Arboretum and look around me I see what can only be described as a treasure that belongs to the people of Los Angeles County. The condition of Baldwin Lake, the centerpiece around which the Arboretum exists is deplorable. It is in desperate need of restoration. Please do all that you can to see that this plan is instituted and that, through it, funding may be found to preserve Baldwin Lake. CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Laura Rocha From: Begell, Gregg - Consultant <gbegell@dpw.lacounty.gov> Sent: Monday, September 29, 2014 4:41 PM To: Crumpacker, Andrea; Tom Barnes; David Pohl Subject: FW: Comments LACFCD SCH 2014081106 NOP Enhanced Watershed Management Programs due 9.29.2014 Here are a few good comments. Are you filing all the comments into a file or folder such that the County can view all the comments in one place? Gregg BeGeCCT E Project Manager Project Management Division II From: Joyce Dillard[mailto:dillardioviceCcDvahoo.coml Sent: Monday, September 29, 2014 4:30 PM To: Begell, Gregg - Consultant Subject: Comments LACFCD SCH 2014081106 NOP Enhanced Watershed Management Programs due 9.29.2014 The Project Description is listed on the State Clearinghouse site as: The development of the EWMP will involve the evaluation and selection of multiple watershed control measures or best management practices (BMP) types including non-structural and distributed, centralized and regional structural BMPs. These BMPs will be implemented to meet compliance goals and strategies under the 2014 MS4 Permit. Structural BMPs involve the construction of a physical control measure to alter the hydrology and/or water quality of incoming stormwater or non-stormwater. The three major functions for structural BMPs are infiltration, water quality treatment, and storage. These are three categories of structural BMPs, defined by the runoff area treated by the BMP and the required retention volume in accordance with the Permit. Comments: Watershed control measures seems to be the emphasis, but that term is not defined. It seems to exclude Watershed Protection Management Measure in areas applicable to the Coastal Zone Act Reauthorization Amendments which recognizes the impact of land -use activities on estuaries, beaches, marine resources and the ocean. Economically feasible measures and greatest degree of pollutant reduction achievable are terms from that Act. All receiving waters should be identified as to type and federal jurisdiction. The project only allows a build environment in a watershed that should have natural lands, ecosystems and normal watershed characteristics Southern California Bight. Antidegradation procedures should be addressed. including ambient water quality standards and the Alternatives should be presented for non-structural or structural projects. Surrounding land uses and settings should be addressed as should settings such as air space in relationship to bird migratory patterns. Ambient air quality should be included. Other public agencies should be included. US Army Corps of Engineers plays a role in navigable waters as does Caltrans in its responsibility for NPDES compliance. Private parties, such as Lauren Bon (Water Rights Draft Permit A032212) should be included. Baselines should be presented. There should be consistency including applications of the various General Plan and its Elements across jurisdictions. Infrastructure should be addressed including but not limited to age, condition and operations and maintenance. Since federal regulations are enforced involving Clean Water Act Navigable Waters, we question why there is no NEPA document preparation. Joyce Dillard P.O. Box 31377 Los Angeles, CA 90031 Kenneth D. Hill. Ph.D., P.E. 1994 Meadowbrook Rd. Altadena, CA 91001-3404 (626)797-2089 October 27, 2014 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont, 5`h Floor Alhambra, CA 91803 Subject: Baldwin Lake Restoration Los Angeles County Arboretum and Botanic Garden Dear Mr. BeGell: As president of the L.A. County Arboretum Foundation and as a concerned citizen, I encourage you to restore Baldwin Lake at the Arboretum. I am sure you are aware that the lake has environmental significance to Los Angeles County including impact on water conservation and reclamation, regional ecology, educational opportunity, and historical importance. The restoration of Baldwin Lake, including improvements to its function as an urban runoff collection basin, should be considered as a high-priority project within the Rio Hondo Enhanced Watershed Management Plan. Please note the following: Baldwin Lake, with a current capacity of just under four million gallons, if returned to its original depth, would provide over twelve million gallons of storage capacity. With modification, it could also serve as a significant infiltration basin for aquifer recharge. 2. Tule Pond to the north, a canal roughly 600ft. in length, is the point of entry for the urban watershed, feeding directly into Baldwin Lake. Its size, shape and location offer great potential for water quality enhancement through modification as a bioswale. 3. The Lake is a key educational, scenic, wildlife, and historic resource serving over 330,000 visitors per year, including over 16,000 elementary school students on field trips. The project would provide an unrivaled opportunity to educate a broad public about regional water management, home and community water conservation, and the role of the Raymond Basin and other key water resources that sustain us. 4. The Los Angeles Arboretum Foundation, the County's non-profit partner in operating the Arboretum, stands ready to help leverage public dollars to realize the site's unique educational potential. At our recent strategic planning meeting (October 25` ) the restoration of Baldwin Lake was the top priority for the foundation over the next year. In sum, Baldwin Lake offers the ideal project to both enhance watershed function and serve the public with remarkable educational, ecological, and scenic benefits. It is an exceptionally strong candidate for inclusion in the Rio Hondo Enhanced Watershed Management Plan. Sincerely, Kenneth D. Hill, Ph.D., P.E. President, L.A. County Arboretum Foundation RIM Baldwin Lake 2 messages Marsha Perez <marshaaperez@gmail.com> To: gbegell@dwp.lacounty.gov Dear Mr. BeGell, Marsha Perez <marshaaperez@gmail.coi Thu. Oct 23, 2014 at 4:45 I am a frequent visitor to our LA County Arboretum. Here I can find beauty, contentment and sollice for my busy lifestyle. Baldwin Lake is one of our families favorite visiting areas. Here we find the solitude and the different forms of wildfowl very enjoyable. Lately we find that our lake is becoming a disaster! The water is murkey, the banks are crumbling and it has a swamp like look in certain areas. On behalf of my family and many friends and visitors I implore you to take advantage of the opportunity now available to restore the health and beauty of our beloved lake. Thank you for your consideration. Sincerely. Marsha Perez Mwo „•i 1. ''I 1+1�1� 111:1• Illli':'.�. 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' ' I•.`n �. ,.'.:.'., I'•1 Illi ;I ! �Eli;l111 .1111 _' -: .I I'1 11'1' 1:: I'I L IL' - 'IMI: II1:1L:11'i L'll ill; Mill L 1•.1'.11 Ili II'11 ,�, I1111.1 .:ti.: iti -1'"IJ ::x::11 l: l II" 1'.: 1a�%1 illi i ;L i!'['1 .' l :i ..L c 111 i; ,•I- 1 i %•L CI.I l 11: 111'11.< 111 E'IL .11-L:1 Il- f'; Iii lit liti. I'L'i I'1',)[1L' I' II: I ll:i'l1I ':1'.i rl'IL:1' I :1L 111. 11 i 11'x'[10111.111 11 ;1 i..•' I)i'%II"L:I I.• x.•11: 1i I'll l .l:l 1,)I' II i s I. ' L.I:i Il' li Ill:II .'.l til %i%I list,', k I%. i 11%; r'r' 1 I-Iti 11) IM . I 'r' 11 ills rll I-� �1: Ir'r I 11% I. % i it r•.: :II':' 'i:: Ill:;-r•I-I:.I•: .I 11 i '.I"I%I:ILaIi 111 :'I,[1:1:Willi -'- to [!I•:!•'I;il• iIII11.I- Il! `-:,•II :I-lrll['. I'It %%,...11'1'.1 '.`. 111111; r1,1'.,I111 I'1 1 Li l%.11l� IL1iLll� 10l LIL I I: I I I:I-II Li; Id [11111:: ,%1' II II` 11111 l.: 1:11 IIII't 11'I '• I.'•l,ll Li:. [11•::1'•1 I'II II.IiI �1�. 11:�Il:Ili �1,•1ri:llil :;i 1_ I ;'1 ' 1 --'171:1,. 1111;: 1.1'111 ti• II:LL' t :1 11-.•11 11rnI1. ]'1;1111 11" 1 ;1111 NEVE:rd - ! 11" I.I I I r,:I I.' '.11'11. ...1.111'.: 1•,'I'I • I� X11'•'•: 1•I: "I•. .. ,.1 'I .1 ..1'•I l.ncln<IIi��: I'1;lnnim.• I111 I,icIi1-1 1. :.:rl,i 11ap r'I '.1"II-,%.ImI.I;m 1 ;11iIiIi:%. 111 1'1.IiCiI 1'ii nil Introduction Tine. following Gcn;Rr :l CTT-:idej hies �jhc -ld be ;.o' l:,wcd -r,: the c £•s.iC'T, of n_ ro:� FcE d `_ar-ilitiF and G"Vel❑✓f'.CP.'_� in the rc. i. of fac='i'ie:: _E c pr')_)crt i Ems, and!Ur easenl-'-nts. ` =). lverCQa_re �]at C'oF;1C5 C?� `rol_'r t.cntative and lnai recur c: mace:, = aa> r.^_ , �i:':IITy , street -r r.•racemcnt a- 51 cEPc', "to= Cr,'in, a:]r lltl Ll t�' r�lens _'1e �l=k1T-1 t�P-;; -•7r Cllr rel'i&- ,' and WrlttpR aC'o."oi'al pis the; rjmrt.�,in to yrf'tr'�'k1G_4tc:'.'_ aei L'_t.ie=,f -e[' Pr np=ti'.S and ea :cmen,s, -Drier tHlc COTImc_=emcnt o_ anti co=Etructi^n T=ct Maas ^_t:c folio i ar= `T =' -or Lic l -zert- =j in the ic�:;tific,,tion r..i ai [.a Of F:ici1; fce nro-Dertac„ and/or casemc-nts oti c•GLLtr Ilan.c;, Pa-Cc1 ap aT tract -ti-•-:. ."c-E._t.l _'E. . -, .. �. iCir f-as�j:'•: _..- ntci'.- Thr t3et_c•t;ol:ttan wat__ Dist:rlct o_ �outhr_r;: 1 ]fir, L' . :Y Introduction Tine. following Gcn;Rr :l CTT-:idej hies �jhc -ld be ;.o' l:,wcd -r,: the c £•s.iC'T, of n_ ro:� FcE d `_ar-ilitiF and G"Vel❑✓f'.CP.'_� in the rc. i. of fac='i'ie:: _E c pr')_)crt i Ems, and!Ur easenl-'-nts. ` =). lverCQa_re �]at C'oF;1C5 C?� `rol_'r t.cntative and lnai recur c: mace:, = aa> r.^_ , �i:':IITy , street -r r.•racemcnt a- 51 cEPc', "to= Cr,'in, a:]r lltl Ll t�' r�lens _'1e �l=k1T-1 t�P-;; -•7r Cllr rel'i&- ,' and WrlttpR aC'o."oi'al pis the; rjmrt.�,in to yrf'tr'�'k1G_4tc:'.'_ aei L'_t.ie=,f -e[' Pr np=ti'.S and ea :cmen,s, -Drier tHlc COTImc_=emcnt o_ anti co=Etructi^n T=ct Maas ^_t:c folio i ar= Net :a. ti tan's requ-4 cents for the ic�:;tific,,tion r..i itr facilities, fce nro-Dertac„ and/or casemc-nts oti c•GLLtr Ilan.c;, Pa-Cc1 ap aT tract ra s: u. rietropolita;;' fee Aron. rt-e� and easements and piLcl-ne:: ana othez-';.acilities m:st be ftlly shown and i ;.tif i :i u mc==D s o__ all ap licabl: Mans . t:. nlet.roPolita�'s ice Properties and/or easements ,:: t be chow- ane, -demi f-ec as Met: -o ^li tan's with the r offi.Cici1 1eC r 4n9 data ort :.ill aF ;•_icable rar^c'1 ane; tract mans. roF;Glita:. `s fee proPArt=es an::/or easements e};1 t1;1 survc'y mo_: 1mF-nts T•u t be cimersional ltied to th P.rccl or tract. `ao=darics. 3. tietznr;clitan' record; of sttrt•eys must be rcfc-ren� on the parcrl arc tract mans. �•-1 it ='ori: I1 C. 1-1 7.7 LI el __C]�..�i'ne.. T- a. _ - _ "_.. _ �', �_ Cnr c+,-fir..- I: «F c.!"r e•" _". i.__. El -j i"tFt rlllt::.n _ t'::LF ."�._, r_..r c)_1 -,.`ci:l'.'C"1 1'. c" T"r,- _ -__'I rl:"-..."" _ t•^ at `- aril if ..1 I C' . nw•e:: - e:•-r. _ C'- ra'rlr en Z-1 C. "._ San ^ ll p•. -_ i r•=the - n ^ '�.rl^.L: '-1�=GJth•: r -x C:J Orl til Cry.. r.n _ rr'_rC;:: "='}l lt[:• Ir:'.F:''_-f:T�C•=-{"1•, r L.•.-. n,e:1-u,�." n-o]it�*:'_ IL =r=11',=t 0- ';;j' tE:r.anc of _- t'- ,i i_. t.s c:z.erlc. tC. T'cr lI:t=r1 �': C.e C'' `h l ._y "ra-1.`-.. k--�:1 c-•^:�r�t_C', 1.1n•-: er I•l�Y.rGr•�a l.i;', Ir EL:St hr: Vi' C } facll it C3• _ C-1'- - �1' tL'[l• IC_ =rlS rl.-• VliLL:i_- c1' �J ^-lG t.^. F" C�.35E•T�:r X10_^. ':.% ti _1111.... an f. x th.. �,i• .1:i: F n th•. f 1'_it: a or :z1 r1 E.n :c'- k; r•e u=- "?"-f =- c''' = rcl�=in%- b,:siz. - 3 --''- �i V i,�'F•1G1e rC lei!.1' Zn^•': _zciliti ._ ::r:!u •: zIl a nr• - r: un3 o-' t;:' rout' frcr"I our c - COc.5=. ri":1:: rlc r �cnr_ �houlc c 1.1t v o:i a gra::e v r =�• ts .lc-iCl- .._.� Fick -- `.,�11'pner,'_. ;:•rl e:•:zT�1e 1. -- tFl=� i�. nhnw•n ci. d. Tti _cot -rl_ ::,.il_ F'' r - . 11t='. f.__ - rt- izcc.: - tcl er.C.: a;r i-:t"o t " - - n= rl= - .. rlr1%St r.•-) =r• r:=nn�rt. ciitir.-:a: l:: inq e- _i.• z=-Fme thon. . r't; -=n. r r>th',- 1:T�rZ =rl :s JrL'�r_ r•f 1 •'.1h:: C''l ,=in , h•1==1c EJr true uI• , '_ .. _ t:•l n- ::L -h fc:Ctincs for LEkCL CC-lt tC ttlC F.._; EF%LI a _ ��c. } �: rOnC 7't .-_i: �C' -�� 7`. thr _ - _ Dlt r'•1;:1c Cr :thr.,- l - - 1. r, rC•-:i E_• [:_ ilr.�i F. 1.: -_ .. .... :: ni: =L:,L U!2 il.'1-1==� e:: U.: ��I'I: c.l]. tr. :•:IL'r:l=,`__r .:li:"}'i'" =L_ r".• .: t.l__� �.nd.'�.r=".._..." "c T.11 .'.'_ b[_ :I'�211 = n:'>: -':"r "r: I-; -... `.'f]- --1 t:".-. �Li'_'_..l t':' ."_""R•:i�__ c'}'I ] �" 1C,:' -_Te _ F C•=J,: [: :i'J,"+.`1:-:1"i. '1'�,= 1.'.�:'I, C•_�.^L 1T'`_1:]". %-tile l-1 '_ i✓,. - :,- T: r. We e:`• ura,7�n -�h lli +_ar,' L _ ^P. f I. -r_ __... ..: - } a;?1'I it =r:` u�1:=._ :.-.._ .-...- tt- - vI`.I: t::::r::_ _ at such n e 9' f is t.....: r.: it.h _•_r"t"t-1 :,]__: _ -. i r r :t 'rt. - - idtl _r"e p -on rtv th•-nn:-_v ~.[lblic _-_c t. -."[ a; _-_- r}. :d]uC. i.r _ - f:.. -.-Ch U`:.- of tlU_ �:s•.-r t.`t!: Dir'•:^stn.-: c.%•tan _ c'_rt e,= v)0%:• �:r,d L:.: n•� L:i': :.sic, -:, te-ec`lor"e [::1'] 250, F: ca.yc:•:-._:.- ;t:_-L..-:,e-:ts =cr la" s._ ina, r--.- rr a_zinr .... ner , WLLi _- G- 0 rlUr ^Lt h]]"1 •'.' =.7 7r 1 ]t} e:. L-oLT-,1 ?•3 wltI in i.`is,:i r. r:l .a_:) and i q:'1 d c-1pt-�:•:- r•f the re7u=st,-~r_n•:r:t r -u _ v= succi_ :3. P.1 .;, tirt:te `. ",U mitmea the s.h _tw �= ti -L<: cic•: r]:- oount :.'ill =c: c_-: _hasri<.f-:-t fo: t.})F =ci mL=- ses int"-) i=s }:_ic S ::=n:lt of -�h.� r . ::r!...- will LN bic.", c• __repo!-it..l:r'-- - �hts Lo a ;_ i :, _: r" fcr ..L:t(�I pip, .linr.+< a^,:i at.r: ou_cc: t., t. �r szr-ye _..er a i- suc}r crar.t had not. h;r-r�-: rl h= c.kya-q•:' -��_- th_ .----erlent. _lease noir-: t.tr=t, -- cntr i' r[jciyi' ec Dr- -.i r- p_-c_r:rlrt_ _3rio_ L'a., ;r :]' ='he = .s cm .[lt, an E::==r'.' _ •. '_T.•1 i. T--Ust k1•:: rb = 1 . P: e= _ �: _] . so be ciy:: f r th•_ [51 rr_. ":rI'-: l::nd >e guia• -ir"es `n: _ts ic, % 17 17. creen b:":.t ra; b' ,=_11 -:wed .. _::ir h1e'-opol-tar.' r (2:._...:i nt. ..i""= C]i �:-.�-may:'. fe=lt.ro: = e -:3r o_ "._.. r,ent Z-1 { nc: nt.=r'.'"-=F.•=_=r:. r: oc;: r I F:_ t.. _._ _ - th' in., i7 Les �.�._tE•a - ` S = rti`_r. art', cl _r c�n tE-1_ C 1Pc-_:ir arcs. •.J71 _ '= _. ., n =r._� Ila -1 .? L t, i s .-z: =ter: t tr=.:r' nc%. c- %a _ :._ =a-rctF= _ n,tL:cl 'it.. f rn Ln In - RriL, - 1 xS .� _. ._. f tia'. F..- cr - 1 _r. c:=:F't: t.]cR;: fc•r Il�:lr =,} _ i-• _.n allv � .:c1t:C�:L L:�C: •: i�_Cr:: f•:tr LG L :ir 1Ci:C iiL ai.l tlCnC C:_`'n:T =tom i. 12. J_C .-_ i_t'•t'rl" f .1 lti _ S t :_Ci:l. == u r :i in r-: - - %C, - - wa Ird 1R y•7 c- '-c 111E 1P�' Tl:c ..:R.=_:1CtE'`. �!] tom..--•L-'it F:-_'['lrp S" �Y.s t,._ ti_..t`-r h•r::l,.to and Ic-:_n..: an o; t;•_tro�; l]-.a^'� f e ~c_ .. a--c;:il-c:Q fr, Lr i'iC1f::1- •I atl C. i+_. 'r7 i t Fr itr ntr- e ce pri:.r t.:� .:n•. �- � _ts ..u�;t fcr n^ s F,r ;nrrtj . T'1- E-�wi1' an. pr r it cr ea_.-,i•'n+ r� �` :.hrq:.: qui na ren tha=rime`.cr fen i. c e: =E,•_ It _E -S Uci.w �t:t1.-teG ce Un_'r r•r;;�:- 1 -.L R}`. 6 f�E't ill 1Lc igh'= a•''..'t(D - - C - k=_ nUled u�' a F1'e:_ ith tta�i= of U•art�:: ' Cl �1RC Cllt4:c Lc ilt tCit - '' 4� f `'i:�'e ti f'.1,:'It C- u :;ti Y�'_ : =rrt . ng rr.a•: 1) r. re;i L;• �'e- c ,: ,clita?:. �_•'-ilii `iri Mt `' &_n'= FeE• r- _ -•dC-_'lit .'� lt� I.1 �E... - .i-CiO-Ems: _•�;T e.,+� t=nr:cl ter' :-•clic: tc•a -}lr alir.:nr=. Ltilit's _ _-rtittL'd v, in i t . - e Pro?rrta _i: r2 :]_ of o] 1c `-nts. Ye=.-ne-,= st=>1. -u-n_ i;c1L'in catcz basirLs, marholr> Dower F:o1e C trt1 riGcr o}:os, etc. , shy: n kJc nc:ated alt = -, it __. n'-oa+=. t.i._... ar:d, �_ ca�._r,�r.^tt. L•:e red �clst that pe-manent ll „tCt u Wi th J. TI pug-ic sti ects1:_ w:_1 ch Me pro• :-'__t1':'s la!'1�1t.1E arra c•_1nst.ructec und_•r t h u Mc'zropo1itan L:a=e_ District. t-, 1)�: pliaLed as lar frc:m our piocli::e as passible, bu:. not G1USlo:t:l= r fe'=t F=OT: �hcn ou,LF=rte or oi:r C'. ` hC - Inst -J.). A.at1 On c= u"_i11ti2S Me t r Opo'_ . tan' s it 1p P-1 J.n eL {s ] must h E' n aca oi- n c e w th ML F. r e c u'fr�n rR�-Rt sliorwn on, the• cnclosc ^=ints of Drawings NVr,.C-'�1 [,�� and Lr4j•". 'r Vi fl•_a n" -Ie L'.- '.]!]�. _. i.b 1e We rC-Cti:-fit .- ri'am�rium of once foot c1 ear ancebetw-,e-: t•;=_'tronc!it a_:'s pipe and VOLLr 1=aoi11t TeIP.:,Ore, r�---;_ic•rt Cif M trODD Iitari pipe :a als. b^_. r s'_ired z` t^~ercrossi^gs of its pipe in cin o:,:;i trench. The tenrorar•:r �:,uano=:. tel: -ns must bc' re.-iewew itr.:1 apr%rovea by hf.'=ropol_tar_. c. ..,aterc, ut-=lit-F c=oss'_ncs of tstro�ol to -'s piF lin° r: 1t:1: ;t be as perpor.::i•:u'?ipeliF..c alineT.er_t as practical. Prior to any excavation nu= P' pc lino. :i'r 11 bx^ located rr.an�.all and en'y e�cac•ation wit}1i'I tr:n fee_` of our pi13(?_ i nirst i e acne by il2rrd. This s' -al- bc• not -:°d on the ar:rocriate drawings_ e. utilit-les constructed longitudinally wit'in x'.c t.rc•�rJli to ' , _igtit.:-ai-wa n unt be 10=ted outside t`. e theoretical trench pricrm for uncovering -.a nioeline and mus. b= 1Jr.at. parallel to aria close to its ricghts- c - ay lines as pr:autical. f. Wh-an pipinc is jacked cr instsallc-d in jacked casing or tunnel under Metror..olit.a's pine, there must bc� �.t least two. fcut of ve=t _J clearance �)etwee'n tine bot -ori of Metron0litan's p,irre acid the top of tho jacked r, jaci inti caj 'in7 or tunny 1. We also rccui_e that detail dr,iw=.r:q of the shoring or thebac-L-inc or turz::ol._ng pits be. submittr.a for our review and approval. P;-ovisions :,..._ be ri:ad tc,' grout a::y %r•oids arnund the e^i:terior of the ;ackea ripe, jacked czsinc or tuna. =1. I: the r ic:i.r.g is installed in a jacked casing or tunnel the anr,ula' ,aCr_ between- the piping and the jacked casing or tll71i1e1 rlllst b•=' fillF'd wit}l GrOUt. CCU G�r:l�..t: Yh: f!� _ �C-.::� [ y�'r L,r`_.. [Iti. F C11 2t aerrs'- _.r r.in=:t=u:'ciG" C't:�E:r r,C• _ `_. - rn'..iitnn .._ � j ; r, c - 1 - c'i 'ar n.-.;. -i M�Q--i:er ru-� t: ., =r" ::hr tC:• t- e �.: ,:•.:I- :j'- i•.: ilo,.•ili --`ic rnur,:i -1-ct F'c:'%-n.'." ce `cn ar, i1"r, cam` r h•_lp Gt,, r Hc:•r : L• ir[c cu_ my ".,...i-ntt! rc- '•} Lin cf.e :lan:::•- _-_ ri th'_'lRC" +C•1'_ R= c:]C 511 p' :]I" _ t'"ti'r• . IVB J C'r.,ilt: ; - .•_" Z� , .- i - Oi'��rl::=iC iR•:':5 - 1 -erwa 91V ll.lder'YC:';n[i :.I r:C Yr=r1)_ "•, .0 Z71-_1•.YL'it'- - L:rf:'--'%:ti1_•�Q W' tY•i*' C'.]_1 �: L'-:�c T:1�`.cL,i'Fl nC - �.. _ css='P..E!n''_r ." of rec; an:ur o: r" rc cirrnc rlL2-� p1 ceci it:•-" r ,h%. T: E` _ round c:: F_re t}i• co: dt:i: rnt� ` r r e]:it tc . i:. � ^cli::t _ r�ctic-: C. -• �clL TL n tSE t"ODU itan' SFCGI!f0= t[1 �ne Cr:ii`_oEni to-? rtr�c �:1�tf H trparat n of 'r ter ^:'ii: rl - C e {-D- Cit., •- ti:e Cit': CI 7' L'�i]i'tl' f_r•c,r'i. rld ,i :fir[' SE. I-V 1Cr_'S -3 _ inc�talfDn of srwrra i the ._".�; .-nclic� E's it rE'_ trs. t, 'r:., L e r 1 l Il E'•�.• T. - n:.t: O_ _-Com.'_: �1; •L Coil!:: rTl" i};.�r�, _l c]^ C'i _�L,•C rli:le; 1 71 i tr• rt r-cht - WE v%r Ljo- 5111 RC':r cil^•Trc.._1'•t_N F.. Il`_'f:t j iYniL� - r - rlrCi��"r`"•J n:= �r &n t)Le' 10 C�i.1(7 GI loc:: tiGz:: .� _ _ our F'+.^elirc [sl �}Ee _:,zs sr:::1 l •" r., t L Gc�LL r^ P}.c�liRet n' C'"^i.1t1C:Il. c'_1 �.'R .".___t ❑"`. :jr ln':S =',r []•,]r j. I r;tl:clin: :-f ?•:c.tropcl:-tart's pipoliiiF i = rP�:-i.� ed r._ -wee: a L;til it.•: end h7e_-o_o;li.ta-' pi- 1i is inciicatted on the TDlan tc• be one fno _ c:•r a ('= _ . I i -khe innicat.r < clearernCe _ s between ❑ Eni tw:i feet, pc:th:_l:)q 1:. sllgRes=P•', i'ictr=0-i-an wi-- prc..-ode L recresent-ative -o al:sists other:; in looatin❑ and Ic:nt-f i:iy l:ipc•1ire. Two--wor?:int da_:s no -ice-- re•:: aestc�ci . } e�_uato shcri nr and bracinc i _ <<-cFui •rr_•:i for the f;;Il dcp-h [: i tiv_ -rent` till= the excay.it _on ehr-root he w_tzirt '--ze zon= shown on F: qurx- 4. 'h ]uc`:i-_cn of uti-mics within Met:roolf.t=ti' fee-Drcpe,-,tv and /n- easy=ment hall be _Dial my marked to 1ir%lp Dic-:ent damage durin7 main`-Pnano - or cthc' wuJ ?: cone --- thc- a-ra. Dct.,rta'.:•Lr_ t.a-,c: over b2ried utilit=es should he• rlaced a r-inimu-c of 12 inch es abo:'c the utilitl enr. ::frail- c:oniorri to -,ne-011.0•.ai::G rcc::ireatc-:ts: - i j 4 tits r r ipcline : r. two i nY blue warn enc; _at,e shall be :Tr I) rLtrd ..i. "C'=:'.TS❑?I F3LIFIE1 Fi:TE PIPELINE" 2) Cr_ , ni" , or chc%micc.l . ianline+ F two-inch yellow wa=-ning tare nhr j 11 7,5 imnri-r:ted with.: ^C_=:U:IOti BriRIED F=2ELINE" ':tom d_ air :llama=. 1-iP: A two -'nth gree-: War: inq tape shall he iaprinted wi `_: "CAUTIO`] BURIED P=pLLIhL" 4] Ylectric, street linh_ting, err traffic s.igna'-s cond.u-t.: tW7:�-inch rtd war:i.nc_ tapc° shall be ia: rir.tud wi t�-h: "rl :.0 :ION BUP.IED CONDUIT" 1 Tc-lepi�nn or telev-sior_ =dui=: two-in•cn orange warning tape shall 4x im�rintcd with: "aA=IUN BUL IEC TO:^UTT" :.n rerb t s 1'r If t erc is a cathn3ic "-Otection stat or, or Neto; olitc r--' ; p=pclin[• in thc area cf tltc' ';r[»a�er7 wot k, it- stt 11 :)e lncat.ed i [. a o_:c3V ati-o: . The eraot 1o,.aLL oT tirac` nc o.r bf titin, d^sCri1)tion a: -u prbt ctinn sha]1 kib show cn all 'lcanr_ contan e.rnnolita-'s C all2rDp'icable plans, lien, lccate:i at tetra: ni i`.arl' z lay nyinrcrir.q Sa ite;:i c ar_c Fiit a i+n-_ 7 ut} tine Flar:t, 700 ?:Orth M•o=enc HV•_:nup La Ve_-:•e, f all nrnia 5177r =q=_, • 'telcphonr [71 j -o= thccation: F'-❑ of f_otcctior c:taticIs. Z] If ati inducec:-r_xrrrnt cathn3ic prr'en}ion s rst[ n. .s to be i nStall[�d o:: an, t'.etrnaolitan'� pipeline, pi' CbRtbt Mz. p+r- re E. Finer at (714) 5n3-7.;7: or [131 250-^085, fI• wit r[=:',. _r•tv `, h� orbpos edst.ett :c::.lictE and Bete tine if an, ati 'hit tr' exi ti::g .^-athod c prctE_ _ ior; stctc : itis; 1l as by Mctrcpc:l i tan . ?1 F:ithin M•'xop:.?ita-'n ri(Th ts-of-way, ipel ttcs and carrier riFe; [casin;s] shall be ca,tFd wit:- a_- a:]rjrOved protectivr c•.)ating to Cor -forte to ;Setrnpo-m'an's requir=cnts, and shall be �aintaincd ir, a ne,.t and ordrrl,: oor.c'itian as directed b_: Me ra o-ita The a n. i.lLcati,7n and riori.tcrit:c of cathodic protection or- the Lipcli.ne ar,c^-asi-g shall cop. -Q= theto Title 45 of Crede of i'�deral' kf+gulat' ons, Peart 195, 4] if a nte41 carr:.cr Pine iC3singl is used: Inl Cathodic protection shall be prc:-ided u=" Cf LI Nacr-ficial magne iur a lode [� Y,etch ::howirig the cathocic protection, uetai_s can be 7rC' 1G�:i for the cusiCcm _ i foz-ma r, Rs tlb. , (b) `1'!1e Stc,U. carrier D. -rue shall bE- p-[)tected with a coal tar e7 aam,_1 ccating insid[: ane out in coard2ncc with JAwe C C'3 sneci`_icatian. n- l_ troncktes shall by excavated to co. CAL with the CtLjGSF, COnst=tiotl Safetti• Order_ , !LtinIe o, begir.ninq with Sectia:t:; 1 39 h b h 153 "relic backfill s6hall he placed ir, 8 -inch lifts and shc11 h]l' cc'qua =ed tc 95 nerce-� relative canpaction (A;m^M D698) across roadways and through c_k ororectite es. Trench bac?-i11 elsacahe•e wi11 he c0mpact..+3 to SO tie-x::ent -elati: cospact.on (A$Ti: Iit"•9$) . r.. Cn 1: -)l at 1e I-c:nne• :_i':7 ..•i. _h _he ope tic n of tI Opo tan ter: a::_ bur"._.. within. st:-:=t-s propertle= a-, ;'or ccse �ttt.;. The ]acat'_o s and-lerrat- r,"_: of thr=isN ..an1t:5s shall bP _hovn ❑^ t.hE draw�;-gc,. •Phe =s inga shall note that prier to =ny exca:- =:. in t.`e. area t:.)r cont-rol c, b'_e=_ shall be located and rr.e sure: ch. -'-1 he tak_� k%_ the u=tra^t.or to _-�rctect t -he cah�lec7 it: p_=C-E'. F' ti1��tr'•=�::elitan nen:k7er cf Ur.c-crnt�n:'_ S,�r�-cs T::_ contract= (F'-xca'.ator) .hall LIS-- al 1-eGG-4? 133 `c:.:-: -_ `cr : - {.+ ., lir"' t-311_ _ ley _ _c 48 hours pr -or to starting =vr-°xca.vatio:; worl-, T11 contracto %will hr_: '-a %1.e ro- a ^ v damace to M_5 t=o o1itar's facilitie° as a res:;=t of th_s cnnF-tru:tfon . E. r'�:.ramount F:iaht Fac. il--�Les constructed within M-tronn1ita''� fr properties analn: shall be- suh^ E.•ct "_o the right of N.e'rorol_tan o use it -rF p npr ti and/cNaseraojit�. for the purpose for which thew were acqirLICi. 'f at tLme t:etronoli u=,7tan or it assicns should, it:• ttc+ E:c rcisc: of the=r rights, find it necesz=v to remos.-=_ anv of the fac_lities f=-. the fPe aropertirrc and/o a :r nr.nt.s, such removal and rculacenen- shall be at t.he. cr:p=_.__,_ cl the o n^ of the faciL-4tv. 3. Moc_ficaLion cf Metro •:litrri's Fac-1=ties YTher. manhole, or other of Metrornolitan's facil; ties r..ust bc• modifie.d tri riccormtodate vour construction Or reco-s- tructio;r Me-tropolitan will nodi_v the faci'-=ties wi.th its, forcNs. `_'his ,sho'id be ncted o: t.lLe. conS=uct'_on plari�l. TY r• cstimatef cost t.e p=J orm this nodificatio: will kit+ ❑i Cn tc tion a:3 w w.11 require a deposit for this amount before thy_ Once t --.e depn_ i.t. is received, we will sch=_du[e the war}:_ Our forces will coordinat•. the work with Yo= contractor. our final killing will be based on actual cost incurri[-, and wit- includF materials, ccnstructio;;, tight °cri : t p•'_an rev-ew, insr•ection, and adninistrC:tive overhead churve.s caiculatcd in accorC"ance with Metronc•lita-,'s standard accounting practices, if the cost is Less that; the deposit, a refu::d will be nade; ho::eve-, if the cos= exceeds the cep^s-t, an invoice will be forwarder for payrr.e::t cf additinna- amount. a. x:esid ntial or cormerci al decelc c-: 1: Crcar; �-5 i�d CC�r:C�::t r�_te5 Z' t- tC'plcal-'_:: the p'a storm wale' runoff Nell a-, thr al �•e.arl} stogy n:naff from an area as ino_easin7 '_:1e reaui_ eats - dc ..st.r%- -c of the -em. fcr tosT drain -acili ier. c3. -c _•lr:•pment. All. , throuchout t tc haler f o -r lan:isc: _-.e 1r_1 } yee- olttdno- rio nr_:sti c „; e la `-cn, car washinq , and othr r t r u;cs flnws into the Stozr.. dreinaap c,:stom Tcsuitin in wr�ed abeternez-_, inset' infe tatiDn, - n7strLc sd act ss a. d ^ther nroble;r,s, v-,� - Th=�refare, it is ,e _1_opclt:, Cf s usual prractice nrt. tc: aparo:- ti�.t:-s that. shoe: d-r:c: ar.;r Cf era na7c -rem ccvelopmerts an}o its fee r•rc_re=tie -d or :asNments, - tic carried a h - McLro oiitzn l fe= ,�r 'res:: ❑r dis^ i'--c;cc. :int P - c•: tier; and/or E°aseZcntr., M trnF>:i=tan Wd it insist that Dlzns for cevcloc-r.ent provide that it ba ca--iec b: cl. =,,d conduit o lined cper. chdr_nel ap•roved in c r ting Metropolitan. :.s0 the drainagr_ facilities m ^.tur:t e ; i:tained by others, e.g., city, count;~, ho Downers etc=. the develonIn.eIlt arOonses ChcL-1 ir. "D�idtlnn, `ezturr.s,, ther; t g`'s _ existi^7 d--a4naq,, dr'vercper Shall make previsio;is to r,rpvide fClr Tt'.0 i.y Ce".:•:'Rt and those- changers must be au_rraved :�y in writ.ina. 11. Coni-t_uc-tior� 0-�ordinatie=� 7 Uurinp canst:'uction, ';etropolitan'r: field represer.tat,J' = wi__ make- oe�r,o:ic i=pec ions, We request that a slinulatier, hr added to t;Ie plans or sDe cifications f•r)r r:otification of Of -Metropolitan p._itar , s Uacrations Services Tranch, te-ephonc [ 13} 1�a- , at least two wor9�in dal -S e,ny work in the 1•iC].= irl' of our facilities. � p -'C)` to l ' ine Ln:i3_r:� keStriCti.arls z. netropclitar.'s pipelines and condu_t:: vzzy is structural strcncth, and some are not adc�_uate for i+F:S TC; I -2 l ading_ Therefore, snecific loads ovc- lh_� Specific ^_ctinns of pipe or conduit must lac reviewr%C and approved h•; Nx_tronoli.tan. ?iowevrz, Metropolitan's D4.Daj.ines are typically adequate for AASFITO Ei-20 loading provided that the cover over the pipeline is not less than four feet cr the cover ;s not substar.t'_ally increased. 1f the temp^rary covet nvc�- the peline a nur during consrction ibetween tn;pee= eet, ecuipr%cnt must restricte:', to that c:hich T-pCs es -Dads no greater _::an -y �T:. 1I-10, r -n �'�=- is bc.twc(?n tw_' a_^_3 th'-ee = —t, eC9 ].D•R'•:... ^..115_ t'_ Y" t0 ti:a= of: :, Cater -lar L;-•1 tz-;;ct-tvj:%e tC,.n If the c.-wor __. ]fess thaI: _,. fe^_.t, D.^.--, hand en7,,;.%fit. 'la•: be us•?li. 7t1.o, _f thy. :-D-"•tr&a:t.or p.'ans to__c._ a,:%: rcu�rT.,-t o:e- 3'M-`-tri7t':� 1JtaI1't _❑iv�l-rl�= wnica rvilli-r.00se loads c_rc�at=x" thatl iS1:��:?TD 11-20', 1t w: 11 bc. nc'�C'S52'r'i` tC sllL]r-1xt le of s•act ecuip-nent far our rcvie:: and appro-:-1 at least c•nE �• wc:c}: nr=ar to -� u�;�.. _nr[' re�t�"ir ��-:c req�-irc-•ts -ray ap;:l}- to tf:r_ lu.�dine yL ice'_ in•- o -:ex" :"�c: Sar, D_r•.gr• 1'i:x°.lines ] and c:•` the Orange Count-: FeEd=>: , and ihE Co1^7"aG''C .:l Vit' rt'lleC set. YleacL. contact us for lo:cding rest_'ict"_D"_s on al_ :?] M.,5 t rotiDl'-a s Ti_:1c n•1 b. '"Ry_.i:istinc co:cr Over t�:c pi c1inc: 5i all hr I^.ai -I taiad tln1;'-- Mr-.. t. nonl itas dete-zr. dins at rcoosed changes de not pose a hazard to tI1 intccrit.y o the n 1.inE nr" an nm-edlment to its Ir,ai^tsnancc. 1 Lil�sti_::' a. At _east ZG da s -Orior to thestart of ^.•: d-ilLi-c far rock ercr:: ition blas' inc, or any lilast_tr-, ir. ths vicinity of ^Metrooclitan's f.a^ilities, a two-part peel=min ary cone: t.ual v1a, _;hall bs sunmj.tted to Metropolitan a,, follows: i:. Fart 1 of tnP co::ceatual plan shall inclulul, a r_o,lc>]"_toCZumn::ry D c;ropo=c.J transportation, handling, r;to=ace, ane Ise ❑- Explosions. c . p�.rt. < <::1::] 1 _ ncludd"=. tkle proposed i7eneral concst t for t�'_aetir% _.'Clue inr Can-::ro1�3 of ILCIF3e, fly centro?"1c:3 rock., a bl .sting rklla t., and t c11n_r,uc and arourir3 vibration, 14, CE`s% ii. Why hn-: ==ent.u1 Doc>1-r;?_^.ts fla:•e 3tiot Been =cil trEd c alalia: s ire le.rentirlc the. CalifD zia Enviro=cntal Quality Tact {C ;Q>_Y) -eauire that have an opportunity to cor_sult with tk: , aaenCvT n= consultants are::• :rine an•. en-rironm�::tal doCunentation. til_ are recuired to review and cors icier tl:c e viro::R n'_a'_ e-fccts of he nr^'mac`_ as sten:" in the 'tic-5gativr- Dr- 'a_ tion o3 En-:ironr-lE-tal Impact Report =orycur project Ijafnre Coy.*cittinc �'t�_'t• =':J C:_1ti:I1 .-_, aP•Pr C':'� 'Dtir rE':3ll•'•;t. 17 - -] In order to en urc a7r:.ianc•- with the r P_U vl c.t I4Dj i—nD2-e;Zentlnr7 C�, where t•Iuti: Dnli.tan }•=. nom: th LE_ad A er.cy, the following in nut n-oncdur� to en ,vr _: coT_:•_i n; e the Ac`. r• is _st L bl ___: cc: aJ Metropolitar shay_ 1)•c timn ly .' zdrises an dctFrmir.atint: tha: r Cater rices xeto`"; nn apdi:i lies to the pr . oje�tThe ad - ; , , to U �ictropo-i.tan that it ane o`.r•e_ aQ cis articiratir_ in the �r;ject a fnE' -ecu-ener.ts of CEQ'& corr_,liec w_th k- prior t n1c_roocl tan' � s } r`--r'`opnlitari is to be con_.ulte.: curing the p: r parat.io_, of the Neua ; -_.E. L 1'r �Iet. tin:: nr cJ ^etropolitan i to reviA„ 3rd submit an lr ne•=:ec;sar;• comments on the Necat r.rar. ETF,x'1e Declaration nr d) Metrcnolitan is to index "= ar+.V costs or 1'-2bility arising Out oFLnie� Soi viola -'ion 01 ar.1:o- regtl.ation�, irLoindinc_ but rot lirritA-d to the Cal fornix Env`_-nnnental QUiLlitv Act and its implomr_ntin re^ h. Siher �;7•; i±cnmenta? Docu`er"ts Iiave Tf nvironme.ntal doCLTments havF been prepared for 'rpur project, please turninh us a copy for aar review and filF in a timely manner sp that we May have suffici =evieW alLd corintent. The followent time to ing, steps must also time accomplished:be 1] T=i Fad 2'0ncy is tO advise ASetro�oli.tar. that _y and other agencies part4ciYave in thF pro7ec' w the require- frMts of Com, pr'ar to N"•tro o-itars's participation, =f YOU must afire.. to indc= i_v ;letropalitan of`_icers, engineers, and agents for ar_, costs or its Iia :•flit} arising out nf. ar_}• viola}ion c.f an laws or regulations inclucirg but not limited to -hc Califo-nia Envrronmcntal Qual_t_: Act and its implementing reguIo s 15. ''let -Ono 1itar"' F'an-Re�,°iew Cost a. e.n inceringre;-iew of your prop•nse^ facilities and deve_opments anc the prena-atinn of a l.cttet response L - : _.:1_ . _.,..., r, -. _oil..._..._ = e .r'..,.- �.- se vo:: that !✓.ctrcpo1 t.a^S = eWS an - perio-rred at nfL costo tt' he deE__Ot,e_ ll:i ,,� , .... __.__lit_ re r..us _ be modi Pied whereMetr0a)01 ha 1t;f%ic._ r_ ^.ts. : f nfo ? a =lot a. .a;. _, -, ar. en41'le"ring review an -d lc Iter respo :« _ quires m'. rr_- _-a^ ? T.an-; oul-s Cf effo.t b_; ht�opol-tan t-, rn-r.e tiq.,•_onal=t.ari pr000sec fa__, c: d aclaamer.t is cn= tide with w. -ch was rte. b or _t_. c; f -a ;,11:.1t'-:•, c .f rcQdificatlon`r to l'.'.is] iz mann or othr_' faci' it'es will be red, the:; of _ecus _.11 r:•,_ Mr �r Gp:Jl itan' : costs associated wi-h t` r?. ::•r•njcct rr.•ist be = c'ra1 p'ai'd' by tr_e de:re'_aper, u"le s:: tr.� cc. elcper has S C:;, rights. b. A deposit of funds c:i'_- he recuired fzo7� the _ developer before `ictrocclitan can begin its detailed cr.�ineerinq pl=, review that will e^e^ E hou�i�j%. ^h arou^t Of the rc•cuirrzc dcp^sit will be ceter-mined after a Elm 2 r.- r. f•_ c su'....__.:.dct r--ursory civic°w of t_2e mans f= t:hz� rn-.c :c d de:-e1^amen' _ . -:zfc. tr•>�olitar '_, final bil'_i^ v- l ie has• -d cn c•. -c-t. _:icurrcbd, and will. inc].u'e er.c-r.c —L= _:1a- -- Ie _..�:)=cti-^r;, m�tcria].:. Co �tru:. in aric admin: strati• _ overhead charr_res calcula.e.4 _-- acco-"dance with N.ctrc•olit::�•'�= standar:. account -ng =:.-ces. .f the cost ._, less than the do co :it, a re=Lind wil'_ br, ...=•ie; now(INY-or, -f the co_ -t cxc^ 3s the deposi _, an -n-: 4 will Lc° `or-..-arded fc_ ment cf the additioza'_ a-onn... dti tio&I ceposit, mLv br- -e=ire:l If theL Cost r"evie.W E.'.;<C:E.'.:_ -I%cf a.nuunt of the nit- n' do it We ad:: se vo:: that !✓.ctrcpo1 t.a^S plan rev. eWS an re �onses b:i_;� :i�c:; nfo ? a =lot a. �._._ _...;1P tiq.,•_onal=t.ari w. -ch was rte. b or on be`.alf c; r:•,_ -r, taR = c'ra1 rec-rL - os_� or.'. S C:;, _ Elm 2 r.- r. f•_ c su'....__.:.dct -:zfc. ___:r, •C'�_ t+lir: warrant •.. d1._. 17 E'' -eSS Cr .._ --1...., -:•:r. aitGC::IE.'. L: tC t[:_ �o`r.a e1.. CC1:"vC':C� F=. _, _.. __._.. _..._: C_C^_.lir:. Ilc R.� �..� .._ _... Craw- .._ _.. _. _ __..:n .._G h, _ _::•I"' i�.. �..-�.__tir._ tC:• O.^. a.^ -� Ci� _ r.11r .._ :'l_�.. :. .^. _ .-_ _ the_=fo=_ tt _, rve_:s role t. a_.: ..=_ ...�i~ _,:rr: tD -_•,i' :n estic t__.,..: _✓G r.a ee pr de: t tC ttLaa an; G ams icr rrroje:t. coy_..__. u e _....F1f _ __ d.. _ - 1.4 - 1". A.adional IIFeCZati l Should you requ'_r^ additiara? ?nfcat=cn, please contact: Civil EnQ:neer'r! SuSuhstr7jctures Section hietropc'_itaz Water District Of Southern Ca?i€arn_a P.4. ?3ox 5415 Los Angeles, Califo_nia 90054-0753 (213) 217-6000 ATE 22, leg LJ •9 U' 1 c i C Y ;k �•f � lY�, P �t F _ 41 c -- t LJ •9 U' 1 c i C Y ;k �•f � lY�, P �t F _ 41 `I I NG Fcir,U1:1NE1V7- ST-RUCTURES r7ERMIT7-Ft: M. WG. PE:rxAly PtlV RIGHT OF W.4 r` Nd RJC�F OVERHANG PERITiEr� r I BUILDING FOOTING eUUST NOT AD.I.CCENT ENCROACH INTO fiv RIGHT RIGHT OF WAY Or WAY I I FINISHED - � 5Ur7F.4'CE r jl � ! 1 DEPfiH OF ! FOCTING ! _ TYPICAL I IP I � r i I � M,W.Q PIPELINE I I NDTE w a-W0D PIPELINE SIZE, DEPTH, L 0CA7I0N AND wIDrH OF PERhmNENT RIGHT L,'F h E.,'; 'O oi1.iS'�- J W„Y VARIES. F: G� f—= u„ v Tei I � I « \ -/j \§%I z\J/ \~/\ \ /2 Lk \ ^\ 2C(� z«2% <>>< 62rG f>§R z&§« � \\ / .y : \ « \ -/j \§%I z\J/ \~/\ : \j Lk 2C(� z«2% <>>< 62rG f>§R z&§« / .y Yi r eL ,I .�•I 'i r, i -_ Imo.• .y. a": ImeL Iy - :I d ;t L%; I fVI _ LV 9 Lr r• ' - ' -- ..i .. • .}}; ,: _ SS -C7 -10N I I f{i r 4 NxEXpremolded 1r ezpotrslon AVIV- +Aller Apertures cr dir _ ry m the Engineer,0 otC1 volumB -- not to exceedthe r0lume Of the supporting wZF all Concrete support wall to be placed flgalnst undis- turbed ground I. Supporting wall shall here a firm bearing on the su6grade and against the side of the ezravation. 2_ Premolded exponsian f043r tiller per XSrAf 0-I�l T3 to be used in support for steel pipe only. 3. if trench width is 4 /eel or greater, measured alarng centerline of ,ff w p pipe concrete Vupp art must be canstruCted 4 If trench width is less than 4 feet, cleon sand back- fi1l, CwnpaCted to 90% denslry in Cccardance with the provisions of AS7Af Stondord p-1557_TC may be - used in lieu of the concrete support wall, CPOS5 SECTION `vr7 n J,� c'pNN? CROSS Cf^7ICf c It, pipe r.JNr 5s if 1Pn _?;ii?yIii-- cicn:r!cr is qre_^:: r 11^a^ .R I5 . pip' Cr;. the cc rr o r ^e u!:ii,r I:n^ l: 17No "lrPCf S:,•'?.'CS .Tlrl N' Cl':' The. re 'ripe .r N. fife. 40- .. � 1 -1 C C CXF7 � 75ia7.'7 ,ICl ,. r 1550 Harbor Blvd., ROOM 100 West SACRAMENTO, CA 95691 y wl (916)373,3710 e e ! 3 Fox (916) 373-5471 September 25, 2014 Gregg BeGell Los Angeles County Flood Control District 900 South Fremont Avenue, 11th Floor Alhambra, CA 91803 RE: SCH# 2014081106 Enhanced Watershed Management Programs (EWMP) Program EIR, Los Angeles County Dear Mr. BeGell, The Native American Heritage Commission (NAHC) has reviewed the Notice of Preparation (NOP) referenced above. The California Environmental Quality Act (CEQA) states that any project that causes a substantial adverse change in the ological resources, is a significant effect requiring the preparation of significance of an historical resource, which includes arche an EIR (CEQA Guidelines 15064(b)). To comply with this provision the lead agency is required to assess whether the project will have an adverse impact on historical resources within the area of project effect (APE), and if so to mitigate that effect. To adequately assess and mitigate project -related impacts to archaeological resources, the NAHC recommends the following.. actions: ✓ Contact the appropriate regional archaeological Information Center for a record search. The record search will determine: • If a part or all of the area of project effect (APE) has been previously surveyed for cultural resources. • If any known cultural resources have already been recorded on or adjacent to the APE. • If the probability is low, moderate, or high that cultural resources are located in the APE. • If a survey is required to determine whether previously unrecorded cultural resources are present. ✓ If an archaeological inventory survey is required, the final stage is the preparation of a professional report detailing the findings and recommendations of the records search and field survey. • The final report containing site forms, site significance, and mitigation measurers should be submitted immediately to the planning department. All information regarding site locations, Native American human remains, and associated funerary objects should be in a separate confidential addendum, and not be made available for pubic disclosure. • The final written report should be submitted within 3 months after work has been completed to the appropriate - regional archaeological Information Center. ✓ Contact the Native American Heritage Commission for: A Sacred Lands File Check. USGS 7.5 -minute quadrangle name township range and section required • A list of appropriate Native American contacts for consultation concerning the project site and to assist in the mitigation measures. Native American Contacts List attached ✓ Lack of surface evidence of archeological resources does not preclude their subsurface existence. • Lead agencies should Include in them mitigation plan provisions for the identification and evaluation of accidentally discovered archeological resources, per California Environmental Quality Act (CEQA) Guidelines §15064.5(f). In areas of identified archaeological sensitivity, a certified archaeologist and a culturally affiliated Native American, with knowledge in cultural resources, should monitor all ground -disturbing activities. Lead agencies should include in their mitigation plan provisions for the disposition of recovered cultural items that are not burial associated, which are addressed in Public Resources Code (PRC) §5097.98, in consultation with culturally affiliated Native Americans. • for discovery of Native American human remains in their mitigation plan Lead agencies should include provisions. Health and Safety Code §7050.5, PRC §5097.98, and CEQA Guidelines §15064.5(e), address the process to be followed in the event of an accidental discovery of any human remains and associated grave goods in a location other than a dedicated cemetery. Sincerely, man Katy Sanchez Associate Government Program Analyst CC: State Clearinghouse Native American Contacts Los Angeles County September 25, 2014 Tongva Ancestral Territorial Tribal Nation Gabrielino-Tongva Tribe John Tommy Rosas, Tribal Admin. Bernie Acuna, Co -Chairperson Gabrielino Tongva contact information unavailable Gabrielino tattnlaw@gmail.com (310) 570-6567 Last attempted verification 9/5/14 (310) 428-5690 Cell Gabrieleno/Tongva San Gabriel Band of Mission Indian Gabrielino-Tongva Tribe Anthony Morales, Chairperson Linda Candelaria, Co -Chairperson P.O. Box 693 Gabrielino Tongva contact information unavailable Gabrielino San Gabriel CA 91778 Last attempted verification 9/5/14 GTTribalcouncil Q aol.com (626) 483-3564 Cell (626),286-1262 Fax Gabrielino [Tongva Nation - Sandonne Goad, Chairperson 106 1/2 Judge John Aiso St. Gabrielino Tongva Los Angeles , CA 90012 sgoad @gabrielino-tongva.com (951) 807-0479 Gabrielino Tongva Indians of California Tribal Council Robert F. Dorame, Tribal Chair/Cultural Resources P.O. Box 490 Gabrielino Tongva Bellflower CA 90707 gtongva@verizon.net (562) 761-6417 Voice/Fax (626) 676-1184 Cell Gabrieleno Band of Mission Indians Andrew Salas, Chairperson P.O. Box 393 Gabrielino Covina , CA 91723 gabrielenoindians@yahoo. (626)926-4131 Gabrielino-Tongva Tribe Conrad Acuna contact information unavailable Gabrielino Last attempted verification 9/5114 This list is current only as of the date of this document. Distribution of this list does not relieve any person of statutory responsibility as defined in Section 7050.5 of the Health and Safety Code, Section 5097.94 of the Public Resources Code and Section 5097.96 of the Public Resources Code This list Is only applicable for contacting local Native Americans with regard to cultural resources for the proposed SCH # 2014061106, Enhanced Watershed Management Programs (EW MP) Program EIR, Los Angeles County. Native American Contacts Los Angeles County September 25, 2014 Gabrielino /Tongva Nation Sam Dunlap, Cultural Resources Director P.O. Box 86908 Gabrielino Tongva Los Angeles , CA 90086 samdunlap@earthlink.net (909)262-9351 This list is current only as of the date of this document. Distribution of this list does not relieve any person of statutory responsibility as defined in Section 7050.5 of the Health and Safety Code, Section 5097.94 of the Public Resources Code and Section 5097.96 of the Public Resources Code This list is only applicable for contacting local Native Americans with regard to cultural resources for the proposed SCH # 2014061106, Enhanced Watershed Management Programs (EWMP) Program EIR, Los Angeles County. Laura Rocha From: Begell, Gregg - Consultant <gbegell@dpw.lacounty.gov> Sent: Monday, October 06, 2014 6:59 AM To: Crumpacker, Andrea; David Pohl Subject: FW: COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EIR FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR LA COUNTY Comment Letter. Gregg BeGeCCP E Project Manager Project Management Division II From: patricia me Pherson[mailto:patriciamcpherson1@verizon.net] Sent: Friday, October 03, 2014 1:27 PM To: Begell, Gregg - Consultant Su bj ect: COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EI R FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR LA COUNTY Grassroots Coalition submits its support of the comments made below by Mr. Rex Frankel. Due on the 29th, GC was in transit from out of state and belatedly requests that its support of the comments below be part of the record. Please also note attachment of imagery of California. Currently, the State Coastal Conservancy and the Dept of Fish and Wildlife have created a preordained outcome for the Ballona Wetlands Restoration. This outcome that has been determined to destroy the freshwater aquifers of Ballona (classified as potential drinking water) without the legal requirements of public participation and transparency of process that the millions of dollars of public bond money set forth in 2004. Such destructive plans to the watershed of the Ballona Valley should not be allowed to proceed. The failure of the state to fully engage the public and provide accountability and transparency of process has led to the dire situation of groundwater removal that CAlifomia and Ballona Wetlands have. htto://www.latim es.com/science/sciencenow/la-sci-sn-california-drought-groundwater- satellite-20141002-story. htm I Thank you, Patricia McPherson, President -Grassroots Coalition COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EIR FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR L.A. COUNTY September 29, 2014,1:30 pm From Rex Frankel, director, Ballona Ecosystem Education Project, 6038 west 75" street, L.A. CA 90045 310-738-0861, email: rexfrankel(a)vahoo.com I understand why no one but myself attended the NOP hearing on September 91" in Marina Del Rey. You have no specific projects to analyze for environmental impacts. You are attempting to analyze the environmental impact of words, not specific actions. It is impossible to analyze the impacts of no stated physical projects, just as it is impossible to analyze those unstated projects' impacts on the environmental setting, ie., the proper baseline, because you have no specific locations for these unspecified projects. Thus all you can say is to analyze the entire county. The two most essential parts of an environmental analysis are missing here: specific projects and specific sites. You have the process all backwards here, and thus, commenting on this NOP in any specific manner is impossible. Some background: In 2002, local governments settled lawsuits and agreed to consent decrees and promised to stop violations of bacterial health codes at our beaches by 2021. This agreement gave the public agencies an extension beyond the original deadline of 2013 but only if the projects created new parkland and river corridors that could catch and clean water before it fouled the beaches. In 2006, L.A. City proposed its first big plan under this agreement, an Implementation Plan for the Santa Monica Bay Beaches watersheds. This plan was sent back for redrafting by the RWQCB as it only reached 2% of its target and thus, would not accomplish the goal in the consent decree. Also in 2006, L.A. city proposed the Integrated Resource Plan which mainly focused on building 25 Hyperion -style urban runoff treatment plants which would have cost the average homeowner ratepayer $400 a month. This plan went nowhere. In 2012, the County Supervisors tried to quietly approve a $300 million per year property tax hike to build a non-existent list of runoff cleansing and capturing projects. Howls of opposition arose and that plan went nowhere. The public wanted to know what they were paying for. Now, you are finally starting to design the cleanup plan. But how can you ask the public to weigh in on the scope of the environmental analysis of that plan, when your description of that plan contains no specifics? Your stated plan to defer the environmental analysis of specific project impacts to when each one is up for approval thus ignores the cumulative impacts and therefore is "piecemealing", by starting major momentum of a project that is composed of many necessary parts, yet deferring analysis and the controversy to a multitude of separate EIRs and CEQA documents and public hearings, all the while public input is diffused. We never get to weigh in on whether we like the complete plan because the Program EIR has no specifics to arouse concern and the real project discussion is delayed until much later in a way that requires massive efforts by the public to keep track of the success of the big plan. The people who will pay for this plan want to see the specifics before you raise our taxes to pay for it. We want expanded and unpaved river corridor parks. We do not want the plan to include converting existing wetlands and wildlife habitat into pollution dumps and sumps. We want what we were promised, not a lame compromise that puts the cleanup burden on existing public lands, parks and house front yards. We want a complete plan for us to judge whether it will accomplish its promises and goals before you produce an EIR, not the other way around. Please put me on the notification list for all actions relating to this project. Thank you Paige Anderson To: Tom Barnes Subject: RE: ADDITIONAL COMMENTS ON L.A. County Enhanced Watershed Management Program, Notice of Preparation From: Rex Frankel [mailto:rexfrankel(cDvahoo.coml Sent: Wednesday, October 29, 2014 5:28 PM To: Begell, Gregg - Consultant Cc: kathv.knight(a7.verizon.net Subject: ADDITIONAL COMMENTS ON L.A. County Enhanced Watershed Management Program, Notice of Reparation ADDITIONAL COMMENTS ON EWMP NOP: October 29, 2014 The problem I have with a Program EIR for a "program" that is devoid of a list of all necessary specific projects is that it short-circuits the cumulative impacts review plus it facilitates illegal piecemealing of the many TMDL compliance projects. A program EIR can be allowed when the individual and currently unknown specific sub projects have "independent utility", thus building and analyzing them separately has no impact on the effectiveness of the other sub projects, nor does it make it mandatory that these other projects also be approved. That is not the case here. The goal of the EWMP and the sub projects is "to achieve permit compliance with RWLs" (NOP page 7 paragraph 3 and page 8, paragraph 1). Thus, all projects must be approved and successfully achieve their goals or the region will not be in compliance with the 2012 MS4 permit, the Federal Clean Water Act and the NPDES permits. If only some of the projects prove feasible and buildable, the construction of the others will not result in CWA compliance. That begs the question of is this project worthwhile if piecemealed at all? Will the beach only be clean in certain locations along the shore, while others will not be as a treatment strategy proved too expensive or technologically infeasible? If the taxpayers ultimately decide this project is too expensive, but certain parts are already built, does that mean that pulling -the -plug will result in non compliance and thus a waste of the taxpayers' dollars already spent? This s How can the public know if the permits and Clean Water Act will be complied with if the approval of the individual pieces of the compliance strategy are broken up into numerous pieces each receiving their own separate CEQA review? All of this leads me to conclude that the specific projects must be reviewed and approved as part of a master plan project, with the public knowing the full cost of compliance, the full impacts of all projects and alternative policy choices. One specific alternative, distasteful as I find it, would be analysis of only building some projects and also enforcing no -swimming rules for three days after rainfall at beaches. I will repeat the conclusion of my first NOP comments: The people who will pay for this plan want to all of the see the specifics before you raise our taxes to pay for it. We want expanded and unpaved river corridor parks. We do not want the plan to include converting existing wetlands and wildlife habitat into pollution dumps and sumps. We want what we were promised, not a lame compromise that puts the cleanup burden on existing public lands, parks and house front yards. We want a complete plan for us to judge whether it will accomplish its promises and goals before you analyze and mandate it with an EIR, not the other way around. Rex Frankel From: "Begell, Gregg - Consultant" <gbegell(a)dpw.lacountv.gov> To: Rex Frankel <rexfrankel(aa)vahoo.com> Sent: Monday, September 29, 2014 2:26 PM Subject: RE: L.A. County Enhanced Watershed Management Program, comments on Notice of Preparation Rex Thank you for your comments. It will be reviewed for use in the PEIR. Yes, when people think of an EIR they are thinking of a project. This is a Program EIR, the main PEIR document contains some projects as examples but it's a program. We are presently working on the PEIR, check our website for information and details. www.LACoH2Osheds.com. We will be posting the PEIR plus public review meetings on the website. Gregg BeGell P E Project Manager Project Management Division II From: Rex Frankel fmailto:rexfrankel(avahoo.coml Sent: Monday, September 29, 2014 1:59 PM To: Begell, Gregg - Consultant Subject: L.A. County Enhanced Watershed Management Program, comments on Notice of Preparation COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EIR FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR L.A. COUNTY September 29, 2014,1:30 pm From Rex Frankel, director, Ballona Ecosystem Education Project, 6038 west 75" street, L.A. CA 90045 310-738-0861, email: rexfrankel(avahoo.com I understand why no one but myself attended the NOP hearing on September 91" in Marina Del Rey. You have no specific projects to analyze for environmental impacts. You are attempting to analyze the environmental impact of words, not specific actions. It is impossible to analyze the impacts of no stated physical projects, just as it is impossible to analyze those unstated projects' impacts on the environmental setting, ie., the proper baseline, because you have no specific locations for these unspecified projects. Thus all you can say is to analyze the entire county. The two most essential parts of an environmental analysis are missing here: specific projects and specific sites. You have the process all backwards here, and thus, commenting on this NOP in any specific manner is impossible. Some background: In 2002, local governments settled lawsuits and agreed to consent decrees and promised to stop violations of bacterial health codes at our beaches by 2021. This agreement gave the public agencies an extension beyond the original deadline of 2013 but only if the projects created new parkland and river corridors that could catch and clean water before it fouled the beaches. In 2006, L.A. City proposed its first big plan under this agreement, an Implementation Plan for the Santa Monica Bay Beaches watersheds. This plan was sent back for redrafting by the RWQCB as it only reached 2% of its target and thus, would not accomplish the goal in the consent decree. Also in 2006, L.A. city proposed the Integrated Resource Plan which mainly focused on building 25 Hyperion -style urban runoff treatment plants which would have cost the average homeowner ratepayer $400 a month. This plan went nowhere. In 2012, the County Supervisors tried to quietly approve a $300 million per year property tax hike to build a non-existent list of runoff cleansing and capturing projects. Howls of opposition arose and that plan went nowhere. The public wanted to know what they were paying for. Now, you are finally starting to design the cleanup plan. But how can you ask the public to weigh in on the scope of the environmental analysis of that plan, when your description of that plan contains no specifics? Your stated plan to defer the environmental analysis of specific project impacts to when each one is up for approval thus ignores the cumulative impacts and therefore is "piecemealing", by starting major momentum of a project that is composed of many necessary parts, yet deferring analysis and the controversy to a multitude of separate EIRs and CEQA documents and public hearings, all the while public input is diffused. We never get to weigh in on whether we like the complete plan because the Program EIR has no specifics to arouse concern and the real project discussion is delayed until much later in a way that requires massive efforts by the public to keep track of the success of the big plan. The people who will pay for this plan want to see the specifics before you raise our taxes to pay for it. We want expanded and unpaved river corridor parks. We do not want the plan to include converting existing wetlands and wildlife habitat into pollution dumps and sumps. We want what we were promised, not a lame compromise that puts the cleanup burden on existing public lands, parks and house front yards. We want a complete plan for us to judge whether it will accomplish its promises and goals before you produce an EIR, not the other way around. Please put me on the notification list for all actions relating to this project. Thank you CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Paige Anderson To: Tom Barnes Subject: RE: ADDITIONAL COMMENTS ON L.A. County Enhanced Watershed Management Program, Notice of Preparation From: Rex Frankel fmailto:rexfrankel(a)vahoo.coml Sent: Monday, September 29, 2014 1:59 PM To: Begell, Gregg - Consultant Subject: L.A. County Enhanced Watershed Management Program, comments on Notice of Preparation COMMENTS ON NOTICE OF PREPARATION FOR DRAFT PROGRAM EIR FOR ENHANCED WATERSHED MANAGEMENT PROGRAMS FOR L.A. COUNTY September 29, 2014, 1:30 pm From Rex Frankel, director, Ballona Ecosystem Education Project, 6038 west 75th street, L.A. CA 90045 310-738-0861, email: rexfrankel(avahoo.com I understand why no one but myself attended the NOP hearing on September 9th in Marina Del Rey. You have no specific projects to analyze for environmental impacts. You are attempting to analyze the environmental impact of words, not specific actions. It is impossible to analyze the impacts of no stated physical projects, just as it is impossible to analyze those unstated projects' impacts on the environmental setting, ie., the proper baseline, because you have no specific locations for these unspecified projects. Thus all you can say is to analyze the entire county. The two most essential parts of an environmental analysis are missing here: specific projects and specific sites. You have the process all backwards here, and thus, commenting on this NOP in any specific manner is impossible. Some background: In 2002, local governments settled lawsuits and agreed to consent decrees and promised to stop violations of bacterial health codes at our beaches by 2021. This agreement gave the public agencies an extension beyond the original deadline of 2013 but only if the projects created new parkland and river corridors that could catch and clean water before it fouled the beaches. In 2006, L.A. City proposed its first big plan under this agreement, an Implementation Plan for the Santa Monica Bay Beaches watersheds. This plan was sent back for redrafting by the RWQCB as it only reached 2% of its target and thus, would not accomplish the goal in the consent decree. Also in 2006, L.A. city proposed the Integrated Resource Plan which mainly focused on building 25 Hyperion -style urban runoff treatment plants which would have cost the average homeowner ratepayer $400 a month. This plan went nowhere. In 2012, the County Supervisors tried to quietly approve a $300 million per year property tax hike to build a non-existent list of runoff cleansing and capturing projects. Howls of opposition arose and that plan went nowhere. The public wanted to know what they were paying for. Now, you are finally starting to design the cleanup plan. But how can you ask the public to weigh in on the scope of the environmental analysis of that plan, when your description of that plan contains no specifics? Your stated plan to defer the environmental analysis of specific project impacts to when each one is up for approval thus ignores the cumulative impacts and therefore is "piecemealing", by starting major momentum of a project that is composed of many necessary parts, yet deferring analysis and the controversy to a multitude of separate EIRs and CEQA documents and public hearings, all the while public input is diffused. We never get to weigh in on whether we like the complete plan because the Program EIR has no specifics to arouse concern and the real project discussion is delayed until much later in a way that requires massive efforts by the public to keep track of the success of the big plan. The people who will pay for this plan want to see the specifics before you raise our taxes to pay for it. We want expanded and unpaved river corridor parks. We do not want the plan to include converting existing wetlands and wildlife habitat into pollution dumps and sumps. We want what we were promised, not a lame compromise that puts the cleanup burden on existing public lands, parks and house front yards. We want a complete plan for us to judge whether it will accomplish its promises and goals before you produce an EIR, not the other way around. Please put me on the notification list for all actions relating to this project. Thank you CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Draft Enhanced Watershed Management Program - Scoping Comments/Requests TRANSMITTAL DATE: October 29, 2014 TO: Gregg BeGell, P.E. County of Los Angeles, Department of Public Works/LACo Flood Control District 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 gbegell@dpw.lacounty.gov CC: Gloria Molina, LACo Supervisor Micheal Antonovich, LACo Supervisor Sierra Club, Angeles Chapter, Water Committee CCFAC Executive Director FROM: Dr. Tom Williams, Sierra Club, Angeles Chapter, Water Committee Citizens Coalition For A Community 4117 Barrett Road, Los Angeles, CA 90032-1712 ctwilliams20l2@yahoo.com, 323-528-9682 SUBJECT: County of Los Angles, Enhanced Watershed Management Plan Scoping for Programmatic EIR RE: COMMENTS for Enhanced Watershed Management Plan PEIR CS-CH#2014081106 Based on NOP and other project information downloaded from www.LACoH2Osheds.com. Thank you for the opportunities to comment on the Notice of Preparation/Initial Study (NOP/IS) and other Scoping documents related to the proposed LA County Enhanced Watershed Management Plan (EWMP). Also thank you for the extension of the deadline for such comments, I believe it was very helpful for our commenters. I could have continued for many more pages but I have been exhausted by the lack of real effort on the part of the preparers to make the Enhanced Watershed Program project meaningful, adequate, and complete and initially assess its secondary and tertiary impacts for knowledgeable public reviewers. Unfortunately the current NOP/IS and supporting documents appears to be an initial version of the vague program that has been developed by others, rather than a project or even program level DEIR preparation and is in need of major tecchnical additions, editing, technical, and other revisions. The Scoping documents are inadequate and incomplete for the purposes of Scoping, and Scoping documents must updated, revised, and reissued. 11 you need further clarifications and many more comments, I am available for discussions or correspondence with your staff. Dr. TW: Background: 40+ years with Worldwide/California water resources, management plans, water supplies, water distribution and transmission systems, and remote water resources development, with preparation, review, and commenting for 300+ EIRs/EISs/EAs (1972 to Date) and with 30+ years in Parsons and URS Corporations, 12+ years with Dubai Govt./Dubai World, and 6+years with Sierra Club Angeles Chapter (Water, Transportation, and Oil and Gas Comtes) and Citizens Coalition for a Safe Community. Thank you for the opportunity to review and comment. Our comments form two parts: general and specific comments, as shown below for the Section and the two segments. I have tried to provide citations in comment format with Doc./page/paragraph. Where appropriate, text has been inserted from documents and emphasis added usually as bolded/underlines. Comments/Requests are added in bolded/italics. Dr. Tom Williams 323-528-9682 Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests 1. GENERAL COMMENTS 1-1 Scoping and Project/Program Purposes and Needs The Program description for any DE/R or PDE/R must include the basis of the project: Purposes, Needs Goals, Objectives, Absence of clearly defined purposes and need, goals and objectives, and priorities renders both the Program and Projects virtually non -reviewable and thereby inadequate and incomplete for public review and comment. Without purposes and needs/goals and objectives, the public and reviewers cannot be expected to provide reasonable alternatives. NOP/IS p.1/par.2 The purpose of the MS4 Permit is to ensure Permittees are not causing or contributing to exceedances of water quality objectives or impairments of beneficial uses in the receiving waters of the Los Angeles region. 7/3 2.2 States are required not only to identify these "water quality limited segments" but also to prioritize such waters for the purpose of developing Total Maximum Daily Loads (TMDLs). 9/5 4. 1.1 Capture and Use BMPs collect and use stormwater where applicable for purposes such as irrigation. 1/3 The overarching goal of BMPs in the EWMP is to reduce the impact of stormwater and non- stormwater on receiving water 2/1 quality and address the water quality priorities as defined by the MS4 Permit. 2/1 The development of each EWMP will involve the evaluation and selection of multiple BMP types, including nonstructural (institutional) and distributed, centralized, and regional structural watershed control measures, that will be implemented to meet compliance goals and strategies under the 2012 MS4 Permit. 8/7 The overarching goal of BMPs in the EWMPs is to reduce the impact of stormwater and non- stormwater on receiving water quality and to address water conservation and the water quality priorities. 11/3 The MS4 permit allows Permittees to customize MCMs to address high-priority water quality goals within their watersheds. 13/2 The PEIR will examine the project's effects on global climate change and evaluate consistency of the project with the State's GHG emissions reduction goals. Scoping Meeting - Pic 4 Project Purpose: MS4 Permit Compliance (R4-2012-0175) — Each Permittee is responsible for its local MS4 compliance — Permit compliance through EWMPs 12 NOls submitted to LARWQCB Collectively prepared by participating Permittees — Los Angeles Regional Water Quality Control Board (LARWQCB) approves EWMPs 1-2 PEIR Contents 1-2 Total lack of reference to assignment of significance and related mitigation. NOP/IS lacks clear definition and presentation as to potential effects, scopes, and schedules of the program and related projects and their implementation, construction, and operations. As a water resources project, the physical changes represent a small portion of the overall potential effect of the program and projects, and the NOP does not reflect the systemic nature of water resources effects on the environment. The NOP and the PDE/R andd PjDE1Rs must clearly provide a Scope for each basin, schedules, and related environmental sectors, a Schedule for "implementation", construction, and "operations" (?=forever). The PEIR will - "result from implementation of the projects and management actions identified in each EWMP "result from the construction and operation of EWMP projects, "focus on potential effects. "assess the physical changes... including direct, indirect, and cumulative impacts. "identify mitigation measures to minimize potentially significant impacts of each EWMP. "anticipated to evaluate... following preliminary listing of environmental issues. Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests 1-3. Environmental Resources, Setting, and Effects - Employment, Costs, Revenues, and Socieconomics Employment, Costs, Revenues, and Socioeconomics Although mentions are made regarding economic and employment effects related to the Program and its projects, no costs -benefits, financials/funding sources, or other revenues assessments are included in the NOP. Similarly, socioeconomics for major infrastructure programs and projects are closely related to "Environmental Justice" of those receiving benefits and those experiencing adverse effects directly through water -related operations and indirectly through direct/indirect payments for such effects and prospective benefits for those with much largely parcels and incomes. 5/1 The primary approach to each of the EWMPs, as identified in the Draft Work Plans, includes identifying community -friendly, cost-effective methods of reducing urban runoff pollution and incorporating distributed and centralized structural and nonstructural watershed control measures for a multi -pollutant, multi -benefit approach. 8/3 The EWMPs include multi -benefit stormwater management projects that may also provide environmental, aesthetic, recreational, water supply, and/or other community enhancements cost- effective manner. 11/1 Most institutional BMPs are implemented to meet Minimum Control Measure (MCM) requirements in the MS4 permit; MCMs are considered a subset of institutional BMPs. MCMs do not involve construction of facilities that physically remove pollutants, but may involve costs associated with the procurement and installation of items such as signage or spill response kits. 12.3 Air Quality Construction and operation of EW MP projects could cause air emissions... vehicle trips associated with any increases in employment.... 14/3 Population... The PEIR will, however, identify current population and employment projections... 1-4 Controversies Regarding Program/Projects --- Stormwater Fees Since the LACo Board of Supervisors have experienced significant controversy regarding the imposition of parcel fees for stormwater revenue and funding and has further created controversies regarding reassignment of parcel -area fees to parcel only fees, a thorough review of the economic, employment, and environmental justice issues must be addressed and defined for the NOP/IS, As currently understood but avoided in Water agency and County presentations, an increase (e.g., x2+) in LA Co stormwater fees would be applied on a parcel basis (no matter the size of parcel) as being proposed under the 2014 Measure P initiative which has no relationship to stormwater runoff and effects, compared to the current Recreation and Parks 1990s initiative which are based on parcel area (sqft) fees. For stormwater generation, area is directly related stormwater generation (e.g., 5000sgft may generate less runoff than 50,OOOsgft lots). Therefore the NOP has not discussed the socioeconomic effects and related Environmental Justice issues related to the proposed program and the related controversy. A thorough assessment of all related revenue%osts issues must be presented in the PDEIR, including sources of revenues, revenue streams for life -of -project costs (especially for operations, maintenance, and replacements), basis for revenues (by parcel or by parcel -area), and Environmental Justice (which is not mentioned any where in the NOP/IS or presentation). 1-5 Mitigation Measures Inconsistency uses and lack of definitions for most if not all related terms. activities of "develop", identify", "proposed", or "evaluate". to reduce potential, reduce the level, reduce potential adverse effect, any significant effects, to avoid, are reduced or avoided, recommend Vague generalities are presented and are so inconsistently applied within the same or related paragraphs as to render the entire presentation as useless. The PDEIR must clearly present in matrices with links to discussions and appendices the project and program effects (quantifiedd/ranked), levels of significance for each sector/parameter, criteria levels for significances, proposed mitigations/compensations for significant effects, and a quantitative ranking of the effects levels following mitigation/compensation. Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests Lack of Mitigation 1-6 No measures are mentioned for many sectors but no basis could be established for such omissions, and comparable effects could be expected within these sectors similar to those that had need for measures mentioned. 12/2 Aesthetics No mitigation mentioned. 12/4 Biology... No mitigation mentioned. 13/2 Greenhouse Gases No mitigation mentioned. 13/6 Land Use... No mitigation mentioned. 14/4 Public Services... No mitigation mentioned. 15/1 The PEIR will evaluate potential energy consumption associated with implementation of structural and nonstructural BMPs. No mitigation mentioned for Energy 1-7 Mitigation, protection, and other measures and strategies are mentioned along with textual review of environmental sector but without any clear and concise statement of what they are, when they would be used, and how they could affect impacts, effects, and conditions. Mitigation measures in the Scoping NOP/IS are inconsistently mentioned as shown below. Mitigation or compensation is required by CEQA for significant impacts. Although mitigation is mentioned in the NOP/IS, mitigation and compensation are not mentioned in the Scoping Presentation slides; in reverse of "Alternatives", not mentioned in NOP/IS but present once in the Presentation. Various terms - without definitions and consistent uses. Protection measures mitigation strategies significant effects significant impacts potentially necessary significant impacts mitigate secondary effects of growth As lead agency for the program LACo must clearly state the sole responsibility for thorough and consistent implementation in all projects of CEQA compliance and consistency of impact mitigation and compensation (including Environmental Justice and Socioeconomics). The recirculated NOP/IS and PDEIR must provide a thorough presentation of: Definitions of all related terms, Process and quantified analyses for establishing the level of effects, mitigation, and remaining adverse effects and potential subjects of compensation, Consistency of mitigations amongst all watersheds, All current mitigation and compensation measures planned or anticipated by the Program and Project proponents, and Explanation of absence of mitigation or compensation. Examples 12/3 Air Quality ... The PEIR ... will develop mitigation measures if necessary to reduce potential impacts. 12/5 Cultural Resources Mitigation measures will be identified if necessary to reduce the level of impact where possible. 13/1 Geology... The PEIR will identify mitigation measures if necessary to reduce potential adverse effects to proposed facilities. 13/3 Hazards... Mitigation measures will be proposed if necessary to reduce any significant effects of the project ... enountered during construction would be handled in accordance with applicable regulations. 13/4 Hydrology... The PEIR will identify stormwater quality protection measures required during construction and operation of proposed facilities. The PEIR also will evaluate potential impacts to flood control capacity and develop mitigation strategies if necessary to avoid significant impacts. 13/5 The PEIR will evaluate potential effects of increased storm water recharge and will identify mitigation measures if necessary to ensure that potentially necessary significant impacts are reduced or avoided. 14/2 Noise... The PEIR will recommend mitigation strategies to ensure that proposed EWMP projects implemented by local agencies comply with local noise policies and ordinances. 14/3 Population... The PEIR will... identify local planning jurisdictions with the authority to approve growth and mitigate secondary effects of growth. Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests 14/5 Traffic... The PEIR will 14/6 Utilities... The PEIR will 1-8 Alternatives Although the project proponent has chosen to prepare an Environmental Impact Report, no mention is made regarding alternatives in the Initial Study/NOP. Only one reference to alternatives in all available related documents occurs in Slide 28, "Issues to be Analyzed" in the PEIR Scoping Presentation. As the preparer included one reference to Alternatives, complete exclusion of such from the IS/NOP represents an arbitrary and incomplete presentation of CEQA documents. Without a clear concise statement of purposes and needs (goals and objectives, etc.), reasonable alternatives cannot be developed through the public participation and have not been developed by the watershed stakeholders. LA Co must revise and recirculate the NOP. LACo must include a thorough description of Purposes and Needs for the project, quantification of such P&Ns, detailed quantified analyses as to how the Program achieves such P&Ns, basis for development of other alternative programs and projects within each alternative, and an assessment as to the best available alternative. Some prospective alternatives include: Single parcel fee assessment for 20 -plus year full Administration, O&M and replacements; Parcel -Area fee assessment for 20 -plus year full Administration, O&M and replacements; Hybrid Parcel-Area/Runoff fee assessment for 20 -plus year full Administration, O&M and replacements; Zero -Parcel Discharge Assessment and fee adjustment for 20 -plus year full Administration, O&M and replacements; Large -Parcel and Large Discharge Assessment and fee increments for 20 -plus year full Administration, O&M and replacements; Full capture and recharge of flows of >100cfs from all waterways; 1-9 Mitigation Monitoring and Report Plan The Draft Programmatic Environmental Impact Reports must include draft plans for the implementation, monitoring, and enforcements of the Mitigation Monitoring, and Reporting Plan for the Program. Also the PDE/R and draft Programmatic MMR Plan must provide the descriptions and process for funding, staffing, means, monitoring, enforcement, and reporting for the public for the monitoring of all Project - Level activities and compliance which must be subject to noticing/subscriptions, public reviews, and comment as part of the project-DEIR processes and not wait until the "Final E/R" is circulated for projects. 1-10 Scoping Report Because of the poor development of the NOP/IS and lack of coordination between the LACo efforts and those projected for the individual Project DE/Rs and dispersed responsibilities for compliance and responsibilities, following the October 29th deadline for these comments, we request that LACo recirculate the entire NOP/IS, and if not done issue a Scoping Report ass to the LACo responses to comments and the table of contents for the PDE/R in order to establish the level of incorporation provided for the Scoping comments herein. 1-11 As indicated elsewhere many terms have been used and will be used inconsistently in the NOP/IS and Scoping Presentation and has created confusion and such must be avoided in the PDE/R. The PDE/R must contain a single glossary and set of definitions for all terms for the PDE/R, and preparers and editors must assure full and specific compliance and consistency for all usage. Such a glossary may be included as an appendix with proper references throughout the PDE/R. 1-12 Program Compliance and Monitoring The LACo, Department of Public Works, Flood Control District is assumed to be in charge of the EWMP Program and has 12 groups responsible for specific areas and is related to the Los Angeles Regional Water Quality Control Board through the MS4 permit and sub -permits for water quality and flows within the Program regional and Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests area watersheds. No formal agreement has been presented as part of the NOP/1S and discussion seems to differ between the NOP/IS and the Scoping Presentation. As the LACFCD is scoping the PDEIR, reviewers must assume that only the LACo shall answer to the LARWQCB for compliance and monitoring for the next 20 years and that LACo shall have the powers, staffing, expertise, and funding to assure compliance of 12 different agencies/sub- permittees. The Program description of the PDEIR must clearly and concisely present the administrative and operational arrangement and oversight assurance mechanisms to achieve implementation of all aspects of the MS4 permit and sub -permits and any and all CEQA and MS4 permit terms, conditions, mitigations, and compensations which may be related the Program and its projects. All contractual, regulatory, and judicial records must be provided as appendices and referenced within the text. 1-13 During a 20+ year Program, Implementation and Enforcement of all elements for 12+ different plans represent a major quality control/assurance and management and must be provided with adequate enforcement capabilities and support. The LACo, Department of Public Works, Flood Control District is assumed to be in charge of the EWMP Program and has 12 groups responsible for implementation, completion, and enforcement activities related to but in addition to those of the Los Angeles Regional Water Quality Control Board through the MS4 permit and sub -permits for water quality and flows within the Program regional and area watersheds. No formal management and enforcement agreement has been presented as part of the NOP/IS and the Scoping Presentation. As the LACFCD is scoping the PDEIR, reviewers must assume that only the LACo shall answer to the LARWQCB for implementation and enforcements for the next 20 years and that LACo shall have the powers, staffing, expertise, and funding to assure implementation and enforcement with 12 different agencies/sub-permittees. Fundamentally, will LACFCD or LARWQCB assess penalties against the sub -permittees for lack of timely implementation, achievement, and penalties. The Program description of the PDEIR must clearly and concisely present the administrative and operational arrangement and quality-controls/assurance processes to achieve initiation and completion of all aspects of the MS4 permit and sub -permits and assignment of penalties, both financial and organizational for any and all CEQA and MS4 permits which may be related the Program and its projects. The LACFCD must also have the specific powers to assume direct authority over any projects under its responsibilities to the LARWQCB, and such must be documented within the PDEIR and PFEIR as appendices and referenced within the text Environmental Sectors 2-1 No mention is made of "wetlands" which are often not included under either riparian (trees and bushes with dry land beneath) or aquatic habitats (open and standing water). Although this is one of the few specific habitats with federal and special protections, it is not mentioned which indicates the lack of background on the preparers part or a specific avoidance of controversial issues. The current NOP/IS lack competence, adequacy, and completeness for the public and stakeholder to review and comment upon the scope and specificity requireed for the PDEIR and subsequent PjDE1Rs. Revise and recirculate the entire NOP/IS and related documents. The recirculation NOP/IS and the PDEIR must contain a general map of the Program and area maps for each of the projects with the following: all existing delineated riparian, wetlands, and aquatic habitats; related existing upstream and adjacent infiltration, recharge, and liquefaction areas; potential groundwater movement patterns for 1500ft upstream and downstream of wetlands and riparian habitats; and current surface water flows for 1500ft upstream and downstream of wetlands and riparian habitats. 12/4 Biological Resources Implementation of the EWMP projects could occur within existing sensitive habitats... result in changes to wildlife habitat, disruption of natural movement corridors, fragmentation or isolation of wildlife habitats, and disturbance of sensitive species during construction or operation. -could alter riparian and aquatic habitats. The PEIR will evaluate the Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests potential for such facilities to impact biological resources and will also discuss local ordinances and state and federal regulations governing biological resources. 2-2 Geology and Groundwater Slight mention is made of groundwater, infiltration, recharge, and related liquefaction although much of the stormwater reduction must depend upon groundwater storage of captured runoff. The General Plan has not specific policies regarding changing the entire groundwater regime by massive expansion of septic tank/leach field system in another LACo project (i.e., Hauled Water Initiative) and this Programs LID and related recharge systems. No information has been provided as to where recharge/infiltration areas are in relation to liquefaction zones and their drier extensions of alluvium and other permeable soils and bedrock. The recirculation NOP/IS and the PDE/R must contain a general map of the Program and area maps for each of the projects with the following: All geologically potential recharge/infiltration areas, existing recharging project, and proposed recharging areas and of all areas with more than 10 septic tanks per any 100 acres; Currently delineated liquefaction areas and geologically similar surface materials which are not now considered as liquefiable due to lack of high groundwater tables; Known groundwater levels and elevations of stream beds downslope of the groundwater tables; and Anticipated local and project recharging rates. 12/6 5. Geology, Soils, and Seismicity Southern Los Angeles County is a seismically active region. The proposed EWMP BMPs would require construction of structural BMPs that could be subject to potential seismic and geologic hazards, including 13/1 ground shaking, liquefaction, soil stability conditions, soil erosion rates, expansive soils, and landslides. Policies provided in the County's General Plan and applicable standard County requirements will be evaluated as to their effect of mitigating or avoiding any potentially significant effects.... 13/4 Hydrology and Water Quality Implementation of the proposed EWMP BMPs may change local drainage patterns at construction sites .... which could affect the hydrology, hydraulics, and/or water quality of streams, rivers, and other receiving waters ... The PEIR also will evaluate potential impacts to flood control capacity and develop mitigation strategies if necessary to avoid significant impacts. 13/5 Implementation of the proposed EWMP BMPs would likely result in increased infiltration and recharge in various locations throughout the EWMP watersheds. Such activities could affect local groundwater levels and water quality. The PEIR will evaluate potential effects of increased storm water recharge and will identify mitigation measures if necessary to ensure that potentially necessary significant impacts are reduced or avoided. 2-3 Hazards and Groundwater Recharge No mention is made regarding the influence of groundwater movements upon hazards and hazardous materials in the soil/alluvium/bedrock context. Groundwater plumes have cause major expansions of underground contamination from storage tanks and contaminated soil. Contaminated groundwater in the northeastern and western San Fernando Valley and elsewhere are known to be migrating based on the groundwater flows and basin pumping for water supplies. Current LACo policies do not reflect the responsibilities and liabilities of LACo approved watershed plans causing the changes of hazardous materials migration induced by groundwater flows fed by LACo and agency approved recharge/infiltration projects. No information has been provided as to where recharge/infiltration areas, groundwater flows, and known or expected contaminated groundwater and soils, and potential routes for plume migration through extensions of alluvium and other permeable soils and bedrock. The recirculation NOP/IS and the PDEIR must contain a general map of the Program and projects' area maps with the following: Known subsurface contaminated soils and groundwater and active remediation sites; Known pump/treaUuse or pump/treat/recharge projects; Current and expected recharge/infiltration areas; and Known/Expected groundwater migration pathways. 13/3 Hazards and Hazardous Materials Excavation during construction of proposed EWMP BMPs could uncover contaminated soils or hazardous substances that pose a substantial hazard Dr. Tom Williams 11/5/2014 Draft Enhanced Watershed Management Program - Scoping Comments/Requests to human health or the environment... The policies provided in the County's General Plan and any standard County requirements will be evaluated as to their effect of mitigating or avoiding any potentially significant effects. 2-4 Socioeconomics (including Total and Disposal incomes, Employment, Existing Infrastructure Costs, and Property and Other Revenues) No information has been provided as to any socioeconomic setting, effects, and mitigation for the program or the projects. The recirculation NOP/IS and the PDEIR must contain an overall socioeconomic review of the Program area and separate project area for each of the projects with the following: Educational, employment, age/gender, and other socioeconomic parameters to characterize the areas for the Program and its projects; Incomes, Current Taxes and Fees, and other Ability -To -Pay parameters to characterize the areas for the Program and its projects; Existing Special Assessment Districts and Other Urban Costs for Local Residents and Property Owners for the Program's and its projects' areas; and State and conditions of existing infrastructure and potential for major future projects in the same Program's and its projects' areas. 2-5 "Environmental Justice" No information has been provided as to any information regarding the setting, effects, and mitigation for the program or the projects related to issues of Environmental Justice. The recirculation NOP/IS and the PDEIR must contain an overall and specific projects' Environmental Justice review of the similar major infrastructure programs and projects as related to those receiving benefits and those experiencing adverse effects directly through water -related operations and indirectly through direct/indirect payments for such effects and prospective benefits for those with much largely parcels and incomes. 2-6 Mitigation Monitoring and Reporting Plan The Draft Programmatic and Draft Project Environmental Impact Reports must include tiered draft plans for the implementation, monitoring, and enforcements of the Mitigation Monitoring, and Reporting Plan which will be subject to public review and comment as part of the DEIR processes and not wait until the "Final EIR" is circulated. Dr. Tom Williams 11/5/2014 pQOF PIANti.�4Y (04;X STATE OF CALIFORNIAOF Governors Office of Planning and Research State Clearinghouse and Planning unit Ken Alex Edmund G. Broom Sr. Director Governor Vr Notice of Preparation t t August 29, 2014d} y S 1 0 9 `' t To: Reviewing Agencies Re: Enhanced Watershed Management Programs (EWMP) Program EIR SCH# 2014081106 Attached for your review and comment is the Notice of Preparation (NOP) for the Enhanced Watershed Management Programs (EWMP) Program EIR draft Environmental Impact Repoli (EIR). Responsible agencies must transmit their comments on the scope and content of the NOP, focusing on specific information related to their own statutory responsibility, within 30 days of receipt of the NOP from the Lead A enc . This is a courtesy notice provided by the State Clearinghouse with a reminder for you to comment in a timely marmer. We encourage other agencies to also respond to this notice and express their concerns early in the environmental review process. Please direct your comments to: Gregg BeGell Los Angeles County Flood Control District 900 South Fremont Avenue, 11th Floor Alhambra, CA 91803 with a copy to the State Clearinghouse in the Office of Planning and Research. Please refer to the SCH number noted above in all correspondence concerning this project. If you have any questions about the enviromnental document review process, please call the State Clearinghouse at (916) 445-0613. Sincerely, y Scot orgazi Director, State Clearinghouse Attachments cc: Lead Agency 1400 TENTH STREET P.O. BOR 3044 SACRAMENTO, C_ALIFORNLA 95512-3044 TEL (916) 445-0613 FAX (916) 323-3018 www opnca.gov Document Details Report State Clearinghouse Data Base SCH# 2014081106 Project Title Enhanced Watershed Management Programs (EWMP) Program EIR Lead Agency Los Angeles County Flood Control District Type NOP Notice of Preparation Description The development of the EWMP will involve the evaluation and selection of multiple watershed control measures or best management practices (BMP) types including non-structural and distributed, centralized and regional structural BMPs. These BMPs will be implemented to meet compliance goals and strategies under the 2014 MS4 Permit. Structural BMPs involve the construction of a physical control measure to alter the hydrology and/or water quality of incoming stormwater or non-stormwater. The three major functions for structural BMPs are infiltration, water quality treatment, and storage. These are three categories of structural BMPs, defined by the runoff area treated by the BMP and the required retention volume in accordance with the Permit. Lead Agency Contact Name Gregg BeGell Agency Los Angeles County Flood Control District Phone 626 300 3298 Fax email Address 900 South Fremont Avenue, 11th Floor City Alhambra State CA Zip 91803 Project Location County Los Angeles City Los Angeles, City of Region Cross Streets Throughout Los Angeles County Lat/Long Parcel No. Various Township Range Section Base Proximity to: Highways Various Airports LAX, Burbank Railways Various Waterways Various ' Schools Various Land Use Various land uses throughout the County Project Issues AestheticNisual; Agricultural Land; Air Quality; Archaeologic -Historic; Biological Resources; Drainage/Absorption; Flood Plain/Flooding; Geologic/Seismic; Minerals; Noise; Population/Housing Balance; Public Services; Recreation/Parks; Soil Erosion/Compaction/Grading; Toxic/Hazardous; Traffic/Circulation; Water Quality; Vegetation; Water Supply; Wetland/Riparian; Wildlife; Cumulative Effects; Other Issues Reviewing Resources Agency; Coachella Valley Mountains Conservancy; Department of Parks and Recreation; Agencies Department of Water Resources; Department of Fish and Wildlife, Headquarters; Department of Fish and Wildlife, Marine Region; Native American Heritage Commission; Santa Monica Bay Restoration; Caltrans, District 7; Air Resources Board; State Water Resources Control Board, Division of Water Quality; State Water Resources Control Board, Division of Water Rights; Regional Water Quality Control Board, Region 4; San Gabriel & Lower Los Angeles Rivers & Mountains Conservancy; Santa Monica Mountains Conservancy Date Received 08/29/2014 Start of Review 08/29/2014 End of Review 09/29/2014 T r�• C _ mo O C O m 0 N U c t o L L O U U C ° v v T U T C N Y ^ m N V LL= K N Lu >Cc m k (p c v oc 0 m> m m% m ca ° o y m y U m° U M C C U c 2 m c C eF anm Nm Mau m« v m'✓, m y� m>' 3p m 3 m p m o' 3 m15 anCOd y C3 '� r U U° U c N U m Uay Um d'Uti U(Y U f1 .�> U U OCA Q=m O0 0 a0 d0 0 M O m U Qm CJo t S c L71 0 O. a li fL N¢ m 2' C 6' m CL m CL ❑ O U > O C 0 �r❑ Oi m o com m mo m m o m m� a .c ❑Uz❑wUm❑U�®U ❑ M 0 � ❑U❑v�v� ❑ -! a N� Q N d' m k� � o c c c c m m U U O o y >. 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Ld o c c ry w w� LLm?� a u m m vouc2 �a o - m>iZ ®UU W UL Cl LU UUw UO U o.� Oaf 0 0 0 U ��w 006 ❑ O:Kz OU W ii❑ O �Z ❑ ® ❑ ❑ ❑ ❑ Cl ❑ OWIn❑ ❑ LL ❑ Appendix C CalEEMod Air Quality Data r ESA J CaIEEMod Version: CalEEMod.2013.2.2 Page 1 of 1 Date: 9/30/2014 10:39 AM 1.0 Project Characteristics 1.1 Land Usage 1.2 Other Project Characteristics Urbanization Urban Wind Speed (m/s) Climate Zone 9 Utility Company Los Angeles Department of Water & Power Centralized BMP South Coast Air Basin, Winter 2.2 CO2 Intensity 1227.89 CH4 Intensity 0.029 (Ib/MWhr) (Ib/MWhr) 1.3 User Entered Comments & Non -Default Data Project Characteristics - Land Use - 2ac, 2,000 sq. feet Construction Phase - correct days/ratios Off-road Equipment - Equipment for Biding Const Off-road Equipment - Egipment for Grading Off-road Equipment - Equipment for Site Prep Grading - ac. disturbed Construction Off-road Equipment Mitigation - Precipitation Freq (Days) 31 Operational Year 2015 N20 Intensity 0.006 (Ib/MWhr) 2.0 Emissions Summary 2.1 Overall Construction (Maximum Daily Emission) Unmitiqated Construction Exhaust PM10 ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio -CO2 NBio-CO2 Total CO2 CH4 N20 CO2e PIVI PM10 Total PM2.5 PM2.5 Total ear ay ay 12.3264 165.4322 ::117.0269 0.2835 18.9218 4.8885 23.8103 8.3619 1 HHJU . . . . 1 1 . 1 1 . 1 1 . 92 2 1 0 Total. 12.3264 165.4322 117.0269 0.2835 18.9218 4.8885 23.8103 8.3619 4.4971 12.8590 0.0000 28,945.22 1.3553 0.0000 28,973.691 92 128,945.2291 2 0 Mitigated Construction 2.2 Overall Operational Unmitigated Operational ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio -0O2 NBio-0O2 Total CO2 CH4 N20 CO2e PRed PM10 PM 10 Total PM2.5 PM2.5 Total Year f lbiday Inmay, 2015 :: 123264 165.4322 ::117.0269: 0.2835 11.7891 4.8885 16.6776 4.65864 4971 9 1957 0.00 5. 45. : 1.3553 uctionn .......................... Energy ::................ j 0.0000 :................ j 0.0000 !: .............. :............................................... 0.0000 i 0.0000 j i 0.0000 i 0.0000 ........ j i 0.0000 i 0.0000 ........ j j 0.0000 j 0.0000 i 0.0000 i 0.0000 'r, 0.0000 92 2 j................�j.............. 0.0000 j............... p.............. t............... 0.0000 0.0000 0.0000 0.0000 0 Total 12.3264 165.4322 117.0269 0.2835 11.7891 4.8885 16.6776 4.6586 4.4971 9.1557 0.0000 28,945.22 28,945.229 1.3553 0.0000 28,973.691 1 1 1 1 1 1 1 1 92 1 2 1 0 2.2 Overall Operational Unmitigated Operational ROG x CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 lo -CO2 NBo-0O2 TotalCO2e e PRed PM10 PM10 Total PM2.5 PM2.5 Total rcent 0.00 0.00 0.00 0.00 37.70 0.00 29.96 44.29 0.00 28.80 0.00 0.00 0.00 0.00 0.00 0.00 uctionn .......................... Energy ::................ j 0.0000 :................ j 0.0000 !: .............. :............................................... 0.0000 i 0.0000 j i 0.0000 i 0.0000 ........ j i 0.0000 i 0.0000 ........ j j 0.0000 j 0.0000 i 0.0000 i 0.0000 'r, 0.0000 ......................... Mobile jj................ 0.0000 j................�j.............. 0.0000 j............... p.............. t............... 0.0000 0.0000 0.0000 0.0000 2.2 Overall Operational Unmitigated Operational ROG N xFugitive Exhaust PM10 Fugitive TxhaustPM2.5io- io- ola e PM10 PM10 Total PM2.5 PM2.5 Total Category 111.3906 Ib/day Ib/day rea ij .......................... Energy ::................ j 0.0000 :................ j 0.0000 !: .............. :............................................... 0.0000 i 0.0000 j i 0.0000 i 0.0000 ........ j i 0.0000 i 0.0000 ........ j j 0.0000 j 0.0000 i 0.0000 i 0.0000 'r, 0.0000 ......................... Mobile jj................ 0.0000 j................�j.............. 0.0000 j............... p.............. t............... 0.0000 0.0000 0.0000 0.0000 j............... j.............5................ 0.0000 0.0000 0.0000 j................ j............... 0.0000 p.............. Q ............... j............... j............... Sj.............. 0.0000 0.0000 0.0000 e 0.0000 ["""""`"a7l1.39ulD Mitigated Operational 3.0 Construction Detail Construction Phase Phase ROG x CO S02 FugitiveExhaust Exhaust PM10 Fugitive Exhaust PM2.5 Bio- UU2 Nbo- U021 1 otal UU2 CH4 N20 CO2e Preparation ................i:.....................................................:............................................... Grading :Grading PM10 PM 10 Total PM2.5 PM2.5 Total I ±ategory 0. 0. .0 0. ay Dirtay 0 Area E1 11.3906 1 0.0000 !; 0.0000 0.0000 1 0.0000 0.0000 1 0.0000 0.0000 1 1 0.0000 1 0.0000 0.0000 'y, 0.0000 ............................................ Energy .. 0.0000 ............................ 0.0000 0.0000 ....................................... 0.0000 0.0000 ........................................... 0.0000 0.0000 .............................. 0.0000 ............. ............... 0.0000 0.0000 .......... 0.0000 ..................... 0.0000 0.0000 .......................... Mobile ::................ j 0.0000 :................ j 0.0000 li .............. 0.0000 . ....:... i 0.0000 j 0.0000 i 0.0000 i 0.0000 j 0.0000 i 0.0000 i 0.0000 ........ j j 0.0000 j 0.0000 i 0.0000 ........ i ii 0.0000 Total 11.3906 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 3.0 Construction Detail Construction Phase Phase ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio -0O2 NBio-0O2 TotalCO2 CH4 N20 CO2e Preparation ................i:.....................................................:............................................... Grading :Grading PM10 PM10 Total PM2.5 PM2.5 Total erten[ 0. 0. .0 0. 0 0.0 Reduction 3.0 Construction Detail Construction Phase Phase Phase Name Phase Type Start Date End Date Num Days Num Days Phase Description Number Week .Site Preparation:Site Preparation ................i:.....................................................:............................................... Grading :Grading ...................................................a...............j 14/23/2015 j5115/2015 5: .............i............................................... ... 17: ................ j..................................................... 3 :Building Construction j................................................ :Building Construction j.......................... j.......................... p................. :5/16/2015 :7/1/2015 5; j.................. j..................................................... 33; Acres of Grading (Site Preparation Phase): 10 Acres of Grading (Grading Phase): 10 Acres of Paving: 0 Residential Indoor: 0; Residential Outdoor: 0; Non -Residential Indoor: 0; Non -Residential Outdoor: 0 (Architectural Coating -sgft) OffRoad Equipment Tired Dozers Trips and VMT Phase Name Offroad Equipment Worker Trip Vendor Trip Hauling Trip Worker Trip Vendor Trip Hauling Trip Worker Vehicle Vendor Hauling Count Number Number Number Length Length Length Class ehicle Class ehicle Class ite Preparation 6; 15.00; 0.00; 0.00; 14.70; 6.90; 20.uu::LD_Mix :HDT_Mix :HHDT ..................................i radin ..............................6i .................. 15.00: ..................................................................:.......................:.............................................................................................. 0.00: 5,647.00: 14.70; 6.90; 20.00'LD_Mix !HDT_Mix ?HHDT ...................................'i............................... Building Construction i....................... '„ 8; i..................... 183.00: i.................... 71.00: o...................... 0.00: i....................... 14.70; i.................... 6.90; ii............................. 20.008LD_Mix i...................... ;HDT_Mix i..................... ;HHDT 3.1 Mitigation Measures Construction Water Exposed Area 3.2 Site Preparation - 2015 Unmitigated Construction On -Site ROG x CO S02 Fugitive Exhaust PMIO Fugitive Exhaust mI Exhaust lo- lo- ata Total CO2 CH4 N20 e IbIday PM10 PM10 Total PM2.5 PM2.5 I Total Total Category lb/day ay Ib/day ugihve ust Intuay au ing 71 0.0000 0.0000 0.0000 0.0000 0.0000 .......................... ii................i............... i.............. ii............... Off -Road 2.1028 20.9856 14.5647 a 0.0198 i............... i.............. ii............... 1.4545 1.4545 i............... i............... ti................ 1.3381 a 1.3381 i............... i............... ; 2,081.428:2,081.4286a i............... ii............... 0.6214 i............... i............... :2.094.477 0.0000 .....:. 0.0000 .. ..:i. .. ...:. 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 6 0.0000 0.0000 ......... 0.0000 Worker Total 2.1028 20.9856 14.5647 0.0198 0.6628 1.4545 2.1173 0.0716 1.3381 1.4097 0.1691 2,081.428 2,081.4286 0.6214 2,094.477 173.3466 • 9.9400e- • 173.5553 1 1 1 6 003 Unmitigated Construction Off -Site Mitigated Construction On -Site ROG ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive mI Exhaust PM2.5 Bio -CO2 NBio-CO2 Total CO2 CH4 N20 CO2e IbIday PM70 PM10 Total PM2.5 PM2.5 Total ategory ay Intuay au ing 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1: 0.0000 ..........................::................:. Vendor 0.0000 .....:. 0.0000 .. ..:i. .. ...:. 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 ......... 0.0000 0.0000 0.0000 ......... 0.0000 Worker 00709 '• 0.0951 0.9938 1.9900e- 0.1677 : 14800e 0.1691 0.0445 1.3509e- 0.0458 '• 1733466: 173.3466 • 9.9400e- • 173.5553 003 003 003 003 Total e- e- 5 e- e - 173.5553 003 003 003 003 Mitigated Construction On -Site ROG x CO S02 Fugitive PM70 I Exhaust PM10 Total Fugitive PM2.5 x aust PM2.5 Total io- UUZ I Nbio- UUZ I I otai CO2 CH4 N20e EIb/day Category IbIday Mitigated Construction Off -Site 3.3 Grading - 2015 Unmitiaated Construction On -Site x 0 ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive mI Exhaust PM2.5 Bio -CO2 NBio-CO2 Total CO2 CH4 N20 CO2e Total PM70 PM10 Total PM2.5 PM2.5 Total ategory Ib/day ugihve ust b1day 5 6.7333 0.0000 6.7333 lomay au ing _..... _ 57.3739 _ ...., ...., 36.7654 0.0365 _ _ .............. ..............._ p 3.1019 ` ............... 3.1019 _ _ ...., 2.8538 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 .......................... ::................ Vendor 0.0000 : ....... 0.0000 .. ..:',. 0.0000 .. ...:... i 0.0000 0.0000 0.0000 i 0.0000 0.0000 0.0000 ;; 0.0000 ......... 0.0000 0.0000 ;; 0.0000 ......... 0.0000 ............... :................ Worker 0.0709 0.0951 0.9938 . 19900e- '• 0.1677 .. 14800e- ................... 0.1691i0.0445 .............. 1.3500.. :................ 0.0458 ................ ;............... 173.3466 ............... 173.3466 ............... 9.9400e- ..5..5.5..3.. i ....................... 003 003 003 003 Total e• 0.1677 1.4800e. e• e- 003 003 003 003 3.3 Grading - 2015 Unmitiaated Construction On -Site x 0 ugdrve x aust Fugitive Exhaust Bio- io- ata e PM10 PM10 Total PM2.5 PM2.5 Total Category Ib/day Ib/day ugihve ust 5 6.7333 0.0000 6.7333 ...........................................__ Off Road 5.3907 _..... _ 57.3739 _ ...., ...., 36.7654 0.0365 _ _ .............. ..............._ p 3.1019 ` ............... 3.1019 _ _ ...., 2.8538 _ 2.8538 :., _ _ ............... , 3,836 970 . .... . . ...... .. .. .. ..:. _ , :3,836.9708:: 1.1455 :3,861.0263 8 Total 5.3907 57.3739 35.7654 0.0355 12.9685 3.1019 16.0704 5.7333 2.8538 9.5871 3,836.970 3,836.9708 1.1455 9,861.026 8 Unmitigated Construction Off -Site Mitigated Construction On -Site ROG ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio -CO2 NBio-CO2 Total CO2 CH4 N20 CO2e PM70 PM10 PM70 PM10 Total PM2.5 PM2.5 Total Category Ib/day ategory Ib/day ay ugi4ve ust5.B458 ay 5.8358 3.0300 0.0000 suing .0000 ... ii.�...............................r............ Off -Road 5.3907 i 57.3739 i 36.7654 s 0.0365 ii...............�...............r............. 3.1019: 3.1019 5, 2.8538 2.8538 1.1455 i ,3.861.026 0.0000 3,836.970:3,836.9708':..............................:3,861.026 8 Total 5.3907 57.3739 35.7654 0.0355 5.6356 3.1019 8.9377 3.0300 2.8538 5.8837 0.0000 3,636.970 3,836.9708 1.1455 3,861.026 16 8 4 -- ....... Vendor _ _...0. 0.0000 _ _..................... 0.0000 0 -..... 0.0000 0 0000 0 0000 ', 0.0000 - _--__0-0-0 0.0000 0 0000 0 0000 0.0000 0.0000 0.0000 - _;.--0.-00-00- 0 0000 .......................... ..............................................:. Worker :: 0.0709' 0.0951 0.9938, 1.9900e- 0.1677 1.4800e -i '�, 0.1691 .....:. 0.0445 ................. i 1.3500e- 2 0.0458 ................ :............... ' 173.3466E ................. 173.3466 :............... 2 9.9400e- . :............... :............... i E 173.5553 003 003 003 003 Total 83 3 8 Mitigated Construction On -Site ROG NOx CO S02 Fugitive Exhaust PMIO Fugitive mIx austBio- Exhaust coz NBio- UUZ I otal UU2 CH4 N20 CO2e CO2e PM70 PM10 Total PM2.5 PM2.5 Total PM2.5 Total Category Ib/day Ib/day ugi4ve ust5.B458 0.0000 5.8358 3.0300 0.0000 3.0300 .0000 ... ii.�...............................r............ Off -Road 5.3907 i 57.3739 i 36.7654 s 0.0365 ii...............�...............r............. 3.1019: 3.1019 5, 2.8538 2.8538 1.1455 i ,3.861.026 0.0000 3,836.970:3,836.9708':..............................:3,861.026 8 Total 5.3907 57.3739 35.7654 0.0355 5.6356 3.1019 8.9377 3.0300 2.8538 5.8837 0.0000 3,636.970 3,836.9708 1.1455 3,861.026 8 1 1 Mitigated Construction Off -Site ROG NOx CO SO2 Fugitive Exhaust PM70 Fugitive Exhaust PM2.5 Bio -0O2 NBio-0O2 TotalCO2 CH4 N20 CO2e PM10 PM10 Total PM2.5 PM2.5 Total 3.4 Building Construction - 2015 Unmitigated Construction On -Site Unmitigated Construction Off -Site ROG x CO S02 Fugitive Exhaust PMIO Fugitive x aust Bio-Totale PM10 PM10 Total PM2.5 PM2.5 Total Category lb/day Ib/day - oad 3.4820 25.4773 18.621 r. 0.0269 1.97 71 1. 1.: 9358::O.5358.45.1 7 8 Total 3.4820 25.4773 18.6212 0.0269 1.U712 1.97122,633.935 5. 7 8 j2,633.9358jU.5358 Unmitigated Construction Off -Site Total 1.6015 8. 187 21.2532 0.0397 2.4891 0.1401 2.6292 0.6688 0.1288 .797 io- 3,668.182 3,668.1823 0.1339 3,670. 94 PM10 PM10 Total PM2.5 PM2.5 Total 3 Mitigated Construction On -Site Mitigated Construction Off -Site ROG x CO S02 Fugitive x austPMIO PMI0 ugitive Exhaust io- io- ata e PM10 PM10 Total PM2.5 PM2.5 Total ategoryb1clay to.0000 1010ay Off -Road : 3.4820 : 25.4773 18.6212 'y 0.0269 : 1.9712 1.9712 au ing : 1.8869 1.8869 : 0.0000 ; 2,633.93512,633.9358:: 0.0000 0.5358 : :2,645.187 000 0.0000 .............................................•i...............i..............!;................i... Vendor 0.0.44......e 0.7370 7.1583 9.1286 0.0154 .................. 0.4436 0.1221 0.56......:... 0.5657 0.12...... r.............n 0.1263 0.1123 i 0.2386 ......... 11,553.35411,553.3543:'. •................:...............:1,553..20 0.0127 8 Total 3 ........Worker 0.8645 : • 1.1604..,..121246 :: ............... �, 0.0243 ...........:........................................................... i 2.0455 0.0180 2.0635 0.5425 ...............................................:...............J 0.0165 0.5590 2,633.935 2,633. 358 0.535 i :2,117.374 0 Total 8 Mitigated Construction Off -Site 4.0 Operational Detail - Mobile 4.1 Mitigation Measures Mobile ROG x CO 802 Fugitive Exhaust PMI0 FugitiveTxhaust lo- lo- ata e PM10 PM10 Total PM2.5 PM2.5 Total Category to.0000 Ib/day Ib/day au ing 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 000 0.0000 .............................................•i...............i..............!;................i... Vendor 0.0.44......e 0.7370 7.1583 9.1286 0.0154 .................. 0.4436 0.1221 0.56......:... 0.5657 0.12...... r.............n 0.1263 0.1123 i 0.2386 ......... 11,553.35411,553.3543:'. •................:...............:1,553..20 0.0127 ;1,553.620 3 ........Worker 0.8645 : • 1.1604..,..121246 :: ............... �, 0.0243 ...........:........................................................... i 2.0455 0.0180 2.0635 0.5425 ...............................................:...............J 0.0165 0.5590 :2,114.828:2,114.8280: 0.1213 i :2,117.374 0 Total .182 0.1339 3 13,663.18231 1 13,670.9949 4.0 Operational Detail - Mobile 4.1 Mitigation Measures Mobile 4.2 Trip Summary Information Average Daily Trip Rate Unmitigated Mitigated Land Use Weekday Saturday Sunday Annual VMT Annual Vivi T User Defined Industrial Total 0.00 0.00 0.00 4.3 Trip Type Information 5.0 Energy Detail 4.4 Fleet Mix Historical Energy Use: N 5.1 Mitigation Measures Energy ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio -CO2 NBio-CO2 Total CO2 CH4 N20 CO2e Zmoom tegory ay ay gate .......................... Unmitigated ::................ :............................... ............... :......... i 0.0000 i 0.0000 i 0.0000 i 0.0000 i 0.0000 i 0.0000 i 0.0000 0.0000 ................................ 0.0000 i 0.0000 ......... i 0.0000 i 0.0000 ii 0.0000 i i 0.0000 4.2 Trip Summary Information Average Daily Trip Rate Unmitigated Mitigated Land Use Weekday Saturday Sunday Annual VMT Annual Vivi T User Defined Industrial Total 0.00 0.00 0.00 4.3 Trip Type Information 5.0 Energy Detail 4.4 Fleet Mix Historical Energy Use: N 5.1 Mitigation Measures Energy 5.2 Energy by Land Use - NaturalGas Unmitigated ROG x CO S02 Fugitive PM10 Exhaust PM10 PM1D Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- UQz NBIo-Intel io-uzi rotale CH4 e ategory - ay Ib/day Ib/day ser a ine Industrial micay NaturalGas 0.0000 0.0000 0.0000 ;; 0.0000 0.0000 ;; 0.0000 0.0000 ;; 0.0000 0.0000 0.0000 ;; 0.0000 0.0000 0.0000 Mitigated 0.0000 0.0000 0.0000 0.0000 0.0000 .........................:. NaturalGas ................... :.............. .............................................. ii 00000 i 0.0000 i 0.0000 ', 0.0000 i 0.0000 'r. 0.0000 ......... i i 0.0000 i 0.0000 ......... i 0.0000 i 0.0000 'r. 0.0000 i 00000 i 0.0000 Unmitigated Industrial 5.2 Energy by Land Use - NaturalGas Unmitigated Mitigated NaturalGa s Use ROG N x CO S02 Fugitive PM70 I Exhaust PM 10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.bio- Total Bio -CO2 io-uzi rotale CH4 N2O CO2e Land Use kBTU/yr Ib/day Ib/day ser a ine Industrial 0.0000 0.0000 0.0000 0.0000 PM2.5 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 rimay Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Industrial Mitigated NaturalGa ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio -CO2 NBio-CO2 Total CO2 CH4 N2O CO2e s Use PM70 PM 10 Total PM2.5 PM2.5 Total an se yr ay rimay ser a ine 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Industrial 6.0 Area Detail 6.1 Mitigation Measures Area 6.2 Area by SubCategory Unmitigated ROG x CO S02 FugitiveExhaust PM10 PM 10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- io- UU21 I otal Guz CH4 N20 CO2e ategory I lbiday 0 1 waay Mitigated ;; 11.3906 0.0000 '„ 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 ;; 0.0000 .......................... Unmitigated ::................................ .............. :........................................ 0:...0 ..........:...0.00......:.... Ep 11.3906 p 0.0000 !; 0.0000 0.0000 p 0.0000 0.0000 ...:.................................... 0.0000 0.0000 ........ p ........ p 0.0000 p 0.0000 0.0000 'y, 0.0000 6.2 Area by SubCategory Unmitigated ROG x CO S02 Fugitive Exhaust PM10 Fugitive ExhaustPM2.5io- io- ota e PM10 PM10 Total PM2.5 PM2.5 Total SubCategory Ib/day Ib/day rc itectura2,7658 0.0000 0.0000 0.0000 0.0000 0.0000 Coating .........................i..................................'i..............i...............a.................. Consumer 8.6249 ...:.. ....c... 0.0000 .......... ...o... 0.0000 0.0000 0.0000 ........ ........ ......... ........ 0.0000 ;; 0.0000 Products ............................ Landscaping ...... i 0.0000 .. . ....:. ........ i 0.0000 !: 0.0000 i 0.0000 i i 0.0000 ........ i 0.0000 i i 0.0000 i 0.0000 ........ i ........ i 0.0000 i 0.0000 i 0.0000 0.0000 otaTl 11.3906 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated 7.0 Water Detail 7.1 Mitigation Measures Water 8.0 Waste Detail 8.1 Mitigation Measures Waste 9.0 Operational Offroad Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type 10.0 Vegetation ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio -0O2 NBio-0O2 Total CO2 CH4 N20 CO2e PM10 PM10 Total PM2.5 PM2.5 Total __._ u. ,.... aY ay rc itectura Coating -- ....... __ _ Consumer „ _ _ _...... 86249 _ _...... -- ...... _.... _ '„ 00000 _...... 0.0000 _ _......-- ....................................... 0.0000 00000 i�� .. ..... 0.0000 � . "� 00000 Products Landscaping i 0.0000 ................................ :. ....:............... i 0.0000 !i 0.0000 i 0.0000 i i 0.0000 i 0.0000 i i 0.0000 0.0000 i 0.0000 i 0.0000 i 0.0000 8 0.0000 Total 7.0 Water Detail 7.1 Mitigation Measures Water 8.0 Waste Detail 8.1 Mitigation Measures Waste 9.0 Operational Offroad Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type 10.0 Vegetation CaIEEMod Version: CalEEMod.2013.2.2 Page 1 of 1 Date: 10/10/2014 1:51 PM 1.0 Project Characteristics 1.1 Land Usage 1.2 Other Project Characteristics Urbanization Urban Wind Speed (m/s) Climate Zone 9 Utility Company Los Angeles Department of Water & Power Distributed BMP South Coast Air Basin, Winter 2.2 CO2 Intensity 1227.89 CH4 Intensity 0.029 (Ib/MWhr) (Ib/MWhr) 1.3 User Entered Comments & Non -Default Data Project Characteristics - Land Use - 2ac, 2,000 sq. feet Construction Phase - correct days/ratios Off-road Equipment - Equipment for Biding Const Off-road Equipment - Egipment for Grading Off-road Equipment - Equipment for Site Prep Grading - ac. disturbed Construction Off-road Equipment Mitigation - Trips and VMT - VMT trips reduced Precipitation Freq (Days) 31 Operational Year 2015 N20 Intensity 0.006 (Ib/MWhr) ........................................................................................................................................................................................................................................................ tblConstructionPhase Construction NumDays Daily Emission) 200.00 Construction 14.00 .................................................................1.............................................................. tblConstructionPhase NumDays ...............................................................4........................................................ 2.00 5.00 ........................... ......................................:.............................................................. tblGrading AcresOfGrading :...............................................................:......................................................... 1.00 2.00 ................................................................ tblGrading 5.............................................................. AcresOfGrading i............................................................... 0.00 o........................................................ 2.00 ........................... ......................................E.............................................................. tblGrading MaterialExported i............................................................... 0.00 P......................................................... 9,000.00 ....................... ......................................................................................................... tblLandUse LandUseSquareFeet :......................................................................................................................... 0.00 87,120.00 ....................... .......................................... tblLandUse r.............................................................. LotAcreage i............................................................... 0.00 e........................................................ 2.00 ............... ..................................................:..............................................................................................................................:. tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 ........................................................ 0.00 ---------- --IOff-oa -1 pm- --------------`---- tblOffRoadEquipment -a- -a-----n-it ----------'-- OffRodEquipmentUnitAmount -------------- --------------- -------------` 2.00 -------------- -------------- -------------- 1.00 .................................................................r.............................................................. tblOffRoadEquipment OffRoadEquipmentUnitAmount i............................................................... 1.00 ¢........................................................ 0.00 .................................................................:..............................................................................................................................:......................................................... tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00 .............................................................................................................................................................................................. tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 n ........................................................ 2.00 ............... .................................................. tblOffRoadEquipment .............................................................................................................................. OffRoadEquipmentUnitAmount 2.00 i......................................................... 1.00 ............... ................................................................................................................. tblOffRoadEquipment OffRoadEquipmentUnitAmount :......................................................................................................................... 3.00 1.00 ................................................................ tblOffRoadEquipment i.............................................................. UsageHours i............................................ ---------- 8.00 ..... i........................................................ 6.00 ................... tbl.......o..adE.......quip.............nt ................. OffRmes ....................... Us......age.....H.....our........................ i............................... 7....00......................................................... ....00.......................... 6".'0"0 ................................................................ tblOffRoadEquipment '...............................................................'......................................................................................................................... UsageHours 8.00 4.00 ............... .................................................. tblOffRoadEquipment t.............................................................. UsageHours i............................................................... 8.00 o........................................................ 4.00 .............................................................................................................................. tblOffRoadEquipment UsageHours c........................................................................................................................ 7.00 8.00 ---------- --I Off------ -1 pm- --------------`---- tblOffRoadEquipment -----------U -------------- ----------'-- UsageHours -------------- --------------- --------..... 7.00 `-------------- .6.0.-------- -------------- 6.00 .................................................................j.............................................................. tbIProlectCharacterist1cs Operationaffear j............................................................... 2014 q........................................................ 2015 ................... ............................................:...............................................................:...................... tblTripsAndVMT HaulingTripNumber ? .. .... .................. 1,125.00 ...:.... ................ .. ..... ... ................ 989.00 .................................................................:..............................................................:..............................................................n........................................................ tblTripsAndVMT VendorTripNumber 14.00 0.00 2.0 Emissions Summary 2.1 Overall Construction (Maximum Daily Emission) Unmitigated Construction Mitigated Construction ROG N x CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.6 Bio- uuz NbIO- UU21 I ofal Guz CH4 N20 CO2e iDiday PM10 PM10 Total PM2.5 PM2.5 Total INbIO- Year lbiday Inmay 2015 6.6754 96.4709 ;: 69.9358: 0.1942 8.1916 2.2393 10.4309: 2.9538 2.0599 5.0137 0.0000 :19,775.3219,775.322 i it 0.4893 0.0000 :19185.59 � � � 26 6 8 Total 6.67547 58 U.1942 8.1916 2.2393 1U.4309 2.9538 2.05995.0137j 4.0507 U.UUR 19,775. ,775. ,7 5.5 j j j j j j 26 j 6 8 Mitigated Construction 2.2 Overall Operational Unmitigated Operational ROG x CO S02 Fugitive Exhaust PM10 Fugitive ExhaustBio- bio- uuZ UU21 I otal UUZ CH4 N20 CO2e iDiday PM10 PM10 Total PM2.5 PM2.5 Total INbIO- Year Ib/day Ib/day 2015 6 6754.47 58 0.1942 6.1039 2.2393 8.3432 1.9908 05995 70 0000:19,775.32:19.775,322: r rr i it 0.4 ;;717775 .5 � � � 26 6 8 Total 6.6754 96.470958 0.1942 6.1039 2.2393 8.3432 1.9908 2.0599 4.0507 0.0000 19,775.32,775. 26 1 6 119,785.591 8 mi 2.2 Overall Operational Unmitigated Operational N x Fugitive PM10 Exhaust PM10 Total Fugitive PM2.5 PM2.5 Total bio- io eR lbiday Ef iDiday r rr r rr r rr r rr i rr r r r rr r rr iii r rr r rr i it i ri � � � 2.2 Overall Operational Unmitigated Operational N x Fugitive PM10 Exhaust PM10 Total Fugitive PM2.5 PM2.5 Total bio- io eR lbiday Ef iDiday Mitigated Operational 3.0 Construction Detail Construction Phase ROG x CO S02 Fugitive Exhaust PM10 Fugitive ExhaustPM2.5io- PM2.5 Bio -0O2 io- ota CH4 N20 e PM10 PM10 Total PM2.5 PM2.5 Total ategory 0.00 0.00 0.00 0.00 0.00 ay 0.00 0.00 0.00 0.00 0.00 0.00 0.00 ay 0.00 Area 1.8728 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 v 0.0000 .........................::................:. Energy :: 0.0000 .. : 0.0000 ': ....i....................... 0.0000: .... o-;. 0.0000 : .... : 0.0000 ..... �. ... .. : 0.0000 ...,. : .... : 0.0000 ... 0.0000 ........ : : 0.0000 : 0.0000 : 0.0000 : 0.0000 :' 0.0000 Mobile .. i 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 i 0.0000 0.0000 0.0000 i''. 0.0000 Total 1.8728 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 3.0 Construction Detail Construction Phase ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio -0O2 NBio-0O2 TotalCO2 CH4 N20 CO2e PM70 PM10 Total PM2.5 PM2.5 Total Percent 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Reduction 3.0 Construction Detail Construction Phase ........................................................................................................................................................................................................................ :Building Construction :Building Construction :3/13/2015 4/1/2015 5: 14: Acres of Grading (Site Preparation Phase): 2 Acres of Grading (Grading Phase): 2 Acres of Paving: 0 Residential Indoor: 0; Residential Outdoor: 0; Non -Residential Indoor: 0; Non -Residential Outdoor: 0 (Architectural Coating — sgft) OffRoad Equipment Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor I Vendor Trip I Hauling Trip Worker Vehicle Vendor Hauling Site Preparation :Excavators 1: 8.00: 162: 0.38 .............................................................. Site Preparation o.......................................................:.................................... :Graders i........................... 0; o........................... 8.00: o............................. 174: 0.41 .............................................................. Site Preparation ...................................................................................................................... :Other General Industrial 1: ........................... 8.00: �............................. 87: 0.3 .............................................................. i,F. n i t inm?.nt...................................... f....................................F........................... ;HHDT o...........................5............................. ..............................3: 3,..................00,.................00e.........989.00 .• Site Preparation :Scrapers 0: 8.00: 361: 0.4 ..............................................................4.......................................................1....................................1...........................4...........................P............................. Site Preparation ;Tractors/Loaders/Backhoes 1: 6.00: 97: 0.3 .............................................................. Grading ...................................................................................................................... :Graders 1: ........................... 4.00: �............................. 174: 0.41 Grading ._____________ °______ :Rubber Tired Dozers _______ : 1E 4.00: 255: 0.4 .............................................................. Grading :........................................................ :.................................... :Tractors/Loaders/Backhoes :........................... 1: :............................ 8.00: :............................... 97: 0.3 ..............................................................'........................................................'....................................'........................................................................................ Building Construction :Cranes 0: 6.00: 226: 0.2 .............................................................. Building Construction :.......................................... ............. E.................................... :Forklifts i.................-------"--......................... ii 600: i.............................. 89 0.2 .............................................................. Building Construction :........................................................ :................................................................:. :Generator Sets 1 ...........................:.............................. 8.00: 84: 0.7 Building Construction :Tractors/Loaders/Backhoes 2: 6.00: 97: 0.3 .............................................................. Building Construction :........................................................:....................................:...........................n...........................:.............................. :Welders 1: 8.00: 46E 0.4 Trips and VMT Phase Name Offroad Equipment Worker Trip Vendor Trip lHauling Tripi Worker Trip I Vendor Trip I Hauling Trip Worker Vehicle Vendor Hauling Count Number Number Number Length Length Length Class ehicle Class ehicle Class ite Preparation 3; 8.00: 0.00: 0.00: 14.70; 6.90; 20.00:1-D Mix iHDT_Mix ;HHDT .....ding .......................... ..............................3: 3,..................00,.................00e.........989.00 .• ..............14.70F...............6.90 ............20.00".............................;......................;..................... ,LD_Mix ;HDT_Mix :HHDT ..................................................................i.......................i.....................i....................a......................i.......................:....................ii.............................i......................i..................... Building Costructio, 5: 37.00: 0.00: 0.00: 14.70: 6.90: 20.00::LD_Mix :HDT_Mix :HHDT 3.1 Mitigation Measures Construction Water Exposed Area 3.2 Site Preparation - 2015 Unmitigated Construction On -Site ROG x CO ROG aust CO ugitive x aus[ Exhaust io- lo- ata PM2.5 Bio- uuz e I otal UUZ =ugitivex PM10 Total PM2.5 PM2.5 Total PM70 PM10 Total PM2.5 ategory Total ay Category Ih/day ay amp Fugitive Dust 0.4242 0.0000 s 0.4242 0.0458 0.0000 s 0.0458 : 0.0000 0.0000 s 0.0000 .......::............ ............ ...... ....j...............i..............i;................i............ Off -Road 1.0837 10.8309 7.3875 0.0102 : ...:. .. ... : 0.7300 i ....:... 0.7300 : ......... ...:. : ....::... 0.6716 ii 0.6716 ......... : : 1,066.803:1,066.80391 i................:...............i.............. 0.3185 : :1,073.4921 : 0.0000 : 0.0000 'r, 0.0000 ......... i : 0.0000 ..........................::.................. Worker ........ :......... ` 0.0378 : 0.0507 .....::...............�... : 0.5300 �'� 1.O600e- ...; : 0.0894 : 7.9000e- ��'� 0.0902 : 0.0237 ... : 7.2000e- ��'� 0.0244 9 :92.4515:92.4515 ...: ��'� 5.3000e-: Total 003 004 004 j Totale- e- e- e 1 1 e- Unmitigated Construction Off -Site Mitigated Construction On -Site ROG x CO S02 Fugitive Exhaust PM10 Fugitive x aust PM2.5 Bio- uuz NBio- UUZ I otal UUZ CH4 N20 CO2e PM70 PM10 Total PM2.5 PM2.5 Total Category Ih/day Ib/day au ing 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 .......................... Vendor ::................ :. .....:. i 0.0000 i 0.0000 .. ................................ : 0.0000 0.0000 : 0.0000 i 0.0000 'r, 0.0000 : 0.0000 i 0.0000 i 0.0000 ......... : 0.0000 : 0.0000 'r, 0.0000 ......... i : 0.0000 ..........................::.................. Worker ........ :......... ` 0.0378 : 0.0507 .....::...............�... : 0.5300 �'� 1.O600e- ...; : 0.0894 : 7.9000e- ��'� 0.0902 : 0.0237 ... : 7.2000e- ��'� 0.0244 ......... :92.4515:92.4515 ...: ��'� 5.3000e-: ......... :92.5628 003 004 004 003 Totale- e- e- e- 003 OOd 004 003 Mitigated Construction On -Site Mitigated Construction Off -Site ROG x CO S02 Fugitive Exhaust PMIO Fugitive Exhaust PM2.5 lo- lo- ata CH4 N20 CO2e e IbIday PM70 PM10 PM10 Total PM2.5 PM2.5 Total ategory Category lb/day ay Ib/day ugihve ust au ing 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 .......................... Off -Road ii................i............... i.............. ii............... 1.0837 10.8309 7.3875 a 0.0102 i............... i.............. ii............... 0.7300 :� 0.7300 i............... i............... ti................ 0.6716 a 0.6716 i............... 0.0000 i............... ; 1,066.803:1,066.8039:: i............... ii............... 0.3185 i............... i............... :1.073.4921 0.0000 0.0000 0.0000 ......... 0.0000 0.0000 0.0000 ......... 0.0000 Worker 00378 '• 0.0507 9 1.0600e- 0.0894 '. 79000e Total 1.0837 10.8309 7.3875 0.0102 0.1909 0.7300 0.9209 0.0206 0.6716 0.6922 0.0000 1,066.803 1,066.8039 0.3165 1,073.4927 003 004 004 1 9 003 Total Mitigated Construction Off -Site 3.3 Grading - 2015 Unmitigated Construction On -Site ROG ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive mI Exhaust PM2.5 Bio -CO2 NBio-CO2 Total CO2 CH4 N20 CO2e IbIday PM70 PM10 Total PM2.5 PM2.5 Total ategory ay loluay au ing 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1: 0.0000 ..........................::................:. Vendor 0.0000 .....:. 0.0000 .. ..:i. .. ...:. 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 ......... 0.0000 0.0000 0.0000 ......... 0.0000 Worker 00378 '• 0.0507 0.5300 1.0600e- 0.0894 '. 79000e 0.0902 0.0237 . 7.2000e- 0.0244 924515: 92.4515 5.3000e- • 92.5628 003 004 004 003 Total e- 0.0094 7.VUUUe. U.URU2 0.0237 7. e- e- 003 004 004 003 3.3 Grading - 2015 Unmitigated Construction On -Site ROG x CO S02 Fugitive PM70 I Exhaust PM10 Total Fugitive PM2.5 x aust PM2.5 Total io- UUZ INbio- UUZI I otai CO2 CH4 N20e EIb/day Category IbIday Unmitigated Construction Off -Site Mitigated Construction On -Site ROG x CO ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive mI Exhaust PM2.5 Bio -CO2 NBio-CO2 Total CO2 CH4 N20 CO2e PM10 Total PM2.5 PM2.5 Total PM70 PM10 Total PM2.5 PM2.5 Total Category Ib/day ategory Ib/day ugihve ust b1clay 1.7081 0.7879 0.0000 0.7879 ay Crff Road 15279 16.0596 10.4042 0.0107 au ing 08370 08370 00000 ,1,122986,1,122.9865 0.3353 ;1,13002727 r, 5.6351 1.1791 1.2222 2.4013 18,559.88 :18,559.884:: OA488 TAT" Total 1.5279 16.0596 10.4042 0.0107 1.7081 0.9098 2.5179 0.7879 0.8370 1.6248 0.0000 45 5 1,130.027 0 ............................................: Vendor 0.0000 ....... 0.0000 .. ..:',. 0.0000 .. ...:... i 0.0000 0.0000 0.0000 i 0.0000 0.0000 0.0000 ;; 0.0000 ......... 0.0000 0.0000 ;; 0.0000 ......... 0.0000 ..........................' Worker ........ 00378 0.0507 0.5300 . 10600e- 0.0894 79000e- .. ................... 0.0902i0.0237 ............... 7.2000.. :................ 0.0244 ................ :............... 92.4515 ............... 92.4515 . ........... 5.3000..- ....................... 92.5.62. 003 004 004 003 Total 52.33 18,65. 60 0 8 Mitigated Construction On -Site ROG x CO S02 Fugitive Exhaust PMID Fugitive x aus[ PM2.5 Bio- uuz NBlo- otal UUZ CH4 N20 CO2e PM10 PM10 Total PM2.5 PM2.5 Total Category Ib/day Ib/day ugihve ust 1.7081 0.0000s 1.7081 0.7879 0.0000 0.7879 Crff Road 15279 16.0596 10.4042 0.0107 p 09098 ` 0.9098 08370 08370 00000 ,1,122986,1,122.9865 0.3353 ;1,13002727 5 Total 1.5279 16.0596 10.4042 0.0107 1.7081 0.9098 2.5179 0.7879 0.8370 1.6248 0.0000 1,122.986 1,122.9865 0.3353 1,130.027 1 5 1 Mitigated Construction Off -Site 3.4 Building Construction - 2015 Unmitigated Construction On -Site ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio -CO2 NBio-CO2 Total CO2 CH4 N20 CO2e PM70 PM10 Total PM2.5 PM2.5 Total ategory Ib/day Ib/day - oadt::2.0613 13.7974 ay 1 ay suing 5. 24 59.0016 0.1824 4.3064 1.3287 5.6351 1.1791 1 2999 9401.1 0.145ti m mio,=3.009 45 5 0 -- ....... Vendor ___ _ _...0. 0 0000 0.0000 __..... 0.0000 - -..... 0.0000 0.0000 0.0000 ', 0.0000 - _000 0.0000 -- ...... 0.0000 _..................................... __0-0-0 0.0000 0.0000 0.0000 0.0000 - _;.--0.-00-00- 0 0000 .......................... ..............................................:............... Worker :: 0.0378 ' 0.0507 0.5300 , 1.0600e- 0.0894 i 7.9000e- i '�, 0.0902 ' 0.0237 :.................................:................................,...............:...............:............... p 7.2000e- 2 0.0244 92.4515 i 92.4515 �, 5.3000e- . i i 92.5628 003 004 2 004 mi 003 Total 60 0 8 3.4 Building Construction - 2015 Unmitigated Construction On -Site Unmitigated Construction Off -Site ROG NOx CO S02 Fugitive Exhaust PMIO Fugitive Exhaust PM2.5 Bio-cozio- NBio-0O2 ata CH4 N20 e PM70 PM10 Total PIV PM2.5 Total Category Ib/day Ib/day - oadt::2.0613 13.7974 4 1 r, 1. 1 24 1.44 MrO 2 Total 2.0613 13.79745 j 2 mi Unmitigated Construction Off -Site ROG NOx CO SO2 Fugitive Exhaust PM70 Fugitive Exhaust PM2.5 Bio -0O2 NBio-0O2 TotaICO2 CH4 N20 CO2e PM10 PM10 Total PM2.5 PM2.5 Total Category - ay CO - ay Fugitive Exhaust PIMIO Fugitive x aust mauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0rem"0.0000 u.uuuu U.0000 0.0000 0.0000 0.0000 .......................... Vendor ::................ : ....... .. ...... ...:... i 0.0000 i 0.0000 i 0.0000 0.0000 i 0.0000 i 0.0000 'r. 0.0000 i 0.0000 i 0.0000 i ......... ......... 0.0000 i 0.0000 i 0.0000 'r. 0.0000 i i 0.0000 .......... Worker °°................:............................ i................... :: 0.1748 0.2346 2.4514 4.9100e- : 0.4136 1 3.6400e-� �.� 172 i 0.4172��� ���0.1097 �� � 3.3400e- r ' �3.34OOe-�':...0.1130 .....................427.5882�i� 427 5882 �������.��2�����������������������-���28.1031 0.0245 i i 428.1031 PM2.5 003 003 003 Category Total e- 0.4136 3.640De- e - 0.1130 427.5032 427.5M 0.0245 423.111131 10.461 003 003 003 7 Mitigated Construction On -Site Mitigated Construction Off -Site ROG x CO S02 Fugitive Exhaust PIMIO Fugitive x aust PM2.5 Bio-0O2io- ota e PM10 PM10 Tolal PM2.5 PM2.5 Total Category lb/day Ib/day - oad 2.0613 13.7974 10.461 15 1. 7 7 1.0282 1.0282 OMOO :1.44.1 :1.44 01 . 024 .44 2 Total 2.0613 13.7974 10.4616 0.01501.U709 1.11709 1.0282 1.0282 0.0000 1,442.019 1,442.0192 U.3(124 1 1 2 j mi Mitigated Construction Off -Site 4.0 Operational Detail - Mobile 4.1 Mitigation Measures Mobile ROG x CO S02 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5Bio-0O2 Total 0.00 io- ota 0.00 0.00 e Category to/day Ib/day i4gate0.0000 0.0000 0.0000 0.0000 0 0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0,0000 0.0000 .......................... iE................ E. ....... ....: Unmitigated i 0.0000 i 0.0000 i 0.0000 r. 0.0000 i 0.0000 i 0.0000 r. 0.0000 i 0.0000 i 0.0000 r. 0.0000 ......... ......... i i 0.0000 i 0.0000 r. 0.0000 i i 0.0000 4.2 Trip Summary Information 4.3 Trip Type Information Average Daily Trip Rate Unmitigated Mitigated Land se VVeeKday Saturdav Sunday Annual vim I Annual User Defined Industrial 0.00 0.00 0.00 Total 0.00 0.00 0.00 4.3 Trip Type Information Miles Trip % Trip Purpose % LandUse H -W or C -W H -S or C -C H -D or C -NW H -W or C- H -S or C -C H -D or C -NW Primary Diverted Pass -by ser a Ioo nclustrial 5.0 Energy Detail 4.4 Fleet Mix Historical Energy Use: N 5.1 Mitigation Measures Energy 5.2 Energy by Land Use - NaturalGas Unmitigated ROG NOx CO SO2 Fugitive PM70 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e ategory =anse[BTU/yr ay ay ay User Defined Industrial ay 0.0000 p 0.0000 p 0.0000 ;i 0.0000 p 0.0000 0.0000 atura as0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0 noon 0 noon 0.0000 0.0113T'I '1 0.0000 0.0000 Mitigated p 0.0000 Tota .......................... NaturalGas ::................ :. .....:. .. .. ............... 00000 i 00000 i 0.0000 ,; 0.0000 i 0.0000 ;'�, 0.0000 ......... i i 0.0000 '�,, 0.0000 ......... 0.0000 i 0.0000 i''. 0.0000 i 00000 i 0.0000 Unmitigated 5.2 Energy by Land Use - NaturalGas Unmitigated Mitigated NaturalGa s Use ROG NOx CO S02 Fugitive PM70 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 IPM2.5io- Total io- ata e =anse[BTU/yr ay ay User Defined Industrial 0 0.0000 p 0.0000 p 0.0000 ;i 0.0000 p 0.0000 0.0000 p 0.0000 p 0.0000 ;i p 0.0000 p 0.0000 0.0000 p 0.0000 p 0.0000 Tota Mitigated 6.0 Area Detail 6.1 Mitigation Measures Area ROG S CO x PM10 Exhaust PM10 Fugitive PM10 Exhaust PM10 Total Fugitive PM2.5 Exhaust PM2.5 Total BIO- io- ota e Category e Land Use H Ib/day Ib/day ser a ne Industrial 0.0000 0.0000 0.0000 0,0000 0.0000 0.0000 ....... _ _.... Unmingaletl 1 8728 --.... 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 . 0.0000 0.0000 0.0000 0.0000 0 s0 0000 0 0000 0.0000 0.0000 Total 6.0 Area Detail 6.1 Mitigation Measures Area ROG N xFugitive CO SO2 PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 ExhaustPM2.5io- PM2.5 Total Bio -0O2 io- ora CH4 N2O e Category Ib/day Ib/day itigated 1.87 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0,0000 0.0000 0.0000 ....... _ _.... Unmingaletl 1 8728 --.... 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 . 0.0000 0.0000 0.0000 0.0000 6.2 Area by SubCategory Unmitiqated ROG NUa CO SO2 Fugitive PM10 Exhaust PM10 PM10 To[al Fugitive PM2.5 Exhaust PM2.5 PM25 Total Bio -0O2 NBio-0O2 Total CO2 CH4 N2O CO2e u Eategory ay ay, Mitigated ROG x CO S02 Fugitive Exhaust PM10 Fugitive ExhaustPIV12.5io- io- oto e PM10 PM10 Total PM2.5 PM2.5 Total 00 ±"uategory ay ay Architectural 0.1478 0.0000 0.0000 0.0000 0.0000 0.0000 v 0.0000 Coating . ....:.................i.............. i............... s..............;... ........ ........ ........ ......... ........ Consumer 1.7250 : : 0.0000 : 0.0000 : : 0.0000 0.0000 : Products -- ....... __ _.... _ _...... ......... -- ...... -- •.., _ _...... ......... -- ...... _ --_.. - Landscaping 0.0000 0.0000 ', 0.0000. 0.0000 0.0000 0.0000 0.0000 0.0000 i 0.0000 0.0000 0.0000 �, 0.0000 Total 1.8728 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.0 Water Detail 7.1 Mitigation Measures Water 8.0 Waste Detail 8.1 Mitigation Measures Waste 9.0 Operational Offroad Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type 10.0 Vegetation CaIEEMod Version: CalEEMod.2013.2.2 Page 1 of 1 Date: 9/30/2014 2:49 PM 1.0 Project Characteristics 1.1 Land Usage 1.2 Other Project Characteristics Urbanization Urban Wind Speed (m/s) Climate Zone 9 Utility Company Los Angeles Department of Water & Power Regional BMP South Coast Air Basin, Winter 2.2 CO2 Intensity 1227.89 CH4 Intensity 0.029 (Ib/MWhr) (Ib/MWhr) 1.3 User Entered Comments & Non -Default Data Project Characteristics - Land Use - 2ac, 2,000 sq. feet Construction Phase - correct days/ratios Off-road Equipment - Equipment for Biding Const Off-road Equipment - Egipment for Grading Off-road Equipment - Equipment for Site Prep Grading - ac. disturbed Construction Off-road Equipment Mitigation - Precipitation Freq (Days) 31 Operational Year 2015 N20 Intensity 0.006 (Ib/MWhr) 2.0 Emissions Summary 2.1 Overall Construction (Maximum Daily Emission) Unmitiqated Construction PM10 Fugitive ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5Bio-CO2 NBio-0O2 Total CO2 CH4 N20 CO2e PM10 PM10 Total PM2.5 PM2.5 Total ear ay ay 18.5176 256.2670 ::184.4165: 0.4654 30.7563 6.8767 37.6330 12.9892 6.3260 19.3151 0.0000 9547,469.49:47,469.499:51. Mitigated Construction 2.2 Overall Operational Unmitigated Operational ROG x CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5Bic-0O2 Bio- CO2 [o- ota e PM10 PM10 Total PM2.5 PM2.5 Total I INBo-CO2Total Year Ib/day 1:1&5176 Ib/day 5 0 256.2670 ::184.4165: .4 5 19.3724 6.8767 26.2491 7.3588 6 3M0 136848 7. 7.469 499;: 1.8018 Reduction s 7.57. 95 5 1 Total 18.5175 5. 7 5 0.4554 9. 7 6.87b7 26.2491 7.3588 7, 7, 7,5 7. j j j 95 5 1 2.2 Overall Operational Unmitigated Operational ROG x CO S02 Fugitive Exhaust PMIO Fugitive Exhaust PM2.5 Bio- CO2 e PM10 PM10 Total PM2.5 PM2.5 Total I INBo-CO2Total erten[ 0. 0. 0 7. 0. 5 5 5 0 Reduction 2.2 Overall Operational Unmitigated Operational Mitigated Operational 3.0 Construction Detail Construction Phase Phase ROG x CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5Bio-uuz Bio -CO2 Nbo-UU21 I otal UUZ CH4 N20 CO2e Preparation :3111201 b :4/412UIb b: 2b: ................:......................................................................................................i.........................i........ ;Grading ;Grading PM10 PM10 Total PM2.5 PM2.5 Tolal ±ategory 0. 0. 0. ay 0 0. loicay 0 0.0 Area: 45.5626 : 0.0000 0.0000 0.0000 : 0.0000 0.0000 : 0.0000 0.0000 : : 0.0000 : 0.0000 0.0000 0.0000 ............................. Energy .. ............... 0.0000 .............. 0.0000 .............. 0.0000 ........................................ 0.0000 0.0000 ........................................... 0.0000 0.0000 ............................... 0.0000 .......... 0,0000 ............... 0.0000 .......... 0.0000 ...................... 0.0000 0.0000 ......................... Mobile ::................ i 0.0000 :................ i 0.0000 li :. ....:. 0.0000 ....:... i 0.0000 i 0.0000 i 0.0000 i 0.0000 i 0.0000 i 0.0000 i 0.0000 ........ i i 0.0000 i 0.0000 i 0.0000 ........ i ii 0.0000 Tolal 45.5626 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 3.0 Construction Detail Construction Phase Phase ROG NOx CO 502 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio -CO2 NBio-CO2 Total CO2 CH4 N20 CO2e Preparation :3111201 b :4/412UIb b: 2b: ................:......................................................................................................i.........................i........ ;Grading ;Grading PM10 PM10 Total PM2.5 PM2.5 Total erc 0. 0. 0. 0 0. 0.00 0 0.0 0 Reduction 3.0 Construction Detail Construction Phase Phase Phase Name Phase Type Start Date End Date Num Days Num Days Phase Description Number Week .Site Preparation:Site Preparation :3111201 b :4/412UIb b: 2b: ................:......................................................................................................i.........................i........ ;Grading ;Grading ............ ...........................i ... ...c... ...5:0: ;4/5/2015 :5/1/2015 5: ............................................... ... 20; .................................................................................................................................................................................................................................................................. 3 :Building Construction :Building Construction :5/2/2015 8/1/2015 5 65 Acres of Grading (Site Preparation Phase): 40 Acres of Grading (Grading Phase): 40 Acres of Paving: 0 Residential Indoor: 0; Residential Outdoor: 0; Non -Residential Indoor: 0; Non -Residential Outdoor: 0 (Architectural Coating — sgft) OffRoad Equipment Trips and VMT Phase Name Offroad Equipment Worker Trip Vendor Trip Hauling Trip Worker Trip Vendor Trip Hauling Trip Worker Vehicle I Vendor Hauling Count Number Number Number Length Length Length Class ehicle Class ehicle Class ite reparation _ oc _ I .......... rading ........................::.............................8E " ......................................... 20.00: :.................... 0.00: :....................... 11�293.00E :............................................ 14.70: 6.90: : 20.00:::L .........................::HD.................::HH................ LD_Mix �HDT_Mix �HHDT Buildin Construction' 9 ..................................................... 12: 732.00: .................................................................:....................... 286.00: 0.00? 14.70; :.................................................. 6.90; 20.00p,LD_Mix :..................... !HDT_Mix ..................... ?HHDT 3.1 Mitigation Measures Construction Water Exposed Area 3.2 Site Preparation - 2015 Unmitigated Construction On -Site ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio -CO2 NBio-CO2 Total CO2 CH4 N20 CO2e PM70 PM10 Total PM2.5 PM2.5 Total ategory ay ay ugitive usl 13.7410 0.0000 13.7410 6.8037 0.0000 6.8037 0.0000 ...................................................._ _.... _ _ -- -.7.. - _...... -- ...... _ _ _842 - _ _ 745 Off -Road 64281 67.2729 48.3602 � 0.0537 ;��40026 ', 4.0026 36824 36824 ,5,641377,5,641.3776 1.6842 ;5,676745 6 Total 6 Unmitigated Construction Off -Site Mitigated Construction On -Site ROG NOx CO S02 Fugitive Exhaust PMIO Fugitive Exhaust PM2.5 Bio-0O2io- NBio-0O2 ata CH4 N20 e PM10 PM10 Total PM2.5 PM2.5 Total ±ategory - ay I 1010ay Hauling 0.0000 : 0.0000 0.0000 0.0000 0.0000 0.0000' 0.0000 0.0000 : 0.0000 0.0000 0.0000 0.0000' 0.0000 0.0000 .......................... Vendor i................ 0.0000 i............... i.............. p 0.0000 ii............... 0.0000 ;; 0.0000 i... 0.0000 p 0.0000 ;; 0.0000 0.0000 p 0.0000 0.0000 ......... 0.0000 0.0000 ;; 0.0000 ......... : 0.0000 ........ Worker .............:................;...0.3383.... '' 0.1417 i 0.1902 1.9876 i'� 3.9800e- 0.3353 i 95e- i 0.0889 2.7100... rr.................................. 0.0916 ' 346.6931 i 346.6931 i' ....1......� �, 0.0199 ....................... 47.1������ p 347.1106 003 . 003 . 003 . . Total 0.1417 0.1902 1.9876 3.9800e- 0.3353 2.9500e- 0.3383 0.0889 2.7100e- 0.0916 346.6931. 346.6931 0.0199 347.1106 003 003 003 Mitigated Construction On -Site ROG NOx CO SO2 Fugitive Exhaust PM70 Fugitive Exhaust PM2.5 Bio -0O2 NBio-0O2 TotaICO2 CH4 N20 CO2e PM10 PM10 Total PM2.5 PM2.5 Total Mitigated Construction Off -Site 3.3 Grading - 2015 Unmitigated Construction On -Site ROG x CO S02 Fugitive ExhaustPMIO Fugitive Exhaust PIM2.5 Bio- CO2 CO21 e PM10 PM10ML Total PM2.5 PM2.5 Total INBio- ±ategory lbiday I lomay Hauling p 0.0000 i 0.0000 i 0.0000 Y', 0.0000 i 0.0000 p 0.0000 ", 0.0000 0.0000 i 0.0000 Y', 0.0000 p 0.0000 i 0.0000 Y', 0.0000 p 0.0000 .......................... Vendor ................ 0.0000 :............... :. i 0.0000 .. ..::...............:... i 0.0000 i 0.0000 i 0.0000 i 0.0000 i 0.0000 i 0.0000 ....,. i 0.0000 i 0.000000 ......... i 0.0000 i 0.0000 ii 0.0000 ......... i i 0.0000 ........ Worker .............:. '' 0.1417 :: i 0X1902 1.9876 � 3.9800e -....0X3353 .................:...............:.............. - 0.3383 i 2�9500e- i 0.0889 ",................................... 2.7100e- �, 0.0916 346.6931 i 346.6931 :............... -, 0.0199 :............... :...47.11106 i i 347.1106 003 003 003 Total 0.1417 0.1902 1.9876 3.9800e- 0.3353 2.9500e- 0.3383 0.0889 2.7100e- 0.0916 346.6931 346.6931 0.0199 347.1106 003 003 003 3.3 Grading - 2015 Unmitigated Construction On -Site Total 6.7539 72.6 90 48.3483 0.0462 20.6981 3.8403 24.5384 10.2371 3.5331 13.7701 PIAL5 4,852.774 NBlo- UUZ I otal UUZ CH4 97 CO2e 1 PM10 Total 1 1 1 Total PM2.5 PM2.5 0 1 ategory ay Unmitigated Construction Off -Site Mitigated Construction On -Site ROG NOx ROG x CO S02 Fugitive Exhaust PMIO Fugitive Exhaust PIAL5 Bio- UUZ NBlo- UUZ I otal UUZ CH4 N20 CO2e PM70 PM10 Total PM2.5 PM10 PM10 Total PM2.5 PM2.5 Total ategory ay ategory ay ugihve ust 9.3142 0.0000 9.3142 4.6067 0.0000 ay 0.0000 0.0000 .......00 -Road.......::• 6.7539 :72.6190:48.3483 :: ...........:...............:...........................................................................................................:................................:...............i............... 0.0462 3.8403 3.8403 3.5331 3.5331 0.0000 4,852.774:4,852.7740: 1.4488 : :4,883.197 ay Hauling :: 11.6691 183.5212 134.7432 0.4166 9.8347 3.0344 s 12.8691 2.6928 2.7911 s 5.4839 42,385.5942,385.596:, 0.3398 :42,392.73 14,852.774 0 14,88MI 68 8 1 .......................... Vendor :. i 0.0000 ...... .....;.............. i 0.0000 0.0000 . .. ... i 0.0000 ... 0.0000 0.0000 ....... :� 0.0000 : 0.0000 0.0000 0.0000 ......... 0.0000 0.0000 0.0000 ......... 0.0000 Worker 0.0945 ............................... 0.1268 _ 1.3251 2.6600e- , 0.2236 : 1.9700e- � 0.2255 0.0593 1 8000e- ... 0.0611 .. 231.1287: , 231.1287 0.0133 :231 4071 003 003 003 Total 11.7636 183.6480 136.0682 0.4192 10.0562 3.0364 13.0946 2.7521 2.7929 5.5450 42,616.72 42,616.725 0.3530 42,624.13 1 1 1 1 1 1 1 1 55 1 5 2 Mitigated Construction On -Site ROG NOx CO SO2 Fugitive Exhaust PM70 Fugitive Exhaust PM2.5 Bio -CO2 NBio-CO2 Total CO2 CH4 N20 CO2e PM70 PM10 Total PM2.5 PM2.5 Total ategory ay ay ugihve ust 9.3142 0.0000 9.3142 4.6067 0.0000 4.6067 0.0000 0.0000 .......00 -Road.......::• 6.7539 :72.6190:48.3483 :: ...........:...............:...........................................................................................................:................................:...............i............... 0.0462 3.8403 3.8403 3.5331 3.5331 0.0000 4,852.774:4,852.7740: 1.4488 : :4,883.197 0 Total 6.7539 72.6190 ".3483 0.0462 9.3142 3.5403 13.1545 4.6967 3.5331 a.i3lia 0.0000 4,852.7740 1.4488 14,852.774 0 14,88MI Mitigated Construction Off -Site 3.4 Building Construction - 2015 Unmitigated Construction On -Site ROG x CO S02 Fugitive Exhaust PMIO Fugitive Exhaust PIM2.5Bio-0O2 io- io- ota CH4 N20 e lb/day PM10 PM10 Total PM2.5 PM2.5 Total Category Ib ay day Off -Road Ib/day i 41.0093 : 29.6913 'y, 0.0444 i 3.1411 'y, 3.1411 Ib/day i 3.0241 au ing :: 11.6691 183.5212 : 1 .41 47 i :4.343.847 .7 3 68 8 1 .......................... Vendor ii................ 0.0000 i............... i.............. 0.0000 ii............... 0.0000 :� 0.0000 i............... i.............. ii............... 0.0000 0.0000 :� 0.0000 i............... i............... 0.0000 ti................ 0.0000 0.0000 i............... i............... 0.0000 i............... ii............... 0.0000 a 0.0000 i............... i ......... ...... 0.0000 Worker 00945 ......................... 0.1268 _ 1.3251 2.6600e- . 02236 p 19700e �, 0.2255 00593 18000e- ..... 00611 2311267, 231.1287 0.0133 :2314071 003 003 1 003 Total 183.6489 5.5450 .7 .7 5 0.353U 42,6TM. 55 5 2 3.4 Building Construction - 2015 Unmitigated Construction On -Site Unmitiaated Construction Off -Site ROG ROG N x CO S02 Fugitive Exhaust PMIO Fugitive Exhaust PM2.5Bio-0O2 io- io- otal CO2 CH4 N20 CO2e lb/day PM10 PM10 Total PM2.5 PM2.5 Total ±ategory Ib ay day Off -Road i 5.4660 i 41.0093 : 29.6913 'y, 0.0444 i 3.1411 'y, 3.1411 i 3.0241 'y, 3.0241 i :4,326.923:4,326.9233' 0.7964 i :4.343.847 3 14,343.647 Total1 4,326.923 0.7964 3 14,326.92331 1 miiiiiij Unmitiaated Construction Off -Site ROG x Fugitive PM10 Exhaust PM10 Total ugiti PM 2.5 x aust PM2.5 .5 Total Bio- io- Total e lb/day Ef lb/day Mitigated Construction On -Site Mitigated Construction Off -Site ROG x CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio- UU2 Nbio- UUZ I otal UU2 CH4 N20 CO2e PM10 PM10 Total PM2.5 PM2.5 Total ategory ay ay Off -Road 5.4660 41.0093 29.6913 r. 0.0444 3.1411 r. 3.1411 au ing 3.0241 r. 3.0241 0.0000 '4,326.923 '4,326.9233'i 0.7964 :4.343.647 0.0000 0.0000 _._._,.,,, Vendor _ ..... 2.9688 28.8349 36.7715 0.0619 .............. _..... 1.7868 0.4919 2.2787 _ ...... 0.5088 _ ..... _ 0.4523 0.9611 :.......................... , :6,257.173:6,257.1737:: _ .... _...., 0.0510 _,:, _ :6,258.2440 3 Total 7 ..........................:: Worker :...4.6417 ...i.48.4982.!!................?............................. .................................:................................ 3.4581 0.0972 r 8.1820 0.0720 .; ............... 8.2540 i............... i............... 2.1699 i : 0.0660 ................:............... ', 2.2359 .923 4,326.9233 0.7964 : :8,4K4009606 Total 33.4766 5. 3 j [,343M705 mi Mitigated Construction Off -Site ROG x CO S02 Fugitive Exhaust PMID Fugitive Txhaust PM2.5 Bio- uuz NBlo- otal UUZ CH4 N20 CO2e PM10 PM10 Total PM2.5 PM2.5 Total Category f::0.0000 Ib/day Ib/day au ing )MOO 0.0000 0.0000 0.0000 0.0000 0.0000 MOM 0.0000 0.0000 0.0000 0.0000 0.0000 _._._,.,,, Vendor _ ..... 2.9688 28.8349 36.7715 0.0619 .............. _..... 1.7868 0.4919 2.2787 _ ...... 0.5088 _ ..... _ 0.4523 0.9611 :.......................... , :6,257.173:6,257.1737:: _ .... _...., 0.0510 _,:, _ :6,258.2440 7 ..........................:: Worker :...4.6417 ...i.48.4982.!!................?............................. .................................:................................ 3.4581 0.0972 r 8.1820 0.0720 .; ............... 8.2540 i............... i............... 2.1699 i : 0.0660 ................:............... ', 2.2359 : i............... :8,459.311:8,459.3118:: i...............: 0.4851 : :8,4K4009606 Total 33.4766 5. ]MM 55 5 1 1 7 4.0 Operational Detail - Mobile 4.1 Mitigation Measures Mobile 4.2 Trip Summary Information Average Daily Trip Rate Unmitigated Mitigated Land Use Weekday Saturday Sunday Annual VMT Annual Vivi T User Defined Industrial 0.00 0.00 0.00 Total 4.3 Trip Type Information ROG x GO S02 Fugitive PM70 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Blo- UO2 NBlo- UUZ I otal UQZ CH4 N20 CO2e 000mategory - or - ay DivertedPass-by User Defined Industrial 16.60 lb1cay 6.90 0.00 Mitigated : 0.0000 : 0.0000 : 0.0000 0.0000 : 0.0000 : 0.0000' 0.0000 : 0.0000 : 0.0000 ;; 0.0000 0.0000 : 0.0000' 0.0000 : 0.0000 ................. Unmitigated . ... _P. .. .. ............... ..............i.............. 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 'y .. 0.0000 0.0000 p 0.0000 'y, 0.0000 0.0000 0.0000 0.0000 0.0000 4.2 Trip Summary Information Average Daily Trip Rate Unmitigated Mitigated Land Use Weekday Saturday Sunday Annual VMT Annual Vivi T User Defined Industrial 0.00 0.00 0.00 Total 4.3 Trip Type Information 5.0 Energy Detail 4.4 Fleet Mix Miles Trip % Trip Purpose % an se H -VV or - - or - - or - - or - - or - - or - Primary DivertedPass-by User Defined Industrial 16.60 8A0 6.90 0.00 0.00 0.00 0 0 0 5.0 Energy Detail 4.4 Fleet Mix Historical Energy Use: N 5.1 Mitigation Measures Energy ROG x CO S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2.b Blo- QQZ NBIo- otal UO2 CIA4 N20 CO2e PM70 PM10 Total PM2.5 PM2.5 Total Category Ib/day Ib/day atu ra as 0.0000 0.0000 0.0000 0.0000 0.0000 0,0000 0.0000 0.0000 0.0000 0,0000 0.0000 0.0000 Mitigated -............................... - ---... - --------- - ------ --------- - ---_- NaturalGas 0.0000 0.0000 0.0000 0.0000 : 0 0000 0.0000 0.0000 0.0000 � 0.0000 0.0000 0.0000 0.0000 0.0000 Unmitigated 5.2 Energy by Land Use - NaturalGas Unmitigated Mitigated NaturalGa s Use ROG NOx CO 502 Fugitive PM70 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio -CO2 NBio-CO2 Total CO2 CH4 N2O CO2e an se yr ay ay, ser a metl Industrial 0 s Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Mitigated 6.0 Area Detail 6.1 Mitigation Measures Area ROG atura a s Use CO x Fugitive PM10 Exhaust PM10 Fugitive PM10 x ausf PM10 Total Fugitive PM2.5 Exhaust PM2.5 .5 Total Bio-0O2io- CH4 Ota CO2e ategory e Land Use yr ay ay Industrial 0 : 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 ..............:.............:. : : 0.0000 0 0.0000 0.0000 s 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.0 Area Detail 6.1 Mitigation Measures Area ROG x CO S02 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.b Total Bm-UUZio- olal UUZ CH4 N20 CO2e ategory ay lbtaay Mitigated :: 45.5626 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 a 0.0000 .......................................... :. ...... ....:. .. .._ Unmitigated :: 45.5626 p 0.0000 0.0000 : 0.0000 ..............:.............:. : : 0.0000 0 .....:..... : 0.0000 : 0.0000 0.0000 ............... : : 0.0000 : 0.0000 : 0.0000 0.0000 6.2 Area by SubCategory Unmitiqated Mitigated 7.0 Water Detail 7.1 Mitigation Measures Water 8.0 Waste Detail 8.1 Mitigation Measures Waste 9.0 Operational Offroad Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type 10.0 Vegetation ROG NOx CO SO2 Fugitive Exhaust PM10 Fugitive Exhaust PM2.5 Bio -CO2 NBio-0O2 Total CO2 CH4 N20 CO2e PM10 PM10 Total PM2.5 PM2.5 Total u ategory ay ay rc itectura Coating .........................n................i...............:i m Consuer .. :: 34.4995: ..............I...............P..............5.............1.........[...............5................1..............[...............P..............P...............1...............[...............51.......... 0 0 .0000 0.00 0.0000 0.0000 0.0000 0 0.0000 0.00000 Products .................: .......::. Landscaping ....:. 0.0000 . ....P... ...;. ....1. .. ....i... ........ : 0.0000 �'�� 0.0000: 0.0000 0.0000 : 0.0000 ........ : � 0.0000 0.0000 ........ : 0.0000 : 0.0000 : 0.0000 ........ : �'� 0.0000 ota 7.0 Water Detail 7.1 Mitigation Measures Water 8.0 Waste Detail 8.1 Mitigation Measures Waste 9.0 Operational Offroad Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type 10.0 Vegetation Appendix D Sensitive Natural Communities Descriptions r ESA J APPENDIX D Sensitive Natural Communities Descriptions California Walnut Woodland' Description: Similar to and intergrading with Interior Live Oak Woodland or Coast Live Oak Woodland, but with a more open tree canopy dominated by Juglans californica. The open tree canopy allows development of a grassy understory. In most sites, this understory is composed of introduced winter - active annuals that complete most of their growth cycle before the deciduous Juglans leafs out in spring. Site Factors: On relatively moist, fine -textured soils of valley slopes and bottoms, as well as encircling rocky outcrops. These drier, rocky sites often support Venturan or Riversidian Sage Scrub. Intergrades with Coast Live Oak Woodland or Coast Live Oak Forest on more mesic sites, especially in canyons. Characteristic Species: Juglans californica, Quercus agrifolia, Q. engelmannii, Rhus ovata, R. trilobata, [Bromus rubens],[ Marrubium vulgare] Distribution: South side of San Gabriel Mountains to the Santa Ana Mountains, mostly between 500 feet and 3,000 feet. Canyon Live Oak Ravine Forest* Description: Similar to Coast Live Oak Forest, but usually denser and not so tall. Dominated by Quercus chrysolepis, a broadleaved sclerophyll. Typically forms forests with little understory up to 20 m tall in canyons. Trees often with multiple trunks, probably from crown -sprouting after fires. Growing season from late spring into summer, similar to that of Lower Montane Coniferous Forests. Site Factors: Transitional between low elevation broadleaved forests and higher elevation coniferous forests. On rocky, often steep slopes with little soil development. Typically in canyons and on north - facing slopes at relatively low elevations and on south -facing slopes at higher elevations. At higher elevations with colder winters than Mixed Evergreen Forest, Blue Oak Woodland, Coast Live Oak Forest or Californian Mixed Chaparral. Often adjacent to Montane Chaparral on dry slopes or lower Montane Coniferous Forest on less rocky soils. May intergrade with any of the above vegetation types and is not always distinct from them. Characteristic Species: Calocedrus decurrens, Lithocarpus densis torus, Pinus coulteri (Southern Coast Ranges), Pseudotsuga menziesii, Quercus chrysolepis, Umbellularia californica t Descriptions taken from: Holland, R. F. 1986. Preliminary descriptions of the terrestrial natural communities of California. Unpublished report. State of California, The Resources Agency, Department of Fish and Game, Natural Heritage Division, Sacramento, California. Please note: Many species names have changed since the preparation of this document. Also, brackets denote species that are non-native. Distribution: Inner Northern Coast Ranges from Siskiyou County to Lake County, Southern Coast Ranges from Mount Diablo to Monterey County. West slope of the Sierra Nevada from Tehama County to Kern County at elevations of 1,000 to 4,000 feet in the north and 3,000 to 6,000 feet in the south. Replaced by the closely related Bigcone Spruce -Canyon Oak Forest in the Transverse and Peninsular Ranges of Southern California. Mainland Cherry Forest Stands of hollyleaf cherry (Prunus ilicifolia) on steep, dry, north -facing slopes with rocky, sandstone - derived soils. Plants most often seen as shrubs, but may reach tree size. Stands with large trees are exceptional (California Native Plant Society). Open Engelmann Oak Woodland* Description: An evergreen woodland quite reminiscent of Blue Oak Woodland but dominated by Quercus engelmannii with an understory of typical "grassland" species. Site Factors: Relatively moist sites on fine -textured soils of gentle slopes and valley bottoms. Intergrades with Venturan or Riversidean Sage Scrubs on drier, rockier sites, and with Dense Engelmann Oak Woodland on more mesic sites. Often surrounds grassland portreros, occupying the ecotone between the grassland (on fine -textured, deep soils) and surrounding shrub fields (on rockier, drier sites). Characteristic Species: Juglans californica, Quercus agrifolia, Q. engelmannii, Rhus ovata, R. trilobata Distribution: Mainly in the Santa Ana Mountains of San Diego and adjacent Riverside counties, usually below about 4,000 feet. Riversidean Alluvial Fan Sage Scrub* Description: This is the most xeric expression of Coastal Sage Scrub south of Point Conception. Typical stands are fairly open and dominated by Artemisia californica, Eriogonum fasciculatum, and [Bromus rubens], each attaining at least 20 percent cover. Site Factors: Typically on xeric sites such as steep slopes, severely drained soils, or clays that released stored soil moisture only slowly. Intergrades at slightly higher elevations with several Southern Californian chaparrals. Characteristic Species: Artemisia californica, Atriplex canescens, [Bromus rubens], Encelia farinosa, Ericameria pinefolia, Eriodictyon crassifolium, Eriogonum fasciculatum, Gutierrezia californica, Ericameria linearifolia, Isomeris arboreus, Lotus scoparius, Malacothamnus fasciculatus, Salvia apiana, S. mellifera, Yucca whipplei parishii Distribution: Along the coastal base of the Transverse and Peninsular ranges from central Los Angeles County to the Mexican frontier. Southern California Arroyo Chub/Santa Ana Sucker Stream Streams used by arroyo chub (Gila orcuttii) and/or Santa Ana sucker (Catostomus santaanae). 2 Southern California Coastal Lagoon Coastal lagoons in Southern California. Southern California Threespine Stickleback Stream Streams used by threespine stickleback (Gasterosteus aculeates), typically slow -flowing waterways along the coast with emergent vegetation. Southern Coast Live Oak Riparian Forest* Description: Open to locally dense evergreen sclerophyllous riparian woodlands dominated by Quercus agrifolia. This type appears to be richer in herbs and poorer in understory shrubs than other riparian communities. Similar to and questionably distinct from Central Coast Live Oak Riparian Forest. Site Factors: Bottomlands and outer floodplains along larger streams, on fine-grained, rich alluvium. Characteristic species: Acer macrophyllum, Artemisia douglasiana, Cardamine californica, Eucrypta chrysanthemifolia, Heteromeles arbutifolia, Keckiella cordifolia, Lonicera hispidula, Mara macrocarpus, Pholistoma auritum, Quercus agrifolia, Rhus trilobata, Rosa californica, Rubus ursinus, Sambucus Mexicana, Symphoricarpos mollis, Toxicodendron diversilobum, Umbellularia californica Distribution: Canyons and valleys of coastal Southern California, mostly south of Point Conception. Southern Coastal Bluff Scrub* Description: Similar to Northern Coastal Bluff Scrub (a low, often prostrate, scrub 5-50 cm high, forming continuous mats or more scattered. Dwarf shrubs, herbaceous perennials, and annuals are represented...), but plants less prostrate (up to 2 meters tall). Most plants woody and/or succulent. Most growth and flowering occur from late winter through spring. Site Factors: Similar to Northern Coastal Bluff Scrub (exposed to nearly constant winds with high salt content; soil usually rocky and poorly developed), but conditions less extreme as a result of less intense but still moisture -laden winds. Intergrades in less exposed settings with Venturan Coastal Sage Scrub, or on finer -grained soils with Valley and Foothill Grassland. Characteristic Species: Atriplex spp., Calystegia cyclostegia, C. macrostegia, Castilleja affinis, Chorizanthe orcuttiana, Coreopsis gigantea, C. maritima, Dudleya spp., Encelia californica, Erigeron glaucus, Eriophyllum staechadifolium, Mesembryanthemum sp., Haploppappus spp., Malacothrix saxatilis, Marah macrocarpus, [Carpobrotus aeguilateralus], [Mesembryanthemum crystallinum], Opuntia littoralis, Rhus integrifolia Distribution: At localized sites along the coast, south of Point Conception; Point Mugu, Point Dume, Point Vicente, Dana Point, Torrey Pines State Reserve, Point Loma, etc. Several sites on the off -shore islands. Southern Coastal Salt Marsh* Description: Similar to Northern Coastal Salt Marsh (highly productive, herbaceous and suffrutescent, salt -tolerant hydorphytes forming moderate to dense cover and up to 1 meter tall) but with a longer 3 growing season and greater abundance of suffrutescent species in the higher, drier sites. Southern "specialties" include Atriplex watsonii, Batis maritima, Lycium californicum, Monanthochloe littoralis, Sueda californica, and Salicornia subterminalis. Site Factors: Very similar to Northern Coastal Salt Marsh (usually found along sheltered inland margins of bays, lagoons, and estuaries; these hydric soils are subject to regular tidal inundation by saltwater for at least part of each year) but with warmer water and air temperatures. Frankenia, Sueda, and/or Salicornia subterminalis often occur along the upper, landward edges of the marshes; Salicornia bigelovii, S. virginica, and Batis maritima at middle elevations; and Spartina closest to open water. Characteristic Species: Amblyopappus pussilus, Atriplex watsonii, Batis maritima, Cressa truxillensis, Cuscuta salina, Distichlis spicata var. spicata, Frankenia grandifolia, Heliotropium curassavicum, Jaumea carnosa, Juncus acutus sphaerocarpus, Limonium californicum, [Carpobrotus aeguilateralis], [Mesembryanthemum crystalinum], [M. nodii locum], Monanthochloe littoralis, Salicornia bigelovii, Salicornia spp., Spartina foliosa, Suaeda californica Distribution: Bays, lagoons, and estuaries along the coast from about Point Conception to the Mexican border. Intergrades broadly with Northern Coastal Salt Marsh along the south central coast. Nowhere as extensive as the larger northern marshes, and now considerably reduced by land development activities. Good to fair examples occur at Goleta Slough and near Carpinteria, Santa Barbara County; Point Mugu, Ventura County; Upper Newport Bay, Orange County; and several small areas in San Diego County. Southern Cottonwood -Willow Riparian Forest* Description: Tall, open, broadleafed winter -deciduous riparian forests dominated by Populus fremontii, P. trichocarpa, and several tree willows. Similar to Central Coast Cottonwood -Sycamore Riparian Forest, although apparently with less Quercus agrifolia or Alnus rhombifolia (this merits further study). Understories usually are shrubby willows. Site Factors: Sub -irrigated and frequently overflowed lands along rivers and streams. The dominant species require moist, bare mineral soil for germination and establishment. This is provided after flood waters recede, leading to uniform -aged stands in this seral type. Characteristic species: Artemisia douglasiana, Baccaris viminea, Marah macrocarpus, Platanus racemosa, Populus fremontii, P. trichocarpa, Salix gooddingii, S. hindsiana, S. lasiandra, S. lasiolepis, Urtica holosericea Distribution: Along perennially wet stream reaches of the Transverse and Peninsular ranges, from Santa Barbara County south to Baja California Norte and east to the edge of the deserts. Southern Dune Scrub* Description: Similar to Central Dune Scrub (a dense coastal scrub community of scattered shrubs, subshrubs, and herbs, generally less than 1 meter tall and often developing considerable cover) but plants somewhat shorter and often succulent. 13 Site Factors: Similar to Central and Northern Dune Scrub (Central: restricted to the coast on t stabilized backdune slopes, ridges, and flats), but drier and somewhat warmer and probably with less onshore wind. Intergrades toward the coast with Southern Foredunes and away from the coast on rockier soils with Venturan Sage Scrub, or Coastal Succulent Scrub. Characteristic Species: Atriplex leucophylla, Croton californicus, Ephedra californica, Ericameria ericoides, Haplopappus venetus vernonioides, Lupinus chamissonia, Lycium brevipes, [Mesembryanthemum crystallinum], Opuntia littoralis, Rhus integrifolia, Simmondsia chinensis Distribution: Same general areas as Southern Foredunes (areas of sand accumulation along the coast between Point Conception and the Mexican border), but usually a little farther back from the coast. With the notable exception of the El Segundo Dunes, this community has been virtually eliminated from mainland Southern California. Other small examples persist in Baja California and the Channel Islands. Southern Mixed Riparian Forest Streamside forest with mixed species composition. Southern Riparian Forest Streamside forest with mixed species composition. Southern Sycamore -Alder Riparian Woodland* Description: A tall, open, broadleafed, winter -deciduous streamside woodland dominated by Platanus racemosa (and often also Alnus rhombifolia). These stands seldom form closed canopy forests, and even may appear as trees scattered in a shrubby thicket of sclerophyllous and deciduous species. Lianas include Rubus ursinus and Toxicodendron diversilobum. Distinctions between this type and Sycamore Alluvial Woodland merit additional study. Site Factors: Very rocky streambeds subject to seasonally high-intensity flooding. Abuts increases in abundance on more perennial streams, while Platanus favors more intermittent hydrographs. Characteristic Species: Acer macrophyllum, Alnus rhombifolia, Artemisia douglasiana, Aralia californica, Equisetum hyemale, Oryzopsis miliacea, Quercus agrifolia, Rubus ursinus, Sambucus Mexicana, Toxicodendron diversilobum, Umbellularia californica, Urtica holsoericea Distribution: Transverse and Peninsular Ranges from Point Conception south into Baja California Norte Southern Willow Scrub* Description: Dense, broadleafed, winter -deciduous riparian thickets dominated by several Salix species, with scattered emergent Populus fremontii and Platanus racemosa. Most stands are too dense to allow much understory development. Site Factors: Loose, sandy, or fine gravelly alluvium deposited near stream channels during flood flows. This early seral type requires repeated flooding to prevent succession to Southern Cottonwood -Sycamore Riparian Forest. 5 Characteristic Species: Pluchea sericea, Populus fremontii, Salix gooddingii, S. hindsiana, S. laevigata arauipa, S. lasiandra, S. lasiolepis, S. leucodendroides, others? Distribution: Formerly extensive along the major rivers of coastal Southern California, but now much reduced by urban expansion, flood control, and channel "improvements." Valley Oak Woodland* Description: Similar to Northern Oak Woodland and Blue Oak Woodland, but typically more open, forming a grassy-understoried savanna rather than a closed woodland. Quercus lobata is usually the only tree present. This winter -deciduous species is California's largest broad-leaved tree, with mature individuals reaching 15-35 meters. Most stands consist of open -canopy growth form trees and seldom exceed 30-40 percent absolute cover. Site Factors: On deep, well -drained alluvial soils, usually in valley bottoms, apparently with more moisture in summer than in Blue Oak Woodland. Intergrades with Valley Oak Riparian Forest near rivers and with Blue Oak Woodland on drier slopes. Also found on non -alluvial settings in the South Coast and Transverse Ranges. Fire may have prevented some valley oak stands from succeeding to Ponderosa Pine or Coulter Pine forests before fire suppression. Characteristic Species: Quercus lobata, Elymus triticoides, Toxicodendron diversilobum, Q. douglasii Distribution: Sacramento and San Joaquin valleys adjacent to the Sierra Nevada foothills, valleys of the Coast Ranges from Lake County to western Los Angeles County. Usually below 2000 feet (6 10 meters). Walnut Forest Riparian corridors dominated by California walnut (Juglans californica). Other species present may include foothill ash (Fraxinus dipetala), coast live oak (Quercus agrifolia), Mexican elderberry (Sambucus Mexicana), and California bay (Umbellularia californica). 0 Appendix E CNDDB Species List r ESA J Selected Elements by Element Code California Department of Fish and Wildlife .s California Natural Diversity Database 0 Query Criteria: Taxonomic Group is (Fish or Amphibians or Reptiles or Birds or Mammals or Mollusks or Arachnids or Crustaceans or Insects or Ferns or Gymnosperms or Monocots or Dicots or Lichens or Bryophytes) and County is (Los Angeles) Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 1 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 514/2015 Rare Plant RanklCDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP AAAAD02110 Batrachoseps gabrieli None None G2 S2 San Gabriel slender salamander AAAAD04011 Ensatina eschscholizii croceator None None G5T3 S3 SSC yellow -blotched salamander AAAAD04013 Ensatina klauberi None None G2G3 S2S3 SSC large -blotched salamander AAAAF02032 Taricha torosa None None G4 S4 SSC Coast Range newt AAABB01230 Anaxyrus califomicus Endangered None G2G3 S2S3 SSC arroyo toad AAABF02020 Spea hammondii None None G3 S3 SSC western spadefoot AAABH01022 Rana draytonii Threatened None G2G3 S2S3 SSC California red -legged frog AAABH01330 Rana muscosa Endangered Endangered G1 S1 SSC southern mountain yellow -legged frog ABNDC04030 Oceanodroma homochroa None None G2 S2 SSC ashy storm -petrel ABNGE02020 P/egadis chihi None None G5 S3S4 WL white-faced ibis ABNKA03010 Gymnogyps californianus Endangered Endangered G1 S1 California condor ABNKC06010 Elanus leucurus None None G5 S3 FP white-tailed kite ABNKC10010 Haliaeetus leucocephalus Delisted Endangered G5 S2 FP bald eagle ABNKC12040 Accipiter cooperii None None G5 S3 WL Cooper's hawk ABNKC19070 Buteo swainsoni None Threatened G5 S3 Swainson's hawk ABNKC19120 Buteo regalis None None G4 S3S4 WL ferruginous hawk ABNKC22010 Aquila chrysaetos None None G5 S3 FP golden eagle ABNKD06030 Falco columbarius None None G5 S3S4 WL merlin ABNKD06071 Falco peregrinus anatum Delisted Delisted G4T4 S3S4 FP American peregrine falcon Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 1 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 514/2015 Selected Elements by Element Code r� California Department of Fish and Wildlife California Natural Diversity Database Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 2 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Rare Plant Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP ABNKD06090 Falco mexicanus None None G5 S4 WL prairie falcon ABNME03041 Laterallus Jamaicensis coturniculus None Threatened G4T1 S1 FP California black rail ABNNB03031 Charadrius alexandrinus nivosus Threatened None G3T3 S2 SSC western snowy plover ABNNB03100 Charadrius montanus None None G3 S27 SSC mountain plover ABNNMO8103 Sternula antillarum browni Endangered Endangered G4T2T3Q S283 FP California least tern ABNNN07012 Synthlfboramphus scrippsi Candidate Threatened G3 S2 Scripps's murrelet ABNRB02022 Coccyzus americanus occidentalis Proposed Endangered G5T3Q S1 western yellow -billed cuckoo Threatened ABNSB10010 Athens cunicularia None None G4 S3 SSC burrowing owl ABNSB13040 Asio flammeus None None G5 S3 SSC short -eared owl ABNUA01010 Cypseloides niger None None G4 S2 SSC black swift ABPAE33043 Empidonax traillli extimus Endangered Endangered G5T1T2 S1 southwestern willow flycatcher ABPAT02011 Eremophila alpestris actia None None G5T3Q S3 WL California horned lark ABPAU08010 Riparfa riparia None Threatened G5 82S3 bank swallow ABPBG02095 Campylorhynchus brunneicapillus sandiegensis None None G5T3Q 83 SSC coastal cactus wren ABPBJ08081 Polioptila californica califomica Threatened None G3T2 S2 SSC coastal California gnatcatcher ABPBK06100 Toxostoma/econtei None None G4 S3 SSC Le Conte's thrasher ABPBRO1030 Lanius ludovicianus None None G4 S4 SSC loggerhead shrike ABPBRO1036 Lanius ludovicianus mearnsi Endangered None G4T1Q S1 SSC San Clemente loggerhead shrike ABPBWO1114 Vireo bellii pusillus Endangered Endangered G5T2 S2 least Bell's vireo ABPBX03010 Setophaga petechia None None G5 S3S4 SSC yellow warbler ABPBX24010 /cteria virens None None G5 S3 SSC yellow -breasted chat Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 2 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Selected Elements by Element Code _ "av r� California Department of Fish and Wildlife California Natural Diversity Database Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 3 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Rare Plant Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP ABPBX91091 Aimophila ruficeps canescens None None G5T3 S2S3 WL southern California rufous -crowned sparrow ABPBX97021 Artemisiospiza belli belli None None G5T2T4 S2? WL Bell's sage sparrow ABPBX97024 Artemisiospiza belli clementeae Threatened None G5T1Q Si SSC San Clemente sage sparrow ABPBX99015 Passercu/us sandwichensis beldingi None Endangered G5T3 S3 Belding's savannah sparrow ABPBXA0020 Ammodramus savannarum None None G5 S2 SSC grasshopper sparrow ABPBXA301C Melospiza melodia graminea None None G5T1 Si SSC Channel Island song sparrow ABPBXB0020 Agelaius Vico/or None None G2G3 S1S2 SSC tricolored blackbird AFCHA0209J Oncorhynchus mykiss irideus Endangered None G5T1Q Si SSC southern steelhead - southern California DPS AFCJB1303H Siphateles bicolor mohavensis Endangered Endangered G4T1 Si FP Mohave tui chub AFCJB13120 Gila orcutdi None None G2 S2 SSC arroyo chub AFCJB3705K Rhinichthys oscu/us sap.3 None None G5T1 Si SSC Santa Ana speckled dace AFCJCO2190 Catostomus santaanae Threatened None Gt Si SSC Santa Ana sucker AFCPA03011 Gasterosteus aculeatus williamsoni Endangered Endangered G5T1 Si FP unarmored threespine stickleback AFCQN04010 Eucyclogobius newberryi Endangered None G3 S2S3 SSC tidewater goby AMABA01101 Sorex oroatus willetti None None G5T1 Si SSC Santa Catalina shrew AMABA01104 Sorex ornatus salicornicus None None G5T1? S1 SSC southern California saltmarsh shrew AMACB01010 Macrotus californicus None None G4 S3 SSC California leaf -nosed bat AMACC01020 Myotfs yumanensis None None G5 S4? Yuma myotis AMACC01070 Myotis evotis None None G5 S4? long-eared myotis AMACC01090 Myotis thysanodes None None G4 S4 fringed myotis AMACC01110 Myotis volans None None G5 S4? long-legged myotis Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 3 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Selected Elements by Element Code _ "av yp California Department of Fish and Wildlife California Natural Diversity Database Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 4 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Rare Plant Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP AMACCO1140 Myotis ciliolabrum None None G5 S2S3 western small -footed myotis AMACCO2010 Lasionycteris noctivagans None None G5 S3S4 silver -haired bat AMACC05030 Lasiurus cinereus None None G5 S4? hoary bat AMACC05060 Lasiurus blossevillii None None G5 S3? SSC western red bat AMACC05070 Lasiurus xanthinus None None G5 S3 SSC western yellow bat AMACC07010 Euderma maculatum None None G4 S3 SSC spotted bat AMACC08010 Corynorhinus townsendii None Candidate G3G4 S2S3 SSC Townsend's big -eared bat Threatened AMACC10010 Antrozous pallidus None None G5 S3 SSC pallid bat AMACD02011 Eumops perotis californicus None None G5T4 S4 SSC western mastiff bat AMACD04010 Nyctinomops femorosaccus None None G4 S3 SSC pocketed free -tailed bat AMACD04020 Nyctinomops macrotis None None G5 S2 SSC big free -tailed bat AMAEB03051 Lepus californicus bennettll None None G5T3T4 S384 SSC San Diego black -tailed jackrabbit AMAFB02172 Neotamias speciosus speciosus None None G4T2T3 S2S3 lodgepole chipmunk AMAFBO4040 Ammospermophilus nelsoni None Threatened G2 S2 Nelson's antelope squirrel AMAFBO5150 Xerospermophilus mohavensis None Threatened G2G3 S2S3 Mohave ground squirrel AMAFDO1041 Perognathus longimembris brevinasus None None G5T1T2 S1S2 SSC Los Angeles pocket mouse AMAFDO1042 Perognathus longimembris pacificus Endangered None G5T1 S1 SSC Pacific pocket mouse AMAFDO1060 Perognathus inornatus None None G2G3 S2S3 San Joaquin Pocket Mouse AMAFDO1082 Perognathus alticolus inexpectatus None None G1G2T1T2 S1S2 SSC Tehachapi pocket mouse AMAFD03143 Dipodomys merriami parvus Endangered None G5T1 S1 SSC San Bernardino kangaroo rat AMAFDO5031 Chaetodipus fall" fallax None None G5T3T4 S3S4 SSC northwestern San Diego pocket mouse Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 4 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Selected Elements by Element Code Oj California Department of Fish and Wildlife California Natural Diversity Database Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 5 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Rare Plant Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP AMAFD05032 Chaetodipus fallax pallidus None None G5T34 S3S4 SSC pallid San Diego pocket mouse AMAFF06022 Onychomys torridus ramona None None G5T3 S3 SSC southern grasshopper mouse AMAFF08041 Neotoma lepida intermedia None None G5T3T4 S3S4 SSC San Diego desert woodrat AMAFF11035 Microtus californicus stephensi None None G5T1T2 S1S2 SSC south coast marsh vole AMAJA04022 Urocyon liftoralis catalinae Endangered Threatened G1T1 S1 Santa Catalina Island fox AMAJA04023 Urocyon liftoralis clementae None Threatened G1T1 S1 San Clemente Island fox AMAJF04010 Taxidea taxus None None G5 S3 SSC American badger AMALE04013 Ovis canadensis nelson None None G4T4 S3 FP desert bighorn sheep ARAAA02010 Chelonia mydas Threatened None G3 S1 green turtle ARAAD02030 Emys marmorata None None G3G4 S3 SSC western pond turtle ARAAF01012 Gopherus agassizii Threatened Threatened G3 S2 desert tortoise ARACC01012 Anniella pulchra pulchra None None G3G4T3T4Q S3 SSC silvery legless lizard ARACF12100 Phrynosoma blainvillff None None G3G4 S384 SSC coast horned lizard ARACJ02143 Aspidoscelfs tigris stejnegeri None None G5T3T4 S2S3 coastal whiptail ARACK01020 Xantusia riversiana Delisted None G3 G3 island night lizard ARADA01020 Charina trivirgata None None G4G5 S384 rosy boa ARADB10015 Diadophis punctatus modestus None None G5T2T3Q S2? San Bernardino ringneck snake ARADB19062 Lampropeltis zonata(parvirubra) None None G4G5 S2? SSC California mountain kingsnake (San Bernardino population) ARADB19063 Lampropeltis zonata(pulchre) None None G4G5 8182 SSC California mountain kingsnake (San Diego population) ARADB36160 Thamnophis hammondii None None G4 S3S4 SSC two -striped garter snake ICBRA07010 Streptocephalus wooftoni Endangered None G1G2 8182 Riverside fairy shrimp Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 5 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 °pF Selected Elements by Element Code 0 ° California Department of Fish and Wildlife California Natural Diversity Database RS Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 6 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Rare Plant Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP IICOL02080 Cicindela gabbii None None G2G4 S1 western tidal -fiat tiger beetle IICOL02101 Cicindela hirticollis gravida None None G5T2 S1 sandy beach tiger beetle IICOL02113 Cicindela latesignata latesignata None None G2G4T1T2 S1 western beach tiger beetle IICOL02121 Cicindela senilis frosti None None G2G3T1T3 S1 senile tiger beetle IICOL4A010 Coe/us globosus None None G1G2 S1S2 globose dune beetle IICOL4W010 Onychobaris langei None None Gt S1 Lange's EI Segundo Dune weevil IICOL51021 Trigonoscuta dorothea dorothea None None G1T1 S1 Dorothy's EI Segundo Dune weevil IIDIP05022 Rhaphiomidas terminatus terminatus None None G1T1 S1 EI Segundo Flower -loving fly IIDIP17010 Brennania belkini None None G1G2 S1S2 Belkin's dune tabanid fly IIHYM71040 Ceratochrysis longimala None None Gt S1 Desert cuckoo wasp IILEMOR390 Eucosma hennei None None G1 S1 Henne's eucosman moth IILEM2X090 Carolella busckana None None G1G3 SH Busck's gallmoth IILEP84030 Panoquina errans None None G4G5 S2 wandering (=saltmarsh) skipper IILEPE2206 Callophrys mossii hidakupa None None G4T1T2 S1S2 San Gabriel Mountains elfin butterfly IILEPG201B Euphi/otes battoides allyni Endangered None G5T1 S1 EI Segundo blue butterfly IILEPG402A Glaucopsyche lygdamus palosverdesensis Endangered None G5T1 S1 Palos Verdes blue butterfly IILEPG6011 Plebejus saepiolus aureolus None None G5T1 S1 San Gabriel Mountains blue butterfly IILEPG7010 Plebulina emigdionis None None G1G2 S1S2 San Emigdio blue butterfly IILEPP2010 Danaus plexippus None None G5 S3 monarch butterfly IIORT32020 Aglaothorax longipennis None None G1G2 S1S2 Santa Monica shieldback katydid IIORT36300 Trimerotropis occidentiloides None None G1G2 S1S2 Santa Monica grasshopper Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 6 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 opF Selected Elements by Element Code 0 California Department of Fish and Wildlife ism t California Natural Diversity Database Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 7 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Rare Plant Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP IITRI23010 Diplectrona californica None None G1G2 S1S2 California diplectronan caddisfly ILARAU7010 Socalchemmis gertschi None None G1 S1 Gertsch's socalchemmis spider IMGAS19020 Sterkia clementina None None G1 S1 San Clemente Island blunt -top snail IMGAS36030 Haplotrema catalinense None None G1 S1 Santa Catalina lancetooth IMGAS80110 Pristiloma shepardae None None G1 S1 Shepard's snail IMGASB6010 Radiocentrum avalonense None None G1 S1 Catalina mountainsnail IMGASC5030 Micrarionta gabbi None None G1 S1 San Clemente islandsnail IMGASD1010 Xerarionta intercisa None None G1 S1 horseshoe snail IMGASD1030 Xerarionta redimita None None G1G2 S1 wreathed cactussnail IMGASJ7040 Tryonia imitator None None G2 S2 mimic tryonia (=California brackishwater snail) NBMUS7L090 Tortula californica None None G2? S2 1B.2 California screw moss NBMUS80010 Anomobryum julaceum None None G4G5 S2 4.2 slender silver moss NLTES29470 Graphis saxorum None None G1G3 S1S3 3 Baja rock lichen NLTEST7980 Texosporium sancti-jacobi None None G3 S1 3 woven -spored lichen PDAPI0O090 Cymopterus deserticola None None G2 S2 113.2 desert cymopterus PDAP11BOWO Lomatium insulare None None G2G3 S2S3 113.2 San Nicolas Island lomatium PDAP11G030 Oreonana vestita None None G3 S3 113.3 woolly mountain -parsley PDASTOWOWO Baccharis malibuensis None None Gt S1 113.1 Malibu baccharis PDAST20095 Chaenactis glabriuscula var. orcuftiana None None G5T1 S1 113.1 Orcutt's pincushion PDAST31N070 Eriophyllum mohavense None None G2 S2 113.2 Barstow woolly sunflower PDAST31N090 Constancea nevinii None None G3 S3 113.3 Nevin's woolly sunflower Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 7 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 oe av,a 'rte Selected Elements by Element Code aff� i" California Department of Fish and Wildlife California Natural Diversity Database Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 8 of 15 Rare Plant 12, 2014 Information Expires 5/4/2015 Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP PDAST44000 Pseudognaphalium leucocephalum None None G4 S2 213.2 white rabbit -tobacco PDAST4H020 Hazardia cans None None G2 S2 1B.2 San Clemente Island hazardia PDAST4N102 Helianthus nuttallii ssp. parishii None None GSTH SH 1A Los Angeles sunflower PDAST4N250 Helianthus inexpectatus None None G1 S1 1B.1 Newhall sunflower PDAST4ROJO Deinandra minthornii None Rare G2 S2 1B.2 Santa Susana tarplant PDAST4ROP4 Centromadia parryi asp. australis None None G3T2 S2 1 B.1 southern tarplant PDAST57091 Isocoma menziesii var. decumbens None None G3G5T2T3 S2 1 B.2 decumbent goldenbush PDAST5LOA1 Lasthenia glabrata sap. coulteri None None G4T2 S2 1 B.1 Coulter's goldfields PDAST5N070 Layia heterotricha None None G2 S2 1B.1 pale -yellow layia PDAST6X060 Pentachaeta lyonii Endangered Endangered G2 S2 1B.1 Lyon's pentachaeta PDAST8H060 Senecio aphanactis None None G3? S2 2B.2 chaparral ragwort PDAST81JOKO Munzothamnus blairii None None G3 S3 1B.2 Blair's munzothamnus PDAST8Y080 Stylocline masonii None None G1 S1 1B.1 Mason's neststraw PDASTE8000 Symphyotrichum defoliatum None None G2 S2 1B.2 San Bernardino aster PDASTE80UO Symphyotrichum greatae None None G3 S3 1B.3 Greata's aster PDBER060AO Berberis nevinii Endangered Endangered G1 S1 1B.1 Nevin's barberry PDBOROA370 Cryptantha traskiae None None G2 S2 1B.1 Trask's cryptantha PDBOROA3MO Cryptantha clokeyi None None G2 S2 1B.2 Clokey's cryptantha PDBOROA400 Cryptantha wigginsii None None G2 S1 1B.2 Wiggins' cryptantha PDBOROH010 Harpagonella Palmeri None None G4 S3 4.2 Palmer's grapplinghook PDBOROVOUO Plagiobothrys parishii None None G1 S1 1B.1 Parish's popcornflower Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 8 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 oe av,a 'rte Selected Elements by Element Code aff� 1 California Department of Fish and Wildlife California Natural Diversity Database Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 9 of 15 Rare Plant 12, 2014 Information Expires 5/4/2015 Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP PDBRA061M3 Soechera lincolnensis None None G4? S2 213.3 Lincoln rockcress PDBRA10020 Dithyrea maritima None Threatened G2 S1 1B.1 beach spectaclepod PDBRA1M114 Lepidium virginicum var. robinsonii None None G5T3 S3 4.3 Robinson's pepper -grass PDBRA270VO Nasturtium gambelii Endangered Threatened G1 S1 1B.1 Gambel's water cress PDBRA2AO20 Sibara filifolia Endangered None G1 S1 1B.1 Santa Cruz Island winged-rockcress PDBRA2Q070 Thysanocarpus rigidus None None G1G2 S1S2 1B.2 rigid fringepod PDCACOD053 Opuntia basilaris var. brachyclada None None G5T3 S3 1 B.2 short -joint beavertail PDCAC11010 Bergerocactus emoryi None None G2 S2 2B.2 golden-spined cereus PDCAMOFOB2 Nemacladus secundiflorus var. robbinsii None None G3T2T3 S2S3 1 B.2 Robbins' nemacladus PDCAR040LO Arenaria paludicola Endangered Endangered G1 S1 1B.1 marsh sandwort PDCAROEO11 Loeflingia squarrosa var. artemisiarum None None G5T2T3 S2 2B.2 sagebrush loeflingia PDCHE02010 Aphanisma blifoides None None G3G4 S3 1B.2 aphanisma PDCHE040EO Atriplex coulteri None None G2 S2 1B.2 Coulter's saltbush PDCHE041CO Atriplexpacifica None None G3G4 S2 1B.2 south coast saltscale PDCHE041DO Atriplex parishii None None G1G2 S1 1B.1 Parish's brittlescale PDCHE041TI Atriplex serenana var. davidsonii None None G5T1 S1 1B.2 Davidson's saltscale PDCHE091ZO Chenopodium littoreum None None G2 S2 1B.2 coastal goosefoot PDCHEOPODO Suaeda esteroa None None G3 S2 1B.2 estuary seablite PDClS02090 Crocanthemum greenei Threatened None G2 S2 1B.2 island rush -rose PDCON040AO Calystegia peirsonii None None G4 S4 4.2 Peirson's morning-glory PDCON040PO Calystegia felix None None GHQ SH 3.1 lucky morning-glory Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 9 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 oe av,a 'rte Selected Elements by Element Code a� 1 California Department of Fish and Wildlife California Natural Diversity Database Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page Rare Plant Report Printed on Wednesday, November 12, 2014 Information Expires Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP PDCPR030R3 Lonicera subspicata var. subspicata None None G5T2 S2 1 B.2 Santa Barbara honeysuckle PDCRA04051 Dudleya blochmaniae sap. blochmaniae None None G2T2 S2 1 B.1 Blochman's dudleya PDCRA040A3 Dudleya cymosa sap. marcescens Threatened Rare G5T2 S2 1 B.2 marcescent dudleya PDCRA040A5 Dudleya cymosa sap. ovatifolia Threatened None G5T1 S1 1 B.1 Santa Monica dudleya PDCRA040A7 Dudleya cymosa sap. agourensis Threatened None G5T1 S2 1 B.2 Agoura Hills dudleya PDCRA040A8 Dudleya cymosa sap. crebrifolia None None G5T1 S1 1 B.2 San Gabriel River dudleya PDCRA040BO Dudleya densiflora None None G2 S2 1B.1 San Gabriel Mountains dudleya PDCRA040HO Dudleya multicaulis None None G2 S2 1B.2 many -stemmed dudleya PDCRA040SI Dudleya vixens sap. hassei None None G3?T2? S2? 1 B.2 Catalina Island dudleya PDCRA040S2 Dudleya vixens sap. insularis None None G3?T3 S3 1 B.2 island green dudleya PDCRA040S3 Dudleya vixens sap. virens None None G3?T1 S1 1 B.2 bright green dudleya PDCRO02020 Crossosoma californicum None None G2 S2 1B.2 Catalina crossosoma PDCUS01111 Cuscuta obtusiflora var. glandulosa None None G5T4T5 SH 26.2 Peruvian dodder PDER104070 Arctostaphylos catalinae None None G2? S2? 1B.2 Santa Catalina Island manzanita PDER1042PO Arctostaphylos glandulosa sap. gabrielensis None None G5T2 S2 1 B.2 San Gabriel manzanita PDEUP0O1BO Euphorbia misera None None G5 S2 26.2 cliff spurge PDFABOF1GO Astragalus brauntonii Endangered None G2 S2 1B.1 Braunton's milk -vetch PDFABOF4TO Astragalus leucolobus None None G2 S2 1B.2 Big Bear Valley woollypod PDFABOF5XO Astragalus nevinii None None G3 S3 1B.2 San Clemente Island milk -vetch PDFABOF721 Astragalus preussii var. laxiflorus None None G4T2 S1 1B.1 Lancaster milk -vetch PDFABOF7B1 Astragalus pycnostachyus var. lanosissimus Endangered Endangered G2T1 S1 1B.1 Ventura Marsh milk -vetch Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 10 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 t oe e�yr " Selected Elements by Element Code 0. California Department of Fish and Wildlife '��< California Natural Diversity Database Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 11 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 514/2015 Rare Plant Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP PDFABOF8R2 Astragalus tener var. till Endangered Endangered G2T1 S1 1B.1 coastal dunes milk -vetch PDFABOFB92 Astragalus lentiginosus var. anlonius None None G5T2 S2 1B.3 San Antonio milk -vetch PDFAB2AO41 Acmispon argophyllus var. adsurgens None Endangered G5T1 Si 1B.1 San Clemente Island bird's -foot trefoil PDFAB2A1G2 Acmispon dendroideus var. traskiae Threatened Endangered G4T2 S2 1B.1 San Clemente Island lotus PDFAB2B1TO Lupinus guadalupensis None None G3 S3 1B.2 Guadalupe Island lupine PDFAB2B330 Lupinus peirsonii None None G2 S2 1B.3 Peirson's lupine PDFAB2XOH3 Oxytropis oreophils var. oreophila None None G5T4 S2 2B.3 rock -loving oxytrope PDFAG050DO Quercus dumosa None None G3 S3 1B.1 Nuttall's scrub oak PDGER01070 California macrophylla None None G2 S2 1B.1 round -leaved fllaree PDGRO020F3 Ribes divaricatum var. parishii None None G4TH SH 1A Parish's gooseberry PDGRO021 PO Ribes viburnifolium None None G2? S2? 1B.2 Santa Catalina Island currant PDHYDOAOHO Nama stenocarpum None None G4G5 S1S2 2B.2 mud nama PDHYDOC1GO Phacelia floribunda None None G2 S2 1B.2 many -flowered phacelia PDHYD00510 Phacelia slellaris None None G1 S1 1B.1 Brand's star phacelia PDLAMOV060 Lepechinia rossii None None Gt S1 1B.2 Ross' pitcher sage PDLAM180A3 Monardella hypoleuca asp. hypoleuca None None G4T2T3 S2S3 1B.3 white -veined monardella PDLAM180D2 Monardella 11noides asp. oblongs None None G5T2 S2 1B.3 Tehachapi monardella PDLAM180EI Monardella macranlha sap. Mill None None G5T3 S3 1B.3 Hall's monardella PDLAMIUOA1 Scute//aria bolanded sap. auslromontana None None G4T2 S2 1B.2 southern mountains skullcap PDMALON022 Lavalera assurgentiflora asp. glabra None None G1T1 S1 1B.1 southern island mallow PDMAL0O030 Malacothamnus clemenlinus Endangered Endangered G2 S2 1B.1 San Clemente Island bush -mallow Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 11 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 514/2015 z a Selected Elements by Element Code 0. California Department of Fish and Wildlife California Natural Diversity Database Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 12 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Rare Plant Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP PDMAL0O040 Malacothamnus davidsonii None None G2 S2 1B.2 Davidson's bush -mallow PDMAL110JO Sidalcea neomexicana None None G4? S2S3 2B.2 Salt Spring checkerbloom PDONA030M1 Camissoniopsis guadalupensis ssp. clementina None None G3T3 S3 1B.2 San Clemente Island evening -primrose PDONA05181 Clarkia xantiana sap. parviflors None None G4T3 S3 4.2 Kern Canyon clarkia PDORO040A2 Orobanche parishii sap. brachyloba None None G4?T4 S3 4.2 short -lobed broomrape PDORO040G2 Orobanche valida sap. valida None None G3T2 S2 1 B.2 Rock Creek broomrape PDPAP05020 Canbya candida None None G3G4 S3S4 4.2 white pygmy -poppy PDPAP08012 Dendromecon harfordii var. rhamnoides None None G4T1Q S1 3.1 south island bush -poppy PDPGN040J1 Chorizanthe parryi var. fernandina Candidate Endangered G2T1 S1 1B.1 San Fernando Valley spineflower PDPGN040J2 Chorizanthe parryi var. parryi None None G3T3 S3 1B.1 Parry's spineflower PDPGN082A2 Eriogonum giganteum var. formosum None None G3T3 S3 1 B.2 San Clemente Island buckwheat PDPGN083BI Eriogonum kennedyi var. alpigenum None None G4T3 S3 1B.3 southern alpine buckwheat PDPGN083W5 Eriogonum microthecum var. johnstonii None None G5T2 S2 1B.3 Johnston's buckwheat PDPGN0O011 Nemacaulis denudata var. denudata None None G3G4T2 S2 1 B.2 coast woolly -heads PDPGNOV010 Dodecahema leptoceras Endangered Endangered G1 S1 1B.1 slender -horned spineflower PDPLM030GO Eriastrum rosamondense None None G1 S1 113.1 Rosamond eriastrum PDPLM090DO Linanthus concinnus None None G3 S3 113.2 San Gabriel linanthus PDPLM09102 Leptosiphon pygmaeus asp. pygmaeus None None G4T1 S1 1B.2 pygmy leptosiphon PDPLM00080 Navarretia fossalis Threatened None G1 S1 113.1 spreading navarretia PDPLMOCOLO Navarretia peninsularis None None G39 S2 113.2 Baja navarretia PDPLMOCOQO Navarretia prostrata None None G2 S2 113.1 prostrate vernal pool navarretia Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 12 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Selected Elements by Element Code _ "av yp California Department of Fish and Wildlife California Natural Diversity Database Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 13 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Rare Plant Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP PDPLMOCOSO Navarretia setiloba None None G2 S2 1B.1 Piute Mountains navarretia PDPOR04010 Lewisia brachycalyx None None G4G5 S2 2B.2 short-sepaled lewisia PDRANOBIX2 Delphinium variegatum sap. thornei None None G4T2 S2 1B.1 Thoma's royal larkspur PDRANOB1X3 Delphinium variegatum sap. kinkiense Endangered Endangered G4T2 S2 1 B.1 San Clemente Island larkspur PDROS08030 Cercocarpus traskiae Endangered Endangered Gt S1 1B.1 Catalina Island mountain -mahogany PDROSOW045 Horkelia cuneata var. puberula None None G4T1 S1 1 B.1 mesa horkelia PDROS12011 Lyonothamnus floribundus asp. aspleniffolius None None G3T3 S3 1 B.2 Santa Cruz Island ironwood PDROS12012 Lyonothamnus floribundus asp. floribundus None None G3T2 S2 1 B.2 Santa Catalina Island ironwood PDR081BOS3 Drymocallis cuneffolia var. ewanii None None G1T1 S1 1B.3 Ewan's cinquefoil PDROS1B120 Potentilla multijuga None None GX SX 1A Bailors cinquefoil PDRUBONOF1 Galium catalinense ssp. acrispum None Endangered G4T2 S2 113.2 San Clemente Island bedstraw PDRUBONOF2 Galium catalinense ssp. catalinense None None G4T2T3 S2S3 113.2 Santa Catalina Island bedstraw PDRUBONOVO Galium grande None None G2 S2 113.2 San Gabriel bedstraw PDSAXOM070 Lithophragma maximum Endangered Endangered Gt S1 113.1 San Clemente Island woodland star PDSAXOP030 Parnassia cirrata var. cirrata None None G5T2 S2 113.3 San Bernardino grass -of -Parnassus PDSCROD140 Castilleja gleasoni None Rare G2 S2 113.2 Mt. Gleason paintbrush PDSCROD160 Castilleja grisea Threatened Endangered G3 S3 1B.3 San Clemente Island paintbrush PDSCROJOC2 Chloropyron maritimum ssp. maritimum Endangered Endangered G4?T1 S1 1 B.2 salt marsh bird's -beak PDSCR1B2PO Mimulus traskiae None None GX SX 1A Santa Catalina Island monkey0ower PDSCRISODO Scrophularia villosa None None G3 S3 1B.2 Santa Catalina figwort PDSCR2H010 Gambelia speciosa None None G3 S3 1B.2 showy island snapdragon Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 13 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 oe av,a 'rte Selected Elements by Element Code aff� 1 California Department of Fish and Wildlife California Natural Diversity Database Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page Rare Plant Report Printed on Wednesday, November 12, 2014 Information Expires Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP PDSOLOGONO Lycium brevipes var. hassei None None G1Q S1 1B.1 Santa Catalina Island desert -thorn PDSOLOZ280 Solanum wallacei None None G2Q S2 1B.1 Wallace's nightshade PDVIO04431 Viola pinetorum var. grisea None None G4G5T3? S3? 1 B.3 grey -leaved violet PMAGA080EO Nolina cismontana None None G2 S2 1B.2 chaparral nolina PMCYP039MO Carex occidentalis None None G4 S2S3 2B.3 western sedge PMCYP04010 Cladium californicum None None G4 S2 2B.2 California saw -grass PMCYPOBONO Fimbristylis thermalis None None G4 S2 2B.2 hot springs fimbristylis PMLIL00050 Brodiaea filifolia Threatened Endangered G1 S1 1B.1 thread -leaved brodiaea PMLIL00080 Brodiaea kinkiensis None None G2 S2 1B.2 San Clemente Island brodiaea PMLILOD096 Calochortus clavatus var. gracilis None None G4T2T3 S2S3 1 B.2 slender mariposa -lily PMLILOD122 Calochortus Palmeri var. Palmeri None None G3T3? S3? 1B.2 Palmer's mariposa -lily PMLILOD150 Calochortus plummerae None None G4 S4 4.2 Plummer's mariposa -lily PMLILOD190 Calochortus striatus None None G2 S2 1B.2 alkali mariposa -lily PMLILODIJ1 Calochortus weedii var. intermedius None None G3G4T2 S2 1B.2 intermediate mariposa -lily PMLILODIJ2 Calochortus fimbriatus None None G3 S3 1B.2 late -flowered mariposa -lily PMLIL1AOJO Lilium parryi None None G3 S3 1B.2 lemon lily PMLIL21020 Triteleia clementina None None G2 S2 1B.2 San Clemente Island triteleia PMPOA29010 Dissanthelium californicum None None G1 S1 1B.2 California dissanthelium PMPOA3D020 Imperata brevifolia None None G3 S3 26.1 California satintail PMPOA48020 Muhlenbergia appressa None None G4 S3 2B.2 appressed muhly PMPOA480A0 Muhlenbergia californica None None G3 53.3 4.3 California muhly Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 14 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 un I Selected Elements by Element Code California Department of Fish and Wildlife California Natural Diversity Database Record Count: 295 Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 15 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Rare Plant Rank/CDFW Element Code Species Federal Status State Status Global Rank State Rank SSC or FP PMPOA4G010 Orcuttia californica Endangered Endangered G1 S1 1B.1 California Orcutt grass PPOPH010LO Botrychium crenulatum None None G3 S2 213.2 scalloped moonwort PPTHE05192 Thelypteris puberuls var. sonorensis None None G5T3 S2 213.2 Sonoran maiden fern Record Count: 295 Commercial Version -- Dated November, 4 2014 -- Biogeographic Data Branch Page 15 of 15 Report Printed on Wednesday, November 12, 2014 Information Expires 5/4/2015 Appendix F Supplemental Hydrology and Water Quality Data r ESA J APPENDIX F Supplemental Hydrology and Water Quality Data This appendix provides supplemental information describing the Enhanced Watershed Management Program (EWMP) Management Areas, the designated Beneficial Uses of the major water bodies within each EWMP Area, and applicable Total Maximum Daily Loads (TMDLs) for each EWMP Area and Permittee. Land Use Table F-1 describes land use in each of the EWMP Management Areas, based on the 2005 Southern California Area Governments Land Use Database. As previously described in Section 3.8, "Hydrology and Water Quality," each EWMP group falls into one of six categories: • Southern Coastal EWMP Areas (Beach Cities, Santa Monica Bay Jurisdictions 2 + 3, Marina Del Rey, Ballona Creek), dominated by urbanized beach communities with high- density residential and commercial land uses. • Northern Coastal EWMP Areas (Malibu Creek and Northern Santa Monica Bay), characterized by lower -density development along the coast and greater open space areas inland. • Upper San Gabriel and Rio Hondo/San Gabriel EWMP Areas, characterized by higher - density development in the lower watershed areas and lower -density development and open space in the upper watersheds where the foothills to the San Gabriel Mountains begin. • Upper Los Angeles River EWMP Area, which is primarily urbanized with high-density residential and commercial uses but with characteristics of the Upper San Gabriel in the farthest upper reaches near the foothills. • Dominguez Channel and Palos Verdes Peninsula EWMP Areas, with high-density beach and inland communities and a relatively larger area of industrial land use. • Upper Santa Clara River EWMP Area, which is predominantly open space. TABLE F-1 LAND USE DISTRIBUTIONS WITHIN EWMP AREAS 1. Percentages do not total 100% due to small areas (<4%) of no data Surface Water Hydrology of EWMP Management Areas The following sections describe major surface water hydrologic features in each EWMP Management Area. Ballona Creek The Ballona Creek watershed covers more than 81,000 acres, over 78,000 of which fall in the EWMP Area within the jurisdiction of Municipal Separate Storm Sewer System (MS4) Permittees. The Los Angeles County Flood Control District (LACFCD) owns and operates drainage infrastructure within incorporated and unincorporated areas in the watershed. Land use within the EWMP Area is primarily urbanized (82.5%), with most urbanized areas (59.2%) in multi- or single-family housing. Ballona Creek and Estuary are collectively approximately 9.5 miles long and divided into three hydrologic units: Reach 1, which extends for 2 miles from Cochran Avenue to National 2 Land Use Distribution (%)' Vacant/ Single Open EWMP Area/ Multi -Family Family Other Space/ Subarea Residential Residential Urban Commercial Industrial Transportation Agricultural Recreation Ballona 13.7% 45.5% 6.0% 10.6% 4.0% 2.7% 0.0% 15.9% Creek Beach Cities 8.2% 51.4% 6.6% 13.7% 10.6% 3.5% 0.8% 2.4% Dominguez 14.2% 27.7% 15.9% 18.4% 15.7% 0.0% 0.3% 7.6% Channel Malibu 4.6% 8.7% 1.4% 1.6% 0.3% 1.7% 1.3% 79.6% Marina 27.4% 16.9% 6.2% 19.1% 2.0% 21.1% 0.0% 7.5% del Rey North SMB 0.3% 5.0% 0.3% 0.4% 0.1% 0.0% 0.8% 93.1% Palos Verdes 2.8% 55.8% 4.2% 1.6% 0.7% 1.2% 0.5% 30.2% Peninsula Rio Hondo/ 7.0% 47.0% 3.0% 8.0% 7.0% 1.0% 3.0% 24.0% San Gabriel River SMB Juris 6.4% 27.3% 2.5% 3.9% 4.0% 7.7% 0.0% 47.1% 2+3 Upper 5.3% 47.3% 5.0% 6.3% 5.5% 6.4% 0.8% 21.4% LA River Upper 2.7% 42.9% 6.5% 4.6% 7.9% 5.6% 1.2% 25.1% San Gabriel River Upper 5.1% 7.9% 1.6% 1.1% 2.5% 3.5% 2.1% 74.1% Santa Clara River 1. Percentages do not total 100% due to small areas (<4%) of no data Surface Water Hydrology of EWMP Management Areas The following sections describe major surface water hydrologic features in each EWMP Management Area. Ballona Creek The Ballona Creek watershed covers more than 81,000 acres, over 78,000 of which fall in the EWMP Area within the jurisdiction of Municipal Separate Storm Sewer System (MS4) Permittees. The Los Angeles County Flood Control District (LACFCD) owns and operates drainage infrastructure within incorporated and unincorporated areas in the watershed. Land use within the EWMP Area is primarily urbanized (82.5%), with most urbanized areas (59.2%) in multi- or single-family housing. Ballona Creek and Estuary are collectively approximately 9.5 miles long and divided into three hydrologic units: Reach 1, which extends for 2 miles from Cochran Avenue to National 2 Boulevard (channelized); Reach 2, which extends for about 4 miles from National Boulevard to Centinela Avenue, where Ballona Estuary starts (channelized); and Ballona Estuary, which starts at Centinela Creek and extends for 3.5 miles to the Pacific Ocean (soft -bottom channel, tidally influenced). Major tributaries to Ballona Creek include Sepulveda Canyon Channel (Reach 2) and Centinela Creek (Ballona Estuary). Other water bodies in the watershed include the Del Rey Lagoon and the Ballona Wetlands, which are both connected to the Ballona Estuary through tide gates. The Ballona Wetlands, which are the site of a major multiagency restoration project, encompass approximately 626 acres (541 acres of wetlands and 85 acres of roads, parking lots, levees, and other structures). Approximately 460 acres of the Ballona Wetlands are located within the Ballona Creek watershed; the remaining portion is located in the Marina Del Rey watershed. The Ballona Wetlands are owned and/or managed by the California Department of Fish and Wildlife (CDFW) and the State Land Commission and, as such, are not subject to MS4 Permit or EWMP requirements. Beach Cities The Beach Cities EWMP Area covers over 20,000 acres divided into three watersheds: Santa Monica Bay (38.4% of the EWMP Area), Dominguez Channel (36.1%), and Machado Lake watershed (35.5%). This watershed is the most relatively urbanized of the EWMP areas as 93.9% of the watershed is urbanized. Significantly, almost a quarter of the EWMP Area is commercial and industrial lands. The Dominguez Channel watershed within the Beach Cities EWMP includes drainage from the Torrance Carson Channel (Torrance Lateral). The Machado Lake watershed includes drainage from the Wilmington Drain, an LAFCD facility. Additional information about the Dominguez Channel and Machado Lake watersheds is provided below in the Dominguez Channel EWMP description. Beaches within the Beach Cities EWMP Area do not have any storm drain infrastructure that collects and discharges beach runoff directly to Santa Monica Bay and are therefore considered non -point sources, which are not subject to the MS4 Permit or EWMP requirements. Similarly, the Hermosa Beach and Manhattan Beach piers are not part of the MS4; they are non -point sources excluded from the MS4 Permit scope and therefore the EWMP. Dominguez Channel Dominguez Channel is a 15.7 -mile -Long waterway that drains 133 square miles of the Los Angeles Basin. The lower half of this watershed— approximately 37,600 acres—is subject to the Dominguez Channel EWMP. This EWMP Area is highly urbanized (91.9%), with over a third of the area in commercial and industrial uses. The EWMP Area includes three receiving water bodies: Machado Lake, Dominguez Channel, and the Los Angeles Harbor. Machado Lake is a 40 -acre freshwater lake/reservoir that impounds stormwater runoff from the Wilmington Drain, an LACFCD facility. Approximately 3,000 feet of the drain immediately upstream of Machado Lake is earthen -lined and vegetated; the remainder upstream is channelized. Immediately downstream of the lake is a 63 -acre seasonal freshwater marsh. The portion of Dominguez Channel within the EWMP Area is composed of 3 miles of the lined channel between Imperial Highway near Interstate 105 to Vermont Avenue near Interstate 110, and 2.2 miles of the unlined tidal estuary channel downstream of Vermont Avenue. The 3 EWMP Area also includes 1.8 miles of the Torrance Carson Channel, or Torrance Lateral, which drains into the Dominguez Channel estuary. The estuary drains into the northeast side of the Consolidated Slip, the uppermost section of the tidal Los Angeles Harbor. The Los Angeles Inner Harbor within the EWMP Area covers about 3,000 acres and includes portions of both the Los Angeles and Long Beach Harbors. Other portions of the Los Angeles Harbor covered in the EWMP are the Fish Harbor (91 acres), and the inner and outer portions of Cabrillo Beach. Inner Cabrillo Beach (82 acres) on the north side of the peninsula (west of Fish Harbor) is considered to be a bay/harbor, while Outer Cabrillo Beach (— 0.58 miles long) to the south is considered to be a coastal shoreline. Malibu Creek The Malibu Creek Watershed drains over 75,000 acres of the Santa Monica Mountains north of Los Angeles and is the largest contributing watershed to Santa Monica Bay. Over 42,000 acres of this watershed within Los Angeles County comprise the Malibu Creek EWMP Area. Unincorporated Los Angeles County lands account for 70% of the EWMP Area; this does not include federal lands within the Santa Monica Mountains National Recreation Area, state lands within Malibu Creek State Park, or lands managed by the Santa Monica Mountains Conservancy. Almost 80% of the EWMP Area is open space, with most development centered around the communities of Agoura Hills and Calabasas. Major tributaries to Malibu Creek include Cold Creek, Las Virgenes Creek, Medea Creek, and Potrero Valley Creek. The creek terminates at the Pacific Ocean at Malibu Lagoon, which is currently the location of a multi -agency habitat and water quality enhancement project. The watershed is characterized by steep topography and densely vegetated ravines typical of undeveloped coastal mountains, which create many dangerous and inaccessible areas that cannot be safely monitored and are not suitable for water quality Best Management Practices (BMPs). In addition, the Monterey/Modelo formation outcrops in the watershed are natural sources of sulfate, phosphate, metals, and selenium, and are believed to contribute to the Malibu Creek Watershed water quality impairments. The development of the Malibu Creek EWMP is closely coordinated with that of the North Santa Monica Bay EWMP, which is responsible for lands to the west and east of the Malibu Creek Watershed Management Area. Marina del Rey Marina del Rey is the largest man-made small craft harbor in the world, and is a small contributing watershed to Santa Monica Bay. The Marina del Rey Harbor is open to the Santa Monica Bay through the main channel and shares a common breakwater with Ballona Creek. Of the 1400 -acre EWMP Area, 92.7% is urbanized, with relatively high proportions of multifamily residential (27.4%) and commercial (19.1%) lands. Four subwatersheds drain to the harbor: Subwatershed 1, composed primarily of unincorporated County lands immediately surrounding the main harbor; Subwatershed 2, which includes the Venice Canals and Ballona Lagoon that discharge into the main channel; Subwatershed 3, a small area north of the main harbor that drains into the harbor via the Boone Olive Pump Plant; and Subwatershed 4, which drains City of Los Angeles and Culver City lands into the 10 -acre Oxford Basin, which is connected to the harbor via storm drains and tide gates. The 2004 Marina del Rey 13 Small Drain Survey completed for the Los Angeles County Department of Beaches and Harbors (LACDBH) identified approximately 724 small outfalls that discharge directly into harbor, the majority of which serve the individual parcels and small roads among the basins. LACDBH is responsible for approximately 700 of these outfalls associated with leased parcel sites, and the LACFCD is responsible for 20 outfalls and two storm drain inlets that flow into the Oxford Basin. No MS4 Permittee was identified for the remaining storm drains. A small section of the Ballona Wetlands drains into Subwatershed 1, but, as state lands, it is not subject to the MS4 Permit or EWMP process. North Santa Monica Bay The North Santa Monica Bay EWMP Area includes over 55,000 acres within Santa Monica Bay Jurisdictional Groups (JGs) 1 and 4, and the portion of 9 within the City of Malibu's borders. It does not include federal lands within the Santa Monica Mountains National Recreation Area, state lands within Malibu Creek State Park, or lands managed by the Santa Monica Mountains Conservancy. Similar to the Malibu Creek EWMP Area, most of the watershed is undeveloped open space -93.1%, more than any other EWMP Area. Most development is single-family housing within the incorporated boundaries of the City of Malibu. Like the Malibu Creek EWMP Area, the North Santa Monica Bay EWMP Area is characterized by steep topography and densely vegetated ravines typical of undeveloped coastal mountains. The North Santa Monica Bay EWMP Area includes portions of 6 watersheds, 18 subwatersheds, and 28 coastal streams that all drain directly to Santa Monica Bay and are thus subject to the provisions of the California Ocean Plan (SWRCB, 2012). The Ocean Plan regulates waste discharges to protect the quality of ocean waters for use and enjoyment by the general public. In particular, the Ocean Plan designates Areas of Special Biological Significance (ASBS), which are areas requiring special protection of species or biological communities to the extent that maintenance of natural water quality is ensured. The area from Laguna Point to Latigo Point offshore of a portion of the North Santa Monica Bay EWMP Area is designated as ASBS 24. North Santa Monica Bay EWMP agencies requested and received an exemption from the Ocean Plan (SWRCB Resolution No. 2012-0012) that establishes criteria for allowable discharge of stormwater and nonpoint source pollution to Santa Monica Bay. Palos Verdes Peninsula The Palos Verdes Peninsula is situated in the southwestern portion of Los Angeles County atop the Palos Verdes Hills, which are bounded to the north by the City of Torrance, to the east by the City of Los Angeles, and to the south and west by the Pacific Ocean. The EWMP Area covers over 14,000 acres of incorporated, unincorporated (Los Angeles County), and LACFCD lands throughout the peninsula (see Figure 3.8-1); it does not include the City of Rolling Hills, which is participating in the peninsula's Coordinated Integrated Monitoring Program (CIMP). Most of the watershed's land use is distributed between single family housing (55.8%) and open space (30.2%), and the area is particularly known for its equestrian and golf facilities. The EWMP Area is divided into two watersheds: (1) the Santa Monica Bay Watershed and (2) the Greater Dominguez Channel Watershed Management Area, which is further subdivided into two subwatersheds, the Los Angeles Harbor Subwatershed and the Machado Lake Subwatershed 5 (previously described in detail under the Dominguez Channel EWMP). A drainage divide dissects the Peninsula from the northeast to the southwest with the westerly portion (63% of the EWMP Area) draining into Santa Monica Bay and the easterly portion draining into Machado Lake (22%) and the Los Angeles Harbor (15%) subwatersheds. Water drains from the peninsula to receiving waters through a combination of vegetated open channels and storm drains. Rio Hondo/San Gabriel River The Rio Hondo/San Gabriel River EWMP Area includes over 26,000 acres of land within the eastern portion of the Los Angeles River watershed (tributary to Rio Hondo) (38% of the EWMP Area) and the upper portion of the urban San Gabriel River watershed (62%). The EWMP Area does not include federal lands that are part of Angeles National Forest. Approximately 73% of the EWMP Area is urbanized, with single-family housing comprising 47%. The remaining quarter of the area is undeveloped open space, mostly along lower slopes of the San Gabriel Mountains. Both Rio Hondo and the San Gabriel River are heavily urbanized, channelized, and managed systems. Rio Hondo is a tributary of the Los Angeles River, which receives drainage from the Rio Hondo/San Gabriel River MS4 Permittees via several smaller tributaries: Arcadia Wash, Little Santa Anita Wash, Monrovia Canyon Wash, and Sawpit Wash. Prior to draining to the Rio Hondo, the Santa Anita and Sawpit Washes drain to Peck Road Water Conservation Park (a.k.a. Peck Road Lake), which then drains to the Rio Hondo. Peck Road Lake is owned by the LACFCD and maintained by the Los Angeles County Department of Parks and Recreation. Reach 5 of the San Gabriel River receives drainage from Little Dalton Wash, Big Dalton Wash, and San Dimas Wash. About 4 miles below the mouth of the San Gabriel Canyon is the Santa Fe Dam and Reservoir, which is operated and maintained by the LACFCD through an easement with the U.S. Army Corps of Engineers (USACE). Both the Rio Hondo and San Gabriel River flow into the Whittier Narrows Reservoir upstream and may merge behind the reservoir during large storm events. Flows from the upper watershed are directed to spreading grounds located in and adjacent to the Rio Hondo and San Gabriel Rivers. Santa Monica Bay Jurisdictions 2 + 3 The EWMP Area for Santa Monica Bay Jurisdictions 2 + 3 includes over 25,000 acres of land north and northwest of the Marina del Rey EWMP Area and East of the North Santa Monica Bay EWMP Area. Approximately half of the area is composed of mostly undeveloped lands within the Santa Monica Mountains; the other half includes much more urban areas in the cities of Los Angeles, Santa Monica, and El Segundo. The EWMP Area does not include state lands within Topanga State Park or those managed by the Santa Monica Mountains Conservancy, federal lands within the Santa Monica Mountains National Recreation Area, or Chevron lands at their facility in El Segundo. Subwatersheds within the Santa Monica Bay EWMP Group Area include the mostly open space Castle Rock, Pulga Canyon, Temescal Canyon, and Santa Monica Canyon Subwatersheds characterized by steep topography and densely vegetated ravines typical of undeveloped coastal mountains. Other subwatersheds include the more urbanized Dockweiler and Santa Monica 0 subwatersheds, which are dominated by residential, commercial, and industrial uses. Upper Los Angeles River The area considered in the Upper Los Angeles River EWMP covers approximately 479 square miles (over 308,000 acres), which is more than half of the total area of the entire Los Angeles River watershed. A little over 75% of the watershed is urbanized, with slightly more than half of the watershed comprising multi- and single-family residential housing. The watershed includes multiple facilities owned and operated by LACFCD as well as multiple major transportation corridors. The Los Angeles River is approximately 55 miles long, and five of six reaches lie within the Upper Los Angeles River EWMP Area. The natural hydrology of the Los Angeles River watershed has been significantly altered by urbanization, channelization, and the construction of dams and flood control reservoirs. The river and many of its tributaries are lined with concrete for most or all of their length. Soft -bottom segments of the river occur where groundwater upwelling prevents armoring of the river bottom. The river is segmented into six reaches by the Basin Plan as follows: • Reach 6 begins at the headwaters of the Los Angeles River (the confluence of Arroyo Calabasas and Bell Creek) and extends to Balboa Boulevard. • Reach 5 runs from Balboa Boulevard through the Sepulveda Basin. • Reach 4 runs from Sepulveda Dam to Riverside Drive. • Reach 3 runs from Riverside Drive to Figueroa Street. • Reach 2 runs from Figueroa Street to Carson Street. • Reach 1 runs from Carson Street to the estuary. Reach 1 is outside the boundaries of the Upper Los Angeles River EWMP but is a receiving water body for the entire EWMP Area. Major tributaries to the Upper Los Angeles River include Aliso Canyon Creek, Bell Creek, Bull Creek, Tujunga Wash, Burbank Western Channel, Arroyo Seco, Rio Hondo, and Compton Creek. Other water bodies covered in the EWMP include Echo Park Lake, Legg Lake, and Lake Calabasas. The Los Angeles River is the focus of a proposed multi -agency restoration effort that aims to improve habitat, water quality, flood management, and recreational/transportation amenities along much of the length of the river. USACE recently approved $1 billion in funding to restore 11 miles of the river from downtown through Elysian Park; this first phase would restore 719 acres of habitat and restore the river's confluence with Verdugo Wash. Upper San Gabriel River The Upper San Gabriel River EWMP Area includes almost 68,000 ac of land that are not covered within the Rio Hondo/San Gabriel River EWMP Area described above. The EWMP Area does not include state lands or federal lands that are part of Angeles National Forest. Similar to the Upper Los Angeles River watershed, approximately three quarters of the Upper San Gabriel River EWMP Area is urbanized, with approximately half in multi- and single-family housing. More than half of the area is unincorporated lands within the jurisdiction of Los Angeles County. 7 As previously mentioned, the San Gabriel River is a heavily managed system, with abundant channelization, dams, and other flood management infrastructure. Water bodies within the EWMP area include Thompson Wash, Little Dalton Wash, Big Dalton Wash, San Dimas Creek, Walnut Creek Wash, Puente Creek, San Jose Creek Reaches 1 and 2, San Gabriel River Reaches 2 through 5, and the North Fork of Coyote Creek. Receiving waters downstream of the EWMP area include Reach 1 of the San Gabriel River, Coyote Creek, and the San Gabriel Estuary. Additionally, there are unnamed tributaries draining unincorporated County areas that discharge into Coyote Creek and Puddingstone Reservoir. Upper Santa Clara River The Upper Santa Clara EWMP Area includes over 121,400 ac of lands within unincorporated Los Angeles County and the City of Santa Clarita. Roughly three quarters of the watershed is undeveloped open space bounded by the San Gabriel and Santa Susana Mountains; the remaining quarter includes the urbanized portions of the City of Santa Clarita and its environs. The EWMP Area does not include the majority of the upper river's watershed located within state and federal lands, nor the downstream watershed within Ventura County. The Santa Clara River is one of the last primarily "natural" rivers in Southern California, with relatively few dams/reservoirs in its watershed (Pyramid Lake and Castaic Lake are notable exceptions, though neither are regulated through this EWMP). Though much of the river is bounded by flood control levees, no portions of it are channelized into concrete structures like more urban rivers. In years of significant rainfall, ephemeral springs and year-round flows exist in some tributaries and natural upstream areas. The portion of the river downstream within Ventura County is a target for enhancement by the California Coastal Conservancy and other agencies; therefore, actions in the upper watershed that affect flows downstream must be carefully considered. Beneficial Uses Table F-2 on the following page summarizes the beneficial uses for major hydrologic features within each of the 12 EWMP Management Areas. The TMDLs described in Table F-3 are meant to maintain or improve these beneficial uses. Total Maximum Daily Loads Table F-3 on page 13 summarizes the relevant TMDLs for each Permittee within each EWMP Area. Some TMDLs, such as those for Santa Monica Bay, are applicable to multiple EWMP Areas. 0 TABLE F-2 BASIN PLAN BENEFICIAL USES EWMP Area 8 Water E ry Yeo E U E E P o E E G J Lu K Z J J E Body W W Z 7 G 0: 3 > E Q E w Q J O Ee E` ir Lu r W Ballona Wetlands E E INL P Z K O I Q O P O E E E Ee E` IL N E Del Rey Lagoon 0: K 2 i E 0- 0 2 U E U w i E GO Ee E` E' E E Ballona Creek Ballona Creek Estuary E E Yeo E E E P E E E E Ee E` E' E E Ballona Lagoon E E P* E E E E E E E Ee E` E' E E Ballona Wetlands E E P I E E P P E E E Ee E` E' E E Del Rey Lagoon E E P* E E E E P E E E Ee E` E' E E Ballona Creek Reach 2 Pe'e" E Yav P* E E E P E E E E Ee5 E E Ballona Creek Reach 1 Pe'e" E Yav P* E E E P E E E E Ee5 E E Beach Cities Santa Monica Bay Nearshore + Offshore E E Yeo E E E P E E E E E E E E E Manhattan Beach E E P* E E E E E E E E E P E E Hermosa Beach E E P I E E P P E E E E Ee5 E E King Harbor E E P* E E E E P E E E P P E E Redondo Beach E E P* E E E E E E E E Ee5 E E Torrance Beach E E P* E E E E E E E E Ee5 E E Dominguez Channel P* E E P I P P E E Torrance Lateral P* E E P 1 P P E E Dominguez Channel Dominguez Channel (lined) P E Yeo E E P E E P E E' E' E E Dominguez Channel Estuary (unlined) E E P* P E E E E E E E E E E Torrance Lateral P* E P I E E P P E P E E P E E Inner Harbor P E P* E E E P E E E P P E E Public Beach Areas E E P* E E E E Malibu Creek Malibu Lagoon E E E E E E E Ee E' E' E E Malibu Creek E E P* E E E E E E E E E E Cold Creek E E P* I E E E P E E E E P E E Las Virgenes Creek Em E P* E E E P E E E P P E E Century Reservoir E E P* E E E E Malibou Lake E E P* E E E E E Madea Creek Reach 1 Im I P* I I E E E Madea Creek Reach 2 E" E 1* 1 E E E Lindero Creek Reach 1 1 1 P* I E Lindero Creek Reach 2 1 1 P* I E Triunfo Creek Reach 1 Im I P* I E Triunfo Creek Reach 2 Im I P* I I E E Westlake Lake E E P* E E E Potrero Valley Creek I I P* I P E Lake Eleanor Creek I I P* I I E Lake Eleanor E E P* E E E E E Las Virgenes (Westlake) Reservoir P"," E E E E E P E Hidden Valley Creek Lake Sherwood I E 1 E 1* P* 1 E E 1 E E E E Marina del Rey Harbor E E E E E E E E E E E E Public Beach Access E E P* E E E E E E E E E E All Other Areas P E P* I E E E E E E E E E E E Entrance Channel E E P* E E I E E E E North Santa Monica Bay Coastal Watersheds Malibu Lagoon E E E E E E E E E E Malibu Creek E E P* E E E E E E E Arroyo Sequit E E P* I E E E E E E E Nicholas Canyon Creek I I P* I E Los Alisos Canyon Creek I I P* I E E Lechuza Canyon Creek I I P* I E TABLE F-2 BASIN PLAN BENEFICIAL USES EWMP Area & WaterFE P u P* E UO I E i P p E p J w E` z J J Body w N Z 7 p (7 3 > Q O Q O Q J O Q = a w w Machado Lake E E LL 2 P* ? D: dr0 I E E E N E E E'" KEncinal E` E' E" E Canyon E E P* E E E E',P E',P Ee P Creek E I P*I E El j2 E E P E E P Trancas Canyon E E P* E E I E E P Creek I E E* E E E Zuma Canyon Creek E E E* I E E E E P P E Ramirez Canyon I I I I I E E Creek I 1 1* I 1 E E P E Escondido Canyon P' E P* I E E P E I P E Creek I 1 1* E E 1 E E E E E" E Latigo Canyon Creek I 1 1* E E E E E E 1 E E E E E E" E Puerco Canyon P' 1 P* I P P Creek I 1 1* I 1 E Solstice Canyon 1' 1 P* El j2 I E E2 Creek E E E* E E P P Corral Canyon Creek I 1 1* 1 E Carbon Canyon P I P* I I E E Creek I I P* I E Las Flores Canyon Creek I I P* I E Piedra Gorda Canyon Creek I I P* I E Pena Canyon Creek I I P* I E E Tuna Canyon Creek I I P* I E Topanga Canyon Creek I I P* E E E P I Palos Verdes Peninsula Los Angeles Coastal P I P* E I E E P E P E'" Ee E` E' Ea, Santa Monica Bay Nearshore E E E E E E E E Ee E` E' E Machado Lake E E P* E I E E E E E E'" E E` E' E" E Inner LA Harbor E E P* E E E E',P E',P Ee P Fish Harbor E E P* E El j2 E E P 2 E P Outer LA Harbor E E P* E E I E E P Rio Hondo/San Gabriel River Arcadia Wash P I P* E I E E P E P E'" Ee E` E' Ea, Little Santa Anita E E E E E E'" Ee E` E' Ea, Canyon Creek P* E I E E I E E E'" Ee E` E' E" Santa Monica Canyon Channel E',P 1 P* E',P E',P Santa Anita Wash Y E P* El j2 P 2 E Sullivan Canyon Creek I I P* I E Monrovia Canyon I I P* I E Wash I I I I I E E E Sawpit Wash I I I I I E E Rio Honda Reach 3 1 E P* I P I E E Peck Road Park Lake P' E P* I E E P E I P E San Gabriel River E E E E E E E E" E Reach 5 E E E E E E E E E E E E E E E E" E Little Dalton Wash P' 1 P* I P P Big Dalton Wash P' 1 P* I P P San Dimas Wash 1' 1 P* El j2 I E E2 Santa Fe Dam Park Lake P I P* I I E E Santa Monica Bay Jurisdictions 2+3 Santa Monica Bay - Nearshore Zone" E E E E E E E E'" Ee E` E' Ea, La Pulga Canyon' E E E E E E'" Ee E` E' Ea, Temescal Canyon E E E E E E'" Ee E` E' E" Santa Monica Canyon Channel P ' 1 P* P P Rustic Canyon Creek I I P* I E Sullivan Canyon Creek I I P* I E Mandeville Canyon Creek I I P* I E Santa Ynez Canyon P' E P* I E E Quarry Canyon P' E P* I E E Trailer Canyon P' E P* I E E Will Rogers Beach E E E E E E P E Santa Monica Beach E E E E E E E E" E Venice Beach E E E E E E E E E" E 10 TABLE F-2 BASIN PLAN BENEFICIAL USES EWMP Area & Water E E Yav P* E i E E JJz E Body cK N2 7 p O E I QZ J O Q =az FW McCoy Creek W W LL P* M 0 I O I O E Bell Creek K Ya" 2 ? E E I I 2 E E E N N E Dockweiler Beach E E %ry P* E I E E I E E P Upper LA Rivers LA River Reach 6 E E Yav P* P E E E E Dry Canyon Creek Im I P* E E E I I E E E McCoy Creek I I ry P* I I E Bell Creek Im I Ya" P* E E E I I E E E E Aliso Canyon Wash Im I %ry P* I I E Bull Creek im I P* I I E LA River Reach 4+5 E E Yav P* P P,1 P,1 E E E E P E Pacoima Wash P" E P* E E E E E Tujunga Wash P" I Ya" P* P P E I P P P E E LA River Reach 3 E E Yav P* P P P E E E E Burbank Western Channel P' I Yav P* 1 1 1 1 P P Verdugo Wash P" I Yav P* I P P Arroyo Seco Im I Ya" P* I P P LA River Reach 2 Es E Yav P* P E E P Rio Honda Reach 2 + 3 Im E Yav P* I P I Rio Honda Reach 1 P' E Yav P* I P I Compton Creek Es E P* E E E E E E E E E LA River Reach 1 Es E Yav P* P P E E E E E P P Pe Echo Park Lake P E P* P E Legg Lake - E E P* E E E E E E E E Upper San Gabriel Rivers Thompson Wash Im I la" P* I I E Little Dalton Wash P" I P* E E E I P P E E Big Dalton Wash P' I ry P* I P P San Dimas Wash E E P* E E E E E E E E E (Upper) Im I P* E I E San Dimas Wash (Lower) Im I h" P* E,1 P,1 P,1 I I E E P E Walnut Creek Wash Im I P* I I E E Puente Creek P I P* P P E I P E P E E Upper San Gabriel E E P P P P P E E E Reach 5 (Santa Fe E" E 1* 1 1 1 1 1 E Dam to Huntington Dr.) Im I Ya" P* I I E Upper San Gabriel Reach 5 (Huntington Dr. to Van Tassel Cyn) E E E E E E E E E E E Upper San Gabriel Reach 5 (Van Tassel Cyn to SG Reservoir) E E E E E E E E E E San Gabriel River Reach 3+ 4 Im I Yav P* I I E San Jose Creek Reach 1 +2 P" I Yav P* I I E San Gabriel River Reach 2 E'° E Ya" P* P P I 1 E E San Gabriel River Reach 1 E" E Yav P* P P E Coyote Creek P" I Ya" P* P P P P E San Gabriel River Estuary E E E E E E E E Ee E' E' P Puddingstone Reservoir E E E* E E E E E E Upper Santa Clara Rivers Santa Clara River Reach 5+6+7 E E P* E E E E E E E E Santa Clara River Reach 4B E E P* E E E E E E E E E Bouquet Canyon (SCR R6 to Vasquez Cyn) E"' E E,1 E,1 P,1 P,1 E E E E P E Bouquet Canyon (above Vasquez Cyn) E"' E P P P E E E E E E E Lake Elizabeth E E P P P P P E E E Mint Canyon E" E 1* 1 1 1 1 1 E 11 TABLE F-2 BASIN PLAN BENEFICIAL USES EWMP Area & Waterci U i 2 o o J w Z J Body rn z 7 G 3 > K Q JLU Q J O F w w w LL Z 1' a Q O O (~ ri IL N K K 2 a (7 z U U w f m Piru Creek E E P E E E E E E E Ea E E E Munz Lake E E P* P P P E E E Lake Hughes E E P P P P P E E Castaic Lake E E E E E E E E I E E E Pyramid Lake E E E E E E E E E E E E: Existing beneficial use P: Potential beneficial use action would require a detailed analysis of the area. I: Intermittent beneficial use E,P, and I: shall be protected as required. *: Asterisked MUN designations are designated under SB 88-63 and RB 89-03. Some designations may be considered for exemption at a later date. a: Waterbodies are listed multiple times if they cross hydrologic area or subarea boundaries. Beneficial use designations apply to all tributaries to the indicated waterbody, if not listed separately. b: Waterbodies designated as WET may have wetlands habitat associated with only a portion of the waterbody. Any regulatory action would require a detailed analysis of the area. c: Coastal waterbodies which are also listed in inland Surface Waters Tables (2-1) or in Wetlands Table (2-4). e: One or more rare species utilizes all ocean, bays, estuaries, and coastal wetlands for foraging and/or nesting. f: Aquatic organisms utilize all bays, esturaries, lagoons, and coastal wetlands, to a certain extent, for spawning and early development. This may include migration into areas which are heavily influenced by freshwater inputs. m: Access prevented by Los Angeles County Department of Public Works in concrete -channelized areas. an:Areas of Special Biological Significance: along coast from Latigo Point to Laguna Point, Big Sycamore Canyon and Abalone Cove Ecological Reserves, and Point Fermin Marine Life Refuge. ar: Areas exhibiting large shellfish populations include Malibu, Paint Dume, Point Fermin, White Point and Zuma Beach. as: Most frequently used grunion spawning beaches. Other beaches may be used as well. au: The REC-1 use designation does not apply to recreational activities associated with the swimmable goal as expressed in the Federal Clean Water Act section 101(a)(2) and regulated under the REC-1 use in the Basin Plan, or the associated bacteriological objectives set to protect those activities. However, water quality objectives set to protect other REC-luses associated with the fishable goal as expressed in the Federal Clean Water Act section 1010(a)(2) shall remain in effect for waters where the (au) footnote appears. av: The High Flow Suspension only applies to water contact recreational activities associated with the swimmable goal as expressed in the federal Clean Water Act section 101(a)(2) and regulated under the REC-1 use, noncontact water recreation involving incidental water contact regulated under the REC-2 use, and the associated bacteriological objectives set to protect those activities. Water quality objectives set to protect (1) other recreational uses associated with the fishable goal as expressed in the federal Clean Water Act section 101(a)(2) and regulated under the REC-1 use and (2) other REC-2 uses (e.g., uses involving the aesthetic aspects of water) shall remain in effect at all times for waters where the (av) footnote appears. 1. Only applies to upper portion of the corresponding water body. 2. Only applies to lower portion of the corresponding water body. 3. Access prohibited by Los Angeles County Department of Public Works 4. Beneficial uses were not identified in the Basin Plan for Peck Road Park Lake. Therefore the downstream segment's uses (Rio Hondo Reach 1) apply based on Regional Board input (USEPA, 2012b). 5. Only major water bodies listed here; for complete list see Basin Plan. 12 TABLE F-3 RELEVANT TMDLS FOR EWMP PERMITTEES 13 Rio Honda/San Gabriel EWMP SMB EWMP Upper LA River EWMP Upper San Gabriel River EWMP + m a m m a a m m D ` m o mm m •nc o c` 8 m a c� •Vcq e maci «m o p E o Z' p LARWQCB C 1 Water LL L c E 22 LL Resolution U w TMDL # N m 0 i i2 m N N J J N J JBody Trash 2004-023 Toxic Pollutants: Cadmium, Copper, Lead, Silver, Zinc, 2005-008, Chlordane, DDTs, PCBs, 2013-010 PAHs Ballona Creek Metals: 2007-015, Ballona Copper, Lead, Selenium, 2013-010 Creek Zinc Wetlands Sediment & N/A Invasive Veg (TMDL) Estuary and Sepulveda Channel Bacteria: Total 2006-011, Coliform, Fecal Coliform, 2012-008 Enterococcus Trash 2010-010 X X X X X N/A DDTs and PCBs (USEPA X X X X X Santa TMDL) Monica Bay 2002-004, Bacteria (Wet+ Dry -022 Weather) (amended X X X X X by R12- 007); Toxic Pollutants: Copper, Domingue Lead, Zinc, DDT, PAHs, R11-008 X X X X X X X X z Channel PCBs, Cadmium, Chromium, Mercury Trash 2007-006 Nutrients: Nitrogen and 2008-006 Machado Phosphorus Lake Pesticides and PCBs: DDT, DDE, DDD, Chlordane, R10-008 Dieldrin Bacteria: Total Coliform, Fecal Coliform, 2004-011 LA Harbor Enterococcus 13 TABLE F-3 RELEVANT TMDLS FOR EWMP PERMITTEES 14 Rio Honda/San Gabriel EWMP SMB EWMP Upper LA River EWMP Upper San Gabriel River EWMP + m a m a O a y,p c y m o v a c a m 2 m am c ` m10 > > c p° o Um LARWDCB a o o o oc o M m LL LL 0. U LL Uc LLWater Resolution : . a o Q Q t m o 0 0 m o o m Q m o Q Body TMDL # Q Q m a a 0) J J J W 0) J J J Q m U 0 i d K N N 0) f J J m U G N J J Trash 2008-007 Malibu N/A Creek Nutrients: Nitrogen and (USEPA Phosphorus TMDL) Bacteria: Total Coliform, Fecal Coliform, R12-009 Malibu Enterococcus, E. coli Creek+ Sediment + Nutrients : Lagoon Nitrogen and Phosphorus N/A (Benthic Comm. (USEPA Impairments) TMDL) Bacteria: Total Coliform, Fecal Coliform, 2003-012 Enterococcus Marina Del Rey Toxic Pollutants: Copper, 2005-012 Lead, Zinc, Chlordane, (amended PCBs, DDT, DDE by 014- 004) 2003-009 Nitrogen (by nd d X X X X X X X X X X X X X X X X X X X X X X X X X 010) Trash 2007-012 X X X X X X X X X X X X X X X X X X X X X X X X X LA River 2007-014 Metals: Copper, Lead, Zinc, (amended X X X X X X X X X X X X X X X X X X X X X X X X X Cadmium by R10- 003) Bacteria: E. coli R10-007 X X X X X X X X X X X X X X X X X X X X X X X X X Peck Road Park Lake X X X X X X X X X X X Legg Lake X X X Legg Lake Trash X X N/A LA Lakes Lake Calabasas (USEPA X X X TMDL) Echo Park Lake X X X Puddingstone Reservoir X X Santa Fe Dam Park Lake X X 14 TABLE F-3 RELEVANT TMDLS FOR EWMP PERMITTEES 15 Rio Honda/San Gabriel EWMP SMB EWMP Upper LA River EWMP Upper San Gabriel River EWMP + CID a m LL a m D m o m o m Se •C mc > > g e t m ac o Z' d p C1 C C Q « m LLLL LLARWQCB UJc c mm a LLE $ > d LLWater Resolution Body TMDL # N m 7 S Jy i i N N N F J ¢ N JV J2 2006-014 San Metals: Copper, Lead, Zinc, (amended X X X X X X X X X X X X X X Gabriel Selenium by R13 - River 004) Nitrogen 2003-011 X X X Santa 2008-012 Clara Chloride (amended X X X River by R14- 010) 1 Bacteria: E. coli R10 -006X -4 X X Lake Trash 2007-009 X Elizabeth 1 Italics indicate Permittees within multiple EWMP areas. 2. Table does not note TMDLs that are applicable to Permittees outside the EWMP Process. 15 Appendix G EWMP Proposed BMP and Priority Project Data r ESA J UpperLos AngCICS 1 V u J Iooci ,q 1 s Reservoir � j/•' Stone Reser o Reservoirr Canyn L Resewoir Po\wena - Res%roir Franklin Car: f. • 101 • WEST L OD I• BEVERLY • • 1\ <t . HILLS Ike ®SANGE S • Garaplto • • �. • Creek-Fronfal '`9 J LO • -Ballona Sana Monica Bay • /. Creek• • \Bay ANTA MONICAZ 4 •• • • �, Santa Monic• ®• • Priority Project / =� ��ULVER • SAN LES • Sept, CITY couNTr • Potential BMPs (Regional and Centralized)' -,j • • Ballona Creek WMG -- ® • • Q Participating Permittees 0 Sub -Watersheds LOS ANGELES INGLEW006 • Q III• Water Resources - - Artificial Path / •�•�� Stream/River ° z i / Channel 1� �• Canal/Ditch Cha \ \ Channel Miles f Lake/Pond Potential Distributed BMP not shown - predominantly /opted in urbanized areas SOURCE: ESRI; National Hydrology Dataset. Lower Los Angeles River Participating Permittees - Beverly Hills - Culver City - Inglewood - Los Angeles - Santa Monica - West Hollywood - LA County -LACFCD LA County PEIR EWMP . 140474 Figure A Ballona Creek Watershed Management Group SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP . 140474 Figure B Beach Cities Watershed Management Group SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP. 140474 Figure C Dominguez Channel Watershed Management Group Prioirty Projects have yet to be determined SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP . 140474 Figure D Malibu Creek Watershed Management Group e �c �Q CULVER CITY LOS ANGELES : goo has Pacific Ocean COUNTY COUNTY Priority Projects Q Marina del Rey WMG Q Participating Permittees n m Water Resources � Artificial PathBallona Wetlands Participating Permittees — Stream/River T - Culver City Canal/Ditch G 2,00G - Los Angeles -LACFCD Lake/Pond Feet - LA County SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP . 140474 Figure E Marina del Rey Watershed Management Group SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP . 140474 Figure F North Santa Monica Bay Coastal Watersheds Participating Permittees - Palos Verdes Estates - Rancho Palos Verdes • •tom • 0002 - Rolling Hills Estates -LA County •• � - • • - .. - LACFCD • •' • • • • • �� _ ALOS�(EaDES ES TES • • • m • • Hawthorne • • a° • • •• • • !1 • • �4 • • • • • • RANCHO PALOS VERDES • Priority Projects Potential BMPs (Regional and . • Centralized)' Q Palos Verdes Peninsula WMG Q Participating Permittees Q Sub -Watersheds Water Resources Pacific Ocean — Artificial Path — Stream/River .� Canal/Ditch Lake/Pond 'otential Distributed BMP not shown - predominantly located in urbanized areas SOURCE: ESRI; National Hydrology Dataset. ROLLING 1JILLS • ESTATESG,,_ \J • Pa os Verdes eservoir • P • y • 1 7 \Z • • s T a t I I Milos LA County PEIR EWMP . 140474 Figure G Palos Verdes Peninsula Watershed Management Group SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP . 140474 Figure H Rio Hondo / San Gabriel River Watershed Management Group SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EWMP. 140474 Figure I Santa Monica Bay Watershed Jurisdictions 2 and 3 Watershed Management Groups COUNTY `/ R J r a / SAN FERNANDO e i LOS NGELES 0 �. Y £ • 4nHeles • 00 �e �� •BIS HIDDEN RILLS\ 0S R,1111 011 CAMBASAS 111111 Priority Projects e Potential BMPs (Regional and Centralized)' Q Upper Los Angeles River WMB Q Participating Permittees Water Resources Santa Monica Bay — Artificial Path — Stream/River — Canal/Ditch o 4 Lake/Pond Miles otential Distributed BMP not shown - predominantly located in urbanized areas SOURCE: ESRI; National Hydrology Dataset. \� LA CANADA FLINTRIDG� 1. OL COUNTY DALE ^ PASADENA a ® J -Mrs CITY LOS ANGELES NI ROSEMEAD LA V �.Rsae.y REY PA 'MD TE RN r cou CITY —�� T:- r4oNaseE�L.o Participating Permittees -Alhambra - Burbank - Calabasas i e - Glendale -i' - Hidden Hills _ - La Canada Flintridge t, - Los Angeles LOS ANGELES r - Montebello r - - Monterey Park - -Pasadena T - Rosemead e - San Gabriel - San Marino - South Pasadena - Temple City Y -LAFCD LA County PEIR EWMP . 140474 Figure J Upper Los Angeles River Watershed Management Group Participating Permittees - Baldwin Park - Covina - Glendora -Industry - La Puente -LACFCD - LA County Rio Hondo ma i 6AK INPARK COVINA �fYW Dalton Wash not shown - predominantly located in urbanized areas SOURCE: ESRI; National Hydrology Dataset. Chino Creek Priority Projects • Potential BMPs (Regional and Centralized)" Q Upper San Gabriel River WMG Q Participating Permittees Sub -Watersheds Water Resources Artificial Path Stream/River o z -- Canal/Ditch NP Lake/Pond Miles LA County PEIR EWMP . 140474 Figure K Upper San Gabriel River Watershed Management Groups SOURCE: ESRI; National Hydrology Dataset. LA County PEIR EW MP . 140474 Figure L Upper Santa Clara River Watershed Watershed Management Group Priority Projects EWMP Group Approximate Project Figure Number and Title ID Number Location Ballona Creek La Cienega Park — Multi -Use 8400 Gregory way, Bev Figure A, Ballona Creek Watershed 1 Detention Basin Hills, CA 90211 Management Group Culver Blvd Median Culver Blvd between Figure A, Ballona Creek Watershed 2 Sepulveda and Overland Management Group Edward Vincent—Subsurface Figure A, Ballona Creek Watershed 3 flow wetland with Management Group equalization storage Ladera Park 6027 Ladera Park Ave, Los Figure A, Ballona Creek Watershed 4 Angeles, CA 90056 Management Group Plummer Park 7377 Santa Monica Blvd, Figure A, Ballona Creek Watershed 5 West Hollywood, CA 90046 Management Group Lafayette Park Los Angeles, CA 90005 Figure A, Ballona Creek Watershed 6 Management Group Rancho Park Golf Course 10460 W Pico Blvd, Los Figure A, Ballona Creek Watershed 7 Angeles, CA 90064 Management Group Poinsettta Recreation Center 7341 Willoughby Avenue, Figure A, Ballona Creek Watershed 8 Los Angeles, CA 90046 Management Group Queen Anne Recreation 1240 West Blvd, Los Figure A, Ballona Creek Watershed 9 Center Angeles, CA 90019 Management Group Beach Cities Watershed Management Group Not yet determined Figure B, Beach Cities Watershed Management Group Dominguez Channel Watershed Management Area Group Darcy Park— Infiltration Figure C, Dominguez Channel 1 Watershed Management Group EI Segundo Project— Figure C, Dominguez Channel 2 Infiltration Watershed Management Group Ramona Park— Capture and 4662 West 136th Street Figure C, Dominguez Channel 3 Reuse Hawthorne, CA 90250 Watershed Management Group Jim Thorpe— Infiltration Figure C, Dominguez Channel 4 Watershed Management Group Chester Washington — Figure C, Dominguez Channel 5 Infiltration Watershed Management Group Helen Keller— Infiltration Figure C, Dominguez Channel 6 Watershed Management Group Harbor City/Wilmington Drain Figure C, Dominguez Channel 7 —Capture and Reuse Watershed Management Group Averill Park— Infiltration 1300 South Dodson Figure C, Dominguez Channel 8 Avenue Watershed Management Group San Pedro, CA 90732 Malibu Creek Watershed Not yet determined Figure D, Malibu Creek Watershed Management Group Marina del Rey Area 1—Green Streets Venice Blvd Figure E, Marina del Rey Watershed 1 Management Group Priority Projects EWMP Group Approximate Project Figure Number and Title ID Number Location Area 2—Green Streets Venice Blvd Figure E, Marina del Rey Watershed 2 Management Group North Santa Monica Bay Coastal Watersheds Trancas — Infiltration 33332 Pacific Coast Figure F, North Santa Monica Bay 1 Highway Coastal Watersheds Malibu, CA 90265 Zuma 1, 2, 3 — Infiltration Encinal Canyon Rd Figure F, North Santa Monica Bay 2 Coastal Watersheds Malibu Legacy Park Pump Cross Creek Rd and PCH Figure F, North Santa Monica Bay 3 Station Improvements— Coastal Watersheds Treatment Plant Pump Upgrades Paradise Cove 1 — Infiltration Paradise Cove Rd and PCH Figure F, North Santa Monica Bay 4 Coastal Watersheds 11/4 Topanga —1,3 — East of Topanga Canyon Figure F, North Santa Monica Bay 5 Infiltration RD Coastal Watersheds 11/4 Topanga —2 — Infiltration East of Summit Trail Figure F, North Santa Monica Bay 6 Coastal Watersheds 11/4 Topanga —4 — Infiltration North of Topanga School Figure F, North Santa Monica Bay 7 Rd Coastal Watersheds 11/4 Topanga —5 — Infiltration East of Topanga Canyon Figure F, North Santa Monica Bay 8 RD Coastal Watersheds 11/4 Topanga —6 — Infiltration West of Topanga Canyon Figure F, North Santa Monica Bay 9 Rd Coastal Watersheds 11/4 Topanga —7 — Infiltration East of Summit Trail Figure F, North Santa Monica Bay 10 Coastal Watersheds 11/4 Topanga —8 — Infiltration East of Valley Drive Figure F, North Santa Monica Bay 11 Coastal Watersheds 11/4 Topanga —9— Infiltration East of Topanga Canyon Figure F, North Santa Monica Bay 12 RD Coastal Watersheds 11/4 Topanga —10 — Between Topanga Canyon Figure F, North Santa Monica Bay 13 Infiltration Rd and Fernwood Pacific Coastal Watersheds Drive Palos Verdes Peninsula EWMP Agencies Chandler Quarry Project— Club View Lane Figure G, Palos Verdes Peninsula 1 Infiltration Watershed Management Group Casaba Estates (Butcher Palos Verdes Drive Figure G, Palos Verdes Peninsula 2 Ranch) — Bioretention Watershed Management Group Rio Hondo/San Gabriel River Water Quality Group Recreation Park Lemon Avenue and Figure H, Rio Hondo/San Gabriel 1 Mountain Avenue River Watershed Management Group Sierra Vista Park Sierra Madre Boulevard Figure H, Rio Hondo/San Gabriel 2 and Rancho Road River Watershed Management Group Priority Projects EWMP Group Approximate Project Figure Number and Title ID Number Location Arboretum of Los Angeles Baldwin Avenue and Figure H, Rio Hondo/San Gabriel 3 County Colorado Street River Watershed Management Group Santa Anita Golf Course Huntington Drive and Figure H, Rio Hondo/San Gabriel 4 Santa Anita Avenue River Watershed Management Group Royal Oaks Trail (LAR) Los Angeles River Figure H, Rio Hondo/San Gabriel 5 River Watershed Management Group L. Garcia Park Olive Avenue and Figure H, Rio Hondo/San Gabriel 6 Mayflower Avenue River Watershed Management Group Peck Road Park Lake Peck Road and Rio Hondo Figure H, Rio Hondo/San Gabriel 7 Parkway River Watershed Management Group LADWP Easement From Irwindale to Lake Figure H, Rio Hondo/San Gabriel 8 Ellen south of Arrow Hwy River Watershed Management Group Encanto Park Encanto Pkwy, Duarte, CA Figure H, Rio Hondo/San Gabriel 9 91010 River Watershed Management Group Memorial Park (Azusa) 3rd Street and N Orange Figure H, Rio Hondo/San Gabriel 10 Ave River Watershed Management Group Royal Oaks Trail (SGR) San Gabriel River Figure H, Rio Hondo/San Gabriel 11 River Watershed Management Group Santa Monica Bay Watershed, Jurisdictions 2 & 3 Brentwood Golf Course 590 South Burlingame Figure I, Santa Monica Bay 1 Avenue Watershed Jurisdictions 2 and 3 Los Angeles, CA 90049 Watershed Management Groups Riviera Country Club 1250 Capri Drive Figure I, Santa Monica Bay 2 Pacific Palisades, CA 90272 Watershed Jurisdictions 2 and 3 Watershed Management Groups Rustic Canyon Recreation Latimer Rd Figure I, Santa Monica Bay 3 Center Santa Monica, CA 90402 Watershed Jurisdictions 2 and 3 Watershed Management Groups Oakwood Park 767 California St Figure I, Santa Monica Bay 4 Venice, CA 90291 Watershed Jurisdictions 2 and 3 Watershed Management Groups Santa Monica Civic 1725 Main St Figure I, Santa Monica Bay 5 Auditorium and Courthouse Santa Monica, CA 90401- Watershed Jurisdictions 2 and 3 3274 Watershed Management Groups Memorial Park 1401 Olympic Boulevard Figure I, Santa Monica Bay 6 Santa Monica, CA 90404 Watershed Jurisdictions 2 and 3 Watershed Management Groups Priority Projects EWMP Group Approximate Project Figure Number and Title ID Number Location LADWP easement for South of Imperial Hwy Figure I, Santa Monica Bay 7 potential Northwest Watershed Jurisdictions 2 and 3 Infiltration basins Watershed Management Groups Recreation Park 401 Sheldon Street Figure I, Santa Monica Bay 8 EI Segundo, CA 90245 Watershed Jurisdictions 2 and 3 Watershed Management Groups Upper Los Angeles River Watershed North Holly Park Project 11430 Chandler Boulevard Figure J, Upper Los Angeles River 1 North Hollywood, CA Watershed Management Group 91601 Alhambra Golf Course 630 South Almansor Street Figure J, Upper Los Angeles River 2 Alhambra, CA 91801 Watershed Management Group Fremont Park 600 Hahn Avenue Figure 1, Upper Los Angeles River 3 Glendale, CA 91203 Watershed Management Group Roosevelt Park 7600 Graham Avenue Figure J, Upper Los Angeles River 4 Los Angeles, CA 90001 Watershed Management Group Sierra Vista Park 311 North Rural Drive Figure J, Upper Los Angeles River 5 Monterey Park, CA 91755 Watershed Management Group 208 Park Ave 208 Park Ave, San Figure 1, Upper Los Angeles River 6 Fernando, CA 91340 Watershed Management Group Lacy Park— 1485 Virginia Road Figure J, Upper Los Angeles River 7 Infiltration/Retention Basin San Marino, CA 91108 Watershed Management Group Lower Arroyo Park South Pasadena, CA 91030 Figure 1, Upper Los Angeles River 8 Watershed Management Group Upper San Gabriel River Barnes Park 3251 Patritti Avenue Figure K, Upper San Gabriel River 1 Baldwin Park, CA 91706 Watershed Management Groups Kahler Russell Park 735 North Glendora Figure K, Upper San Gabriel River 2 Avenue Watershed Management Groups Covina, CA 91724 Finkbiner Park Glendora, CA 91741 Figure K, Upper San Gabriel River 3 Watershed Management Groups San Angelo Park 245 San Angelo Avenue Figure K, Upper San Gabriel River 4 Bassett, CA 91746 Watershed Management Groups La Puente Park 501 Glendora Avenue Figure K, Upper San Gabriel River 5 La Puente, CA 91744 Watershed Management Groups Adventure Park 10130 South Gunn Avenue Figure K, Upper San Gabriel River 6 Whittier, CA 90605 Watershed Management Groups Allen J Martin Park 14830 East Giordano Figure K, Upper San Gabriel River 7 Street Watershed Management Groups La Puente, CA 91744 Bassett Park 510 Vineland Avenue Figure K, Upper San Gabriel River 8 La Puente, CA 91746 Watershed Management Groups Upper Santa Clara River Watershed 13 Priority Projects EWMP Group Approximate Project Figure Number and Title ID Number Location Not yet determined Figure L, Upper Santa Clara River Watershed Management Group Appendix EWMP proposed BMP and Prins project Data Region Apn lurediction/City Land Use Type Address Figure Number and Tills Dominguez 2448028904 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2002020900 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez EO79003506 Los Angeles County Elementary Schools 2-1S, Dominguez Channel Waterford Management Group Dominguez 6079003047 Los Angeles County Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2005018052 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 7439016WO Ins Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 743901SWO Los Angeles Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2406021900 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershetl Management Group Dominguez 2446021905 Ins Angeles Elementary Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez 2446021901 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershetl Management Group Dominguez 2446021903 Ins Angeles Elementary Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez 2446021902 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2456022902 Ins Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2456022906 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2462003002 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2462003004 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershd Management Group Dominguez 2462003001 Ins Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2462003005 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2462003003 Ins Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2462003900 Ins Angeles Elementary Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez 7467003006 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2442010013 Ins Angeles Elementary Schools 2-15, Dominguez Channel WatersoM Management Group Dominguez 2442010015 Ins Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2442010014 Ins Angeles Elementary Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez 7344002034 Torrance Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2442010016 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2442010012 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershd Management Group Dominguez 2430006035 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2410006900 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2410006034 Ins Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2345006901 Torrance Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 7349029901 Ins Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2462025900 Ins Angeles Elementary Schools 2-15, Dominguez Channel WatershN Management Group Dominguez 2452006001 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2452006016 Ins Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2452006002 Ins Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 7325020900 Lomita Junior Or Intermediate High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2452006004 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2452006012 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershd Management Group Dominguez 2452006002 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2452006009 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2452006011 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2452002012 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez 2452006015 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2452006006 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez 2452006003 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez 2452006005 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2452006008 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2452006010 Los Angeles Elementary Schools 2-15, Dominguez Channel Warmn" Management Group Dominguez 7351033031 Los Angeles Colleges And Universities 2-15, Dominguez Channel Watershed Management Group Dominguez 2410020018 Los Angeles Elementary Schools 2-15, Dominguez Channel Warmn" Management Group Dominguez 2458024918 Los Angeles Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2553012022 Lomita Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2553012900 Lomita Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2553012023 Lomita Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2452034003 San Pedro Senior High Schools 2-15, Dominguez Channel WatershM Management Group Dominguez 2452034031 Los Angeles Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2452034032 Los Angeles Senior High Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez 2452034036 Los Angeles County Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2452034035 Los Angeles Senior High Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez 2452034028 San Pedro Senior High Schools 2-15, Dominguez Channel Watershd Management Group Dominguez 2452034033 Los Angeles Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2 4 5 4 00100 1 Los Angeles Senior High Schools 2-15, Dominguez Channel Watershd Management Group Dominguez 2454001003 Los Angeles Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2454001006 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 2 4 5 4 00190 0 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 6139003002 Compton Senior High Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez 6139003031 Los Angeles Courtly Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 6139003029 Compton Senior High Schools 2-15, Dominguez Channel Watershd Management Group Dominguez 6139003028 Compton Senior High Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez 6139003030 Compton Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 6130015901 Los Angeles County Junior Or Intermediate High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 6130015900 Los Angeles County Junior Or Intermediate High Schools 2-15, Dominguez Channel Watershd Management Group Dominguez 613200409 Compton Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 61320.04056 Gardena ]if Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4011026022 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4023039902 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4023039903 Inglewood Elementary Schools 2-15, Domingun Channel WatershM Management Group Dominguez 4023039904 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4023039WS Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4023039902 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4023039030 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4023039906 Inglewood Elementary Schools 2-15, Dominguez Channel Watershd Management Group Dominguez 4024021026 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4024021023 Inglewood Elementary Schools 2-15, Dominguez Channel Watershd Management Group Dominguez 4024021025 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4033013900 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4033013906 Inglewood Elementary Schools 2-15, Dominguez Channel Waterman] Management Group Dominguez 4021032900 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez M38029014 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4038029004 Lennox Elementary Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez 4038029006 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 14M24 Draft Program Environmental Impact Report 2 January 2015 Appendix EWMP Proposed BMP and Priodry Project Data Region Apo Jurisdiction/City Land Use Type Address Figure subduer and Tills Dominguez 4038029007 Inglewood Elementary Schools 2-15, Dominguez Channel undersbetl Management Group Dominguez Q38029WS Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4038029020 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4022002900 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4039020000 Los Angeles County Junior Or Intermediate High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4039021000 Los Angeles Courcy Junior Or Intermediate High Schools 215, Dominguez Channel Watershed Management Group Dominguez 4039023901 Los Angeles County Elementary Schools 2-15, Dominguez Channel Watershed! Management Group Dominguez 4039022901 Los Angeles Courcy Junior Or Intermediate High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4039026900 Los Angeles County Junior Or Intermediate High Schools 2-15, Dominguez Channel understand Management Group Dominguez 4030033903 Inglewood Senior High Schools 2-15, Dominguez Channel Watershrl Management Group Dominguez 4030033901 Inglewood Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4030033902 Inglewood Junior Or Intermediate High Schools 2-15, Dominguez Channel Watershrl Management Group Dominguez 4030033904 Inglewood Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4034014001 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4034014802 Inglewood Elementary Schools 2-15, Dominguez Channel Watershd Management Group Dominguez Q57WSWO Hawthorne Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4035002900 Inglewood Elementary Schools 2-15, Dominguez Channel WatershM Management Group Dominguez 4035004032 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4035008902 Los Angeles County Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4020009902 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4020009010 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4020009005 Inglewood Elementary Schools 2-15, Dominguez Channel Watershrl Management Group Dominguez 4020009006 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4020009004 Inglewood Elementary Schools 2-15, Dominguez Channel Watershrl Management Group Dominguez 4036007901 Lennox Elementary Schools 2-15, Dominguez Channel understand! Management Group Dominguez 4020016900 Inglewood Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4036007902 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4020025900 Inglewood Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4020026900 Inglewood Senior High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez MS7014016 Los Angeles Elementary Schools 2-15, Dominguez Channel undershetl Management Group Dominguez OS7014017 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4128002902 Los Angeles Elementary Schools 2-15, Dominguez Channel undershetl Management Group Dominguez 4128002901 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershrl Management Group Dominguez 4126016015 Inglewood Colleges And Universities 2-15, Dominguez Channel Watershed Management Group Dominguez 4126016009 Inglewood Colleges And Universities 2-15, Dominguez Channel Watershrl Management Group Dominguez 4126016018 Inglewood Colleges And Universities 2-15, Dominguez Channel understand! Management Group Dominguez 4126016011 Inglewood Colleges And Universities 2-15, Dominguez Channel Watershed Management Group Dominguez 4126016010 Inglewood Colleges And Universities 2-15, Dominguez Channel understand! Management Group Dominguez WT9002917 Los Angeles County Colleges And Universities 2-15, Dominguez Channel Watershed Management Group Dominguez W 9002918 Los Angeles Courtly Colleges And Universities 2-15, Dominguez Channel Watershed Management Group Dominguez 4074027906 Los Angeles Courcy Colleges And Universities 2-15, Dominguez Channel Watershed Management Group Dominguez W79W2272 Los Angeles County Colleges And Universities 2-15, Dominguez Channel understand Management Group Dominguez ONW2271 Los Angeles County Colleges And Universities 2-15, Dominguez Channel Watershed Management Group Dominguez 4023039029 Inglewood Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4126016025 Inglewood Colleges And Universities 2-15, Dominguez Channel Watershed Management Group Dominguez 4128002900 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4128002015 Los Angeles Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4126016016 Inglewood Colleges And Universities 2-15, Dominguez Channel Watershed Management Group Dominguez 4126016014 Inglewood Colleges And Universities 2-15, Dominguez Channel understand! Management Group Dominguez 4126016017 Inglewood Colleges And Universities 215, Dominguez Channel Watershed Management Group Dominguez 4039023900 Los Angeles Courcy Junior Or Intermediate High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4039009902 Los Angeles Courtly Junior Or Intermediate High Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 4038029906 Los Angeles County Elementary Schools 2-15, Dominguez Channel understand Management Group Dominguez 7345006900 Torrance Elementary Schools 2-15, Dominguez Channel Watershed Management Group Dominguez 7414002904 Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershrl Management Group Forks And Recreation Dominguez 7414002903 Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershrl Management Group Parks And Recreation Dominguez 7478026914 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7420026927 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel WatershM Management Group Undifferentiated Dominguez 7428028940 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7478026907 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7478028945 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7478028947 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7478028939 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel understand! Management Group Undifferentiated Dominguez 7478028941 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7478028963 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 748028942 Los Angeles Open Space Public, Vam 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7478028958 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7478028960 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7478029920 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7420029931 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel WatershM Management Group Undifferentiated Dominguez 7428028925 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel WatershM Management Group Undifferentiated W County Flood Control District Enhanced Watershed Management Programs ESA/ 140474 Draft Program Environmental Impact Report 3 January 2015 Appendix EWMP Proposed BMP and Priodry Project Data Region Apn Jurisdiction/CHy Land Use Type Address Figure Numher and Tilk Dominguez 2028028927 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2028028935 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2428028969 Los Angeles Open Space Public, Van[ 215, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2428029902 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428026926 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2428028930 Los Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2428028953 Los Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2428028920 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428029923 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2428028961 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 248029902 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 248028962 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 248029908 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2428028924 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2428028938 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 248026908 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428026928 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 248028965 Los Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 248029909 Ins Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428029912 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2428029934 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428028929 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428028952 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 248028934 Los Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 248029904 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428028951 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428028921 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428029924 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 74MO29926 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428028931 Ins Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428029901 Ins Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 248029903 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 248028968 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 248028966 Ins Angeles Open Space Public, Vend 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428028933 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428028954 Los Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 248028922 Los Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2428029918 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2428028928 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428028936 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428029921 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428029932 Ins Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428028926 Ins Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 248028946 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428028959 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428029919 Los Angeles Open Space Public, Vend 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428029930 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated IA County Flood Control District Enhanced Watershed Management Programs ESA/ 140424 Draft Program Environmental Impact Report 4 January 2015 Appendix EWMP Proposed BMP and Puri Project Data Region Apo Jurisdiction/CHy Land Use Type Address Figure Numher and Tilk Dominguez 2428028932 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428028962 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2428028964 Los Angeles Open Space Public, Van[ 215, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2428029910 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428029935 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2428029933 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2428029900 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2428029922 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428028922 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2428029943 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 24802996 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 208030901 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 248029939 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2428029944 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2428030902 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428029932 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428029946 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2428030WS Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2428029938 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428029942 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2428030900 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428029941 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428029940 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 24802990 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 248035914 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428035923 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428035922 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2428035913 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 74MO35915 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428035916 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2428029936 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2429013918 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2429013919 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2425023910 Ins Angeles Open Space Public, Developetl Lot 2-15, Dominguez Channel Watershd Management Group Parks And Recreation Dominguez 2425032900 Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershd Management Group Parks And Recreation Dominguez 4138030904 El Segundo Open Space Public, Vart 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 4145021900 Hawthorne Open Space Public, Developed Lot 2-15, Dominguez Channel Watershetl Management Group Parks And Recreation Dominguez QUOU916 Hawthorne Open Space Public, Vant 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 4055008900 Hawthorne Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 4041016902 Hawthorne Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 4055021900 Hawthorne Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 4052031902 Ins Angeles County Open Space Public, Vard 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 4052031908 Ins Angeles County Open Space Public, Vard 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 4052032900 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 4043002904 Hawthorne Open Space Public, Correlated Lot 2-15, Dominguez Channel Watershd Management Group Parks And Recreation Dominguez 6089021901 Ins Angeles Open Space Public, Correlated Lot 2-15, Dominguez Channel Watershd Management Group Parks And Recreation Dominguez 4051020903 Hawthorne Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated W County Flood Control District Enhanced Watershed Management Programs ESA/ 140424 Draft Program Environmental Impact Report 5 January 2015 Appendix EWMP Proposed BMP and Puri Project Data Region Apo Jurisdiction/City Land Use Type Address Figure Numher and Tilk Dominguez 4051012901 Hawthorne Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 4051020900 Hawthorne Open Space Public, Vant 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 4051020901 Hartshorne Open Space Public, Vard 215, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 6089029903 Los Angeles County Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 6089028WS Los Angeles Courcy Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed! 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Management Group Parks And Recreation Dominguez 7440030918 Ins Angeles Open Space Public, Gesell Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 7440034907 Ins Angeles Open Space Public, Correlated Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 7440040906 Ins Angeles Open Space Public, Correlated Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 7440034906 Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 7440030921 Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 7442001907 Palos Verdes Est Open Space Public, Vard Area 2-15, Dominguez Channel Watershed Management Group Dominguez 744201910 Los Angeles Open Space Public, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 744201911 Los Angeles Open Space Public, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442001919 Los Angeles Open Space Public, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 744201915 Los Angeles Open Space Public, Vard Area 2-15, Dominguez Channel Watershed Management Group Dominguez 744201914 Ins Angeles Open Space Public, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7412024902 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7442W1913 Ins Angeles Open Space Public, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7412026912 Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 4074027907 Los Angeles County Open Space Public, Developed Regional 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 7448033914 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448033910 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448033917 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448033921 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448033901 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448034914 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448034921 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 7448033923 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448034915 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448033908 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448034901 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448035901 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448035913 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448033911 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448033915 Los Angeles Open Space Public, Vard 215, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448034906 Ins Angeles Open Space Public, Vant 2i5, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7448034909 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated W County Flood Control District Enhanced Watershed Management Programs ESA / 140174 Draft Program Environmental Impact Report 7 January 2015 Appendix EWMP Proposed RMP and Prionry Project Data Region Apo lurediction/CHy Land Use Type Address Figure Numher and Tilk Dominguez 24J8035918 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 24Y8034WO Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2008035900 Los Angeles Open Space Public, Van[ 215, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2008035910 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008035921 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2008033912 Los Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2008030908 Los Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2008030910 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008033900 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008033909 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008030911 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2008035929 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2008033906 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2008030912 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2008035920 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008033902 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008030913 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2008030922 Ins Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2008033919 Ins Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008030902 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2008030912 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008030923 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008035930 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008033916 Los Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008033918 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008030905 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008035915 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008030926 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008030920 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008035931 Ins Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008033903 Ins Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2008033WS Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008030916 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008030918 Ins Angeles Open Space Public, Vend 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008035925 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008030925 Los Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2008030922 Los Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2008030919 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2008035908 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008035926 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008035935 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008036WS Los Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008036906 Los Angeles Open Space Public, Vanl 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008036902 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008036908 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008036900 Los Angeles Open Space Public, Vend 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2008036922 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated IA County Flood Control District Enhanced Watershed Management Programs ESA/ 100020 Draft Program Environmental Impact Report 8 January 2015 Appendix EWMP Proposed BMP and Puri Project Data Region Apo lurediction/CHy Land Use Type Address Figure Numher and Tilk Dominguez 20J8036911 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 20J8036916 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2008036903 Los Angeles Open Space Public, Van[ 215, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2008036900 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2008036921 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008036926 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2008036923 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008036919 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008036915 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2008036920 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2006001900 Los Angeles Open Space Public, Developetl Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2050022900 Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Forks And Recreation Dominguez 20120D1901 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012001900 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012001906 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012001902 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2002023901 Ins Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2012001903 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2006001903 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012001908 Wilmington Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2017W1911 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2017W1910 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2017W1912 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012001909 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012001910 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2017W1915 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012001913 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012001905 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012001902 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013033901 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013033902 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 7417008900 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012009903 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013033900 Ins Angeles Open Space Public, Vend 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012009901 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013033905 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012008901 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012009900 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012009902 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013033900 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012009900 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012008906 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012009916 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012009902 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7417009910 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7417009917 Los Angeles Open Space Public, Vend 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012009915 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated W County Flood Control District Enhanced Welcomed Management Programs ESA/ 100020 Draft Program Environmental Impact Report 9 January 2015 Appendix EWMP Proposed BMP and Priodry Project Data Region Apn Jurisdiction/CHy Land Use Type Address Figure Numher and Tdk Dominguez 24320091 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012009908 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2412000912 Los Angeles Open Space Public, Vard 215, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 24320.9^913 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412009914 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2412009909 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2412009911 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2412009918 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2413033903 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! 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Management Group Undifferentiated Dominguez 2412018901 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2403020900 Los Angeles County Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2 412 018 912 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2412019914 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2412019911 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2412019918 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 7417019909 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2412019920 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 7417018908 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7417019923 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7417019908 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412019921 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2412019922 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412018919 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2 412 019 916 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2412018915 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2412018909 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2412018910 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7417019907 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2412019925 Ins Angeles Open Space Public, Vend 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 7417018911 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2412019924 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2412019910 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2412019912 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2412018903 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412018900 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7417018918 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412019913 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2412018916 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2412019915 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 7417018906 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2412018913 Ins Angeles Open Space Public, Vend 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 2412018904 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated W County Flood Control District Enhanced Watershed Management Programs ESA / 140,174 Draft Program Environmental Impact Report 10 January 2015 Appendix EWMP Proposed BMP and Puri Project Data Region Apo lurediction/CHy Land Use Type Address Figure Numher and Tilk Dominguez 2012019927 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2012019912 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2432019919 Los Angeles Open Space Public, Vard 215, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2412019928 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7417018907 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412018912 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2412018WS Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412018914 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7417019906 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2559034WO Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7417018902 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2446019901 Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2559035901 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412020WO Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2412021WO Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2442003901 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2455010903 Ins Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2455010902 Ins Angeles Open Space Public, Dessmoped Lot 2-15, Dominguez Channel Watershed! Management Group Parks And Recreation Dominguez 2412010903 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412011WO Harbor OW Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412012901 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412012WO Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412012902 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412012903 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2412014WO Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 74UOISWO Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2462010WO Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2462011900 Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 75WO23WO Ins Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2439022906 Ins Angeles Open Space Public, Dessmoped Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2439022904 Ins Angeles Open Space Public, Dessmoped Lot 2-15, Dominguez Channel Watershetl Management Group Parks And Recreation Dominguez 2439027WS Los Angeles Open Space Public, Developetl Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2439027902 Ins Angeles Open Space Public, Developetl Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2439027903 Inmtta Open Space Public, Correlated Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2442029WO Los Angeles Open Space Public, Desolated Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2462031WO Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2462030901 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2462032WO Los Angeles Open Space Public, Vant 2-1S, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2462030902 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2413021906 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2413021904 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2413021924 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2413021914 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2413021931 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2413021932 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2413021916 Ins Angeles Open Space Public, Vend 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2413021907 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated W County Flood Control District Enhanced Watershed Management Programs ESA / 14D474 Draft Program Environmental Impact Report 11 January 2015 Appendix RAW Pmpomd RMP and Puri Project Data Region Apn Jurisdiction/Culy Land Use Type Address Figure Number and Tilk Dominguez 7413021918 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013021912 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2013021912 Los Angeles Open Space Public, Van[ 215, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 20]3021922 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013021925 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7413021915 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 7413021917 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013021926 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013021911 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013021929 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7413021919 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7413021921 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013021930 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013021928 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 20]3021WS Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 20]3021910 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2 013 0 2191 3 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013021918 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013021919 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013021923 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 20]3021913 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 20]3021920 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013021922 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2055025910 Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2008006910 Los Angeles Open Space Public, Other Open Spare 2-15, Dominguez Channel Watershed Management Group And Recreation Dominguez 2008002910 Los Angeles Open Space Public, Other Open Space 2-15, Dominguez Channel Watershed Management Group And Recreation Dominguez 2008000910 Los Angeles Open Space Public, Other Open Space 2-15, Dominguez Channel Watershed Management Group And Recreation Dominguez 2013021930 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7413021935 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013021936 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013021933 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 7322008912 Inmita Open Space Public, Developetl Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2013023910 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7322008915 Inmtta Open Space Public, Developetl Lot 2-15, Dominguez Channel Watershed Management Group Parks And Recreation Dominguez 2013020911 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013020910 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013020916 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013020910 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013020912 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013020913 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013020915 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013020916 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013020915 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013020913 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013020910 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013020912 Ins Angeles Open Space Public, Vend 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013020919 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated W County Flood Control District Enhanced Watershed Management Programs ESA / 10M20 Draft Program Environmental Impact Report 12 January 2015 Appendix EWMP Proposed BMP and Prionry Project Data Region Aim Jurisdiction/Culy Land Use Type Address Figure Number and Tilk Dominguez 2013020920 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2013020908 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2433020919 Los Angeles Open Space Public, Vard 215, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 24]3024911 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2413024918 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 7413024910 Los Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2413024921 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2413024922 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2413024912 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 74MO35WS Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2418035904 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2469018903 Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershetl Management Group Parks And Recreation Dominguez 74MO36MI Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 2413024902 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 2418035906 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2418036905 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 2418036900 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! 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Management Group Undifferentiated Dominguez 6132018900 Los Angeles Open Space Public, Developetl Lot 2-15, Dominguez Channel Watershed! Management Group Parks And Recreation Dominguez 4021015901 Inglewood Open Space Public, Dowell Lot 2-15, Dominguez Channel Watershd Management Group Parks And Recreation Dominguez 4010023900 Inglewood Open Space Public, Correlated Lot 2-15, Dominguez Channel Watershd Management Group Parks And Recreation Dominguez Q34WS912 Inglewood Open Space Public, Vard 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez QUW507 Inglewood Open Space Public, Vard 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 4034005905 Inglewood Open Space Public, Vart 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez QM02102 Inglewood Open Space Public, Developed Lot 2-15, Dominguez Channel Watershetl Management Group Parks And Recreation Dominguez 4032002913 Inglewood Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 4032001900 Inglewood Open Space Public, Vard 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 4032001908 Inglewood Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 4032001901 Inglewood Open Space Public, Vard 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 4032003915 Inglewood Open Space Public, Vard 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 4032001905 Inglewood Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 4032001904 Inglewood Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 4032001902 Inglewood Open Space Public, Vant 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 6052010903 Los Angeles Open Space Public, Developed Regional 2-15, Dominguez Channel Watershd Management Group Parks And Recreation W County Flood Control District Enhanced Watershed Management Programs ESA/ 140424 Draft Program Environmental Impact Report 13 January 2015 Appendix EWMP Proposed BMP and Priodry Project Data Region Aim Jurisdiction/City Land Use Type Address Figure Number and rdle Dominguez 4129037913 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 4129037916 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 4129 0 3 7 910 Los Angeles Open Space Public, Van[ 215, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 4129037902 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 4129037912 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 4129037911 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 4129037915 Ins Angeles Open Space Public, Vard 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 4129037906 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 4129037907 Ins Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 4129037909 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 4129037914 Los Angeles Open Space Public, Vant 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 4129037908 Los Angeles Open Space Public, Vart 2-15, Dominguez Channel Watershetl Management Group Undifferentiated Dominguez 4123018927 Los Angeles Open Space Public, Developed Lot 2-15, Dominguez Channel Watershetl Management Group Parks And Recreation Dominguez E079002903 Los Angeles County Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 7440012902 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 7440020910 Los Angeles Open Space Public, Van[ 2-15, Dominguez Channel Watershed Management Group Undifferentiated Dominguez 4034005908 Inglewood Open Space Public, Vant 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 4032001907 Inglewood Open Space Public, Vard 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 4034005900 Inglewood Open Space Public, Vard 2-15, Dominguez Channel Watershd Management Group Undifferentiated Dominguez 4034005906 Inglewood Open Space Public, said 2-15, Dominguez Channel Watershed! Management Group Undifferentiated Dominguez 4123018926 Ins Angeles Open Space Public, Developetl Lot 2-15, Dominguez Channel Watershd Management Group Forks And Recreation Dominguez 4123018928 Ins Angeles Open Space Public, Developetl Lot 2-15, Dominguez Channel Watershd Management Group Forks And Recreation Dominguez QM024WS Inglewood Open Space Public, Developed Lot 2-15, Dominguez Channel Watershed Management Group Ranks And Recreation Dominguez 7 478 013 016 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershetl Management Group Dominguez 7 4 23 016 00 9 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7423017001 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershetl Management Group Dominguez 7423016011 Los Angeles Open Space Private, Vant Undifferentimed 2-15, Dominguez Channel Watershd Management Group Dominguez 7 4 23 016 010 Los Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 7423017002 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 7423016018 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7423016015 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 7423017023 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7423023WS Wilmington Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershd Management Group Dominguez 7423023006 Ins Angeles Open SpacePrivate, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed! Management Group Dominguez 4138012809 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershetl Management Group Dominguez 4138015803 El Segundo Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Wmershd Management Group Dominguez 7423028044 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershetl Management Group Dominguez 4138012810 El Segundo Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Wmershd Management Group Dominguez 7423028045 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 7423028046 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 7425011025 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 7425023804 Ins Angeles Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed! Management Group Dominguez 7425031008 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7425031002 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 7425031005. Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7425031001 Wilmington Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershetl Management Group Dominguez 7425031004 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7425031007 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7425031006 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 7425031003 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4149011228 Hawthorne Open SpacePrivate, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershd Management Group Dominguez 4149011223 Hawthorne Open Space Private, Developed bad Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149011225 Hawthorne Open SpacePrivate, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershd Management Group Dominguez 4149011224 Hawthorne Open SpacePrivate, Developed Lot Paris; And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149011229 Hawthorne Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149011227 Hawthorne Open SpacePrivate, Developed Lot Paris; And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149011221 Hawthorne Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershetl Management Group Dominguez 4149011222 Hawthorne Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed! Management Group Dominguez 4149011226 Hawthorne Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershetl Management Group Dominguez 4149011231 Hawthorne Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershd Management Group Dominguez 4138030058 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershetl Management Group Dominguez 4138030059 El Segundo Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 4138030062 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030009 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 4138030010 El Segundo Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 4138030000 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4149011236 Hawthorne Open SpacePrivate, Developed Lot Emirs And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030014 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4149013076 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030011 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershetl Management Group Dominguez 4138030023 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4138030061 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershetl Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 140,174 Draft Program Environmental Impact Report 14 January 2015 Appendix EWMP Purposed BMP and Prionry Project Data Region Apo Jurisdiction/City Land Use Type Address Figure Number and rdle Dominguez 41M030063 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4149011234 Hawthorne Open SpacePrivate, Developed Lot Parks And Recreation 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 4138030012 El Segundo Open Space Private, Vant Undifferentiated 2-1S, Dominguez Channel Watershed Management Group Dominguez 4138030064 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 4138030066 El Segundo Open Space Private, Vant Undifferentiated 215, Dominguez Channel Watershed Management Group Dominguez 4149011235 Hawthorne Open Space Private, Developed Lot Palls And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149013069 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4149011233 Hawthorne Open Space Private, Developed Lot PaMS And Recreation 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 4149018011 Hawthorne Open Space Private, Developed Lot PaMS And Recreation 2-15, Dominguez Channel WatersM1M Management Group Dominguez 4149018012 Hawthorne Open Space Private, Developed Lot PaMS And Recreation 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 4149018032 Hawthorne Open Space Private, Developed Lot Palls And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018025 Hawthorne Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018003 Hawthorne Open SpacePrivate, Developed Lot Palls And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 41M030095 El Segundo Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018016 Hawthorne Open SpacePrivate, Developed Lot Pads And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018030 Hawthorne Open SpacePrivate, Developed Lot Pads And Recreation 2-15, Dominguez Channel WatersM1d Management Group Dominguez 4138030023 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030026 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030034 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018015 Hawthorne Open SpacePrivate, Developed Lot PaMS And Recreation 2-15, Dominguez Channel WatersM1M Management Group Dominguez 4138030022 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018013 Hawthorne Open SpacePrivate, Developed Lot Fare; And Recreation 2-15, Dominguez Channel WatersM1N Management Group Dominguez 4149018031 Hawthorne Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030024 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030025 El Segundo Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030093 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterms" Management Group Dominguez 4149018004 Hawthorne Open SpacePrivate, Developed Lot Pads And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018022 Hawthorne Open SpacePrivate, Developed Lot Pads And Recreation 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 4138030068 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4149011230 Hawthorne Open Space Private, Developed Lot Pads And Recreation 2-15, Dominguez Channel understand! Management Group Dominguez 4149018006 Hawthorne Open Space Private, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018023 Hawthorne Open Space Private, Developed Lot Pads And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030091 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1M Management Group Dominguez 4149018002 Hawthorne Open Space Private, Developed Lot Pads And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018024 Havalorne Open Space Private, Developed Lot Pads And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030082 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018001 Hawthorne Open Space Private, Developed Lot Pads And Recreation 2-15, Dominguez Channel understand! Management Group Dominguez 4149018026 Hawthorne Open Space Private, Developed Lot Pads And Recreation 2-15, Dominguez Channel WatersM1d Management Group Dominguez 4149018002 Headroom Open SpacePrivate, Developed Lot Pads And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030020 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1d Management Group Dominguez 4149018008 Hawthorne Open Space Private, Developed Lot Pads And Recreation 2-15, Dominguez Channel understand! Management Group Dominguez 4149018021 Hawthorne Open Space Private, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018009 Hawthorne Open Space Private, Developed Lot Pads And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018018 Hawthorne Open SpacePrivate, Developed Lot Fare; And Recreation 2-15, Dominguez Channel WatersM1M Management Group Dominguez 4149018029 Hawthorne Open Space Private, Developed Lot Pads And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030022 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1M Management Group Dominguez 4138030029 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018014 Hawthorne Open Space Private, Developed Lot Pads And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018019 Hawthorne Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030090 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 41M030082 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1d Management Group Dominguez 4149018012 Headroom Open SpacePrivate, Developed Lot Pads And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018028 Hawthorne Open Space Private, Developed Lot Paris And Recreation 2-15, Dominguez Channel WatersM1d Management Group Dominguez 4138030028 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel understand! Management Group Dominguez 4149018010 Hawthorne Open Space Private, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030021 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel understand! Management Group Dominguez 41M030069 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1M Management Group Dominguez 4138030083 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018020 Hawthorne Open Space Private, Developed Lot Pads And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030086 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018005 Hawthorne Open Space Private, Developed Lot Pads And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4149018022 Hawthorne Open SpacePrivate, Developed Lot Pads And Recreation 2-15, Dominguez Channel WatersM1d Management Group Dominguez 4138030084 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4149011232 Hawthorne Open SpacePrivate, Developed Lot Pads And Recreation 2-15, Dominguez Channel WatersM1d Management Group Dominguez 4138030WS El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030062 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4143002012 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4143002022 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1M Management Group Dominguez 4143002018 Havalorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4143002021 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1M Management Group Dominguez 4143002019 Hawthorne Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4143002016 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2422008011 Ins Angeles Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 404800,1055 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watersnal Management Group Dominguez 40480.00054 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 40MOM056 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 401 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 401 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4055006012 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4055008013 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4055021012 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1M Management Group Dominguez 4141016026 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4141016088 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4141016024 Hawthorne Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4141015064 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4141016082 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4141016022 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4141016086 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1d Management Group Dominguez 4141016025 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4141016029 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4141016028 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4141016090 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1M Management Group Dominguez M52031034 Los Angeles Comply Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4052031035 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1M Management Group Dominguez 4052031032 Los Angeles County Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA/ 140424 Draft program Environmental Impact Report 15 January 2015 Appendix EWMP supposed BMP and prionry Project Data Region Apn Jurisdiction/City Land Use Type Address Figure Number and lUitk Dominguez 4051020028 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 405101]00] Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez E08902907 Los Angeles Open Space Private, Developed Led ParNS And Recreation 2-1S, Dominguez Channel Watershed Management Group Dominguez 4071018018 Gardena Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4071018019 Gardena Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 11051031M3 Hawthorne Open Space Private, Developed Lot ParNS And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4051030010 Hawthorne Open SpacePrivate, Developed Lot Par%Antl Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4051030011 Hawthorne Open Space Private, Developed Lot ParNSAnd Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4051031004 Hawthorne Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed! Management Group Dominguez 4051032000 Hawthorne Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4051031007 Hawthorne Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 6129001035 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez ONW2029 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7425011803 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 6079002028 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7425011805 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138012004 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138015007 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138015008 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030028 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030035 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 41380300D El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030044 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030025 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030057 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 413 8 0 3 0 013 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030045 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030034 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030054 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030056 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030046 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030026 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030032 El Segundo Open Space Private, Vant Undifferentiated 2-15, Domingun Channel Watershed Management Group Dominguez 4138030012 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030055 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4143007015 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4057032801 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030049 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030051 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030039 El Segundo Open Space Private, Vant Undifferentiated 2-1S, Dominguez Channel Watershed Management Group Dominguez 4138030040 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030037 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030050 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030052 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030038 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030041 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030048 El Segundo Open Space Private, Vault Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4143007020 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030024 El Segundo Open Space Private, Vault Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030015 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030036 El Segundo Open Space Private, Vant Undifferentiated 2-1S, Dominguez Channel Watershed Management Group Dominguez 4138030053 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030022 El Segundo Open Space Private, Vant Undifferentiated 2-1S, Dominguez Channel Watershed Management Group Dominguez 4140016163 Ins Angeles Open Space Private, Other Open Spare And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4138030013 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 6079002064 Ins Angeles Comply Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4055000019 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4048004043 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4008004053 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4057031039 Ins Angeles Open Space Private, Vault Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4048004058 Hawthorne Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4048004051 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4048004052 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028121 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028117 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028129 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028146 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028118 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028143 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028157 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028ll1 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028127 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028136 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028122 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028II4 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028123 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028US Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028120 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028145 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028116 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028130 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028"4 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028128 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028135 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028139 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028156 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028119 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 744202M6 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028140 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028142 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028155 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028132 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028149 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028138 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028133 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group W County Flood Control District Enhanced Watershed Management Premiums ESA/ 140474 Draft Program Environmental Impact Report 16 January 2015 Appendix EWMP Purposed BMP and Priority Project Data Region Apn Jurisdiction/City Land Use Type Address Figure Number and rdle Dominguez 2002028147 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442028144 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442028153 Los Angeles Open Space Private, Vant Area 2-1S, Dominguez Channel Warmest" Management Group Dominguez 2442028154 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442028148 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442028150 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442028132 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442028152 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442028158 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 74420ID23 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Waterman] Management Group Dominguez 240201033 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442028]51 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442028141 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442001009 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 744201024 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 744201010 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442001002 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442001022 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442004018 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442005008 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442005023 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442005016 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 74420DS017 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442005001 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442004012 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442005009 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442004016 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 74420DS022 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2412022009 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2412022008 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2412026021 Ins Angeles Open SpacePrivate, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4055006018 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2442009018 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442009019 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Waterman] Management Group Dominguez 2442033003 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033008 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033005 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033030 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033004 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033013 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033019 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033021 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033034 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033026 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033035 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033010 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033015 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033012 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033012 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033031 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033025 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Warmest" Management Group Dominguez 2442033006 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033036 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033033 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033002 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033009 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Waterman] Management Group Dominguez 2442033022 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033014 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Waterman] Management Group Dominguez 2442033022 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033002 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033018 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033032 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033024 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033020 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033011 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033028 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033029 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033016 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033023 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033040 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033049 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033051 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033046 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033042 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033048 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033052 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033039 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033043 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033050 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033038 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033042 San Pedro Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033044 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Waterman] Management Group Dominguez 2442033045 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033053 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033055 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033041 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033066 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030143 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030150 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033062 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033063 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030146 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030142 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033058 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030142 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA/ 140424 Draft Program Environmental Impact Report 17 January 2015 Appendix EWMP Purposed BMP and Priority Project Data Region Apn Jurisdiction/City Land Use Type Address Figure Number and rdle Dominguez 2002033060 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002030144 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030145 Los Angeles Open Space Private, Vant Area 2 -IS, Dominguez Channel Warmest" Management Group Dominguez 2442033020 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033061 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033052 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033068 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030152 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033069 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030153 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Waterman] Management Group Dominguez 2442033060 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033065 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033062 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030149 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030151 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030168 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033054 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030122 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030129 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030196 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030192 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030148 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030122 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030184 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030156 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030160 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030192 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030165 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030190 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030201 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030154 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030186 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030203 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030163 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030180 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030194 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030198 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033059 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030166 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030123 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030202 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030162 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030181 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030195 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030125 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030182 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030193 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030200 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030161 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030164 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030128 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Warmest" Management Group Dominguez 2442030183 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030169 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030121 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030]88 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030152 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030120 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030182 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030189 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030159 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030191 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030124 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030126 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442030158 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030162 San Pedro Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442030199 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033032 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033025 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033022 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033084 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033031 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033035 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033101 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 7442030US Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033030 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033092 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033039 Ins Angeles Open Space Private, Vant Area 215, Dominguez Channel Watershed! Management Group Dominguez 2442033024 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033026 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033056 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033090 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 7442033W1 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033034 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033103 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033029 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033022 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033028 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033036 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033032 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033033 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033100 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033102 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033082 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033089 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033082 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 14M24 Draft Program Environmental Impact Report 1g January 2015 Appendix EWMP Purposed BMP and Priority Project Data Region Apn Jurisdiction/City Land Use Type Address Figure Number and rdle Dominguez 200203303 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002033088 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2402033095 Los Angeles Open Space Private, Vant Area 2 -IS, Dominguez Channel Warmest" Management Group Dominguez 2002033304 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033083 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033038 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershetl Management Group Dominguez 7442030155 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2448036021 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033021 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033120 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Waterman] Management Group Dominguez 2442033122 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033115 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033119 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033109 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033122 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033116 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033114 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershetl Management Group Dominguez 2442033126 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033102 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Waterman! Management Group Dominguez 7442033118 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033n2 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442033113 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033130 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033131 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442033UI Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033124 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033112 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442033117 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033108 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033110 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442033US Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033123 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 244203309 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033106 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033086 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033111 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2442033128 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2445012048 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442033305 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2460004015 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2449014023 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2412003043 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2412003045 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershetl Management Group Dominguez 2446006014 San Pedro Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 744600SWI Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2412003046 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2412003044 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2449014020 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2449014028 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2449014033 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2449014022 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Warmest" Management Group Dominguez 2449014029 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2449014032 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2412003042 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2449014030 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2449014032 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2442028004 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2449014035 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2449014034 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2449014026 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2442028005 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2449014031 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2449014025 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2449014036 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442028003 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Waterman! Management Group Dominguez 2449014038 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2412003048 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman! Management Group Dominguez 7417003049 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2413033050 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413033043 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2413033044 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413033048 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413033042 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2413033042 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 241303306 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413033046 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413033053 Los Angeles Open Space Private, Vant Undifferentiated 215, Dominguez Channel Watershed! Management Group Dominguez 2413033064 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman! Management Group Dominguez 2413033055 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413033081 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2442028010 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2413033049 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2442028002 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2413033058 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413033028 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442028012 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2413033059 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413033022 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442028014 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershetl Management Group Dominguez 2413033061 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413033025 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2442028015 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2413033062 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413033051 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2413033066 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 14M24 Draft Program Environmental Impact Report 19 January 2015 Appendix EWMP Purposed RMP and Priority Project Data Region Apn Jurisdiction/City Land Use Type Atltlress Figure Number and rdle Dominguez 2013033060 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2013033026 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028016 Los Angeles Open Space Private, Vant Area 2 -IS, Dominguez Channel Watershed] Management Group Dominguez 2009010020 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2013033023 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028009 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028011 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2013033020 Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028018 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028020 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Waterman] Management Group Dominguez 2002028012 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028019 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2013033062 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028028 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2013033063 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028022 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2013033056 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028030 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028036 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2013033052 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2013033021 Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 2013033029 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028032 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028025 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028038 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2002028002 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2013033069 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028008 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028000 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2013033090 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028022 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028001 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028021 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028006 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028005 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028030 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2002028008 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028031 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028009 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2013033020 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028035 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2013033068 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028013 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028050 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028026 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028000 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028003 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2002028052 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2013033050 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2013033065 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2002028020 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2002028039 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2002028032 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028033 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028002 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028029 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028050 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028053 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028051 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2012003002 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2002028056 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2056011800 Los Angeles Open SpacePrivate, Developed Led Partys And Recreation 2-15, Dominguez Channel Watershed! Management Group Dominguez 2013033052 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028006 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2056012800 Ins Angeles Open Space Private, Developed] Lot Palls And Recreation 2-15, Dominguez Channel Watershed] Management Group Dominguez 2056012020 Ins Angeles Open SpacePrivate, Developed] Lot Par%Antl Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028023 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2002028055 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2006010021 Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 2006015001 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2006012003 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2006015002 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2006012000 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2006012006 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2002028058 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028060 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028060 Ins Angeles Open Space Private, Vant Area 215, Dominguez Channel Watershed Management Group Dominguez 2002028021 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2002028066 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028020 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2005018053 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028062 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028068 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028059 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2002028061 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028063 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028062 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028069 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028WS Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028023 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028026 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group Dominguez 2002028029 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028080 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028028 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028091 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed] Management Group W County Flood Control District Enhanced] Watershed] Management Programs ESA / 100420 Draft Program Environmental Impact Report 20 January 2015 Appendix EWMP supposed BMP and Priority Project Data Region Apn lurediction/City Land Use Type Address Figure Dumber and rdle Dominguez 200202807 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028095 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028083 Los Angeles Open Space Private, Vant Area 2 -IS, Dominguez Channel Watershed! Management Group Dominguez 2002028088 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028082 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028080 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Waterman! Management Group Dominguez 2002028020 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028086 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028082 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel WatershM Management Group Dominguez 2002028025 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2006018000 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2006018005 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2006012005 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2006012009 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 2002028052 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028022 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershd Management Group Dominguez 2006012008 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman! Management Group Dominguez 2002028030 Ins Angeles Open Space Private, arm Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028032 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028030 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028032 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028105 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel WatershN Management Group Dominguez 2002028035 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028100 San Pedro Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028036 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028091 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Wmerstetl Management Group Dominguez 2002028101 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028093 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028102 Ins Angeles Open Space Private, arm Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028100 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028039 Ins Angeles Open Space Private, arm Area 2-15, Dominguez Channel Armond! Management Group Dominguez 2002WID31 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028038 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel WatershN Management Group Dominguez 2002028103 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Waterman] Management Group Dominguez 2002001032 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2006019021 Los Angeles Open Space Private, Developed Urd Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2002001030 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2002081029 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028102 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Wmerstetl Management Group Dominguez 2002028112 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028111 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 7442028114 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Armor" Management Group Dominguez 2002028109 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028113 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028115 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028089 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002028106 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028110 Ins Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed Management Group Dominguez 2012021023 Los Angeles Open Space Private, Developed Urd Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2002003001 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2002028108 Los Angeles Open Space Private, Vant Area 2-15, Dominguez Channel Watershed! Management Group Dominguez 2002003020 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2055010001 Los Angeles Open Space Private, Developed Lot Par%Antl Recreation 2-15, Dominguez Channel Watershed! Management Group Dominguez 2055010006 Ins Angeles Open Space Private, Developed Lot Palls And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2002009001 Los Angeles Open SpacePrivate, Developed Lot Par%Antl Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2002009003 Los Angeles Open Space Private, Developed Lot Palls And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 7320010038 Lomita Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershN Management Group Dominguez 7320010036 Lomita Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman] Management Group Dominguez 7320010032 Lomita Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2012011006 Ins Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 7320010000 Lomita Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2320010002 Lomita Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 2012009002 Wilmington Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7320010005 Lomita Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 7320010003 Lomita Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7320010009 Lomita Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Armor" Management Group Dominguez 7320010032 Lomita Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7320010039 Lomita Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2012010002 Ins Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2012010026 Ins Angeles Open SpacePrivate, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed! Management Group Dominguez 2012010012 Los Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2012010019 Ins Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2012010022 Los Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2012010010 Los Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 20II010015 Los Angeles Open Space Private, Developed Regional Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2012010012 Los Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2012016003 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2012010023 Ins Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2012010008 Los Angeles Open Space Private, Developed Regional Parks And Recreatlon 2-15, Dominguez Channel Watershed Management Group Dominguez 2012010009 Los Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2012016006 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2012010WS Los Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Waterman] Management Group Dominguez 74UO10021 Ins Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2012010018 Los Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 74UO10020 Ins Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 74UO16WS Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2012010020 Los Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Wmersted Management Group Dominguez 20II010011 Los Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershd Management Group Dominguez 2012016009 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman! Management Group Dominguez 2012010016 Los Angeles Open Space Private, Developed Regional Parks And Recreatlon 2-15, Dominguez Channel Armor" Management Group Dominguez 2012016002 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman] Management Group Dominguez 2012016000 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2012010000 Los Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2012016W1 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2012010010 Los Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Waterman] Management Group W County Flood Control District Enhanced Amended Management Programs ESA / 10M20 Draft Program Environmental Impact Report 21 January 2015 Appendix EWMP Proposed BMP and Priodty Project Data Region Apn Juriniction/City Land Use Type Atltlress Figure Dumber and rdle Dominguez 2012015003 Los Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Aderhold Management Group Dominguez 2012014025 Los Angeles Open Space Private, Developed Regional Parks And Permanent 2-15, Dominguez Channel Watermed Management Group Dominguez 74VOI6010 Los Angeles Open Space Private, Vant Undifferentiated 2 -IS, Dominguez Channel Watershed Management Group Dominguez 2412016011 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 2412016012 Los Angeles Open Space Private, Vant Undifferentiated 215, Dominguez Channel Watershed Management Group Dominguez 2412014013 Ins Angeles Open Space Private, Developed Regional Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 7324014041 Inmita Open Space Private, Vant Undifferentiated 215, Dominguez Channel Watershed Management Group Dominguez 7412012WI Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterms" Management Group Dominguez 2462010010 Ins Angeles Open SpacePrivate, Developed Lot Parks And Recreation 2-15, Dominguez Channel WatershN Management Group Dominguez 2462010023 Los Angeles Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Waterms" Management Group Dominguez 2462011019 Ins Angeles Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2462011002 Ins Angeles Open Space Private, Developed Let Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2462011023 Ins Angeles Open SpacePrivate, Developed Lot Parks And Recreation 2-15, Dominguez Channel Warren" Management Group Dominguez 2462010011 Los Angeles Open Space Private, Developed Let Parks And Recreation 2-15, Dominguez Channel Watershd Management Group Dominguez 2462010003 Los Angeles Open SpacePrivate, Developed Lot Paris; And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2462011020 Los Angeles Open SpacePrivate, Developed Let Paris And Recreation 2-15, Dominguez Channel Watershd Management Group Dominguez 2462011022 Ins Angeles Open Space Private, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2462011024 Los Angeles Open SpacePrivate, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2462011008 Ins Angeles Open Space Private, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026166 Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026168 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026154 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2439026123 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026153 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Warren" Management Group Dominguez 2439026120 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026163 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Warren" Management Group Dominguez 2439026152 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026155 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026122 Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026165 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026151 Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026126 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026160 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershN Management Group Dominguez 2439026162 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026125 Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2439026122 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026162 Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026128 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 2439026159 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026149 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 2439026124 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026161 Los Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026164 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026158 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2439026169 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026156 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2439026121 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026150 Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026152 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026]80 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Warren" Management Group Dominguez 2442020030 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2442018018 Los Angeles Open SpacePrivate, Other Open Space And Recreation 2-15, Dominguez Channel Warren" Management Group Dominguez 2442020029 Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2442020032 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2442020028 Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2442018012 Los Angeles Open Space Private, Other Open Spam And Recreation 2-15, Dominguez Channel Warren" Management Group Dominguez 2442020009 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2439026183 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Wmerhetl Management Group Dominguez 7439026 US Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Warren" Management Group Dominguez 2439026184 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026186 Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Warren" Management Group Dominguez 2442020031 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 2439026129 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2439026182 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 2455021042 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 245502ID43 Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 245502ID39 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021046 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021050 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021051 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021038 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021040 Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 245502106 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021042 Los Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021051 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 2455021066 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021041 Los Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021058 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021056 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021036 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021053 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2455021052 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Wmerhetl Management Group Dominguez 2455021064 Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021062 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021044 Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021032 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021055 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021059 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 2455021063 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021WS Ins Angeles Open Space Private, arm Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021062 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021052 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Ancestor! Management Group Dominguez 2455021050 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021054 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2439026181 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 140624 Draft Program Environmental Impact Report 22 January 2015 Appendix EWMP Purposed RMP and Priority Project Data Region Apn Jurisdiction/City Land Use Type Atltlress Figure Number and rdle Dominguez 205502101 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2055021082 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2055021020 Los Angeles Open Space Private, Vant Undifferentiated 2 -IS, Dominguez Channel Watershed] Management Group Dominguez 2055021022 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021026 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021023 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021080 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021022 Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021029 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021081 Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Waterman] Management Group Dominguez 2455021069 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021024 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021025 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021028 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021084 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021085 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021089 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021096 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021088 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 745502INS Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021032 Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021031 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021034 Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021108 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021109 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021086 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021103 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021116 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 245502ID99 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021120 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021II2 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021lll Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021110 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021104 Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021106 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7455021115 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021082 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021049 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021102 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021114 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021038 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021305 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021123 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021032 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021093 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021111 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021II5 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021101 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2 4 55 0 2 1118 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 245502ln5 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021113 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021112 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2 4 55 0 2 1119 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021132 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7455021OO Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021129 Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021102 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021121 Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021126 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021II2 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021133 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021112 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021130 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021124 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021149 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021068 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021128 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021143 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021VO Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021138 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021140 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021145 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021146 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021142 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021144 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021151 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021154 Ins Angeles Open Space Private, Vant Undifferentiated 215, Dominguez Channel Watershed! Management Group Dominguez 2455021139 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021150 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 245502153 Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021142 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021141 Los Angeles Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 2439001006 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021148 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 2455021083 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021100 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2455021134 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2462029011 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2455021136 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2448004012 Ins Angeles Open SpacePrivate, Other Open Space And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2413021032 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 244800,1011 Ins Angeles Open SpacePrivate, Other Open Space And Recreation 2-15, Dominguez Channel Watershed! Management Group Dominguez 2448005008 Los Angeles Open Space Private, Other Open Space And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2448002003 Ins Angeles Open SpacePrivate, Other Open Space And Recreation 2-15, Dominguez Channel Watershed! Management Group Dominguez 2448002005 Los Angeles Open Space Private, Other Open Space And Recreation 2-15, Dominguez Channel Watershed] Management Group W County Flood Control District Enhanced] Watershed] Management Programs ESA / 140,174 Draft Program Environmental Impact Report 23 January, 2015 Appendix EWMP summer! BMP and Prionty Project Data Region Apn Jurisdiction/City Land Use Type Mdress Figure Number and TRIP Dominguez 2448005002 San Pedro Open Space Private, OtherOpen Space And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2448002002 Los Angeles Open Space Private, Other Open Space And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2448005002 Los Angeles Open Space Private, Other Open Space And Recreation 2 -IS, Dominguez Channel Watershed! Management Group Dominguez 2448002001 Los Angeles Open Space Private, Other Open Space And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2448004012 Ins Angeles Open Space Private, Other Open Spare And Recreation 215, Dominguez Channel Watershed Management Group Dominguez 2448002004 Ins Angeles Open Space Private, Other Open Spare And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2448004015 Ins Angeles Open Space Private, Other Open Spare And Recreation 215, Dominguez Channel Watershed Management Group Dominguez 74UWSWS Los Angeles Open Space Private, Other Open Spam And Recreation 2-15, Dominguez Channel Watershed! Management Group Dominguez 2448005006 Ins Angeles Open Space Private, Other Open Space And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2448002006 Los Angeles Open Space Private, Other Open Spam And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2448005003 Ins Angeles Open Space Private, Other Open Space And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 2448005004 Ins Angeles Open Space Private, Other Open Space And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 244800,1013 Ins Angeles Open SpacePrivate, Other Open Space And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 7350W7020 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350002018 Los Angeles Comity Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350002012 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350002019 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350002016 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350002045 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 24]3024008 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7351034022 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7351034028 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024063 Ins Angeles Open Space Private, Vault Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024066 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024062 Ins Angeles Open Space Private, Vault Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024089 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024WS Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024092 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024052 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024034 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024096 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 24n024111 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 24nO24113 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024061 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024038 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024035 Los Angeles Open Space Private, Vault Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024064 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024039 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7413024106 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024091 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 74 13 0 2 4110 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024091 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024033 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413@4010 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 74 13 0 2 410 8 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024083 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7413024101 Los Angeles Open Space Private, Vault Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024084 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024088 Los Angeles Open Space Private, Vault Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024082 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7413024104 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024105 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024055 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024102 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024082 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024086 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 24nO24100 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024309 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024102 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7413024103 Los Angeles Open Space Private, Vault Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024032 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7413024112 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2413024090 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7413024114 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 24HO36021 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7346019033 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7346019032 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2346019034 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350015043 Los Angeles Comity Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350015053 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350016015 Torrance Open Space Private, Vault Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350015056 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350015042 Ins Angeles County Open Space Private, Vault Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350016014 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350016004 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350016020 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350016025 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 73MOISW1 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350016002 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350016WS Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350016018 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350016022 Ins Angeles Coumy Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350015051 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350016012 Torrance Open Space Private, Vault Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350015052 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350016036 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350016038 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350015052 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350016019 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350016026 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350016041 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350016032 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7342001002 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350016016 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350016029 Los Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 140,124 Draft Program Environmental Impact Report 24 January 2015 Appendix EWMP Proposed BMP and Priority Project Data Region Apn Jurisdiction/City Land Use Type Atltlress Figure Number and Tile Dominguez 2350016033 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2350015055 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350016012 Torrance Open Space Private, Vant Undifferentiated 2 -IS, Dominguez Channel Watershed! Management Group Dominguez 2350016030 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 2350015005 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350015009 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2350016031 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350015058 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350016003 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2350016028 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman] Management Group Dominguez 7350016035 Ins Angeles Comity Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman] Management Group Dominguez 7350016030 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350015050 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman] Management Group Dominguez 7350015059 Los Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2302001033 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7302001035 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2350015050 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 23420D1D30 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350015006 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 7350015048 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350016032 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350012032 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 7350012038 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350012040 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman] Management Group Dominguez 7350018005 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350012039 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 7350012036 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350018002 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350018003 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350012035 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2350018001 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7350018000 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 7350018006 Torrance Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 7351002033 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 200300003 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2003009002 Los Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 200900020 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2403009001 Los Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2400009005 Los Angeles Comity Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2403009006 Los Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 200309'004 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2452024011 San Pedro Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2052025018 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2052032001 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2052032016 Los Angeles Comity Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2052032008 Ins Angeles Comity Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 7342018054 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2052033012 San Pedro Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2452033031 Los Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7SM026035 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 7SM026038 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2500028001 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2559022WS Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559022013 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559022008 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559022001 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559022012 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2559022019 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559022011 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2559073005 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559022014 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559022000 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2559022006 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559022012 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2559023003 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2559023010 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559023002 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2559023009 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2559022016 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559023010 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2559073006 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2559073002 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559023013 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2559022021 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559023011 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2559022009 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559022020 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559022002 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2559023000 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559022015 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559023001 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2559023008 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559028036 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559022018 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2559073012 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2562012008 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2562012011 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2562012013 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2562012015 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2562012009 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2562012002 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2562012012 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2562012010 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 2562012010 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershM Management Group Dominguez 2562012001 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 14M24 Draft Program Environmental Impact Report 25 January 2015 Appendix EWMP supposed RMP and Priority Project Data Region Apn Jurisdiction/City Land Use Type Address Figure Number and Tithe Dominguez 2562012006 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 2562012003 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Wateir" Management Group Dominguez 2562012000 Los Angeles Open Space Private, Vant Undifferentiated 2-1S, Dominguez Channel Watershed Management Group Dominguez 2562012WS Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Wateir" Management Group Dominguez 2562026008 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 6132001003 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman] Management Group Dominguez 6132002001 Ins Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021002 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 0025021005 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021006 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021008 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021015 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021016 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021012 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershel Management Group Dominguez 0025021023 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021010 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershel Management Group Dominguez 4025021022 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021013 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021024 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman] Management Group Dominguez 4025021022 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021011 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4 0 25 0 2 1014 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021021 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021012 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021019 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021018 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021020 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021009 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021056 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021008 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021052 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021002 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4 0 25 0 2105 0 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 00250210/9 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021050 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021052 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021053 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021051 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021020 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021020 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021055 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez Q250210S Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021022 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021064 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021061 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4 0 25 0 2103 5 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021062 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021023 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021069 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021100 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021059 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021063 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021060 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021008 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025021101 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021119 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez Qn021UO Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022WS Inglewood Open Space Private, Developed Lot Partys And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022001 Inglewood Open Space Private, Developed Lot Partys And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022013 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022012 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022002 Inglewood Open SpacePrivate, Developed Led Partys And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022014 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022008 Inglewood Open SpacePrivate, Developed Led Partys And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022015 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022011 Inglewood Open Space Private, Developed Led Par%Antl Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022012 Inglewood Open Space Private, Developed Lot Partys And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022010 Inglewood Open SpacePrivate, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022016 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022019 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022003 Inglewood Open Space Private, Developed Led Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022020 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022009 Inglewood Open Space Private, Developed Led Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022018 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022006 Inglewood Open Space Private, Developed Led Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022025 Inglewood Open SpacePrivate, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022034 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022022 Inglewood Open Space Private, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022033 Inglewood Open Space Private, Developed Led Par%Antl Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022029 Inglewood Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022030 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022023 Inglewood Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 0025021058 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022020 Inglewood Open Space Private, Developed Led Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022031 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022035 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 0025022028 Inglewood Open SpacePrivate, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022032 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022026 Inglewood Open Space Private, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022022 Inglewood Open Space Private, Developed Led Par%Antl Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022002 Inglewood Open Space Private, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022004 Inglewood Open SpacePrivate, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022032 Inglewood Open Space Private, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022002 Inglewood Open SpacePrivate, Developed Lot Paris And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 0025023002 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 1OM24 Draft Program Environmental Impact Report 26 January 2015 Appendix EWMP Proposed RMP and Plenty Project Data Region Apn lurediction/City Land Use Type Address Figure Number and rdle Dominguez 4025023009 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023010 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023019 Inglewood Open Space Private, Vant Undifferentiated 2-1S, Dominguez Channel Watershed Management Group Dominguez 4025022021 Inglewood Open SpacePrivate, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watermed Management Group Dominguez 4025023020 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023003 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023021 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022046 Inglewood Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershetl Management Group Dominguez 1025023015 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatershN Management Group Dominguez 4025023005 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4025023002 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023022 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022040 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022045 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4025023016 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023004 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4025023008 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershetl Management Group Dominguez 4025023023 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022043 Inglewood Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 1025023014 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022044 Inglewood Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel Watershed! Management Group Dominguez 1025023013 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023012 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023012 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022039 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023011 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4025023018 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023001 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023006 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023030 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman Management Group Dominguez 4025023031 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023058 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman! Management Group Dominguez 4025023025 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023034 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4025023063 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023020 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023029 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023032 Inglewood Open Space Private, Vant Undifferentiated 2-1S, Dominguez Channel Watershd Management Group Dominguez 4025024001 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023022 Inglewood Open Space Private, Vant Undifferentiated 2-1S, Dominguez Channel Watershd Management Group Dominguez 4025023062 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman Management Group Dominguez 4025023061 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023068 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershetl Management Group Dominguez 4025023029 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024WS Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4025023033 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023026 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4025024006 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 402502309 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023080 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023056 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 4025024008 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023025 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershd Management Group Dominguez 4025023028 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023021 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023026 Inglewootl Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023035 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023050 Inglewootl Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024002 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025022036 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025023059 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024016 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4025024025 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024019 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4025024010 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman! Management Group Dominguez 4025024022 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024012 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman! Management Group Dominguez 4025024023 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez W25024020 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4025024022 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024013 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4025024015 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024014 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4025022038 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024024 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 4025024026 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024012 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024021 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterman! Management Group Dominguez 4025024018 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez W25023024 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed! Management Group Dominguez 40 25 02 4 03 1 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024040 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024035 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024036 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024030 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024032 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024034 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024041 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024011 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024032 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024039 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024061 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024038 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024063 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024020 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 140624 Draft Program Environmental Impact Report 27 January 2015 Appendix EWMP Proposed RMP and Priority Project Data Region Apn lurediction/City Land Use Type Address Figure Number and rdle Dominguez 4025024072 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 4025024095 Inglewood] Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024037 Inglewood Open Space Private, Vant Undifferentiated 2-1S, Dominguez Channel Watershed Management Group Dominguez 4025024029 Inglewood] Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024065 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024045 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 4025024042 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025012 Inglewood] Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 1025025015 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024069 Inglewood] Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 4025024062 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025014 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 4025024071 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 4025024036 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024025 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024034 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025011 Inglewood] Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 4025025013 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024067 Inglewood] Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025037 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024033 Inglewood] Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed] Management Group Dominguez 4025024066 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024102 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025036 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 4025024073 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025003 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 4025025039 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024068 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024100 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025001 Inglewood] Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025038 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025046 Inglewood] Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024039 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4024009004 Inglewood] Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024064 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025048 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025009 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025041 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024074 Inglewood] Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025010 Inglewood Open Space Private, Vant Undifferentiated 2-1S, Dominguez Channel Watershed Management Group Dominguez 4025025044 Inglewood] Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025002 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025045 Inglewood] Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 40250250D Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025007 Inglewood] Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025040 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 402502SO42 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 402409'003 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025024028 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 4025025065 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed] Management Group Dominguez 4025025067 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4024009030 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025066 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025063 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025069 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025070 Inglewood] Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025071 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4025025043 Inglewood] Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 4030001011 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez Q300ID13 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4030001012 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez QMW2057 Inglewood Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4039014028 Los Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4039014026 Lennox Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4039014030 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4018024038 Inglewood Open SpacePrivate, Developed] Lot Parka And Recreation 2-15, Dominguez Channel Watershed Management Group Dominguez 73]8010041 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7318W9II6 Ins Angeles Comity Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 73M011071 Dominguez Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 73]8011073 Dominguez Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7 318 01180 9 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 73 M 019 0 3 5 rumn Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 73]8019010 Rancho Dominguez Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7318019044 Rancho Dominguel Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 73]8010027 Rancho Dominguez Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7318020007 Dominguez Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7318019046 Los Angeles Comity Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7318020009 Dominguez Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7318020008 rpm Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7318019043 Compton Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 73]8020011 rson Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 73]8020014 Dominguez Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 7318020013 Dominguez Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7318073046 Los Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7318073044 Ins Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez E079002081 Los Angeles County Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 7440012805 Los Angeles Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138015044 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138015049 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138015039 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138015040 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138015046 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138015054 El Segundo Open Space Private, Vant Undifferentiated] 2-15, Dominguez Channel Watershed Management Group Dominguez 4138015041 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group Dominguez 4138015038 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Watershed Management Group W County Flood Control District Enhanced] Watershed Management Programs ESA / 140674 Draft Program Environmental Impact Report 28 January 2015 Appendix EWMP Proposed BMP and Puri Project Data Region Apo Jurisdiction/City Land Use Type Address Figure Number and rdle Dominguez 4138015053 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 41380150,17 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 41380150,18 El Segundo Open Space Private, Vant Undifferentiated 2-1S, Dominguez Channel Watershed Management Group Dominguez 4138015051 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 4138015050 El Segundo Open Space Private, Vad: Undifferentiated 215, Dominguez Channel Wateir" Management Group Dominguez 4138015055 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 4138015052 El Segundo Open Space Private, Vad: Undifferentiated 215, Dominguez Channel Wateir" Management Group Dominguez 4018024007 Inglewood Open Space Private, Developed Lot Parks And Recreation 2-15, Dominguez Channel understand Management Group Dominguez 4138015059 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1M Management Group Dominguez 41380150,13 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel understand Management Group Dominguez 4138015800 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1M Management Group Dominguez 4138015058 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 4138015060 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 413801507 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1d Management Group Dominguez 4138015006 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel Waterms" Management Group Dominguez 4138015033 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1d Management Group Dominguez 4138015005 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 4138015012 El Segundo Open Space Private, Vad: Undifferentiated 2-15, Dominguez Channel Armor" Management Group Dominguez 4138015014 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 41380150,12 El Segundo Open Space Private, Vant Undifferentiated 2-15, Dominguez Channel WatersM1M Management Group Dominguez 4138003900 El Segundo Open Space Private, Government Offices 2-15, Dominguez Channel Watershed Management Group Dominguez 4138002905 El Segundo Open Space Private, Base Government Offices 2-15, Dominguez Channel WatersM1N Management Group Dominguez 4035026906 Hawthorne Open Space Private, Government Offices 2-15, Dominguez Channel Watershed Management Group Dominguez 4035026904 Hawthorne Open Space Private, Government Micas 2-15, Dominguez Channel Watershed Management Group Dominguez 4057032908 Hawthorne Open Space Private, Other Public Facilities 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 4138002904 El Segundo Open Space Private, Base Government Offices 2-15, Dominguez Channel Waterms" Management Group Dominguez 4035026905 Hawthorne Open Space Private, Government Offices; 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 4049016900 Hawthorne Open Space Private, Other Public Facilities 2-15, Dominguez Channel WatersM1ed Management Group Dominguez WS7032906 Hawthorne Open Space Private, Other Public Facilities 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 4035026907 Hawthorne Open Space Private, Government Off 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 4035026908 Hawthorne Open Space Private, Government Offices 2-15, Dominguez Channel Watershed Management Group Dominguez 4041015901 Hawthorne Open Space Private, Government Offices 2-15, Dominguez Channel Watershed Management Group Dominguez 4049009904 Hawthorne Open Space Private, Other Public Facilities 2-15, Dominguez Channel WatersM1N Management Group Dominguez 7451015901 Los Angeles Open Space Private, Government Offices 2-15, Dominguez Channel Watershed Management Group Dominguez 7451020902 Ins Angeles Open Space Private, Government Offices 2-15, Dominguez Channel WatersM1M Management Group Dominguez 7451020900 Los Angeles Open Space Private, Government Offices 2-15, Dominguez Channel WatersM1ed Management Group Dominguez 7451020901 Ins Angeles Open Space Private, Government Micas 2-15, Dominguez Channel understand Management Group Dominguez 7455025909 Los Angeles Open Space Private, Government Offices 2-15, Dominguez Channel WatersM1d Management Group Dominguez 7455025910 Los Angeles Open Space Private, Government Offices 2-15, Dominguez Channel WatersM1d Management Group Dominguez 7455025901 Los Angeles Open Space Private, Government Offices 2-15, Dominguez Channel WatersM1d Management Group Dominguez 7455025911 Ins Angeles Open Space Private, Government Officas 2-15, Dominguez Channel WatersM1d Management Group Dominguez 7455025907 Los Angeles Open Space Private, Government Offices 2-15, Dominguez Channel Watersrd Management Group Dominguez 7455025908 Ins Angeles Open Space Private, Government Officas 2-15, Dominguez Channel WatersM1d Management Group Dominguez 7455025906 Ins Angeles Open Space Private, Government Offices 2-15, Dominguez Channel WatersM1d Management Group Dominguez 7455025905 Los Angeles Open Space Private, Government Offices 2-15, Dominguez Channel WatersM1d Management Group Dominguez 7455025904 Ins Angeles Open Space Private, Government Offices 2-15, Dominguez Channel WatersM1d Management Group Dominguez 7455026939 Los Angeles Open Space Private, Government Offices 2-15, Dominguez Channel WatersM1d Management Group Dominguez 7455026900 Ins Angeles Open Space Private, Government Micas 2-15, Dominguez Channel WatersM1d Management Group Dominguez 7374001902 Inglewood Open Space Private, Government Offices 2-15, Dominguez Channel Watershed Management Group Dominguez 7374001904 Inmim Open Space Private, Government Offices 2-15, Dominguez Channel Armored! Management Group Dominguez 737,1001908 Lomita Open Space Private, Government Offices; 2-15, Dominguez Channel Watershul Management Group Dominguez 6132014902 Los Angeles Comity Open Space Private, Government Offices 2-15, Dominguez Channel WatersM1d Management Group Dominguez 6132016903 Ins Angeles Open Space Private, Government Offices 2-15, Dominguez Channel Watershed Management Group Dominguez 6130003900 Ins Angeles Open Space Private, Other Public Facilities 2-15, Dominguez Channel WatersM1d Management Group Dominguez W790SWI Ins Angeles Open Space Private, Government Offices 2-15, Dominguez Channel Watersrd Management Group Dominguez 60790.01901 Los Angeles Open Space Private, Government Officas 2-15, Dominguez Channel understand Management Group Dominguez 60790.01903 Ins Angeles Comity Open Space Private, Government Offices 2-15, Dominguez Channel WatersM1d Management Group Dominguez 6079006904 Los Angeles Open Space Private, Government Officas 2-15, Dominguez Channel WatersM1d Management Group Dominguez 60790.00902 Ins Angeles Open Space Private, Government Micas 2-15, Dominguez Channel Watershd Management Group Dominguez 4124002916 Los Angeles Open Space Private, Other Public Facilities 2-15, Dominguez Channel WatersM1d Management Group Dominguez 7440022913 Ins Angeles Open Space Private, Government Micas 2-15, Dominguez Channel Watershd Management Group Dominguez 7440027917 Los Angeles Open Space Private, Government Offices; 2-15, Dominguez Channel WatersM1d Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 140174 Draft program Environmental Impact Report 29 January 2015 Appendix EWMP proposed BMP and priority project Data Region Apn luredictioll IaM Use Type Address Figure Number and Title Beach Cities Fwmp Beach Cities No Hermosa Beach 1315 Valley Dr., Hermosa Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Hermosa Beach 425 Valley Dr., Hermosa Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Manhattan Beach 1998 N Valley Dr., Manhattan BeacM1 2-7, Beach Cities Watershed Management Group Beach Cities No Manhattan Beach Manhattan Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Manhattan Beach 1701 N Herrin Ave., Manhattan Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Redondo Beach 801 mine Real, Redondo Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Redondo Beach 2723 Alvoul In., Redondo Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Redondo Beach ISO Flagler Ln., Redondo Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Redondo Beach 15ea Hawk Way, Redondo Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Redondo Beach 303 Esplanade, Redondo Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Torrance 3141 Torrance Blvd, Torrance 2-7, Beach Cities Watershed Management Group Beach Cities No Hammel And The Strand Mumma And The Strand 2-7, Beach Cities Watershed Management Group Beach Cities No Hermosa Beach 425 Valley Drive, Hermosa Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Hermosa Beach 526 Gould Ave., Hermosa Beach 2-7, Beach Cities Watershed Management Group Beach Cities No The Strand 28Th 5t And The Strand 2-7, Beach Cities Watershed Management Group Beach Cities No The Strand Strand And 4411r 32Nd St (6 OuHalls) 2-7, Beach Cities Watershed Management Group Beach Cities No The Strand Strand And 2Nd 181th St (9 Cuttings) 2-7, Beach Cities Watershed Management Group Beach Cities No The Strand Strand And 151: 351rh 5t (2 OuUalls) 2-7, Beach Cities Watershed Management Group Beach Cities No Redondo Beach 801 mine Real, Redondo Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Redondo Beach 1801 Rockefeller lane, Redondo Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Torrance 1119 Barbara St., Torrance 2-7, Beach Cities Watershed Management Group Beach Cities No Manhattan Beach Manhattan Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Manhattan Beach 1701 N Herrin Ave., Manhattan Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Manhattan Beach 1701 N Herrin Ave., Manhattan Beach 2-7, Beach Cities Watershed Management Group Beach Cities No Hermosa Beach Hermosa Ave From Herondo To 21Nd 5q Hermoll Beach Cities Watershed Management Group W County Flood Coal District Enhanced Watershed Management Proposes ESA / 140474 Draft Magnum Environmental Impact Report 30 January 2015 Appendix EWMP Proposed BMP and Priority Project Data Region Apo lurediaion/ciy land Use Type Address Figure Number and TRIP Pals Verdes Peninsula Ewmp Palos Verdes No Open Space And Recreation Peppertree Trail 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Ocean Terrace Drive 29, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Forrestal Drive 29, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 1805 Wert 9Th Street 29, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation rings Harhor Drive 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Palos Verdes Drive East 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 3094011awthome Boulevard 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 7040 VQa Del Mar 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation IU200 Valor PI 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Indian Peak Road 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 29301 Haw[home Boulevard 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 212 Von In Cuesta 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Malaga myon Tail 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation open Trail 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Palos Verdes Drive East 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 4N3 Browntleer In 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 1Peppertree Or 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Palos Verdes Drive East 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 1700 Westmont Drive 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 4300 Maritime Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Nike Trail 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 2Park Place 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 28013 Seashell Way 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 65005eamve Drive 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes Na Etlulional Use 30840 Hawlhome Blvtl 2-9, Palos Vertles Peninsula Watershed Management Group Palos Verdes No Edutional Use 30800 Palos Verdes Drive East 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes Na Etlulional Use 200145 Montereina Or 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Edutional Use 20915 Northhay, Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Edutional Use 3050030698 Rue De La Pierre 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Edutional Use 2760827660 Flaming Arrow Dr 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Fortiori Use 6956 Purple Ridge Or 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Edutional Use 32623358 Crest Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Edutional Use 1916 W Crestwood 5t 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Edutional Use 54005598 Diversey, Dr 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Government lnrtiNtlon 3094011aw[home Boulevard 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Golf Course/Country Club 7000 Los Verdes Drive 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Commercial Use 642 Silver Spur Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes Na Commercial Use 5739 Crertridge Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes Na Commercial Use 5837 Crest Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes Na Commercial Use 5741 Crertridge Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 970 Paseo la Cresta 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Del Sol Fire Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 1304 Vma Papaya 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Batting ge Tail 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 2100 Rusifa Ph 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 1729VQa Arriba 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 1525 Von Comnel 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Valinami South Frei 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 100115N Volta Martinez 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 1536 Von here 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 113199 Von pay 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 1822 Paseo Del Sol 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 15001598 Lower Paseo ha Cresta 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 1274 Vma Coronal 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Von Nivel 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 556558 Paseo Del Mar 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 130113N Von Fernandez 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreatlon 4025 Von Solana 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Pio Pim Hillside Tail 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 796804 Visa Del Monte 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 1516 Paseo In Cresta 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 1408 Chelsea Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation In Selva Path 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Torrence Utility Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 170117N Lower Paseo In Cresta 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Come Path 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Torrance Utility Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Telephone Pole Tail 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 1016 Von Venturi 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 2008 VQa Fernandez 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Torrence Utility Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Torrence Utility Rd 29, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Torrence Utility Rd 29, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 2216 Von Anam 29, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 300 Palos Verdes Or W 29, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Upper In Coal Fire Station Trail 29, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 140114N Plaza Francisco 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Torrence Utility Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 63 Malaga Cove Plaza 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 14131499 Von Andres 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 278208 Palos Verdes Or W 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Von Coria 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 22142216 Thorley Ph 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Edulional IndiMion 1000 Palos Verdes Or W 2-9, Paloa Verdes Peninsula Watershed Management Group Palos Verdes No Edutional Institution 301359 Von All 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Etlulional Institution 520 Paseo opera 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Edutional Institution 120112N Von Nogales 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Edulional Institution 3801 Von to Selva 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Edutional Institution 600 Cloyden Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Edulional Institution Von mpesina 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Other Commercial 361399 Tejon Ph 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Golf Course/Country Club 30003298 Paseo Del mpa 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Commercial Use 135 Coronet Plaza 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Commercial Use 23402398 Von Atones 2-9, Palos Verdes Peninsula Watershed Management Group IA Counts Flood Control District Enhanced Watershed Management Programs ESA / 140,174 Draft Program Environmental Impact Report 31 January 2015 Appendix EWMP Proposed BMP and Priority Project Data Region Apn lurediaioNCiy Iand Use Type Address Figure Number and Tisk Palos Verdes No Commercial Use 14401444 VQa COronel 2-9, Palos Verdes Peninsula Admitted Management Group Palos Verdes No Open Space And Recreation 26201 Crenshaw Blvd 2-9, Palos Verdes Peninsula Amended Management Group Palos Verdes No Open Space And Recreation 2300 Bridle Trail 2-9, Palos Verdes Peninsula Amended Management Group Palos Verdes No Open Space And Recreation 31 Peartree to 2-9, Palos Verdes Peninsula Amended Management Group Palos Verdes No Open Space And Recreation 27575 Indian Peak Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation Iighridge Trail 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 501 Indian Peak Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 2E04026,174 Hawthorne 0lvd 2-9, Palos Verdes Peninsula Admitted Management Group Palos Verdes No Open Space And Recreation 4700 Palos Verdes Or N 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Open Space And Recreation 4400 Palos Verdes Dr N 2-9, Palos Verdes Peninsula Admitted Management Group Palos Verdes No Open Space And Recreation Iighridge Rd 2-9, Palos Verdes Peninsula Amended Management Group Palos Verdes No Open Space And Recreation Crenshaw Boulevard 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Etlutional Use Phillip's myon Trail 2-9, Palos Verdes Peninsula Amended Management Group Palos Verdes No Etlutional Use 2711RUIver Spur Road 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Etlutional Use Summer Morning'S Spur Trail 2-9, Palos Verdes Peninsula Attended Management Group Palos Verdes No frictional Use 26944 Rolling Hills Rd 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Etlutional Use Bridle Trail 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Government nstitutor 4045 Palos Verdes Dr N 2-9, Palos Verdes Peninsula Watershed Management Group Palos Verdes No Golf Course/ 270M Palos Verdes Drive East 2-9, Palos Vendes Peninsula Watershed Management Group Palos Verdes No Commercial Use 627 Deep Valley Dr 2-9, Palos Verdes Peninsula Armored Management Group Palos Verdes No Open Space And Recreation 26300 Crenshaw Boulevard 2-9, Palos Verdes Peninsula Admitted Management Group Palos Verdes No Etlutional Use 26000 South Ariemy Drive 2-9, Palos Verdes Peninsula Armored Management Group W Counts Flood Conrad District Enhanced Watershed Management Progams ESA/ 140474 Draft Program Environmental Impact Report 32 January 2015 Appendix EWMP Proposed BMP and Priority Project Data Region Apn lulditic" iry Land Use Type Address figure Number and rdle Rio Hondo/Son Global River Ewmp Rio Hondo Nortbside Park/School 12Th Street Antl Orange Avenue 2-13, Rio Hondo/San Gabriel River Arrested Management Group Rio Hondo gates Park 1St Streetfind Virginia Avenue 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Bonita Park 2Nd Avenue And Bonita Street 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Eisenhower Park 2Nd Avenue And Haven Avenue 213, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Metional Park (Azusa) 3Rd Street And N orange Ave 2-13, Rio Hondo/San Gabriel River Watershetl Management Group Rio Hondo Slauson Park 5Th Street And Pasadena Ave 213, Rio Hondo/San Gabriel River Watershetl Management Group Rio Hondo Arboretum Of Lac Fell Avenue And Colorado Street 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo inim Grove Park/School mine Grove Avenue And 6Th Avenue 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Gordon Sports Park/Schml Central Avenue And Mt. Olive Drive 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Cibus Community College G[ms Avenue And Formill Boulevard 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Utility Easement From Irwindale To lake Ellen South of Arrow He 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Gladstone Park Gladstone Street Antl Pasadena Avenue 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Duarte Park Herbal Drive And Highland Avenue 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Santa Anita Goff Course Huntington Drive And Sane Anita Avenue 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Valleydale Park Lack Ellen Avenue And Gladstone Street 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Rancho Duai Goff Course Las Lomas Road And Hacienda Drive 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Wrigley Way Elementary Las Tunas Drive And Longley Way 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Recreation Park Lemon Avenue And Mountain Avenue 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Memorial Pack Mariposa Avenue Antl Sierra Madre Boulevard 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Pamela Park Maytlee Sbem Antl Goodall Avenue 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Spreading Grounds Meridian Street And Tifal Avenue 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Bailey nyon Park Oak Crest Drive And debr Avenue 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo LGarcia Pack Olive Avenue And Mayflower Avenue 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Library Park Palm Avenue And Myrtle Avenue 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Peck Road Park Park Road And Rio Hondo Parkway 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Royal oaks Park Royal Oaks Drive And Vineyard Ave 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Highland Oaks Elementary Santa Anita Avenue And Virginia Drive 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Pioneer Park Sierra Madre Avenue And Dalton Avenue 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Azusa Greens Country Club Sierra Madre Avenue And Todd Avenue 2-13, Rio Hondo/San Gabriel River Watershetl Management Group Rio Hondo Sierra Vista Park/School Sierra Madre Boulevard And Rancho Road 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Foothills Middle School Symore Avenue And Oakhaeen Road 2-13, Rio Hondo/San Gabriel River Watershetl Management Group Rio Hondo Attila Golf Course Wildflower Read And Mapleton Avenue 2-13, Rio Hondo/San Gabriel River Watershed Management Group Rio Hondo Royal oaks Elementary Royal Oaks Drive And Mt. olive Drive 2-13, Rio Hondo/San Gabriel River Watershetl Management Group lA County Flood Control District Enhanced Watershed Management Programs ESA/ 140020 Draft Program Environmental Impact Report 33 January 2015 Appendix EWMP Proposed BMP and Priority Project Data Region Apo Jurisdiction/City Land Use Type Address Figure Number and Title Upper Los Angeles River Ewmp Ular 6086031918 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular MM031910 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 6148015903 aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 6148016901 UCounry 2-14, Upper Los Angeles River Watershed Management Group Ular 6149021930 La County 2-14, Upper Los Angeles River Watershed Management Group Ular 6149022926 aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 6149028914 La County 2-14, Upper Los Angeles River Watershed Management Group Par 6056010901 aCounty 2-14, Upper Los 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2-14, Upper Los Angeles River Watershed Management Group Ular 5813021900 anada F1'mtridge 2-14, Upper Los Angeles River Watershed Management Group Par 581400!900 U nada F1'mtridge 2-14, Upper Los Angeles River Watershed Management Group Ular 5815001900 anada F1'mtridge 2-14, Upper Los Angeles River Watershed Management Group Par 22100185,02 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2210018909 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2 210 018 90 1 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2 210 018 910 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2210018907 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2309012900 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2024023900 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2024023901 Los Angeles 2-14, Upper Los Angeles River Watershed 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River Watershed Management Group Uiar 5376010900 aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 5376011900 La County 2-14, Upper Los Angeles River Watershed Management Group Par 916021904 South Pasadena 2-14, Upper Los Angeles River Watershed Management Group that 8587024901 Temple City 2-14, Upper Los Angeles River Watershed Management Group Par 0587024900 Temple CRY 2-14, Upper Los Angeles River Watershed Management Group that 5334025900 San Marino 2-14, Upper Los Angeles River WatersM1ed Management Group W County Flood Capped District Enhanced Watershed Management Programs ESA/ 140474 Draft Program Environmental Impact Report 35 January 2015 Appendix EWMP Proposed BMP and Prionty PmjeR Data Rgion Apo Jurisdiction/City Land Use Type Address Figure Number and Thin Ular 5333035903 San Gabriel 2-14, Upper Los Angeles RiverWatershed Management Group Ular 5366026900 San Gabriel 2-14, Upper Los Angeles RiverWatershed Management Group War 5035036500 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 5381009900 aCounty 2-14, Upper Los Angeles River Watershed Management Group Uiar 5381036901 UCounty 210, Upper Los Angeles River Watershed Management Group Ular 5381036903 to County 2-14, Upper Los Angeles River Watershed Management Group Uiar 5381036902 aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 5435039900 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 5381021900 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5381019900 aCounty 2-14, Upper Los Angeles River Watershed Management Group bar 5385010901 Temple CRY 2-14, Upper Los Angeles River Watershed Management Group Ular 8589026903 Temple City 2-14, Upper Los Angeles River Watershed Management Group Ular 8589026902 Temple City 2-14, Upper Los Angeles River Watershed Management Group Ular 8589026901 Temple City 2-14, Upper Los Angeles River Watershed Management Group bar 8590010900 Temple City 2-14, Upper Los Angeles River Watershed Management Group War 5313012901 South Pasadena 2-14, Upper Los Angeles River Watershed Management Group bar 5314026938 South Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 5319030904 South Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 5319030907 South Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 5319030905 South Pasadena 2-14, Upper Los Angeles River Watershed Management Group that 5319029901 South Pasadena 2-14, Upper Los Angeles River Watershed Management Group bar 5387007903 Temple CRY 2-14, Upper Los Angeles River Watershed Management Group that 5442029900 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5311002901 South Pasadena 2-14, Upper Los Angeles River Watershed Management Group bar 5467008901 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 5336017900 Alhambra 2-14, Upper Los Angeles River Watershed Management Group War 5346005901 Nhambra 2-14, Upper Los Angeles River Watershed Management Group bar 5346005902 Alhambra 2-14, Upper Los Angeles River Watershed Management Group War 5387034901 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group Ular 5387034900 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group Ular 5445006901 has Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5361002903 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group bar 5362012900 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group that 5362018900 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group bar 5367027900 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group Ular 5373020901 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 5373022901 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group bar 5373026900 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group bar 8590030901 Temple City 2-14, Upper Los Angeles River Watershed Management Group Ular 8590031910 Temple City 2-14, Upper Los Angeles River Watershed Management Group bar 5388024902 Temple City 2-14, Upper Los Angeles River Watershed Management Group Ular 5369024WS Temple Chy 2-14, Upper Los Angeles River Watershed Management Group Ular 5389024903 Temple CRY 2-14, Upper Los Angeles River Watershed Management Group Ular 8592018903 Rosemead 2-14, Upper Los Angeles River Watershed Management Group that 5343001906 Anambra 2-14, Upper Los Angeles River Watershed Management Group bar 5343001907 Alhambra 2-14, Upper Los Angeles River Watershed Management Group that 5343026901 Anambra 2-14, Upper Los Angeles River Watershed Management Group Ular 5343026902 Alhambra 2-14, Upper Los Angeles River Watershed Management Group Ular 5356009900 Alhambra 2-14, Upper Los Angeles River Watershed Management Group Ular 5291008900 Alhambra 2-14, Upper Los Angeles River Watershed Management Group Ular 529028907 aCounty 2-14, Upper Los Angeles River Watershed Management Group bar 5357005900 Alhambra 2-14, Upper Los Angeles River Watershed Management Group Ular 5372019900 Rosemead 2-14, Upper Los Angeles River Watershed Management Group Ular 5360010901 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group Ular 536,0010902 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group Ular 5360018900 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group bar 5 2110 2 190 0 has Angeles 2-14, Upper Los Angeles River Watershed Management Group that 5370006901 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group bar 5370005900 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group Ular 5447005900 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5447017901 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group War 5360032900 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group bar 5360029902 San Gabriel 2-14, Upper Los Angeles River Watershed Management Group War 5447027901 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 5447020901 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5447027906 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5447027908 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 5447026900 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group that 5447027907 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 5289002900 Rosemead 2-14, Upper Los Angeles River Watershed Management Group Ular 5403012903 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5403023934 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5224034900 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 5283020908 Rosemead 2-14, Upper Los Angeles River Watershed Management Group War 5283032903 Rosemead 2-14, Upper Los Angeles River Watershed Management Group bar 8117006900 aCounty 2-14, Upper Los Angeles River Watershed Management Group War W21016WO to County 2-14, Upper Los Angeles River Watershed Management Group bar E021016MI to County 2-14, Upper Los Angeles River Watershed Management Group Ular 6024001902 aCounty 2-14, Upper Los Angeles River Watershed Management Group that W25032917 aCounty 2-14, Upper Los Angeles River Watershed Management Group bar W47015MI aCounty 2-14, Upper Los Angeles River Watershed Management Group that 609005901 aCounty 2-14, Upper Los Angeles River Watershed Management Group bar OM030904 aCounty 2-14, Upper Los Angeles River Watershed Management Group bar MM031WO to County 2-14, Upper Los Angeles River Watershed Management Group Ular 6079031903 to County 2-14, Upper Los Angeles River Watershed Management Group bar MM031MI to County 2-14, Upper Los Angeles River Watershed Management Group bar 6044008905 aCounty 2-14, Upper Los Angeles River Watershed Management Group War 6044008904 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 6026030902 to County 2-14, Upper Los Angeles River Watershed Management Group Ular W26026WO aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular W26024913 to County 2-14, Upper Los Angeles River Watershed Management Group bar 6026025902 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 6044021906 aCounty 2-14, Upper Los Angeles River Watershed Management Group bar 6045019WS aCounty 2-14, Upper Los Angeles River Watershed Management Group that 6045019902 aCounty 2-14, Upper Los Angeles River Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA/ 140474 Draft Program Environmental Impact Report 36 January 2015 Appendix EWMP Proposed BMP and Priority Project Data Rgion Apn JurediRion/Ciry Land Use Type Address Equal Number and Tisk Ular 6060011904 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 6060009909 aCounty 2-1O, Upper Los Angeles River Watershed Management Group Uiar 6060013WO to County 2-14, Upper Los Angeles River Watershed Management Group Ular 6076003901 aCounty 2-14, Upper Los Angeles River Watershed Management Group Uiar 6076001902 to County 210, Upper Los Angeles River Watershed Management Group than 6076003900 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 6070006900 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group than 6109010907 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 6109014903 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 6149014904 aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 6149014909 aCounty 2-14, Upper Los Angeles River Watershed Management Group than 6149014WO to County 2-14, Upper Los Angeles River Watershed Management Group Ular 6149028WO to County 2-14, Upper Los Angeles River Watershed Management Group than 6149028902 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 6150014WO aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 6152002901 aco mi 2-14, Upper Los Angeles River Watershed Management Group Ular 6086022904 aCounty 2-14, Upper Los Angeles River Watershed Management Group Uiar W86031914 aCounty 2-14, Upper Los Angeles River Watershed Management Group than 6086031909 to County 2-14, Upper Los Angeles River Watershed Management Group Uiar 6086031911 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 6006031915 Ra County 2-14, Upper Los Angeles River Watershed Management Group Ular 601 LaCounty 2-14, Upper Los Angeles River Watershed Management Group that WH031917 RaCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 6086031908 to County 2-14, Upper Los Angeles River Watershed Management Group bar 6086037901 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 6086037903 UCoundy 2-14, Upper Los Angeles River Watershed Management Group Ular 6086037907 to Coundy 2-14, Upper Los Angeles River Watershed Management Group Ular 6086037902 UCoundy 2-14, Upper Los Angeles River Watershed Management Group Ular 6086037WO to Coundy 2-14, Upper Los Angeles River Watershed Management Group than 6134033WO to County 2-14, Upper Los Angeles River Watershed Management Group Uiar 6100017922 LaCounty 2-14, Upper Los Angeles River Watershed Management Group than 6180015903 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 7306019901 LaCounty 2-14, Upper Los Angeles River Watershed Management Group that 7306019902 La County 2-14, Upper Los Angeles River Watershed Management Group Ular 2124018906 has Angeles 2-14, Upper Los Angeles River Watershed Management Group than 2770013901 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2516028902 San Fernando 2-14, Upper Los Angeles RiverWatershed Management Group bar 2516030908 San Fernando 2-14, Upper Los Angeles River WatersM1ed Management Group Ular 2516030903 San Fernando 2-14, Upper Los Angeles Rive -Watershed Management Group Cher 2516030909 San Fernando 2-14, Upper Los Angeles River WatersM1ed Management Group Ular 2519026901 San Fernando 2-14, Upper Los Angeles River WatersM1ed Management Group Uiar 2613008900 San Fernando 2-14, Upper Los Angeles River WatersM1ed Management Group than 60210)8901 LaCounty 2-14, Upper Los Angeles River Watershed Management Group Uiar 5223030924 La County 2-14, Upper Los Angeles River Watershed Management Group that 5332025900 San Marino 2-14, Upper Los Angeles RiverWatershed Management Group Ular 5347029907 Alhambra 2-14, Upper Los Angeles River Watershed Management Group that 5347031903 San Gabriel 2-14, Upper Los Angeles RiverWatershed Management Group Ular 5347028WS Alhambra 2-14, Upper Lori RiverWatershed Management Group than 5360002900 San Gabriel 2-14, Upper Los Angeles RiverWatershed Management Group Ular 5360012901 San Gabriel 2-14, Upper Los Angeles RiverWatershed Management Group Ular 5361002902 San Gabriel 2-14, Upper Los Angeles RiverWatershed Management Group Ular 5361002904 San Gabriel 2-14, Upper Los Angeles Rive -Watershed Management Group Ular 5364024903 San Gabriel 2-14, Upper Los Angeles River WatersM1ed Management Group than 5370016902 San Gabriel 2-14, Upper Los Angeles Rive -Watershed Management Group Uiar 5372012900 Rosemead 2-14, Upper Los Angeles River WatersM1ed Management Group than 5376012901 LaCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 5387032924 Temple CRY 2-14, Upper Los Angeles River Watershed Management Group that 5387030917 Temple City 2-14, Upper Los Angeles River Watershed Management Group Ular 5389001903 Rosemead 2-14, Upper Los Angeles River Watershed Management Group than 5389001904 Rosemead 2-14, Upper Los Angeles River Watershed Management Group Ular 5389001901 Rosemead 2-14, Upper Los Angeles River Watershed Management Group Ular Si Rosemead 2-14, Upper Los Angeles River Watershed Management Group Ular 5390001900 Rosemead 2-14, Upper Los Angeles River Watershed Management Group Ular 5390002900 Rosemead 2-14, Upper Los Angeles River Watershed Management Group than 5435038902 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Uiar 5435039903 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group than 5442031901 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular Si has Angeles 2-14, Upper Los Angeles River Watershed Management Group that 5457001901 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5457001902 has Angeles 2-14, Upper Los Angeles River Watershed Management Group than 5637006900 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 5675013901 Glendale 2-14, Upper Los Angeles River Watershed Management Group than 5675028WO Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 5696008928 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 5189010922 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5189010924 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5225019916 UCormy 2-14, Upper Los Angeles River Watershed Management Group than 5233027921 to County 2-14, Upper Los Angeles River Watershed Management Group Uiar 5233026931 LaCounty 2-14, Upper Los Angeles River Watershed Management Group that 5234008900 LaCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 5234015904 LaCounty 2-14, Upper Los Angeles River Watershed Management Group that 5234015905 LaCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 5237023907 Monterey Park 2-14, Upper Los Angeles River Watershed Management Group bar 5238009900 to County 2-14, Upper Los Angeles River Watershed Management Group Ulan 5238008905 to County 2-14, Upper Los Angeles River Watershed Management Group bar 5287013901 Rosemead 2-14, Upper Los Angeles River Watershed Management Group Ular 5287014WO Rosemead 2-14, Upper Los Angeles River Watershed Management Group Ular 5287022WO Rosemead 2-14, Upper Los Angeles River Watershed Management Group than 5171025901 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Uiar 5171025902 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group than 2460032902 Burbank 2-14, Upper Los Angeles River Watershed Management Group Ular 2538015WO Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group their 5607010WO Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 5607012901 Glendale 2-14, Upper Los Angeles River Watershed Management Group that 5615014902 Glendale 2-14, Upper Los Angeles River Watershed Management Group W County Flood Con[ml District Enhanced Watershed Management Programs ESA/ 140474 Draft Program Environmental Impact Report 37 January 2015 Appendix EWMP Proposed BMP and Plenty Pmject Data Rallied Apn Jurisdiction/City land Use Type Address Figure Number and rdle Ular 562201SWO Glendale 2-14, Upper Los Angeles River Watershed Management Group than 5628016WO Glendale 2-1O, Upper Los Angeles River Watershed Management Group War 56MO27WO Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 5635006900 Glendale 2-14, Upper Los Angeles River Watershed Management Group War 5635020WO Glendale 210, Upper Los Angeles River Watershed Management Group than 5636006900 Glendale 2-14, Upper Los Angeles River Watershed Management Group that 5636016901 Glendale 2-14, Upper Los Angeles River Watershed Management Group than S6"013902 Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 5644013914 Glendale 2-14, Upper Los Angeles River Watershed Management Group that 564602SWO Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 56500NUg7 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 5650004905 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 5690036901 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 2681011902 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 5293013901 Montebello 2-14, Upper Los Angeles River Watershed Management Group War 6343022901 Montebello 2-14, Upper Los Angeles River Watershed Management Group Par 6344023902 Montebello 2-14, Upper Los Angeles River Watershed Management Group that 6344014900 Montebello 2-14, Upper Los Angeles River Watershed Management Group than 6346022901 Montebello 2-14, Upper Los Angeles River Watershed Management Group that 6348010900 Montebello 2-14, Upper Los Angeles River Watershed Management Group that 6349019WS Montebello 2-14, Upper Los Angeles River Watershed Management Group Par 6351020900 UCourody 2-14, Upper Los Angeles River Watershed Management Group that 6353001900 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 2405027WO Burbank 2-14, Upper Los Angeles River Watershed Management Group bar 5434039901 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 5593018903 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group War 2353001904 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 240701SWO Los Angeles 2-14, Upper Los Angeles River Watershed Management Group War 2449031903 Burbank 2-14, Upper Los Angeles River Watershed Management Group than 2449035904 Burbank 2-14, Upper Los Angeles River Watershed Management Group that 2451000901 Burbank 2-14, Upper Los Angeles River Watershed Management Group than 2451011906 Burbank 2-14, Upper Los Angeles River Watershed Management Group Par 2451009903 Burbank 2-14, Upper Los Angeles River Watershed Management Group that 2451010903 Burbank 2-14, Upper Los Angeles River Watershed Management Group Par 2634006902 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2547006900 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2555023901 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 2555032901 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 2555023902 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2557024WO Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 2557024909 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group that 2557027909 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group than 2559017WO Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group that 5601017903 Glendale 2-14, Upper Los Angeles River Watershed Management Group that 5602000901 Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 5602010901 Glendale 2-14, Upper Los Angeles River Watershed Management Group that 5602011901 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 5603003901 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 5603011WO Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 5606006900 Glendale 2-14, Upper Los Angeles River Watershed Management Group War 5606016WO Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 5606017WO Glendale 2-14, Upper Los Angeles River Watershed Management Group War 5801010901 to County 2-14, Upper Los Angeles River Watershed Management Group than 5801016904 to County 2-14, Upper Los Angeles River Watershed Management Group that 5803023WO aCounty 2-14, Upper Los Angeles River Watershed Management Group than 5865017902 to County 2-14, Upper Los Angeles River Watershed Management Group Par 5870013901 Unada Runnette 2-14, Upper Los Angeles River Watershed Management Group that 574901SWO Pasadena 2-14, Upper Los Angeles River Watershed Management Group Par 950003902 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 952006901 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 5759020WO Pasadena 2-14, Upper Los Angeles River Watershed Management Group War 5759019WO Pasadena 2-14, Upper Los Angeles River Watershed Management Group Par 5823022WO Pasadena 2-14, Upper Los Angeles River Watershed Management Group War 5823031WO Pasadena 2-14, Upper Los Angeles River Watershed Management Group than 5825020904 Pasadena 2-14, Upper Los Angeles River Watershed Management Group that 5825020906 Pasadena 2-14, Upper Los Angeles River Watershed Management Group than 5825020905 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Par 5878021901 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5829006905 aCounty 2-14, Upper Los Angeles River Watershed Management Group Par 5829006904 aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 5830013909 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 5830013931 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 5830013925 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 5830013924 to County 2-14, Upper Los Angeles River Watershed Management Group War 5830013902 to County 2-14, Upper Los Angeles River Watershed Management Group Par 5835013904 aCounty 2-14, Upper Los Angeles River Watershed Management Group War 5842020902 to County 2-14, Upper Los Angeles River Watershed Management Group than 5843008901 to County 2-14, Upper Los Angeles River Watershed Management Group that 5849025901 Pasadena 2-14, Upper Los Angeles River Watershed Management Group that 5849025WO Pasadena 2-14, Upper Los Angeles River Watershed Management Group Par 5857035901 Pasadena 2-14, Upper Los Angeles River Watershed Management Group that 2451005901 Burbank 2-14, Upper Los Angeles River Watershed Management Group Par 2451006904 Burbank 2-14, Upper Los Angeles River Watershed Management Group bar 5319027906 South Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 5493038WO Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 5467011901 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 5723026WO Pasadena 2-14, Upper Los Angeles River Watershed Management Group War 923026902 Pasadena 2-14, Upper Los Angeles River Watershed Management Group than 5593030903 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group that 5593012909 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group than 5593018907 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 2459008900 Burbank 2-14, Upper Los Angeles River Watershed Management Group that 2459007901 Burbank 2-14, Upper Los Angeles River Watershed Management Group Par 2459007900 Burbank 2-14, Upper Los Angeles River Watershed Management Group that 2459008901 Burbank 2-14, Upper Los Angeles River Watershed Management Group W County Flood Funded District Enhanced Watershed Management Programs ESA/ 140474 Draft Program Environmental Impact Report 38 January 2015 Appendix EWMP Proposed BMP and Priority Pmject Data Rallied Apn lurediction/City Land Use Type Address Figure Number and rdle Ular 2059006900 Burbank 2-14, Upper Los Angeles River Watershed Management Group Ular 2069001902 Burbank 2-14, Upper Los Angeles River Watershed Management Group War 5830013908 to Coundy 2-14, Upper Los Angeles River Watershed Management Group Par 5830013910 aCounty 2-14, Upper Los Angeles River Watershed Management Group Uiar 2525018901 Los Angeles 210, Upper Los Angeles River Watershed Management Group Oar 2525016901 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Gmup Ular 2525019900 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Oar 2525023902 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 2526023918 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 2681010910 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 2]0600190] Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2706001906 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 2555032900 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2SS7023901 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 5601026901 Glendale 2-14, Upper Los Angeles River Watershed Management Group War 5606012900 Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 5866005900 aCounty 2-14, Upper Los Angeles River Watershed Management Gmup Ular 5602002900 Glendale 2-14, Upper Los Angeles River Watershed Management Group Oar 5603010900 Glendale 2-14, Upper Los Angeles River Watershed Management Gmup Ular 5806019900 U nada F1'mtridge 2-10, Upper Los Angeles River Watershed Management Group that 58640M900 to nada F1'mtridge 2-14, Upper Los Angeles River Watershed Management Group Par 5602009900 Glendale 2-14, Upper Los Angeles River Watershed Management Group that 5610020901 Glendale 2-14, Upper Los Angeles River Watershed Management Group bar 5 611015 90 1 Glendale 2-14, Upper Los Angeles River Watershed Management Group bar 5803011900 to County 2-14, Upper Los Angeles River Watershed Management Group Par 5803011901 aCounty 2-14, Upper Los Angeles River Watershed Management Group War 5803027900 to Coundy 2-14, Upper Los Angeles River Watershed Management Group Par 5803026900 aCounty 2-14, Upper Los Angeles River Watershed Management Group War 5804015909 to Coundy 2-14, Upper Los Angeles River Watershed Management Group Oar 5804015911 to County 2-14, Upper Los Angeles River Watershed Management Gmup Ular 5804015912 aCounty 2-14, Upper Los Angeles River Watershed Management Group Oar 5804013901 to County 2-14, Upper Los Angeles River Watershed Management Group Par 5804014901 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5803008900 aCounty 2-14, Upper Los Angeles River Watershed Management Group Par 5803020901 aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 5865026900 to County 2-14, Upper Los Angeles River Watershed Management Group bar 5866030901 to Coundy 2-14, Upper Los Angeles River Watershed Management Group bar 5865031900 to County 2-14, Upper Los Angeles River Watershed Management Group Par 5864003900 Unada Deducts 2-14, Upper Los Angeles River Watershed Management Group Bar 5 816 014 913 to natla Flintridge 2-14, Upper Los Angeles River Watershed Management Group Par 2634004913 Los Angeles 2-14, Upper Los Angeles River Watershed Management Gmup Ular 5812007900 La nada Flintridge 2-14, Upper Los Angeles River Watershed Management Group Oar 5812013903 to nada Flintridge 2-14, Upper Los Angeles River Watershed Management Gmup Ular 5812013902 La nada Flintridge 2-14, Upper Los Angeles River Watershed Management Group that 5864020900 La nada Deducts 2-14, Upper Los Angeles River Watershed Management Group Par 5 611010 90 0 Glendale 2-14, Upper Los Angeles River Watershed Management Group that 5810012902 La County 2-14, Upper Los Angeles River Watershed Management Group bar 5870012901 to natla Deducts 2-14, Upper Los Angeles River Watershed Management Group Ular 5870023902 to nada Danitlge 2-14, Upper Los Angeles River Watershed Management Group bar 5864026902 to natla Flintridge 2-14, Upper Los Angeles River Watershed Management Group Ular 2 314 0 0190 0 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 2 314 0 05 90 0 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2 314 0 05 90 3 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Oar 240300!901 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Gmup Ular 5613006900 Glendale 2-14, Upper Los Angeles River Watershed Management Group Oar 5613007900 Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 56]30:8900 Glendale 2-14, Upper Los Angeles River Watershed Management Group that 5615001901 Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 5615001900 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 5807024900 Glendale 2-14, Upper Los Angeles River Watershed Management Group bar 5810023900 to nada Deducts 2-14, Upper Los Angeles River Watershed Management Group War 5801006902 to Ccundy 2-14, Upper Los Angeles River Watershed Management Group Par 5816005900 La area Flintridge 2-14, Upper Los Angeles River Watershed Management Group War 5617015900 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 2462008900 Burbank 2-14, Upper Los Angeles River Watershed Management Gmup Ular 2463000900 Burbank 2-14, Upper Los Angeles River Watershed Management Group Oar 5819005902 to nada Flintridge 2-14, Upper Los Angeles River Watershed Management Group Par 5819006902 La nada Flintridge 2-14, Upper Los Angeles River Watershed Management Group that 5842020900 La County 2-14, Upper Los Angeles River Watershed Management Group Par 5842020901 La County 2-14, Upper Los Angeles River Watershed Management Group Ular 5829005903 Pasadena 2-14, Upper Los Angeles River Watershed Management Group bar 5829005902 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 5616003900 Glendale 2-14, Upper Los Angeles River Watershed Management Group bar 5832017900 to Coundy 2-14, Upper Los Angeles River Watershed Management Group War 5835012908 to Coundy 2-14, Upper Los Angeles River Watershed Management Group Par 5835012901 La County 2-14, Upper Los Angeles River Watershed Management Group War 5835012904 La Coumy 2-14, Upper Los Angeles River Watershed Management Group Ular 5835012900 to County 2-14, Upper Los Angeles River Watershed Management Gmup Ular 5835012906 La County 2-14, Upper Los Angeles River Watershed Management Group that 5835012907 La County 2-14, Upper Los Angeles River Watershed Management Group Par 5842021900 La County 2-14, Upper Los Angeles River Watershed Management Group that 5842021901 La County 2-14, Upper Los Angeles River Watershed Management Group Par 5878009903 La County 2-14, Upper Los Angeles River Watershed Management Group bar 5829006902 to County 2-14, Upper Los Angeles River Watershed Management Group bar 5829006901 to Coundy 2-14, Upper Los Angeles River Watershed Management Group bar 5829006903 to County 2-14, Upper Los Angeles River Watershed Management Group Par 5829006900 La County 2-14, Upper Los Angeles River Watershed Management Group War 2451010904 Burbank 2-14, Upper Los Angeles River Watershed Management Group Oar 2451010905 Burbank 2-14, Upper Los Angeles River Watershed Management Gmup Ular 5843015900 La County 2-14, Upper Los Angeles River Watershed Management Group Oar 5878021903 to County 2-14, Upper Los Angeles River Watershed Management Gmup Par 5840010900 La County 2-14, Upper Los Angeles River Watershed Management Group that 5840000901 La County 2-14, Upper Los Angeles River Watershed Management Group Par 5841032900 La County 2-14, Upper Los Angeles River Watershed Management Group that 2415015900 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA/ 140474 Draft Program Environmental Impact Report 39 January 2015 Appendix EWMP Proposed BMP and Priority PmjeR Data Region Apo Jurisdiction/City Land Use Type Address Figure Number and rdle Ular 2014005902 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2415013900 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group War 5730030903 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Par 5730030900 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 5730029903 Pasadena 214, Upper Los Angeles River Watershed Management Group Our 5848030900 Pasadena 2-14, Upper Los Angeles River Watershed Management Group that 2451006903 Burbank 2-14, Upper Los Angeles River Watershed Management Group Our 2453023901 Burbank 2-14, Upper Los Angeles River Watershed Management Group Par 2453023902 Burbank 2-14, Upper Los Angeles River Watershed Management Group that 2453023900 Burbank 2-14, Upper Los Angeles River Watershed Management Group Par 2449035902 Burbank 2-14, Upper Los Angeles River Watershed Management Group Ular 2449035907 Burbank 2-14, Upper Los Angeles River Watershed Management Group Ular 2451007904 Burbank 2-14, Upper Los Angeles River Watershed Management Group Ular 2462017WS Burbank 2-14, Upper Los Angeles River Watershed Management Group Par 2462017904 Burbank 2-14, Upper Los Angeles River Watershed Management Group War 5825020WS Pasadena 2-14, Upper Los Angeles River Watershed Management Group Par 5825020900 Pasadena 2-14, Upper Los Angeles River Watershed Management Group that 5825020902 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Our 5827013904 La County 2-14, Upper Los Angeles River Watershed Management Group that 2476013900 Burbank 2-14, Upper Los Angeles River Watershed Management Group that 2490009900 Burbank 2-14, Upper Los Angeles River Watershed Management Group Par 2483006901 Burbank 2-14, Upper Los Angeles River Watershed Management Group that 2490009901 Burbank 2-14, Upper Los Angeles River Watershed Management Group Ular 5627003903 Glendale 2-14, Upper Los Angeles River Watershed Management Group bar 5627006900 Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 5627003902 Glendale 2-14, Upper Los Angeles River Watershed Management Group War 951018907 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Par 5751020904 Pasadena 2-14, Upper Los Angeles River Watershed Management Group War 951019900 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Our 5623010900 Glendale 2-14, Upper Los Angeles River Watershed Management Group that 5623020900 Glendale 2-14, Upper Los Angeles River Watershed Management Group Our 978011900 Pasadena 2-14, Upper Los 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5740020900 Pasadena 2-14, Upper Los Angeles River Watershed Management Group that 5633021900 Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 5635006902 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 5690036900 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 5726015900 Pasadena 2-14, Upper Los Angeles River Watershed Management Group War 5722010913 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Par 5593001902 Glendale 2-14, Upper Los Angeles River Watershed Management Group War 5593001906 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 2443000900 Burbank 2-14, Upper Los Angeles River Watershed Management Group that 957002901 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Our 5752005900 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Par 5636012WS Glendale 2-14, Upper Los Angeles River Watershed Management Group that 5644013935 Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 952002901 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 5644018927 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 950003905 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 952015903 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 2443025904 Burbank 2-14, Upper Los Angeles River Watershed Management Group War 2443025906 Burbank 2-14, Upper Los Angeles River Watershed Management Group Par 2443025900 Burbank 2-14, Upper Los Angeles River Watershed Management Group War 5696010901 Glendale 2-14, Upper Los Angeles River Watershed Management Group Ular 5696008929 Glendale 2-14, Upper Los Angeles River Watershed Management Group that 5643020906 Glendale 2-14, Upper Los Angeles River Watershed Management Group that 5643019900 Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 5721026900 Pasadena 2-14, Upper Los Angeles River Watershed Management Group that 2485029900 Burbank 2-14, Upper Los Angeles River Watershed Management Group Par 5593018900 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 2069006903 labasas 2-14, Upper Los Angeles River Watershed Management Group bar 5324003902 Pasadena 2-14, Upper Los Angeles River Watershed Management Group bar 5324003901 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Par 242400.3901 aCounty 2-14, Upper Los Angeles River Watershed Management Group War 242400.3900 La County 2-14, Upper Los Angeles River Watershed Management Group Our 5676024900 Glendale 2-14, Upper Los Angeles River Watershed Management Group that 5676024901 Glendale 2-14, Upper Los Angeles River Watershed Management Group Our 5676024904 Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 5679001900 Glendale 2-14, Upper Los Angeles River Watershed Management Group that 5640035901 Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 5594016900 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group that 5594016903 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group W County Flood Funded District Enhanced Watershed Management Programs ESA/ 140474 Draft Program Environmental Impact Report 40 January 2015 Appendix EWMP Proposed BMP and Priority Project Data Region Apn Jurisdiction/City Land Use Type Address Figure Number and Title Ular 5594018901 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group that 5594018900 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group War 559/016901 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5594016902 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group War 5593030904 Los Angeles 214, Upper Los Angeles River Watershed Management Group that 5 5 93 0 02 901 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Uiar 5593029900 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group that 5376001913 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 5376001912 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5493037900 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 916021903 South Pasadena 2-14, Upper Los Angeles River Watershed Management Group that 5467012900 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 5467012901 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group that 5291027902 Alhambra 2-14, Upper Los Angeles River Watershed Management Group Ular 5286017902 Rosemead 2-14, Upper Los Angeles River Watershed Management Group War 5287020902 Rosemead 2-14, Upper Los Angeles River Watershed Management Group Ular 5287020904 Rosemead 2-14, Upper Los Angeles River Watershed Management Group that 5287020900 Rosemead 2-14, Upper Los Angeles River Watershed Management Group that 5287020903 Rosemead 2-14, Upper Los Angeles River Watershed Management Group Uiar 5207021900 Rosemead 2-14, Upper Los Angeles River Watershed Management Group that 5255008902 Monterey Park 2-14, Upper Los Angeles River Watershed Management Group Ular 5255008900 Monterey Park 2-14, Upper Los Angeles River Watershed Management Group that 5258002908 Monterey Park 2-14, Upper Los Angeles River Watershed Management Group bar 52E00W901 Monterey Park 2-14, Upper Los Angeles River Watershed Management Group bar 5284038900 Rosemead 2-14, Upper Los Angeles River Watershed Management Group Ular 528/034900 Rosemead 2-14, Upper Los Angeles River Watershed Management Group War 5285007923 Rosemead 2-14, Upper Los Angeles River Watershed Management Group Ular 5205008905 Rosemead 2-14, Upper Los Angeles River Watershed Management Group War 5285008904 Rosemead 2-14, Upper Los Angeles River Watershed Management Group that 5285008909 Rosemead 2-14, Upper Los Angeles River Watershed Management Group that 5205006908 Rosemead 2-14, Upper Los Angeles River Watershed Management Group that 5205005912 Rosemead 2-14, Upper Los Angeles River Watershed Management Group Ular 52250115,00 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5251018902 Monterey Park 2-14, Upper Los Angeles River Watershed Management Group Ular 5251023900 Monterey Park 2-14, Upper Los Angeles River Watershed Management Group that 5262008900 Monterey Park 2-14, Upper Los Angeles River Watershed Management Group bar 5273016900 Monterey Park 2-14, Upper Los Angeles River Watershed Management Group bar 5226028904 La County 2-14, Upper Los Angeles River Watershed Management Group Ular 5226028WS aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5226033907 UCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 5226033906 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5226035901 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5226030900 to County 2-14, Upper Los Angeles River Watershed Management Group Uiar 5227025903 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5227025917 aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 5233004905 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 52330M903 aCounty 2-14, Upper Los Angeles River Watershed Management Group bar 523300491/ La County 2-14, Upper Los Angeles River Watershed Management Group that 5233011900 La County 2-14, Upper Los Angeles River Watershed Management Group bar 5233012912 La County 2-14, Upper Los Angeles River Watershed Management Group War 5234002900 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 5234013903 aCounty 2-14, Upper Los Angeles River Watershed Management Group War 5234013904 to County 2-14, Upper Los Angeles River Watershed Management Group that 5234012903 to County 2-14, Upper Los Angeles River Watershed Management Group Uiar 5234012902 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5274014900 Monterey Park 2-14, Upper Los Angeles River Watershed Management Group Ular 5267006900 Montebello 2-14, Upper Los Angeles River Watershed Management Group that 526700)902 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 5267009900 Montebello 2-14, Upper Los Angeles River Watershed Management Group that 5267007900 Monohello 2-14, Upper Los Angeles River Watershed Management Group bar 5267097901 Montebello 2-14, Upper Los Angeles River Watershed Management Group War 5267009903 MonteMllo 2-14, Upper Los Angeles River Watershed Management Group Ular 52670)9901 Montebello 2-14, Upper Los Angeles River Watershed Management Group War 5185025908 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group that 0117024906 to County 2-14, Upper Los Angeles River Watershed Management Group that 5232014900 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5235008908 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 52350)7918 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5235020911 aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 5235021906 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5235025903 La County 2-14, Upper Los Angeles River Watershed Management Group bar 5240008900 La County 2-14, Upper Los Angeles River Watershed Management Group that 52400)7900 La County 2-14, Upper Los Angeles River Watershed Management Group bar 5246014916 La County 2-14, Upper Los Angeles River Watershed Management Group War 5246021900 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 5248012914 aCounty 2-14, Upper Los Angeles River Watershed Management Group War 5248010904 to County 2-14, Upper Los Angeles River Watershed Management Group that 634100)907 to County 2-14, Upper Los Angeles River Watershed Management Group that 6341023900 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 52470M905 aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 52470)3901 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5232021900 aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 5232021903 aCounty 2-14, Upper Los Angeles River Watershed Management Group bar 5233013903 La County 2-14, Upper Los Angeles River Watershed Management Group Ular 5233013902 La County 2-14, Upper Los Angeles River Watershed Management Group bar 5233013907 La County 2-14, Upper Los Angeles River Watershed Management Group Ular 5233013904 aCounty 2-14, Upper Los Angeles River Watershed Management Group War 5233017903 to County 2-14, Upper Los Angeles River Watershed Management Group that 5233013905 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 5239010906 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 5232020913 aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 5278004901 Montebello 2-14, Upper Los Angeles River Watershed Management Group that 5293022900 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 5171024902 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group that 5171024910 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group W County Flood Funded District Enhanced Watershed Management Programs ESA/ 140474 Draft Program Environmental Impact Report 41 January 2015 Appendix EWMP Proposed BMP and Plenty Foulest Data Region Apn Jurisdiction/City Land Use Type Address Figure Number and rdle Ular 5268010901 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 52NO13WO Montebello 2-1O, Upper Los Angeles River Watershed Management Group War 52NO145,03 MonteMllo 2-14, Upper Los Angeles River Watershed Management Group Ular 63440)1906 MonteMllo 2-14, Upper Los Angeles River Watershed Management Group War 6305011WO MonteMllo 210, Upper Los Angeles River Watershed Management Group Ular 63 06 0 06 90 0 Montebello 2-14, Upper Los Angeles River Watershed Management Group that 6351024WO aCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 6351033902 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 6351033903 aCounty 2-14, Upper Los Angeles River Watershed Management Group that 6351035901 LaCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 6332034900 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 6332034901 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 6349023WO Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 6350012906 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 6350016904 Man@bello 2-14, Upper Los Angeles River Watershed Management Group War 6350022900 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 6350026900 Man@bello 2-14, Upper Los Angeles River Watershed Management Group that 6351004900 La Comply 2-14, Upper Los Angeles River Watershed Management Group Ular 6344012900 Montebello 2-14, Upper Los Angeles River Watershed Management Group that 6346028912 Montebello 2-14, Upper Los Angeles River Watershed Management Group that 6349002915 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 6349002910 Montebello 2-14, Upper Los Angeles River Watershed Management Group that 6349MSWO Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 63500)6901 Montebello 2-14, Upper Los Angeles River Watershed Management Group bar 6390011900 Mon@bello 2-14, Upper Los Angeles River Watershed Management Group Ular 6350018904 Mon@bello 2-14, Upper Los Angeles River Watershed Management Group War 6008005902 UCourry 2-14, Upper Los Angeles River Watershed Management Group Ular 6346022901 Mon@bello 2-14, Upper Los Angeles River Watershed Management Group War 6346023900 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 6346022900 Montebello 2-14, Upper Los Angeles River Watershed Management Group that 6346023901 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 6346025902 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 6348003901 Montebello 2-14, Upper Los Angeles River Watershed Management Group that 6348003900 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 63520)6901 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 63520)5902 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 6352022902 Montebello 2-14, Upper Los Angeles River Watershed Management Group bar 6008015903 to Dowdy 2-14, Upper Los Angeles River Watershed Management Group Ular 6008015908 Lacounty 2-14, Upper Los Angeles River Watershed Management Group Ular 6008013906 La Coundy 2-14, Upper Los Angeles River Watershed Management Group Ular 6009014WO UCounty 2-14, Upper Los Angeles River Watershed Management Group that MM014WS LaCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 6008015904 to County 2-14, Upper Los Angeles River Watershed Management Group that MM013924 LaCounty 2-14, Upper Los Angeles River Watershed Management Group that MM015928 LaCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 6009014901 LaCounty 2-14, Upper Los Angeles River Watershed Management Group that MM016WO LaCounty 2-14, Upper Los Angeles River Watershed Management Group Ular 6008014903 to County 2-14, Upper Los Angeles River Watershed Management Group Ular W10012901 to County 2-14, Upper Los Angeles River Watershed Management Group Ular E010023WO to County 2-14, Upper Los Angeles River Watershed Management Group War 6010023901 to County 2-14, Upper Los Angeles River Watershed Management Group Ular 6010017903 UCounty 2-14, Upper Los Angeles River Watershed Management Group War E010021WO to County 2-14, Upper Los Angeles River Watershed Management Group Ular E010026923 to County 2-14, Upper Los Angeles River Watershed Management Group that 6354026901 Montebello 2-14, Upper Los Angeles River Watershed Management Group Ular 2031008906 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 20310:8903 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group that 2031008905 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5864001901 U hand F1'mtridge 2-14, Upper Los Angeles River Watershed Management Group Ular 2519018WO San Fernando 2-14, Upper USAngeles River Watershed Management Group Ular 2519019WO San Fernando 2-14, Upper Los Angeles River Watershed Management Group War 2 519 012 90 0 San Fernando 2-14, Upper Los Angeles River Watershed Management Group Ular 5602012901 Glendale 2-14, Upper Los Angeles River Watershed Management Group War 2308010902 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 2028022900 Ins Angeles 2-14, Upper Los Angeles River Watershed 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91900N900 Pasadena 2-14, Upper Los Angeles River Watershed Management Group that 9190)4914 Pasadena 2-14, Upper Los Angeles River Watershed Management Group that 52190M902 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 5234032902 Pasadena 2-14, Upper Los Angeles River Watershed Management Group that 923013902 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 531901700 South Pasadena 2-14, Upper Los Angeles River Watershed Management Group bar 5435038904 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5319030903 Sa th Pasadena 2-14, Upper Los Angeles River Watershed Management Group bar 5319030WO South Pasadena 2-14, Upper Los Angeles River Watershed Management Group Ular 5319030906 South Pasadena 2-14, Upper Los Angeles River Watershed Management Group War 54450)4902 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5445031905 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group that 5445031902 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5445031901 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 5445031903 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group that 5445031904 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 544500,1906 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group that 5445031906 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA/ 140424 Draft Program Environmental Impact Report 42 January 2015 Appendix EWMP Proposed BMP and Plenty Project Data Region Apn lurediction/Ciry Land Use Type Address Figure Number and Thin her 5352028902 Alhambra 2-14, Upper Los Angeles River Watershed Management Group Ular 5352028901 Alhambra 2-14, Upper Los Angeles River Watershed Management Group War 5003017906 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 5003017WS Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Uiar 5226031908 to County 210, Upper Los Angeles River Watershed Management Group Uiar 5171020900 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Uiar 5171025900 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Uiar 6201017900 to County 2-14, Upper Los Angeles River Watershed Management Group Par 6024022900 toCounty 2-14, Upper Los Angeles River Watershed Management Group Ular W71021916 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Par W71021915 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Ular 6071021914 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 24"015900 Burbank 2-14, Upper Los Angeles River Watershed Management Group Ular 5171015900 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 5723017911 Pasadena 2-14, Upper Los Angeles River Watershed Management Group War 5723017915 Pasadena 2-14, Upper Los Angeles River Watershed Management Group Par 240.3025902 Burbank 2-14, Upper Los Angeles River Watershed Management Group that 5435037904 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Uiar 5172013900 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Uiar 5307011901 Temple City 2-14, Upper Los Angeles River Watershed Management Group Ular 5623020901 Glendale 2-14, Upper Los Angeles River Watershed Management Group Par 53WO11WO San Gabriel 2-14, Upper Los Angeles River Watershed Management Group Ular 2784001901 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 27840015,02 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group bar 2784002903 Ins Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 2784002902 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group War 2468020904 Burbank 2-14, Upper Los Angeles River Watershed Management Group Par 5652005901 Glendale 2-14, Upper Los Angeles River Watershed Management Group War 56520.W901 Glendale 2-14, Upper Los Angeles River Watershed Management Group Uiar 53WO21MI San Gabriel 2-14, Upper Los Angeles River Watershed Management Group Uiar 5171015902 Los Angeles 214, Upper Los Angeles River Watershed Management Group Uiar 2634646908 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group Par 5445006909 Los Angeles 2-14, Upper Los Angeles River Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA/ 140474 Draft Program Environmental Impact Report 43 January 2015 Appendix EWMP Proposed BMP and Priority Project Data Region Apn lurisdictioli LpM Use Type Address Figure Number and Tilk _ Upper San Gabriel River Ewmp IIIIC San Gabriel 8558023905, County Oid Bassett Unified School 0lstrict Site 05M023910 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8125014039, Intlurtry Client Specified lndurtry No.1 0125014002, 8125014901, 0125016012, 8125016018, 8125016019, 8125016020, 8125016021, 8125016022, 8125016023, 9125016024, 8125016025, 9125016027, 8125016900 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0115001220, County Cllenl Specified Industry No.2 81150018001 01151 0115 0 0190 8, 0115 0 0190 9, 81150 02 2 2 0, 8150021300, 0115002001, 8115002902, 0115002904, 8115002905, 0115002906, 8115002902, 0115002908, 0115002909 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8554005900 Baldwin Park Hilda L. Solis Park 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8544021900, Baldwin Park Morgan Park 8544021901, 8544021902, 8544021903, 8544021904, 8544021905, 8544021907, 8544021908, 8544021909, 8544021910, 0544021911, 8544022902 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8558022801, County Shyer Park 85E0028001, B5E0028904 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0564014902, Baldwin Park Walnut Creek Nature Park 8564014908, 0564016909, 8564016912, MM016913 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel. 8550001904, Baldwin Park Barnes Park 8550001906 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8156001910, County Adventure Park MS6001911 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8633002900 Glendora Stanton Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0628D01905 Glendora Citrus Community College 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0632001900 Glendora Sierra High School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8635000901 Glendora to Extra Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0638009906 Glendora Finkbiner Park 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8640006901 Glendora Whitcomb Continuation High 2-12, Upper San Gabdel River Watershed ManagementGmups San Gabriel 0649020901 Glendora Williams Elementarykno l 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 8648018906 Glendora Cullen Elementary5ch al 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8653023902 Glendora Willow Elementary5chool 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. MM017MI Glendora Glendora High School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8]26001900 County Borrow (Remote) Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8110 0 2 9 90 2 County High Voltage Electril Easement Near San Angelo Park 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8242010901 County Valinda Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8245014900 County Wag Wine Elementary Scha01 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel B2E0023909 Intlurtry Ron Hockwalt High School(Rldid 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8210 0 2 190 1 La Puente Nelson Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8214 0 2 4 90 0 La Puente to Puente High School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8214025900 aPuente In Puente Park 2-12, Upper San Cannel River Watershed Management Groups San Gabriel 0212011901 County Temple Ademy Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel B2II020901 County Sparks Elementary 5chcol 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 8212011902 County Allen l Martin Park 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0206014904 County Avodo Heights Park 212, Upper San Gabriel River Watershed Management Groups San Gabriel 8218009901 County Truck (Watling Dock 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 82420M900 County Gorselder Elementary School 2- 12 Upper San Gabriel River Watershed Management Groups San Gabriel 824500,1906 Intlurtry Commercial Buildings 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8248015900 County Grandview ElementarySchool 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8248015901 County Rimgrove Park 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel 8251003900 La Puente Del Valle Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8252013900 La Puente Fairgrwe Ademy 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0263030900 aPuente Hurley (Remote) Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0641002223, Glendora Dawson Avenue Park 8641002904 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8 4 28 016 90 2 County Western Christian High School 212 Upper San Gabriel River Watershed Management Groups San Gabriel. 8406001902 Covina Faintalley High (Continuation) School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel M03013900 County Charter Oak Park 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel M03013901 County Charter Oak Park jCoustl Parcell 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8405008900 County Ben Wmond Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel M02001905 Covina Hollenbeck Park 2-12, Upper San Gabriel River Watershed Management Groups W County Flood Coal District Enhanced Watershed Management Formal ESA /14MT4 Draft program Environmental Impact Report 44 January 2015 Appendix EWMP Proposed BMP and Priority Project Data Region Apn lurediction/Ciry Land Use Type Address Figure Number and rdle San Gabriel MM021WO Covina Valencia Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8409019906 Covina Gladstone High School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0020013901 Covina Northview High School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8021015900 County Cypress Ball Park And Elementary5chool 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0020013902 Covina Northview High School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 8019031905 County Lark Ellen Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8026012902 Covina Badillo Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 8110001901 County Vent Lm Near Stir 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8550001907 Baldwin Park Twin Lakes Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8035016901 County Manzanim Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8035006900 County Partially Vant Lot Near maintain Shopping Center 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8038000900 Baldwin Park Central Elemerrtary5chool 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel 8030001900, Baldwin Park Baldwin Park High School 8059001900 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8006007903 Covina Sierra Vista Middle School 2-12, Upper San Gabdel River Watershed ManagementGmups San Gabriel 84510011900 Covina Barran Park, Barran Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8072022901 County Partially Vant lM Nearlifomia Elementary 2-12, Upper San Gabriel River Waterfied Management Groups San Gabriel 0535011901 Baldwin Park Site At Top Of Baldwin Park 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 8552011902 Baldwin Park Siena Vista High School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel SSS4018WO Baldwin Park Vineland Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8555012902 Baldwin Park mines (Charles Dj Middle School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0555017900 Baldwin Park Foster Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8561020900 Industry Touch Middle School 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel 8556009900 Baldwin Park Elwin Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8560008900 County Van Wig U E) Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8500004902, Baldwin Park Buildings And Parking Loc Near Channel 05000.00903 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8565020902 Industry Madridjlifred Sj Middle School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0550019901 Baldwin Park De Anna Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8608001927 Glendora George Manooshian Park And Goddard Middle School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8535011900 Baldwin Park Chose Middle School 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel. 8725005906 County Nogales High School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 9110029002, County Vant cut Near Channel 8110029903 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 85000.00901 Baldwin Park Truck Liading/Parking 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8000010900 County Cardiogram Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8656005909 Glendora Sellers Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0678001902 Glendora Citrus Community College (Buildings) 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8638027908 Glendora Glendora Civic Center 2-12, Upper San Gabdel River Watershed Management Groups San Gabriel 8562010901 County Bassett Park 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8253010900 County mlyn Rosas Park 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8031026001, Covina Covina Park 8031026900, 0031026901 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8031012900, Covina Edna Park 8031012901 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8265019900 County Gloria Hear Park 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel SILM015902, Covina Kohler Russell Park 8 0 78 015 90 3, 8078023901 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel 0030015900, Covina Kelby Park 8030035900 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0211003901 County cos Robles County Park 212, Upper San Gabriel River Watershed Management Groups San Gabriel. 8215012900 County Manzanim Park 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8608018909 Glendora Ole Hammer Park 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8007031901 Covina Pursue Nalapa 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8207010900 County Pepperbrook Park 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 07620.04902 County Rowland Heights Park 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8110012903, County San Angelo Park 8110012904, 8130012WS 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8200005915 County Stimson Park Steinmetz Park) 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8656005910 Glendora WillowSprings Park 2-12, Upper San Gabdel River Watershed ManagementGmups San Gabriel 0030026900 Covina Civic Center Park 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 8653002902, Glendora Gladsrone Park 8653002905, 8653002906 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8007001909 Covina Hallenbeck Park)Frd Priced) 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0727010902, County Sunshine Park 0727010903, 8727010900, 9727014905, 8727010906, 8727010907, 079010908, 8727010909, 0727010910, 8727010911, 0727010912, 0727010913 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 86351 Glendora Spending School Park 8635005901, 8635005902 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8760002900 County Santana High)Continuaton) School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8003013901 County Unknown School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8065013900, County Edgewood Moray 8065013901 2-12, Upper San Gabdel River Watershed Management Groups San Gabriel 8272001900 County Alvarado Middle School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 8503015900 Baldwin Park Holland )ferry D) Middle School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0502001900 Baldwin Park Walnut Elementary School 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel. 8029017900, Covina Covina Elementary School 8029018900 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8002010939 Covina Glen Oak Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8761001900 County Iellick Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8506025900 Baldwin Park Bui pbarles) Elementary5chool 2-12, Upper San Gabriel River Watershed ManagementGmups W County Flood Con[ml District Enhanced Watershed Management Programs ESA/ 100070 Draft Program Environmental Impact Report 45 January 2015 Appendix EWMP Proposed BMP and Priority Project Data Region Apn luredictioni Land Use Type Add ones Figure Number and rdle San Gabriel 8415007930, Baldwin Park Geddes pErnest Rj Elementary School M15014932, 8015022930 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0043013930, Covina Covina Hip School 0003010930, 0443010931 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0551021936, Baldwin Park Tracy Elementary5chool 8551021939 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8601006930, Glendora Washington Elementary School 8601006931, 8601006932 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0552012931 Baldwin Park Kenmore Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 07220.00930 County to Seen Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0536025932 Baldwin Park Hersh (Margaret) Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0 4 28 016 93 8, County Royal Oak Middle Schall 8028016932 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 0434010931 Covina Las Palmas Middle School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 863500,4931 Glendora Sandburg Middle School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 0 414 018 93 0 Baldwin Park Pleasant View Elementary School 2-12, Upper San Gabriel Rlver Watershed Management Groups San Gabriel 0403WSWI Covina Charter Oak High School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0206WSWO County Don Julian ElementarySchool 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 911501000 County Andrews (Wallen) Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0 2 28 015 93 0 County Villamrta (Remote) Democracy School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8035002930 County Meadow Green ElementarySchool 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0400032930 County Sunkist Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8465022930, County Erwin (Thomas Mj Elementary School 0465022931 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0270023932 County Rowland (Remote) Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0178003930 County Nelson Ada S) Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 0201010930 to Puente BasseUSenior High School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0272020931, County Killian Elementary School 8272020932 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 81215027907 County Mill Elementarykhml 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8253010931 County Farjardo Bornotej Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0203008930 Lai Puente Sunset ElementarySchool 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0203015932 to Puente Iassaletfe Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0254008931, County Baltlwin Ademy ElementarySchool 0254008932 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8072018930 County Iifornia Elementarykhml 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel 0250001912 Industry Workman (William) High School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0251013930, Lai Puente Sierra Vista Middle Scherer] 0251010930 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel 8727010930 County Yorbita Ulcerate) Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0203001931 County Wedgeworth Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 02070.04931 County Wilson (Glen A) High School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0203036930 County Creation Middle School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 02070.04930 County Bixby Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0293016930 County Us Molinos Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0222022931 County Us Altos Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0215022930, County Newton Middle School 0215022931 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0211003932 County Us Robles Ademy Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0215001930 County Los Altos High School 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel. 9218013901, County Shadybend Elementary School 0218010937 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel 8220009930 County Palm Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0207011936, Lai Puente Workman Elementary5chool 8207011937 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8044010930 Covina Tri[ommunby Adult School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8601007930, Glendora Glenoaks Goff Course 8601007931, 0601007932, 8601007933, 0601007930, 8601007935, 8601007936, 8601007937, 8601007938, 8601007939, 8601007910, 8601007911, 8601007912, 8601007913, 8601007917, 8601007918, 8601007919, Ni 8601007921 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0554001930, Baldwin Park Baldwin Park City Hall SSMW1910 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0209025910 Industry Industry City Hall 2-12, Upper San Gabriel R'rver Watershed Management Groups San Gabriel 8206016933 Lai Puente Ia Puente City Hall 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0206003930, County Avenue Park 0206003931, 02060.04930 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0120019WS County San Jose Creek Overlook 2-12, Upper San Gabriel River Watershed Management Groups W County Flood Control District Enhanced Watershed Management Programs ESA/ 140070 Draft Program Environmental Impact Report 46 January 2015 Appendix EWMP Proposed BMP and Plenty Project Data Roger APn San Gabriel 0535020800, 8535020801, 0535020902, 8535020909, 8535021001, 8506001800, BS50001800, 05501 8550001803, 0500012801 San Gabriel 8550003270, 8550003271, 8550003273, 0551011220, 8551011271, 0556009272, 851 85W019272 San Gabriel. 8653003900 San Gabriel 8005001913 San Gabriel 8000021903, 1900 San Gabriel W260oSWO San Gabriel 8269040900, 0269000901 San Gabriel 8295021900, 0295021901 San Gabriel 8602017901, 8602018900, 8602018907, 0602018WS San Gabriel 8171028900 San Gabriel 8171015901 San Gabriel 8205007900 San Gabriel 8201020235, 8241021170, 8201025305 San Gabriel 0031012903 San Gabriel 8269003901, 8269003902 San Gabriel. MINIONS, 8119010906 San Gabriel. 8201001021, 0241001020 San Gabriel 8206030017 San Gabriel 8036016001, 8036016002 San Gabriel 8125026800, 81250261 Mn026902, 8125026903 San Gabriel 8762020030 San Gabriel 8152020002 San Gabriel. 0156020022 San Gabriel 8053019010 San Gabriel. 8032027005 San Gabriel 0226011033 San Gabriel 8661020017 San Gabriel 0130028067 San Gabriel UM020017 San Gabriel 0032014900 San Gabriel 8155018007, 81550180181 8155019010 San Gabriel. 8159003017 San Gabriel W31011017 San Gabriel. 8762018902, 8762018903 San Gabriel 8 0 28 013 90 1 San Gabriel 8027003901 San Gabriel 8402001001, 8402001002, 8002001022, 8002001023 San Gabriel UNW2029 San Gabriel 8764001131, 07MW1132 San Gabriel. 827600' 900 San Gabriel 0159005901 San Gabriel B1n019902, 8177019900, B1n01990s San Gabriel 8169"1 8169000901, 8169008902, 0169020030, 810020031, 8169020032, 8169020033, 0169020030, 8169020901, 0169020902, 8169020903, 8169020900 San Gabriel 822700,1900 luris iction/Ciry Land Use Type Address Baldwin Park Sce Utility Electril Tower Brownfelds Baldwin Park Iadwp Utility Electric Corridor Glendora Arrow High (Continuation) Covina Covina City Hall Covina CovinaValley Unified School District Sports Complex County Amelia Mayberry Park County Bill Blevins Park County Countryuootl Park Glendora Lane Pompei Memorial Sports Park County Mcnees Park County Sorensen Park County Thomas S Burton Park County Park County County County County County County County County County County Covin Covin County County County Covin County County County County County Covina Covin Covina County County County County County County County Los Altos Park Pathfinder Community Regional Park Pico Rivera Municipal Goff Course Pah Pah Southern lifamia univen'iry IN Health Sciences Rio Hondo Community College Wisdom Kids College Painter Avenue Christian Walker Ademy Sacred Heart Elementary School Western Christian lap pelta Christian Ademy Foothill Montessori Solid Faits Christian School Barren Future learning Center EI mino High (Continuation) School SG Gregory The Great East Whittier Center Children'SPLemy Yocum Elementary School Sonrise Christian Sonrise Christian SG rouise De kill Elementary School Figure Number and Tile 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabdel River Watershed Management Groups Cori Ademy 2-12, Upper San Gabriel River Watershed Management Groups Soumlands Chi Schools 2-12, Upper San Gabriel River Watershed Management Groups Rowland High Scholl 2-12, Upper San Gabriel River Watershed Management Groups Mulberry Elementary School 2-12, Upper San Gabriel River Watershed Management Groups Pioneer High School 2-12, Upper San Gabriel River Watershed Management Groups Aeolian Elementary School In Colima Elementary School 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups lA County Flood Control District Enhanced Watershed Management Programs ESA/ 140070 Draft Program Environmental Impact Report 47 January 2015 Appendix EWMP Proposed BMP and Plenty Project Data Region Apn Iuredictions iry Land Use Type Address Figure Number and rdle San Gabriel 8028005900 County Iuma Vista Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 817/021900 County West Whittier Elememary5chwl 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel 878010900, County Northam Bemo@j Elementary School 97MO10MI 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0031012903, County Los Altos/Monte Vise Elementary School 8031012900, 0031013WO 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8030008901, County Telechmn Elementary School 8030008902 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8176028WO County Phelan Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 817101SWO County Sorensen (Christian) Elememary5chshl 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 82580:9900 County Elantlbrtl Elementary5chml 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel 8178023900, County Los Miami Middle School 8178025901, 8178025902 2-12, Upper San Gabdel River Watershed Management Groups San Gabriel 8156028029, County Mckinnon (Howard l) Elementary School 0156028920 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0036009900 County Anil Christian School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 0060012WO County Granada Middle 5choal 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0176032901 County Edwards(Katherinej Middle Scheel 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0155008900, County Ceres Elementary School 8155008901 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8276002906 County Shelyn Elementary5chool 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0039016900 County Nen School Of Whittier 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0173022900 County Washington Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8151027WS County Iifornia High School 2-12, Upper San Gabdel River Watershed Management Groups San Gabriel 0036023WO County Rancho5tarbuck Middle School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8665012011, County Bishop Apart Memorial High 8665012013 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 87300M006, County SG Martha's Elementary School 0730006032 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0205016900 County Mesa Robles Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 820,14022900 County Choice Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 0215018002, County SG Mark'S Lutheran Elementary 8215018022, 8215018023, 8215018026, 82ss018027, 8215018028 2-12, Upper San Gabdel River Watershed ManagementGmups San Gabriel 8211013WO County Orange Grove Middle School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8215012901 County Kwis Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8178005001, County Brethren Christian School 8178005021, 8178005025, 8178005027 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 060/033036 Glendora SG Lui Entry High School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8555011011 Baldwin Park EasNalley Adventist 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel 8666008010 County Ieroy Boys Home Secondary 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 820502302/ County Um Molokan Elementary 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 868022900, County Hillview Middle School 828022901 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8170012023 County Palm View Christian 2-12, Upper San Gabdel River Watershed Management Groups San Gabriel 821/016020 aPuente New Montessori School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 820100' 001 aPuente SG Louis Of France 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8120005032 County Creative Comers 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 86/0012061 Glendora Foothill Christian 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 82720010/6 County Oxford School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 84010( 1 County Gateway Montesson And Preschool 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8453006036 Covina Ada Montessori 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8762010011 County Fairway French Center 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel 8531010017 Glendora Use Oak nyon 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8226001002 County Kids And Blacks Preschool&Kindergarten 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8222003050 County Morning Star Christian 5chml 2-12, Upper San Gabdel River Watershed Management Groups San Gabriel 82MO16037 County Hacienda Christian 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel. 8230001028 aPuente Sumet Christian 2-12, Upper San Gabdel River Watershed Management Groups San Gabriel 8156027021, County All Nations Ademy Of Excellence 8156027022 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8152001012 County Faith Lutheran Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8619011013 Glendora Hope Lutheran Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel W31013018 County Ie Lyme Forms De Downey 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8269011011 County New 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 7 016 01512 0 County First Evangelil Clourch Of Cerritos Children 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8001021062 County Beginning Montessori Childreni House 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8001036038 County Conine Baptist Ademy 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 865502/039 Glendora SG Dorothy Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 850.3000053 Baldwin Park Creative Planet School INThe Arts 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 82510160// LaPuente SG Joseph Elementary School 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8553007029 Baldwin Park SG turn The Baptist 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8258019036 County Rowland Christian Preschool 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8658002033, Glendora Bluebird Preserve 0658006015 2-12, Upper San Gabriel River Watershed ManagementGmups San Gabriel 9125012910, County Whittier Narrows Equestrian Center 8125062003, 812506290/ 2-12, Upper San Gabriel River Watershed Management Groups San Gabriel 8552017019 Baldwin Park Mid Valley learning Centers 2-12, Upper San Gabriel River Watershed Management Groups W County Flood Control District Enhanced Watershed Management Programs ESA/ 160676 Draft Program Environmental Impact Report 48 January 2015 Appendix EWMP Purposed BMP and Prionry Project Data Ranged San Gabriel San Gabriel San Gabriel San Gabriel San Gabriel San Gabriel San Gabriel San Gabriel San Gabriel San Gabriel San Gabriel San Gabriel San Gabriel San Gabriel San Gabriel APn Jurisdiction/City 0242013904, Industry 0242014900, 8262001010, 0262001011, 0262001900, 0262001902, 8262011011, 8262011930, 0262011931, 8262012028, 0262012220, 8262012221, 0262012222, 0262012223, 0262012224, 0262012225, 0262012226, 0262015900, 0262015902, 0262015904, 8262015905, 02 0115001904, County 8115001906 0125021933, County 8125026026, 0125026022, 8125026028 8710002902, County 0210002903, 8210003902, 0210003916 8265028900 County 8265002904, County 8265002906, 0265002908, 8265003904, 0295019900, 0295019901, 0295019903 8426026016, County 8426026018 0119 010 90 5, County 8119010906 8391015025, County 0391015022 0226020905 County 8026006900 County 0162029902, County 8162029908 Ni County 0636042022 8636013005, Glendora 8636013006, 8636013012, 8636016009 8658002019, Glendora 8658012030, 8658012031, 0658012032, 8658012033, 8658012034, 8658012035, 8658012036, 8658012032, 8658012038, 8658012039, 8658012040, 8658012041, 865801205q 8658012054, 8658012063, 8658018032, 8658018033, 8658018034, 8658018035, 8658018036,86 Land Use Type Address Industry Hills Golf Club San Jose Creek Water Reclamation Plant West Puente Hills Materials Recovery Facility thrown Polytechnic University Pomona Trailview Park Peter F Schabamm Regional Comity Park Via Verde Cou"Club Streamland Park Ivary Baptist Church And Schools 0¢hard Dale Elementary School recall Elementary School Lake Marie Elementary School Brodiaea Reserve Spectrum Reserve Gordon Mull Preserve Figure Number and Tilk 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Gmups 2-12, Upper San Gabnel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabnel River Watershed Management Groups 2- 12, Upper San Gabnel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabnel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups W County Flood Control District Enhanced Watershed Management Programs ESA / 14M24 Draft Program Environmental Impact Report 49 January 2015 Appendix EWMP proposed BMP and priority project Data Region Apo Jurisdiction/City Land Use Type Address San Gabriel 86"010056, Glendora South HMIs Park 8641010902, 0641013505, 8641013906, 8611013902, 0641011221, Ni 0641014901, 0644014902, 0644014901, 0644011905, 0611011907, 8641011909, 0641014910, 0644014911, 0641015911, 8641015914, 0614015915, Ni 8641027901, 0641027902, 86 San Gabriel 8]6400264], County Los Angeles Royal Vista Golf Course 0764002008 San Gabriel 8762022002, County Ius Angeles Royal Vista Golf Course 0762022005, 8762022006, 8762022008, 8762023001, 8]62023002 Figure Number and Tilk 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups 2-12, Upper San Gabriel River Watershed Management Groups IA County Flood Control District Enhanced Watershed Management Programs ESA / 140474 Draft Program Environmental Impart Report So January 2015 Appendix EWMP proposed BMP and prionry project Data Region Apn luritdiRion/CNy LaM Use Type Mtlrrss Figure Number and Tills FN4gep.A!�7k Upper Santa Clara 2802003908 L A Co Flood Control Dist 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 28020900 13 LACaunry 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2805013900 Saugus Union School Dist 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2 8110 2 9 90 0 Santa Clarity City 2-16, Upper Santa Clara Elver Watershed Management German Upper Santa Clara 2 8110 2 9 90 1 Saugus Union School District 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2836018900 Sane Clarim City 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2832033900 Sane Claim City 2-16, Upper SantaClara Elver Watershed Management Group Upper Santa Clara 2844013900 Sane Claude City 2-16, Upper SantaClara Ever Watershed Management Group Upper Santa Clara 2844021900 Sane Clane City 2-16, Upper Santa Clara Elver Watershed Management Group Upper Santa Clara 2844006904 Sane Clarim City 2-16, Upper SantaClara Ever Watershed Management Group Upper Santa Clara 28538900 40 Sane ClaimCCityEl 2-16, Upper Santa Clara ver Watershed Management Group Upper Santa Clara 2865024906 Water Dist 2-16, Upper Sane Clara Ever Watershed Management Group Upper Santa Clara 2865024901 LA County LA Countytyo 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 286601/900 LACounty 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2866020909 Castaic Union School District 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2866020910 School District 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 2866015900 L A CocUnion LAComrty 2-16, Upper SantaClara Elver Watershed Management German Upper Santa Clara 286501/93/ Casic Union School Dix[ 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 2866020908 CmSchool District 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 2825010929 meCUnion Sane Claims lone Ciry 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 28220/0900 La CO Flood Control Dlx[ 2-16, Upper SantaClara Ever Watershed Management Group Upper Santa Clara 282203/901 L Amo Flood City Dist 2-16, Upper Santa Clara Elver Watershed Management Group Upper Santa Clara 2833016900 San e Claudia nCity 2-16, Upper SantaClara Ever Watershed Management Group Upper Santa Clara 2822022900 LA Co Flood Control Dist 2-16, Upper Santa Clara Elver Watershed Management Group Upper Santa Clara 2822022901 L A Co Flood Control Dist 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2822001901 LA County 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 28290 LACa Flood Control Dist 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 283301290012WO Sane Clarim City 2-16, Upper SantaClara Elver Watershed Management Group Upper Santa Clara 283102691/ SaneCity 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 2827001908 LA County 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2822001900 LACounty 2-16, Upper SantaClara Elver Watershed Management Group Upper Santa Clara 2822011902 LACa 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 283101/900 Sane Claud City 2-16, Upper Sane Clara River Watershed Management Group Upper Santa Clara 2826130900 LA County 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2827001904 LA County 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2822011903 LACounty 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2833014902 Sane Claim City 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2831006900 Sane Claude City 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2831009900 Sane Clarim City 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 283301/903 City ou[lari[a 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 283300590/ LAConty mrty 2-16, Upper SantaClara Elver Watershed Management Group Upper Santa Clara 2855006904 WilliamHigh School 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2855006902 me Claim City Sane Clarim Ciry 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 28550011 Ha Wiliam Hart Union High School 2-16, Upper Santa Clara Elver Watershed Management Group Upper Santa Clara 2833005903 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 2855006900 Wiliam William SHart Union 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2855011902 LAB Flood Control Dix[ 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 34 28024918 Sane Clarim City 2-16, Upper SantaClara Elver Watershed Management Group Upper Santa Clara 2855006901 Sane Claim Ciry 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2855011901 LA d Control Dist 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2858012900 hall School Newhall Schooltro 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2855011900 Control Dist 216, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 285901/900 &me Claim Saneuny City 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 2859030900 LA County 2-16, Upper SantaClara Ever Watershed Management Group Upper Santa Clara 2859030901 LA County 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2859013902 Housing Authority 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 2859030902 meClaude &ne SaClane Ciry 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2858002900 Sane Claim City 2-16, Upper Sane Clara Ever Watershed Management Group Upper Santa Clara 2836036900 Sane Clarim City 2-16, Upper Santa Clara Elver Watershed Management Group Upper Santa Clara 2836064900 Sane Claim City 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 2860003900 Sane Clarim CCity2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 2861026900 Sane Clane City 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2861009905 SaneClarim City 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2861024' County 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 2 8110 65 90 2 &meClari Sane Clarim City 2-16, Upper SantaClara Elver Watershed Management Group Upper Santa Clara 2861024'903 Sane Claim City 2-16, Upper SantaClara Ever Watershed Management Group Upper Santa Clara 2861009902 Sane Claude City 2-16, Upper SantaClara Ever Watershed Management Group Upper Santa Clara 2861009906 Sane Claude City 2-16, Upper SantaClara Elver Watershed Management Group Upper Santa Clara 2812009900 Sane Clone City 2-16, Upper SantaClara Ever Watershed Management Group Upper Santa Clara 3244150900 LA County 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2 8 26 119 900 LACaunry 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2832020900 SaneCity 2-16, Upper Santa Clara Elver Watershed Management Group Upper Santa Clara 2826022901 LACaununry 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2834023950 SantaClarimPa City 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2826160901 InCounty 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2 810 0 4190 0 Clan Ci Sane Clarim City 2-16, Upper SantaClara Elver Watershed Management Group Upper Santa Clara 2810032901 Sane Claim City 2-16, Upper SantaClara Ever Watershed Management Group Upper Santa Clara 2831011904 Sane Clarim City 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 283101 Sane Claude City 2-16, Upper Santa Clara Elver Watershed Management Group Upper Santa Clara 28360129052WS Sane Claude City 2-16, Upper SantaClara Ever Watershed Management Group Upper Santa Clara 280203890/ Sane Claude City 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2802038902 Sane Clone City 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2865012916 LA County 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2865021902 LA County 2-16, Upper Sane Clara Ever Watershed Management Group Upper Santa Clara 2826150900 La CO Flood Control Dix[ 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2866042900 Sane Clone City 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2810032902 Saugus Union School Dirt 2-16, Upper SantaClara River Watershed Management Group Upper Santa Clara 2810020900 Sane Claim City 2-16, Upper SantaClara Ever Watershed Management Group Upper Santa Clara 28610 2-16, Upper Santa Clara Elver Watershed Management Group Upper Santa Clara 28260259007SWO LACounty 2-16, Upper SantaClara Ever Watershed Management Group Upper Santa Clara 3220021900 LA County 2-16, Upper SantaClara Ever Watershed Management Group Upper Santa Clara 2865018900 LACounty 2-16, Upper SantaClara Elver Watershed Management Group Upper Santa Clara 281 Sane Clarim City 2-16, Upper SantaClara Ever Watershed Management Group Upper Sane Clara 280000392MW3920 Sane Clone City 2-16, Upper Sane Clara Elver Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 111324 Draft Program Environmental Impact Report 51 January 2015 Appendix FAME proposed BMP and priority project Data Region Apn lurediction/Ciry Land Use Type Address Figure Number and Tisk Upper Santa Clara 2810110900 2-16, Upper Santa Clara River WatersM1etl Management Group Upper Santa Clara 2800003919 LA County 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 3220020902 LA County 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2831006901 Santa Clarita City 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2831006903 Santa Clarity City 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2831006902 Santa Claim City 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 28101WWO LA Co Flood Control Dist 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2826085900 NeviM1all School District 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 2800003921 LA County 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 28MW3922 Sane Clarity City 2-16, Upper Santa Clara River Watershed Management Group Upper Santa Clara 3201035900 Sane Claude City 2-16, Upper Santa Clara Ever Watershed Management Group Upper Santa Clara 2833005902 LA County 2-16, Upper Sane Clara Elver Watershed Management Group Upper Santa Clara 2836018901 Sane Claim City 2-16, Upper Sane Clara Ever Watershed Management Group Upper Santa Clara 2865012912 LA County 2-16, Upper Sane Clara River Watershed Management Group Upper Santa Clara 2810001903 Hart William S Union High School 2-16, Upper Sane Clara River Watershed Management Group Upper Santa Clara 2866005806 2-16, Upper Sane Clara River Watershed Management Group Upper Santa Clara 2861009900 Sane Clare City 2-16, Upper Sane Clara Ever Watershed Management Group Upper Santa Clara 2811062904 Same Clarie City 2-16, Upper Sane Clara River Watershed Management Group Upper Santa Clara 2859002901 L A Co Flood Cmrtml Dist 5 By 5 2-16, Upper Sane Clara Ever Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA/ 100020 Draft Program Environmental Impact Report 52 January 2015 Appendix EWMP proposed BMP and priority project Data Region Apn lurisdiction/Ciry Lam! Use Tirps Ballon 4259018901 Los Angeles Balloon 4261003900 Los Angeles Ballon 4261011911 Los Angeles Ballon 4261011912 Ins Angeles Ballon 4261013900 Ins Angeles Ballon 4261018900 Los Angeles Balloon 42620..1900 Los Angeles Ballon 4263022901 Ins Angeles Balloon 4262023900 Los Angeles Balloon 4261010908 Ins Angeles Ballon 4262032901 Los Angeles Balloon 4263021904 Ins Angeles Balloon E017012WO Los Angeles Ballon 6019003905 Los Angeles Balloon 4105016900 Los Angeles Ballon 4105026900 Ins Angeles Ballon 4211012900 Ins Angeles Ballon 421H002908 Ins Angeles Ballon 4218D02906 Ins Angeles Balloon 4249011900 Los Angeles Ballon 4258005900 Ins Angeles Ballon 4258016900 Los Angeles Balloon 4365009900 Ins Angeles Ballon 4005023900 Los Angeles Balloon 4006013900 Ins Angeles Balloon 4006014900 Los Angeles Ballon 4006011901 Los Angeles Ballon 4006019900 Ins Angeles Ballon 4005019901 Ins Angeles Ballon MB029901 Inglewood Balloon 4014007900 Inglewood Balloon 4014007901 Inglewood Balloon 4015013901 Inglewood Balloon 401501590o Inglewood Ballon 4012026900 Inglewood Balloon 4012026901 Inglewood Balloon 4012032902 Inglewood Ballon 4012026903 Inglewood Balloon 4012026902 Inglewood Ballon 4012032908 Inglewood Ballon 4012031905 Inglewood Ballon 4122016901 Ins Angeles Ballon 4205015902 Culver City Balloon 4206027900 Culver City Ballon 420902700 Culver City Ballon 4209032900 Culver City Ballon 4210021900 Culver City Ballon 4210025900 Culver City Ballon 4213006901 Culver City Balloon 4215005905 Los Angeles Ballon 4213026902 Culver City Ballon 4215031902 Los Angeles Ballon 4251010902 Ins Angeles Ballon 4252023900 Los Angeles Balloon 4254023901 Los Angeles Ballon 4314014900 Ins Angeles Balloon 5001002908 Los Angeles Balloon 5003014920 Ins Angeles Ballon 5003013901 Los Angeles Balloon 5003021900 Ins Angeles Balloon 5005006903 Los Angeles Ballon 5005006907 Los Angeles Balloon 5005007904 Los Angeles Ballon 5005007911 Ins Angeles Ballon 5005005900 Los Angeles Ballon 5005006909 Ins Angeles Ballon 5005007905 Ins Angeles Balloon 5005006910 Los Angeles Ballon 5005006911 Ins Angeles Ballon 5005007909 Los Angeles Balloon 5005007907 Ins Angeles Ballon 5005006912 Los Angeles Ballona 5005005901 Los Angeles Ballon 5005006908 Los Angeles Ballona 5005007913 Ins Angeles Ballon 5005007912 Los Angeles Ballon 5005007914 Ins Angeles Ballon 5005007915 Los Angeles Balloon 5005007916 Los Angeles Ballon 5005007906 Ins Angeles Balloon 5005007910 Los Angeles Balloon 5005019900 Los Angeles Ballon 5005007908 Los Angeles Balloon 5006007900 Los Angeles Balloon 5006008900 Los Angeles Ballon 5006000902 Los Angeles Ballon 5007011900 La County Ballon 5010003900 La County Ballon 5 014 0019 2 2 Los Angeles Ballon 5014024901 Ins Angeles Ballon 5014024900 Ins Angeles Balloon 5016015926 Los Angeles Balloon 5012001905 Ins Angeles Ballon 5017013901 Los Angeles p�Actress Figure Number and rdle neGAd�;n_gq 23, Ballon Creek WatershedManagement Group 23, Ballon Creek Watershed Management Group 23, Ballon Creek WatershedManagement Group 2E, Ballon Creek Watershed! Management Group 23, Ballon Crack Watershed Management Group 2L, Ballon Crack Watershed Management Group 2d, Ballon Creek Watershed! Management Group 2L, Ballon Crack Watershed Management Group 23, Ballon Crack Watershed! Management Group 23, Ballon Crack Watershed Management Group 23, Ballon Crack Watershed!Management Group 23, Ballonre Creek Watershed Management Group 23, Ballonre Creek Watershed Management Group 23, Balloon re Creek WatershedManagement Group 2E, Ballon Creek Watershed! Management Group 23, gagman Cheek WatershedManagement Group 2E, Ballon Creek Watershed! Management Group 23, Ballon Creek Watershed! Management Group 2L, Ballon Crrek Watershed Management Group 23, Ballon Crrek Watershed! Management Group 23, Ballon Crack Watershed Management Group 23, Ballon Crack Watershed! Management Group 23, Ballon Crack Watershed Management Group 23, Ballon Crack Watershed!Management Group 23, Ballonre Creek Watershed Management Group 23, Ballon Creek Watershed Management Group 23, Ballon re Crk WatershedManagement Group 2a, Ballon Creek Watershed! Management Group 23, Ballon re Crk Watershed Management Group 2L, Ballon Crrek Watershed Management Group 23, Ballon Creek Watershed!Management Group 2L, Ballon Crrek Watershed Management Group 23, Ballon Crack Watershed Management Group 23, Ballon Crack Watershed Management Group 23, Ballon Crack Watershed!Management Group 23, Ballonre Creek Watershed Management Group 23, Ballonre Creek Watershed Management Group 23, Balloon re Creek WatershedManagement Group 2E, Ballon Creek Watershed! Management Group 23, BalloCheekCrk WatershedManagemeGroup 2E, Ballon Creek Watershed! Management Group 23, Ballon Creek Watershed! Management Group 2L, Ballon Crrek Watershed Management Group 23, Ballon Crrek Watershed!Management Group 23, Ballon Crack Watershed Management Group 23, Ballon Crack Watershed Management Group 23, Ballon Crack WatershedManagement Group 23, Ballonre Creek Watershed Management Group 23, Ballonre Creek Watershed Management Group Creek 23, gallons Watershed Management Group 23, gagman Cheek Watershed Management Group 2E, Ballon Creek Watershed Management Group 23, BalloCheekCrk WatershedManagement Group 2E, Ballon Creek Watershed! Management Group 2d, Ballon Creek Watershed!Management Group 2L, Ballon Crrek Watershed Management Group 23, Ballon Crack Watershed Management Group 23, Ballon Crack WatershedManagement Group 23, Ballon Crack Watershed Management Group 23, Ballon Creek WatershedManagement Group 23, Ballon Cook Watershed Management Group 23, Balloon re Creek WatershedManagement Group 2a, Ballon Creek Watershed! Management Group 23, BalloCheekCrk WatershedManagemeGroup 2a, Ballon Creek Watershed! Management Group 2d, Ballon Creek Watershed! Management Group 2L, Ballon Crrek Watershed Management Group 23, Ballon Crrek Watershed!Management Group 23, Ballon Crack Watershed Management Group 23, Ballon Crack Watershed Management Group 23, Ballon Crack WatershedManagement Group 23, Ballon Cook Watershed Management Group 23, Ballonre Creek Watershed Management Group 23, Ballon Cook Watershed Management Group 23, Ballon re Crk WatershedManagement Group 2E, Ballon Creek Watershed! Management Group 23, BalloCheekCrk WatershedManagemeGroup 2-6, Ballon Creek Watershed! Management Group 2d, Ballon Creek Watershed! Management Group 2L, Ballon Crrek Watershed Management Group 23, Ballon Crack Watershed! Management Group 23, Ballon Crack Watershed Management Group 23, Ballon Crack Watershed!Management Group 23, Ballonre Creek Watershed Management Group 23, Ballon Cook Watershed Management Group 23, Ballon Crrek WatershedManagement Group 2a, Ballon Creek Watershed! Management Group 23, BalloCrookCrk Watershed Management Group 2a, Ballon Creek Watershed Management Group 2d, Ballonre Cek Watershed Management Group 2L, Ballon Crrek Watershed Management Group 23, Ballon Crrek Watershe Management Group 23, Ballon Crack Watershed! Management Group 23, Ballon Crack Watershed! Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 140474 Draft Program Environmental Impact Report 53 January 2015 Appendix EWMP proposed BMP and priority project Data Region Apn Jurisdiction/City Land Use Type Address figure Number and rdle Balloon 5017013904 Los Angeles 2L, Ballon Creek Watershed Management Group Balloon S017020WO Los Angeles 23, Ballon Creek Watershed Management Group Balloon SOMM3914 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon SOM024WO Los Angeles 24,Ballon Creek Watershed Management Group Balloon 5019004903 Los Angeles 2a, Balloon Creek Watershed Management Group Balloon 5020029902 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5021012902 Los Angeles 2L, Ballon Creek Watershed Management Group Balloon 5023027WO Los Angeles 2d, Ballon Dark Watershed Management Group Balloon 5024018901 Ins Angeles 2L, Ballon Creek Watershed Management Group Balloon 502401SWO Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5024019WO Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5024018902 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5024019904 Ins Angeles 2-6, Balloon Creek Watershed Management Group Balloon 5024029901 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 502801902 Los Angeles 2-6, Balloon Creek Watershed! Management Group Balloon 5030015900 Los Angeles 2E, 8allona Creek Watershed! Management Group Balloon 50310..1900 Ins Angeles 23, gagman Creek Watershed Management Group Balloon 5032003901 Los Angeles 2E, 8allona Creek Watershed! Management Group Balloon 5032003902 Ins Angeles 23, Fallcon Dark Watershed Management Group Balloon 5032003900 Ins Angeles 2L, Ballon Creek Watershed Management Group Balloon 50330..1901 Los Angeles 23, Fallcon Dark Watershed Management Group Balloon 5034010900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5036026912 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5036026901 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5036025910 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5036026914 Ins Angeles 24, Balloon Creek Watershed Management Group Balloon 5036026WO Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5036027WO Los Angeles 2-6, Balloon Creek Watershed! Management Group Balloon 5036026902 Los Angeles 2E, 8allona Creek Watershed! Management Group Balloon 5032028909 Ins Angeles 24, gagman Creek Watershed Management Group Balloon 5040004900 Los Angeles 2L, Ballon Creek Watershed Management Group Balloon 5040016908 Los Angeles 23, gagman Dark Watershed Management Group Balloon 5040030905 Ins Angeles 2L, Ballon Creek Watershed Management Group Balloon 5041011902 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5041013905 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5041026WO Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5041034WO Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5041034901 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5042008904 Los Angeles 2-6, Balloon Creek Watershed Management Group Balloon 5042008902 Los Angeles 2E, 8allona Creek Watershed! Management Group Balloon 5045001900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5046004902 Los Angeles 2E, 8allona Creek Watershed! Management Group Balloon 5045019900 Ins Angeles 24, Falcon Creek Watershed Management Group Balloon 5046013900 Ins Angeles 2L, Ballon Creek Watershed Management Group Balloon 5047018924 Los Angeles 23, Fallcon Dark Watershed Management Group Balloon 5049017901 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5050006905 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5050006909 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5050022WO Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5051038911 Ins Angeles 2-6, Balloon Creek Watershed! Management Group Balloon 5054029912 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5054031901 Los Angeles 24, gagman Creek Watershed Management Group Balloon 5054029906 Los Angeles 2E, 8allona Creek Watershed! Management Group Balloon 5059003901 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5 123 0 0 8 910 Los Angeles 2L, Ballon Creek Watershed Management Group Balloon 5124009902 Los Angeles 2d, Ballon treek Watershed Management Group Balloon 5124020903 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 5124023911 Los Angeles 26, Ballon treek Watershed Management Group Balloon 5124000903 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 5124023909 Los Angeles 26, Ballon Creek Watershed Management Group Balloon 5124021906 Ins Angeles 2-A Balloon Creek Watershed! Management Group Balloon 6001016WO Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 6001019900 Los Angeles 2-A Balloon Creek Watershed! Management Group Balloon E001014WO Los Angeles 26, 8allona Creek Watershed! Management Group Balloon E001017MI Ins Angeles 23, Ballon Creek Watershed Management Group Balloon W02024WO Los Angeles 26, 8allona Creek Watershed! Management Group Balloon 6003013908 Ins Angeles 26, Fallcon Dark Watershed Management Group Balloon 6003013906 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 6003005908 Los Angeles 26, Fallcon Dark Watershed Management Group Balloon 6003006901 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 6003013907 Los Angeles 26, Ballon Creek Watershed! Management Group Balloon 6004002903 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 6004006900 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 6016023912 Los Angeles 2-A Balloon Creek Watershed! Management Group Balloon 5056018912 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5056014908 Los Angeles 2-A Balloon Creek Watershed! Management Group Balloon 5056024906 Los Angeles 26, 8allona Creek Watershed! Management Group Balloon 5055024901 Ins Angeles 24, Ballon Creek Watershed Management Group Balloon 5056025908 Los Angeles 2-6, Balloon Creek Watershed Management Group Balloon 5056025909 Los Angeles 2-6, Balloon Dark Watershed Management Group Balloon 5056024905 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 5056024904 Los Angeles 26, Ballon Creek Watershed! Management Group Balloon 5056030904 Los Angeles 24, Ballon Creek Watershed Management Group Balloon 5056024903 Los Angeles 26, Ballon Creek Watershed! Management Group Balloon 5056030909 Ins Angeles 2-A Balloon Creek Watershed! Management Group Balloon SOM03OWS Los Angeles 24, Ballon Creek Watershed! Management Group Balloon 5060030901 Los Angeles 2-A Balloon Creek Watershed! Management Group Balloon SOW03OW2 Los Angeles 26, 8allona Creek Watershed! Management Group Balloon 5060031WO Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5061014WO Los Angeles 26, 8allona Creek Watershed! Management Group Balloon 5071022WO Ins Angeles 26, Fallcon Dark Watershed Management Group Balloon 5072013WO Ins Angeles 26, Ballon Creek Watershed! Management Group Balloon 5072014901 Los Angeles 26, Ballon Dark Watershed Management Group Balloon 5072012917 Ins Angeles 26, Ballon Creek Watershed! Management Group Balloon 5072014902 Los Angeles 26, Ballon Creek Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 14174 Draft Program Environmental Impact Report 54 January 2015 Appendix EWMP proposed BMP and priority project Data Region Apn Jurisdiction/City Land Use Type Address figure Number and rdle Balloon 5073001N0 Los Angeles 2L, Ballon Creek Watershed Management Group Balloon 5073001901 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5073018WO Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5023013900 Los Angeles 24,Ballon Creek Watershed Management Group Balloon 5073018MI Los Angeles 2a, 8allona Creek Watershed Management Group Balloon 5075010900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5075035902 Los Angeles 2L, Ballon Creek Watershed Management Group Balloon 5075034906 Los Angeles 2d, Ballon Dark Watershed Management Group Balloon 5075035911 Ins Angeles 2L, Ballon Creek Watershed Management Group Balloon 5075033900 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5075035900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5075035913 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5075033901 Ins Angeles 2-6, Balloon Creek Watershed Management Group Balloon 5076008900 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5076002900 Los Angeles 2-6, Balloon Creek Watershed! Management Group Balloon 5072006900 Los Angeles 2E, 8allona Creek Watershed! Management Group Balloon 5072009913 Ins Angeles 23, gagman Creek Watershed Management Group Balloon 5072006901 Los Angeles 2E, 8allona Creek Watershed! Management Group Balloon 5072022900 Ins Angeles 23, Fallcon Dark Watershed Management Group Balloon 5077026903 Ins Angeles 2L, Ballon Creek Watershed Management Group Balloon 5078W1920 Los Angeles 23, Fallcon Dark Watershed Management Group Balloon 5077021900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5078002904 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5072026902 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5078002905 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5078024910 Ins Angeles 24, Balloon Creek Watershed Management Group Balloon 5080012WS Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5080016907 Los Angeles 2-6, Balloon Creek Watershed! Management Group Balloon 5080016910 Los Angeles 2E, 8allona Creek Watershed! Management Group Balloon 5080019911 Ins Angeles 24, gagman Creek Watershed Management Group Balloon 5080012904 Los Angeles 2L, Ballon Creek Watershed Management Group Balloon 5080016908 Los Angeles 23, gagman Dark Watershed Management Group Balloon 5080019921 Ins Angeles 2L, Ballon Creek Watershed Management Group Balloon 5080023900 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5080023903 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5080023904 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5080032903 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5082007910 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5082011903 Los Angeles 2-6, Balloon Creek Watershed Management Group Balloon 5082007903 Los Angeles 2E, 8allona Creek Watershed! Management Group Balloon 5082012900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon S083W1900 Los Angeles 2E, 8allona Creek Watershed! Management Group Balloon 5003032900 Ins Angeles 24, Falcon Creek Watershed Management Group Balloon 5084005905 Ins Angeles 2L, Ballon Creek Watershed Management Group Balloon 5090012900 Los Angeles 23, Fallcon Dark Watershed Management Group Balloon 5090026900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5092008915 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5092011901 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5092011904 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5094006902 Ins Angeles 2-6, Balloon Creek Watershed! Management Group Balloon 5094006905 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5094006903 Los Angeles 24, gagman Creek Watershed Management Group Balloon 5094006904 Los Angeles 2E, 8allona Creek Watershed! Management Group Balloon 51350..1900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5135025900 Los Angeles 2L, Ballon Creek Watershed Management Group Balloon 5132002913 Los Angeles 2d, Ballon treek Watershed Management Group Balloon 5132002911 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 5132014903 Los Angeles 26, Ballon treek Watershed Management Group Balloon 5141016900 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 5141WSWI Los Angeles 26, Ballon Creek Watershed Management Group Balloon 5141016902 Ins Angeles 2-A Balloon Creek Watershed! Management Group Balloon 5141006904 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5141016WS Los Angeles 2-A Balloon Creek Watershed! Management Group Balloon 5141016903 Los Angeles 26, 8allona Creek Watershed! Management Group Balloon 5141003900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5141017WS Los Angeles 26, 8allona Creek Watershed! Management Group Balloon 5142023900 Ins Angeles 26, Fallcon Dark Watershed Management Group Balloon 5142013911 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 5142013906 Los Angeles 26, Fallcon Dark Watershed Management Group Balloon 5142026906 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 5153004900 Los Angeles 26, Ballon Creek Watershed! Management Group Balloon 5152015905 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 5152014900 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5152018903 Los Angeles 2-A Balloon Creek Watershed! Management Group Balloon 5152018900 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5501010900 Ins Angeles 2-A Balloon Creek Watershed! Management Group Balloon 5501008908 Los Angeles 26, 8allona Creek Watershed! Management Group Balloon 5501010909 Ins Angeles 24, Ballon Creek Watershed Management Group Balloon 5501017902 Los Angeles 2-6, Balloon Creek Watershed Management Group Balloon 5501014901 Los Angeles 26, Ballon treek Watershed Management Group Balloon S501014WO Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 5501010904 Los Angeles 26, Ballon Creek Watershed! Management Group Balloon 5501020900 Los Angeles 24, Ballon Creek Watershed Management Group Balloon 5501010902 Los Angeles 26, Ballon Creek Watershed! Management Group Balloon 5501024900 Los Angeles 2-A Balloon Creek Watershed! Management Group Balloon 5502018902 Los Angeles 24, Ballon Creek Watershed! Management Group Balloon 5504008900 Los Angeles 2-A Balloon Creek Watershed! Management Group Balloon 5504008901 Los Angeles 26, 8allona Creek Watershed! Management Group Balloon 5507012900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5513030900 Ins Angeles 26, 8allona Creek Watershed! Management Group Balloon 5516002900 Ins Angeles 26, Fallcon Dark Watershed Management Group Balloon 5517007916 Ins Angeles 26, Ballon Creek Watershed! Management Group Balloon 5517007917 Los Angeles 26, Ballon Dark Watershed Management Group Balloon 5517007918 Ins Angeles 26, Ballon Creek Watershed! Management Group Balloon 5512014900 Los Angeles 26, Ballon Creek Watershed Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 14174 Draft Program Environmental Impact Report 55 January 2015 Appendix EWMP proposed BMP and priority project Data Region Apn Jurisdiction/City Land Use Type Address figure Number and rdle Failure 5518032906 Los Angeles 2L, Ballon Creek Watershed Management Group Ballon SSU032900 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5520014WO Los Angeles 23, Ballon Creek Watershed Management Group Ballon 5520018901 Los Angeles 24, Hagman Creek Watershed Management Group Balloon 5522023903 Ins Angeles 2a, gagman Creek Watershed Management Group Balloon 5532013900 Ins Angeles 24, Hagman Creek Watershed Management Group Balloon 5533012901 Ins Angeles 2L, Hagman Creek Watershed Management Group Balloon 5533018WO Los Angeles 2d, Hagman Dark Waterman] Management Group Balloon 5533014WO Ins Angeles 2L, Hagman Creek Watershed Management Group Balloon 5533017WO Los Angeles 23, Hagman Creek Watershed Management Group Balloon 5535032WO Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5535032907 Los Angeles 23, Hagman Creek Watershed! Management Group Balloon 5536014WO Ins Angeles 2-6, Balloon Creek Watershed Management Group Balloon 5535032WS Los Angeles 23, Ballon Creek Watershed Management Group Ballon 5535032904 Los Angeles 2-6, Balloon Creek Watershed Management Group Balloon 5535032906 Los Angeles 2E, 8allona Creek Watershed Management Group Balloon 5535032903 Ins Angeles 23, gagman Creek Watershed Management Group Balloon 5536014WS Ins Angeles 2E, 8allona Creek Watershed Management Group Balloon 5535033WO Ins Angeles 2-6, Balloon Dark Waterman] Management Group Balloon 5535032901 Ins Angeles 2L, Hagman Creek Watershed Management Group Balloon 5535032902 Los Angeles 2-6, Balloon Dark Waterman] Management Group Balloon 4255019WO Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 4255020WO Los Angeles 23, Ballon Creek Watershed Management Group Balloon 4255021900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 4256011902 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 4256011901 Ins Angeles 24, Balloon Creek Watershed Management Group Balloon 4301017904 Los Angeles 23, Ballon Creek Watershed Management Group Ballon 4305003900 Los Angeles 2-6, Balloon Creek Watershed Management Group Balloon 4307013909 Los Angeles 2E, 8allona Creek Watershed Management Group Balloon 4307012902 Ins Angeles 24, gagman Creek Watershed Management Group Balloon 4307014908 Los Angeles 2L, Hagman Creek Watershed Management Group Balloon 4300002901 Los Angeles 23, Hagman Dark Watershed Management Group Balloon 4300002902 Ins Angeles 2L, Hagman Creek Watershed Management Group Balloon 4318001900 Los Angeles 24, Hagman Creek Watershed Management Group Balloon 4319001902 Beverly Hills 23, Ballon Creek Watershed Management Group Failure 4 319001900 Beverly Hills 24, Hagman Creek Watershed! Management Group Balloon 4319001901 Beverly Hills 23, Ballon Creek Watershed Management Group Balloon 4319003900 Los Angeles 23, Ballon Creek Watershed Management Group Ballon 4321015900 Los Angeles 2-6, Balloon Creek Watershed Management Group Balloon 4325005932 Los Angeles 2E, 8allona Creek Watershed Management Group Balloon 4325030900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 4326016900 Los Angeles 2E, 8allona Creek Watershed Management Group Balloon 4378005900 Beverly Hills 23, Ballon Creek Watershed Management Group Balloon 4331009900 Beverly Hills 2L, Hagman Creek Watershed Management Group Balloon 4331012901 Beverly Hills 24, Balloon Dark Watershed Management Group Balloon 4331012900 Beverly Hills 23, Ballon Creek Watershed Management Group Balloon 4333017904 Beverly Hills 24, Hagman Creek Watershed Management Group Balloon 4333017906 Beverly Hills 23, Ballon Creek Watershed Management Group Balloon 4333017905 Beverly Hills 23, Ballon Creek Watershed Management Group Ballon 4333026900 Beverly Hills 2-6, Balloon Creek Watershed Management Group Balloon 4333026901 Beverly Hills 23, Ballon Creek Watershed Management Group Ballon 4333031900 Beverly Hills 24, gagman Creek Watershed Management Group Balloon 4336008909 West Hollywood 2E, 8allona Creek Watershed Management Group Balloon 4336008910 West Hollywood 24, Hagman Creek Watershed Management Group Balloon 5063021901 Los Angeles 2L, Hagman Creek Watershed Management Group Balloon 5063022908 Los Angeles 2d, Ballon treek Watershed Management Group Balloon 5064029908 Ins Angeles 2-6, Hagman Creek Watershed Management Group Balloon 5000024901 Los Angeles 2-6, Balloon Dark Watershed Management Group Balloon 5068008900 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 5069031902 Los Angeles 24, Hagman Creek Watershed Management Group Balloon 5070013906 Los Angeles 2-A Balloon Creek Watershed Management Group Balloon 5070013907 Los Angeles 23, Ballon Creek Watershed Management Group Ballon 5070013904 Los Angeles 2-A Balloon Creek Watershed Management Group Balloon 5089010900 Los Angeles 26, 8allona Creek Watershed Management Group Balloon 5089018900 Ins Angeles 24, Hagman Creek Watershed Management Group Balloon 5069005900 Los Angeles 26, 8allona Creek Watershed Management Group Balloon 5089011900 Ins Angeles 2-6, Balloon Dark Waterman] Management Group Balloon 5089003901 Ins Angeles 26, Hagman Creek Watershed Management Group Balloon 5089020WO Los Angeles 2-6, Balloon Dark Waterman] Management Group Balloon 5500018902 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 5512004903 Los Angeles 24, Hagman Creek Watershed Management Group Balloon 551200907 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 5525010WO Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5527021WO Los Angeles 2-A Balloon Creek Watershed Management Group Balloon 5 5 78 018 90 0 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5529000900 West Hollywood 2-A Balloon Creek Watershed Management Group Balloon 5529020901 Ins Angeles 26, gagman Creek Watershed Management Group Balloon 5529020WO West Hollywood 24, Ballon Creek Watershed Management Group Balloon 5529023901 Ins Angeles 2-6, Balloon Creek Watershed Management Group Balloon 5531020WO Los Angeles 26, Ballon treek Waterman] Management Group Balloon 4340003900 West Hollywood 26, Hagman Creek Watershed Management Group Balloon 4341029901 Beverly Hills 24, Hagman Creek Watershed Management Group Balloon 4341029900 Beverly Hills 24, Ballon Creek Watershed Management Group Balloon 4358003900 Ins Angeles 24, Hagman Creek Watershed Management Group Balloon 4359014902 Ins Angeles 2-A Balloon Creek Watershed Management Group Balloon 4359019900 Beverly Hills 24, Ballon Creek Watershed Management Group Ballon 4359018900 Los Angeles 2-A Balloon Creek Watershed Management Group Balloon 4360024900 Los Angeles 26, gagman Creek Watershed Management Group Balloon 5531003900 West Hollywood 24, Hagman Creek Watershed Management Group Balloon 5531003901 West Hollywood 26, gagman Creek Watershed Management Group Balloon 5533009900 Ins Angeles 2-6, Balloon Dark Waterman] Management Group Balloon 5533009901 Ins Angeles 26, Hagman Creek Watershed Management Group Balloon 5534012909 Los Angeles 26, Hagman Dark Waterman] Management Group Balloon 5536WSWO Ins Angeles 26, Hagman Creek Watershed Management Group Balloon 5545016WO Los Angeles 24, Hagman Creek Watershed! Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 14D474 Draft Program Environmental Impact Report 56 January, 2015 Appendix EWMP proposed BMP and priority project Data Region Apn Jurisdiction/Ciry Land Use Type Address figure Number and rdle Balloon 5545017907 Los Angeles 2L, Ballon Creek Watershed Management Group Balloon 5545019914 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5545017902 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5545017904 Los Angeles 24, Ballon Creek Watershed Management Group Balloon 5545019915 Los Angeles 2a, Balloon Creek Watershed Management Group Balloon 5545017900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 55460.9^906 Los Angeles 2L, Ballon Creek Watershed Management Group Balloon 5547003908 Los Angeles 2d, Ballon Dark Watershed Management Group Balloon 5547015900 Ins Angeles 2L, Ballon Creek Watershed Management Group Balloon 5547015904 Los Angeles 23, Flagman Creek Watershed! Management Group Balloon 5547016908 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5547003907 Los Angeles 23, Balloon Creek Watershed! Management Group Balloon 5547015901 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5547015908 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5547030900 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5547009900 Los Angeles 2E, 8allona Creek Watershed Management Group Balloon 5547015903 Ins Angeles 23, gallons Creek Watershed Management Group Balloon 5547015905 Los Angeles 2E, 8allona Creek Watershed Management Group Balloon 5547016907 Ins Angeles 23, Ballon Dark Watershed Management Group Balloon 5548014900 Ins Angeles 2L, Ballon Creek Watershed Management Group Balloon 5550013900 Los Angeles 23, Ballon Dark Watershed Management Group Balloon 5550025902 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5550025903 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5559003901 West Hollywood 23, Ballon Creek Watershed Management Group Balloon 5559003900 West Hollywood 23, Ballon Creek Watershed! Management Group Balloon 5401015900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5426017900 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5429025900 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5429025901 Los Angeles 2E, Balloon Creek Watershed Management Group Balloon 5430029901 Ins Angeles 23, gallons Creek Watershed Management Group Balloon 553700mUO Ins Angeles 2L, Ballon Creek Watershed Management Group Balloon 5539WSWO Los Angeles 23, gagman Dark Watershed Management Group Balloon 5539005903 Ins Angeles 2L, Ballon Creek Watershed Management Group Balloon 5539002900 Los Angeles 24, Flagman Creek Watershed Management Group Balloon 5539023900 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5539025900 Los Angeles 24, Flagman Creek Watershed! Management Group Balloon 5539024902 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5539024901 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5539025902 Los Angeles 2-6, Balloon Creek Watershed Management Group Balloon 5540003900 Los Angeles 2E, Balloon Creek Watershed Management Group Balloon 5542027909 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5542028900 Los Angeles 2E, Balloon Creek Watershed Management Group Balloon 5544027903 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5589028900 Ins Angeles 2L, Ballon Creek Watershed Management Group Balloon 5590020900 Los Angeles 23, Ballon Dark Watershed Management Group Balloon 5591022900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5591022901 Los Angeles 24, Flagman Creek Watershed Management Group Balloon 5122003900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5122003902 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 51220M900 Ins Angeles 23, Ballon Creek Watershed! Management Group Balloon 5122014907 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5122017908 Ins Angeles 23, gallons Creek Watershed Management Group Balloon 5126W1900 Los Angeles 2E, Balloon Creek Watershed Management Group Balloon 5126018917 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 5126018916 Los Angeles 2L, Ballon Creek Watershed Management Group Balloon 5127002908 Los Angeles 2d, Ballon treek Watershed Management Group Balloon 5127012904 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 5127029900 Los Angeles 26, Ballon treek Watershed Management Group Balloon SIM016904 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon SIM016910 Los Angeles 24, Flagman Creek Watershed Management Group Balloon SINW7921 Ins Angeles 2-A Balloon Creek Watershed! Management Group Balloon 5134022903 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 5134022902 Los Angeles 2-A Balloon Creek Watershed! Management Group Balloon 42UW1900 Los Angeles 26, Balloon Creek Watershed Management Group Balloon 4134020903 Culver City 23, Ballon Creek Watershed Management Group Balloon 4208023902 Culver City 26, Balloon Creek Watershed Management Group Balloon 4206026906 Culver City 2-6, Balloon Dark Watershed! Management Group Balloon 4210026903 Culver City 26, Ballon Creek Watershed Management Group Balloon 4255009901 Los Angeles 26, Ballon treek Watershed Management Group Balloon 4255006900 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 4301018900 Los Angeles 24, Flagman Creek Watershed! Management Group Balloon 4213026903 Culver City 26, Ballon Creek Watershed Management Group Balloon 4254023900 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 4314016901 Los Angeles 2-A Balloon Creek Watershed! Management Group Balloon 4309019900 Los Angeles 23, Ballon Creek Watershed! Management Group Balloon 4205035900 Los Angeles 2-A Balloon Creek Watershed! Management Group Balloon 5048013901 Ins Angeles 26, Balloon Creek Watershed Management Group Balloon 5048012900 Ins Angeles 24, Ballon Creek Watershed Management Group Balloon 4249002900 Los Angeles 2-6, Ballon Creek Watershed Management Group Balloon 4249026900 Los Angeles 26, Ballon treek Watershed Management Group Balloon 4249W1901 Ins Angeles 26, Ballon Creek Watershed Management Group Balloon 42 17 01190 3 Culver City 24, Flagman Creek Watershed! Management Group Balloon 4249025900 Ins Angeles 24, Ballon Creek Watershed Management Group Balloon 4213026900 Culver City 24, Flagman Creek Watershed! Management Group Balloon 4212007900 Ins Angeles 2-A Balloon Creek Watershed! Management Group Balloon 4102015900 Inglewood 24, Ballon Creek Watershed! Management Group Balloon 5047014900 Los Angeles 2-A Balloon Creek Watershed Management Group Balloon 4259020900 Los Angeles 26, Balloon Creek Watershed Management Group Balloon 4001013900 Ins Angeles 23, Ballon Creek Watershed Management Group Balloon 4001014901 Inglewood 26, Balloon Creek Watershed Management Group Balloon 4013028900 Inglewood 26, Ballon Dark Watershed Management Group Balloon 4013025900 Inglewood 26, Ballon Creek Watershed! Management Group Balloon 4 014 017 90 0 Inglewood 26, Ballon Dark Watershed Management Group Balloon 4235020901 Culver City 24, Ballon Creek Watershed! Management Group Balloon 4204013900 Culver City 26, Ballon Creek Watershed! Management Group W County Flood Control District Enhanced Watershed Management programs ESA / 14D474 Draft program Environmental Impact Report 52 January 2015 Appendix EWMP proposed BMP and priority project Data Region Apn Jurisdiction/City Land Use Type Address Figure Number and Tisk Bailors 4205012903 Culver City 2L, gagman Creek Watershed Management Group Bailors 4206030902 Los Angeles 23, Ballon Creek Watershed Management Group Balloon 5042014901 Los Angeles 23, Ballon Cook Watemhed Management Group Bailors 5042014902 Los Angeles 24, Balloon Creek Watershed Management Group Ballon 5048012901 Ins Angeles 2a, gallons Crook Watershed Management Group Bailors 5065015906 Ins Angeles 24, Balloon Crook Watershetl Management Group Ballon 5048008901 Ins Angeles 24, Ballon trook Watershed Management Group Balloon 5048014901 Los Angeles 2d, Ballon Crook Watershed Management Group Ballon 5048012900 Ins Angeles 24, Ballon trook Watershed Management Group Balloon 4 3110 3 190 1 Los Angeles 23, gallons trook Watershetl Management Group Balloon 4211011900 Ins Angeles 23, Ballon Crook Watershed Management Group Bailors 4218003900 Ins Angeles 23, gallons trook Watershe! Management Group Balloon 4221024908 Ins Angeles 23, Ballon Crook Watershetl Management Group Balloon 4210 012 90 0 Culver City 23, Ballon Dark Watershe! Management Group Bailors 4221008900 Los Angeles 23, Ballon Crook Watershed Management Group Balloon 4212029903 Los Angeles 2E,Waco trook Watershed Management Group Bailors 4220015900 Ins Angeles 23, gagman Crook Watershetl Management Group Ballon 4221006900 Los Angeles 2E,Waco trook Watershed Management Group Bailors 4221024902 Ins Angeles 2-6, Balloon Crook Watershed Management Group Bailors 4218002902 Ins Angeles 24, Ballon trook Watershed Management Group Balloon 4203011902 Culver City 2-6, Balloon Crook Watershed Management Group Ballon 4210026902 Culver City 23, Ballon Crook Watershed Management Group Bailors 4019019900 La County 23, Ballon trook Watershed! Management Group Balloon 4221024900 Ins Angeles 23, Ballon Crook Watershed Management Group Bailors 4221024909 Ins Angeles 23, Ballon trook Watershe! Management Group Balloon 42 16 013 90 0 Culver City 23, Ballon Crook Watershetl Management Group Balloon 42100155,02 Culver City 23, Ballon Dark Watershe! Management Group Bailors 4210 016 90 0 Culver City 23, Ballon Crook Watershed Management Group Balloon 5142026915 Los Angeles 24,Waco trook Watershed Management Group Bailors 5142026921 Ins Angeles 24, Balloon Crook Watershed Management Group Ballon 4220012900 Ins Angeles 24, Ballon trook Watershed Management Group Balloon 6001013906 Los Angeles 23, Ballon trook Watershed! Management Group Ballon 6001001900 Ins Angeles 24, Ballon trook Watershed Management Group Balloon 5123009'905 Los Angeles 23, gallons trook Watershed Management Group Balloon 4206034906 Ins Angeles 23, Ballon Crook Watershed Management Group Bailors 5046013905 Los Angeles 23, gallons trook Watershetl Management Group Balloon 5066013900 Ins Angeles 23, Ballon Crook Watershed Management Group Balloon 42110 2 2 90 0 Los Angeles 23, Ballon Cook Watershed Management Group Bailors 4211013900 Los Angeles 23, Ballon Crook Watershetl Management Group Balloon 4006011900 Los Angeles 24,Waco trook Watershed Management Group Bailors 4235021900 Ins Angeles 23, Ballon Crook Watershetl Management Group Ballon 5124001900 Los Angeles 24,Waco trook Watershed Management Group Bailors 5032004908 Ins Angeles 23, Ballon Crook Watershetl Management Group W County Flood Control District Enhanced Watershed Management Programs ESA / 14M24 Draft Program Environmental Impact Report 5g January 2015 LOS ANGELES COUNTY FLOOD CONTROL DISTRICT ENHANCED WATERSHED MANAGEMENT PROGRAMS Final Program Environmental Impact Report Prepared for April 2015 County of Los Angeles Department of Public Works ESA s•_ 7t LOS ANGELES COUNTY FLOOD CONTROL DISTRICT ENHANCED WATERSHED MANAGEMENT PROGRAMS Final Program Environmental Impact Report Prepared for April 2015 County of Los Angeles Department of Public Works F` ESA J 626 Wilshire Boulevard Suite 1100 Los Angeles, CA 90017 213.599.4300 W W.esassoc.com Oakland Orlando Palm Springs Petaluma Portland Sacramento San Diego San Francisco Seattle Tampa Woodland Hills 140474 TABLE OF CONTENTS Final Program Environmental Impact Report for the Los Angeles County Flood Control District Enhanced Watershed Management Programs Final EIR Volume 2 10. Introduction..........................................................................................................10-1 10.1 Purpose........................................................................................................10-1 10.2 Environmental Review Process.....................................................................10-1 PublicCirculation ..........................................................................................10-1 Public Meetings, Newspaper Ads and E-mails.............................................10-3 11. Response to Comments ......................................................................................11-1 11.1 Requirements for Responding to Comments on a Draft EIR ........................11-1 11.2 Comments and Response to Comments......................................................11-1 Comment Letter 1 (City of Baldwin Park Department of Public Works) ........11-2 Comment Letter 2 (Culver City Department of Public Works) ....................... 11-5 Comment Letter 3 (City of Baldwin Park Department of Public Health) ........ 11-8 Comment Letter 4 (Metropolitan Water District).........................................11-10 Comment Letter 5 (City of Inglewood Public Works Department)...............11-39 Comment Letter 6 (City of Los Angeles Sanitation District)........................11-41 Comment Letter 7 (Los Angeles Regional Water Quality Control Board)... 11-45 Comment Letter 8 (City of West Hollywood)...............................................11-49 Comment Letter 9 (County of Los Angeles Department of Parks and Recreation)..................................................................11-51 Comment Letter 10 (Central Basin Municipal Water District) ...................... 11-55 Comment Letter 11 (City of Malibu)............................................................11-65 Comment Letter 12 (State Clearinghouse).................................................11-79 Comment Letter 13 (Westwood Gardens Civic Association) ......................11-82 Comment Letter 14 (Arcadia Historical Society).........................................11-85 Comment Letter 15 (Kellogg Garden Products)..........................................11-87 Comment Letter 16 (Los Angeles Water Keeper).......................................11-90 Comment Letter 17 (Topanga Creek Watershed Committee) ..................11-154 Comment Letter 18 (Monrovia).................................................................11-157 Comment Letter 19 (California Native Plant Society)................................11-159 Comment Letter 20 (Sierra Club, Angeles Chapter).................................11-166 Comment Letter 21 (Connie Heflin)..........................................................11-291 LA County Flood Control District ESA 1140474 Enhanced Watershed Management Programs April 2015 Draft Program Environmental Impact Report Table of Contents 12. Clarifications and Modifications.........................................................................12-1 12.1 Introduction...................................................................................................12-1 Paqe Comment Letter 22 (Harry Heflin).............................................................11-293 Comment Letter 23 (Leelee Doughty).......................................................11-295 Comment Letter 24 (Jonathan Weiss)......................................................11-298 Comment Letter 25 (George Brumder).....................................................11-301 Comment Letter 26 (Pamela Warner).......................................................11-303 Comment Letter 27 (Kathleen BonEske)..................................................11-306 Comment Letter 28 (Dan Foliart)..............................................................11-308 Comment Letter 29 (Catherine Heinlein)..................................................11-311 April 2015 Comment Letter 30 (Andy Edmonds).......................................................11-314 Comment Letter 31 (Shake Manigonian)..................................................11-317 Comment Letter 32 (Gina Shaw)..............................................................11-320 Comment Letter 33 (Chris and Gloria Cox)..............................................11-322 Comment Letter 34 (Margaret Page)........................................................11-325 Comment Letter 35 (Virginia Stein)...........................................................11-327 Comment Letter 36 (Martini Arden)..........................................................11-329 Comment Letter 37 (Kristine Hannibal).....................................................11-331 Comment Letter 38 (Emily Rosedale-Kousoulis)......................................11-334 Comment Letter 39 (Margaraux Viera).....................................................11-339 Comment Letter 40 (Robin Kirk)...............................................................11-342 Comment Letter 41 (Joyce Dillard)...........................................................11-344 Comment Letter 42 (Rex Frankel)............................................................11-364 Comment Letter 43 (Theresa Brady)........................................................11-369 Comment Letter 44 (Enrique Huerta)........................................................11-372 Comment Letter 45 (City of Santa Monica)...............................................11-393 Comment Letter 46 (Sarah Hays).............................................................11-402 11.3 Public Meeting Comment Summaries and Responses .............................11-405 Public Meeting 1 (Florence -Firestone Service Center) ............................11-406 Public Meeting 2 (Los Angeles County Fire Camp).................................11-407 Public Meeting 3 (San Pedro Service Center).........................................11-408 Public Meeting 4 (Topanga Library).........................................................11-409 Public Meeting 5 (Hacienda Heights Community Center).........................11-417 Public Meeting 6 (East Los Angeles Library)............................................11-421 11.4 References...............................................................................................11-426 12. Clarifications and Modifications.........................................................................12-1 12.1 Introduction...................................................................................................12-1 12.2 Clarification and Modifications......................................................................12-2 Pages ES -7 through ES -25 (Executive Summary Table).......................................12-3 Page1-1..............................................................................................................12-24 Page1-3..............................................................................................................12-24 Page1-11............................................................................................................12-25 Page1-12............................................................................................................12-25 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District II ESA / 140474 Enhanced Watershed Management programs April 2015 Draft program Environmental Impact Report Table of Contents Page Page3.3-20.........................................................................................................12-28 Page3.3-21.........................................................................................................12-28 Page3.3-24.........................................................................................................12-28 Page3.3-26.........................................................................................................12-28 Page3.3-30.........................................................................................................12-29 Page3.5-28.........................................................................................................12-29 Page3.7-17.........................................................................................................12-29 Page3.7-23.........................................................................................................12-30 Page3.8-4...........................................................................................................12-31 Page3.8-6...........................................................................................................12-31 Page3.8-27.........................................................................................................12-31 Page3.8-29.........................................................................................................12-32 Page3.8-30.........................................................................................................12-32 Page3.8-36.........................................................................................................12-33 Page3.8-37.........................................................................................................12-33 Page3.8-38.........................................................................................................12-34 Page3.8-39.........................................................................................................12-34 Page3.9-1...........................................................................................................12-35 Page3.9-28.........................................................................................................12-35 Page3.9-36.........................................................................................................12-35 Page3.9-38.........................................................................................................12-36 Page3.14-14.......................................................................................................12-36 Page3.14-16.......................................................................................................12-36 Page3.14-17.......................................................................................................12-37 Page3.14-18.......................................................................................................12-37 Page3.14-19.......................................................................................................12-38 Page3.14-20.......................................................................................................12-38 Page3.14-21.......................................................................................................12-38 Page4-4..............................................................................................................12-39 Page6-5..............................................................................................................12-39 Page6-13............................................................................................................12-40 Page9-16............................................................................................................12-40 AppendixB..........................................................................................................12-40 Appendices A. Scoping Report and Comment Letters (originally Appendix B in Draft PEIR) LA County Flood Control District III ESA 1140474 Enhanced Watershed Management Programs April 2015 Draft Program Environmental Impact Report Table of Contents Draft EIR (provided on CD) Volume 1 ExecutiveSummary ..................................................................................................... ES -1 1. Introduction............................................................................................................1-1 1.1 Introduction.....................................................................................................1-1 1.2 Project Background........................................................................................1-4 1.3 CEQA Environmental Review Process...........................................................1-8 1.4 Documents Incorporated by Reference........................................................1-16 1.5 PEIR Organization ........................................................................................1-18 2. Project Description................................................................................................2-1 2.1 Introduction.....................................................................................................2-1 2.2 Goals and Objectives......................................................................................2-2 2.3 Watersheds, Participants, and Process..........................................................2-2 2.4 EWMP BMP Types.........................................................................................2-5 2.6 EWMP BMP Implementation Schedule........................................................2-57 2.7 Operation and Maintenance.........................................................................2-57 2.8 Required Approvals......................................................................................2-57 3. Environmental Impacts and Mitigation Measures 3.1 Aesthetics Resources..................................................................................3.1-1 3.2 Air Quality....................................................................................................3.2-1 3.3 Biological Resources...................................................................................3.3-1 3.4 Cultural Resources......................................................................................3.4-1 3.5 Geologic and Mineral Resources.................................................................3.5-1 3.6 Greenhouse Gases......................................................................................3.6-1 3.7 Hazards and Hazardous Materials...............................................................3.7-1 3.8 Hydrological Resources...............................................................................3.8-1 3.9 Land Use and Agriculture............................................................................3.9-1 3.10 Noise.........................................................................................................3.10-1 3.11 Population and Housing.............................................................................3.11-1 3.12 Public Services and Recreation.................................................................3.12-1 3.13 Transportation and Circulation...................................................................3.13-1 3.14 Utilities, Service Systems and Energy .......................................................3.14-1 4. Cumulative Impacts...............................................................................................4-1 4.1 Introduction.....................................................................................................4-1 4.2 Related Projects.............................................................................................4-2 4.3 Plan Consistency............................................................................................4-6 4.4 Cumulative Impacts and Mitigation Measures................................................4-7 5. Growth-Inducement...............................................................................................5-1 5.1 CEQA Requirements ......................................................................................5-1 5.2 Methodology...................................................................................................5-2 5.3 Growth Inducement Potential and Significant and Irreversible Effects ............ 5-2 5.4 Secondary Effects of Growth..........................................................................5-3 IA County Flood Control District iv ESA / 140474 Enhanced Watershed Management programs April 2015 Draft program Environmental Impact Report Table of Contents Paqe 5.5 Significant Irreversible Environmental Changes.............................................5-3 6. Alternatives Analysis.............................................................................................6-1 6.1 Introduction.....................................................................................................6-1 6.2 Review of Proposed Program Goals and Objectives......................................6-2 6.3 Review of Significant Environmental Impacts.................................................6-3 6.4 Program -Level Alternatives Analysis..............................................................6-3 6.5 Comparison of Alternatives...........................................................................6-12 6.6 Alternatives Suggested in Scoping...............................................................6-12 6.7 Environmentally Superior Alternative............................................................6-13 7. Organizations and Persons Contacted................................................................7-1 7.1 Participating Permittees..................................................................................7-1 7.2 NOP and Draft EIR Distribution List................................................................7-1 8. Report Preparers....................................................................................................8-1 8.1 Lead Agency...................................................................................................8-1 8.2 Draft PEIR......................................................................................................8-1 9. References.............................................................................................................9-1 Appendices A. Notice of Preparation B. Scoping Report and Comment Letters C. CalEEMod Air Quality Data D. Sensitive Natural Communities Descriptions E. CNDDB Species List F. Supplemental Hydrology and Water Quality Data G. EWMP Proposed BMP and Priority Project Data LA County Flood Control District v ESA 1140474 Enhanced Watershed Management Programs April 2015 Draft Program Environmental Impact Report Table of Contents Paae List of Figures 1-1 Watersheds and EWMP Groups within LACFD Boundaries.................................1-2 2-1 Watersheds and EWMP Groups within LACFCD Boundaries..............................2-4 2-2 Location of Example Planned and Installed Distributed BMP Projects ...............2-21 2-3 Location of Example Planned and Installed Centralized BMP Projects ..............2-33 2-4 Location of Example Planned and Installed Regional BMP Projects ..................2-39 2-5 Marina del Rey Watershed Management Group.................................................2-45 2-6 Ballona Creek Watershed Management Group..................................................2-46 2-7 Beach Cities Watershed Management Group.....................................................2-47 2-8 Santa Monica Bay Watershed Jurisdictions 2 and 3 Watershed Management Groups.....................................................................................2-48 2-9 Palos Verdes Peninsula Watershed Management Group...................................2-49 2-10 Malibu Creek Watershed Management Group....................................................2-50 2-11 North Santa Monica Bay Coastal Watersheds....................................................2-51 2-12 Upper San Gabriel River Watershed Management Groups................................2-52 2-13 Rio Hondo / San Gabriel River Watershed Management Group .........................2-53 2-14 Upper Los Angeles River Watershed Management Group.................................2-54 2-15 Dominguez Channel Watershed Management Group........................................2-55 2-16 Upper Santa Clara River Watershed Management Group..................................2-56 3.1-1 Scenic Highways...............................................................................................3.1-7 3.3-1 Typical Drainages in the Southern Coastal EWMP Watersheds ........................3.3-3 3.3-2 Typical Drainages in the Dominguez Channel Watershed Management Areas............................................................................................................. 3.3-4 3.3-3 Typical Drainages in the Northern Coastal EWMP Watersheds ........................3.3-5 3.3-4 Typical Drainages in the Upper Los Angeles River Watershed .........................3.3-6 3.3-5 Typical Drainages in the Upper San Gabriel and Rio Hondo Watersheds ......... 3.3-8 3.3-6 Typical Drainages in the Upper Santa Clara River Watershed ..........................3.3-9 3.3-7 Natural Communities.......................................................................................3.3-10 3.3-8 Los Angeles County Significant Ecological Areas and Critical Habitat ............3.3-14 3.5-1 Regional Geology..............................................................................................3.5-3 3.5-2 Local Faults with Recent Movement..................................................................3.5-6 3.5-3 Liquefaction and Landslide Potential Map.........................................................3.5-9 3.5-4 Mineral Resources Map...................................................................................3.5-12 3.7-1 Los Angeles County Fire Hazard Severity Zone Map for State Responsibility Areas......................................................................................3.7-5 3.7-2 Los Angeles County Fire Hazard Severity Zone Map for County Responsibility Areas......................................................................................3.7-6 3.8-1 Watersheds and EWMP Groups........................................................................3.8-2 3.8-2 South Santa Monica Watershed Area — Hydrologic Features and Potential BMPLocations............................................................................................3.8-11 3.8-3 Northern Coastal Watershed Area— Hydrologic Features and Potential BMP Locations..................................................................................................... 3.8-12 3.8-4 Upper San Gabriel Watershed Area— Hydrologic Features and Potential BMPLocations............................................................................................3.8-13 3.8-5 Upper Los Angeles River Watershed — Hydrologic Features and Potential BMPLocations............................................................................................3.8-14 3.8-6 Dominguez Channel and Palos Verdes Watersheds— Hydrologic Features and Potential BMP Locations......................................................................3.8-15 IA County Flood Control District vi ESA / 140474 Enhanced Watershed Management programs April 2015 Draft program Environmental Impact Report Table of Contents Pape List of Figures (cont.) 3.8-7 Upper Santa Clara River Watershed - Hydrologic Features and Potential BMPLocations............................................................................................3.8-16 3.8-8 Effect of Urbanization on an Example Stream Hydrograph and Hydrograph after Implementation of Retention -Type BMP.............................................3.8-18 3.8-9 System of Dams and Reservoirs in Los Angeles Basin...................................3.8-19 3.8-10 Groundwater Basins within the EWMP Areas..................................................3.8-22 3.9-1 Land Use in the Ballona Creek Watershed Management Group .......................3.9-3 3.9-2 Land Uses in the Beach Cities Watershed Management Group ........................ 3.9-5 3.9-3 Land Use in the Dominguez Channel Watershed Management Group .............3.9-7 3.9-4 Land Use in the Malibu Creek Watershed Management Group ......................... 3.9-9 3.9-5 Land Use in the Marina del Rey Watershed Management Group....................3.9-11 3.9-6 Land Uses in the North Santa Monica Bay Watershed Management Group... 3.9-13 3.9-7 Land Uses in the Peninsula Cities EWMP Agencies.......................................3.9-16 3.9-8 Land Uses in the Rio Hondo / San Gabriel River Watershed Management Group..........................................................................................................3.9-18 3.9-9 Land Use in the Santa Monica Bay Watershed Jurisdictions 2 and 3 Watershed Management Group..................................................................3.9-20 3.9-10 Land Use in the Upper Los Angeles River Watershed Management Group.... 3.9-22 3.9-11 Land Use in Upper San Gabriel River Watershed Management Group ........... 3.9-24 3.9-12 Land Use in Upper Santa Clara River Watershed Management Group ........... 3.9-25 3.10-1 Effects of Noise on People...............................................................................3.10-2 3.12-1 Public School Locations...................................................................................3.12-4 3.12-2 County Parks Locations...................................................................................3.12-6 3.14-1 Water Recharge Facilities................................................................................3.14-3 4-1 Planned EWMP Projects......................................................................................4-5 List of Tables ES -1 Summary of Impacts and Mitigation Measures for the Enhanced Watershed ManagementPrograms................................................................................. ES -7 1-1 NOP Commenters..............................................................................................1-12 2-1 EWMP Participants and Watersheds....................................................................2-3 2-2 Typical Structural Best Management Practices....................................................2-7 2-3 Examples of Planned or Installed Distributed BMP Projects...............................2-17 2-4 Examples of Planned Centralized BMP Projects................................................2-29 2-5 Example of Planned Regional Projects...............................................................2-37 2-6 Required Approvals............................................................................................2-58 3.1-1 Summary of Aesthetics Impacts Requiring Mitigation Measures ..................... 3.1-15 3.2-1 South Coast Air Basin Attainment Status..........................................................3.2-6 3.2-2 Ambient Air Quality Standards for Criteria Pollutants........................................3.2-8 3.2-3 SCAQMD Regional Air Quality Significance Thresholds.................................3.2-16 3.2-4 Modeling Parameters for Worst -Case Construction Scenario for a Distributed BMP project..............................................................................3.2-18 3.2-5 Modeling Parameters for Worst -Case Construction Scenario for a Centralized BMP project.............................................................................3.2-18 3.2-6 Modeling Parameters for Worst -Case Construction Scenario for a Regional BMPProject................................................................................................3.2-19 IA County Flood Control District VII ESA / 140474 Enhanced Watershed Management programs April 2015 Draft program Environmental Impact Report Table of Contents Paqe List of Tables (cont.) 3.2-7 Estimated Peak Daily Emissions for Project Construction Activities for a Distributed BMP Project..............................................................................3.2-20 3.2-8 Estimated Peak Daily Emissions for Project Construction Activities for a Centralized BMP Project.............................................................................3.2-21 3.2-9 Estimated Peak Daily Emissions for Project Construction Activities for a Regional BMP Project.................................................................................3.2-21 3.2-10 Summary of Air Quality Impacts Requiring Mitigation Measures .....................3.2-30 3.3-1 Summary of Biological Resource Impacts Requiring Mitigation Measures ......3.3-32 3.4-1 Paleontologically Sensitive Geologic Units/Formations within the ProgramArea..............................................................................................3.4-10 3.4-2 Summary of Cultural Resource Impacts Requiring Mitigation Measures ......... 3.4-29 3.5-1 Modified Mercalli Intensity Scale........................................................................3.5-5 3.5-2 Principal Historically Active and Active Faults in the Project Vicinity .................3.5-7 3.5-3 Summary of Geologic Resource Impacts Requiring Mitigation Measures .......3.5-29 3.6-1 Recommended Actions from CARB climate change scoping plan.....................3.6-7 3.6-2 Estimated Construction -Related Greenhouse Gas Emissions - Proposed Distributed BMP Project..............................................................3.6-13 3.6-3 Estimated Construction -Related Greenhouse Gas Emissions - Proposed Centralized BMP Project.............................................................3.6-13 3.6-4 Estimated Construction -Related Greenhouse Gas Emissions - Proposed Regional BMP Project.................................................................3.6-14 3.6-5 Summary of Greenhouse Gas Impacts Requiring Mitigation Measures ..........3.6-17 3.7-1 Summary of Hazards Impacts Requiring Mitigation Measures ........................3.7-25 3.8-1 Major Impaired Water Bodies in the Study area..............................................3.8-20 3.8-2 Groundwater Basins within the EWMP Areas..................................................3.8-24 3.8-3 Summary of Hydrological Resource Impacts Requiring Mitigation Measures.. 3.8-43 3.9-1 Ballona Creek Watershed Land Area Distribution..............................................3.9-2 3.9-2 Beach Cities Watershed Land Area Distribution................................................3.9-4 3.9-3 Dominguez channel Watershed Land Area Distribution....................................3.9-6 3.9-4 Dominguez channel Watershed Land Use........................................................3.9-6 3.9-5 Malibu Creek Watershed Land Area Distribution...............................................3.9-8 3.9-6 Marina del Rey Watershed Land Area Distribution..........................................3.9-10 3.9-7 Marina del Rey Watershed Land Use..............................................................3.9-10 3.9-8 North Santa Monica Bay Watershed Land Use...............................................3.9-12 3.9-9 Palos Verdes Peninsula Land Area Distribution..............................................3.9-15 3.9-10 Rio Hondo / San Gabriel River Land Area Distribution....................................3.9-17 3.9-11 Rio Hondo / San Gabriel River Watershed Land Use......................................3.9-17 3.9-12 Santa Monica Bay Land Area Distribution.......................................................3.9-19 3.9-13 Upper Los Angeles River Land Area Distribution.............................................3.9-21 3.9-14 Upper San Gabriel River Land Area Distribution.............................................3.9-23 3.9-15 Upper Santa Clara River Land Area Distribution.............................................3.9-23 3.9-16 Summary of Land Use and Agriculture Impacts Requiring Mitigation Measures....................................................................................3.9-40 3.10-1 Construction Vibration Damage Criteria..........................................................3.10-7 3.10-2 Community Noise Exposure (Ldn or CNEL) ....................................................3.10-9 3.10-3 Caltrans Vibration Damage Potential Threshold Criteria ...............................3.10-10 3.10-4 Caltrans Vibration Annoyance Potential Criteria............................................3.10-10 IA County Flood Control District VIII ESA / 140474 Enhanced Watershed Management programs April 2015 Draft program Environmental Impact Report IA County Flood Control District IX ESA / 140474 Enhanced Watershed Management programs April 2015 Draft program Environmental Impact Report Table of Contents Pape List of Tables (cont.) 3.10-5 County of Los Angeles Exterior Noise Standards By Noise Zones................3.10-11 3.10-6 County of Los Angeles Interior Noise Standards for dwelling units................3.10-12 3.10-7 County of Los Angeles Construction noise standards ...................................3.10-13 3.10-8 Typical Outdoor Construction Noise Levels ...................................................3.10-15 3.10-9 Typical Noise Levels from Construction Equipment.......................................3.10-16 3.10-10 Vibration Velocities for Construction Equipment............................................3.10-20 3.10-11 Summary of Noise Impacts Requiring Mitigation Measures ..........................3.10-25 3.11-1 2014 Los Angeles County Area Median Household Income Classification inU.S. Dollars.............................................................................................3.11-2 3.11-2 Summary of Population and Housing Impacts Requiring Mitigation Measures....................................................................................3.11-9 3.12-1 School Districts in EWMP Areas......................................................................3.12-3 3.12-2 Summary of Public Services and Recreation Impacts Requiring Mitigation Measures..................................................................................3.12-16 3.13-1 Summary of Transportation and Circulation Impacts Requiring Mitigation Measures....................................................................................3.13-8 3.14-1 EWMP Area Water Purveyors.........................................................................3.14-2 3.14-2 EWMP Area Wastewater Treatment Plants .....................................................3.14-5 3.14-3 Summary of Utilities and Service System Impacts Requiring MitigationMeasures..................................................................................3.14-22 4-1 EWMP Projects.....................................................................................................4-4 4-2 Key Regional Resource Management and/or Protection Agencies ......................4-7 4-3 Summary of Cumulative Impact Analysis.............................................................4-8 6-1 Summary of Program Impact Analysis..................................................................6-4 6-2 Ability of Project Alternatives to Meet Project Objectives....................................6-13 IA County Flood Control District IX ESA / 140474 Enhanced Watershed Management programs April 2015 Draft program Environmental Impact Report Acronym List AB Assembly Bill ACS American Community Survey AGB Alamitos Gap Barrier AOA Air Operations Area AQMP Air Quality Management Plan AR4 IPCC Fourth Assessment Report ARMR Archaeological Resource Management Reports ASBS Areas of Special Biological Significance ASTM American Society for Testing and Materials ASTs Aboveground Storage Tanks ATCM Airborne Toxics Control Measure B.P. Before Present BACT Best Available Control Technology BAU Business As -usual BMP Best Management Practices BMPs Best Management Practices BWER Ballona Wetlands Ecological Reserve C1-C4 Chlordane (tissue), Chrysene CAA Clean Air Act CAAA CAA Amendments of 1990 CAAQS California Ambient Air Quality Standards Cal/OSHA California Division of Occupational Safety and Health CalARP California Accidental Release Prevention CalEPA California Environmental Protection Agency CARB California Air Resources Board CB Catch Basin CBC California Building Code CCAA California Clean Air Act CCAP Community Climate Action Plan CCAT California Climate Action Team CCC California Coastal Commission CCR California Code of Regulations CDFW California Department of Fish and Wildlife CDP Coastal Development Permit CEC California Energy Commission CEQA California Environmental Quality Act CESA California Endangered Species Act CFCs Chlorofluorocarbons CFR Code of Federal Regulations CGP Construction General Permit CH4 Methane CHLs California Historical Landmarks CIRS Coastal Interceptor Relief Sewer CIWMB California Integrated Waste Management Board CNDDB California Natural Diversity Database CNPS California Native Plant Society CO Carbon Monoxide CO2 Carbon Dioxide CPUC California Public Utilities Commission CRHR California Register of Historical Resources IA County Flood Control Dishict x ESA / 140474 Enhanced Watershed Management programs April 2015 Final program Environmental Impact Report Table of Contents Acronym List (cont.) CWA Clean Water Act DGSG Dominguez Channel Spreading Grounds DHS Department of Health Services DNL Day -Night Average Noise Level DOT Department of Transportation DTSC Department of Toxic Substances Control EIR environmental impact report ERP Emergency Response Plan ESA Environmental Site Assessment ET Evapotranspiration EWMP Enhanced Watershed Management Program FAA Federal Aviation Administration FESA Federal Endangered Species Act FHSZs Fire Hazard Severity Zones FMMP Farmland Mapping and Monitoring Program GHG Greenhouse Gas GWP Global Warming Potential HAPs Hazardous Air Pollutants HFCs Hydrofluorocarbons HMBP Hazardous Materials Business Plan HR Hydrologic Region HVAC Heating, Ventilation, and Air Conditioning IC/ID Illicit Connection / Illicit Discharges IPCC Intergovernmental Panel on Climate Change IRAs Identified Resource Areas JWPCP Joint Water Pollution Control Plant LACFCD Los Angeles County Flood Control District LACFD Los Angeles County Fire Department LACOE Los Angeles County Office of Education LACSD Los Angeles County Sanitation Districts LARWQCB Los Angeles Regional Water Quality Control Board LASD Los Angeles County Sheriffs Department LAUSD Los Angeles Unified School District LCFS Low Carbon Fuel Standard LCPs Local Coastal Programs LFD Low -Flow Diversion LID Low -Impact Development LOS Level of Service LST Localized Significance Threshold LUSTs Leaking Underground Storage Tanks MACT Maximum Achievable Control Technology MBTA Migratory Bird Treaty Act MCM Minimum Control Measure ML Richter Local Magnitude MMRP Mitigation Monitoring and Reporting Program MMT Million Metric Tons MOU Memorandum of Understanding MPO Metropolitan Planning Organization MRZs Mineral Resource Zones M34 Municipal Separate Storm Sewer System IA County Flood Control District xi ESA / 140474 Enhanced Watershed Management programs April 2015 Final program Environmental Impact Report Table of Contents Acronym List (cont.) N2O Nitrous Oxide NAAQS National Ambient Air Quality Standards NCCP/HCP Natural Community Conservation Planning/Habitat Conservation Plan NESHAPs National Emission Standards for Hazardous Air Pollutants NH3 Ammonia NHPA National Historic Preservation Act NMFS National Marine Fisheries Service NO Nitric Oxide NO2 Nitrogen Dioxide NOI Notice of Intent NOP Notice of Preparation NOX Nitrogen Oxides NPDES National Pollutant Discharge Elimination System NRHP National Register of Historic Places OEHHA Office of Environmental Health Hazard Assessment DES Office of Emergency Services OPR Office of Planning and Research OSHA Office of Safety and Health Administration P -C Production -Consumption PEIR Program Environmental Impact Report PFCs Perfluorocarbons PGA Peak Ground Acceleration PHI Points of Historical Interest PM10 Particulate Matter (10 micrometers or less) PM2.5 Particulate Matter (2.5 micrometers or less) PPV Peak Particle Velocity PRDs Permit Registration Documents PSD Prevention of Significant Deterioration PVC Polyvinyl Chloride RAA Reasonable Assurance Analysis RCRA Resource Conservation and Recovery Act RMP Risk Management Plan RMS Root Mean Square ROG Reactive Organic Gases RWLs Receiving Water Limitations RWQCB Regional Water Quality Control Board RWQCBs Regional Water Quality Control Boards SAR Second Assessment Report SB Senate Bill SCAG Southern California Association of Governments SCAQMD South Coast Air Quality Management District SEAs Significant Ecological Areas SF6 Sulfur Hexafluoride SIP State Implementation Plan SLIC Spills, Leaks, Investigations, and Cleanups Program SMARA State Surface Mining and Reclamation Act SMURRF Santa Monica Urban Runoff Recycling Facility SO2 Sulfur Dioxide SO3 Sulfur Trioxide SO4 Sulfates IA County Flood Control Dishict XII ESA / 140474 Enhanced Watershed Management Programs April 2015 Final program Environmental Impact Report Table of Contents Acronym List (cont.) SOX Sulfur Oxides SPCC Spill Prevention, Control and Countermeasure SVP Society for Vertebrate Paleontology SWPPP Stormwater Pollution Prevention Plan SWRCB State Water Resources Control Board SZs Scientific Resource Zones TAC Technical Advisory Committee TACs Toxic Air Contaminants TDS Total Dissolved Solids TMDLs Total Maximum Daily Loads UCMP University of California Museum of Paleontology ULSD Ultra Low Sulfur Diesel UNFCCC United Nations Framework Convention on Climate Change USACE U.S. Army Corps of Engineers USEPA U.S. Environmental Protection Agency USFS U.S. Forest Service USFWS U.S. Fish and Wildlife Service USTs Underground Storage Tanks UWMP Urban Water Management Plan VMT Vehicle Miles Traveled VOC Volatile Organic Compound WCBB West Coast Basin Barrier Project WDRs Waste Discharge Requirements WMA Watershed Management Area WMG Watershed Management Group WMP Watershed Management Program WRP Water Reclamation Plants WWII World War II IA County Flood Control Dishict XIII ESA / 140474 Enhanced Watershed Management programs April 2015 Final program Environmental Impact Report CHAPTER 10 FINAL EIR PURPOSE AND ENVIRONMENTAL REVIEW PROCESS 10.1 Purpose As defined by Section 15050 of the California Environmental Quality Act (CEQA) Guidelines, the Los Angeles County Flood Control District (LACFD) is serving as "Lead Agency" for the preparation of the Program Environmental Impact Report (PEIR) for implementation of the Enhanced Watershed Management Programs (EWMPs). The Final PEIR presents the environmental information and analyses that have been prepared for the proposed program, including comments received addressing the adequacy of the Draft PEIR, and responses to those comments. The Final PEIR—which includes the Draft PEIR, responses to comments and clarifications and modifications—will be used by the Board of Supervisors in the decision-making process for the proposed program. 10.2 Environmental Review Process Public Circulation A Notice of Preparation (NOP)/Initial Study (SCH No. 2014081106) was circulated for a 30 -day public review period beginning on August 29, 2014. Twenty (20) individual written comment letters were received and used in the preparation of the Draft PEIR. Following the preparation of the Draft PEIR, eight other comment letters were later identified as comments submitted during the NOP public review period. These comment letters did not include any new comment topics that the existing identified NOP comments, and have since been added to Table 1.1 in Chapter 12, Clarifications and Modifications of this PEIR. The Draft PEIR for the proposed project was initially circulated for a 45 -day public review period beginning on January 21, 2015 and ending on March 9, 2015. Per an announcement via e-mail blast on March 6, the comment period was extended through March 16, 2015 at 5PM. A total of 46 individual written comment letters were received on the Draft PEIR. Section 15088 of the CEQA Guidelines requires that the lead agency evaluate comments on environmental issues received from persons and agencies that reviewed the Draft PEIR and prepare a written response addressing each of the comments received. The response to comments is contained in this document—Volume 2, Chapter 11 of the Final PEIR. Volumes 1 and 2 together constitute the Final PEIR. A list of agencies and interested parties who have commented on the Draft PEIR is provided below. A copy of each numbered comment letter and a lettered response to each comment are provided in Chapter 11, Response to Comments, of this Final PEIR. a County Flood Control District 10-1 ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Environmental Impact Report Final EIR Purpose and Environmental Review Process The following agencies, organizations and individuals submitted written comments on the Draft PEIR. Agencies City of Baldwin Park Department of Public Works — January 21, 2015 (Comment Letter 1) Culver City Department of Public Works — February 13, 2015 (Comment Letter 2) City of Baldwin Park Department of Public Health — February 23, 2015 (Comment Letter 3) Metropolitan Water District— February 25, 2015 (Comment Letter 4) City of Inglewood Public Works Department — March 2, 2015 (Comment Letter 5) City of Los Angeles Sanitation District — March 2, 2015 (Comment Letter 6) Los Angeles Regional Water Quality Control Board— March 6, 2015 (Comment Letter 7) City of West Hollywood — March 9, 2015 (Comment Letter 8) County of Los Angeles Department of Parks and Recreation — March 10, 2015 (Comment Letter 9) Central Basin Municipal Water District — March 12, 2015 (Comment Letter 10) City of Malibu— March 16, 2015 (Comment Letter 11) State Clearinghouse — March 17, 2015 (Comment Letter 12) City of Santa Monica — March 12, 2015 (Comment Letter 45) Organizations Westwood Gardens Civic Association — March 1, 2015 (Comment Letter 13) Arcadia Historical Society — March 3, 2015 (Comment Letter 14) Kellogg Garden Products — March 4, 2015 (Comment Letter 15) Los Angeles Water Keeper — March 9, 2015 (Comment Letter 16) Topanga Creek Watershed Committee — March 9, 2015 (Comment Letter 17) Monrovia —March 11, 2015 (Comment Letter 18) California Native Plant Society — March 16, 2015 (Comment Letter 19) Sierra Club, Angeles Chapter — March 17, 2015 (Comment Letter 20) Interested Individuals Connie Heflin — February 10, 2015 (Comment Letter 21) Harry Heflin — February 13, 2015 (Comment Letter 22) Leelee Doughty — February 24, 2015 (Comment Letter 23) a County Flood Career District 10-2 ESA / 140379 Enhanced Watershed Management Programs April 2015 Final Environmental Impact Report Final EIR Purpose and Environmental Review Process Jonathan Weiss — February 24, 2015 (Comment Letter 24) George Brumder — February 24, 2015 (Comment Letter 25) Pamela Warner — February 26, 2015 (Comment Letter 26) Kathleen BonEske — March 2, 2015 (Comment Letter 27) Dan Foliart — March 2, 2015 (Comment Letter 28) Catherine Heinlein — March 2, 2015 (Comment Letter 29) Andy Edmonds — March 3, 2015 (Comment Letter 30) Shake Manigonian— March 3, 2015 (Comment Letter 31) Gina Shaw — March 3, 2015 (Comment Letter 32) Chris and Gloria Cox — March 4, 2015 (Comment Letter 33) Margaret Page — March 4, 2015 (Comment Letter 34) Virginia Stein — March 4, 2015 (Comment Letter 35) Martini Arden — March 5, 2015 (Comment Letter 36) Kristine Hannibal — March 5, 2015 (Comment Letter 37) Emily Rosedale-Kousoulis — March 8, 2015 (Comment Letter 38) Margaraux Viera — March 8, 2015 (Comment Letter 39) Robin Kirk — March 9, 2015 (Comment Letter 40) Joyce Dillard — March 16, 2015 (Comment Letter 41) Rex Frankel — March 16, 2015 (Comment Letter 42) Theresa Brady — March 18, 2015 (Comment Letter 43) Enrique Huerta (Comment Letter 44) Sarah Hays — February 27, 2015 (Comment Letter 46) Public Meetings, Newspaper Ads and E-mails LACFCD held 6 community meetings on January 29 and February 3, 5, 10, 11 and 17, 2015 to discuss the Draft PEIR analysis and alternatives. The six public meetings that took place at 6PM each night listed are as follows: Public Meeting 1 (Florence -Firestone Service Center — January 29, 2015) Public Meeting 2 (LA County Fire Camp — February 3, 2015) Public Meeting 3 (San Pedro Service Center— February 5, 2015) IA County Flood Cancer District 10-3 ESA / 140379 Enhanced Watershed Management Programs April 2015 Final Environmental Impact Report Final EIR Purpose and Environmental Review Process • Public Meeting 4 (Topanga Library — February 10, 2015) • Public Meeting 5 (Hacienda Heights Community Center—February 11, 2015) • Public Meeting 6 (East Los Angeles Library — February 17, 2015) The general topics of oral public comments made at these meetings were transcribed and presented in Section 11.3 of Chapter 11, Response to Comments, of this Final PEIR. As the lead agency under CEQA, LACFCD provided responses to the comments received on the Draft PEIR. A summary of the PEIR was included in the following publications: • LA Times (legal notice — 1/29) • The Signal (legal notice — 1/23) • Arcadia Weekly (legal notice — 1/26) • Eastern Group Publications (legal notice — 1/29) • Santa Monica Daily Press (legal notice — 1/28, website ad — 2/5, print ad — 2/6 through 2/12) • San Gabriel Valley Tribune (legal notice — 2/9, website ad — 2/8, print ad — 2/9 through 2/12) • Topanga Messenger (website ad — 2/4 through 3/4, print ad — 2/12) • Malibu Times (legal notice — 2/11, website ad — 2/5 through 3/5) IA County Flood Career District 10-4 ESA / 140379 Enhanced Watershed Management Programs April 2015 Final Environmental Impact Report CHAPTER 11 RESPONSE TO COMMENTS 11.1 REQUIREMENTS FOR RESPONDING TO COMMENTS ON A DRAFT EIR Lead agencies are required to evaluate all comments on environmental issues received on the Draft PEIR and prepare a written response pursuant to CEQA Guidelines Section 15088. Written responses should address the environmental issue(s) raised and provide a detailed response. Rationale must be provided when specific comments or suggestions (e.g., additional mitigation measures) are not accepted. In addition, the written response must be a good faith and reasoned analysis. As long as a good faith effort at full disclosure is made in the EIR (CEQA Guidelines Section 15204), lead agencies need only to respond to significant environmental issues associated with the project and do not need to provide all the information requested by commenters. CEQA Guidelines Section 15204 recommends that commenters provide detailed comments that focus on the sufficiency of the Draft PEIR in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated. CEQA Guidelines Section 15204 also notes that commenters should provide an explanation and evidence supporting their comments. Pursuant to CEQA Guidelines Section 15064, an effect shall not be considered significant in the absence of substantial evidence. CEQA Guidelines Section 15088 also recommends that where the response to comments results in revisions to the Draft PEIR, those revisions should be noted as a revision to the Draft PEIR or in a separate section of the Final EIR. Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. 11.2 COMMENTS AND RESPONSE TO COMMENTS This section responds to those comments received that specifically pertain to the scope and content of the Draft PEIR. The written comment letters received by the County are included at the beginning of each response. Where comments have prompted changes to text in the Draft EIR, the new text is provided in indented paragraphs showing additions in underline and deletions in st£ilEethrougk text. These changes have been compiled in Chapter 12. Where stated in the responses that implementation of mitigation measures would reduce potentially significant impacts to less than significant levels, it is assumed that the agencies implementing the projects will employ the mitigation as well. As noted in the Draft EIR on page 1-4, "Each implementing agency would determine the significance after mitigation for potential impacts of their proposed projects." a County Flood Control District 11-1 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 1 Paige Anderson To: Crumpacker, Andrea Subject: RE: Letter of support for PEIR to Eval.EWMPs -----Original Message ----- From: David Lopez[mailto:DLopez(&baldwinpark.coml Sent: Wednesday, January 21, 2015 6:21 PM To: Linda Lee Miller Subject: Letter of support for PEIR to Eval.EWMPS Linda, Please see attached. I'll also send via e-mail. David Lopez Associate Engineer City of Baldwin Park, DPW 14403 East Pacific Avenue Baldwin Park, CA 91706 Gen. (626) 813-5255 Dir. (626) 960-4011 ext. 458 Fax. (626) 962-2625 CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 1 P- A- R� K January 21, 2015 Gregg BeGell, P.E. County of Los Angeles Department of Public Works 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 Subject: Support for LACFCD Program EIR to Evaluate Enhanced Watershed Management Programs (EWMPs) Dear Mr. BeGell: The City of Baldwin Park supports the development of programs that improve water quality. The Los Angeles County Flood Control District is preparing a Program Environmental Impact Report (PEIR) to evaluate the proposed Enhanced Watershed Management Programs (EWMPs) that are being developed to improve water quality in Los Angeles County. The PEIR is an Advanced Planning Document describing details of the Countywide water quality program (EWMPs) being launched in partnership with Baldwin Park and other municipalities in the County to comply with new MS4 Permit. Advanced Planning improves public awareness and government transparency and provides for a higher level assessment of policy decisions prior to the consideration of individual projects. The City of Baldwin Park has reviewed the Draft PEIR and agrees with its conclusions regarding the impacts of the proposed EWMPs on the environment and its proposed mitigation measures. The City is writing to offer its support for the implementation of EWMPs to achieve A compliance with the MS4 Permit and to encourage the certification of the Program Environmental Impact Report (PEIR) developed by the Los Angeles County Flood Control District (LACFCD). Sincerely,, I Daniel Wall, P.E. Director of Public Works CITY OF BALDWIN PARK , 14403 EAST PACIFIC AVENUE • BALDWIN PARK • CA , 91706 • (626) 960-4011 FAX (626) 962-2625 Comments Response to Comment Letter 1 (City of Baldwin Park Department of Public Works — January 21, 2015) Response to Comment 1-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The commenter's support for the PEIR is noted. LA County Flood Control District 11-4 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 2 Paige Anderson To: Crumpacker, Andrea Subject: RE: Culver City - Letter of Support for PEIR (EWMPs) From: Finton, Steven[mailto:Steven. Finton(@culvercitv.oral Sent: Friday, February 13, 2015 11:31 AM To: Gregg Begell Cc: Herbertson, Charles; Skinner, Damian; Young, Kaden; TJ Moon Su bj act: Culver city - Letter of Support for PEI R (EWMPs) Gregg - Attached is a letter indicating our support for the EWMP PEIR. Thank you Steven Finton, P.E. Senior Civil Engineer City of Culver City Environmental Programs and Operations Public Works Department 9505 Jefferson BI. 90232 (310) 253-6457 Steven.Finton@CuIverCity.org CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Charles D. Herbertson, P.E., LS Public Works Director and City Engineer Damian Skinner Environmental Programs and Operations Manager February 12, 2015 PUBLIC WORKS DEPARTMENT 9770 Culver Boulevard, Culver City, California 90232 Gregg BeGell, P.E. County of Los Angeles Department of Public Works 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 To Mr. BeGell: Comment Letter 2 cgcR`"v excef(e�ue ii (310) 2535600 FAX (310) 2535626 The Los Angeles County Flood Control District is preparing a Program Environmental Impact Report (PEIR) to evaluate proposed Enhanced Watershed Management Programs (EWMPs) being developed to comply with the new National Pollutant Discharge Elimination System Permit No. CAS004001(M54 Permit). The PEIR is an Advanced Planning Document describing details of twelve EWMPs being developed countywide in partnership with local agencies. Advanced Planning improves public awareness and government transparency and provides for a higher level assessment of policy decisions prior to the consideration of individual projects. The City of Culver City supports preparation of the PIER by the Los Angeles County Flood ControlA I District. Yours truly, 4 Charles Her drtitts+on, P.E. Public Work irector, City Engineer Culver City Employees take pride in effectively proving the highest levels of service to enrich the quality of rife for the community by building on our tradition to Comments Response to Comment Letter 2 (Culver City Department of Public Works — February 13, 2015) Response to Comment Letter 2-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The commenter's support for the PEIR is noted. a County Flood Control District 11-7 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 3 Paige Anderson To: Crumpacker, Andrea Subject: RE: Notice of Availability of the Draft Program EIR for the Enhanced Watershed Management Programs -Comments From: Michelle Tsiebos Sent: Monday, February 23, 2015 9:21 AM To: Gregg Begell Subject: Notice of Availability of the Draft Program EIRfor the Enhanced Watershed Management Programs -Comments Dear Mr. BeGell, Thank you for the opportunity to comment on the Enhanced Watershed Management Programs Draft EIR. The Los Angeles County Department of Public Health -Environmental Health Division has reviewed the document, and offers the following comment: In the Hydrological Resources Chapter, in section 3.8-2 on the impact on Groundwater it is stated: "The proposed project would result in higher groundwater levels and could potentially affect groundwater quality." We agree with the above statement, but we noticed the question of the impact on existing and future Onsite A Wastewater Treatment Systems (OWTS) was not addressed. OWTS are still the only method of wastewater disposal in some areas of the County of Los Angeles. Please feel free to contact me for any questions regarding this comment. Thank you. Michelle Tsiebos, REHS, DPA Environmental Health Specialist IV Land Use Program Environmental Health Services Department of Public Health 5050 Commerce Drive Baldwin Park, CA 91706 Ph. (626) 430-5382 Fax. (626) 813-3016 CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. to Comments Response to Comment Letter 3 (City of Baldwin Park Department of Public Health — February 23, 2015) Response to Comment 3-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR evaluates potential impacts of higher groundwater levels on groundwater quality on Page 3.8-5. As noted in the PEIR, Regional BMPs would recharge storrnwater into the groundwater basin and could raise local groundwater levels following major storm events. In areas with shallow groundwater tables or impermeable soils, recharge could result in mounding that affects subsurface infrastructure such as building or bridge foundations. As noted in the comment, OWTS are classified as subsurface infrastructure and could be affected if water was infiltrated adjacent to their location. However, areas within the County where OWTS are used for wastewater treatment (rather than a sewer system) are usually more rural with some exceptions for instance in Malibu. The proposed BMPs would be installed largely but not exclusively in highly urbanized areas. Therefore, OWTS are not expected to be significantly affected by BMP implementation except in certain areas, such as Malibu. However, in response to the comment, Mitigation Measure HYDRO -3 has been modified on page 3.8-36 of the PEIR, as shown below to specifically include an assessment of local OWTS when installing BMPs. Implementation of the mitigation measure would reduce potentially significant impacts to less than significant levels. This modification has been included in Chapter 12, Clarifications and Modifications of the Final PEIR. Since the Draft PEIR already identified potentially significant impacts to groundwater quality, the comment does not identify a new significant impact, and the modification to the mitigation measure clarifying that on-site treatment plant systems can be one of many sources of pollution does not trigger recirculation of the Draft PEIR under Section 15088.5 of the CEQA Guidelines. HYDRO -3: Prior to the installation of an infiltration BMP, the Permittee shall conduct a regulatory database review for contaminated groundwater sites within a quarter mile of the proposed infiltration facility. The review shall include locations of on-site wastewater treatment systems that could be affected by the BMP. The Permittee shall identify whether any contaminated groundwater plumes or leach fields are present within close proximity to the BMP location that could be affected by infiltrated water and whether coordination with the local and state environmental protection overseeing agency and responsible party is warranted prior to final design of infiltration facility. a County Flood Control District 11-9 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report MWD METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA Executive Office February 25, 2015 Mr. Gregg BeGell Project Management Division II Los Angeles County Flood Control District 900 South Fremont Avenue, 5a' Floor Alhambra, CA 91803 Dear Mr. BeGell: Via Mail Comment Letter 4 5 ¢� Pit !i1; ;7 : Notice of Availability of the Draft Program Environmental Impact Report for the Enhanced Watershed Management Programs The Metropolitan Water District of Southern California (Metropolitan) has reviewed the Draft Program Environmental Impact Report for Enhanced Watershed Management Programs (EWMPs) in Los Angeles County, California. The Los Angeles County Flood Control District (LACFCD) is the Lead Agency. An EWMP is one regulatory compliance mechanism for stormwater management under the Los Angeles County Municipal Separate Storm Sewer System (MS4) Permit adopted in 2012 (hereafter referred to as 2012 LA County MS4 Permit). The LACFCD proposes the development of 12 separate EWMPs in their respective watershed groups. The potential benefits from the EWMPs include the following: (1) improved water quality; (2) reduction in the impairment of water bodies for Designated Beneficial Uses; (3) promotion_ of waterconservation and supply;_(4) enhanced recreational opportunities; (4) support for public education opportunities; (5) improved local aesthetics; and (6) management of flood risks. Metropolitan commented on the Notice of Preparation for this project in September 2014. This letter contains Metropolitan's comments to the proposed project as a potentially affected agency. Metropolitan is a public agency and regional water wholesaler. It is comprised of 26 member public agencies serving approximately 18.4 million people in portions of six counties in Southern California, including Los Angeles County. Metropolitan's mission is to provide its 5,200 - square -mile service area with adequate and reliable supplies of high-quality water to meet present and future needs in an environmentally and economically responsible way. Metropolitan owns and operates numerous facilities within Los Angeles County including pipelines, a water A treatment plant, power plants, dams, reservoirs, and other infrastructure associated with our water conveyance and distribution system. Metropolitan supports the development and implementation of EWMPs, particularly as watershed management plans can impact supply and promote water conservation. A governor - 700 N. Alameda Street, Los Angeles; California 90012 • Mailing Address: P.O. Box 54153, Los Angeles, California, 90054-0153 a Telephone: (213) 217-6000 Comment Letter 4 Mr. BeGell Page 2 February 25, 2015 declared drought has been in effect since January 17, 2014, and agency and public awareness is extremely important in carrying out conservation measures. A cont The proposed project may impact Metropolitan's ability to dewater its pipelines. As part of a proactive maintenance and refurbishment program, Metropolitan periodically dewaters its treated and raw water pipelines prior to inspection, maintenance, or repair activities. Such periodic inspections and repairs are essential to prevent pipe failures and subsequent damage from high- pressure water releases. These water discharges are short-term in nature and are acknowledged B by both the LA County Regional Water Quality Control Board and the State Water Resources Control Board as having a de minimus, or low -threat, impact to the environment and aquatic life. As such, these discharges are categorized as "Conditionally Exempt Essential Non -Storm Water Discharges" under the 2012 LA County MS4 Permit and are authorized under the recently adopted Statewide NPDES Permit for Drinking Water System Discharges to Waters of the United States (Order WQ 2014-0194-DWQ). Metropolitan requests that LACFCD and its co-permitees continue to allow for periodic discharges by potable water systems into the MS4 under the proposed EWMPs. These de minimus, low -threat discharges are specifically called out as permissible under the 2012 LA County MS4 and Statewide Drinking Water System Discharges permits. Metropolitan will continue to follow industry -accepted best management practices (BMPs) for its potable water C system discharges. BMPs include, but are not limited to, the following: (a) advanced notification of LACFCD 72 hours prior to all planned discharges greater than 100,000 gallons and as soon as possible after an unplanned discharge greater than 100,000 gallons; (b) dechlorination; (c) monitoring for pollutants of concern; and (d) recordkeeping (e.g., date, time, and location of discharge, discharge pathway, receiving water, total number of gallons discharged, BMPs used, etc.). Based on a review of the proposed project boundaries, the proposed project has potential to impact Metropolitan facilities. Metropolitan must be allowed to maintain its rights-of-way and requires unobstructed access to its facilities in order to maintain and repair its system. Any future design plans associated with this project should be submitted to the attention of D Metropolitan's Substructures Team. Approval of the project should be contingent on Metropolitan's approval of design plans for portions of the proposed project that could impact its facilities. Detailed prints of drawings of Metropolitan's pipelines and rights-of-way may be obtained by calling Metropolitan's Substructures Information Line at (213) 217-6564. To assist the applicant in preparing plans that are compatible with Metropolitan's facilities and easements, we have enclosed a copy of the "Guidelines for Developments in the Area of Facilities, Fee Properties, and/or Easement of The Metropolitan Water District of Southern California." Please note that all submitted designs or plans must clearly identify Metropolitan's facilities and rights-of-way. Comment Letter 4 Mr. BeGell Page 3 February 25, 2015 We appreciate the opportunity to provide input to your planning process and we look forward to receiving future documentation and plans for this project. For further assistance, please contact Ms. Michelle Morrison at (213) 217-7906. truly yours, Cor� Deirdre West _r Manager, Environmental Planning Team J:\Environmental Planning&CompliancelCOMPLETED JOBS\February2015\EPT Job No. 20150201EXT Enclosures: Planning Guidelines and Map of Metropolitan Facilities in Project Vicinity Comment Letter 4 1. Introduction a. The following general guidelines should be followed for the design of proposed facilities and developments in the area of Metropolitan's facilities, fee properties, and/or easements. b. We require that 3 copies of your tentative and final record maps, grading, paving, street improvement, landscape, storm drain, and utility plans be submitted for our review and written approval as they pertain to Metropolitan's facilities, fee properties and/or easements, prior to the commencement of any construction work. 2. Plans, Parcel and Tract Maps The following are Metropolitan's requirements for the identification of its facilities, fee properties, and/or easements on your plans, parcel maps and tract maps: a. Metropolitan's fee properties and/or easements and its pipelines and other facilities must be fully shown and identified as Metropolitan's on all applicable plans. b. Metropolitan's fee properties and/or easements must be shown and identified as Metropolitan's with the official recording data on all applicable parcel and tract maps. C, Metropolitan's fee properties and/or easements and existing survey monuments must be dimensionally tied to the parcel or tract boundaries. d. Metropolitan's records of surveys must be referenced on the parcel and tract maps. 3. Comment Letter 4 2 - a. Proposed cut or fill slopes exceeding 10 percent are normally not allowed within Metropolitan's fee use of Properties or easements. This is required to facilitate the construction access toits aboveground aand ebelowground facilitiesnance equipmentr anrovide bo drivewaWe require that 16 -foot -wide commercial -type Y approaches be constructed on both sides of all streets crossing Metropolitan's rights-of-way. Openings are required in any median island. Access ramps, if necessary, must be at least 16 -feet -wide. Grades of ramps are normally not allowed. -to exceed 10 percent. I£ the slope of an access ramp md%t exceed 10 percent due to the topography, the ramp must be paved. We require a g level area on the driveway approach to access ramps where the ramp meets the street. At Metropolitan's fee properties, we may require fences and gates. c. The terms of Metropolitan's permanent easement deeds normally preclude the building or maintenance of structures of any nature or kind within its easements, to ensure safety and avoid interference with operation and maintenance of Metropolitan's pipelines or other facilities. Metropolitan must have vehicular access along the easements at all times for inspection, patrolling, and for maintenance of the pipelines and other. facilities on a routine basis. We require a 20 -foot -wide clear zone around all above -ground facilities for this routine access. This clear zone should slope away from our facility on a grade not to exceed 2 percent. We must also have access along the easements with construction equipment. An example of this is shown on Figure 1. d. The footings of any proposed buildings adjacent to Metropolitan's fee properties and/or easements must not encroach into the fee property or easement or impose additional loading on Metropolitan's pipelines or other facilities therein. A typical situation is shown on Figure 2. Prints of the detail plans of the footings for any building or structure adjacent to the fee property or easement must be submitted for our review and written approval as they pertain to the pipeline or other facilities therein. Also, roof eaves of buildings adjacent to the easement or fee property must not overhang into the fee property or easement area. Comment Letter 4 3 - e. Metropolitan's pipelines and other facilities, e.g. structures, manholes, equipment, survey monuments, etc, within its fee properties and/or easements must be protected from damage by the easement holder on Metropolitan's property or the property owner where Metropolitan has an easement, at no expense to Metropolitan. If the facility is a cathodic protection station it shall be located prior to any grading or excavation. The exact location, description and way of protection shall be shown on the related plans , for the easement area. 4. Easements on Metropolitan's Property a. We encourage the use of Metropolitan's fee rights- of-way by governmental agencies for public street and utility purposes, provided that such use does not interfere with Metropolitan's use of the property, the entire width of the property is accepted into the agency's public street system and fair market value is paid for such use of the right-of-way. b. Please contact the Director of Metropolitan's Right of Way and Land Division, telephone (213) 250-6302, concerning easements for landscaping, street, storm drain, sewer, water or other public facilities proposed within Metropolitan's fee properties. A map and legal description of the requested easements must be submitted. Also, written evidence must be submitted that shows the city or county will accept the easement for the specific purposes into its public system. The grant of the easement will be subject to Metropolitan's rights to use its land for water pipelines and related purposes to the same extent as if such grant had not been made. There will be a charge for the easement. Please note that, if entry is required on the property prior to issuance of the easement, an entry permit must be obtained. There will also be a charge for the entry permit. 5. Landscaping Metropolitan's landscape guidelines for its fee properties and/or easements are as follows: a. A green belt may be allowed within Metropolitan's fee property or easement. b. All landscape plans shall show the location and size of Metropolitan's fee property and/or easement and the location and size of Metropolitan's pipeline or other facilities therein. Comment Letter 4 4 - C, Absolutely no trees will be allowed within 15 feet of the centerline of Metropolitan's existing or future Pipelines and facilities. d. Deep-rooted trees are prohibited within Metropolitan's fee properties and/or easements. Shallow - rooted trees are the only trees allowed. The shallow -rooted trees will not be permitted any closer than 15 feet from the centerline of the pipeline, and such trees shall not be taller than 25 feet with a root spread no greater than 20 feet in diameter at maturity. Shrubs, bushes, vines, and ground cover are permitted, but larger shrubs and bushes should not be planted di acceptable, uirectly over our pipeline. Turf is We reqre submittal of landscape plans for Metropolitan's prior review and written approval. (See Figure 3)_ e. The landscape plans must contain provisions for Metropolitan's vehicular access at all times along its rights-of-way to its pipelines or facilities therein. Gates capable of accepting Metropolitan's locks are required in any fences across its rights-of-way. Also, any walks or drainage facilities across its access route must be constructed to AASHTO H-20 loading standards. f- Rights to landscape any of Metropolitan's fee Properties must be acquired from its Right of Way and Land Division. Appropriate entry permits must be obtained prior to any entry on its property. There will be a charge for any entry permit or easements required. 6. Feng 7. Metropolitan requires that perimeter fencing of its fee properties and facilities be constructed of universal chain link, 6 feet in height and topped with 3 strands of barbed wire angled upward and outward at a 45 degree angle or an approved equal for a total fence height of 7 feet. Suitable substitute fencing may be considered by Metropolitan. (Please see Figure 5 for details). Metropolitan's policy for the alinement of utilities Permitted within its fee properties and/or easements and street rights-of-way is as follows: Comment Letter 4 - 5 - a. Permanent structures, including catch basins, manholes, power poles, telephone riser boxes, etc., shall not be located within its fee properties and/or easements. b. We request that permanent utility structures within public streets, in which Metropolitan's facilities are constructed under the Metropolitan Water District Act, be placed as far from our pipeline as possible, but not closer than 5 feet from the outside of our pipeline. c. The installation of utilities over or under Metropolitan's pipeline(s) must be in accordance with the requirements shown on the enclosed prints of Drawings Nos. C-11632 and C-9547. Whenever possible we request a minimum of one foot clearance between Metropolitan's pipe and your facility. Temporary support of Metropolitan's pipe may also be required at undercrossings of its pipe in an open trench. The temporary support plans must be reviewed and approved by Metropolitan. d. Lateral utility crossings of Metropolitan's pipelines must be as perpendicular to its pipeline alinement as practical. Prior to any excavation our pipeline shall be located manually and any excavation within two feet of our pipeline must be done by hand. This shall be noted on the appropriate drawings. e. Utilities constructed longitudinally within Metropolitan's rights-of-way must be located outside the theoretical trench prism for uncovering its pipeline and must be located parallel to and as close to its rights- of-way lines as practical. f. When piping is jacked or installed in jacked casing or tunnel under Metropolitan's pipe, there must be at least two feet of vertical clearance between the bottom of Metropolitan's pipe and the top of the jacked pipe, jacked casing or tunnel. We also require that detail drawings of.the shoring for the jacking or tunneling pits be submitted for our review and approval. Provisions must be made to grout any voids around the exterior of the jacked pipe, jacked casing or tunnel. If the piping is installed in a jacked casing or tunnel the annular space between the piping and the jacked casing or tunnel must be filled with grout. Comment Letter 4 6 - g• Overhead electrical and telephone line requirements; 1) Conductor clearances are to conform to the California State Public UtilitiesCommission, General Order 950 for Overhead Electrical Line Construction or at a greater clearance if required by Metropolitan. Under no circumstances shall clearance be less than 35 feet. 2) A marker must be attached to the power pole showing the ground clearance and line voltage, to help Prevent damage to your facilities during maintenance or other work being done in the area, 3) Line clearance over Metropolitan's fee Properties and/or easements shall be shown on the drawing to indicate the lowest point of the line under the most adverse conditions including consideration of sag, wind load, and support type, temperature change, We require that overhead lines be located at least 30 feet laterally away from all above -ground structures on the pipelines. 4) When underground electrical conduits, 120 volts or greater, are installed within Metropolitan's fee property and/or easement, the conduits must be incased in a minimum of three inches of red concrete. Where possible, above ground warning signs must also be placed at the right-of-way lines where the conduits enter and exit the-right-of=way, - h• The construction of sewerlines in Metropolitan's fee properties and/or easements must conform to the California Department of Health Services Criteria for the Separation of Water Mains and Sanitary Services and the local City or County Health Code Ordinance as it relates to installation of sewers in the vicinity of pressure waterlines. The construction of sewerlines.should also conform to these standards in street rights -of- way. i, Cross sections shall be provided for all pipeline crossings showing Metropolitan's fee property and/or easement limits and the location of our pipeline(s). The exact locations of the crossing pipelines and their elevations shall be marked on as -built drawings for our information, Comment Letter 4 7 - j. Potholing of Metropolitan's pipeline is required if the vertical clearance between a utility and Metropolitan's pipeline is indicated on the plan to be one foot or less. If the indicated clearance is between one and two feet, potholing is suggested. Metropolitan will provide a representative to assists others in locating and identifying its pipeline. Two -working days notice is requested. k. Adequate shoring and bracing is required for the full depth of the trench when the excavation encroaches within the zone shown on Figure 4. 1. The location of utilities within Metropolitan's fee property and/or easement shall be plainly marked to help prevent damage during maintenance or other work done in the area. Detectable tape over buried utilities should be placed a minimum of 12 inches above the utility and shall conform to the following requirements: 1) Water pipeline: A two-inch blue warning tape shall be imprinted with: "CAUTION BURIED WATER PIPELINE" 2) Gas, oil, or chemical pipeline: A two-inch yellow warning tape shall be imprinted with: "CAUTION BURIED PIPELINE" 3) Sewer or storm drain pipeline: A two-inch green warning tape shall be imprinted with: "CAUTION BURIED PIPELINE" 4) Electric, street lighting, or traffic signals conduit: A two-inch red warning tape shall be imprinted with: "CAUTION BURIED CONDUIT" 5) Telephone, or television conduit: A two-inch orange warning tape shall be imprinted with: "CAUTION BURIED I CONDUIT" Comment Letter 4 8 - m. Cathodic Protection requirements: 1) If there is a cathodic protection station for Metropolitan's pipeline in the area of the proposed work, it shall be located prior to any grading or excavation. The exact location, description and manner of protection shall be shown on all applicable plans. Please contact Metropolitan's Corrosion Engineering Section, located at Metropolitan's F. E. Weymouth Softening and Filtration Plant, 700 North Moreno Avenue, La Verne, California 91750, telephone (714) 593-7474, for the locations of Metropolitan's cathodic Protection stations. 2) If an induced -current cathodic protection system is to be installed on any pipeline crossing Metropolitan's pipeline, please contact Mr. Wayne E. Risner at (714) 593-7474 or (213) 250-5085 He will review the proposed system and determine if any conflicts will arise with the existing cathodic protection systems installed by Metropolitan. 3) Within Metropolitan's rights-of-way, pipelines and carrier pipes (casings) shall be coated with an approved protective coating to conform to Metropolitan's requirements, and shall be maintained in a neat and orderly condition as directed by Metropolitan. The application and monitoring of cathodic protection on the pipeline and casing shall conform to Title 49 of the Code of Federal^Regulations, Part 195, 4) If a steel carrier pipe (casing) is used; (a) Cathodic protection shall be provided by use of a sacrificial magnesium anode (a sketch showing the cathodic protection details can be Provided for the designers information). (b) The steel carrier pipe shall be Protected with a coal tar enamel coating inside and out in accordance with AWWA C203 specification. n. All trenches shall be excavated to comply with the CAL/OSHA Construction Safety Orders, Article 6, beginning with Sections 1539 through 1547. Trench backfill shall be placed in 8 -inch lifts and shall be compacted to 95 percent relative compaction (ASTM D698) across roadways and through protective dikes. Trench backfill elsewhere will be compacted to 90 percent relative compaction (ASTM D698). Comment Letter 4 9 - o. Control cables connected with the operation of Metropolitan's system are buried within streets, its fee properties and/or easements. The locations and elevations of these cables shall be shown on the drawings. The drawings shall note that prior to any excavation in the area, the control cables shall be located and measures shall be taken by the contractor to protect the cables in place. p. Metropolitan is a member of Underground Service Alert (USA). The contractor (excavator) shall contact USA at 1-800-422-4133 (Southern California) at least 48 hours prior to starting any excavation work. The contractor will be liable for any damage to Metropolitan's facilities as a result of the construction. 8. Paramount Right Facilities constructed within Metropolitan's fee properties and/or easements shall be subject to the paramount right of Metropolitan to use its fee properties and/or easements for the purpose for which they were acquired. If at any time Metropolitan or its assigns should, in the exercise of their rights, find it necessary to remove any of the facilities from the fee properties and/or easements, such removal and replacement shall be at the expense of the owner of the facility. 9. Modification of Metropolitan's Facilities When a manhole or other of Metropolitan's facilities must be modified to accommodate your construction or recons- truction, Metropolitan will modify the facilities with its forces. This should be noted on the construction plans. The estimated cost to perform this modification will be given to you and we will require a deposit for this amount before the work is performed. Once the deposit is received, we will schedule the work. Our forces will coordinate the work with your contractor. Our final billing will be based on actual cost incurred, and will include materials, construction, engineering plan review, inspection, and administrative overhead charges calculated in accordance with Metropolitan's standard accounting practices. If the cost is less than the deposit, a refund will be made; however, if the cost exceeds the deposit, an invoice will be forwarded for payment of the additional amount. 10 - 10. Drainage Comment Letter 4 a. Residential or commercial development typically increases and concentrates the peak storm water runoff as well as the total yearly storm runoff from an area, thereby increasing the requirements for storm drain facilities downstream of the development. Also, throughout the year water from landscape irrigation, car washing, and other outdoor domestic water uses flows into the storm drainage system resulting in weed abatement, insect infestation, Obstructed access and other problems. Therefore, it is Metropolitan's usual practice not to approve plans that show discharge of drainage from developments onto its fee properties and/or easements. b. If water must be carried across or discharged onto Metropolitan's fee properties and/or easements, Metropolitan will insist that plans for development provide that it be carried by closed conduit or lined open channel approved in writing by Metropolitan. Also the drainage facilities must be maintained by others, e.g., city, county, homeowners association, etc. If the development proposes changes to existing drainage features, then the developer shall make provisions to provide for replacement and these changes must be approved by Metropolitan in writing. 11. Construction Coordination During construction•, Metropolitan's field representative will make periodic inspections. We request that _a stipulation - beaddedto theplansor specifications for notification of Mr. of Metropolitan's Operations Services Branch, telephone 213) 250 , at least two workingdays any work in the vicinity of our facilities, y prior to 12. Pipeline Loading Restrictions a. Metropolitan's pipelines and conduits vary in structural strength, and some are not adequate for AASHTO H-20 loading. Therefore, specific loads over the specific sections of pipe or conduit must be reviewed and approved by Metropolitan. However, Metropolitan's pipelines are typically adequate for AASHTO H-20 loading provided that the cover over the pipeline is not less than four feet or the cover is not substantially increased. If the temporary cover over the pipeline during construction is between three and four feet, equipment must restricted to that which Comment Letter 4 imposes loads no greater than AASHTO H-10. If the cover is between two and three feet, equipment must be restricted to that of a Caterpillar D-4 tract -type tractor. If the cover is less than two feet, only hand equipment may be used. Also, if the contractor plans to use any equipment over Metropolitan's pipeline which will impose loads greater than AASHTO H-20, it will be necessary to submit the specifications of such equipment for our review and approval at least one week prior to its use. More restrictive requirements may apply to the loading guideline over the San Diego Pipelines 1 and 2, portions of the Orange County Feeder, and the Colorado River Aqueduct. Please contact us for loading restrictions on all of Metropolitan's pipelines and conduits. b. The existing cover over the pipeline shall be maintained unless Metropolitan determines that proposed changes do not pose a hazard to the integrity of the pipeline or an impediment to its maintenance. 13. Blasting a. At least 20 days prior to the start of any drilling for rock excavation blasting, or any blasting, in the vicinity of Metropolitan's facilities, a two-part preliminary conceptual plan shall be submitted to Metropolitan as follows: b. Part 1 of the conceptual plan shall include a complete summary of.proposed transportation, handling, storage, and use of explosions. c. Part 2 shall include the proposed general concept for blasting, including controlled blasting techniques and controls of .noise, fly rock, airblast, and ground vibration. 14. CEQA Requirements a. When Environmental Documents Have Not Be Prepared 1) Regulations implementing the California Environmental Quality Act (CEQA) require that Metropolitan have an opportunity to consult with the agency or consultants preparing any environmental documentation. We are required to review and consider the environmental effects of the project as shown in the Negative Declaration or Environmental Impact Report (EIR) prepared for your project before committing Metropolitan to approve your request. Comment Letter 4 12 - 2) In order to ensure compliance with the regulations implementing CEQA where Metropolitan is not the Lead Agency, the following minimum procedures to ensure compliance with the Act have been established: a) Metropolitan shall be timely advised of any determination that a Categorical Exemption applies to the project, The Lead Agency is to advise Metropolitan that it and other agencies participating in the project have complied with the requirements of CEQA prior to Metropolitan's participation, b) Metropolitan is to be consulted during the preparation of the Negative Declaration or EIR, c) Metropolitan is to review and submit any necessary comments on the Negative Declaration or draft EIR, d) Metropolitan is to be indemnified for any costs or liability arising out of any violation of any laws or regulations including but not limited to the California Environmental Quality Act and its implementing regulations, b_ If environmental documents have been prepared for your Project, please furnish us a copy for our -review -and -files - in a timely manner so that we may have sufficient time to review and comment. The following steps must also be accomplished: - 1) The Lead Agency is to advise Metropolitan that it and other agencies participating in the project have complied with the requirements of CEQA prior to Metropolitan's participation. 2) You must agree to indemnify Metropolitan, its officers, engineers, and agents for any costs or liability arising out of any violation of any laws or regulations including but not limited to the California Environmental Quality Act and its implementing regulations_ 150 Metropolitan's Plan -Review Cost a• An engineering review of your proposed facilities and developments and the preparation of a letter response Comment Letter 4 giving Metropolitan's comments, requirements and/or approval that will require 8 man-hours or less of effort is typically performed at no cost to the developer, unless a facility must be modified where Metropolitan has superior rights. If an engineering review and letter response requires more than 8 man-hours of effort by Metropolitan to determine if the proposed facility or development is compatible with its facilities, or if modifications to Metropolitan's manhole(s) or other facilities will be required, then all of Metropolitan's costs associated with the project must be paid by the developer, unless the developer has superior rights. b. A deposit of funds will be required from the developer before Metropolitan can begin its detailed engineering plan review that will exceed 8 hours. The amount of the required deposit will be determined after a cursory review of the plans for the proposed development. c. Metropolitan's final billing will be based on actual cost incurred, and will include engineering plan review, inspection, materials, construction, and administrative overhead charges calculated in accordance with Metropolitan's standard accounting practices. If the cost is less than the deposit, .a refund will be made; however, if the cost exceeds the deposit, an invoice will be forwarded for payment of the additional amount. Additional deposits may be required if the cost of Metropolitan's review exceeds the amount of the initial deposit. 16. Caution We advise you that Metropolitan's plan reviews and responses are based upon information available to Metropolitan which was prepared by or on behalf of Metropolitan for general record purposes only. Such information may not be sufficiently detailed or accurate for your purposes. No warranty of any kind, either express or implied, is attached to the information therein conveyed as to its accuracy, and no inference should be drawn from Metropolitan's failure to comment on any aspect of your project. You are therefore cautioned to make such surveys and other field investigations as you may deem prudent to assure yourself that any plans for your project are correct. Comment Letter 4 14 - 17. Additional Information Should you require additional information, please contact: Metropolitan Water District - of Southern California P•O. Sox 54153 Los Angeles, California 90054-0153 (213) 217-6000 JEH/MRW/lk ' Rev. January 22, 1989 Encl. Comment Letter 4 •.o. 01c 111m La c NO PERMANENT cra.1/�4r..n�, M. rr.V. rtorMANENT RIGHT OF WAY NO ROOF OVERHANG PERMITTED FOOTING MUST NOT ENCROACH INTO RIGHT OF WAY FINISHED SURFACE � I Comment Letter 4 BUILDING ADJACENT TO RIGHT OF WAY I 1 REQUIRED I DEPTH OF 1 FOOTING I I I 1 I I f M.WO. PIPELINE NOTE'- M.WD. PIPELINE SIZE, DEPTH, LOCATION BUILDI NGS ANDTFOOT/NGS AND WIDTH OF PERMANENT RIGHT OF ADJACENT TO M, W D, WAY VARIES. RIGHT OF WAY o.. Comment Letter 4 k \ � m � ) I k W kk Z s W o cz mJ4 Comment Letter 4 rM 4 w O ' 4: � s 2 15 h �^ o • 2 � � eE 1 spy g wpON y � g @`SII m 0 iia.E A 4 a 4 w O ' 4: � s 2 15 h �^ o • 2 � � eE Q g i g 4 w O i ent �e�t r 4h W y ' � Z ti �^ o • 2 � � � U Q g i v y � g W m 0 iia.E A 4 a s a Q is�fii�S $�=�L• •4LxS F• :$:.�E �a• ��� � :L Lei 6S 3$h 82i ��a a`a y�;'�`y,�ea�i i �^ y� F=:• 21•.x. ����Eh B=LS � 8 L.c k° 8 e�`. • i ent �e�t r 4h W y ' � Z ti �^ o • 2 � � � U Q g i v �^ o ad Q v y CF g W m 0 0 Comment Letter 4 8� M.W.D. Pipeline irl �l1 I 4 premo/ded 0 /-r--------r expansion Point filler j' C - -E e. Apertures as directed by _ 4 Dmin_ n+ o the Engineer, tato/ vo/ume not to exceed - the vo/ume ••,'; of thesupporting wall ------- o.; v. `; Concrete support wall to be p/aced against undis- rv•, Curbed ground SECT/ON 0;4-A" D CR`OS�S—S-EC-T-/-OW N /. Supporting wall shall hove a firm beoring on the -ioc Subgrade and agdinst the side of the excavation. 2. Premo/ded expansion to joint filler per ASTit! O-/75/ 73 D be used in support for steel pipe on/y. 3. /f trench width is A feet or greater, measured a/ong _� tt R centerline of M. W D. pipe, concrete support must f be constructed. 4. /f trench width is less than 4 feet, c%n sand back- s fill, compacted to 90% density in accordance with Me provisions of ASTM Standard D-1557-70 may " be' used in lieu of the concrete support w471/. TYPIC -4L SUPPORT FOR MWD. PIPELINE Comment Letter 4 Trench width x� I V �3 Preformed exponsion joint filler NOTES I. This method to be•used where the M.W.D. pipe utility line is 24"or greater in diameter and the clearance between the utility line and M.W D. P/ pe is 12' or less. 2. Special protection may be required SECT/ON A if the utility line diameter is greater than M.WD. pipe orif the cover over the utility line to the street surface is minimal and there is 12"or less clearance between MWD. Pipe and the utility fine. J. Preformed expansion joint filler to comply with ASTM designation D-1751-73. 4. All WD. requests 12"minimum clearance whenever possible. CROSS SECTION 11.47 <LRAO MT 3 imits exponsion r r'YP/CAL EXPANS/0N JO /NT FILLER PROTECT/ON FOR 0VERCROSS/NG OF M. W. D. PIPEL INE to Comments Response to Comment Letter 4 (Metropolitan Water District — February 25, 2015) Response to Comment 4-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The commenter's support for the PEIR is noted. Response to Comment 4-B The comment notes that dewatering discharges from water utilities are permitted under separate NPDES permits and WDRs issued by the RWQCB. The EWMPs would be designed to accommodate projected flows within their watersheds. If a pipeline dewatering activity resulted in a volume of water greater than the capacity of the BMP, it could potentially overwhelm the BMP, and discharge from the MS4 as is currently the case. Advanced notification of the discharges as currently required would ensure that no adverse impacts would occur. Response to Comment 4-C Periodic dewatering discharges from water utilities are permitted under separate NPDES permits and WDRs issued by the RWQCB; therefore, the proposed EWPMS would not inhibit these discharges. Advanced notification of the discharges as currently required would ensure that no adverse impacts would occur. The commenter's plan to continue to follow BMPs for these discharges is noted for the record. Response to Comment 4-D The proposed EWMP BMPs are under development. As BMPs are developed, the location of underground utilities would be identified to ensure that services are maintained and access to utilities is maintained. If a project is expected to interfere with Metropolitan's facility access, the project operator would consult with Metropolitan prior to implementation. In response to this comment, an additional mitigation measure has been added (UTIL-1) under the Impact 3.14-1 discussion on page 3.14-14 as follows (thereby shifting the numbering of the original Mitigation Measures UTIL-1 and UTIL-2 to Mitigation Measures UTIL-2 and UTIL-3): Construction requiring ground disturbance could encounter buried utilities including water supply infrastructure. As part of Mitigation Measure UTIL-1, toe prejest design, Implementing Agencies would be required to identify the potential for ..nder,._etm t RTRD As ..«.,char ,. „s«.,.etio., praetie@sroquir@, implementing A ,.oaci@s would conduct an underground utility search prior to excavation and would coordinate with utility providers in advance to ensure no disruption in services to the utility customers. With a County Flood Control District 11-35 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments implementation of UTIL-1, ilmpacts to water supply and other utility infrastructure would be less than significant. On page 3.14-14 as follows (further lessening less than significant impacts): Mitigation Measures: None required UTIL-1: Prior to implementation of BMPs, the implementing agency shall conduct a search for local utilities above and below ground that could be affected by the vroiect. The implementing agencies shall contact each utility potentially affected to address relocation of the utility if necessary to ensure access and services are maintained. Under the Impact 3.14-3 discussion on page 3.14-16 as follows: Construction requiring ground disturbance could encounter buried utilities including water supply infrastructure. As part of Mitigation Measure UTIL-1, t4a pfajeet design, Implementing Agencies ,. e..1a be _..,...:_,.a to identify thepotential for ,,..a,.,.,._,.un RARD A....ta... aFd r nstpaotion p aefie@.r@quire, implementing Ageacies would conduct an underground utility search prior to excavation and would coordinate with utility providers in advance to ensure no disruption in services to the utility customers. With implementation of UTIL-1, ilmpacts to water supply and other utility infrastructure would be less than significant. On page 3.14-16 as follows (further lessening less than significant impacts): These flows would not be affected by infiltration BMPs. However, implementation of Mitigation Measure UTIL42 would ensure that downstream water rights would not be affected by upstream diversions. On page 3.14-17 as follows: Mitigation Measure: Implement Mitigation Measure UTIL-1. UTIL-42: Prior to approval of BMPs, implementing agencies shall evaluate the potential for impacts to downstream beneficial uses, including surface water rights. Implementing agencies shall not approve BMPs that result in preventing access to previously appropriated surface water downstream. On page 3.14-18 as follows: Development of a waste management or recycling plan (Mitigation Measure UTIL-23) would reduce this impact. On page 3.14-18 as follows: Mitigation Measure: UTIL-23: Implementing agencies shall encourage construction contractors to recycle construction materials and divert inert solids (asphalt, brick, concrete, dirt, fines, rock, LA County Flood Control District 11-36 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments sand, soil, and stone) from disposal in a landfill, where feasible. Implementing agencies shall incentivize construction contractors with waste minimization goals in bid specifications where feasible. Under the Impact 3.14-5 discussion on page 3.14-19 as follows: Construction requiring ground disturbance could encounter buried or overhead utilities including electric or gas conveyance infrastructure. As part of Mitigation Measure UTIL- Lr Implementing Agencies for underground utilities And Aehermia@ whether the.r would need to he rialapeteA to aelsommedate the BAIP As standard 13011154U(86011 Pfa6tieeS Fe El rir., im..leffle .ti fig Agencies -would conduct an underground utility search prior to excavation and would coordinate with utility providers in advance to ensure no disruption in services to the utility customers. Impacts to electric or gas infrastructure would be less than significant. On page 3.14-20 as follows (further lessening less than significant impacts): Mitigation Measures: None reqImplement Mitigation Measure UTIL-1. This change also applies to the cumulative impact discussion, requiring added text on page 3.14- 21 as follows: The proposed program consists of improvements to existing storm drainage facilities as well as new storm drain facilities within the EWMP program areas. This PEIR contains an analysis on the potential environmental effects that might result from the installation of storm drainage facilities identified in the proposed EWMPs. Mitigation Measure UTIL-1 would require the implementing agency to search for local utilities that could be affected by the project, thereby avoiding impacts to existing utilities. Cumulative impacts to storm drain facilities would be less than significant. Impacts to the existing water supplies are anticipated to be beneficial as a result of the stormwater and non-stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. Mitigation Measure UTIL42 would require that implementing agencies evaluate impacts to downstream beneficial uses, including surface water rights prior to BMP approval. No adverse cumulative impacts related to new or expanded water supply resources or entitlements would occur. Construction and operation of the structural BMPs would generate solid waste; however, landfills serving the program area are expected to have sufficient capacity to accommodate the amount of waste generated. Development of a waste management or recycling plan (Mitigation Measure UTIL- D would reduce this impact. Disposal of the solid waste generated during construction and operation would comply with all pertinent regulations and statutes. All other projects implemented in the area would also be required to comply with federal, state, and local solid waste regulations and statutes. Cumulative impacts would be less than significant. a County Flood Control District 11-37 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments And on page 3.14-21 as follows (further lessening less than significant impacts): Mitigation Measures: Implement Mitigation Measure UTIL-1,7� Mitigation Measure UTIL-2, and Mitigation Measure UTIL-31 These modifications have been included in Chapter 12, Clarifications and Modifications, of the Final PEIR. The Draft PEIR identified the need for underground utility searches as standard practice. However, in response to the comment and to ensure that the practice is carried out, the new mitigation measure is added. The need to investigate project areas for underground utilities was noted in the analysis on page 3.14-16 as a standard practice. The new Mitigation Measure UTIL-1 ensures that the practice is carried out. Therefore, no new significant impact would occur, and the modification does not trigger recirculation of the Draft PEIR under Section 15088.5 of the CEQA Guidelines. Response to Comment 4-E The commenter's statement that Metropolitan pipeline details can be obtained from Metropolitan and that all designs or plans must identify Metropolitan's facilities and rights-of-way has been noted for the record. Metropolitan pipelines qualify as potential utilities that could be affected by future projects, and thus would be included in the required search for utilities as specified in Mitigation Measure UTIL-1 added in Response to Comment 4-D above. LA County Flood Control District 11-38 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 5 Inglewood California Public Works Department ONE MANCHESTER BOULEVARD / INGLEWOOD, CA. 90301 / P.O. BOX 6500 / INGLEWOOD, CA. 90312 Telephone (310) 412-5333 / Fax (310) 412-5552 www.ciI3Lofirialewood.org LOUIS A. ATWELL, P.E. PUBLIC WORKS DIRECTOR March 2, 2015 Gregg BeGell, P.E. County of Los Angeles Department of Public Works 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 Re: Enhanced Watershed Management Programs (EWMP) Dear Mr. BeGell: The City of Inglewood (City) supports the development of programs that improve water quality. The Los Angeles County Flood Control District (LACFCD) is preparing the Program Environmental Impact Report (PEIR) to evaluate the proposed Enhanced Watershed Management Programs (EWMP); this program is being developed to improve water quality in Los Angeles County. PEIR is an advanced planning document that describes details of the countywide water quality program EWMP. Partnership with municipalities in the county will promote compliance with the new MS4 Permit. The City reviewed the draft PEIR and agrees with its conclusions regarding the impacts of the proposed EWMP on the environment and its proposed mitigation measures. A Therefore, the purpose of this letter is to offer the City's support for the implementation of EWMP. Sincerely, � v L is A. Atwell, P.E. blit Works Director Comments Response to Comment Letter 5 (City of Inglewood Public Works Department — March 2, 2015) Response to Comment 5-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The cornmenter's support for the PEIR is noted. LA County Flood Control District 11-40 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 6 Paige Anderson To: Laura Rocha Subject: RE: Letter Regarding LCFCD Program EIR for EWMPs From: Susie Santilena [mai Ito: susie.santilena(a)lacitv.orgl Sent: Tuesday, March 03, 2015 3:15 PM To: Gregg Begell Cc: Hubertus Cox; TJ Moon; Ryan Thiha Subject: Letter Regarding LCFCD Program ElRfor EWMPs Dear Mr. Begell, Please see the attached letter from the Qty of Los Angeles regarding the Los Angeles County Flood Control District Enhanced Watershed Management Program EIR Let us know if you have any questions. Susie Santilena Environmental Engineering Associate Bureau of Sanitation, Watershed Protection Division Qty of Los Angeles su si e. sant i I ena(al aci ty. org 213.485.0526 Stay in the Loop! CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. BOARD OF PUBLIC WORKS MEMBERS KEVIN JAMES PRESIDENT MONICA RODRIGUEZ VICE PRESIDENT MATTSZABO PRESIDENT PRO TEMPORE MICHAEL R. DAVIS COMMISSIONER COMMISSIONER ELECTRONIC MAIL CITY OF LOS ANGELES CALIFORNIA Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 Dear Mr. BeGell: ERIC GARCETTI MAYOR March 2, 2015 Comment Letter 6 BUREAU OF SANITATION ENRIQUE C. ZALDIVAR DIRECTOR TRACI J. MINAMIDE CHIEF OPERATING OFFICER VAROUJ S. ABKIAN ADEL H. HAGEKHALIL ALEXANDER E. HELOU ASSISTANT DIRECTORS LISA B. MOWERY CHIEF FINANCIAL OFFICER 1149 SOUTH BROADWAY, 10TH FLOOR LOS ANGELES, CA 90015 TEL: (213(485-0587 FAX: (213)485-3939 WWW.LACITYSAN.ORG LOS ANGELES COUNTY FLOOD CONTROL DISTRICT PROGRAM FIR FOR THE ENHANCED WATERSHED MANAGEMENT PROGRAMS The City of Los Angeles (City) supports the development of programs that improve water quality. Through LA Sanitation, the City acts as watershed lead in the development of Enhanced Watershed Management Programs (EWMPs) that are being developed to improve water quality in Los Angeles County for four (4) watersheds, including the Upper Los Angeles River, Ballona Creek, Dominguez Channel, and Santa Monica Bay watersheds. These plans aim to provide a multi -benefit approach to complying with water quality regulations, leading to the construction of projects that will improve stormwater quality, enhance water supply, improve flood control, and bring green space and other amenities to the community. The Los Angeles County Flood Control District (LACFCD) is preparing a Program Environmental Impact Report (EIR) to evaluate the proposed EWMPs. The Program EIR is an Advanced Planning Document describing details of the County -wide water quality program (EWMPs) being launched in partnership with municipalities in the County to comply with the new MS4 Permit. Advanced planning improves public awareness and government transparency and provides for a higher level assessment of policy decisions prior to the consideration of individual projects. zero waste • one water AN EQUAL EMPLOYMENT OPPORTUNITY - AFFIRMATIVE ACTION EMPLOYER 1'[r�,n RecY4 aM mxlefmm aymtl wat v Comment Letter 6 Mr. Gregg BeGell March 2, 2015 Page 2 of 2 LA Sanitation has reviewed the Draft PEIR and supports the advanced planning approach detailed in the PEIR. LA Sanitation is writing to offer its support for the implementation of A EWMPs to achieve compliance with the MS4 Permit and to encourage the certification of the Program Environmental Impact Report (EIR) developed by the LACFCD. Sincerely, S AHRAM KHARAGHAN , D., P.E., BCEE Program Manager SK:HC: W S WPDCR9167 cc: Enrique Zaldivar, LASAN Traci Minamide, LASAN Adel Hagekhalil, LASAN Hubertus Cox, LASAN Angela George, LA County Public Works Comments Response to Comment Letter 6 (City of Los Angeles Sanitation District — March 2, 2015) Response to Comment 6-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The commenter's support for the PEIR is noted. IA County Flood Control District 11-44 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 7 Paige Anderson To: Laura Rocha Subject: RE: EWMP Draft PEIR Comments From: "Ridgeway, Ivar@Waterboards" <Ivar.Ridgeway@waterboards.ca.gov> Date: March 6, 2015 at 11:30:36 AM PST To: "gbegell@dpw.lacounty.gov" <gbegell@dpw.lacounty.gov> Cc: "Purdy, Renee @Waterboards' <Renee.Purdy@waterboa rds.ca.gov>, "Birosik, Shirley@Waterboards" <Shirley.Birosik@waterboards.ca.gov> Subject: EWMP Draft PEIR Comments Mr. BeGell, P.E, Please see the following comments from the Los Angeles Regional Water Board on the County of Los Angeles's Draft PEIR: 1. The draft EIR notes that participation in an EWMP is optional but some sections of the document make it appear that the Los Angeles MS4 Permit requires permittees to develop A EWMPs to ensure meeting water quality objectives. 2. The draft EIR makes it appear that all EWMP projects will be implemented in an urbanized area. The draft EIR's assumptions regarding project implementation appear valid but there B should be a short discussion of potential impacts of projects implemented in non -urbanized areas (e.g. Upper Santa Clara River EWMP). 3. The Basin Plan for the California Regional Water Quality Control Board, Santa Ana Region is included as a reference but the Basin Plan for the California Regional Water Quality Control I C Board, Los Angeles Region, where the EWMP projects will be implemented, is not referenced. If you have any questions feel free to contact me. Ivar K. Ridgeway Senior Environmental Scientist California Regional Water Quality Control Board, Los Angeles Region 320 West 4th Street, Suite 200 Los Angeles, CA 90013-2343 (213)620-2150 Ivar.Ridgeway@waterboards.ca.gov CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comments Response to Comment Letter 7 (Los Angeles Regional Water Quality Control Board — March 6, 2015) Response to Comment 7-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The commenter does not specifically identify which sections of the PEIR the comment refers to, however, the LACFCD acknowledges that participation in an EWMP is one of several options identified in the MS4 Permit for achieving compliance with water quality standards. The MS4 Permit allows Permittees the option of preparing an EWMP to achieve compliance as noted on page 1-1. The commenter is correct that preparation of an EWMP is not a requirement for each Permittee. However, the MS4 provides specific requirements for Permittees that elect to prepare EWMPs. The PEIR refers to these `requirements" when explaining the Permit's outline for preparing an EWMP as noted on page 1-3 and elsewhere in the document. In response to this comment the text on page 1-1 has been revised as follows: The MS4 Permit gives Permittees the option of implementing an innovative approach to permit compliance through development of an Enhanced Watershed Management Program (EWMP). Development of an EWMP is optional, but allows Permittees a Ionizer timeline to develop and implement Best Management Practices (BMPs) needed to achieve compliance. The EWMPS will result in additional benefits including provision of open space and parkland, habitat creation, and storrnwater retention. Permittees not Preparing Watershed Management Programs or EWMPs must achieve compliance within a year of permit adoption. The EWMPs will identify potential and priority structural and non-structural MPs) within the region's stormwater collection system to improve runoff water quality. The LACFCD, along with participating Permittees, has opted to exercise this option and has submitted to the LARWQCB 12 separate Notices of Intent (NOIs) for the development of EWMPs within 12 distinct watershed groups (refer to Figure 1-1). Implementation of the EMWPs would be the responsibility of each Permittee and would occur following approval of the EWMPs by the LARWQCB. And on page 1-3 as follows: The timeline identified in the MS4 Permit requires that Permittees who elect to prepare Watershed Management Programs submit them the ,1 to the LARWQCB by June 28, 2015, in order to be in compliance with the permit conditions. The LACFCD recognizes that implementation of the EWMPs may potentially result in changes to environmental conditions. As a result, the LACFCD has prepared this Program LA County Flood Control District 11-46 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the EWMPs. The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior to submittal of the EWMPs. The EWMPs will be submitted by each EWMP group to the LARWQCB. Participation in a Watershed Management Program is voluntary and allows a Permittee to address the highest watershed priorities, including complying with the requirements of Receiving Water Limitations, Total Maximum Daily Load Provisions by customizing the control measures. The Watershed Management Programs shall ensure that discharges from the Permittee's MS4: (i) achieve applicable water quality -based effluent limitations, (ii) do not cause or contribute to exceedances of receiving water limitations, and (iii) do not include non -storm water discharges that are effectively prohibited. Watershed Management Programs shall be developed either collaboratively or individually using the Regional Water Board's Watershed Management Areas (WMAs). Permittees may elect to develop an enhanced Watershed Management Program (EWMP). An EWMP is one that comprehensively evaluates opportunities, within the participating Permittees' collective jurisdictional area in a WMA, for collaboration among Permittees and other partners on multi -benefit regional projects. As a result of the extended timeline given to achieve permit compliance through development of EWMP, as well as collaboration of resources, several Permittees have selected to prepare EWMPs as their form of MS4 Permit compliance; specific requirements detailed in the MS4 Permit must be met to successfully implement this compliance method. The PEIR discusses the effects of the implementation of these EWMPs. Response to Comment 7-B: The PEIR assumes that BMPs may be installed in any location, whether urbanized or previously undisturbed. The impact analysis assumes some projects may be proposed in open space areas and evaluates impact avoidance and minimization measures. The PEIR provides maps in Appendix G to the PEIR showing prospective locations for BMPs. The locations are broadly distributed throughout the watersheds. The LACFCD acknowledges that BMPs are not limited to urban areas but may be installed throughout a watershed if necessary to achieve water quality objectives. In response to the comment, the following changes have been made to the PEIR on page 1-3. The PEIR analysis is not intended to focus on the site-specific construction and operation details of each management strategy and project included in the EWMP. Rather, this PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution anywhere in the watershed. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources whether in urban environments or previously undisturbed open space. The analysis outlines mitigation strategies to be followed by the LACFCD and other implementing agencies that rely on this PEIR to a County Flood Control District 11-47 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments avoid or minimize impacts wherever feasible. The determinations of significance after mitigation in this PEIR will apply to the LACFCD and other implementing agencies that region this PEIR and the mitigation measures proposed herein. And on page 1-11 as follows: The PEIR focuses its assessment on construction and operation of these potential and priority BMPs to be installed throughout the watersheds—but primarily within urbanized areas where the pollutant loading is greatest and where these BMPs can be most cost- effective in meeting water quality goals. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis also considers potential impacts and mitigation for BMPs implemented in less developed and urbanized areas of the EWMP where water quality issues may exist that are not directly linked to urbanization but are still regulated under the MS4 Permit. The analysis outlines mitigation strategies to be followed by Implementing Agencies to avoid or minimize impacts wherever feasible. Exact locations and BMP designs are not defined. Rather, the overall compliance strategy of BMP type, quantity, and geographic distribution is assessed on a cumulative, regional scale. Response to Comment 7-C: The Basin Plan for the Santa Ana Regional Water Quality Control Board is mistakenly included as a reference on page 9-16. Refer to page 3.8-29 of Section 3.8, Hydrology and Water Quality, which correctly references the Los Angeles Basin Plan. The correct reference has been updated in Chapter 9, References, as shown below. California Regional Water Quality Control Board, Salstp Ana Los Angeles Region - 19943 Water Quality Control Plan for the Sant. Ana niy#r Los Angeles Region Basin (Basin Plan) updated in Febfuary 2008 June 1994. LA County Flood Control District 11-48 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Crnr HALL 8300 Sn A MOMCA BLVD. WEST HOLLYWOOD, CA 90069-6216 Ta: (323) 848-6460 PAx:(323) 848-6562 OFFICE OF THE CITY MANAGER PAUL AREVALO CTCY MANAGER CITY of WEST HOLLYWOOD March 02, 2015 Gregg BeGell, P.E. County of Los Angeles Department of Public Works 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 Mr. BeGell: Comment Letter 8 EC10WI D NAR 0 9 2015 DEPT. PUBUC TOVOR(S PROJECT FFANAPU.7-M 4T DM6i0^J 11 The City of West Hollywood is committed to the development of programs that improve water quality. The Los Angeles County Flood Control District is preparing a Program Environmental Impact Report (PEIR) to evaluate the proposed Enhanced Watershed Management Programs (EWMPs) which are being developed to improve water quality in Los Angeles County. The PEIR is an Advanced Planning Document describing details of the County -wide water quality program (EWMPs) being launched in partnership with municipalities within the County to comply with the new MS4 Permit. Advanced Planning improves public awareness and government transparency and provides for a higher level assessment of policy decisions prior to the consideration of individual projects. The City of West Hollywood has reviewed the Draft PEIR and agrees with its conclusions regarding the impacts of the proposed EWMPs on the environment and its proposed mitigation measures. The City is writing to offer its support for the implementation of EWMPs to achieve A compliance with the MS4 Permit and to encourage the certification of the PEIR developed by the Los Angeles County Flood Control District (LACFCD). Sincerely, a^4w� Paul Arevalo City Manager cc: Sharon Perlstein, City Engineer Matt Magener, Environmental Coordinator File N �y YIII4 ,! 110.4011 ,q Comments Response to Comment Letter 8 (City of West Hollywood — March 9, 2015) Response to Comment 8-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The commenter's support for the PEIR is noted. IA County Flood Control District 11-50 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 9 Paige Anderson To: Laura Rocha Subject: RE: Notice of Availability for the Draft PEIR-Enhanced Watershed Management Programs From: Bryan Moscardini Sent: Tuesday, March 10, 2015 11:55 AM To: Gregg Begell Cc: Kathline J. King; Hayden Sohm; Frank Gonzales; Joe Mendoza; Norma E. Garcia; Joan Rupert Su bj act: Notice of Availability for the Draft PEI R -Enhanced Watershed Management Programs Gregg, Please see attached comment letter for the above project. We look forward to working with you and your Department as these projects are prioritized, funded and implemented. Thank you. Bryan Moscardini Departmental Facility Planner I County of Los Angeles Department of Parks and Recreation Planning Division -Land Management and Compliance 510 South Vermont Avenue Los Angeles, CA 90020 P 213.351.5133 F213.639-3959 bmoscardini(a)parks.lacounty.gov Please note that our office is closed on Fridays CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 9 COUNTY OF LOS ANGELES DEPARTMENT OF PARKS AND RECREATION "Parks Make Life Better.!" Russ Guiney, Director John Wicker, Chief Deputy Director March 3. 2015 Sent via email: gbegell@dpw.lacounty.gov Mr. Greg BeGell County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont Avenue, 5th Floor Los Angeles, CA 91803 Dear Mr. BeGell: NOTICE OF AVAILABILITY OF A DRAFT PROGRAM ENVIRONMENTAL IMPACT REPORT FOR THE ENHANCED WATERSHED MANAGEMENT PROGRAMS The Department of Parks and Recreation (DPR) has reviewed the above project for potential impact on the facilities under the jurisdiction of the Department and offers the following comments: The County Park facilities listed in the document as candidates for structural BMP implementation would likely experience some level of temporary construction impacts: • Ladera Park (Ballona Creek EWMP Group) • Hellen Keller Park (Dominguez Channel Watershed Management Area Group) • Roosevelt Park (Upper Los Angeles River Watershed EWMP) • San Angelo Park (Upper San Gabriel River EWMP Group) • Adventure Park (Upper San Gabriel River EWMP Group) • Allen Martin Park (Upper San Gabriel River EWMP Group) • Bassett Park (Upper San Gabriel River EWMP Group) • Santa Anita Golf Course (Rio Hondo/San Gabriel River Water Quality Group) • Chester Washington Golf Course (Dominguez Channel WMA Group) • The Los Angeles County Arboretum (Rio Hondo/San Gabriel River WQ Group) • Peck Road Water Conservation Park (Rio Hondo/San Gabriel River WQ Group) I1 Please continue to coordinate with our Department as BMP project -types (bio -infiltration cells, bio-swales, porous pavement and filter strips, low -flow diversions, detention ponds, B treatment wetlands, and steam/creek restoration projects) and funding opportunities are identified as well as implementation priorities established. Planning and Development Agency 6 510 South Vermont Ave • Los Angeles, CA 90020-1975 • (213) 351-5198 Comment Letter 9 Mr. Greg BeGell March 2, 2015 Page 2 Thank you for including this Department in the environmental review process. If you have any questions, please contact Bryan Moscardini of my staff at (213) 351-5133 or by email at bmoscardini@parks.lacounty.gov. Sincerely, Kathline J. King Chief of Planning KK:JR:bm / Response to LACFCD-EWMP c: Parks and Recreation (N. E. Garcia, J. Rupert, B. Moscardini) Comments Response to Comment Letter 9 (County of Los Angeles Department of Parks and Recreation — March 10, 2015) Response to Comment 9-A Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The projects implemented as part of the EWMPs are not known at this time; therefore, specific impacts to parks are not known. As discussed in Impact 3.12-4 on pages 3.12-12 and 3.12-13 of the PEIR, certain parts of selected parks and recreational facilities would temporarily be removed from service during the construction of the final proposed structural BMPs, and could potentially increase the use of adjacent parks and other recreational facilities. However, construction periods for each BMP are expected to be relatively short, typically several months to a year. Because the construction will be temporary, the physical deterioration of park and recreational facilities to which recreational activities were diverted would not be substantial. Coordination with the County Parks and Recreation Department will be carried out as projects are identified and moved forward. This comment has been noted and will be provided to the County of Los Angeles Board of Supervisors for their consideration. Response to Comment 9-B The proposed EWMP BMPs are under development. Coordination with the County Parks and Recreation Department will be carried out as projects, funding and implementation priorities are identified. LA County Flood Control District 11-54 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 10 .A*. Central Basin MW Mur -I c'ipal Water ❑isle cl F Board of Directors Division I Division 11 Division III •f1l1• -'11::.:1 DIY351011 IV Division V r.1a1-(.1, C4 1. �..:�il; ��. II r:1r r.;r%, g R Cjr:11. 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Alternatives CurTtrneFit- '•:'I e1 •::I 1-.;111 ::.I fr: 1;:•I 1 1 -Ill'; ,::I:ITR at,:: L.MP 1 C U Ill U I atI V0 Prnje CIS Com nr_nt: TIL- r'riFl= nnis- 1 `: r: a a:_ r r r11 rrrl: •:a :I'- L r.'•.: .1 ; i - It' -I l s StII%- :�c11 1-:iL--I IiI. c;1 .'iII i ":•-} :'!-:(t:, �i l_I :i•.. ll :l'.If� "I:=11' It;lt`.'. 11 1!', �!1;•: :li -:,• I!1+...t..:1 I'�'[r•�1- 1.P,1 .-1 I1Y"i:It t"� .-1 F. •:-i.:':,i C! -I;. ..l'la �• r..- C:r,:�llall:. � K '.:irl r' --IiiIm. to Comments Response to Comment Letter 10 (Central Basin Municipal Water District – March 12, 2015) Response to Comment 10-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR acknowledges that most of the projects to be included in the EWMPs are either currently undefined or currently under development. Priority projects are listed in Appendix G of the PEIR. Some background on the MS4 Permit is provided in Section 1, explaining the policies guiding the implementation of the BMPs. Response to Comment 10-B: Because project details are largely incomplete since the EWMPs are being drafted concurrently, each individual project will be subject to a CEQA compliance evaluation prior to approval by the implementing agencies as noted in Section 1 of the Draft PEIR. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of its proposed projects. The PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis outlines mitigation strategies to be followed by the LACFCD and other implementing agencies that rely on the PEIR to avoid or minimize impacts wherever feasible. The PEIR provides the LACFCD a foundation for any necessary future environmental review that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. Response to Comment 10-C: The 12 EWMPs cover a large geography that exhibits numerous soil types. A comprehensive soils assessment and vegetation mapping within the entire County would not be helpful at the high-level scale of the impact analysis because the level of detail needed for individual BMP projects would not be feasible for all potential BMP locations throughout the County. Soil types may differ acre -by -acre in potential BMP locations, requiring a site specific analysis that is impractical to employ for the entire County in the PEIR. Some areas are underlain by alluvial soils of varying characteristics and other areas by clay or bedrock. Some areas are underlain by aquitards—subsurface impermeable clay layers—that prevent infiltrated water from entering a County Flood Control District 11-59 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments deeper drinking water aquifers. Locating infiltration BMPs in areas with permeable soils (generally sandy soils that allow percolation of water) is a primary criterion for successful infiltration. Mitigation Measure GEO-1 requires that implementing agencies conduct geotechnical assessment of proposed BMP locations to ascertain soil types prior to installing infiltration BMPs, which reduces potentially significant impacts to less than significant levels. Response to Comment 10-D: As noted on page 3.8-35 of the PEIR, soils may contain legacy contamination from past overlying uses or may contain naturally occurring minerals that may be entrained by infiltrating water and conveyed to the drinking water aquifer. Naturally occurring pollutants may include minerals such as arsenic, iron, and manganese. Concentrations of these pollutants are regulated in drinking water. Other pollutants may include petroleum hydrocarbons, nitrates, and pathogens. As described in the PEIR, Mitigation Measures HYDRO -1 through HYDRO -3 would lessen potential impacts from naturally occurring pollutants to a less than significant level. HYDRO -3: Prior to the installation of an infiltration BMP, the Permittee shall conduct a regulatory database review for contaminated groundwater sites within a quarter mile of the proposed infiltration facility. The review shall include locations of on-site wastewater treatment systems that could be affected by the BMP. The Permittee shall identify whether any contaminated groundwater plumes or leach fields are present and whether coordination with the local and state environmental protection overseeing agency and responsible party is warranted prior to final design of infiltration facility. Response to Comment 10-E: Impacts to wetlands were discussed in Impact 3.3-3 on page 3.3-26 of the Draft PEIR. Mitigation measures BIO -1 through BIO -9 were identified to mitigate impacts to wetlands and reduce potentially significant impacts to less than significant levels. Mitigation BIO -9 specifically requires conducting formal wetland delineation in areas where potential jurisdictional resources (i.e., wetlands or drainages) subject to the jurisdiction of the United States Array Corps of Engineers, the Los Angeles Regional Water Quality Control Board, and the California Department of Fish and Wildlife may be affected by the project. Response to Comment 10-F: Impacts to sensitive habitats, wildlife habitat, and natural movement corridors were discussed in Impact 3.3-1, Impact 3.3-2, and Impact 3.3-4, respectively. Mitigation Measures BIO -1 through BIO -8 involve the protection of sensitive habitats and wildlife habitat and would reduce potentially significant impacts under Impact 3.3-1 and Impact 3.3-2 to less than significant levels. As noted under Impact 3.3-4 on pages 3.3-27 and 3.3-28 of the PEIR, , implementation of the EWMPs would not be expected to interfere with wildlife movement or any migratory corridor/linkage, and the BMPs would not be constructed within a native wildlife nursery site; no mitigation is necessary to reduce Impact 3.3-4 to less than significant levels. LA County Flood Control District 11-60 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Comment 10-G: The proposed EWMP BMPS as described in the PEIR are under development. Impacts to cultural resources are detailed in in Impact 3.4-1 through Impact 3.4-4 of the Draft PEIR (pages 3.4-19 through 3.4-26). Per Mitigation Measure CUL -2, an archeological survey of the APE shall be performed where deemed appropriate by a qualified archaeologist, which would reduce potentially significant impacts to less than significant levels. Response to Comment 10-H The proposed EWMP BMPS as described in the PEIR are under development. Mitigation Measures CUL -2, CUL -3 of the Draft PEIR (pages 3.4-22 through 3.4-23) require consultation with local Native American representatives concerning Phase I cultural resources, treatment measures, qualification of historical resources or unique archaeological resources requiring archaeological monitoring, and avoidance measures and mitigation. These mitigation measures would reduce potentially significant impacts to less than significant levels. For projects under development, additional mitigation measures may be identified as necessary to address future - identified impacts. Response to Comment 10-I: Figure 3.5-3 locates the liquefaction zones established in the County. Figures 2-5 through 2-16 identify potential BMP locations. As BMPS are developed, a site assessment would be conducted in accordance with County Low Impact Development Standards. This includes identifying the potential for seismically -induced liquefaction and other ground failures. In addition, Mitigation Measure GEO-1 requires that implementing agencies conduct geotechnical assessment of proposed BMP locations to ascertain soil types prior to installing infiltration BMPS, which would identify liquefaction zones. The PEIR acknowledges that BMPS will be located within liquefaction zones. Response to Comment 10-J: The proposed EWMP BMPS as described in the PEIR are under development. Site specific details regarding groundwater levels and flow gradient would be collected as the BMPS are developed and additional environmental impacts will be analyzed pursuant to the requirements of the California Environmental Quality Act. The PEIR includes Mitigation Measure HYDRO -2 that requires implementing agencies to identify depth to groundwater prior to implementing infiltration BMPS. Mitigation Measure GEO-2 requires implementing agencies to contact groundwater managers prior to installing infiltration BMPS. Both of these mitigation measures would reduce potentially significant impacts to less than significant levels. Response to Comment 10-K: The PEIR acknowledges on page 3.8-35 that underground contamination may be influenced by infiltration BMPS. Mitigation Measure HYDRO -3 requires a database search for groundwater a County Flood Control District 11-61 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments contamination plumes prior to installing infiltration BMPs and would reduce potentially significant impacts to less than significant levels. It should be noted that as part of Response to Comment 3-A above, Mitigation Measure HYDRO - 3 has been modified on page 3.8-36 of the PEIR as shown below: HYDRO -3: Prior to the installation of an infiltration BMP, the Permittee shall conduct a reeulatory database review for contaminated groundwater sites within a quarter mile of the proposed infiltration facility. The review shall include locations of on-site wastewater treatment systems that could be affected by the BMP. The Permittee shall identify whether any contaminated groundwater plumes or leach fields are present and whether coordination with the local and state environmental protection overseeing agency and responsible party is warranted prior to final design of infiltration facility. Response to Comment 10-L: As discussed in Section 3.8, Hazards and Hazardous Materials, page 3.7-19, contaminated soil and/or groundwater could be encountered during excavation posing a health hazard to construction crews, the public, and the environment. Implementation of Mitigation Measure HAZ-2 would reduce the potential impact to less than significant. Mitigation Measure HA -Z-2 would require a Phase I Environmental Site Assessment in areas where hazardous material use or management may have occurred and would reduce potentially significant impacts to less than significant levels. Response to Comment 10-M: Environmental justice is discussed in Section 3.11, Population and Housing and Environmental Justice, Impact 3.11-4 on page 3.11-7. The PEIR concludes that impacts would be less than significant due to the broad distribution of water quality BMPs to be implemented throughout the communities. No mitigation was determined to be necessary to reduce environmental justice impacts to less than significant levels. Response to Comment 10-N: Figure 3.5-3 locates the liquefaction zones established in the County. Figures 2-5 through 2-16 identify potential BMP locations. The 12 EWMPs cover a large geography that exhibits numerous soil types. A comprehensive soils assessment and recharge mapping within the entire County would not be helpful at the high-level scale of the impact analysis because the level of detail needed for individual BMP projects would not be feasible for all potential BMP locations throughout the County. Soil types may differ acre -by -acre in potential BMP locations, requiring a site-specific analysis that is impractical to employ for the entire County in the PEIR. Some areas are underlain by alluvial soils of varying characteristics and other areas by clay or bedrock. Some areas are underlain by aquitards—subsurface impermeable clay layers—that prevent infiltrated water from entering deeper drinking water aquifers. Locating infiltration BMPs in areas with permeable soils (generally sandy soils that allow percolation of water) is a primary criterion for successful infiltration. LA County Flood Control District 11-62 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments As described in Section 3.14, Utilities, page 3.14-1 of the Draft PEIR, the largest stormwater detention and recharge facilities in Los Angeles County are located along the San Gabriel River in the City of Pico Rivera. These facilities are shown in Figure 3.14-1, Water Recharge Facilities. As BMPS are developed, a site assessment would be conducted in accordance with County Low Impact Development Standards. This includes identifying the potential for seismically -induced liquefaction and other ground failures. In addition, Mitigation Measure GEO-1 requires that implementing agencies conduct geotechnical assessment of proposed BMP locations to ascertain soil types prior to installing infiltration BMPS, which would identify liquefaction zones. The PEIR acknowledges that BMPs will be located within liquefaction zones. Response to Comment 10-0: The proposed EWMP BMPS as described in the PEIR are under development. Site-specific details regarding groundwater levels and as necessary, streambeds downslope of the groundwater tables, would be collected as the BMPS are developed and additional environmental impacts will be analyzed pursuant to the requirements of the California Environmental Quality Act. The PEIR includes Mitigation Measure HYDRO -2 that requires implementing agencies to identify depth to groundwater prior to implementing infiltration BMPS. Mitigation Measure GEO-2 requires implementing agencies to contact groundwater managers prior to installing infiltration BMPS. Both of these mitigation measures would reduce potentially significant impacts to less than significant levels. Response to Comment 10-P: The PEIR includes an assessment of potential impacts of groundwater recharge to water quality on page 3.8-35 and to soil stability on page 3.5-23. Implementation of Mitigation Measures GEO- 1, HYDRO -1, HYDRO -2, and HYDRO -3 would reduce impacts to less than significant levels. It should be noted that as part of Response to Comment 3-A above, Mitigation Measure HYDRO -3 has been modified as shown below. HYDRO -3: Prior to the installation of an infiltration BMP, the Permittee shall conduct a regulatory database review for contaminated groundwater sites within a quarter mile of the proposed infiltration facility. The review shall include locations of on-site wastewater treatment systems that could be affected by the BMP. The Permittee shall identify whether any contaminated groundwater plumes or leach fields are present within close proximity to the BMP location that could be affected by infiltrated water and whether coordination with the local and state environmental protection overseeing agency and responsible party is warranted prior to final design of infiltration facility. It should be noted that as part of Response to Comment 16-J below, Mitigation Measure HYDRO -4 has been added under Impact 3.8-3 as shown below, which would also reduce impacts to water quality and soil stability. HYDRO -4: Prior to approving a structural BMP, the implementing agencies shall conduct an evaluation of the potential hydromodification impacts of the project. The evaluation shall recommend design measures necessary to prevent or minimize a County Flood Control District 11-63 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments any identified impacts, including flooding, erosion and/or scour. Design measures could include velocity dissipaters and bank re -enforcement components. Implementing agencies shall include these measures in project designs. The 12 EWMPs cover a large geography that exhibits numerous soil types. A comprehensive stormwater recharge assessment within the entire County would not be helpful at the high-level scale of the impact analysis because the level of detail needed for individual BMP projects would not be feasible for all potential BMP locations throughout the County. Soil types may differ acre - by -acre in potential BMP locations, requiring a site specific analysis that is impractical to employ for the entire County in the PEIR. Some areas are underlain by alluvial soils of varying characteristics and other areas by clay or bedrock. Some areas are underlain by aquitards— subsurface impermeable clay layers—that prevent infiltrated water from entering deeper drinking water aquifers. Locating infiltration BMPs in areas with permeable soils (generally sandy soils that allow percolation of water) is a primary criterion for successful infiltration. As described in Section 3.14, Utilities, page 3.14-1 of the Draft PEIR, the largest stormwater detention and recharge facilities in Los Angeles County are located along the San Gabriel River in the City of Pico Rivera. These facilities are shown in Figure 3.14-1, Water Recharge Facilities. Mitigation Measure GEO-1 requires that implementing agencies conduct geotechnical assessment of proposed BMP locations to ascertain soil types prior to installing infiltration BMPs, which reduces potentially significant impacts to less than significant levels. Response to Comment 10-Q: The EWMPs are being developed cooperatively by municipalities covered in the Permit. Each Permittee is required to implement stormwater quality improvement BMPs regardless of the economic condition of the city or local community. As cooperating Permittees, the EWMP groups have combined resources to develop BMPs benefiting the entire region. Access to funding for BMPs is not an environmental impact addressed in this PEIR. However, the EWMPs will contain a discussion on proposed funding sources available. Financing considerations are outside the realm of CEQA and are thus outside of this PEIR analysis. Response to Comment 10-R: The EWMP groups have developed BMPs based on modeling of local water quality and water quality objectives. The PEIR describes the Permit requirements in Section 1. As individual projects are proposed for implementation, the lead agencies will identify the specific benefits provided by each BMP. If proposed BMPs potentially result in significant impacts, the lead agency for the BMP will assess project alternatives if required to address CEQA compliance on the project level. Response to Comment 10-5: The PEIR identifies natural communities within the County in Figure 3.3-7, Natural Communities in Section 3.3, Biological Resources. The PEIR acknowledges on pages 3.3-18 through 3.3-32 that BMPs could affect natural communities. Implementation of Mitigation Measures BIO -1 through 13I0-9 are proposed to mitigate potential effects to less than significant levels. LA County Flood Control District 11-64 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 11 Paige Anderson To: Laura Rocha Subject: RE: PEIR Comments from City of Malibu From: Jennifer Brown[mailto:JBrown(o)malibucity.oral Sent: Monday, March 16, 2015 5:14 PM To: Gregg Begell Subject: PEI R Comments from Glty of Malibu Hello Mr. BeGell, Attached are the support letter and comments from City of Malibu on the subject project. Please contact me if you have any questions. Kind regards, Jennifer Brown I Sr. Environmental Programs Coordinator Environmental Sustainability Department I City of Malibu 23825 Stuart Ranch Road Malibu, CA 90265 310.456.2489 ext. 275 APlease consider the environment before printing this email Go Dirty for the Drought. Take the Dirty Car Pledge now CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 11 City of Malibu 23825 Stuart Ranch Road - Malibu, California • 90265-4861 Phone (310) 456-2489 - Fax (310) 456-3356 - www.malibucity.org March 16, 2015 Gregg BeGell, P.E. County of Los Angeles Department of Public Works 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 gbegell(a dnw.lacountv.aov RE: Draft Program Environmental Impact Report (EIR) Support and Comments To Mr. BeGell: The City of Malibu supports the development of programs that improve water quality and has historically taken steps to ensure protection of local waters. Therefore, the City of Malibu is committed to such efforts and is actively working with the County of Los Angeles and the Los Angeles County Flood Control District (LACFCD) on the Enhanced Watershed Management Program (EWMP) for the North Santa Monica Bay Coastal Watersheds. The City would like to acknowledge the LACFCD for its efforts to prepare a Program EIR evaluating the proposed EWMPs in Los Angeles County that are being developed to protect water quality. The Program EIR describes details of the County -wide EWMPs being launched in partnership with municipalities in the County to comply with the 2012 Los Angeles region municipal stormwater permit Order No. R4-2012-0175 (Permit). Such advanced planning improves public awareness and government transparency and provides for a higher level assessment of policy decisions prior to the consideration of individual projects. The City of Malibu reviewed the Draft Program EIR and generally agrees with its conclusions regarding the impacts of the proposed EWMPs on the environment and its proposed mitigation measures. The City also offers the enclosed comments and clarifications for consideration. The City of Malibu expresses its support for the implementation of EWMPs to achieve compliance with the Permit and to encourage the certification of the Program EIR developed by LACFCD. The City of Malibu appreciates the attention to these issues and the opportunity to partner in the solution to protecting the region's water quality. If you have any questions regarding this letter, please contact me at (310) 456-2489 x 275 or ibrown(a),malibucitv.org. n:enuYP,I V, vn Sema. .., __ _ Programs Coordinator Enclosure cc: Jim Thorsen, City Manager Christy Hogin, City Attorney r �` RwyWPVm U Document Name: Programmatic EIR for Enhanced Watershed Management Programs Comment Comments Doc. Reference No. Page Parag. Section City of Malibu (pdf/section-page) 1 74/2-18 Re: Wildlife Road project is anticipated to be complete in earl 2015. arae anyon 21 81/2-25ro'ect should be "Flap" not "Flat" ate roa eac 3 87/2-31 Rd Project "treating stormwater and urban dry -weather runoff prior to flowing into..." Broad Beach 4 87/2-31 Rd Project delete "with potential to incorporate harvest and uses stems for Malibu Drains" Broad Beach 5 87/2-31 Rd Project Three Two types of biofilters are included; re -manufactured and custom designed biofilters. Legacy FiarK Pump Station 6 93/2-37 Upgrades insert: "compliance with Santa Monica Bay and Malibu Creek Bacteria TMDL requirements"... "These watersheds are characterized by lower density development along the coast and the larger creeks with greater open space and park areas 7 97/2-41 51 2.5 inland." Change asterix note to: "Potential Distributed BMP not shown - predominantly located in urbaniaecleveloped areas". 8 107 Fig 2-1 map Urbanized implies something that the rural and even suburban areas of the NSMB are not. 9 107 Fig 2-1 map What are the olive green dots for if not potentialprojects? Need to be on key. 10 116/3.12 2 "large acre insert "and rural" residential " Even though this is citing to a RW QCB document, it would be helpful to state that "X acres out of Y acres are impervious" for 11 116/3.12 4 context on both Malibu Creek and Ballona Creek. 12 130/3.2-1 1 3.2.1 Majority is of the County is highly urbanized insert: with some adjacent rural areas and consists of... "dense residential [insert:immediately] along the coast and less development and greater open space areas [insert: as you 13 161/3.3-2 3.3 move off the shoreline and] inland Malibu [insert: Creek] Watershed. This ommission is repeated through the document and could cause confusion to someone not familiar with the area because the majority (approx. 98%) of MC Watershed is outside of the City limits. We attempted to point out al instances as part of this review, but some may have been missed. Please ensure document accurately reflects 14178/3.3-19 6 the name of all watersheds. 15 179/3.3-20 41 1 Malibu insert: Creekl Watershed. See coment 15. 161 180/3.3-211 41 1 change "Pre -urbanization" to "Pre -development" IB IC ID IE IF TG ICI 1J IK IL IM TN 1� IP IQ Comment Doc. Reference Comments No. Page (pdf/section-page) Parag. Section City of Malibu 17 183/3.3-23 Malibu insert: Creekl Watershed. See coment 15. 18 185/3.3-26 Malibu insert: Creek Watershed. See coment 15. 19 295/3.8-4 1 in urbanized areas along the insert: central and southl Santa Monica Ba 20 295/3.8-4 1 In insert: North Santa Monica Ba including City of Malibu and insert: County unincorporated] 21 297/3.8-6 2 change "address" to "preventpossible" bacteria loading 22 303 fig 3.8-3 map Change asterix note to: "Potential Distributed BMP not shown - predominantly located in I -Fhaai�ed developed areas". Urbanized implies something that the rural and even suburban areas of the NSMB are not. 23 303 fig 3.8-3 map What are the olive green dots for? Need to be on key. 24 318/3.8-27 3.8-27 the ASBS general exception also designates Los Angeles Count 25 318/3.8-27 3.8-27 clarify sentence. Should it end after, "discharges to ASBS." 26 318/3.8-27 3.8-27 " rovided that delete: and insert: the discharge]... 27 329/3.8-38 3 fix grammar/clarify: "Drainage patterns would change through implementation of these non-structural institutional BMPs— However, implementation of LID strategies, which include on-site infiltration, chat would minimize off-site flows as well as the potential for erosion and off-site siltation." 28 330/3.8-39 1 3.8 The structural BMPs would also provide ' rotections to water quality of receiving waters 29 330/3.8-39 2 3.8 BMPs but would be designed to improve [insert:runoffl water quality and reduce stormwater flow volumes. 30 335/3.9-1 21 3.9.1 The majority of the County is highly urbanized [insert: with some adjacent rural areas] and consists of several cities, communities and unincorporated areas. 31 335/3.9-1 3 3.9.1 jurisdiction over the land that is owned by the State of California (i.e., [insert: California Department of Parks and Recreation], California Department Fish and Wildlife, the State Lands Commission, and the California Department of Transportation) or the U.S. Government insert: i.e., National Parks Service 32 347 fig 3.9-6 map Potential Distributed BMP not shown - predominantly located in urbanized developed areas 33 347 fig 3.9-6 map What are the olive green dots for? Need to be on key. 34 360/3.9-26 Discussion about potential ag land. Get statement from Planning about ag designations in Bu 35 362/3.9-28 1 make comment about LID Ord requirements 36 370/3.9-36 21 Malibu insert: Creekl Watershed. See coment 15. 371 372/3.9-38 11 because the EW MPs would be implemented in already established urban developed areas IR Is =T IU Iv M 1" IY IZ 2 AA IBB ICC IDD TEE FF 1 GG I HH j11 T .i.i J KK I LL Comment Comments Doc. Reference No. Page Parag. Section City of Malibu (pdf/section-page) The document says that LA City and LA County have LID ordinances in place and that some cities may also have LID ordinances. The document should reflect that all EW MP cities are required to have LID ordinances in place that comply with specific MS4 permit requirements by June 28, 2015 (the same date the EWMP's must be submitted for review). For example and not meant as a limitation, see page 3.9-28. Since this is a regulatory requirement under the 2012 permit, the LID 3.9-28, and requirements that must be included in city ordinances can be accounted for in the analysis and conclusions throughout the 381 442/3.14-10 document. 39 3.2-13 Air qualitysection needs a regulatory setting section for cities. The City has questions about the conclusion that there is a significant and unavoidable construction noise impact. See Impact 3.10-1 and cumulative discussion. Essentially, the City does not have enough information based on what is written to determine if we agree with the conclusion. The document should explain why it assumes, after mitigation, that there may be circumstances where the construction activities for these types of projects may exceed thresholds, or the basis or for that assumption. We typically assume that projects will follow the law unless there is a specific reason to believe these types of projects will exceed noise standards. If a project does violate any local standards, every city has code enforcement teams and strategies in place to promptly remedy the problem or stop construction until it can be remedied. Thus, it is unlikely that a noise violation would go on long enough to cause a significant, unavoidable impact in the community. Please reconsider this 401 3.1-1 conclusion or provide more information explaining the basis for this conclusion. Some of the projects listed (especially, Wildlife Rd, Broad Beach rd, and Legacy Pumps Upgrade) in the PEIR are projects which were to be completed within 30 months of permit adoption as a condition of EWMP Notice of Intent submittals ... such projects are either already completed or under construction and have gone through their own CEQA process if needed. The PEIR should make clear that these are included as examples of the types of projects that may be included in the EW MPs but 41 general not projects that are covered by the PEI R. In the Executive Summary, page ES -2 first full paragraph, second sentence, suggest modifying the second sentence to insert the following: "The EW MPs will identify potential and priority structural and non-structural Best Management Practices (BMPs) within the [drainage areas served by the] region's stormwater collection system to improve runoff water quality." Otherwise it sounds like the PEIR only covers projects actually constructed in the LACFCD easements and it would be of 42 ES -2 1 ES limited use to other agencies who want to tier off of the document. 431 372/3.9-38 1 3.9 structural BMPs would be implemented largely in upbaa494 developed areas 44 393/3.10-19 4 3.1 Given the urbanized environment of insert: much o the County, the potential exists... Me s ruc ura s wou genera y e oca a wi in 45 404/3.11-5 1 existing ud4 a� developed areas the westernmost HS and elementary school in Malibu/N. Santa Monic Bay EW MP area overlap on the map and make it hard 46 412/3.12-1 map to see there are both. Perhaps offset them a little more. MM I NN •• PP �QQ I RR ISS ITT IUU Comment Doc. Reference Comments No. Page (pdf/section-page) Parag. Section City of Malibu 47 434/3.14-2 table There is one additional small district that operates as a retailer for an individual private neighborhood in Malibu- they are from the Valencia/Santa Clarita area and we generally have no contact with them or an understanding how they can to provide service to this neighborhood. 48 448/3.14-16 last In areas with natural unimproved streams, such as in the Santa Clara River watershed and Malibu [insert: Creek] watershed where surface water diversions may be more common, stormwater flows are conveyed downstream quickly. 49 448/3.14-16 last Re: "In areas with natural unimproved streams, such as in the Santa Clara River watershed and Malibu [insert: Creek] watershed where surface water diversions may be more common, stormwater flows are conveyed downstream quickly."- should the North Santa Monica Bay Coastal Watersheds also be mentioned in this? I'm not sure whether to advocate for that: all but a couple short segments of the streams are unimproved and it is not clear what is intended by "conveyed downstream quickly" and what types of "diversions."{ Please clarify and add NSMBCW as necessary. 50 450/3.14-18 11 County of Los Angeles, except under unusual circumstances, it is feasible to recycle or reuse at least 50 percent er of construction 51 458/4-4 table 4-1 Wildlife Rd- Construction was scheduled to begin March 2014 and continue through early 2015 52 458/4-4 table 4-1 Broad Beach Rd- Early to mid -'Q-'-' ^ 2015 53 471/6-5 2 reduce pollutants from dry- and wet -weather arbaa runoff 54 476/6-10 1 since green -streets and small-scale grassy swales would be installed that generally would improve local character in urban settings 55 479/6.2 2nd obi table 6-2 pollutants from dry- and wet -weather ban -runoff in a cost-effective manner I VV I WW XX IYY IZZ IAAA I BBB I CCC I DDD n 0 0 3 rt r rt ID ML ML to Comments Response to Comment Letter 11 (City of Malibu — March 16, 2015) Response to Comment 11-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The commenter's support for the PEIR is noted Response to Comment 11-B: Page 2-18 of the PEIR has been updated with the correct early 2015 completion date for the Wildlife Road Project. Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11-C: Page 2-25 of the PEIR has been updated to change "flat" gate to "flap" gate. Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11-13: The commenter states that "treating stormwater and urban runoff prior to the entering into..." should read, "treating stormwater and dry -weather runoff prior to flowing into..." Page 2-31 of the PEIR has been updated to change "treating stormwater and urban runoff prior to the entering into..." to "treating stormwater and dry -weather runoff prior to flowing into." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11-E: Page 2-31 of the PEIR has been updated to delete "with potential to incorporate harvest and use systems for Malibu Drains." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11-F: Page 2-31 of the PEIR has been updated to read, "Two types of biofilters are included; pre - manufactured and custom designed biofilters." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. a County Flood Control District 11-71 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Comment 11-G: Page 2-37 of the PEIR has been updated to add 'compliance with Santa Monica Bay and Malibu Creek Bacteria TMDL requirements." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11-H: The comment includes copied text from the Draft PEIR, page 2-41, Section 2.5. However, no suggested text revisions were provided. As a result, no change was identified. Response to Comment 11-I: The use of the phrase "predominately urbanized" is appropriate for the figures. The location of BMPs will not be limited to urbanized or developed areas, but will be located wherever water quality improvements are needed to comply with water quality objectives. No revision is necessary. Response to Comment 11-J: The green dots on the figures indicate potential locations being considered for regional or centralized projects. If the green dots were indicated in the legend but not shown on the map, the BMP information was not available at the time of publication of the Draft PEIR. Appendix G includes the locations of priority projects shown as red dots on the figures. No revision is necessary. Response to Comment 11-K: Page 3.1-2 of the PEIR has been updated to change "large -acre residential properties" to "large - acre and rural residential properties." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11-L: Page 3.1-2 of the PEIR generalizes the acreage of impervious acres in Ballona Creek and Malibu Creek watersheds, but no precise calculation has been prepared. No revision is necessary. Response to Comment 11-M: Page 3.2-1 of the PEIR has been updated to change "the majority of the County is highly urbanized and consists of several cities, communities, and unincorporated areas" to "the majority of the County is highly urbanized with some adjacent rural areas and consists of several cities, communities, and unincorporated areas." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. LA County Flood Control District 11-72 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Comment 11-N: Page 3.3-2 of the PEIR has been updated to reflect this change "these watersheds are characterized by dense residential development along the coast and less development and greater open space areas inland" to "these watersheds are characterized by dense residential development immediately along the coast and less development and greater open space areas as you move off the shoreline and head inland." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11-0: Page 3.3-19 of the PEIR has been updated to identify "Creek" in all instances in which "Malibu Creek Watershed" is intended. Additionally, "Creek" has been added to all other appropriate instances in the Draft PEIR. Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11-P: Page 3.3-20 of the PEIR has been updated to change "Malibu Watershed" to "Malibu Creek Watershed." Additionally, "Creek" has been added to all other appropriate instances in the Draft PEIR. Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11-Q: The use of the phrase "pre -urbanization" is appropriate for the text. And is consistent with the text on Page 3.2-1 of the PEIR, which has been updated to change "the majority of the County is highly urbanized and consists of several cities, communities, and unincorporated areas" to "the majority of the County is highly urbanized with some adjacent rural areas and consists of several cities, communities, and unincorporated areas." No changes are needed. Response to Comment 11-R: Page 3.3-24 of the PEIR has been updated to change "Malibu Watershed" to "Malibu Creek Watershed." Additionally, "Creek" has been added to all other appropriate instances. Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11-5: Page 3.3-26 of the PEIR has been updated to change "Malibu Watershed" to "Malibu Creek Watershed." Additionally, "Creek" has been added to all other appropriate instances. Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11-T: Page 3.8-4 of the PEIR has been updated to change "in urbanized areas along Santa Monica Bay" to "in urbanized areas along central and south Santa Monica Bay." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. a County Flood Control District 11-73 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Comment 11-U: The exact original text as described above could not be located in the document. No revision is necessary to page 3.8-4 of the PEIR. Response to Comment 11-V: Page 3.8-6 of the PEIR has been updated to change "address bacteria loading" to "prevent possible bacteria loading." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11-W: The use of the phrase "predominately located in urbanized" is appropriate for the figures. No revision is necessary. Response to Comment 11-X: The "Potential (Regional and Centralized) BMPs" symbolized by green circles are located in the key at the bottom left corner of Figure 3.8-3. No revision is necessary to Figure 3.8-3 of the PEIR. Response to Comment 11-Y: Page 3.8-27 of the PEIR has been updated to add "including Los Angeles County from certain Ocean Plan ASBS discharge prohibitions" after "which exempts certain listed dischargers." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. The revisions are also Response to Comment 11-Z: Page 3.8-27 of the PEIR has been updated to add "California Department of Parks and Recreation" and to add "Laguna Point to Latigo Point," and to delete "and the California." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11 -AA: Page 3.8-27 of the PEIR has been updated to change "provided that it:" to "the discharge:". Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11 -BB: Page 3.8-38 of the PEIR has been updated to change "Drainage patterns would change through implementation of these non-structural institutional BMPs, implementation of LID strategies, which include on-site infiltration, that would minimize off-site flows as well as the potential for erosion and off-site siltation" to "Drainage patterns would change through implementation of these non-structural institutional BMPs. However, implementation of LID strategies, which include on-site infiltration, -would minimize off-site flows as well as the potential for erosion and LA County Flood Control District 11-74 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments off-site siltation." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment CC: Page 3.8-39 of the PEIR has been updated to reflect this change "The structural BMPs would also provide improvements to water quality of receiving waters" to "The structural BMPs would also provide protections to water quality of receiving waters." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11 -DD: Page 3.8-39 of the PEIR has been updated to change "BMPs but would be designed to improve water quality and reduce stormwater flow volumes" to `BMPs but would be designed to improve runoff water quality and reduce stormwater flow volumes." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11 -EE: Page 3.9-1of the PEIR has been updated to change "The majority of the County is highly urbanized and consists of several cities, communities and unincorporated areas" to "The majority of the County is highly urbanized with some adjacent rural areas and consists of several cities, communities and unincorporated areas." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11 -FF: Page 3.9-1of the PEIR has been updated to change "The EWMP agencies have no jurisdiction over the land that is owned by the State of California (i.e., California Department of Fish and Wildlife, the State Lands Commission, and the California Department of Transportation) or the U.S. Government' to, "The EWMP agencies have no jurisdiction over the land that is owned by the State of California (i.e., California Department of Parks and Recreation, California Department of Fish and Wildlife, the State Lands Commission, and the California Department of Transportation) or the U.S. Government (i.e., National Parks Service)." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11 -GG: The use of the phrase "predominately located in urbanized" is appropriate. No changes are needed. Response to Comment 11 -HH: The "Potential (Regional and Centralized) BMPs" symbolized by green circles are located in the key at the bottom right corner of Figure 3.9-6 of the PEIR. No revision is necessary. a County Flood Control District 11-75 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Comment 11 -II: The numerous cities encompassed by the EWMP area all have their own respective agricultural designations. As implementation of the individual BMP projects proceeds, any agricultural designations within the project area will be identified and evaluated on a project -by -project basis during subsequent CEQA environmental processes. No revision is required on page 3.9-26 of the PEIR. Response to Comment 11 -JJ: LID standards are required to be in place within the jurisdictions of Permittees that have chosen EWMPs as their form of compliance with the MS4 Permit. Page 3.9-28 of the PEIR has been updated to reflect this change. Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11 -KK: Page 3.9-36 of the PEIR, has been updated to change "Malibu Watershed" to "Malibu Creek Watershed." Additionally, "Creek" has been added to all other appropriate instances. Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11 -LL: The use of the phrase "urban areas" is appropriate. No revision is necessary. Response to Comment 11 -MM: The PEIR identifies LID ordinances as non-structural BMPs that will assist in achieving permit compliance. The statements on page 3.9-38 and 3.14-10 of the PEIR are sufficient and no changes are needed. Response to Comment 11 -NN: The regulatory summary in Section 3.2, Air Quality of the PEIR is sufficient and no changes are needed. Response to Comment 11-00: The PEIR concludes that under worse -case scenarios, noise impacts could be significant and unavoidable. This does not mean that all projects will result in significant noise impacts. No revision is necessary on page 3.10-1 of the PEIR. Response to Comment 11 -PP: As noted in Chapter 1 of the PEIR, each individual project will undergo subsequent CEQA determination by the lead implementing agency prior to approval. No revision is necessary. LA County Flood Control District 11-76 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Comment 11-QQ: The sentence is sufficient and no revision is necessary. Response to Comment 11 -RR: The use of the word "urbanized" is appropriate. No changes are needed on Page 3.9-38 of the PEIR. Response to Comment 11 -SS: The sentence is sufficient and no revision is necessary. Response to Comment 11 -TT: The sentence is sufficient and no revision is necessary. Response to Comment 11-UU: Figure 3.12-1 of the PEIR is meant to provide an estimated location for schools. No changes are needed. Response to Comment 11-W: The commenter's statement that there is an additional water retailer for a private neighborhood in Malibu has been noted for the record. However, no information was provided for this retailer, such as the `additional small district's' name, therefore, no information was added to page 3.14-1. Response to Comment 11 -WW: The commenter states that "creek" should be added when referring to Malibu Creek Watershed, such as in the following sentence, "In areas with natural unimproved streams, such as in the Santa Clara River watershed and Malibu Creek watershed where surface water diversions may be more common, stormwater flows are conveyed downstream quickly." Page 3.14-16 of the PEIR has been updated to add "Creek" in between "Malibu" and "watershed." Additionally, "Creek" has been added to all other appropriate instances. Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11 -XX: Although the Santa Monica Bay Coastal Watershed has some natural unimproved streams, the Santa Clara River and Malibu Creek watersheds were used as examples in the sentence mentioned by the commenter since they contain greater numbers of natural unimproved streams. Therefore, the sentence is considered sufficient and no revision was made. a County Flood Control District 11-77 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Comment 11 -YY: Page 3.14-18 of the PEIR has been updated to change "it is feasible to recycle or reuse at least 50 percent or construction" to "it is feasible to recycle or reuse at least 50 percent of construction." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11 -ZZ: Table 4.1 on page 4-4 of the PEIR has been updated to change "early to mid -2014" to "early to mid -2015." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11 -AAA: Table 4.1 on page 4-4 of the PEIR has been updated to change "early to mid -2014" to "early to mid -2015." Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 11 -BBB: Page 6-5 of the PEIR has been updated to change "reduce pollutants from dry- and wet -weather urban runoff' to "reduce pollutants from dry- and wet -weather runoff." Chapter 12, Clarifications and Modifcations, outlines the revisions to the Draft PEIR. Response to Comment CCC: The commenter copied text from the PEIR but suggested no revision. The copied text from the PEIR has been noted for the record. Response to Comment DDD: Table 6-2 on page 6-13 of the PEIR has been updated to change "pollutants from dry- and wet - weather urban runoff in a cost-effective manner" to "pollutants from dry- and wet -weather runoff in a cost-effective manner." Chapter 12, Clarifications and Modifcations, outlines the revisions to the Draft PEIR. LA County Flood Control District 11-78 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report EDMUND G. BROWN JR. GOVERNOR March 9, 2015 STATE OF CALIFORNIA GOVERNOR'S OFFICE of PLANNING AND RESEARCH STATE CLEARINGHOUSE AND PLANNING UNIT Gregg BeGell Los Angeles County Flood Control District 900 South Fremont Avenue, 11 th Floor Alhambra, CA 91803 Subject: Enhanced Watershed Management Programs (EWMP) Program EIR SCH#: 2014081106 Dear Gregg BeGell, Comment Letter 12 C A * w a ��OFCAUr"' KEN ALEx DIRECTOR The State Clearinghouse submitted t11e above named Draft EIR to selected state agencies for review. The review period closed on March 6, 2015, and no state agencies submitted cornnents by that date. This letter acknowledges that you have complied with the State Clearinghouse review requirements for draft environmental documents, pursuant to the California Environmental Quality Act. Please call the State Clearinghouse at (916) 445-0613 if you have any questions regarding the environmental review process. If you have a question about the above-named project, please refer to the ten -digit State Clearinghouse number when contacting this office. Sincerely, Scot rgan/,� Director, State Clearinghouse 140010th Street P.O. Box 3044 Sacramento, California 95812-3044 (916) 445-0613 FAX (916) 323-3018 www.opr.ca.gov 1A Li � b ��M•- u.I� i i' e-! t.l 'tea .. n rpt 140010th Street P.O. Box 3044 Sacramento, California 95812-3044 (916) 445-0613 FAX (916) 323-3018 www.opr.ca.gov 1A Document Details Report Comment Letter 12 State Clearinghouse Data Base SCH# 2014081106 Project Title Enhanced Watershed Management Programs (EWMP) Program EIR Lead Agency Los Angeles County Flood Control District Type EIR Draft EIR Description The development of the EWMP will involve the evaluation and selection of multiple watershed control measures or best management practices (BMP) types including non-structural and distributed, centralized and regional structural BMPs. These BMPs will be implemented to meet compliance goals and strategies under the 2014 MS4 Permit. Structural BMPs involve the construction of a physical control measure to alter the hydrology and/or water quality of incoming stormwater or non-stormwater. The three major functions for structural BM Ps are infiltration, water quality treatment, and storage. These are three categories of structural BMPs, defined by the runoff area treated by the BMP and the required retention volume in accordance with the Permit. Lead Agency Contact Name Gregg BeGell Agency Los Angeles County Flood Control District Phone 626 300 3298 Fax email Address 900 South Fremont Avenue, 11th Floor City Alhambra State CA Zip 91803 Project Location County Los Angeles City Los Angeles, City of Region Lat/ Long Cross Streets Throughout Los Angeles County Parcel No. Various Township Range Section Base Proximity to: Highways Various Airports LAX, Burbank Railways Various Waterways Various Schools Various Land Use Various land uses throughout the County Project Issues Agricultural Land; Air Quality; Archaeologic -Historic; Biological Resources; Drainage/Absorption; Flood Plain/Flooding, Geologic/Seismic; Minerals; Noise; Population/Housing Balance; Public Services; Recreation/Parks; Soil Erosion/Compaction/Grading; Toxic/Hazardous; TraffdCirculation; Water Quality; Vegetation; Water Supply, Wetland/Riparian; Wildlife; Cumulative Effects; Other Issues Reviewing Resources Agency; Department of Fish and Wildlife, Region 5; Department of Parks and Recreation; Agencies Department of Water Resources; Office of Emergency Services, California; Caltrans, Division of Aeronautics; California Highway Patrol; Caltrans, District 7; Air Resources Board; State Water Resources Control Board, Division of Drinking Water; State Water Resources Control Board, Divison of Financial Assistance, State Water Resources Control Board, Division of Water Rights; Regional Water Quality Control Board, Region 4; Regional Water Quality Control Be., Region 6 (.Victorville); Native American Heritage Commission Date Received 01/21/2015 StartofReview 01/21/2015 EndofReview 03/0612015 Note: Blanks in data fields result from insufficient information provided by lead agency. to Comments Response to Comment Letter 12 (State Clearinghouse— March 17, 2015) Response to Comment 12-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The commenter's statement that no state agency comments were received and that the Draft PEIR complied with CEQA review requirements has been noted for the record. a County Flood Control District 11-81 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 13 Paige Anderson To: Laura Rocha Subject: RE: Westwood Neighborhood Greenway - EWMP From: Marilyn Tusher [mailto:mltusher6d)att.netl Sent: Sunday, March 01, 2015 4:28 PM To: Gregg Begell Subject: Westwood Neighborhood Greenway - EWMP Dear Mr. BeGell, Please see my attached letter in support of this project. Thank you, Marilyn Tusher, President Westwood Gardens Civic Assn.,lnc. CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 13 Westwood Gardens Civic Association Since 1948 P.O. Box 642001 Los Angeles, Ca. 90064 westwoodgardens@gmail.com Gregg BeGell, PE March 1, 2015 County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont, 5<h Floor Alhambra, California 91803 Rbegell @dpw.lacounty.eov RE: Support for Westwood Neighborhood Greenway Dear Mr. BeGell: I am writing to you today as the President of Westwood Gardens Civic Association, which is comprised of 620 single family homes situated within the boundaries of Ayres Avenue on the north, National Blvd. on the south, Midvale Avenue on the west and Overland and Dunleer Place on the east. Our HOA has been in existence since 1948, over 66 years, and is one of the longest standing homeowner's association on the west side of Los Angeles. We take great pride in our community and work very hard to preserve and protect it for the peaceful enjoyment of all our homeowners. On behalf of our Board of Directors, and as a member of the WNG Steering Committee, I am writing in support of the WNG as part of the Enhanced Watershed Management Plan (EWMP) for the Ballona Creek Watershed. This WNG Project will be a multi -benefit project providing not only urban runoff treatment, but also native habitat and public access via transit, bicycle and pedestrian paths. This will be a unique opportunity for our greater community as it will be adjacent to the busiest station on the Expo Light Rail line, part of the growing Metro transit network. I_1 Our Homeowner's association is the most immediately affected and impacted by this project between Overland and Westwood, as it backs up directly adjacent to our residents' backyards. With your support, B along with many others which the Greenway project has already received, this Westwood Neighborhood Greenway may actually come to fruition along with the opening of the Expo II Light Rail Line, for the benefit of everyone. Sincerely, Marilyn Tusher Marilyn Tusher, President Westwood Gardens Civic Association, Inc. Comments Response to Comment Letter 13 (Westwood Gardens Civic Association — March 1, 2015) Response to Comment 13-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The commenter's support for the PEIR is noted. Response to Comment 13-B: The commenter's statement that their homeowner's association is the most immediately affected and impacted by the Westwood Neighborhood Greenway project between Overland and Westwood is noted for the record. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. More site investigations are needed to fully vet the proposed Westwood Neighborhood Greenway project and define the project scope needed to satisfy the EWMP's requirements. The City of Los Angeles is the primary agency who will benefit from a water quality project at the Westwood Neighborhood Greenway project. 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I.. i,1• lu Comments Response to Comment Letter 14 (Arcadia Historical Society — March 3, 2015) Response to Comment 14-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations by implementing agencies are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. IA County Flood Control District 11-86 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 15 Paige Anderson To: Laura Rocha Subject: RE: Baldwin Lake From: canon ir3035(a)kelloaaarden.coml mai Ito: canon ir3035(a)kell000arden. coml Sent: Wednesday, March 04, 2015 3:17 PM To: Connie Wiersma Subject: Scanned Document (DO NOT REPLY) CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 15 Kellogg Garden Products 350 W. Sepulveda Blvd. Carson. CA 90745 310.830.2200 March 4, 2015 Fax 310.835.6174 www.KelloggGarden.com Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division 11 900 South Fremont, SO Floor Alhambra, CA 91803 Dear Gregg, The restoration of Baldwin Lake will both enhance watershed function and serve the public with exceptional educational, ecological, and scenic benefits. Baldwin Lake is a beloved public resource visited by over 330,000 annual visitors; its inclusion as a high priority A project within the Rio Hondo/San Gabriel River Enhanced Watershed Management Plan offers unparalleled public benefit Please provide every consideration to including Baldwin Lake restoration in the plan. Sincerely, Hap Kellogg President/CEO Kellogg Garden fe(ping Peopfe Create Beau tiACGandscapesAnd Gardens.® to Comments Response to Comment Letter 15 (Kellogg Garden Products — March 4, 2015) Response to Comment 15-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. a County Flood Control District 11-89 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 16 Paige Anderson To: Laura Rocha Subject: RE: Comments on LACFCD EWMP Draft PER From: Liz Crosson [mailto:liz(&lawaterkeeper.org Sent: Monday, March 09, 2015 5:38 PM To: Gregg Begell Cc: Hayat, Becky; Peter Shellenbarger;'Steve Fleischli (sfleischli(a),nrdc.org ; Tatiana Gaur Subject: Comments on LACFCD EWMP Draft PEIR Hi Greg, Please find comments on the County of Los Angeles Department of Public Works' Draft Program Environmental Impact Report for 12 EWMPs under the 2012 LA MS4 Permit attached, along with two exhibits. Please let me know if you have any questions. Best, Liz Crosson Executive Director Los Angeles Waterkeeper (310) 394-6162 x100 Go Dirty for the Drought. Take the Dirty Car Pledge<http://lawaterkeeper.org/dirtyforthedrought/> now! [cid:094271 DA-5738-4B53-9472-00285AC2313F] CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 16 NRDC LOS ANGELES Heal the Bay March 9, 2015 Via electronic mail Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont Avenue, 5"' Floor Alhambra, CA 91803 Email: gbegell@dpw.lacounty.gov Re: Comments on Los Angeles County Draft Program Environmental Impact Report for Enhanced Watershed Management Programs under the Los Angeles County Municipal Separate Storm Sewer System Permit, NPDES Permit No. CAS004001, Order No. R4-2012-0175 Dear Mr. BeGell: On behalf of the Natural Resources Defense Council ("NRDC"), Los Angeles Waterkeeper ("Waterkeeper"), and Heal the Bay (collectively, "Environmental Groups"), we are writing with regard to the Draft Program Environmental Impact Report ("PEIR") for the 12 Enhanced Watershed Management Programs ("EWMP") under the 2012 Los Angeles County Municipal Separate Storm Sewer System Permit ("2012 MS4 Permit" or "2012 Permit").' We appreciate the opportunity to submit these comments to the Los Angeles County Department of Public Work's Flood Control District. ("LACFCD"). L Introduction As an initial matter, Environmental Groups' comments on the EWMP Draft PEIR should T not be construed as approval or acceptance of the 2012 Permit terms. We continue to maintain that several provisions of the Permit fail to meet the requirements of the federal IA Clean Water Act and California Porter Cologne Act, and are otherwise inconsistent with ' The Enhanced Watershed Management Programs addressed in the Program Environmental Impact Report ("PEIR") encompass several watersheds of Los Angeles County including the following: Ballona Creek, Beach Cities, Dominguez Channel, Malibu Creek, Marina del Rey, North Santa Monica Bay Coastal Watersheds, Palos Verdes Peninsula, Rio Hondo/San Gabriel River Water Quality Group, Santa Monica Bay, Upper Los Angeles River, Upper San Gabriel River, and Upper Santa Clara River. Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 12 both federal and state law. Environmental Groups filed a petition with the State Water Resources Control Board ("State Board"), which demonstrates the ways in which the I A cont 2012 Permit violates these legal requirements. The State Board has yet to make a 11 determination on our petition. Under the 2012 Permit, permittees electing to participate in an EWMP are required to submit a draft EWMP plan by June 2015. (2012 Permit, at VI.C.4.c.iv.) The EWMP Work Plans submitted by permittees in June 2014 presented an opportunity for permittees to demonstrate their commitment to developing EWMPs to meet required Receiving Water Limitations ("RWLs") and Total Maximum Daily Load ("TMDL") provisions. Environmental Groups reviewed the EWMP Work Plans and submitted comments to the Regional Board .3 As we expressed in our comments, many permittees have made significant progress towards developing their draft EWMPs. However, the Work Plans are in many instances unclear as to what analysis or programs will ultimately be incorporated into final EWMPs to be submitted to the Regional Board in June 2015. In fact, some of the Work Plans clearly indicate that the permittees' management programs, as currently envisioned, will not ensure that discharges from the permittees' MS4 systems do not cause or contribute to exceedances of RWLs, including applicable water quality standards, or TMDL limitations in the 2012 Permit, and otherwise fail to meet Permit requirements. EWMP Work Plan deficiencies do not bode well for the June 2015 Draft EWMPs, and this CEQA process is an opportunity for LACFCD and EWMP permittees to address our concerns with program development thus far. The Regional Board -approved delay in progress toward compliance with water quality based effluent limits ("WQBELs") and RWLs for EWMP permittees cannot pass lightly—the draft plans submitted by EWMP groups in June 2015 must fully and clearly demonstrate a path to compliance and cleaner waters for the region. To this extent, any identified deficiencies with the EWMP Work Plans must be addressed prior to submission of the draft EWMPs in 2015, and should also be addressed in this PEIR to fully assess the potential environmental impacts of the program. ' For a full explanation of how the permit violates the law, see Memorandum of Points and Authorities in Support of Petition of NRDC, Los Angeles Waterkeeper and Heal the Bay for Review of Action by the California Regional Water Quality Control Board, Los Angeles Region, in Adopting the Los Angeles County Municipal Separate Stormwater National Pollutant Discharge Elimination System (NPDES) Permit; Order No. R4-2012-0175; NPDES Permit No. CAS004001 (Dec, 10, 2012) ("Environmental Groups' Petition"), SWRCB/OCC File No. A -2236(m), attached as Exhibit A- ' See Environmental Groups' Comments on Enhanced Watershed Management Work Plans and Monitoring Plans Pursuant to Requirements under the Los Angeles County Municipal Separate Storm Sewer System Permit, NPDES Permit No. CAS004001, Order No. R4-2012-0175, submitted to the Regional Board September 16, 2014, attached as Exhibit B. L Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 13 II. General Comments Environmental Groups have categorized comments into general comments about the approach in the PEIR and some specific comments about the PEIR analysis. Because the approach in the Draft PEIR will likely follow to the management programs due in June 2015, LACFCD should take this important opportunity to revise the Draft PEIR to address the concerns articulated below. A. Inadequate Information Related to Ensuring Compliance with Required Water Ouality Limits Undermines the Success of the PEIR In areas of the permittees' jurisdictions where retention of the 85' percentile, 24-hour storm event is not technically feasible, EWMPs must include other watershed control measures to "ensure that MS4 discharges achieve compliance with all interim and final WQBELs set forth in Part VLE.... and [] ensure that MS4 discharges do not cause or contribute to exceedances of receiving water limitations in Part V.A." (Id. at VI.C.l.g.v.) In several instances, the Draft PEIR acknowledges this legal obligation and claims that planning efforts are aimed towards that goal. However, whether the environmental impact of the program will indeed include compliance remains uncertain. In fact, based on Environmental Groups' review of several of the EWMP Work Plans related to the Draft PEIR and the very general information included in the Draft PEIR, the actual environmental impact of the EWMPs is difficult to determine. Deficiencies identified in the EWMP Work Plans potentially undermine statements of intended compliance in the PEIR. Thus, Environmental Groups urge LACFCD to clarify several issues related to assuring ultimate compliance with water quality limits. First, several EWMP Work Plans related to the Draft PEIR insufficiently prioritize pollutants as required in the 2012 MS4 Permit. Permittees are required to prioritize pollutants into three categories: (1) TMDL pollutants (highest priority), (2) 303(d) listed but no applicable TMDL (high priority), and (3) insufficient data to determine impairment, but exceeds RWLs (medium priority). Category (1) must also include non- E TMDL pollutants that have similar fate and transport mechanisms as TMDL pollutants. (2012 Permit, at VI.C.2.a.i.) Prioritization is essential to ensuring compliance with required limits. Some of the deficiencies in prioritization include failing to include priority pollutants,' and failing to justify exclusion of some pollutants.' Additionally, permittees have set incorrect timelines for TMDL implementation and compliance in ° See North Santa Monica Bay Coastal Watersheds EWMP Work Plan, at 18; see also Upper Santa Clara River EWMP Work Plan, at 3-4; see also Upper Los Angeles River EWMP Work Plan, at Appendix 2.A. (lacks explanation of why Total Aluminum is not included as a priority despite data demonstrating exceedances). ' See North Santa Monica Bay Coastal Watersheds EWMP Work Plan, at 18. Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 14 some cases.6 Without adequately characterizing each watershed and prioritizing the right pollutants, it is impossible to fully assess the environmental impacts of the proposed programs under CEQA. Environmental Groups understand that the EWMPs are still in E cont development, but this PEIR must include a process and approach that complies with permit terms to fully evaluate the impacts of proposed actions. B. Green Infrastructure Should Be Prioritized Wherever Feasible Environmental Groups commend the LACFCD for proposing multi -benefit stormwater projects that emphasize flood risk mitigation, water conservation and water supply. In light of the fact that the LACFCD has a vested interest in increasing opportunities for stormwater capture and groundwater recharge as a means of assisting local water supply and augmentation, we urge the LACFCD to work with Permittees in all 12 EWMP watersheds to prioritize green infrastructure or low -impact development (LID) practices wherever feasible, and provided that such projects do not produce significant adverse impacts. Environmental Groups have long supported the use of green infrastructure techniques to control urban runoff. Green infrastructure provides multiple benefits to surrounding communities at a higher benefit -cost ratio when compared to grey infrastructure.' A 2007 U.S. Environmental Protection Agency (EPA) study found that "in the vast majority of cases ... implementing well-chosen LID practices saves money for developers, property owners, and communities while protecting and restoring water quality."' With only "a few exceptions," the EPA study found that "[t]otal capital cost savings ranged from 15 to 80 percent when LID methods were used" instead of conventional stormwater management techniques.9 The EPA study is not alone in reaching this conclusion. A report by ECONorthwest concluded that LID methods not only "cost less to install, have lower operations and maintenance (O&M) costs, and provide more cost-effective stormwater management and water -quality than conventional stormwater controls" but they also provide "ecosystem services and associated economic benefits that conventional 'See Balloon Creek EWMP Work Plan, at 1-10 (failure to include interim milestones); see also Rio Hondo/San Gabriel River EWMP Work Plan, Table 1-2, at 2 (failure to include interim and final compliance deadlines); see also Upper Los Angeles River EWMP Work Plan, at 2-7, 2-9 (compliance deadlines exceed allowable deadlines under the Inland Surface Water Plan). U.S. Environmental Protection Agency, Case Studies Analyzing the Economic Benefits ofLow Impact Development and Green Infrastructure Programs (August 2013), available at http://water.epa.gov/polwaste/green/upload/lid-gi-programs report 8-6-13 combined.pdf. a U.S. Environmental Protection Agency, Reducing Stormwater Costs through Low Impact Development (LID) Strategies and Practices, December 2007, at iii. available at http://water.epa.Qov/polwaste/green/upload/2008 01 02 NPS lid costs07uments reducingstormwatercost s-2.pdf. 9 Id. at iv. G Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 15 stormwater controls do not. 10 Moreover, a survey released by the American Society of Landscape Architects in 2011 found that green infrastructure reduced or did not influencel G cont project costs 75 percent of the time.i" Given the current severe drought conditions, protecting and augmenting local water supplies is essential for long-term sustainability. A report by the NRDC found that implementing LID practices at new and redeveloped residential and commercial properties in urbanized areas of Southern California and limited portions of San Francisco Bay has the potential to increase local water supplies by up to 405,000 acre- feet of water per year by 2030.12 This volume of water accounts for roughly two-thirds of all water used by the City of Los Angeles each year. 11 Historically, Southern California has imported approximately 50 percent of its water supply from distant, energy -intensive sources such as the Sacramento -San Joaquin Delta and the Colorado River. 14 Green infrastructure thus has the potential to greatly reduce Los Angeles' dependence on imported water. Last but not least, Environmental Groups strongly advocate for the implementation of structural BMPs (distributed, centralized, and regional) that capture stormwater and store it for reuse — so long as they do not produce significant adverse impacts — as such practices provide both water quality and water supply benefits. III. Specific Concerns in the PEIR Section 3.5 — Geolo¢ic and Mineral Resources Impact 3.5-2: "The proposed program could result in substantial soil erosion or the loss of top soil." The Draft PEIR states environmental impacts associated with substantial soil erosion or loss of top soil are less than significant. Environmental Groups disagree. EWMP projects are encouraged to retain the 85' percentile 24-hour storm event; however, it is unclear that all EWMP BMPs will retain this volume and even if they did, in some instances some volume of runoff will remain untreated. Thus, at least some percentage of stormwater generated, which will vary depending on individual EWMPs, will be treated and discharged into the MS4. Although discharge points from centralized and 10 ECONorthwest, The Economics ofLow Impact Development: A Literature Review, November 2007, at 4, available at http://www.econw.com/media/ap files/ECONorthwest-Economics-of-LID-Literature- Review 2007.pdf, " Stormwater Case Studies, American Society of Landscape Architects, available at http://www.asla.org/storinwatercasestudies.aspx. 12 Natural Resources Defense Council, A Clear Blue Future: How Greening California Cities Can Address Water Resources and Climate Challenges in the 21" Century, August 2009, at 4, available at http://www.nrdc.org/water/lid/files/lid hi.pdf ("A Clear Blue Future"). 13 Id. 14 Id., at 18-19. 171 Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 16 distributed BMPs would be designed to minimize scour potential, soil erosion and loss of top soil are still likely to occur during precipitation events. Los Angeles County J cont contains over 110 soft bottom reaches — increased scour and loss of top soil could severely affect beneficial uses of these reaches. In addition, the 2012 Permit outlines specific hydromodification requirements — it is unclear if the Draft PEIR is consistent with hydromodification provisions in the 2012 Permit. The Final PEIR needs to K address all potential soil erosion and loss of top soil scenarios and needs to reference the hydromodification provisions outlined on pg. 105 of the 2012 Permit. Impact 3.5-5: "The proposed program could have soils incapable of adequately supporting the use of a septic tank or alternative wastewater treatment systems where sewers are not available for the disposal of wastewater." Environmental Groups are concerned with wastewater created in areas incapable of L adequate disposal options (sewer system or septic tanks). In the event that implemented BMPs generate wastewater and cannot properly dispose of wastes via sewer system or septic tanks, the Final PEIR needs to outline how waste will be managed (Le. tank, truck, etc.). In addition, the Final PEIR should reference the State Board's Water Quality Control Policy for Siting, Design, Operation, and Maintenance of Onsite Wastewater Treatment Systems and General Waste Discharge Requirements for Small M Domestic Wastewater Treatment Systems (Order WQ 2014-0153-DWQ) when soils are capable of supporting the use of septic tanks. Cumulative Impact/GEO-2: "Prior to installing BMPs designed to recharge local groundwater supplies, the Implementation Agency shall notify local groundwater manager including the Upper Los Angeles River Area Water Master, the Water Replenishment District of Southern California, or the San Gabriel Water Master as well as local water producers such as local municipalities and water companies. The Implementing Agency shall coordinate BMP siting efforts with groundwater managers and producers to mitigate high groundwater levels while increasing local water supplies." N Environmental Groups agree Implementation Agencies should always notify local groundwater managers and producers before stormwater BMPs are implemented, however, the Draft PEIR fails to acknowledge or reference Salt and Nutrient Management Plans being developed and implemented for Los Angeles County groundwater basins. These Plans outline groundwater inputs and exports as well as identify basins' assimilative capacities. We believe the Final PEIR needs to discuss EWMP coordination with Salt and Nutrient Management Plans. In the light of climate change, protecting while simultaneously contributing to Los Angeles' local water supply is essential for long-term water sustainability. Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 17 Section 3.7 — Hazards and Hazardous Materials Impact 3.7-2: "The proposed program could create a significant hazard to the public or the environment through the accumulation of potentially hazardous materials into BMPs." HAZ-1: "Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the individual BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant O that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater." Environmental Groups support Implementing Agencies' development of BMP Maintenance Plans outlining BMP maintenancepractices as this is necessary to sustain stormwater BMP efficacies. Yet we want to highlight the all -too -common shortcoming Implementing Agencies encounter in operations and maintenance of storm water BMPs —failure to devote adequate resources. Bolstering of agencies' resources, such as additional staffing, training, and funding mechanisms, is necessary and commonly overlooked in the implementation of BMP maintenance plans. Without acknowledging Implementation Agency resources while implementing BMP Maintenance Plants, it is unlikely EWMPs' discharges will comply with water quality standards in the long-term. The Final PEIR needs to expand HAZ-1 to discuss additional agencies' resources needed to implement BMP Maintenance Plans. Section 3.8: Hydrology and Water Quality Impact 3.8-1: "The proposed project would result in higher groundwater levels and could potentially affect groundwater quality" See Cumulative Impact/GEO-2 response above. Impact 3.8-2: "The proposed project could substantially alter the existing drainage P pattern of a site or area through the alteration of the course of a stream or river, or by other means, in a manner that would result in substantial erosion or siltation on- or off- site." See Impact 3.5-2 response above. Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 18 Iv, Conclusion Environmental Groups appreciate this opportunity to comment on the Draft PEIR submitted by the LACFCD for the 12 EWMP groups. Please feel free to contact us with any questions or concerns you may have. Sincerely, eo� Liz Crosson Executive Director Los Angeles Waterkeeper Becky Hayat Staff Attorney Natural Resources Defense Council 1),,k, Ju PeterShellenbarger Water Resources Manager Heal the Bay 9 M 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STEVE FLEISCHLI, Bar No. 175174 NOAH J. GARRISON, Bar No. 252154 NATURAL RESOURCES DEFENSE COUNCIL, INC. 1314 Second Street Santa Monica, CA 90401 (310) 434-2300 Attorneys for NATURAL RESOURCES DEFENSE COUNCIL, INC. AND HEAL THE BAY LIZ CROSSON, Bar No. 262178 TATIANA GAUR, Bar No. 246227 LOS ANGELES WATERKEEPER 120 Broadway, Suite 105 Santa Monica, CA 90401 (310) 394-6162 Attorneys for LOS ANGELES WATERKEEPER AND HEAL THE BAY DANIEL COOPER, Bar No. 153576 LAWYERS FOR CLEAN WATER, INC. 1004A O'Reilly Avenue San Francisco, CA 94129 (415)440-6520 Attorney for LOS ANGELES WATERKEEPER STATE OF CALIFORNIA STATE WATER RESOURCES CONTROL BOARD In the Matter of the Petition of NRDC, Los Angeles Waterkeeper, and Heal the Bay, for Review of Action by the California Regional Water Quality Control Board, Los Angeles Region, in Adopting the Los Angeles County Municipal Separate Stormwater National Pollutant Discharge Elimination System (NPDES) Permit; Order No. R4-2012-0175; NPDES Permit No. CAS004001 Comment Letter116 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PETITION FOR REVIEW OF LOS ANGELES REGIONAL WATER QUALITY CONTROL BOARD ACTION OF ADOPTING ORDER NO. R4-2012-0175 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letterl16 I, INTRODUCTION This petition seeks review of a pollution discharge permit that is both unlawful and inadequate to protect the region's waters or the public health. The Los Angeles Regional Water Quality Control Board's ("Regional Board" or `Board") permit for Los Angeles County municipal separate storm sewer systems (4'MS4s")1 is the unfortunate result of six years of delay in renewing the previous permit, and of largely ignoring the crucial need to address the region's ongoing legacy of water pollution. The 2012 Permit, and the process the Regional Board followed in adopting it, were both deeply flawed, and impermissibly weaken or "backslide" from the requirements of the previous, 2001 MS4 permit z The critical—but by no means only—flaw of the 2012 Permit is that it often abandons requirements to comply with both narrative and numeric water quality standards in receiving waters as a means of protecting water quality. For the reasons discussed below, Petitioners respectfully request that the State Water Resources Control Board ("State Board") overturn these unlawful provisions of the 2012 Permit, or remand the matter to the Regional Board with specific direction to remedy the provisions of the 2012 Permit that violate state and federal I law. The 2012 Permit is unlawful due to its inclusion of safe harbors from provisions, required by the 2001 Permit, that require that discharges comply with Water Quality Standards. The safe harbors—provisions that excuse compliance with Water Quality Standards in the Permit's Receiving Water Limitations section, are illegal for four principal reasons: 1) the safe harbors violate federal anti -backsliding requirements; 2) the safe harbors violate state and federal antidegradation requirements; 3) the safe harbors violate requirements for incorporation of TMD 1 Regional Board, Waste Discharge Requirements for Municipal Separate Storm Sewer System (MS4) Discharges Within the Coastal Watersheds of Los Angeles County, Except Those Discharges Originating From the City of Long Beach, Order No. R4-2012-0175, NPDES Permit No CAS004001 (Nov. 8, 2012) ("2012 Permit" or "Permit"). 2 Regional Board, Waste Discharge Requirements for Municipal Separate Storm Sewer and Urban Runoff Discharges Within the County of Los Angeles, and the Incorporated Cities Therein, Except the City of Long Beach, Order No. 01-182, NPDES Permit No. CAS004001 (Dec. 13, 2001) ("2001 Permit"). Memomndum of P's and A's Page 1 9 0 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letterl16 into National Pollutant Discharge Elimination System permits; and, 4) the Regional Board failed make sufficient findings or provide evidence in the record to support the inclusion of the safe harbors in the 2012 Permit. These violations of law present compelling reasons for the State Board to exercise its statutory duty to correct the unlawful actions of the Regional Board. These corrections are seriously needed to protect the waters of Los Angeles County and the public health. A. Factual Background 1. Monitoring Demonstrates That the Los Angeles County MS4s Discharge Pollution to Receiving Waters The stormwater systems regulated by the 2012 Permit discharge bacteria, metals, and othe pollutants at unsafe levels to rivers, lakes, and beaches in Los Angeles County. This pollution causes increased rates of human illness, harm to the environment, and an economic loss of tens to hundreds of millions of dollars every year from public health impacts alone. As the Regional Board itself acknowledges: Discharges of storm water and non -storm water from the ... Los Angeles County [MS4s] convey pollutants to surface waters throughout the Los Angeles Region.... the primary pollutants of concern in these discharges ... are indicator bacteria, total aluminum, copper, lead, zinc, diazanon, and cyanide. Aquatic toxicity, particularly during wet weather, is also a concern... Pollutants in storm water and non -storm water have damaging effects on both human health and aquatic ecosystems. Water quality assessments conducted by the Regional Water Board have identified impairment of beneficial uses of water bodies in the Los Angeles Region caused or contributed to by pollutant loading from municipal storm water and non -storm water discharges. (2012 Permit, at p. 13, Finding A.)3'4 3 This comports with the findings of the U.S. Environmental Protection Agency ("EPA"), which considers urban runoff to be "one of the most significant reasons that water quality standards are not being met nationwide." (U.S. General Accounting Office (June 2001) Water Quality: Better Data and Evaluation of Urban Runoff Programs Needed to Assess Effectiveness, Report No. GAO -01-679, at 37.) Memomndum of P's and A's Page 2 Comment Lettei 16 1 The pollutants that impair the region's waters come in large part from the MS4s subject to 2 the permit at issue. Monitoring data from mass emission stations in area streams and rivers 3 demonstrate that the MS4s persistently contribute to violations of Water Quality Standards and 4 cleanup targets (total maximum daily loads or "TMDLs") in Los Angeles area water bodies. 5 Monitoring revealed 1,105 violations since 2003 of water quality limits for fecal bacteria, various 6 heavy metals, ammonia, pH, and cyanide, among other constituents, in Ballona Creek, Malibu 7 Creek, the Los Angeles River, Santa Clara River, Dominguez Channel, and Coyote Creek .5 8 Monitoring conducted by non-profit organizations confirms that MS4s in Los Angeles 9 County pollute in the region. Data collected by these organizations show: 10 . Malibu Creek routinely exceeded limits for nitrogen, ammonia, phosphate, E.coli, 11 and enterococcus bacteria during wet and dry weather.6 12 • Compton Creek commonly exceeded applicable pollution limits; the highest magnitude of exceedances occurred during storm events at storm drain outfalls. 13 . 13 of 22 sites sampled in the Los Angeles River watershed during 2005 received an 14 F grade for failing water quality standards for PH, temperature, dissolved solids, nutrients, dissolved oxygen, and turbidity.$ 15 • Dry weather discharges from 18 storm drains flowing into Ballona Creek, which is 16 impaired by fecal bacteria, had consistently high levels of bacteria.9 17 18 4 Unless otherwise noted, all references to documents in this brief are to documents that were 19 timely submitted to the Regional Board and are part of the record in this matter. We include documents originally submitted by Petitioners here for the convenience of the State Water 20 Resources Control Board ("State Board"). 21 5 Los Angeles County, Dept. of Public Works, Stormwater Monitoring Reports for 2003-2004 (Aug. 15, 2004), 2005-2006 (Aug. 22, 2006), 2006-2007 (Sept. 4, 2007), 2007-2008 (Aug. 20, 22 2008), 2008-2009 (Aug. 25, 2009), 2009-2010 (Aug. 12, 2010), 2010-2011 (Aug. 11, 2011), (selected data tables attached and full documents available at 23 http://dow.lacountv.2ov/wmd/NPDES/report directorv.cf n, last visited July 19, 2012). 24 6 See Exhibit A1: Heal the Bay, Water Quality in Malibu Creek Watershed and Surrounding Reference Sites; Exhibit A2: Heal the Bay, Malibu Watershed Exceedances, Raw Data (1998- 25 2010). 7 See Exhibit B 1: Heal the Bay, Monitoring Plan for Compton Creek; Exhibit B2: Heal the Bay, 26 Sediment Data Analysis — Compton Creek (2006-2011); Exhibit B3: Heal the Bay, Water Data 27 Analysis — Compton Creek (2006-2011). g Friends of the Los Angeles River (2005) The First State of the Los Angeles River Report, at 3. 28 9 See Exhibit C: Los Angeles Waterkeeper, Ballona Creek Data (2011-2012). Memomndum of P's and A's Page 3 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letterl16 Receiving water sampling conducted in Ballona Creek, together with dry weather storm drain sampling, as well as monitoring from the City of Malibu, demonstrate a link between polluted storm drain discharges and exceedances of water quality standards, and that the MS4 system is a significant source of this pollution to receiving waters. 10 Finally, California Ocean Plan standards and fecal bacteria TMDL limits established to protect the health of beachgoers have been exceeded on thousands of occasions. Monitoring identified 3,369 exceedances of beach bacteria TMDL limits at 65 Los Angeles County beach monitoring locations during the April — October dry weather season from 2006 through 2011, exposing the public to various well-documented health risks associated with recreating in polluted water. 11 2. Stormwater Pollution Threatens Public Health Polluted urban runoff increases bacteria levels and illness rates among swimmers. 12 Contact with waters contaminated by stormwater runoff can lead to fever, chills, ear infections and discharge, coughing and respiratory ailments, vomiting, diarrhea and other gastrointestinal illness, and skin rashes. 13 Scientists reviewing 22 epidemiological studies found that 19 of them showed that adverse health effects were significantly related to fecal indicator bacteria or bacterial pathogens. 14 One local analysis investigated health risks of people exposed to storm drain runoff 10 Id.; Exhibit D: Los Angeles Waterkeeper, Malibu 2011-2012 Storm Water Monitoring. 11 See, Exhibit F: Heal the Bay, Santa Monica Bay Bacteria TMDL Tally; see also Exhibit G: Los Angeles Waterkeeper, Area of Special Biological Significance [ASBS] Malibu Data Revised March 27, 2012; Exhibit H: Los Angeles Waterkeeper, Non-ASBS and Malibu Creek Data Revised March 27, 2012. 12 Curriero et al. (August 200 1) The Association Between Extreme Precipitation and Waterborne Disease Outbreaks in the United States, 1949-1994, American Journal of Public Health, 91:8 1194-1199. See also, Letter from Dr. Jennifer Jay to Mr. Sam Unger, Executive Officer and Members of the Board, Regional Board re: MS4 Permit for Los Angeles County, July 23, 2012. 13 See, e.g., Haile, et al. (1999) The Health Effects of Swimming in Ocean Water Contaminated by Storm Drain Runoff, Epidemiology 10(4): 355-63; Haile, R. W. et al (1996) An Epidemiological Study of Possible Adverse Health Effects of Swimming in Santa Monica Bay, Santa Monica Bay Restoration Project, 70 pp. 14 Pruss, A. (1998) Review of epidemiological studies on health effects from exposure to recreational waters, International Journal of Epidemiology 27:1-9. Memomndum of P's and A's Page 4 Comment Letter 16 1 while swimming in Santa Monica Bay and found that swimmers exposed directly in front of a 2 storm drain experienced increased health risks of approximately 50-100 percent compared with 3 people swimming more than 400 yards away from the drain. 15 4 The Regional Board itself has acknowledged that the harm to the public from exceeding 5 bacteria standards "is dramatic both in terms of health impacts to exposed beachgoers, and the 6 economic cost to the region associated with related illnesses." (2001 Permit (as amended by Order 7 R4-2009-0130), at p. 16, Finding E.32.) These health impacts come at tremendous cost—one 8 study demonstrated that swimming at polluted beaches in Los Angeles County caused between 9 427,800 and 993,000 excess cases of gastroenteritis per year, resulting in annual health costs of 10 between $14 and $35 million, or $120 and $278 million per year (depending on whether only 11 market costs or both market and non-market costs, such as willingness-to-pay not to get sick, were 12 considered). 16 13 3. Controlling stormwater pollution provides numerous economic benefits, while stormwater pollution creates many economic harms 14 15 Controlling pollution from MS4 systems has far-reaching economic and social benefits for 16 the region. According to a report to California's Resources Agency, "California has the largest 17 Ocean Economy in the United States, ranking number one overall for both employment and gross 18 state product. . . ." 17 One study estimated that local beach goers in California spend as much as 19 $9.5 billion annually and the non-market values associated with beach going in California may be 20 as high as $5.8 billion annually.'8 21 22 15 Haile, R. W. et al (1996) An Epidemiological Study of Possible Adverse Health Effects of Swimming in Santa Monica Bay, Santa Monica Bay Restoration Project, at 54; see also, Haile, et 23 al. (1999) The Health Effects of Swimming in Ocean Water Contaminated by Storm Drain Runoff, 24 Epidemiology 10(4): 355-63. Given, S., et al. (2006) Regional Public Health Cost Estimates of Contaminated Coastal Waters: 25 A Case Study of Gastroenteritis at Southern California Beaches, Environmental Science & Technology 40(16): 4851-4858, at 4856. 26 17 Kildow, J. and Colgan, C.S. (2005) National Ocean Economics Program, California's Ocean 27 Economy: A Report to the Resources Agency, State of California, at 1. 18 Pendleton, L. (July 2004) Harvesting Ocean Observing Technologies to Improve Beach 28 Management: Estimating the Regional Economic Benefits oflmprovements in the California Memomndum of P's and A's Page 5 Comment Letter 16 1 Unfortunately, stormwater runoff in Los Angeles County's coastal waters causes or 2 contributes to an enormous number of beach closures or advisories each year. 19 Beach closures 3 and advisories result in direct and indirect negative effects on the coastal economy, such as lost 4 revenue.20 One study estimated that a hypothetical beach closure of Huntington Beach for one day 5 would result in a loss of 1200 beach visits and associated economic losses of $100,000.21 6 Conversely, the National Oceanic and Atmospheric Association found that improving water 7 quality in Long Beach from a C grade to the healthier standards of Huntington City Beach (a B 8 grade) would create $8.8 million in economic benefits over a 10-year period 22 9 Moreover, the economic and social benefits of stormwater regulation, such as those 10 achievable through this Permit, far outweigh the costs of implementation. For example, the staff 11 report for the Metals TMDL for the Los Angeles River and its tributaries found that removing 12 metals from the waterways would have benefits of as much as $18 billion (if structural systems 13 were used), in comparison to costs of between $5.7 and $7.4 billion. 23 This would be in addition 14 to "[u]nquantifiable health benefits" associated with implementation. 24 15 16 Coastal Ocean Observing System Arlington, VA: Ocean. Unnumbered Report. July; see also, 17 Chapman, D. and Hanemann, M. (2001) Environmental Damages in Court: the American Trader 18 Case, in The Law and Economics of the Environment, (Heyes, edit.), pp. 319-367 (estimating a "consumer surplus" of $8.16 to $60.79 per visit for each beachgoer). 19 19 NRDC (2012) Testing the Waters: A Guide to Water Quality at Vacation Beaches, at California Chapter Summary. Los Angeles County reported 2,430 total closing or advisory days in 2011 20 from all sources. Reported closing or advisory days are for events lasting six consecutive weeks o less. Available at http://www.nrdc.org/water/oceans/ttw/ca.asp. 21 20 See, Leeworthy, V.R. and Wiley, P.C. (2000) Southern California Beach Valuation Project: 22 Economic Value and Impact of Water Quality Change for Long Beach in Southern California, National Oceanic and Atmospheric Administration, at 4. 23 21 Hanemann, M., et al. (November 2005) Welfare Estimates for Five Scenarios of Water Quality 24 Change in Southern California: A Report from the Southern California Beach Valuation Project, at 7-8. 25 22 Leeworthy, V.R. and Wiley, P.C. (2000) Southern California Beach Valuation Project: Economic Value and Impact of Water Quality Change for Long Beach in Southern California, 26 National Oceanic and Atmospheric Administration, at 9, 15. 27 23 Regional Board and U.S. EPA Region 9 (June 2, 2005) Total Maximum Daily Loads for Metals Los Angeles River and Tributaries, at 77. 28 24 Id.; See 2012 Permit, Attachment F ("Fact Sheet"), at 76-77. Memomndum of P's and A's Page 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter116 B. Legal Background In 1972, Congress enacted the Clean Water Act ("CWA") to "restore and maintain the chemical, physical, and biological integrity of the Nation's waters." (33 U.S.C. § 1251(a); see also, NRDC v. U.S.E.P.A., 859 F.2d 156,198 (D.C. Cir. 1988); NRDC v. Costle, 568 F.2d 1369, 1373 (D.C. Cir. 1977); American Frozen Foods Inst. v. Train, 539 F. 2d 107, 124 (D.C. Cir. 1976).) The Act sought to eliminate the discharge of pollutants into navigable waters by 1985, ar to achieve fishable and swimmable conditions, wherever possible, by 1983. (33 U.S.C. § 1251(a)(1)-(2).) Courts have consistently recognized that the CWA is a tough law—"strong medicine." (Texas Municipal Power Agency v. U.S. EPA (5th Cir. 1988) 836 F.2d 1482, 1488.)25 Overall, the Act prohibits the discharge of any pollutant from a point source into a water of the United States except as in compliance with the Act. (33 U.S.C. §§ 1311(a), 1342.) "Point source" is defined to mean any discrete "conveyance," such as a pipe or channel, (33 U.S.C. § 1362(14)), and thus includes MS4s, which are elaborate networks of such conveyances. (33 U.S.C. §§ 1342(p), 1362(14).)26 A point source, such as an MS4, can comply with the CWA by obtaining a discharge permit under the National Pollutant Discharge Elimination System ("NPDES") program. (33 U.S.C. § 1342(b), (p).) The CWA requires each state to adopt Water Quality Standards ("WQSs") for all waters within its boundaries and submit them to the U.S. Environmental Protection Agency ("EPA") for approval. (33 U.S.C. §§ 131l(b)(1)(C), 1313.) WQSs include maximum permissible pollutant levels that must be sufficiently stringent to protect public health and enhance water quality, consistent with the uses for which the water bodies have been designated. (33 U.S.C. § 25 "The [Clean Water Act] is strong medicine.... Congress explicitly recognized that reduction of the amount of effluents—not merely their dilution or dispersion—is the goal of the [Act]." (Texas Municipal Power Agency, 836 F.2d at 1488.) 26 The discharge of pollutants from an MS4, often called "polluted runoff' or "urban runoff," is a two-part problem. It includes what is often referred to as non-stormwater discharges—typically, landscape irrigation flows, washwater, and other flows not related to precipitation carrying herbicides, bacteria, metals, used motor oil, and other pollutants. And it includes urban stormwater—which is basically what it sounds like—storm flows that contain pollutants from the urban environment. (See 33 U.S.C. § 1342(p)(3)(B)(ii)-(iii).) Memomndum of P's and A's Page 7 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter116 1313(c)(2)(A).) WQSs provide the reference point "to prevent water quality from falling below acceptable levels." (PUD No. I of Jefferson County v. Washington Dep't of Ecology (1994) 511 U.S. 700, 704 [quotation omitted].) States also must identify as impaired any water bodies that f to meet water quality standards. (33 U.S.C. § 1313(d).) For impaired waters, states must establish TMDLs, which set a daily limit on the discharge of each pollutant necessary to achieve water quality standards. (Id. § 1313(d)(1).) The TMDL "assigns a waste load allocation (WLA) to each point source, which is that portion of the TMDL's total pollutant load, which is allocated to a point source for which a NPDES permit is required." (Communities for a Better Env 't v. State Water Res. Control Bd. (2005) 132 Ca1.App.4th 1313, 1321 (emphasis in original).) Critically, federal law requires that "once a TMDL is developed, effluent limitations in NPDES permits must be consistent with the WLA's in the TMDL." (Id., at 1322 (citing 40 C.F.R. § 122.44(d)(1)(vii)(B).) According to EPA, which overseas implementation of the CWA, "[w]here the TMDL includes WLAs for stormwater sources that provide numeric pollutant load ... the WLA should, where feasible, be translated into numeric [water quality -based effluent limitations] in the applicable stormwater permits." 27 Like other NPDES permits, MS4 permits must ensure that discharges from storm sewers not cause or contribute to a violation of water quality standards. (33 U.S.C. § 1311(a); 1313; 1341(a); 1342(p).)28 Renewal permits—like the 2012 Permit, at issue—may not contain weaker Z' Memorandum from James A. Hanlon and Denise Keehner, U.S. EPA, to Water Management Division Directors, Regions 1 – 10, re: Revisions to the November 22, 2002 Memorandum "Establishing Total Maximum Daily Load (TMDL) Wasteload Allocations (WLAs) for Storm Water Sources and NPDES Permit Requirements Based on Those WLAs, November 12, 2010, ("EPA Hanlon Memo") at 3. (Attached as Request for Notice ("RN") "Exhibit A".) 38 See, e.g., State Board Order No. WQ 99-05, Own Motion to Review the Petition of Environmental Health Coalition to Review Waste Discharge Requirements Order No. 96-03; hi addition, permits for discharges from municipal storm sewers "shall require controls to reduce the discharge of pollutants to the maximum extent practicable ... and such other provisions as the Administrator or the State determines appropriate for the control of such pollutants. (33 U.S.C. § 1342(p)(3)(B)(iii).) This language in section 1342(p) has been held by California courts to grant "the EPA (and/or a state approved to issue the NPDES permit) ... the discretion to impose `appropriate' water pollution controls in addition to those that come within the definition of `maximum extent practicable."' (Building Industry Assn of San Diego County v. State Water Memomndum of P's and A's Page 8 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment standards than those contained in the previous permit, except under limited circumstances. (33 U.S.C. § 1342(0); 40 C.F.R. § 122.44(1).) Federal and state law additionally require implementation of an antidegradation policy, that mandates that existing water quality in navig waters be maintained unless degradation is justified by specific findings. (See, 40 C.F.R. § 131.12(a)(1).) 1. The 2001 Los Angeles County MS4 Permit In 2001, the Regional Board adopted an NPDES permit for MS4s in Los Angeles County, which was intended to address the harm caused by pollutants conveyed via storm drains to surface waters in the Los Angeles area. The permit regulated Los Angeles County, the Los Angeles County Flood Control District, and 84 incorporated cities within the County. Importantly, the 2001 Permit contained Receiving Water Limitations ("RWLs"), which required that "discharges from the MS4 that cause or contribute to the violation of Water Quality Standards or water quality objectives are prohibited." (2001 Permit, at Part 2.1.)30 The Permittees were directed to begin remedial measures immediately if discharges violate water quality standards. (Id., at Part 2.3.) If exceedances of water quality standards persisted, notwithstanding control measures, the Permittees "shall assure compliance" by preparing a compliance report that identifies the violations and adopting more stringent pollution control measures to correct them. (Id.) Complying with the 2001 Permit's iterative process assisted Permittees in meeting water quality goals, but did not excuse violations of water quality standards. An earlier MS4 permit for Orange County, approved by the State Board, had included language stating "the permittees will Resources Control Bd. (2004) 124 Cal.AppAth 866, 883 (citing Defenders of Wildlife v. Browner (9th Cir. 1999) 191 F.3d 1159, at 1165-1167).) 29 This was the third such permit issued by the Regional Board to Los Angeles County and local municipalities. Prior permits were adopted in 1990 and 1996. (2001 Permit, p. 1, Finding A.) 30 "Water Quality Standards and Water Quality Objectives" are defined in the 2001 Permit to mea "water quality criteria contained in the Basin Plan, the California Ocean Plan.... the California Toxics Rule, and other state or federally approved surface water quality plans." (2001 Permit, at Part 5, p. 70.) Memomndum of P's and A's Page 9 16 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter116 not be in violation of [receiving water limitations] so long as they are in compliance with [the iterative process set forth in the permit] .i31 EPA objected to that provision, (which MS4 permits for Vallejo and Riverside County had additionally adopted), as a "safe harbor," meaning the provision deemed the permittees in compliance with the permit regardless of whether Water Quality Standards were then met. In response, the State Board directed the Regional Boards to include receiving water limitations language devised by EPA, without a safe harbor provision, into all future MS4 permits. 32 The Regional Board followed this clear directive in the 2001 Permit. Indeed, when the County and 43 cities challenged the permit in state court, the court ruled that the Regional Board "included Parts 2.1 and 2.2 in the Permit without a `safe harbor."' (Id. )33 The Regional Board supports this interpretation: "the plain meaning of these provisions is clear: they prohibit discharges that cause or contribute to a `violation of Water Quality Standards' [or water quality objectives] or to a condition of nuisance." Put simply, "[t]he Regional Board's position ... is that the Permit cannot be read to excuse exceedances of water quality standards." 34 Finally, the Ninth Circuit confirmed the state court's interpretation of the 2001 Permit's Receiving Water Limitations, holding that "no such `safe harbor' is present in this Permit.... [there is] no textual 31 See, State Board Order No. WQ 98-01, Own Motion to Review the Petition of Environmental Health Coalition to Review Waste Discharge Requirements Order No. 96-03, at 6-7. 32 See, State Board WQ Order 99-05. 33 See, In re L.A. County Mun. Storm Water Permit Litigation., No. BS 080548 at 4-7 (L.A. Super. Ct. Mar. 24, 2005) ("L.A. County Mun. Stormwater"). The court noted that, "the Regional Board acted within its authority when it included Parts 2.1 and 2.2 in the Permit without a `safe harbor,' whether or not compliance therewith requires efforts that exceed the `MEP' standard." (In re L.A. County Mun. Stormwater, at 7.) But regardless of this authority, as described above, the Court found that "the terms of the Permit taken, as a whole, constitute the Regional Board's definition of MEP, including, but not limited to, the challenged Permit Provisions." (Id. at 7-8.) 34 Brief of Amicus Curiae California Regional Water Quality Control Board, Los Angeles Region, in Santa Monica Baykeeper v. City of Malibu No. CV 08-1465-AHM (PLAx) (C.D. Cal.) (filed Feb. 5, 2010), at 9; see also, id. at 4. Memomndum of P's and A's Page 10 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter 116 support for the proposition that compliance with certain provisions shall forgive non-compliance with the discharge prohibitions.i35 2. The 2012 Permit On November 8, 2012, the Regional Board adopted a new MS4 permit for Los Angeles County. Like the prior 2001 Permit, the 2012 Permit states that, "Discharges from the MS4 that cause or contribute to the violation of receiving water limitations are prohibited." (2012 Permit, at Part V.A.].)36 Rather than maintaining the 2001 Permit's strict prohibition against discharges that cause or contribute to an exceedance of Water Quality Standards, however, the Permit instead incorporates several safe harbors that create broad exemptions to the RWLs section, rendering the limitations inoperative in certain circumstances. Under the 2012 Permit, Permittees have several different compliance options, two of trigger application of a safe harbor. In particular, dischargers may elect to develop or participate ii a Watershed Management Program ("WMP"), or Enhanced Watershed Management Program ("EWMP"). (2012 Permit, at Part VI.C.) These programs in many aspects allow a permittee to draft their own permit requirements, conditions, and schedules for compliance. Under a WMP, a permittee is required to identify water quality priorities (id. at VI.C.5.a), select watershed control measures to be implemented, (id. at VI.C.5.b), and establish compliance schedules for addressing water quality priorities. (Id. at VLC.5.c.) For an EWMP, a permittee must, where feasible within a given watershed, retain all storm water runoff from the 85`h percentile, 24-hour storm event for the drainage areas tributary to the projects. (Id. at VI.C.l.g.) Under both options, Permittees must conduct a "reasonable assurance" analysis to assess whether the programs will result in discharges 35 Natural Resources Defense Council v. County of Los Angeles (2011) 673 F.3d 880, 897. This portion of the 9th Circuit Court's Opinion is not subject to further review. 36 The Permit defines "Receiving Water Limitation" as: "Any applicable numeric or narrative water quality objective or criterion, or limitation to implement the applicable water quality objective or criterion, for the receiving water as contained in Chapter 3 or 7 of the Water Quality Control Plan for the Los Angeles Region (Basin Plan), water quality control plans or policies adopted by the State Water Board, or federal regulations, including but not limited to, 40 CFR § 131.38." (Permit, at Attachment A, A-17.) Memomndum of P's and A's Page 11 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letterl16 that achieve water quality based effluent limitations and RWLs in the 2012 Permit. (Id. at VI.C.l.g; VI.C.5.b.iv(5).) Although it is a goal of these programs to ensure that stormwater discharges do not cause or contribute to exceedances of RWLs, (see, e.g., id. at VLC.5.b.ii), and that TMDL WLAs are achieved, it is not a requirement that the programs achieve these results in fact. Permittees are instead given a safe harbor from the prohibition on violations of RWLs, or, in some cases of TMDL limits, if they participate in a WMP or an EWMP. The safe harbors include relief from RWL compliance: 1) during the development of a WMP or an EWMP, before the plan is approved; 2) after a plan is submitted to and approved by the Regional Board; and, 3) when the specific RWL (or combination of water quality standard and waterbody) at issue is already addressed by a TMDL .37 More specifically, in the first instance, a safe harbor applies to discharges by a permittee upon notification of its intent to develop a WMP or an EWMP to the Regional Board. During the period of plan development and review (up to 28 months from the 2012 Permit adoption date for a WMP or 40 months from the 2012 Permit adoption date for an EWMP before it may be approved (Id. at VLC.4.a.)), the permittee is excused for violations of the Permit's RWLs: • "Upon notification of a Permittee's intent to develop a WMP or EWMP and prior to approval of its WMP or EWMP, a Permittee's full compliance with all of the following requirements shall constitute a Permittee's compliance with the receiving water limitations provisions in Part V.A. not otherwise addressed by a TMDL iiH (2012 Permit, at Part VI.C.2.d.)39 Second, after approval of a Permittee's WMP or EWMP by the Regional Board or the Board's Executive Officer, a safe harbor removes liability for 37 In this last case, in some circumstances the 2012 Permit provides a safe harbor for compliance with either interim or final TMDL limits, or both. 38 We note that the Regional Board lacks authority to exempt state law requirements prohibiting the causation of a condition of nuisance under Part V.A.2. 39 The Permittee is required to: "i. Provide[] timely notice of its intent to develop a WMP or EWMP, ii. Meet[] all interim and final deadlines for development of a WMP or EWMP, iii. For the area to be covered by the WMP or EWMP, target[] implementation of watershed control measures in its existing storm water management program ... and iv. Receive[] final approval of Memomndum of P's and A's Page 12 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letted 16 a violation of all RWLs if the WMP or EWMP addresses that pollutant/waterbody combination, regardless of whether or not compliance with the RWL is actually achieved: • "A Permittee's full compliance with all requirements and dates for their achievement in an approved Watershed Management Program or EWMP shall constitute a Permittee's compliance with the receiving water limitations provisions in Part V.A. of this Order for the specific water body -pollutant combinations addressed by an approved Watershed Management Program or EWMP." (Id. at VLC.2.b.) Third, the 2012 Permit provides a safe harbor from certain TMDL requirements. Specifically, the 2012 Permit provides a safe harbor for interim TMDL WLAs for permittees indicating their intent to develop a WMP or an EWMP: • "Upon notification of a Permittee's intent to develop a WMP or EWMP and prior to approval of its WMP or EWMP, a Permittee's full compliance with all of the following requirements40 shall constitute a Permittee's compliance with provisions pertaining to interim WQBELs with compliance deadlines occurring prior to approval of a WMP or EWMP." (Id. at VLE.2.d.i(4)(d).) And, for permittees implementing an EWMP, the 2012 Permit provides a I safe harbor for all TMDL final limits other than for Trash TMDLs: "A Permittee shall be deemed in compliance with an applicable final water quality -based effluent limitation and final receiving water limitation for the pollutant(s) associated with a specific TMDL if... In drainage areas where Permittees are implementing an EWMP, (i) all non -storm water and (ii) all storm water runoff up to and including the volume equivalent to the 85h percentile, 24-hour event is retained for the drainage area tributary to the applicable receiving water." (Id. at VLE.2.e.i(4).) By allowing these safe harbors, the 2012 Permit excuses compliance with TMDL WLAs, and with its RWLs where the 2001 Permit mandated compliance. its WMP or EWMP within 28 or 40 months, respectively." (Permit, at Part VI.C.3.b.i-iv.) The safe harbor does not apply to interim Trash TMDL limits. 40 The Permittee is required to to: "i. Provide[] timely notice of its intent to develop a WMP or EWMP, ii. Meet[] all interim and final deadlines for development of a WMP or EWMP, iii. For the area to be covered by the WMP or EWMP, target[] implementation of watershed control measures in its existing storm water management program ... and iv. Receive[] final approval of its WMP or EWMP within 28 or 40 months, respectively." (2012 Permit, at Parts VI.E.2.d.i(4)(d)(1)-(4).) Memomndum of P's and A's Page 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter 116 STANDARD OF REVIEW The State Board must exercise its independent judgment as to whether a Regional Board action is reasonable. (See, Stinnes-Western Chemical Corp., State Board WQ Order No. 86-16 (1986).) Specifically, the State Board's review is equivalent to the standard a reviewing court would apply under California Code of Civil Procedure Section 1094.5, (id.), which states "[a]buse of discretion is established if the respondent has not proceeded in the manner required by law, the order or decision is not supported by the findings, or the findings are not supported by the evidence." (Cal. Civ. Proc. Code § 1094.5(b); see also, Zuniga v. Los Angeles County Civil Serv. Comm'n (2006) 137 Cal.App.4th 1255, 1258 (applying same statutory standard).) "Where it is claimed that the findings are not supported by the evidence.... abuse of discretion is established i the court determines that the findings are not supported by the weight of the evidence." (Cal. Civ. Proc. Code § 1094.5(c).) The administrative decision must be accompanied by findings that allow the court reviewing the order or decision to "bridge the analytic gap between the raw evidence and ultimate decision or order." (Topanga Assn for a Scenic Cmty. v. County of Los Angeles (1974) 11 Ca1.3d 506, 515.) This requirement "serves to conduce the administrative body to draw legally relevant sub -conclusions supportive of its ultimate decision ... to facilitate orderly analysis and minimize the likelihood that the agency will randomly leap from evidence to conclusions." (Id. at 516.) "Absent such roadsigns, a reviewing court would be forced into unguided and resource -consuming explorations; it would have to grope through the record to determine whether some combination of credible evidentiary items which supported some line of factual and legal conclusions supported the ultimate order or decision of the agency." (Id. at 516, n.15.) Memomndum of P's and A's Page 14 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter 116 III. ARGUMENT A. The Permit Creates Illegal Safe Harbors in Violation of Federal Anti -Backsliding and Antidegradation Requirements 1. The 2012 Permit Creates Safe Harbors that Exempt Compliance with Receiving Water Limitations in Some Circumstances Rather than maintaining the 2001 Permit's prohibition against discharges that cause or contribute to an exceedance of water quality standards, the 2012 Permit creates safe harbors that exempt compliance with the Receiving Water Limitations for Permittees that elect to participate in a WMP or an EWMP. These safe harbor provisions violate multiple provisions of the CWA and other federal and state regulations, and render the 2012 Permit unlawful. The 2012 Permit creates safe harbors by deeming a Permittee to be in compliance with the Permit's RWLs (which was required by the 2001 Permit), both once a WMP or an EWMP has been approved by the Regional Board and during plan development 41 The Ninth Circuit defined a "safe harbor" as "the proposition that compliance with certain provisions shall forgive non- compliance with the discharge prohibitions." (Natural Resources Defense Council, Inc. v. County of Los Angeles (9th Cir. 2011) 673 F.3d 880, 897 (cert. granted on other grounds).) Unfortunately, the new Permit establishes just such a program. If a Permittee meets the program requirements for a WMP or an EWMP, it legally complies with the 2012 Permit's RWLs, regardless of whether the RWLs are actually achieved. During the 2012 Permit adoption hearing, 42 the Regional Board's Executive Officer admitted that these provisions provide a safe harbor from liability for RWL violations. While attempting to define each provision as only a "compliance mechanism," Mr. Sam Unger stated, "at best, it's a conditional safe harbor. ,43 Similarly, Mr. Unger stated: "Permittees have to be in 41 We note that the 2012 Permit's approach is nonsensical in this regard, as it creates a safe harbor from compliance with Receiving Water Limitations (and for interim TMDL limits) prior to approval of a WMP or an EWMP, while the safe harbor is ultimately expressly conditioned on the approval of the TMDL. 42 Regional Board, In the Matter of the Regional Board Public Meeting/Hearing, Thursday, November 8, 2012. ("November 8 Hearing.") 43 Mr. Sam Unger, Executive Officer, Regional Board, November 8 Hearing, at 346:25. Memomndum of P's and A's Page 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment compliance with the milestones and the activities set out in developing the plan for the watershed management program. And if they're not, then the operative part of the permit that would take place is these receiving water limitation[s].i44 Precisely—the effect of this scheme is that if a Permittee is in compliance with the requirements of a WMP or an EWMP, the Receiving Water Limitations are not operative. There is simply no defensible argument that these provisions constitute anything other than safe harbors, which violate federal and state law. 2. The 2012 Permit's Safe Harbors Violate Federal Anti -Backsliding Requirements Clean Water Act and federal regulations prohibit backsliding, or weakening of permit terms, from the previous permit. Section 402(0)(1) of the Clean Water Act requires that, for effluent limitations based on a state standard, "a permit may not be renewed, reissued, or modified to contain effluent limitations which are less stringent than the comparable effluent limitations in the previous permit," except in circumstances not present here. (33 U.S.C. § 1342(0)(1).) Similarly, federal regulations require that "when a permit is renewed or reissued, interim effluent limitations, standards or conditions must be at least as stringent as the final effluent limitations, standards, or conditions in the previous permit...." (40 C.F.R. § 122.44(1)(1).) By providing a safe harbor waiving requirements to meet Water Quality Standards, the 2012 Permit flatly violates these federal requirements. a. The Safe Harbors Render the RWLs Less Stringent Than in the Previous Permit The Permit allows a Permittee participating in a WMP or an EWMP to comply with Receiving Water Limitations, even if a Permittee's discharges actually cause or contribute to an exceedance of the Receiving Water Limitations, including violations of Water Quality Standards. By contrast, the 2001 Permit required compliance with WQSs. Thus, the 2012 Permit excuses discharges of pollution and violations of WQSs that the previous permit prohibited. 44 Mr. Sam Unger, Executive Officer, Regional Board, November 8 Hearing, at 324:8-12. Memomndum of P's and A's Page 16 16 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter116 b. The Receiving Water Limitations Cannot be Weakened Unless Consistent With 1313(d)(4) or 402(0) Section 402(0) of the Clean Water Act (33 U.S.C. § 1342(0)), generally prohibits relaxation of, among other things, an effluent limitation `necessary to meet water quality standards ... schedules of compliance, established pursuant to any State law or regulations ... or any other Federal law or regulation, or required to implement any applicable water quality standard established pursuant to" the CWA. (See, 33 U.S.C. § 1342(0)(1); 33 U.S.C. § 1311(b)(1)(C).)45 Although a permit may contain less stringent requirements if the change is consistent with the requirements of 33 U.S.C. § 1313(d)(4) or the enumerated exceptions in section 402(o)(2).46 The safe harbors in the 2012 Permit satisfy none of these conditions. i. The Receiving Water Limitations Are Covered by Anti - Backsliding Requirements as "Effluent Limitations" and "Standards or Conditions" of the 2001 Permit The Clean Water Act defines the term "effluent limitation" broadly, as "any restriction established by a State or the Administrator on quantities, rates, and concentrations of chemical, physical, biological, and other constituents which are discharged from point sources...." (33 U.S.C. § 1362(11).) By prohibiting the "discharge" of any pollutant in quantities sufficient to cause or contribute to an exceedance of Receiving Water Limitations, the RWLs easily fit within this sweeping definition. (See also, NRDC v. U.S.E.P.A. (D.C. Cir. 1981) 656 F.2d 768, 775-76 (as a practical matter the limitation restricted the discharge of pollution and consequently was an effluent limitation), NRDC v. USE.P.A. (D.C. Cir. 1982) 673 F.2d 400, 403 (33 U.S.C. § 502(l 1) "defines `effluent limitation' as `any restriction', not just numeric limitations").) 45 We note that EPA has recognized that providing additional time for compliance for a provision required by the previous permit violates anti -backsliding requirements. (Letter from Jon M. Capacasa, Director Water Protection Division, EPA Region III to Jay Sakai, Maryland Department of the Environment, re: Specific Objection to Prince George's County Phase I Municipal Separate Storm Sewer System (MS4) Permit MD0068284, at 3 (Attached as RN "Exhibit B").) The additional time allotted by the new Permit to achieve compliance with RWLs, required in the 2001 Permit, for Permittees developing a WMP or an EWMP constitutes a less stringent limitation. ' See also, U.S. EPA (September 2010) NPDES Permit Writers' Manual ("NPDES Manual), at 7- 1 to 7-3. (Attached as RN "Exhibit C".) Memomndum of P's and A's Page 17 H 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter116 In addition, the RWLs constitute "standards" or "conditions" protected by anti -backsliding requirements under 40 C.F.R. § 122.44(1). Board staff have attempted to avoid the plain implications of section 402(0) by saying that the CWA "talks about [anti -backsliding] in terms of effluent limits. And we're talking about receiving water limitations.s47 Yet, even if this were the case, the safe harbors would still be unlawful. EPA's anti -backsliding regulations require that "effluent limitations, standards or conditions must be at least as stringent as the final effluent limitations, standards, or conditions in the previous permit...." (40 C.F.R. § 122.44(1)(1) (emphasis added).) Thus these requirements "apply to questions regarding non -water quality - based effluent limits," including "backsliding questions regarding permit conditions, (rather than permit limitations) even where the conditions in question are based on water quality considerations.i48 Regional Board staff confirmed at the November 8 Hearing that, at a minimum, the "receiving water limits would be considered a condition[] [of the] permit."49 As a result, even if section 402(0) were inapplicable, which it is not, the prohibition on anti -backsliding contained in 40 CFR 122.44(1) applies to the RWLs as conditions. Because in either case the 2012 Permit weakens the Receiving Water Limitations as compared with the 2001 Permit, it violates anti - 47 Ms. Deborah Smith, Regional Board, November 8 Hearing at 313:5-7. 48 EPA (1989) Memorandum on Interim Guidance on Implementation of Section 402(0) Anti - Backsliding Rules For Water Quality -Based Permits, from James R. Elder, Director, Office of Water Enforcement and Permits to Water Management Division Directors, Regions I -X, NPDES State Directors, at 2. (Attached as RN "Exhibit D".) ("Section 402(0) is silent on the issue of permit conditions, and only addresses backsliding from permit limitations"); See also, EPA (Sept. 2010) NPDES Permit Writers' Manual, EPA 833-K-10-001, at 7-4. ("NPDES Manual") 49 Ms. Deborah Smith, Regional Board, November 8 Hearing, at 314:6-7. Earlier draft versions of the Permit had previously acknowledged the application of anti -backsliding requirements in this context, but, inexplicably, staff edited the October 18, 2012 draft of the 2012 Permit to remove reference to "conditions" in its explanation of anti -backsliding requirements. Referring to 40 C.F.R. § 122.44(1), the sentence "anti -backsliding provisions require effluent limitations or other conditions in a reissued permit to be as stringent as those in the previous permit," was revised to read "anti -backsliding provisions require effluent limitations in a reissued permit to be as stringent as those in the previous permit...." (2012 Permit, at p. 25, Finding N.) Thus, the Permit only incompletely states the requirements of federal anti -backsliding regulations it then proceeds to violate. Memomndum of P's and A's Page 18 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter 116 backsliding requirements. In addition, as discussed below, the exemptions to anti -backsliding do not apply here. ii. The Safe Harbors do not Qualify Under Section 1313(d)(4) as Exceptions to the Anti -Backsliding Rule Section 1313(d)(4) restricts what effluent limitations may be revised in a renewal permit. First, where water quality standards are not being attained (see 33 U.S.C. § 1313(d)(4)(A)), a less stringent effluent limitation based on a TMDL or other WLA is allowed in a renewal permit only "the cumulative effect of all such revised effluent limitations based on such total maximum daily load or waste load allocation will assure the attainment of such water quality standard," or if the designated use is removed. (33. U.S.C. § 1313(d)(4)(A).)50 Second, for waters that are meeting applicable water quality standards, (under 33 U.S.C. § 1313(d)(4)(13)), a limitation based on a TMDL or Water Quality Standard may only be weakened if it is consistent with the applicable state antidegradation policy. (33 U.S.C. § 1342(o)(1).)51 Neither of these conditions has been met. First, for waters that are failing to meet WQSs, the 2012 Permit fails to demonstrate that the revised standards will assure WQSs will be attained. Second, where waters are currently attaining WQSs, the Permit fails to provide required analysis consistent with the state's antidegradation policy. These allowances violate the anti -backsliding requirements both during WMP or EWMP development, before the plan is approved by the Regional Board, and after WMP or EWMP approval, during the plan's implementation. iii. The Safe Harbors do not Qualify Under Section 402(o)(2) as Exceptions to the Anti -Backsliding Rule Although section 402(o)(2) lists a series of exceptions to the otherwise applicable anti - backsliding requirements, none applies to this permit. The law's exemptions include: 50 See also, EPA, NPDES Permit Writer's Manual, at 7-3. 51 See also, EPA, NPDES Manual, at 7-2; Exhibit 7-2. For further discussion of antidegradation issues raised by the 2012 Permit, see section III.A.3, below. Memomndum of P's and A's Page 19 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letterl16 (A) material and substantial alterations or additions to the permitted facility occurred after permit issuance which justify the application of a less stringent effluent limitation; (B)(i) information is available which was not available at the time of permit issuance ... and which would have justified the application of a less stringent effluent limitation at the time of permit issuance; or (ii) the Administrator determines that technical mistakes or mistaken interpretations of law were made in issuing the permit under section (a)(1)(B) of this section; (C) a less stringent effluent limitation is necessary because of events over which the permittee has no control and for which there is no reasonably available remedy; (D) the permittee has received a permit modification under [various other sections] of this title; or (E) the permittee has installed the treatment facilities required to meet the effluent limitations in the previous permit and has properly operated and maintained the facilities but has nevertheless been unable to achieve the previous effluent limitations... (33 U.S.C. § 1342(0)(2).) None of these exceptions apply to the adoption of the 2012 Permit. Other than an unsupported and insufficient statement by Board counsel at the November 8 Hearin] that "Had in 2001 there been 33 [new] TMDLs [incorporated into the Permit] it's possible the Board might have done something very different than what they did" in adopting the 2001 Permit, the Regional Board offered no evidence that these exceptions apply. 52 As a result, the anti - backsliding requirements of section 402(0) prohibit the adoption of safe harbors in the 2012 Permit. iv. The Safe Harbors Violate Section 402(o)(3)'s Prohibition Against Changes that Would Result in a Violation of Applicable Water Quality Standards Even if the 2012 Permit's safe harbors complied with the above anti -backsliding requirements, which they do not, they would still be unlawful under section 402(0)(3), which serves as a "safety clause that provides an absolute limitation on backsliding."53 Section 402(0)(3) requires that in no event shall a permit "be renewed, reissued, or modified to contain a less stringent effluent limitation if the implementation of such limitation would result in a violation of a water quality standard" under 33 U.S.C. § 1313. (33 U.S.C. § 1342(0)(3).) Thus, as EPA explains, "even if one or more of the backsliding exceptions outlined in the statute is applicable and met, CWA section 402(0)(3) acts as a floor and restricts the extent to which effluent 52 Ms. Jennifer Fordyce, Regional Board Counsel, November 8 Hearing at 317:11-13. 53 See EPA, NPDES Manual at 7-4. Memomndum of P's and A's Page 20 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter 116 limitations may be relaxed. ,54 The 2012 Permit, by explicitly excusing violations of Receiving Water Limitations which prohibit discharges that cause or contribute to a violation of WQSs, fails to meet this federally mandated minimum level of protection. 3. The 2012 Permit's Safe Harbor Provisions Violate State and Federal Antidegradation Requirements The overall goal of the Clean Water Act is the complete elimination of the discharge of pollutants into waters of the United States. (33 U.S.C. § 1251(a)(1).) To help meet this goal, states must implement an antidegradation policy. As discussed below, the permit does not comply with applicable antidegradation requirements. a. The Safe Harbors Violate Antidegradation Requirements that Prohibit Actions that Would Lead to Lower Water Quality The federal antidegradation policy contains a three "Tier" test for determining when increases in pollutant loadings or adverse changes to water quality may be allowed. (40 C.F.R. § 131.12.) While Tier II and Tier III apply only to high quality waters and "outstanding National resource waters," respectively, Tier I antidegradation analysis applies to all waters of the United States, including waters that do not exceed the CWA section 101(a) goals. 55 "Tier One classification applies a minimum level of protection to all waters, which protects even seriously degraded water bodies, by prohibiting any additional pollution that would affect existing uses."56 California has established a state antidegradation policy, which incorporates the federal antidegradation policy and establishes additional requirements. 57 NPDES permit renewals or modifications such as the 2001 and 2012 Los Angeles County MS4 Permits are subject to both 54 See EPA, NPDES Manual at 7-4. 55 (64 Fed. Reg. 46058, 46063, Revisions to the National Pollutant Discharge Elimination System Program and Federal Antidegradation Policy in Support of Revisions to the Water Quality Planning and Management Regulation. 56 Brawer, J.M., "Antidegradation Policy and Outstanding Natural Resource Waters in the Northern Rocky Mountain States," 20 Pub. Land & Resources L. Rev. 13, 18 (1999). 57 See, State Board Resolution 68-16; see also In the Matter of the Petition ofRimmon C. Fay, State Board Order No. WQ 86-17 at 16-19 (November 20. 1986). Memomndum of P's and A's Page 21 Comment Letter 16 1 state and federal antidegradation requirements. 58 The State antidegradation policy specifically 2 addresses only "high quality" waters, or waters of better quality than required by water quality 3 standards for a particular beneficial use (or conversely, those waters not designated as "impaired"). 4 However, the State policy applies to all waters, including surface and groundwater, to changes in 5 water quality since 1968, and to all uses, including existing and potential uses. 59 6 Together, state and federal anti-degradation requirements mandate that existing water 7 quality in navigable waters be maintained, unless degradation is justified based on specific 8 findings. hi no case may water quality be lowered to a level that would interfere with existing or 9 designated uses. Thus any action by a Regional Board, including permit issuance, that would result 10 in lower water quality—either in high quality or impaired waters—must be analyzed to ensure 11 consistency with state and federal antidegradation policy. Further, because a receiving water can 12 be considered high quality for one beneficial use, and impaired for others, the analysis must be 13 conducted pollutant by pollutant, and beneficial use by beneficial use. (See, Associacion de Gente 14 Unida for El Agua v. Central Valley Regional Board (2012) (2 10 Cal.App.40i 1255) [149 15 Cal.Rptr.3d 132, 142; 144] (citing "St. Water Res. Control Bd., Guidance Memorandum (Feb. 16, 16 1995); 40 CFR 131.12(a)(1).) 17 Accordingly, the Regional Board was required to conduct a Tier I analysis for all waters 18 impacted by the Los Angeles County MS4 systems, and a Tier II analysis for higher quality Los 19 Angeles waters (taking account of water quality for specific pollutant and beneficial use 20 considerations). In past instances when the Regional Board has failed to provide adequate findings 21 to verify that beneficial uses or high-quality waters will be maintained, the State Board has 22 remanded the orders to the Regional Board for further proceedings. 60 The same should be done 23 here. 24 25 58 See, SWRCB Order No. WQ 86-17; EPA, Region IX, Guidance on Implementing the Antidegradation Provisions of 40 C.F.R. § 131.12, at 2-4 (June 3, 1987) ("EPA Antidegradation 26 Guidance"). (Attached as RN "Exhibit E".) 27 59 State Board Resolution 68-16. 60 See e.g., State Board Order WQ 86-17, at 28 (State Board remanded Regional Board order due 28 to the Regional Board's failure to make appropriate findings as to whether an increase in Memomndum of P's and A's Page 22 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letterl16 b. The Regional Board did not Conduct Any Required Antidegradation Analysis As noted in section IILA.1. above, the safe harbor provisions in the 2012 Permit weaken the Receiving Water Limitations compared with the 2001 Permit requirements. 61 However, despite the 2012 Permit's explicit weakening of the prior permit's limits, and the resulting continued degradation of receiving waters, the Regional Board conducted no antidegradation analysis. The 2012 Permit's reference to antidegradation is limited to a cursory summary of the legal requirements, and a conclusion that "[t]he permitted discharge is consistent with the anti - degradation provision of [40 CFR] section 131.12 and State Water Board Resolution No. 68-16." (2012 Permit, at p. 25, Finding J.) Simply claiming that no degradation will occur does not satisfy the requirements of the Clean Water Act. (Associacion de Gente Unida, 149 Cal.Rptr., at 136.; see also, American Funeral Concepts -American Cremation Soc'y v. Board of Funeral Directors and Embalmers (1982) 136 Cal.App.3d 303, 309.) Even assuming, as the Regional Board claims, that the new Receiving Water Limitations are as stringent as those in the previous Permit, allowing a permit regime that degrades receiving waters to continue triggers antidegradation analysis. At a minimum, the 2012 Permit maintains th( existing failed program implementation for 18 or 30 months during WMP or EWMP development and a potentially additional 10 months during Regional Board review of the plans. Such an approach is inconsistent with antidegradation requirements. As the Third Appellate District suspended solids and bacteria would violate antidegradation requirements in an area used for body -contact sports.); see also, Topanga Assn for a Scenic Cmty., 11 Cal.3d at 515 61 Board counsel indicated that anti -degradation is not a concern during the planning phase for either WMP or EWMPs, before the plans are either approved or adopted, because "they still have to implement their existing MS4 program. So they're going to keep doing what they're doing rig now ... the water quality is not going to get worse." (Ms. Jennifer Fordyce, Regional Board counsel, November 8 Hearing, at 318:3-7; see also Ms. Renee Purdy, Regional Board, November Hearing, at 318:12-18.) Yet as discussed earlier, under the existing program, monitoring shows persistent violations of water quality standards, including in waters not yet listed as impaired undi CWA section 303(d). Memomndum of P's and A's Page 23 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter 116 pointedly stated in rejecting the Regional Board's argument that because a new dairy permit was no worse than the last: Our problem with the Regional Board's reliance on the assertion that no groundwater degradation is allowed is twofold. First, as the order itself recognizes, the groundwater quality has degraded, and dairy operations are partly responsible. To the extent that the Order allows historic practices to continue without change, degradation will continue. (Associacion de Gente Unida, 149 Cal.Rptr., at 145.) There is no meaningful debate that urban runoff continues to degrade receiving waters in the Los Angeles area, and that the stormwater programs implemented under the prior permit failed to control that degradation. Therefore, because an antidegradation analysis is required, and the 2012 Permit fails to conduct that analysis, the 2012 Permit violates State and Federal Law. B. The Permit Unlawfully Fails to Incorporate Waste -Load Allocations Consistent With Applicable TMDLs The Clean Water Act relies on TMDLs to restore water bodies that fail to meet water quality standards. TMDLs establish a clear and scientifically -driven pathway towards protecting beneficial issues for public health and aquatic life. The CWA and its implementing regulations require that NPDES permits are consistent with the assumptions and requirements of TMDL WLAs. (40 C.F.R.§ 122.44(d)(1)(vii)(B).)62 Consistent with EPA regulations, the MS4-related WLAs for TMDLs adopted in the Los Angeles Region must be properly reflected in the MS4 Permit. The Permit itself states: The Permittees shall comply with the applicable water quality -based effluent limitations and/or receiving water limitations contained in Attachments L through R, consistent with the assumptions and requirements of the WLAs established in the TMDLs, including implementation plans and schedules, where provided for in the State adoption and approval of the TMDL (40 CFR § 122.44(d)(1)(vii)(B); Cal.Wat. Code §13263(a)). (2012 Permit, at Part VLE.l.c.) However, the Permit fails to properly incorporate the very limitations it acknowledges are necessary. During this renewal, 33 TMDLs were newly incorporated into the 2012 Permit. In violation of the federal requirements, the 2012 Permit fails 62 See, EPA Hanlon Memo. Memomndum of P's and A's Page 24 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter 116 to ensure compliance with all interim and final WLAs for these TMDLs and incorporates illegal compliance schedules as permit terms. 1. The 2012 Permit Illegally Exempts Dischargers from Complying with Interim and Final Numeric Waste Load Allocations Established in TMDLs Although all permit terms must be consistent with the assumptions and requirements of WLAs established in TMDLs, (40 C.F.R. § 122.44(d)(1)(vii)(B)), the 2012 Permit inexplicably excuses compliance with interim WLAs 63 and eliminates final WLAs in at least two instances. First, the 2012 Permit specifies that where a Permittee is implementing an EWMP and runoff is retained up to the 85`h percentile storm, the Permittee is deemed in compliance with final TMDL WLAs. (2012 Permit, at Part VLE.2.e.i(4).) The Permit states: A Permittee shall be deemed in compliance with an applicable final water quality - based effluent limitation and final receiving water limitation for the pollutant(s) associated with a specific TMDL if... (4)In drainage areas where Permittees are implementing an EWMP, (i) all non -storm water and (ii) all storm water runoff up to and including the volume equivalent to the 85`h percentile, 24-hour event is retained for the drainage area tributary to the applicable receiving water. (Id. at Part VI.E.2.e.i.) By providing this alternative means of demonstrating compliance, the Regional Board thus creates a safe harbor from final TMDL requirements and incorporates a provision that is inconsistent with the WLAs. Under this regime, there is no assurance that actual final TMDL limits, established to achieve WQSs and protect beneficial uses, will ever be met in waterbodies throughout Los Angeles County. 64 Second, for EPA -approved TMDLs, the 2012 Permit removes compliance obligations, again excusing Permittees from complying with final WLAs. Section VLE.3 provides: " Where a Permittee engages in either type of watershed management program, the Permit unlawfully eliminates the need to comply with interim WQBELs and RWLs. Indeed, the Permit includes a safe harbor for violations of interim limits that occur during and after WMP or EWMP development rather than actually achieving the interim limits defined in the TMDL. (2012 Permit, at Parts VI.C.3.a, VLE.2.d.i(4), (4)(d); see also, Section LB.2., above.) 64 See discussion on evidence in the record in section III.C., below. Memomndum of P's and A's Page 25 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter116 TMDLs established by the USEPA, to which Permittees are subject, do not contain an implementation plan adopted pursuant to California Water code section 13424. However, USEPA has included implementation recommendations as part of these TMDLs. In lieu of inclusion of numeric water quality based effluent limitations at this time, this Order requires Permittees subject to WLAs in USEPA established TMDLs to propose and implement best management practices (BMPs) that will be effective in achieving compliance with USEPA established numeric WLAs. (2012 Permit, at Part VLE.3 (emphasis added).) This provision is not consistent with existing, applicable WLAs. (40 C.F.R. § 122.44(d)(1)(vii)(B).) Because TMDLs established by EPA include numeric WLAs, the 2012 Permit must include numeric WQBELs consistent with those WLAs. 65 For example, the San Gabriel River Metals and Selenium TMDL, which has been in effect since 2007, sets numeric WLAs based on the California Toxics Rule ("CTR") (40 C.F.R. 131.36(d)(10)) criteria. The MS4 Permit must incorporate the numeric WLAs set forth in the EPI San Gabriel River Metals and Selenium TMDL and other EPA TMDLs to comply with the Clean Water Act. Yet, the safe harbor provisions do not require compliance with these numeric limits, i violation of federal requirements. 2. The Permit Incorporates Illegal Compliance Schedules In Violation of 40 C.F.R. § 122.47 NPDES permits may only include schedules for achieving compliance with permit limits permit terms when schedules for achieving compliance are authorized, appropriate, and satisfy specific requirements. (See In the Matter of Star-Kist Caribe, Inc. (E.A.B. 1989) 1989 EPA App. LEXIS 38, at *7; 33 U.S.C. § 1313(e)(3)(F); 40 C.F.R. § 122.47.) Any compliance schedules incorporated into the MS4 Permit must lead to compliance "as soon as possible," (40 C.F.R. § 122.47(a)(1)), and must comply with specific requirements including: 1) if the compliance schedule exceeds one year, it must include interim compliance deadlines; 2) interim deadlines must be no more than one year apart; and, 3) if the time necessary for completion of any interim requirement is more than one year and is not readily divisible into stages for completion, the permit shall specify interim dates for the submission of reports of progress toward completion of the interim requirements and indicate a projected completion date. 65 EPA Hanlon Memo Memomndum of P's and A's Page 26 9 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter 116 (40 C.F.R. § 122.47(a)(3).) Further, WLAs and compliance schedules in the 2012 Permit must also be consistent with other state water quality control plans and statutory deadlines; a compliant schedule may only be included in an NPDES permit as a permit term when such compliance schedules are authorized. (See In the Matter of Star-Kist Caribe, Inc., 1989 EPA App. LEXIS, at *7; 33 U.S.C. § 1313(e)(3)(F).) Section IV.A.2.a. of the 2012 Permit does not comply with these federal regulations. It provides that "[e]ach Permittee shall comply with applicable WQBELs as set forth in Part VLE [TMDL section] of this Order, pursuant to applicable compliance schedules." (Emphasis added). The 2012 Permit also references TMDL implementation schedules in several other sections. 66 However, the implementation schedules set out in several of the applicable TMDLs do not satisfy federal laws governing NPDES permit compliance schedules, and therefore cannot be incorporate I into the 2012 Permit. Specifically, any implementation schedule set forth in an applicable TMDL that allows for more than one year to achieve compliance, but lacks interim deadlines, cannot be incorporated intc the 2012 Permit as an NPDES compliance schedule. Because the implementation schedules set out in the Malibu Creek Bacteria TMDL, the Santa Monica Bay Beaches Bacteria TMDLs, and tht Los Angeles River Indicator Bacteria TMDL do not have such deadlines, the 2012 Permit may not incorporate them without a detailed schedule. The Permit contains no such schedule. Moreover, WLAs in metals TMDLs in Los Angeles are based on the CTR criteria, and compliance schedules for CTR -based limits are authorized through the Inland Surface Water Plan ("ISWP"). But the ISWP only authorized compliance schedules for a maximum of 10 years from the time CTR criteria were first promulgated and states that no discharger can be given a compliance schedule to meet CTR criteria after May 18, 2010.67 As a result, any compliance schedules set out in TMDLs implementing the CTR are not authorized. 66 See, e.g., Permit, at Parts VLC.3.c.; VI.E.L; VLE.c.ii.; and, VLe.2.d.i. 67 State Board Resolution No. 2000-15, Policy for the Implementation of Toxics Standards for Inland Surface Waters, Enclosed Bays, and Estuaries of California, at 19; see also October 23, 2006 EPA Letter re: California SIP, Compliance Schedule Provisions; State Board Memo dated Memomndum of P's and A's Page 27 Comment Letter 16 1 C. The Decision to Adopt the 2012 Permit, Including its Safe Harbor Provisions, is not Supported by the Findings or the Evidence in the Administrative Record 2 3 The Regional Board's approval of the 2012 Permit violates long-established requirements 4 for agency decision-making. The Regional Board's findings fail to show the Board's mode of 5 analysis to "bridge the analytic gap between the raw evidence and [the] ultimate decision or 6 order." (See, Topanga Assn for a Scenic Cmty, 11 Ca1.3d at 515.) Moreover, in critical aspects 7 the Regional Board's final decision lacks evidentiary support in the record. The absence of 8 adequate findings or evidence renders the Regional Board's decision unlawful. (See, Cal. Civ. 9 Proc. Code § 1094.5(b); see also, Zuniga, 137 Cal. App. 4th at 1258.) 10 The 2012 Permit's discussion of anti-backsliding requirements exemplifies the Regional 11 Board's lack of sufficient analysis. 68 Environmental Groups raised significant legal and factual 12 argument before the Regional Board to demonstrate that the safe harbors incorporated in the 2012 13 Permit violate federal anti-backsliding requirements. 69 In response, the 2012 Permit merely 14 repeats (incompletely) the legal requirements for anti-backsliding, then leaps to the conclusory 15 statement that, "All effluent limitations in this Order are at least as stringent as the effluent 16 limitations in the previous permit." (2012 Permit, at p. 25, Finding N.) However, bare 17 conclusions are impermissible. (See, American Funeral Concepts -American Cremation Soc'y, 136 18 Cal.App.3d at 309 ("administrative findings set forth solely in the language of the applicable 19 legislation are insufficient").) 20 Similarly, there is insufficient evidence to support the Regional Board's decision to adopt 21 the safe harbor provisions allowed for Permittees under an EWMP. Participation in an EWMP 22 23 September 15, 2006 Re: CTR Compliance Schedules; State Board Resolution No. 2008-0025 at 4; 24 Final Staff Report, State Board Resolution No. 2008-0025 at 10; Final Response to Written Comments, State Board Resolution No. 2008-0025 at 6, 9, 10, 18-19, 26. 25 68 As is discussed in section III.A.3.b., the 2012 Permit's discussion of antidegradation requirements is another stark example of the lack of sufficient findings and evidentiary support. 26 69 See Letter from NRDC, Los Angeles Waterkeeper, and Heal the Bay to Regional Board re: 27 Comments on Tentative Order R4-2012-XXXX, Los Angeles County MS4 Permit, June 6, 2012 Draft, July 23, 2012; NRDC, Los Angeles Waterkeeper and Heal the Bay also presented on this 28 issue at the October 4-5 and November 8 Regional Board Hearings on the 2012 Permit. Memomndum of P's and A's Page 28 Comment Lettet 1 requires retention of runoff from the 85 h percentile, 24-hour storm in exchange for safe harbors. 2 (Permit, at Part VLE.2.e.i.(4).) Yet there is no evidence in the record for the 2012 Permit's 3 adoption to demonstrate that retention of the 85h percentile storm event will, in fact, achieve 4 compliance with either Water Quality Standards required under the Receiving Water Limitations, 5 or with the numerous TMDL WLAs required to be met in the 2012 Permit. At the November 8, 6 2012 Hearing, EPA specifically questioned the adequacy of the record on this point: 7 [T]hc EPA guidance on incorporating TMDLs into ... MS4 permits that has been around since 2002 talks about when you come up with a BMP -based approach for 8 incorporating a TMDL into a permit—so basically this is a BMP -based approach. You would be retaining the 85`h percentile storm—you have to have in the record 9 for the permit the justification for how that gets to those specific wasteload allocations... . 10 We've been very involved with the county's modeling and ... we don't have that 11 rigorous analysis that's been—that's required by the EPA guidance for saying and 12 showing that that specific retention is going to achieve the numeric wasteload allocation.... I haven't seen the support in the administrative record, the fact sheet 13 or otherwise.' 14 Following EPA's observation, the Regional Board Chair asked staff directly if the evidence 15 requested by EPA was in the record.72 The Board's Executive Officer, Mr. Unger replied: 16 Yes. Yes. It was discussed when the county first presented at the last hearing, the enhanced management approach, they discussed their—the watershed modeling 17 system that they would be using to demonstrate a reasonable assurance. 73 18 However, the record, including watershed modeling discussed by Los Angeles County, does not 19 anywhere demonstrate that retention of the 85 h percentile storm will protect water quality 20 standards or achieve TMDL WLAs as required by the Clean Water Act or EPA guidance. 21 In fact, the County's presentation demonstrates only that, in its view, the 85t11 percentile 22 storm represents a cost-effective or "appropriate design storm [size] for use in BMP planning and 23 design" for treatment of stormwater runoff,74 not, as Regional Board staff appear to indicate, that 24 25 70 Mr. John Kemmerer, EPA, November 8 Hearing, at 365:24-25 to 366:1-7. 71 Mr. John Kemmerer, EPA, November 8 Hearing, at 366:10-18; 367:6-8. 26 72 See, Ms. Maria Mehranian, Regional Board Chair, November 8 Hearing, at 368:13-14 (stating 27 "So—I'm sorry ... it is in the record?"). 73 Mr. Sam Unger, at 368:15-19. 28 74 Mr. Gary Hildebrand, November 8 Hearing, at 220: 18-19. Memomndum of P's and A's Page 29 116 H 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter retention of the 85th percentile storm will achieve required WLAs for all TMDLs in all watersheds covered by the permit. At both the October 4-5 Hearing and November 8 Hearing, the County discussed the decision to select the 85th percentile storm and acknowledged it was based on cost and treatment considerations: This concept involves the identification of a storm of specific size, the intensity, and/or duration for use in design stormwater controls to achieve water quality standards that balances cost with pollutant removal efficiency... . 75 The [projected] graph plots the total cost of BMPs needed throughout LA County to comply with all the TMDLs expected in the new permit against various size storm events. As can be seen, the most optimum storm size is the 85th percentile storm event 76 Thus, the County's explanation does not demonstrate a discernible relationship between the 85`h percentile retention approach and full achievement of TMDL WLAs just that the 85th percentile storm is a cost-effective cut-off point for pollution control measures. 77 Nor do the County or the Regional Board provide data, analysis, or in the Regional Board's case, findings to support that this BMP -based approach will achieve applicable WLAs 78 or demonstrate the validity of the County's model.79 Accordingly, the Regional Board's 75 Mr. Gary Hildebrand, November 8 Hearing, at 220: 20-24. Regional Board Staff also indicated their understanding that selection of the 85`h percentile storm was a cost consideration, not an independent assessment of the storm size required to be retained to meet applicable TMDL WLAs. See, Mr. Sam Unger, November 8 Hearing, at 360:14-17 ("when you look at that curve, sort of a dollars versus precipitation event occurred, right about that 85th percentile—right at the 85`h percentile, the curve trends up very markedly."). 76 Mr. Gary Hildebrand, October 4 Hearing, at 308:7-12. 77 The same concern rises for compliance with the Permit's Receiving Water Limitations— retention of the 85th percentile storm represents only, in the County's view, a cost effective upper limit for a design storm. This does not stand for the proposition that retention will then achieve water quality standards for all receiving waters in all conditions. 7' 40 C.F.R. § 122.44(d)(1)(vii)(B); see also, EPA Hanlon Memo. 79 We note that to the extent the Regional Board may have relied on additional information submitted by the County related to selection of the 85th percentile storm submitted after July 23, this evidence is not part of the record. In the agenda for the October 4-5 and the November 8 Hearings, the Regional Board stated unequivocally that "No new written materials may be submitted on the Tentative Order ... Written comments were due by noon on July 23, 2012." (October 4-5 Agenda, at, 2; see also, Notice of Opportunity for Comment, October 18, at 2. Memomndum of P's and A's Page 30 R 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment decision to include the EWMP safe harbors in the 2012 Permit was arbitrary and capricious. IV. CONCLUSION For all the foregoing reasons, the instant Petition for Review should be GRANTED. Respectfully submitted, Dated: December 10, 2012 NATURAL RESOURCES DEFENSE COUNCIL, INC. Noah Garrison Steve Fleischli Attorneys for NATURAL RESOURCES DEFENSE COUNCIL, INC. & HEAL THE BAY Dated: December 10, 2012 Memomndum of P's and A's Page 31 LOS ANGELES WATERKEEPER Elizabeth Crosson Tatiana Gaur Attorneys for LOS ANGELES WATERKEEPER & HEAL THE BAY 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letterl16 PROOF OF SERVICE I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a parry to the within action. My business address is: 1314 Second Street, Santa Monica, California 90401. On December 10, 2012 I served the within document described as MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PETITION FOR REVIEW OF LOS ANGELES REGIONAL WATER QUALITY CONTROL BOARD ACTION OF ADOPTING ORDER NO. R4-2012-0175 on the following interested parties in said action by placing a true copy thereof in the United States mail enclosed in a sealed envelope with postage prepaid, addressed as follows: Ken Berkman City Engineer 30001 Ladyface Court Agoura Hills, CA 91301 David Dolphin 111 South First Street Alhambra, CA 91801-3796 Susannah Turney Environmental Services Officer P.O. Box 60021 Arcadia, CA 91066-6021 Maria Dadian Director of Public Works 18747 Clarkdale Avenue Artesia, CA 90701-5899 Carl Hassel City Engineer 213 East Foothill Boulevard Azusa, CA 91702 David Lopez Associate Engineer 14403 East Pacific Avenue Baldwin Park, CA 91706-4297 Terri Rodrigue City Engineer 6330 Pine Avenue Bell, CA 90201-1291 John Oropeza Director of Public Works 7100 South Garfield Avenue Bell Gardens, CA 90201-3293 Bernie Iniguez Environmental Services Manager 16600 Civic Center Drive Bellflower, CA 90706-5494 Vincent Chee Project Civil Engineer 455 North Rexford Drive Beverly Hills, CA 90210 Elroy Kiepke City Engineer 600 Winston Avenue Bradbury, CA 91010-1199 Bonnie Teaford Public Works Director P.O. Box 6459 Burbank, CA 91510 1 2 3 4 5 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Alex Farassati ESM 100 Civic Center Way Calabasas, CA 91302-3172 Mike O'Grady Environmental Services P.O. Box 3130 Cerritos, CA 90703-3130 Gina Nila 2535 Commerce Way Commerce, CA 90040-1487 Comment Letterl16 Patricia Elkins Building Construction Manager P.O. Box 6234 Carson, CA 90745 Craig Bradshaw City Engineer 207 Harvard Avenue Claremont, CA 91711-4719 Hien Nguyen Assistant City Engineer 205 South Willowbrook Avenue Compton, CA 90220-3190 Vivian Castro, Environmental Services Hector Rodriguez Manager City Manager 125 East College Street P.O. Box 1007 Covina, CA 91723-2199 Cudahy, CA 90201-6097 Damian Skinner Manager 9770 Culver Boulevard Culver City, CA 90232-0507 Yvonne Blumberg P.O. Box 7016 Downey, CA 90241-7016 James A Enriquez Director of Public Works P.O. Box 6008 El Monte, CA 91731 Ron Jackson Building Maintenance Supervisor P.O. Box 47003 Gardena, CA 90247-3778 Dave Davies Deputy Director of Public Works 116 East Foothill Boulevard Glendora, CA 91741 David Liu Director of Public Works 21825 East Copley Drive Diamond Bar, CA 91765-4177 Steve Esbenshades Engineering Division Manager 1600 Huntington Drive Duarte, CA 91010-2592 Stephanie Katsouleas Public Works Director 350 Main Street El Segundo, CA 90245-3895 Maurice Oillataguerre Senior Environmental Program Scientist Engineering Section 633 East Broadway, Room 209 Glendale, CA 91206-4308 Joseph Colombo Director of Community Development 21815 Pioneer Boulevard Hawaiian Gardens, CA 90716 1 2 3 4 5 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Arnold Shadbehr Homayoun Behboodi Chief General Service and Public Works Associate Engineer 4455 West 126th Street 1315 Valley Drive Hawthorne, CA 90250-4482 Hermosa Beach, CA 90254-3884 Kimberly Colberts Environmental Coordinator 6165 Spring Valley Road Hidden Hills, CA 91302 Mike Nagaoka Director of Public Safety P.O. Box 3366 Industry, CA 91744-3995 Kwok Tam Director of Public Works 5050 North Irwindale Avenue Irwindale, CA 91706 Shauna Clark City Manager 1245 North Hacienda Boulevard La Habra Heights, CA 90631-2570 John DiMario Director of Development Services 15900 East Marin Street La Puente, CA 91744-4788 Konya Vivanti P.O. Box 158 Lakewood, CA 90714-0158 Tom A. Odom City Administrator P.O. Box 339 Lomita, CA 90717-0098 Josef Kekula 11330 Bullis Road Lynwood, CA 90262-3693 Craig Melich City Engineer and City Official 6550 Miles Avenue Huntington Park, CA 90255 Lauren Amimoto Senior Administrative Analyst 1 W. Manchester Blvd, 3rd Floor Inglewood, CA 90301-1750 Edward G. Hitti Director of Public Works 1327 Foothill Boulevard La Canada Flintridge, CA 91011-2137 Steve Forster Public Works Director 13700 La Mirada Boulevard La Mirada, CA 90638-0828 Daniel Keesey Director of Public Works 3660 "D" Street La Verne, CA 91750-3599 Marlene Miyoshi Senior Administrative Analyst 14717 Burin Avenue Lawndale, CA 90260 Shahram Kharaghani Program Manager 1149 S. Broadway, 10th Floor Los Angeles, CA 90015 Jennifer Brown Environmental Program Analyst 23825 Stuart Ranch Road Malibu, CA 90265-4861 16 1 2 3 4 5 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Brian Wright Water Supervisor 1400 Highland Avenue Manhattan Beach, CA 90266-4795 Heather Maloney 415 South Ivy Avenue Monrovia, CA 91016-2888 Amy Ho John Hunter (Consultant) 320 West Newmark Avenue Monterey Park, CA 91754-2896 Allan Rigg Director of Public Works 340 Palos Verdes Drive West Palos Verdes Estates, CA 90274 Stephen Walker P.O. Box 7115 Pasadena, CA 91109-7215 Julie Carver Environmental Programs Coordinator P.O. Box 660 Pomona, CA 91769-0660 Mike Shay Principal Civil Engineer P.O. Box 270 Redondo Beach, CA 90277-0270 Greg Grammer Assistant to the City Manager 4045 Palos Verdes Drive North Rolling Hills Estates, CA 90274 Latoya Cyrus Environmental Services Coordinator 245 East Bonita Avenue San Dimas, CA 91773-3002 Comment Letter 116 Andre Dupret Project Manager 4319 East Slauson Avenue Maywood, CA 90270-2897 Cory Roberts 1600 West Beverly Boulevard Montebello, CA 90640-3970 Chino Consunji City Engineer P.O. Box 1030 Norwalk, CA 90651-1030 Chris Cash Utility and Infrastructure Assistant Director 16400 Colorado Avenue Paramount, CA 90723-5091 Art Cervantes Director of Public Works P.O. Box 1016 Pico Rivera, CA 90660-1016 Ray Holland Interim Public Works Director 30940 Hawthorne Boulevard Rancho Palos Verdes, CA 90275 Greg Grammer Assistant to the City Manager 2 Portuguese Bend Road Rolling Hills, CA 90274-5199 Chris Marcarello Director of PW 8838 East Valley Boulevard Rosemead, CA 91770-1787 Ron Ruiz Director of Public Works 117 Macneil Street San Fernando, CA 91340 1 2 3 4 5 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Daren T. Grilley City Engineer 425 South Mission Drive San Gabriel, CA 91775 Comment Chuck Richie Director of Parks and Public Works 2200 Huntington Drive San Marino, CA 91108-2691 Travis Lange Sarina Morales -Choate Environmental Services Manager Civil Engineer Assistant 23920 West Valencia Blvd, Suite 300 P.O. Box 2120 Santa Clarita, CA 91355 Santa Fe Springs, CA 90670-2120 Neal Shapiro Urban Runoff Coordinator 1685 Main Street Santa Monica, CA 90401-3295 John Hunter 2175 Cherry Avenue Signal Hill, CA 90755 John Hunter 8650 California Avenue South Gate, CA 90280 Leslie Cortez Senior Administrative Assistant 3031 Torrance Boulevard Torrance, CA 90503-5059 Jack Yoshino Senior Management Assistant P.O. Box 682 Walnut, CA 91788 Sharon Perlstein City Engineer 8300 Santa Monica Boulevard West Hollywood, CA 90069-4314 David Mochizuki Director of Public Works 13230 Penn Street Whittier, CA 90602-1772 James Carlson Management Analyst 232 West Sierra Madre Boulevard Sierra Madre, CA 91024-2312 John Hunter 1414 Mission Street South Pasadena, CA 91030-3298 Joe Lambert John Hunter 9701 Las Tunas Drive Temple City, CA 91780-2249 Claudia Arellano 4305 Santa Fe Avenue Vernon, CA 90058-1786 Samuel Gutierrez Engineering Technician P.O. Box 1440 West Covina, CA 91793-1440 Roxanne Hughes Stormwater Program Coordinator 31200 Oak Crest Drive Westlake Village, CA 91361 Gary Hildebrand Assistant Deputy Director, Division Engineer 900 South Fremont Avenue Alhambra, CA 91803 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Comment Letter 16 I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. It is deposited with U.S. postal service on that same day in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid if postal cancellation date or postage meter date is more than 1 day after date of deposit for mailing in affidavit. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on December 10, 2012, at Santa Monica, California. Anna Kheyfets Comment Letter 16 NRDC LOS ANGELES Heal the Bay March 9, 2015 Via electronic mail Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont Avenue, 5"' Floor Alhambra, CA 91803 Email: gbegell@dpw.lacounty.gov Re: Comments on Los Angeles County Draft Program Environmental Impact Report for Enhanced Watershed Management Programs under the Los Angeles County Municipal Separate Storm Sewer System Permit, NPDES Permit No. CAS004001, Order No. R4-2012-0175 Dear Mr. BeGell: On behalf of the Natural Resources Defense Council ("NRDC"), Los Angeles Waterkeeper ("Waterkeeper"), and Heal the Bay (collectively, "Environmental Groups"), we are writing with regard to the Draft Program Environmental Impact Report ("PEIR") for the 12 Enhanced Watershed Management Programs ("EWMP") under the 2012 Los Angeles County Municipal Separate Storm Sewer System Permit ("2012 MS4 Permit" or "2012 Permit").' We appreciate the opportunity to submit these comments to the Los Angeles County Department of Public Work's Flood Control District. ("LACFCD"). L Introduction As an initial matter, Environmental Groups' comments on the EWMP Draft PEIR should not be construed as approval or acceptance of the 2012 Permit terms. We continue to maintain that several provisions of the Permit fail to meet the requirements of the federal Clean Water Act and California Porter Cologne Act, and are otherwise inconsistent with ' The Enhanced Watershed Management Programs addressed in the Program Environmental Impact Report ("PEM") encompass several watersheds of Los Angeles County including the following: Ballona Creek, Beach Cities, Dominguez Channel, Malibu Creek, Marina del Rey, North Santa Monica Bay Coastal Watersheds, Palos Verdes Peninsula, Rio Hondo/San Gabriel River Water Quality Group, Santa Monica Bay, Upper Los Angeles River, Upper San Gabriel River, and Upper Santa Clara River. Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 12 both federal and state law. Environmental Groups filed a petition with the State Water Resources Control Board ("State Board"), which demonstrates the ways in which the 2012 Permit violates these legal requirements. The State Board has yet to make a determination on our petition. Under the 2012 Permit, permittees electing to participate in an EWMP are required to submit a draft EWMP plan by June 2015. (2012 Permit, at VI.C.4.c.iv.) The EWMP Work Plans submitted by permittees in June 2014 presented an opportunity for permittees to demonstrate their commitment to developing EWMPs to meet required Receiving Water Limitations ("RWLs") and Total Maximum Daily Load ("TMDL") provisions. Environmental Groups reviewed the EWMP Work Plans and submitted comments to the Regional Board .3 As we expressed in our comments, many permittees have made significant progress towards developing their draft EWMPs. However, the Work Plans are in many instances unclear as to what analysis or programs will ultimately be incorporated into final EWMPs to be submitted to the Regional Board in June 2015. In fact, some of the Work Plans clearly indicate that the permittees' management programs, as currently envisioned, will not ensure that discharges from the permittees' MS4 systems do not cause or contribute to exceedances of RWLs, including applicable water quality standards, or TMDL limitations in the 2012 Permit, and otherwise fail to meet Permit requirements. EWMP Work Plan deficiencies do not bode well for the June 2015 Draft EWMPs, and this CEQA process is an opportunity for LACFCD and EWMP permittees to address our concerns with program development thus far. The Regional Board -approved delay in progress toward compliance with water quality based effluent limits ("WQBELs") and RWLs for EWMP permittees cannot pass lightly—the draft plans submitted by EWMP groups in June 2015 must fully and clearly demonstrate a path to compliance and cleaner waters for the region. To this extent, any identified deficiencies with the EWMP Work Plans must be addressed prior to submission of the draft EWMPs in 2015, and should also be addressed in this PEIR to fully assess the potential environmental impacts of the program. ' For a full explanation of how the permit violates the law, see Memorandum of Points and Authorities in Support of Petition of NRDC, Los Angeles Waterkeeper and Heal the Bay for Review of Action by the California Regional Water Quality Control Board, Los Angeles Region, in Adopting the Los Angeles County Municipal Separate Stormwater National Pollutant Discharge Elimination System (NPDES) Permit; Order No. R4-2012-0175; NPDES Permit No. CAS004001 (Dec, 10, 2012) ("Environmental Groups' Petition"), SWRCB/OCC File No. A -2236(m), attached as Exhibit A- ' See Environmental Groups' Comments on Enhanced Watershed Management Work Plans and Monitoring Plans Pursuant to Requirements under the Los Angeles County Municipal Separate Storm Sewer System Permit, NPDES Permit No. CAS004001, Order No. R4-2012-0175, submitted to the Regional Board September 16, 2014, attached as Exhibit B. Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 13 II. General Comments Environmental Groups have categorized comments into general comments about the approach in the PEIR and some specific comments about the PEIR analysis. Because the approach in the Draft PEIR will likely follow to the management programs due in June 2015, LACFCD should take this important opportunity to revise the Draft PEIR to address the concerns articulated below. A. Inadequate Information Related to Ensuring Compliance with Required Water Ouality Limits Undermines the Success of the PEIR In areas of the permittees' jurisdictions where retention of the 85' percentile, 24-hour storm event is not technically feasible, EWMPs must include other watershed control measures to "ensure that MS4 discharges achieve compliance with all interim and final WQBELs set forth in Part VLE.... and [] ensure that MS4 discharges do not cause or contribute to exceedances of receiving water limitations in Part V.A." (Id. at VI.C.l.g.v.) In several instances, the Draft PEIR acknowledges this legal obligation and claims that planning efforts are aimed towards that goal. However, whether the environmental impact of the program will indeed include compliance remains uncertain. In fact, based on Environmental Groups' review of several of the EWMP Work Plans related to the Draft PEIR and the very general information included in the Draft PEIR, the actual environmental impact of the EWMPs is difficult to determine. Deficiencies identified in the EWMP Work Plans potentially undermine statements of intended compliance in the PEIR. Thus, Environmental Groups urge LACFCD to clarify several issues related to assuring ultimate compliance with water quality limits. First, several EWMP Work Plans related to the Draft PEIR insufficiently prioritize pollutants as required in the 2012 MS4 Permit. Permittees are required to prioritize pollutants into three categories: (1) TMDL pollutants (highest priority), (2) 303(d) listed but no applicable TMDL (high priority), and (3) insufficient data to determine impairment, but exceeds RWLs (medium priority). Category (1) must also include non- TMDL pollutants that have similar fate and transport mechanisms as TMDL pollutants. (2012 Permit, at VI.C.2.a.i.) Prioritization is essential to ensuring compliance with required limits. Some of the deficiencies in prioritization include failing to include priority pollutants,' and failing to justify exclusion of some pollutants.' Additionally, permittees have set incorrect timelines for TMDL implementation and compliance in ° See North Santa Monica Bay Coastal Watersheds EWMP Work Plan, at 18; see also Upper Santa Clara River EWMP Work Plan, at 3-4; see also Upper Los Angeles River EWMP Work Plan, at Appendix 2.A. (lacks explanation of why Total Aluminum is not included as a priority despite data demonstrating exceedances). ' See North Santa Monica Bay Coastal Watersheds EWMP Work Plan, at 18. Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 14 some cases.6 Without adequately characterizing each watershed and prioritizing the right pollutants, it is impossible to fully assess the environmental impacts of the proposed programs under CEQA. Environmental Groups understand that the EWMPs are still in development, but this PEIR must include a process and approach that complies with permit terms to fully evaluate the impacts of proposed actions. B. Green Infrastructure Should Be Prioritized Wherever Feasible Environmental Groups commend the LACFCD for proposing multi -benefit stormwater projects that emphasize flood risk mitigation, water conservation and water supply. In light of the fact that the LACFCD has a vested interest in increasing opportunities for stormwater capture and groundwater recharge as a means of assisting local water supply and augmentation, we urge the LACFCD to work with Permittees in all 12 EWMP watersheds to prioritize green infrastructure or low -impact development (LID) practices wherever feasible, and provided that such projects do not produce significant adverse impacts. Environmental Groups have long supported the use of green infrastructure techniques to control urban runoff. Green infrastructure provides multiple benefits to surrounding communities at a higher benefit -cost ratio when compared to grey infrastructure.' A 2007 U.S. Environmental Protection Agency (EPA) study found that "in the vast majority of cases ... implementing well-chosen LID practices saves money for developers, property owners, and communities while protecting and restoring water quality."' With only "a few exceptions," the EPA study found that "[t]otal capital cost savings ranged from 15 to 80 percent when LID methods were used" instead of conventional stormwater management techniques.9 The EPA study is not alone in reaching this conclusion. A report by ECONorthwest concluded that LID methods not only "cost less to install, have lower operations and maintenance (O&M) costs, and provide more cost-effective stormwater management and water -quality than conventional stormwater controls" but they also provide "ecosystem services and associated economic benefits that conventional 'See Balloon Creek EWMP Work Plan, at 1-10 (failure to include interim milestones); see also Rio Hondo/San Gabriel River EWMP Work Plan, Table 1-2, at 2 (failure to include interim and final compliance deadlines); see also Upper Los Angeles River EWMP Work Plan, at 2-7, 2-9 (compliance deadlines exceed allowable deadlines under the Inland Surface Water Plan). U.S. Environmental Protection Agency, Case Studies Analyzing the Economic Benefits ofLow Impact Development and Green Infrastructure Programs (August 2013), available at http://water.epa.gov/polwaste/green/upload/lid-gi-programs report 8-6-13 combined.pdf. a U.S. Environmental Protection Agency, Reducing Stormwater Costs through Low Impact Development (LID) Strategies and Practices, December 2007, at iii. available at http://water.epa.Qov/polwaste/green/upload/2008 01 02 NPS lid costs07uments reducingstormwatercost s-2.pdf. 9 Id. at iv. Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 15 stormwater controls do not. 10 Moreover, a survey released by the American Society of Landscape Architects in 2011 found that green infrastructure reduced or did not influence project costs 75 percent of the time.i" Given the current severe drought conditions, protecting and augmenting local water supplies is essential for long-term sustainability. A report by the NRDC found that implementing LID practices at new and redeveloped residential and commercial properties in urbanized areas of Southern California and limited portions of San Francisco Bay has the potential to increase local water supplies by up to 405,000 acre- feet of water per year by 2030.12 This volume of water accounts for roughly two-thirds of all water used by the City of Los Angeles each year. 11 Historically, Southern California has imported approximately 50 percent of its water supply from distant, energy -intensive sources such as the Sacramento -San Joaquin Delta and the Colorado River. 14 Green infrastructure thus has the potential to greatly reduce Los Angeles' dependence on imported water. Last but not least, Environmental Groups strongly advocate for the implementation of structural BMPs (distributed, centralized, and regional) that capture stormwater and store it for reuse — so long as they do not produce significant adverse impacts — as such practices provide both water quality and water supply benefits. III. Specific Concerns in the PEIR Section 3.5 — Geolo¢ic and Mineral Resources Impact 3.5-2: "The proposed program could result in substantial soil erosion or the loss of top soil." The Draft PEIR states environmental impacts associated with substantial soil erosion or loss of top soil are less than significant. Environmental Groups disagree. EWMP projects are encouraged to retain the 85' percentile 24-hour storm event; however, it is unclear that all EWMP BMPs will retain this volume and even if they did, in some instances some volume of runoff will remain untreated. Thus, at least some percentage of stormwater generated, which will vary depending on individual EWMPs, will be treated and discharged into the MS4. Although discharge points from centralized and 10 ECONorthwest, The Economics ofLow Impact Development: A Literature Review, November 2007, at 4, available at http://www.econw.com/media/ap files/ECONorthwest-Economics-of-LID-Literature- Review 2007.pdf, " Stormwater Case Studies, American Society of Landscape Architects, available at http://www.asla.org/storinwatercasestudies.aspx. 12 Natural Resources Defense Council, A Clear Blue Future: How Greening California Cities Can Address Water Resources and Climate Challenges in the 21" Century, August 2009, at 4, available at http://www.nrdc.org/water/lid/files/lid hi.pdf ("A Clear Blue Future"). 13 Id. 14 Id., at 18-19. Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 16 distributed BMPs would be designed to minimize scour potential, soil erosion and loss of top soil are still likely to occur during precipitation events. Los Angeles County contains over 110 soft bottom reaches — increased scour and loss of top soil could severely affect beneficial uses of these reaches. In addition, the 2012 Permit outlines specific hydromodification requirements — it is unclear if the Draft PEIR is consistent with hydromodification provisions in the 2012 Permit. The Final PEIR needs to address all potential soil erosion and loss of top soil scenarios and needs to reference the hydromodification provisions outlined on pg. 105 of the 2012 Permit. Impact 3.5-5: "The proposed program could have soils incapable of adequately supporting the use of a septic tank or alternative wastewater treatment systems where sewers are not available for the disposal of wastewater." Environmental Groups are concerned with wastewater created in areas incapable of adequate disposal options (sewer system or septic tanks). In the event that implemented BMPs generate wastewater and cannot properly dispose of wastes via sewer system or septic tanks, the Final PEIR needs to outline how waste will be managed (Le. tank, truck, etc.). In addition, the Final PEIR should reference the State Board's Water Quality Control Policy for Siting, Design, Operation, and Maintenance of Onsite Wastewater Treatment Systems and General Waste Discharge Requirements for Small Domestic Wastewater Treatment Systems (Order WQ 2014-0153-DWQ) when soils are capable of supporting the use of septic tanks. Cumulative Impact/GEO-2: "Prior to installing BMPs designed to recharge local groundwater supplies, the Implementation Agency shall notify local groundwater manager including the Upper Los Angeles River Area Water Master, the Water Replenishment District of Southern California, or the San Gabriel Water Master as well as local water producers such as local municipalities and water companies. The Implementing Agency shall coordinate BMP siting efforts with groundwater managers and producers to mitigate high groundwater levels while increasing local water supplies." Environmental Groups agree Implementation Agencies should always notify local groundwater managers and producers before stormwater BMPs are implemented, however, the Draft PEIR fails to acknowledge or reference Salt and Nutrient Management Plans being developed and implemented for Los Angeles County groundwater basins. These Plans outline groundwater inputs and exports as well as identify basins' assimilative capacities. We believe the Final PEIR needs to discuss EWMP coordination with Salt and Nutrient Management Plans. In the light of climate change, protecting while simultaneously contributing to Los Angeles' local water supply is essential for long-term water sustainability. Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 17 Section 3.7 — Hazards and Hazardous Materials Impact 3.7-2: "The proposed program could create a significant hazard to the public or the environment through the accumulation of potentially hazardous materials into BMPs." HAZ-1: "Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the individual BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater." Environmental Groups support Implementing Agencies' development of BMP Maintenance Plans outlining BMP maintenancepractices as this is necessary to sustain stormwater BMP efficacies. Yet we want to highlight the all -too -common shortcoming Implementing Agencies encounter in operations and maintenance of storm water BMPs —failure to devote adequate resources. Bolstering of agencies' resources, such as additional staffing, training, and funding mechanisms, is necessary and commonly overlooked in the implementation of BMP maintenance plans. Without acknowledging Implementation Agency resources while implementing BMP Maintenance Plants, it is unlikely EWMPs' discharges will comply with water quality standards in the long-term. The Final PEIR needs to expand HAZ-1 to discuss additional agencies' resources needed to implement BMP Maintenance Plans. Section 3.8: Hydrology and Water Quality Impact 3.8-1: "The proposed project would result in higher groundwater levels and could potentially affect groundwater quality" See Cumulative Impact/GEO-2 response above. Impact 3.8-2: "The proposed project could substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river, or by other means, in a manner that would result in substantial erosion or siltation on- or off- site." See Impact 3.5-2 response above. Comment Letter 16 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works March 9, 2015 Page 18 Iv, Conclusion Environmental Groups appreciate this opportunity to comment on the Draft PEIR submitted by the LACFCD for the 12 EWMP groups. Please feel free to contact us with any questions or concerns you may have. Sincerely, eo� Liz Crosson Executive Director Los Angeles Waterkeeper Becky Hayat Staff Attorney Natural Resources Defense Council 1),,k, Ju PeterShellenbarger Water Resources Manager Heal the Bay to Comments Response to Comment Letter 16 (Los Angeles Water Keeper — March 9, 2015) Response to Comment 16-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. As noted on page 1-1 of the PEIR, the Regional Water Quality Control Board issued Order No. R4-2012-0175; NPDES No. CAS004001 in December 2012 covering discharges from multiple municipalities within the Los Angeles Region. The requirements of the MS4 permit are described in Section 1.2 of the PEIR. A primary objective of the proposed program noted on page 2-2 is to comply with the permit requirements. The EWMPs include a methodology required by the MS4 permit to evaluate the effectiveness of the BMPs as they are implemented. The commenter's opinion about the ability of the permit to meet the requirements of the Clean Water Act does not address the adequacy of the PEIR. The PEIR does not critique the effectiveness of the permit to achieve compliance with the Clean Water Act, but rather it evaluates the potential environmental effects that could result from implementing the types of projects proposed in the EWMPs. Response to Comment 16-B: The PEIR acknowledges that most of the projects to be included in the EWMPs are either currently undefined or currently under development. The PEIR explains that EWMPs are being prepared that will contain road maps to permit compliance for each of the 12 watersheds, without yet being fully detailed. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. The PEIR evaluates typical project types to assess potential impacts of implementing the entire program throughout the region over a long period of time. The use of a PEIR pursuant to CEQA Guidelines Section 15168 is intended to evaluate broad-based impacts early in the planning process and is the appropriate CEQA compliance for the EWMPs at this time. Response to Comment 16-C: The permit outlines a required schedule for EWMP preparation that includes project types, priority projects, reasonable assurance analysis, funding prospects, and public review requirements of the EWMPs. The Permittees may be required by the RWQCB to modify the EWMPs as time goes by in order to effectuate compliance. However, the commenter's opinion on the effectiveness of the permit to achieve compliance with the Clean Water Act does not address the adequacy of the PEIR. a County Flood Control District 11-145 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Comment 16-D: The commenter's opinion on the effectiveness of the permit to achieve compliance with the Clean Water Act does not address the adequacy of the PEIR. A PEIR is appropriate when multiple projects are contemplated under a single program that may individually or cumulatively impact the environment. The PEIR compiles reasonably available information on potential projects and environmental conditions over a large geography. Each project is designed to incrementally improve water quality. The PEIR provides preliminary location information in Appendix G for each project currently being contemplated. Although project details are largely incomplete since the EWMPs are being drafted concurrently, each individual project will be subject to a CEQA compliance evaluation prior to approval by the implementing agencies as noted in Section 1. Changes in the EWMPs as they are developed will not undermine the analysis of the overall program. The PEIR as an advanced planning tool provides an early environmental assessment of the overall EWMP compliance approach to assist Permittees in assessing individual projects. Response to Comment 16-E: The commenter's opinion on the prioritization of pollutants needed to achieve compliance with the Clean Water Act does not address the adequacy of the PEIR. The PEIR compiles reasonably available information on potential projects and environmental conditions over a large geography. Each project is designed to incrementally improve water quality. The PEIR provides preliminary location information in Appendix G for each project currently being contemplated. Although project details are largely incomplete since the EWMPs are being drafted concurrently, each individual project will be subject to a CEQA compliance evaluation prior to approval by the implementing agencies as noted in Section 1. Changes in the EWMPs as they are developed will not undermine the analysis of the overall program. The PEIR as an advanced planning tool provides an early environmental assessment of the overall EWMP compliance approach to assist Permittees in assessing individual projects. Response to Comment 16-F: The PEIR evaluates implementation of BMP types that include green infrastructure and low - impact development practices. The EWMPs include lists of projects each designed to improve surface water quality in the region. Response to Comment 16-G: The PEIR evaluates implementation of BMP types that include green infrastructure and low - impact development practices. The EWMPs include lists of projects each designed to improve surface water quality in the region. Response to Comment 16-H: The PEIR evaluates implementation of BMP types that include green infrastructure and low - impact development practices. The EWMPs include lists of projects each designed to improve surface water quality in the region. LA County Flood Control District 11-146 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Comment 164: The PEIR evaluates implementation of distributed, centralized and regional structural BMPs that capture and store stormwater. Potentially significant impacts of BMP implementation are discussed and mitigation measures identified to avoid or reduce potential adverse effects to the environment. Response to Comment 16-J: Although the implementation of BMPs will not eliminate soil erosion in the region, each BMP is designed to reduce pollutant loading into receiving waters. These pollutants can often absorb to sediment particles and impair water quality. The PEIR evaluates potential impacts of BMP construction on soil erosion on page 3.8-33. The PEIR notes on page 3.8-37 that implementation of BMPs will assist in reducing erosion and pollutants in the region. Therefore, impacts resulting from program implementation are less than significant since water quality would improve compared with existing conditions. Mitigation Measure HYDRO -4 has been added to the PEIR under Impact discussion 3.8-3 to address potential hydromodification impacts related to the implementation of structural BMPs. The following modifications have been included in Chapter 12, Clarifications and Modifications of the Final PEIR. The Draft EIR discusses potential impacts caused by erosion and sedimentation on page 3.8-37. Mitigation Measure HYDRO -4 has been added to ensure that these impacts remain less than significant. The modification does not identify any new significant impact or trigger the need to recirculate the Draft PEIR under Section 15088.5 of the CEQA Guidelines. Page 3.8-37 has been edited as follows: Drainage Pattern Alteration Resulting in Erosion or Siltation Impact 3.8-3: The proposed project could substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river, or by other means, in a manner that would result in substantial erosion or siltation on - or off-site, Structural (Regional, Centralized, and Distributed) BMPs The proposed structural BMPs would be designed to minimize off-site discharge of urban runoff pollutants including siltation and sedimentation. Many of the structural BMPs would include on-site infiltration of stormwater runoff which would also be effective in minimizing erosion or transport of sedimentation into receiving waters. Through increased infiltration prior to discharge into receiving waters, flows within existing streams or rivers would receive reduced stormwater flow volumes thereby decreasing flow energies. Therefore, as part of imDlementation of Mitigation Measure HYDRO -4, imDlementing agencies would evaluate the Potential hvdromodification impacts of structural BMPs and include measures to Prevent or minimize any identified impacts in the design of the BMPs, including selecting and designing discharge locations to prevent a County Flood Control District 11-147 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments or minimize erosion and scour. As a result, the potential for erosion or siltation within existing streams or rivers would be reduced and the potential impact less than significant. Mitigation Measures: HYDRO -4: Prior to approving a structural BMP, the implementing agencies shall conduct an evaluation of the potential hydromodification impacts of the project. The evaluation shall recommend design measures necessary to prevent or minimize any identified impacts, including flooding, erosion and/or scour. Design measures could include velocity dissipaters and bank re -enforcement components. Implementing agencies shall include these measures in project designs. Significance Determination: Less than significant Page 3.8-38 has been edited as follows: Drainage Pattern Alteration Resulting in Flooding Impact 3.8-4: The project could substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river or, by other means, substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site, Structural (Regional, Centralized, and Distributed) BMPs The proposed structural BMPs include features that would increase stormwater retention and encourage on-site infiltration to reverse the impacts from urbanization on the natural hydrograph. The widespread :.....t,...,,.ntation of disb:butea BN4Ps with these function., in 3.r. Larger retention and infiltration regional and centralized BMPs would have a beneficial effect on regional hydrology through delayed discharge to avoid the spike in peak flows currently experienced. By retaining stormwater flows and either infiltrating or releasing these flows closer to the natural hydrograph, the change in drainage patterns would result in reduced peak flows and as a result a reduced potential for flooding on- or off-site. Therefore, «1,., potential i .....,,« ,,.,..,1,1 1,.. ,.,.... than ..ignifiea..« However, the implementation of structural BMPs could alter the existing drainage patterns in the immediately surrounding area, depending on the type and location of the BMP. Therefore, as part of implementation of Mitigation Measure HYDRO -4, implementing agencies would evaluate the potential hydromodification impacts of structural BMPs and include measures to prevent or minimize any identified impacts in the design of the BMPs, including selecting and designing discharge locations to avoid increasing the flood risk in the surrounding area. Mitigation Measures: None re"ired Implement Mitigation Measure HYDRO -4. LA County Flood Control District 11-148 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Significance Determination: Less than significant Response to Comment 16-K: The EWMPs are being developed to comply with the 2012 Permit requirements including its hydromodification requirements. Each EWMP includes projects throughout its watershed that would retain, detain, or slow storm flows, reducing downstream peak storm flows. Implementation of EWMPs would be an improvement to existing conditions, and complementary to RWQCB and local hydromodification requirements within the many jurisdictions of the region. Response to Comment 16-L: Once constructed, the structural BMPs would not generate wastewater as described on page 3.14- 13. Some BMPs may divert dry weather flows to treatment facilities that would be contingent on available capacity. Potential impacts to underground wastewater conveyance systems are discussed on page 3.14-14. Construction activities that generate dewatering water or other wastewater would be subject to SWPPP and WDR requirements. The BMPs would result in improved water quality and would not significantly impact septic tanks or sewer systems. Response to Comment 16-M: Once constructed, the structural BMPs would not generate wastewater as described on page 3.14- 13. Structural BMPs would not be subject to the referenced discharge requirements. No modifications or references are necessary. Response to Comment 16-N: The PEIR discusses potential impacts to groundwater quality on page 3.8-35. The PEIR acknowledges that infiltration projects could adversely affect groundwater quality and identifies mitigation measures to minimize potential impacts. The commenter is correct to reference the on- going Salt and Nutrient Management Plans (SNMPs) currently being prepared in the region. The SNMPs amend the Basin Plan, establishing salt and nutrient loading thresholds for each groundwater basin. The SNMPs include estimates for increased stormwater infiltration in the future as the region increases local water supply opportunities. Stormwater tends to have lower salt and nutrient content than imported water or recycled water. Increased infiltration of stormwater on a large scale as envisioned in the EWMPs assists in diluting salts and nutrients from other recharge sources and is consistent with and incorporated into SNMPs under development in the region. However, the PEIR acknowledges that infiltration can mobilize pollutants including salts and nutrients already in the ground. As a result, the PEIR includes Mitigation Measure HYDRO -2 that requires implementing agencies to evaluate treatment requirements for each BMP to meet Basin Plan water quality objectives; this mitigation measure would reduce potentially significant impacts to less than significant levels. In response to the comment the following text is added to page 3.8-29 of the Draft PEIR, describing the status of Salt and Nutrient Management Plans in the region. a County Flood Control District 11-149 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Salt and Nutrient Management Plans In February 2009, the State Water Resources Control Board adopted Resolution No. 2009-0011, which established a statewide Recycled Water Policy. The Recycled Water Policy encourages increased use of recycled water and local stormwater, together with enhanced water conservation. It also requires local water and wastewater entities, together with local salt and nutrient (S/N) contributing stakeholders to develop Salt and Nutrient Management Plans (SNMPs) for each groundwater basin in California in a way that optimizes recycled water use while ensuring protection of groundwater supply and beneficial uses, agricultural beneficial uses, and human health. The Recycled Water Policy encourages development of regional S/N management strategies rather than relying on the past local RWOCB approach of imposing requirements on individual recycled water proiects with no recognition of the relative and cumulative impacts when all projects and loading sources are considered regionally. Accordingly, the SNMP is intended to provide support and justification for elimination of separate anti -degradation analyses and individual site monitoring requirements for proposed recycled water proiects and so that the vast maiority of proposed recycled water projects may be streamlined. The intent of this streamlined permitting process is to expedite the implementation of recycled water projects in a manner that complies with State and Federal water quality laws. The SNMPs will be approved by the Regional Water Quality Control Boards (RWQCBs). The Central and West Coast Basins SNMP was developed by the Water Replenishment District of Southern California (WRD) as the lead agency. The SNMP was submitted to LARWQCB for approval in November 2014, and was approved as a Basin Plan Amendment on February 12, 2015. The Upper Los Angeles River Area (ULARA) SNMP is currently being prepared by the ULARA Watermaster. An SNMP for the Santa Clarita River Valley East Subbasin is being prepared by a _group of local stakeholders comprised of Castaic Lake Water Agency (CLWA), City of Santa Clarita, Los Angeles County Flood Control District (LACFCD), Newhall County Water District (NCWD), San Gabriel & Lower Los Angeles Rivers and Mountains Conservancy, Sanitation Districts of Los Angeles County (SDLAC) and Valencia Water Company (VWC). This modification has been included in Chapter 12, Clarifications and Modifications of the Final PEIR. The modification adds background information, but does not identify any new significant impact. The modification does not trigger recirculation of the Draft PEIR under Section 15088.5 of the CEQA Guidelines. Response to Comment 16-0: The PEIR acknowledges on pages 3.1-12 and 3.7-16 that BMPs will require periodic maintenance to be effective. Mitigation Measures AES -1 and HAZ-1 both require that maintenance plans be prepared for each structural BMP to ensure their long-term effectiveness. The mitigation includes measures to ensure the functionality of the BMPs for the life of the BMP. With implementation of the mitigation measures, the PEIR concludes that impacts to the effectiveness of the BMPs would LA County Flood Control District 11-150 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments be less than significant. It should be noted, Mitigation Measure HAZ-1 has been revised as follows: HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The Maintenance Plan shall include vector control requirements. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. Response to Comment 16-P: The PEIR discusses potential impacts to groundwater quality on page 3.8-35. The PEIR acknowledges that infiltration projects could adversely affect groundwater quality and identifies mitigation measures to minimize potential impacts. The commenter is correct to reference the on- going Salt and Nutrient Management Plans (SNMPs) currently being prepared in the region. The SNMPs amend the Basin Plan, establishing salt and nutrient loading thresholds for each groundwater basin. The SNMPs include estimates for increased storrnwater infiltration in the future as the region increases local water supply opportunities. Stormwater tends to have lower salt and nutrient content than imported water or recycled water. Increased infiltration of storrnwater on a large scale as envisioned in the EWMPs assists in diluting salts and nutrients from other recharge sources and is consistent with and incorporated into SNMPs under development in the region. However, the PEIR acknowledges that infiltration can mobilize pollutants including salts and nutrients already in the ground. As a result, the PEIR includes Mitigation Measure HYDRO -2 that requires implementing agencies to evaluate treatment requirements for each BMP to meet Basin Plan water quality objectives; this mitigation measure would reduce potentially significant impacts to less than significant levels. In response to the comment the following text is added to page 3.8-29 of the Draft PEIR, describing the status of Salt and Nutrient Management Plans in the region. Salt and Nutrient Management Plans In February 2009, the State Water Resources Control Board adopted Resolution No. 2009-0011, which established a statewide Recycled Water Policy. The Recycled Water Policy encourages increased use of recycled water and local stormwater, together with a County Flood Control District 11-151 ESA / 140494 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments enhanced water conservation. It also requires local water and wastewater entities, Nether with local salt and nutrient (S/N) contributing stakeholders to develop Salt and Nutrient Management Plans (SNMPs) for each groundwater basin in California in a way that optimizes recycled water use while ensuring protection of groundwater supply and beneficial uses, agricultural beneficial uses, and human health. The Recycled Water Policy encourages development of regional S/N management strategies rather than relying on the past local RWOCB approach of imposing requirements on individual recycled water projects with no recognition of the relative and cumulative impacts when all projects and loading sources are considered regionally. Accordingly, the SNMP is intended to provide support and justification for elimination of separate anti -degradation analyses and individual site monitoring requirements for proposed recycled water projects and so that the vast majority of proposed recycled water projects may be streamlined. The intent of this streamlined permitting process is to expedite the implementation of recycled water projects in a manner that complies with State and Federal water quality laws. The SNMPs will be approved by the Regional Water Quality Control Boards (RWOCBs). The Central and West Coast Basins SNMP was developed by the Water Replenishment District of Southern California (WRD) as the lead agency. The SNMP was submitted to LARWOCB for approval in November 2014, and was approved as a Basin Plan Amendment on February 12, 2015. The Upper Los Angeles River Area (ULARA) SNMP is currently being prepared by the ULARA Watermaster. An SNMP for the Santa Clarita River Valley East Subbasin is being prepared by a group of local stakeholders comprised of Castaic Lake Water Agency (CLWA), City of Santa Clarita, Los Angeles County Flood Control District (LACFCD), Newhall County Water District (NCWD), San Gabriel & Lower Los Angeles Rivers and Mountains Conservancy, Sanitation Districts of Los Angeles County (SDLAC) and Valencia Water Company (VWC). This modification has been included in Chapter 12, Clarifications and Modifications of the Final PEIR. The modification adds background information, but does not identify any new significant impact. The modification does not trigger recirculation of the Draft PEIR under Section 15088.5 of the CEQA Guidelines. Although the implementation of BMPs will not eliminate soil erosion in the region, each BMP is designed to reduce pollutant loading into receiving waters. These pollutants can often absorb to sediment particles and impair water quality. The PEIR evaluates potential impacts of BMP construction on soil erosion on page 3.8-33. The PEIR notes on page 3.8-37 that implementation of BMPs will assist in reducing erosion and pollutants in the region. Therefore, impacts resulting from program implementation are less than significant since water quality would improve compared with existing conditions. Mitigation Measure HYDRO -4 has been added to the PEIR under Impact discussion 3.8-3 to reduce any hydromodification impacts including those related to erosion and scour. LA County Flood Control District 11-152 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Page 3.8-37 has been edited as follows: Structural (Regional, Centralized, and Distributed) BMPS The proposed structural BMPS would be designed to minimize off-site discharge of urban runoff pollutants including siltation and sedimentation. Many of the structural BMPS would include on-site infiltration of storrnwater runoff which would also be effective in minimizing erosion or transport of sedimentation into receiving waters. Through increased infiltration prior to discharge into receiving waters, flows within existing streams or rivers would receive reduced stormwater flow volumes thereby decreasing flow energies. Furthermore, as part of implementation of Mitigation Measure HYDRO -4, implementing agencies would design BMP discharge locations to minimize any hydromodification impacts including erosion and scour. As a result, the potential for erosion or siltation within existing streams or rivers would be reduced and the potential impact less than significant. Mitigation Measures: ^ HYDRO -4: Prior to approving a structural BMP, the implementing agencies shall conduct an evaluation of the potential hydromodification impacts of the project. The evaluation shall recommend design measures necessary to prevent or minimize any identified impacts, including flooding, erosion and/or scour. Design measures could include velocity dissipaters and bank re -enforcement components. Implementing agencies shall include these measures in project designs. a County Flood Control District 11-153 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 17 Paige Anderson To: Laura Rocha Subject: RE: PEIR Question/Comment From: Topanga Creek Watershed Committee [mailto:tooanga.tcwc(cr_gmail.coml Sent: Monday, March 09, 2015 7:56 AM To: Gregg Begell Cc: Laura Rocha Subject: Re: PEIR Question/ Comment Thanks very much Gregg. That was helpful. The projects I am interested in are on page 435 of the document. T They are described as "Infiltration", Is there another spot in the document where this is explained in more detail? I am trying to understand what kind of infiltration project is proposed for these locations. Sorry to A trouble you, I tried to figure this out on my own but could not do it Thanks for your help On Mon, Mar 9, 2015 at 7:37 AM, Gregg Begell <ebeeell(a,dpw.lacountv.eov> wrote: TM You can find more information on the priority projects in the PEIR document in Section 10 — Appendices — subsection G. The complete PER can be found on our website www.lacoh2osheds.com. The individual sections can be viewed separately. I hope this helps. Gregg BeGeffP E Project Manager Project Management Division II From: gbegell aa)dow.lacountv.gov [mailto:gbegell(g)dow.lacountv.govl Sent: Friday, March 06, 2015 8:42 PM To: Gregg Begell; Irocha(o)esassoc.com Subject: PEIR Question/ Comment Comment Letter 17 PEIR Question/Comment: --------------------------- From: topanga. tcwc (& gmail. com Looking at the PEIR I see a bumch of red dots / priority projects in our (Topanga Creek Wateshed Committee) area, the Topanga Creek Watershed (North SM Bay. How do I find out exactly what these projects are? ThanksB Ben Allanoff 310 908 5505 Ben Allanoff Chair, Topanga Creek Watershed Committee 21936 Canon Dr. Topanga, CA 90290 (310) 908-5505 topanga.tcwc(o%gmail. com Comments Response to Comment Letter 17 (Topanga Creek Watershed Committee — March 9, 2015) Response to Comment 17-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The proposed EWMP BMPs are under development. Infiltration BMPs are described on pages 2- 8 through 2-24. These BMP types capture and infiltrate runoff into underlying soils. Table 2-2 in Chapter 2, Project Description describes specific sub -types of infiltration BMPs, which include surface infiltration BMPs (infiltration basins, bioretention, and permeable pavement) and multi- directional infiltration BMPs (dry wells and hybrid bioretention). Response to Comment 17-B: The MS4 Permit requires that the EWMPs identify priority projects. The priority projects are identified in Appendix G of the PEIR. The information included in the PEIR is limited to the project name and location. Additional information for the priority projects will be provided in the EWMPs. LA County Flood Control District 11-156 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report HOME OFFICE 8E7 E. Monrovia Place P.O. Box 1385 Azusa, CA 91702-1385 Tel: 800-999-9321 CAIRO. CA 1579 GA Highway III South P.O. Box 390 Cairo, GA 39828-0390 Tel: 800-342-6o12 DAYTON, OR 13455 S.E. Lafayette Highway Dayton, OR 97114-8416 Tel: 80o-666-9321 Comment Letter 18 MONROVIA® HORTICULTURAL G R A F T S M 6 N° SINCE 1 9 2 6 www.monrovia.com March 3, 2015 Mr. Gregg BeGell, P.E. County of Los Angeles Dept. of Public Works Project Management Division II 900 South Fremont, 51h Floor Alhambra, CA 91803 Dear Mr. BeGell, I am writing to you in regards to the Enhanced Watershed Management Plan for the San Gabriel and Rio Hondo Watersheds that is presently under development. I support your efforts to enhance the water supply and achieve water quality goals to help restore the health of our local waterways. I would urge that you consider the restoration of Baldwin Lake at the Los Angeles G R A N R Y , C T County Arboretum in Arcadia, CA in the proposed improvement plan. Baldwin Lake 41 Floydville Road . serves as an important collection basin for Arcadia's urban watershed, receiving run-off Granby, CT o6035 from over 150 acres of the suburban neighborhood to the north. In its present state the Tel: 8o0-950-6051 lake cannot adequately serve as a collection point for water run-off from the neighborhoods north of the arboretum. V ISAr.1 A, cn The restoration of Baldwin Lake will both enhance watershed function and serve the 32643 Road 196 public with exceptional educational, ecological and scenic benefits. Its inclusion as a P.O. Box 489 high priority project within the Rio Hondo/San Gabriel River Enhanced Watershed Woodlake, CA 93286-0489 Management Plan.OfferS rinparNled pUhlir_ benefits-tnour local,00mmunities:. „..., Tel; 800-449-9321 Best regards, Gilbert Res ended z cj Managing Director (800,) 999-9321 ext. 1235 gresendez@monrovia.com ,; 1Y1lv I � i 1 E { 1 riwo, a i4i A. "y'4T ie) n, v 10 J Comments Response to Comment Letter 18 (Monrovia — March 11, 2015) Response to Comment 18-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. IA County Flood Control District 11-158 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 19 Paige Anderson To: Laura Rocha Subject: RE: Public Comment Submittal: EWMP PEIR From: Native Conservation [mailto:native.conservation(ja,gmail.coml Sent: Monday, March 16, 2015 4:17 PM To: Gregg Begell Cc: snowdv.dodson(acsun.edu Subject: Public Comment Submittal: EWMP PEIR Dear Mr BeGell, Please find attached review respectfully submitted by the Los Angeles/Santa Monica Mountains Chapter of California Native Plant Society. Kindly confirm electronic receipt of the comments at your earliest convenience. Thank you. CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 19 Cali f gynia Native Plant Societ - March 16, 2015 Gregg BeGell, P.E. County of Los Angeles Department of Public Works 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 SOBmi7TED vm EMAIL: gbeeell a d w.lacounty_goy PUBLIC COMMENT SUBMITTAL LOS ANGELES COUNTY DEPARTMENT OF PUBLIC WORKS ENHANCED WATERSHED MANAGEMENT PROGRAMS (EWMP) PROGRAM ENVIRONMENTAL IMPACT REPORT (PEIR) Dear Mr BeGell: The Los Angeles/Santa Monica Mountains Chapter of California Native Plant Society thanks Los Angeles County Department of Public Works for the opportunity to review and comment on the PEIR. Our organization supports water quality improvements in conjunction with the focus on conservation, protecting habitat and native plants. California Native Plant Society (CNPS) is a science and policy -based interest group formed a half century ago. CNPS works hard to protect Californias native plant heritage and preserve it for future generations. We actively promote use of science in land use and management decisions through our Online Rare Plant Inventory and essential reference book: Manual of California Vegetation, 2nd Edition, both of which are the most advanced resources available for identifying and managing critical habitat in California. CNPS works closely with decision -makers, scientists, and local planners to advocate for well-informed and environmental friendly policies, regulations, and land management practices. Please see our following comments organized in numeric context of the PEIR document. Our chapter representatives and scientists can be available to work with Los Angeles County Department of Public Works to advise best siting and design elements as well as best management practices pertinent to native vegetation in conjunction with all Department projects. Kindly confirm receipt of these electronically -submitted comments. Sincerely, Snowdy Dodson, Chapter President L,AIS ,ta 9Konic 5lfount 'ns Chapter 15811 Lea6wett 'Van ys CA 9]406 818.257. 9 1 DeTiCatec� to toje preservation of ornia native rrra ^` 0 Comment Letter 19 PUBLIC COMMENT SUBMITTAL LOS ANGELES COUNTY DEPARTMENT OF PUBLIC WORKS ENHANCED WATERSHED MANAGEMENT PROGRAMS (EW MP) PROGRAM ENVIRONMENTAL IMPACT REPORT (PEIR) 3.3.1 Environmental Setting The PEIR states native habitats still remain `within mountainous areas and some drainage areas.' CNPS asserts that native plants endemic to this region are significantly more widespread than the document states. Naturally -occurring populations are found in all geographic areas of the County, including urban, disturbed, ruderal areas, engineered channels, and not limited to open space or B `pristine' habitat. All proposed project areas in the PEIR must therefore be considered as having the potential for habitat value and surveyed at times of year appropriate to the vegetation type found on site. 3.3.1.4 Upper Los Angeles River Watershed The PEIR states that dry -weather flows caused by irrigation run-off and waste water discharges contribute to establishment of native plant habitat. First, we suggest this discussion would be more appropriately addressed in a separate C section of the PEIR about existing habitat as native habitat or plant populations are found in all areas of the County including urbanized settings. Second, it is important to note that Los Angeles County has high numbers of historic and current naturally -occurring water features with surface flows during dry weather such as artesian wells, springs, high water tables, and blue -line D streams in almost every region. Native plant habitat is commonly found in these areas. Third, the PEIR should discuss proposed maintenance measures of existing nativeT E habitat at any and all sites. 1 Fourth, albeit the following permit is not subject to the PEIR, we recommend the PEIR incorporate requirements currently under consideration as part of the "Los Angeles County Flood Control District, Maintenance Clearing of Engineered Earth -bottom Flood Control Channels; File No. 99-011 WDR" renewal by the Los Angeles Regional Water Quality Control Board. The PEIR should advise all native habitat management, maintenance, and locations considered for disturbance or removal coordinated at the inter -agency level, and annually reviewed at the appropriate times of year as dictated by plant type by qualified botanists due to the dynamics and important watershed system values of these bio -diverse areas. Native habitat areas or native plant populations should be left in situ at all project areas unless for a compelling project -related reason and disturbed only for purposes of thinning and trimming. Non-native and invasive plant removal is recommended for areas with native species habitat. M/Santa 9W onica !Mountains CGapw 15811 LeaduvffSt Nan Nuys CA 91406 818.257.0309 2 Comment Letter 19 PUBLIC COMMENT SUBMITTAL LOS ANGELES COUNTY DEPARTMENT OF PUBLIC WORKS ENHANCED WATERSHED MANAGEMENT PROGRAMS (EWMP) PROGRAM ENVIRONMENTAL IMPACT REPORT (PEIR) Proiect Impact Discussion The PEIR is well -researched for various sources of special plant species and habitats lists, regulations, ordinances, and CEQA guidelines. CNPS is concerned the PEIR does not G more specifically address how or propose guidelines for native habitat and special plant populations in project areas. Reference is given throughout the section to benefit goal objective of restoring waterways or riparian areas addressed by the PEIR projects to `pre -historic conditions.' The statement is used when describing projected vegetation changes following installation of structural, non-structural, and passive projects. Pre -historic conditions of Los Angeles County can never be replicated due to gross manipulation and change of the former H hydrology. This especially holds true to water features and native vegetation. California Native Plant Society strongly cautions use of this assumption by the County and advises all existing native habitat, regardless of whether its establishment is historic or from nuisance run-off, be protected for long-term beneficial uses and contribution to watershed functionality. Structural- This section states many project sites are located within disturbed areas, implying those have no potential for sensitive species or habitat values. Your Department understands this is not the case as establishment of relatively pristine native habitat that established in some of the Earth -bottom Flood Control Channels, which are both engineered and routinely disturbed for maintenance. It is therefore recommended for purposes of due diligence that all projects that are part of this PEIR are surveyed for native plant species and habitat. Impact 3.3-1 BMPs — Mitigation Measures BIO -5 Habitat values that provide a wide range of nesting opportunities can extend ten months of the year, especially in the coastal Santa Monica Mountains and the Coastal Zone. It is recommended to elongate the requirement for pre -construction J surveys from August 31 to October 31 throughout the County. Furthermore, the surveys should include butterflies, bats, and other pollinator species, as required by California Coastal Commission. BIO -6 Construction, staging, and rights-of-way should be limited to the smallest possible disturbance footprint, even at sites where no special species are identified. This K will ensure less biological impact to biota, soils, air, and water quality. L'AISanta Monica 94ountaim Chapter 15811 LeadwetrSt Nan Nuys CA 91406 818.2570309 3 to Comments Response Comment Letter 19 (California Native Plant Society — March 16, 2015) Comment Letter 19 (California Native Plant Society — March 16, 2015) Response to Comment 19-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The backgrounds and qualifications of the California Native Plant Society have been noted. Response to Comment 19-B: Mitigation Measure BIO -7 requires that implementing agencies conduct floristic surveys prior to BMP installation in areas where sensitive plants may occur. The mitigation measure applies to BMP installations in urban areas as well as rural. Implementation of the mitigation measure would ensure that sensitive plants and habitats are not significantly impacted. Response to Comment 19-C: The PEIR describes existing habitats within the EWMP watersheds in Section 3.3.1 of the Draft PEIR. A separate description is provided for each watershed. Each watershed contains a variety of habitats. Response to Comment 19-13: Mitigation Measure BIO -7 requires that implementing agencies conduct floristic surveys prior to BMP installation in areas where sensitive plants may occur. The mitigation measure applies to BMP installations in urban areas as well as rural. Implementation of the mitigation measure would ensure that sensitive plants and habitats are not significantly impacted. Response to Comment 19-E: Mitigation Measure BIO -8 requires that implementing agencies conduct salvage and replanting plans following construction activities where sensitive habitat is impacted, which would reduce potentially significant impacts to less than significant levels. Response to Comment 19-F: The EWMP projects would be implemented by Permittees and coordinated with responsible agencies as needed to comply with permit requirements. Projects that would impact earth -bottom channels owned by the LACFCD would require LACFCD approval and compliance with applicable Army Corp of Engineers, RWQCB, and California Department of Fish and Wildlife resource permits including 404, 401, and 1602 permits, respectively. For example, Mitigation a County Flood Control District 11-163 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Measure BIO -4 requires that implementing agencies consult with these resource agencies for projects that impact sensitive habitats and drainages. In addition, Mitigation Measure BIO -8 requires that implementing agencies conduct salvage and replanting plans following construction activities where sensitive habitat is impacted. Both mitigation measures would reduce potentially significant impacts to less than significant levels. Response to Comment 19-G: The EWMPs are under development. Areas that could be impacted by individual BMP projects would be analyzed on a project -specific basis. The 12 EWMPs cover a large geography that exhibits numerous native habitat and special plant population types. A native habitat and special plant population type assessment within the entire County would not be helpful at the high-level scale of the impact analysis because the level of detail needed for individual BMP projects would not be feasible for all potential BMP locations throughout the County. Habitat and plant types may differ acre -by -acre in potential BMP locations, requiring a site specific analysis that is impractical to employ for the entire County in the PEIR. Mitigation Measures BIO -1 through BIO -9 provides a road map for minimizing impacts to natural resources that could result from BMP installations, and would reduce potentially significant impacts to less than significant levels. Specifically, Mitigation Measures BIO -4, BIO -7 and BIO -8 would apply to special -status plant populations, requiring the avoidance of special -status species, pre -construction surveys, and replanting plans. Mitigation Measure BIO -1 would require the avoidance of native habitat, and Mitigation Measure BIO -8 would require the re-establishment of native vegetation following construction. Response to Comment 19-H: Mitigation Measures BIO -1 through BIO -9 provide a road map for minimizing impacts to natural resources that could result from BMP installations, and would reduce potentially significant impacts to less than significant levels. Response to Comment 19-I: Mitigation Measure BIO -7 requires that implementing agencies conduct floristic surveys prior to BMP installation in areas where sensitive plants may occur, and would reduce potentially significant impacts to less than significant levels. Response to Comment 19-J: The PEIR identifies a typical nesting season for birds in the southern California environments. Actual nesting behavior may be exhibited in certain locations by certain species outside of this typical range, but the February to August range is a typical nesting duration for most birds. Mitigation Measure BIO -5 would require that a pre -construction survey for breeding and nesting birds and raptors be conducted if construction and vegetation removal is proposed between February 1 and August 31. A qualified biologist shall conduct a pre -construction survey for breeding and nesting birds and raptors within 500 -feet of the construction limits to determine and map the location and extent of breeding birds that could be affected by the project. Active nest LA County Flood Control District 11-164 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments sites located during the pre -construction surveys shall be avoided until the adults and young are no longer reliant on the nest site for survival as determined by a qualified biologist. Although impacts to migratory birds are unlikely because of the disturbed nature of many project locations, the implementing agencies will be required to either avoid impacts to migratory birds and their nests. Should the nesting of any migratory bird occur on or adjacent to the project site during grading or construction activities, a USFWS-qualified biological monitor would have the authority to halt all work activities and notify the city and corresponding resource agency. Response to Comment 19-K: Mitigation Measure 13I0-6 requires that staging areas and rights of way are marked and minimized, and would reduce potentially significant impacts to less than significant levels. a County Flood Control District 11-165 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 20 Paige Anderson To: Laura Rocha Subject: RE: Final NO MORE to Come - BURNED OUT From: Tom Williams[mailto:ctwilliams20l2(a)vahoo.coml Sent: Tuesday, March 17, 2015 6:43 AM To: Gregg Begell Subject: Final NO MORE to Come - BURNED OUT See attached A few additions in sections 2 and 3 by 9am 03/17 or before I am working on a letter commending the efforts and recommending use of MMRP to get a management plan to control all the cats... Dr. Tom Williams CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 20 Dr. Tom Williams March 16, 2015 Final ccSc March 17, 2015 TO: Gregg BeGell, P.E. County of Los Angeles Department of Public Works, Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 gbegell@dpw.lacounty.gov FROM: Dr. Tom Williams, Sr. Techn. Advisor Citizens Coalition for A Safe Community Sierra Club, Angeles Chapter, Water Committee Subject: Enhanced Watershed Management Plan RE: Comments on Programmatic Draft EIR Final Compiled Supplemental Comments EWMP - SPECIFIC COMMENTS Comments, recommendations, and additions are presented in Bolded Italics following relevant PEIR text specific to the comments are presented in plain text as was in the PEIR. Some specifically relevant PEIR text may be Bold Underlined. NEW SUPPLEMENTAL COMMENTS p.2-18 Upper LA River Brandon Street and Green Street Improvements Project The project will reconstruct... roadway... design includes... Much of the runoff from the streets and private properties that would have otherwise drained to the Rio Hondo will be directed to the infiltration area. A No estimate or even guess as to how "much" that would be drained has been made. The EWMP and PEIR suffer from lack of rough orders of magnitude estimates of diversion, redirection, and recharge. 2-19 Upper San Gabriel River Avocado Heights Multiuse Trail Project The project will... thereby reducing the amount of impermeable surfaces as well as runoff. Approximately ... Combined together, up to 115 acre-feet of groundwater will be recharged annually. B Here an estimate as to how "much" is provided but without any supporting calculations and consistent application throughout the EWMP/s. The EWMP and PEIR suffer from inconsistent application of rough orders of magnitude estimates of diversion, redirection, and recharge for all watersheds. 2-2612 Typical constructed wetland projects require extensive grading of site soils, though excavated soils are often balanced on-site to provide material for levees, berms, ecotones, and other flood control/habitat features. 2-27/2 Multi -benefit flood management projects. This category... designed to result in direct or indirect benefits to flood management. ...Tujunga Wash Greenway project that incorporates ... detention elements can improve flood management by reducing stormwater flow rates and/or volumes. References to multiple benefits may be appropriate but are not supported by any supporting analyses and description of specific conditions in EWMPs or the EWMP. LACo EWMP COMMENTS [y Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC 2-2713 Construction Impacts. Multi -benefit flood management projects are typically expansive projects that range from a few to tens of acres in size... Because of their scale, multi - benefit flood 2-28/1 management projects... No definitions are provided for "flood management" vs "flood control" (2-2612), and no D supporting information or analyses are provided for quantification of levels of management/control in addition to other beneficial sectors, e.g., groundwater sourcing for suburban and urban water supplies. 2-2812 ...centralized BMPs... presented in Table 2-4. The locations of these examples of planned and implemented centralized BMP ... in Figure 2-3. Table 2-4 ... the centralized BMPs... structural BMPs that are part of the EWMP.... of potential and priority BMPs, where data ar" available,... BMP Implementation Strategies. E References to centralized BMPs, structural BMPs, and potential and priority BMPs and then "where available" cause confusion for public reviews and clearly indicate that the supporting documents are inadequate if not incomplete.. 2-30 TABLE 2-4 EXAMPLES OF PLANNED CENTRALIZED BMP PROJECTS This project will also have educational signage on a riparian zone and the stormwater cleanup objectives of this project. Centralized projects have been designated as priority, potential, and, here, "planned", but F no clear comparison is provided. Consistent terms and usage is very important for public review and commenting. papkiway wag a flood 2-3411 2.4.5 Regional Structural BMPs Regional structural BMPs are those that can capture The project's BMPs... alleviate local flooding by collecting runoff from a 21 -acre drainage area ... into two underground infiltration galleries... Design volumes and their analyses are not provided for contributing watersheds, provide runoff coefficients, times of concentration, etc.. 2-4214 The Los Angeles River... natural hydrology of the Los Angeles River watershed has been altered by channelization and the construction of dams and flood control reservoirs... Because of the greater extent and number of pollutant priorities, the BMP strategy in the Upper Los Angeles River watershed includes well over a hundred planned regional and centralized retention and infiltration BMPs (Estimated total unfunded projects: 4001 that take advantage of the favorable groundwater recharge characteristics ... BMP strategy also includes distributed smaller BMPs located throughout the urbanized areas of the watershed as retrofits in LACo EWMP COMMENTS Dr. Tom Williams Comment Letter 20 March 16, 2015 Final CCSC existing developments and streets. LFDs to comply with dry -weather bacteria TMDLs may also be included. No quantification of the watersheds, recharge areas, and groundwater storage capacitiesH has been provided. No priority assignment process has been proposed to manage the Cont. many options and maximize the uses of favorable recharge areas and storage capacities. 3.1-12/3 BMP maintenance is also important... Wet ponds and constructed wetlands can also become mosquito -breeding grounds... can usually be reduced or eliminated through proper design and/or organic controls.[=maintenance]..all BMPs need to have trash and debris removed periodically to prevent odor and preserve aesthetic values. With proper maintenance... impacts would be less than significant. Although mosquitoes are mentioned, projections of potential public health impact of such occurrences are not mentioned nor supporting information provided, while trash and debris are related to odor and aesthetic values. 3.1-15/TABLE 3.1-1 SUMMARY OF ... IMPACTS REQUIRING MITIGATION MEASURES Distributed BMP LID — Green Infrastructure — Capture and Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes As indicated elsewhere, the LID program limits detention for single family dwellings to two rain barrels, about 100gal, while a typical 1000-2000sgft roof would generate about 450-900 gal. Rain barrels are discussed but given the limits for only single family dwelling (i.e., multi -family dwellings and commercial structures must have more than 450 gal/1000 sqft). The table and other references to rain barrel requires supporting analyses/calculations to demonstrate any significant mitigation during the EWMP implementation. 3.5-19/2 City of Los Angeles Low Impact Development Manual In November 2011, the City of Los Angeles adopted the Stormwater Low Impact Development (LID) Ordinance #181899) with the stated purpose of: • Requiring the use of LID standards and practices in future developments and redevelopments to encourage the beneficial use of rainwater and urban runoff • Reducing stormwater/urban runoff while improving water quality • Promoting rainwater harvesting • Reducing offsite runoff and providing increased groundwater recharge • Reducing erosion and hydrologic impacts downstream • Enhancing the recreational and aesthetic values in our communities 3.5-19/3 The City institutionalized the use of LID techniques... adoption of the Stormwater LID Ordinance, the City prepared the Development Best Management Practices Handbook, Low Impact Development Manual,... required BMPs (City of Los Angeles, 2011). 3.7-17/2 The LID Standards... provide protocols for designing regional and centralized BMPs that minimize the potential for contaminant loading. For example, the LID Manual requires a certain distance to groundwater to ensure that adequate soil filtration occurs prior to the percolating water reaching a drinking water aquifer. The manual and references to it fail to demonstrate and support contentions regarding purpose and significance of a desired level of implementation during the EWMP peri or the rate of implementation, especially given the minimal detention required of sin, family dwellings. LACo EWMP COMMENTS Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC 3.8-812 5. Dominguez Channel Watersheds (Figure 3.8-6) (Dominguez Channel EWMP and Beach Cities EWMP—...Dominquez Channel EWMP and a portion of the Beach Cities EWMP ... differentiated by a larger area of industrial land use. Because of the high density... large regional and centralized infiltration -type BMPs will be limited. The structural BMP strategy will be more LFDs, both large (centralized) and small (distributed), located at MS4 outfalls ... The other BMP strategy is the use of smaller distributed BMPs ... low -impact development (LID) type of BMPs, such as green streets and biofiltration BMPs. Such generalities require quantification, specific parameters, and some criteria and perhaps cost limitations. For this and other sib -watersheds, the EWMP and PEIR- MMRP can provide a more formal process of sizing and capacities of BMPs. Subsurface infiltration galleries are commonly used in such surface congested areas if suitable alluvium is available. 3.8-2011 ...these LFDs could potentially increase the amount of water available for recycling, reuse, and _groundwater recharge. 3.8-21/1 ...45 percent are supplied by local groundwater basins that are recharged naturally... through constructed recharge facilities (MWD, 2010). 3.8-21/1 ...stormwater recharge facilities currently augment local groundwater supplies in the region by an estimated 477,000 acre-feet per year (MWD, 2014). 3.8-21/1 One of the primary goals of the EWMP program... increase the amount of stormwater that is recharged... particularly in portions of the Central Basin that experience a high degree of hydraulic connectivity between surface water and groundwater. Infiltration BMPs proposed within the EWMPs are expected to increase the rates and amounts of groundwater recharge... Although herein discussions focus on the potential benefits of runoff diversion and recharge as related to augmenting local groundwater supplies to water user service areas, the remainder of the PEIR generally disregards the cumulative impacts and growth inducements of increased local water supply sources while retaining all existing capital works supply capabilities. 3.8-31/3 County of Los Angeles Low Impact Development Manual The County... prepared the 2014 Low Impact Development Standards Manual (LID Standards Manual, County of Los Angeles, 2014b) to comply with the requirements of the 2012 MS4 Permit... provides guidance for the implementation of stormwater quality control measures in new development and redevelopment projects in unincorporated areas of the County with the intention of improving water quality and mitigating potential water quality impacts from stormwater and non-stormwater discharges. LACo may have LID requirements for future developments and redevelopments; however, N the LACo recently proposed and gained voter approval for a "hauled water" initiative for existing developable areas without piped or well -sourced water supplies. Increased local groundwater recharge and additional "surplus" water supply system capacities can promote or induce such developments which were previously restricted. The cumulative effect of increased local supplies and available infrastructure capacities can directly support and induce development of the "Hauled Water" developments and their impacts on local drainages. 3.8-31/4 The LID Standards Manual addresses ... obiectives and goals: T • Lessen the adverse impacts of stormwater runoff from development and urban runoff on I p I natural drainage systems, receiving waters, and other water bodies. LACo EWMP COMMENTS Dr. Tom Williams March 16, 2015 Final Comment Letter 20 CCSC • Minimize pollutant loadings from impervious surfaces by requiring development projects to incorporate properly -designed, technically -appropriate BMPs and other LID strategies. • Minimize erosion and other hydrologic impacts on natural drainage systems by requiring development projects to incorporate properly -designed, technically appropriate O hydromodification control development principles and technologies. Cont. The manual contains only generalized statements - Goals - not quantified and scheduled objectives. LIDS do not provide requirements for agencies to deal with existing and future streets and sidewalks and do not provide for capital and long-term O&M funding sources. Without quantification and definitions, "lessen" and "minimize" become irrelevant and can be attained without reference to LID. City of Los Angeles Low Impact Development Manual 3.8-3115 In November 2011, the City of Los Angeles adopted the Stormwater Low Impact Development Ordinance #181899 with the stated purpose of: • Requiring the use of LID standards and practices in future developments and redevelopments to encourage the beneficial use of rainwater and urban runoff Reducing stormwater/urban runoff while improving water quality Promoting rainwater harvesting • Reducing off-site runoff and providing increased groundwater recharge • Reducing erosion and hydrologic impacts downstream • Enhancing the recreational and aesthetic values in our communities 3.8-31/6 The City of Los Angeles institutionalized the use of LID techniques... Subsequent to the adoption of the Stormwater LID Ordinance, the City prepared the Development Best Management Practices Handbook, Low Impact Development Manual, dated June 2011, to describes the required BMPs (City of Los Angeles, 2011). LID provisions for rain barrels for single family dwellings are only 10-20% of the total detention required for the design storm. The EWMP and the PEIR have not provided basic supporting documentation and analyses for.- Use or:Use of the 85%ile 24 -hr rainfall event, Sufficiency of detention containers (SFD with two 50gal barrels for 450+gal runoff, Importance of rainfall harvesting of 1000sgft on a 5000sgft lot with driveways, sidewalks, etc.. Reference to beneficial use, harvesting, enhancements, and recharge generally relate to reduce demands by existing and future users and thereby freeing up existing water supply capacity for other future developments or expanding base populations in the service areas, infrastructure support of expanded developments - growth inducements. 3.8-3512 Mitigation Measure HYDRO -1 requires Permittees to evaluate the suitability of BMP locations for groundwater recharge. Infiltration BMPs would not be suitable in areas of low permeability where subsurface structures could be adversely affected by groundwater mounding. Q No supporting information is provided regarding recharge capability, local groundwater storage capacities and flow regimes, and potentially affected infrastructure. No process, parameters, nor criteria for "evaluations" are provided as part of EWMP and PEIR. 3.8-4115 Cumulative Impact Discussion Structural (Regional, Centralized, andI R Distributed) BMPs ...Implementation of the proposed structural BMPs,... other reasonably LACo EWMP COMMENTS Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC foreseeable future proiects... result in improved stormwater quality and reduced non storm flows .... will experience reduced dry -weather runoff, a more natural hydrology, and improved receiving water 3.8-42/1 quality. In addition, new infiltration projects will incrementally augment groundwater drinking water supplies. Although the increased infiltration projects may increase pollutant loads to groundwater aquifers, pretreatment systems coupled with regional groundwater management lead by the local Watermasters will ensure that the beneficial uses R of groundwater basins are not significantly impaired....EWMPs will beneficially impact local Cont. surface water quality and groundwater supplies. Mitigation Measures: None required Significance Determination: Less than significant The EWMP does not provide parameters and criteria or selection of "future projects". No management program of "coupling" between LA Co, other watershed agencies, and the "Watermasters" is proposed nor committed to in the EWMP to deal with cumulative impacts. 3.8-43/TABLE 3.8-3 SUMMARY OF HYDROLOGICAL RESOURCE IMPACTS REQUIRING MITIGATION MEASURES Cumulative Impacts, No mitigation required Without a hydrologic model and analyses especially for the "design storm", no objective S assessment of impacts can be made and no supporting information is provided for the absence of mitigation requirements. LACo EWMP COMMENTS Comment Letter 20 Paige Anderson To: Laura Rocha Subject: RE: Most -Near Final additions by 9am tomorrow From: Tom Williams[mailto:ctwilliams20l2(a)yahoo.coml Sent: Monday, March 16, 2015 1:43 PM To: Gregg Begell Subject: Most -Near Final additions by 9am tomorrow See attached A few additions in sections 2 and 3 by 9am 03/17 or before Dr. Tom Williams CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC March 16, 2015 TO: Gregg BeGell, P.E. County of Los Angeles Department of Public Works, Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 gbegell@dpw.lacounty.gov FROM: Dr. Tom Williams, Sr. Techn. Advisor Citizens Coalition for A Safe Community Sierra Club, Angeles Chapter, Water Committee Subject: Enhanced Watershed Management Plan RE: Comments on Programmatic Draft EIR Final Compiled Comments 1-4/4 Following provides a brief review of the CEQA/P-DEIR (PEIR) documents of almost 70MB/1000 pages. We thank the LACo Department of Public Works and Flood Control District for this opportunity to review and comment on the PEIR and greatly appreciate the deadline extension for doing such. Overall review is that the document(s) are inadequate, incomplete, and virtually inaccessible for the general educated public due to the volume, technical character, overly -broad statements, lack of T documentation and support of statements, and lack of definitions and consistency of terms and usage, The proposed Program does not provide a plan for tiered project CEQA considerations by the other permittees nor the County itself. No plan for the Program or the projects has been established for the Enhanced Watershed Management Plan to achieve and comply with the LA Regional Water Quality Control Board's permit requirements. A program may be more generalized but still must provide a plan of actions for both the lead and responsible agencies. The Program does not provide even the requirements, process, and procedures for subsequent CEQA compliance by other permittees and some projection as to whether EIRs, MNDs, ND, or CE will be used to tier down from this P-DEIR/P-FEIR. Conditions for Program Compliance by tiered projects have not been U listed or even referenced other than some ill-defined listing of BMPs. No current listing of all planned and funded Projects has been provided and incorporated into a scheduledTV and quantified plan for submission in June 2015. 11 Although research has been underway for five -plus years, the EWMP and this PEIR does not use nor even reference use of computerized modeling of the appropriate basins (Ballona Creek, Upper LA River, Middle LA River and Arroyo Seco, Lower LA River and San Gabriel River, and LA River Mouth/Estuary- Dominguez Channel), although the federal agencies (BLM, USGS, ACoE, etc.) and perhaps local agencies W (some permittees and the Water Board) have some local or watershed models . Without a model and its components, the impacts and their significance of detention, retention, recharge, and flood protection cannot be assessed nor mitigated adequately or completely. Three goals are provided but no objectives (sub -tiered from goals) are provided with/without defined schedules and other quantitative parameters for program monitoring. Confusion is introduced in later text X when both flood control and water supply "augmentation" are also introduced as "goals" and as "objectives". Specific goals are only to meet the MS4 Permit requirements in June 2015 and after and related water quality conditions and to meet them in a "Cost -Effectiveness" manner. However, costs, financial support, revenue, capital bonding, or economic effectiveness or efficiency are not provided, and thereby Y achievement of the cost effectiveness cannot be judged nor compared and appears to be presumed by submission of any proposed project. LACo EWMP COMMENTS 1 Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC Growth inducement is mentioned primarily with regard to direct housing construction and employment andT Z incomes while dismissing potential effects of recharged (diverted storm flows) water supplies. 1 Additional benefits primarily for flood protection are mentioned in some statements while it is not supported by any text or analyses under water resources. No assessment of beneficial and adverse effects are AA provided for raising base flow levels from program-augmented/diverted-stormwater groundwater resources and their effects upon subsequent pollutant concentrations and flood flows. I am retired from 30 years in water and environmental resources with Parson Corp., Pasadena and URS San Francisco and over 10 years with Dubai (UAE) government and local water and environmental companies. I have prepared sections and entire documents for more than 300 EIRs, EISs, and EAs worldwide for local agencies, cities, counties, states, federal, and international agencies and organizations and have reviewed more than 100 additional assessments. During work for URS, I was involved in the BB development and environmental considerations for the 1970s EPA's Santa Ana and Santa Marguerita/San Luis Rey basins plans. My reviews have included the LACity's Recycled Water Management Plan and Stormwater Capture Management Plan, and I am currently vice chair of the Steering Committee forthe LA City's Floodplain Management Plan. I am also the Senior Technical Advisor for the CCSC and a member of the Sierra Club, Angeles Chapter, Water Committee Di. Tom Williams LACo EWMP COMMENTS Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC MAJOR ISSUES: Comments regarding deficiencies have an implied request for additional information and appropriate revisions to be added in the PEIR, and especially the formal Mitigation, Monitoring, and Reporting Program. CC LA Co Water Computer Model No model has been used or referenced. Project Storm References are made to the Project Storm event of 85th -percentile for 24-hour (not = daily) rainfall and estimated at 0.75 inches, but no primary references or sources for the storm distributions are provided. Choice of this particular criterion is not described but may be related to the DD permit requirements without any further considerations or its appropriateness. Provide references and demonstration that the storm precipitation applies to the entire southern LACo or where it does apply. Increased Water Supply and Growth Inducements Many statements of the use of diverted stormwater and other waters for recharge is not carried through to the ultimate effects of such recharge on base flow (exfiltration) from shallow groundwater into channels or on the available safe yields for potable water supplies. The entire PEIR is incomplete and totally inadequate for the discussion of the volumes, recharge areas, EE and pumping areas and uses for increased local water supplies either as a means of substitution for imported with the same population or to assure adequate total supplies for increasing or re -distributed populations. Environmental Justice for Water Supply Sources Also as an environmental justice issue, the PEIR does not address the distribution of recharge areas for both local stormwater and treated recycled waters (also part of LACo and LACity plans and projects), compared to those areas receiving the higher water quality and lower total delivered costs of imported waters. As both areas would presumably pay the same, or similar, FF water supply rates, they must get the same quality water (e.g., TDS, nitrates, metals, etc.), else wise an environmental justice issue appears to exist. Provide the expected water quality and any treatment related to recharged storm and treated wastewater and to imported water (e.g., northern San Fernando Valley -Santa Clarita vs Torrance -Compton -Whittier. Public Health Retention, detention, and recharge facilities create good habitats for mosquitoes and other vectors but the PEIR mention mosquito and other water related vectors four times. No discussion is presented regarding the public health issues for water- and water-logged soil related habitats for disease vectors, especially give the concerns regarding West Nile and Dengue Fever vectors. Having suffered malaria, the reviewer may be overly concerned, but some assessment and mitigation measures must be included. As a long term operations and maintenance issue, demonstration of ongoing revenue sources, and appropriate O&M funding and activities are vital to any assessment of water related projects in a dense board urban environment. GG Fungi -Mold (Valley Fever) are/is would be expected to expand especially in those areas with high soil moisture and perhaps overlying near surface mounded groundwater. Accumulations of metals and hydrocarbons may occur due to treatment by soil -based systems and stabilization of metals in project basin soils and vegetation. Watershed health is mentioned but only as this health relates to the presence or removal of contaminants from the dry -/wet -weather runoffs. Provide discussion regarding any stormwater-related diseases. Operations and Maintenance and Revenues Proposed facilities would be expected to have high manual maintenance. THH LACo EWMP COMMENTS Dr. Tom Williams Comment Letter 20 March 16, 2015 Final CCSC Provide requirements for coordination/compliance with scheduled maintenance that must be incorporated into a thorough scheduled and quantified Mitigation Monitoring and Reporting HH Plan/Program for all facilities and operations. Cont. Revenues and Stormwater Fees Sources of revenues are not provided to support capital construction and replacement, financing, and long term operations and maintenance, especially any changes in the LACo Storm Water Fees on annual property tax rolls. No provision is made for revenues based on per -parcel or per -area assessments and fees. I I No assignment and delineations are made for benefits and effects/risks to the public and land owners for water quality, flood control, or recharged water supplies. No comparisons are offered to compare abilities for overall or percentile economic groups to pay for both owners and residents. Provide full description and assignments of revenues, life -of -project costs, and ability to pay for revenue sources. Revenues from Groundwater Production Groundwater resources will be increased, but it is unreported as to the ownership and allocation of�JJ the recharged water and to the process of recovery of increased local groundwater resources beyond the immediate vicinity of the recharge areas. Flood Control, Protection, Diversion, and Other Related Issues Flood protection, control, and management are mentioned as a goal/objective of the program but KK without delineation and definition, and significance to other related concerns (e.g., Growth inducement). Provide estimated changes of wet- and dry -weather flows. Effects of Increased Base Flow (levels and flows) No meaningful discussion (two -2 mentions of base flows in all 504 pages) is presented as to both the beneficial and detrimental effects of higher base flow volumes and levels resulting indirectly from rising/mounding groundwater resources downslope of stormwater and recycled water recharge basins/projects. LL Increased low flow volumes for pollution dilution of existing and other permitted discharges are not considered. Increased low flow levels for increased total flood level and expanded flood area are not considered. Special Issue: LA City - EWMP 400+ projects (BMPs) and PEIR Inquiries, internet searches, and requests for public documents have been submitted to the Department/Board of Public Works, City of Los Angeles for documents, reports, and other materials pertaining to the reported 400+ storm water related projects, BMPs, etc., that presumably would be part of the 12 EWMPs for the permittees to submit to the LA WQCB in June 2015 and which is referenced in the LACo EWMP and this PEIR. As of 3pm-16 March, 2015, more than ten days after submission of the request to LACI-BPW, no contact has been made by the LACI-BPW or LACiDPW. This indicates that such EWMPs' projects may be erroneously reported herein or that they are not part of the PEIR and not available to the public. This is a clear example of importance of having all information prior to preparation of the LACo EWMP and this PEIR. as the total number of stormwater related projects probably exceeds the total numbers of other permittees we must assume that the EWMP-PEIR is incomplete and inadequate for public review and meaningful comments. Please withdraw the current PEIR and recirculate at a later date when all relevant information is available for public review and comment. LACo EWMP COMMENTS WIW Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC EWMP - SPECIFIC COMMENTS Comments, recommendations, and additions are presented in Bolded Italics following relevant PEIR text specific to the comments are presented in plain text as was in the PEIR. Some specifically relevant PEIR text may be Bold Underlined. Apdx. A, NOP, p.914 4.1.1 Regional Structural BMPs "Regional EWMP projects" are defined by the MS4 Permit as multi -benefit regional projects that, wherever feasible, retain all non-stormwater runoff and all stormwater runoff from the 85th percentile, 24-hour storm event for the contributing drainage area, while also achieving other benefits such as flood control and/or water supply. The PEIR states consistently that the project storm is the 85th percentile/24-hour/approximately 0.75inch (some up to 1 inch). However no documentation/derivation of the 24 hr storm analyses has been provided. The 24-hour storm event is not equal to a daily storm event (any NN 24 -hr vs a 12:01:01am-11:59:59pm) and can be quite different based on moving 24-hour totals and frequency compared to that for calendar day. Similarly the runoff from a 0.75inch rainfall would not be expected to be the same as the amount of rain falling on the ground (467gals11000sgft vs 0.9x467gais= say 420gals) but no provision is made regarding runoff coefficients.. The PEIR is inadequate with regard to the absence of documentation/analyses demonstrating the total distribution from say 50%-100% of 24hr storm event. Furthermore no assumed runoff coefficient(s) has been provided for estimating the likely detention capacities required. Executive Summary The Executive Summary (ES) has not been thoroughly reviewed as the ES supposedly represents a limited version of the P-DEIR text content and cannot be assessed for adequacy and completeness as a stand-alone item. Some issues warrant some review and comments. ES -212 The EWMPs will identify potential and priority structural and non-structural Best Management Practices (BMPs) within the region's stormwater collection system to improve runoff water quality. As indicated, this EWMP has no direct factual contributions from the individual EWMPs of other permittees within LACo. No formal organization and definitions of the EWMP, EWMPs, and all the "BMPs" has been provided and consistently applied throughout the document. As the statement refers to a future condition, not in evidence, such statements here and throughout the document must be verified and suported by commitments on the part of the other permittees. Potential and priority BMPs are referred to but are not adequately related to the EWMPs and the EWMP/PEIR and as indicated herein they ARE BEING developed, they are not developed. The EWMP and PEIR are not definitive at even a programmatic or conceptual design level. •• ES -215 A few of the BMPs are currently well defined but most are vet to be fully developed under the EWMPs .... priority BMPs... detailed in each of the EWMPs; these are being developed in parallel with the PEIR.... describes the details that are available for each of the EWMPs currently... by the EWMP working groups. PP 1-313 A set of priority BMPs will be detailed in each of the EWMPs; these are being developed in parallel with the PEIR. The PEIR describes the details that are available for each of the EWMPs currently under preparation by the EWMP working groups. As indicated, this EWMP has no direct factual contributions from the individual EWMPs of other permittees within LACo. No definition of "Fully" or "Well" is provided for the PEIR and as they are being developed at the same time as this PEIR their entire discussion is so general as to render assessment QQ impossible and open to any combination of current or future "projects" and BMPs as desired by the agencies. No reliable discretionary decision can be made and funded based on the PEIR. ES -313 ES.3 Project Objectives The primary goals and objectives of the EWMPs are: LACo EWMP COMMENTS T RR Dr. Tom Williams March 16, 2015 Final Comment Letter 20 CCSC • To collaborate among agencies... to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the MS4 Permit. • To develop watershed -wide EWMPs that will... remove or reduce pollutants from dry- and wet - weather urban runoff in a cost-effective manner. • To reduce the impact of stormwater and non-stormwater on receiving water quality. Elsewhere goals and objectives are mentioned and then supposed objectives are provided. Here these are largely "goals" as they have no specification of schedule or quantification. As these are stated as "primary" with no mention of secondary or tertiary goals or objectives, the entire EWMP is without adequate or complete goals and objectives and various statement totally confuse the basis for the "project" and related " alternatives" and their compparisons and assessments. Report is unclear as to definition and has inconsistent usage of Goals and Objectives of the Program. These are Goals only, while objectives must have specifics as to schedule and quantitative indicators of compliance (e.g., acre-feet/year recharged, return rate changes by 2020, etc. ES -315 The LACFCD has a vested interest in increasing opportunities for stormwater capture and groundwater recharge as a means of assisting local water supply augmentation. Direct reference to increased water supply without delineation as to where augmentation and local supplies may be augmented. Without removal of existing facilities in order to reduce existing water supply flow capacities, increased local sources can increase and must be considered as increased total water supply and appropriate assessment of growth inducement. Local augmentation, in general, would be at lower elevations than imported water supplies would serve due to the State Water Project and Colorado River Project source elevations of imported supplies and those of most probable recharge areas and down -flow groundwater wells. Service areas of recharged stormwater and recycled waters are generally of lower elevations and of different economic status from those at higher elevations and served by imported water supplies.. RR Cont. &W 1-113 The MS4 Permit gives Permittees the option of implementing an innovative approach to permit compliance through development of an Enhanced Watershed Management Program (EWMP).... Will identify potential and priority structural and non-structural Best Management Practices (BMPs) within the region's stormwater collection system to improve runoff water quality. The LACFCD, along with participating Permittees, has opted to exercise this option and has submitted to the LARWQCB 12 separate Notices of Intent (NOls) for the development of EWMPs within 12 distinct watershed TT groups... Implementation of the EMWPs would be the responsibility of each Permittee and would occur following approval of the EWMPs by the LARWQCB. BMPs, groups of BMPs, and Projects are not defined at any engineering levels so as to determine cost-effectiveness, capabilities to achieve any project/program goal involving water quality or flows and their effects and impacts. p.1-312 ... timeline ... in the MS4 Permit requires that Permittees submit the 12 EWMPs to the LARWQCB by June 28, 2015, in order to be in compliance with the permit conditions. Should have started earlier. Mid March - Late June, 105 days, is a very tight, aggressive schedule and should have been better scheduled and implemented. Public participation should not be sacrificed for untimely agency coordination. Some issues may be resolved through tiering and MMRP in the Final PEIR. LACo EWMP vs 12 additional EWMPs in 90 days following LACo BOS approval and certification may be in jeopardy. 12 EWMPs are required and presumably requires local jurisdictions to have discretionary actions by city councils. Presumably the cities will reference the LACo EWMP-PEIR as CEQA compliance but must have the project specific and local BMP E/Rs1MNDs processed to be in compliance with this PEIR and CEQA. As stated herein this PEIR, the PEIR does not complete the CEQA compliance for the 12 EWMPs and their CEQA considerations. LACo EWMP COMMENTS 11J Dr. Tom Williams March 16, 2015 Final Comment Letter 20 CCSC p.1-3/2 As a result, the LACFCD has prepared this Program Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the 12 EWMPs. VV Relationship and contents of the master PEIR and tiered EIRs/MNDs and other CEQA documents are not clearly provided. The statement and others promote confusion between the EWMP and the EWMPs and between the PEIR and CEQA considerations for the 12 EWMPs to be tiered off of the PEIR and documented separately. p.1-3/2 The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior to submittal of the EWMPs. The EWMPs will be submitted by each EWMP group to the LARWQCB. WW Discretionary actions by the BOS do not substitute for the discretionary actions by the 12 jurisdictions of the "EWMP Groups" (cities) to approve the 12 local EWMPs and their incorporate BMP projects. What is an "EWMP Group"? Presumably one or more cities who will agree on an EWMP and vote to approve the EWMP before submission the the LARWCBrd. CEQA requires environmental XX considerations other than referencing this PEIR for the 12 local EWMPs. p.1-3/3 This PEIR describes and evaluates each of the EWMPs being prepared by the Permittees collectively. This statement suggests that this PEIR covers all EWMPs prepared by an "EWMP Groups" and that they have been prepared and incorporated herein. No documentation is provided as to whether cities approved and authorized any local EWMP and its inclusion herein. Presumably one or YY more cities who will agree on an EWMP and vote to approve the EWMP before submission the the LACo for inclusion in the PEIR and submission to the LARWCBrd. CEQA requires environmental considerations of the local discretionary actions other than referencing this PEIR for the 12 local EWMPs. p.1-3/3 The discretionary action prompting the need for CEQA compliance is the submittal of the completed EWMPs to the LARWQCB. Submission is not a discretionary action but a ministerial action on the part of a department ZZ following the discretionary action of a Board of Supervisors, city council, or other public elected body to approve the local EWMP and its shcedule and funding. p.1-3/3 A few of the BMPs [--Projects] are currently well defined but most are yet to be fully developed under the 12 local EWMPs. A set of priority BMPs f=Projects] will be detailed in each of the EWMPs; these are being developed in parallel with the PEIR. The PEIR describes the details that are available for each of the 12 local EWMPs currently under preparation by the EWMP working groups. AAA Confused and demonstrates that this PEIR may be incorporating projects, BMPs (if different), some portions of the other 12 EWMPs, and the LACo EWMP which has not been approved by the LACo BOS. Is it EWMP group, EWMP Working Group, or Permittees? Are they the same or different? Have any T been approved and funded by a council in a discretionary action? Clarification is needed. 1 BBB 1-313 The EWMPs will identify management strategies including hundreds of structural Best Management Practices (BMPs) that may be designed and implemented by the Permittees to meet permit compliance objectives [Only one of the Program objectives]. Clearly indicates that this RAA model for water quality is not completed prior to its assessment and that the assessment cannot adequately assure that even the water quality goals and objectives CCC cannot be realized. Water quality and flow models and proposed BMP depend on diversion or reduction of flows during both dry- and wet -weather flows, and therefore the RAA must be based on a hyrdoiogic/hydraulic model which has not bee referenced or mentioned. LACo EWMP COMMENTS Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC This EWMP and PEIR must provide the programmatic management strategy guidelines for those of the tiered -down EWMPs-strategies and related CEQA documents. Use of the conditional: "mayT DDD be" voids following verbs and leaves the statement as irrelevant to the Program and Project 1 EIRs. p.1-4/par.3 The EWMPs... discussion of the environmental documents, assessments, and permitting required for the implementation of the priority projects. The PEIR can provide a basis for this discussion... PEIR in the development and implementation of the EWMPs is further discussed in this EEE chapter in the Purpose of the Program Environmental Impact Report. Priority BMPs were discussed but have not been distinguished from "Priority Projects". A "priority project(s)" are not defined and therefore the statement is rendered meaningless. Throughout the referenced section 1.3 (p.1-9 - 1-10), statements are made as to "can" rather "shall" and thereby the PEIR does not establish a procedure for the tiered environmental documents shall assess their environmental impacts and provide mitigation. FFF The PEIR does not discuss the process of tiering to projects or to specific BMPs and whether Mitigated Negative Declarations will be tiered down from this PEIR or whether the project must require tiered/focused EIRs for full and adequate CEQA compliance. The PEIR must provide a procedural context for most if not all elements for the Project El `MND by the local agencies as the LACo shall be a responsible if nota lead agency for each Project. As GGG provided the PEIR is incomplete and inadequate for establishing an expected or required procedure and process for preparation of a project specific CEQA document. 1-5/3 Watershed Management Programs The MS4 Permit Section VLC (page 47) includes provisions that allow Permittees to voluntarily choose to implement a Watershed Management Program (WMP). The purpose of this program is to "allow Permittees the flexibility to develop Watershed Management Programs to implement the requirements of [the] Order on a watershed scale through customized HHH strategies, control measures, and BMPs. $1 The permit states that "participation in a Watershed Management Program is voluntary and allows a Permittee to address the highest watershed priorities." CEQA is not voluntary and the "Program" must provide the structure for the tiered CEQA process to operate and satisfy CEQA for each project or tiered PEIR. The permittee is not the department but the City or County. Provide a listing of all councils which have approved development and submission of an EWMP to the Regional Board. As a program, provide all documentation as to whether the subsidiary agencies have committed to I the Watershed program or whether they have voluntarily chosen not to participate. No priorities are provided - references are made to conservation priorities, pollutant priorities, renewable priorities water quality priorities, and watershed priorities (and highest watershed JJJ pr...), but only some water quality priorities are discussed. 1-7/1 • Other Receiving Water Considerations (second category): - The second highest priority shall be considered controlling pollutants for which data indicate impairment of exceedances of receiving water limitations and the findings from the source assessment implicates discharges from the MS4. KKK As no hydrologic model for flows and concentrations has been provided even for the TMDL constituents, references to secondary pollutants appears totally inappropriate and purposefully attempts to elevate the credibility of compliance with the TMDL, which has not been achieved. 1-7/2 The EWMP prioritization process includes identifying the priority pollutants and... schedule for implementing BMPs to meet the following criteria: • For pollutants... same class as TMDLs.... consider these pollutants within... same time frame LLL as ... TMDLs. • For ... 303(d) list ... EWMPs develop a schedule to address these pollutants as soon as possible with milestones. LACo EWMP COMMENTS Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC Priority pollutants have already been prioritized and identified, and the prioritization process has not been described although referred to, and no schedule for prioritization, definition of priority projects or priority BMPs has been provided. LLL Prioritization process and schedule are rendered totally inadequate when modified by whenever Cont. "possible". MMRPIan must include a full and scheduled prioritization process for ALL EWMPs. HYDROLOGICAL MODEL References to hydrological "Model" 1-811 Reasonable Assurance Analysis ...(RAA) is ... to demonstrate "that the activities and control measures will achieve applicable water -quality -based effluent limitations and/or RWLs with compliance deadlines ........ as a quantitative demonstration that control measures (such as BMPs) will be effective, the RAA also provides an opportunity to use a modeling process to identify and prioritize potential control measures. The RAA for each EWMP uses a model to simulate a critical storm (design storm) and ... achieve compliance with the TMDLs and water -quality -based effluent limitations. MMM 1-812 The RAA is being performed as part of the preparation of the EWMPs, and in parallel with ... this PEIR. The RAA... primary goal of the EWMP ... meet the water quality goals. The modeling being performed... will determine... number and distribution of the BMP types and specific projects identified in the EWMP Work Plans will meet the water quality goals. This PEIR will assess the types of BMPs that may be implemented to meet these WATER QUALITY goals. As indicated in the PEIR text and appendices, the PEIR lacks any quantified Hydrologic Model for watershed controls and has focused the only "modeling" on meeting the water quality requirements of the MS4 at discharges, not watershed controls. Management strategies (MSs) presumably are different from the BMPs and the EWMPs which they T maybe be parts of, but MSs are not defined nor associated with BMPs and EWMPs. NNN 1 The RAA and a supporting/integrated Hydrologic Model must be provided in a final form to be incorporated, not be performed in parallel, with full integration/incorporation. The MMRPIan T 000 must include a final RAA. 1 Apdx A NOP 8/5 In accordance with the provisions of the MS4 permit, the work plans describe the following steps to EWMP development: 2. Characterization of existing and potential control measures within the watershed PPP 3. Addressing the approach to incorporate reasonable assurance analysis (RAA) in the optimization of watershed control measures 3.2 Air Resources and 3.6 GHGs These sections reference many air -related models and modeled/modeling results and comparable to requirements for surface, recharging, and ground waters. Apdx A. Comment Letter to the LACFCD: Draft PEIR p.16/Item 56: Foothill Municipal Water District Recycled Water Project ... Cal Poly Pomona has partnered with FMWD and is developing a model that will also capture stormwater for recharge using the same infiltration galleries. pdf-254 Comments - Model ...no cost/benefit analysis or any modeling completed to QQQ substantiate the "cost-effectiveness" of these methods. Please identify any additional documentation supporting this claim. Enrique Huerta Downey, CA ehuerta28@gmail.com Scoping Comment Letter indicated that minor agencies/permittees may have conducted some form of hydrological model but not the EWMP or the PEIR. 1-911 The LACFCD will consider the information presented in this PEIR, along with other factors, in the development and implementation of the EWMPs. The EWMPs are to include a discussion of the environmental documents, assessments and permitting required for the implementation of therip ority projects. The PEIR can provide a basis for this discussion. 1-1012 The EWMPs are to include a discussion of the environmental documents, assessments, and permitting required for the implementation of the priority projects. Repeated RRR Consider and other factors are not defined and as such allow the entire PEIR process to be set- aside. The PEIR does not fully define the roles and participations of the LACFCD in the development of tiered EWMPs and their CEQA documents. Again "priority projects" are mentioned and not defined with regard to "priority and potential BMPs." LACo EWMP COMMENTS Dr. Tom Williams March 16, 2015 Final Comment Letter 20 CCSC CEQA texts must recognize differences between "can/could provide" and "will/would provide" and RRR require clarity as to what will occur in the teiring of projects and CEQA documents. Cont. 1-9/3 Purpose of the Program Environmental Impact Report The LACFCD determined that implementation of the 12 EWMPs could have a significant effect on the environment and therefore required preparation of a PEIR...- to provide... information about... significant environmental effects of the proposed program [=EWMP], to identify possible ways to minimize potentially significant effects [=PEIR/EIR Mitigation measures], SSS and to describe and evaluate feasible alternatives to the proposed program [=EIR Alternatives]. Use of EWMP, EWMPs, and Program causes confusion as to what is what and what will be presented in each. PEIR and EWMP/s must be revised for consistency. 1-9/4 This document has been prepared as a PEIR ... one type of environmental review document that may be used to evaluate a plan or program that has multiple components (projects and actions) or to address a series of actions that are related in any of the following ways: Geographically. As logical parts in the chain of contemplated actions. • ...issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program. TTT • As individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental effects that can be mitigated in similar ways. No logical chain has been graphically depicted/modeled and arranged to demonstrate and monitor progress to and through the permit and compliance process for such a wide variety and mammoth scale of the projects and their components (e.g., diversion -transmission -spreading - recharging -production). 1-11/1 Maps identifying potential and priority BMP locations are provided in Chapter 2 ... with the overall EWMP watershed characteristics and BMP implementation strategy. No definition or specificity of potential and the subgroup priority BMPs and locations nor details are provided within the tables and generalized maps. No watershed characteristics are provided UUU regarding runoff coefficients, design rainfall amounts, times of concentrations, are estimated flow levels are provided for any watershed, not even a ranking of highest to lowest flows or highest -lowest dry- and wet weather water qualities. 1-11/1 The PEIR focuses its assessment on construction and operation of these potential and priority BMPs to be installed throughout the watersheds—but primarily within urbanized areas where the pollutant loading is greatest and where these BMPs can be most cost-effective in meeting water quality goals. No focused information is given regarding the BMP operations and their effectiveness in removing VVV pollutants and meeting water quality goals (not objectives). No information is provided regarding the degree of urbanization for each watershed, nor the assumed "loadings" being greater, median, or least. Herein "priority" and "potential" BMPs are equated while in other statements there are implied "priority" and "non-priority" "potential BMPs". I WWW BMPs are presumed as cost effective without documentation and analyses as to pollutant - presenf/removed per 100 acft or any other quantified parameter and as to achievement of current reductions down to desired goals. XXX Clarify and apply consistently BMPs assignments. 1-11/2 Scoping Period ...A Notice of Preparation (NOP) ... was circulated to ... other interested parties ...discussed the purpose of the EWMPs and their management strategies, identified the EWMP Study Areas, and provided a brief and preliminary list of environmental issue areas that could be impacted. As indicated in Scoping Comments, the PEIR does not reflect comments provided during the Scoping period and for the Initial Study and Notice. -Socio-economics and revenue sources to assure operations and maintenance, - Environmental justice LACo EWMP COMMENTS 10 YYY Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC YYY Y Cont.Water models or Other Quantitative Estimates/Flowcharts I � Con 1-18/2 Chapter 1.0, Introduction. This chapter discusses... the background and purpose of the PEIR for the proposed program. The PEIR does not provide the objective, full disclosure, complete, and adequate purposes of the ZZZ EWMP, and therefore the purposes of the PEIR cannot be satisfied. Similarly, the PEIR is suppose to be publicly understandable/accessible which it is not. Issue -Water Supply 2-1/ The structural watershed control measures that will be implemented by the LACFCD will be multi - benefit stormwater projectsthat emphasize flood risk mitigation... AAAA Control [=BMPs] measures refers to stormwater/flood risk mitigation = Flood Control which is not developed and is not part of the Program Goals. EWMP/s may claim multiple benefits but must provide documentation and analyses in order adequate support such claims. p.2-1/par.3 This Project Description describes types of BMPs... to illustrate the function, type of construction, and general locations of the BMP types for the purpose of the environmental assessment of the BMP types identified in the EWMPs. BBBB As indicated elsewhere, the local conditions govern where the optimal locations for BMP would be and general assessments cease to be appropirate for CEQA compliance unless the forms and procedures are provided to reflect the local assessment in the project E/Rs/MNDs. 2-2/2 2.2 Project Goals awc4CJajaWia�as Therip mare goals and objectives of the EWMPs are: • To collaborate among agencies (Permittee jurisdictions) ... to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the MS4 Permit. • To develop watershed -wide EWMPs... remove or reduce pollutants from dry- and wet -weather urban runoff in a cost-effective manner. • To reduce the impact of stormwater and non-stormwater on receiving water quality. [#2 and #3 are virtually identical and only differ by the "terms" used: Wet vs Dry Weather Flow vs Stormwater and Non-Stormwater, which would be defined the same] [In #1 and #2, references are made to cost-effectiveness although never discussed and compared.] Reference to costs requires a description, assessment of impacts, and provisions for the life of the project - at least 25 years. Most importantly are provisions sufficient annual funding for operations and maintenance of all facilities through and beyond 2040. Assessment must include best -available information and projections economic, financial, bonding, costs (both capital and O&M), and ability to pay by the service populations. This is particularly important as the LACo and associated cities are promoting changes of "Storm Water Fees on the LACo annual property taxes and fees. This deficiency and conflict clearly indicate that the entire PEIR is incomplete and inadequate with regard to costs and other related issues for the proposed program. [@1618167 Table 2-3 Project Feature - Flood Protection No description of flood protection is developed for the EWMP and thereby must not be included, or T mentioned, without development and assessment of benefits and impacts. No 111 DDDD coordination/collaboration has been referenced or known in the LACity Floodplain Management Plan. 2-5/1 Additional information and figures on the location and distribution of potential and priority BMPs based on available data at the time of publication of this PEIR, are presented in Section 2.5, EWMP Watershed Characteristics and BMP Implementation Strategies. EEEE No additional information is provided regarding the City of Los Angeles array of 400+ projects/BMPs. Public Health and BMP Maintenance (ongoing annual costs) LACo EWMP COMMENTS 11 Dr. Tom Williams Comment Letter 20 March 16, 2015 Final CCSC 2-9/1 Wet detention ponds may require engineering... to ensure that the permanent pool does not become stagnant and a magnet for mosquito production (must be emptied within 72 hours). "Wet detention ponds" and dry ponds are not characterized and compared. No engineering FFFF mitigation measures are provided to mitigate this important potential impact in the urban/suburbanized areas in the vicinity of such "ponds" Rain Barrels 2-1312 Planter Boxes. Planter boxes are bioretention systems... where space constraints limit the implementation of other LID elements... designed to both filter and store runoff... used in combination with rain barrels and cisterns that store the runoff and then direct it into these boxes to filter the runoff. 2-14/2 Rainfall Harvest. Rainfall harvesting improves water quality by intercepting rooftop runoff... rain barrels are storage tanks used to intercept and store rooftop runoff for nonpotable use such as landscape GGGG irrigation or gradual infiltration. Rain barrels and planter boxes can suffer from the same public health issues as "detention ponds". Rain barrels are important components of the LID programs but most if not all LID ordinances require only two barrels (e.g., 100 gal storage) for a typical 1000-2000sgft roof on single family dwellings which would generate 450-900 gal of roof runoff for the design storm. Revise the ML entire LID write-up. 2-1512 Source Control BMPs. Source control structural BMPs are commercial products designed to treat runoff in highly urbanized environments. Mechanical separation, or more complex physicochemical processes, provides separation of gross solids and other pollutants... designed to sequester hydrocarbons and other pollutants. HHHH Residual pollutants and their disposition is not mentioned nor provided anywhere in the PEIR. No discussion is included regarding the soil sequestering of hydrocarbons, metals, and other pollutants in the ground materials (especially in/on clays). No estimate is provided as to anticipated sequestering per year and probable long-term removal of soil materrials before they achieve "hazardous" levels. 2-1612 Specific examples of distributed BMPs that are in various stages of planning and implementation and part of a possible EWMP are presented in Table 2-3. The locations of these examples of planned distributed BMPs are shown in Figure 2-2. Table 2-3 presents the locations, project description, and key elements of the distributed BMPs to further illustrate these types of structural BMPs that may be part of III an EWMP. Additional information and figures on the location and distribution of potential and priority BMPs, where data areis available, are presented in Section 2.5, EWMP Watershed Characteristics and BMP Implementation Strategies. Centralized and Regional BMP discussions repetitive from 2-1612 except as highlighted. TO BE SUBMITTED p.2-18 Upper LA River Brandon Street and Green Street Improvements Project The project will reconstruct... roadway... design includes... Much of the runoff from the streets and private properties that would have otherwise drained to the Rio Hondo will be directed to the infiltration area. How much 2-19 Upper San Gabriel River Avocado Heights Multiuse Trail Project The project will ... thereby reducing the amount of impermeable surfaces as well as runoff. Approximately ... Combined together, up to 115 acre-feet of groundwater will be recharged annually. 2-2211 Infiltration BMPs. Infiltration facilities are designed to decrease runoff volume through groundwater recharqe and improve water quality through filtration and sorption. No discussion of beneficial effects is provided for rising base flow JJJJ providing greater dilution volumes assuming that discharges remain constant, or providing higher water levels when stormwater arrives at downstream locations and thereby elevating the flood water levels and inundation extent. 2-2613 Creek/River/Floodplain/Estuary Restoration. This category includes multi -benefit projects that KKKK typically combine elements of habitat restoration... as flood management and water quality improvement. LACo EWMP COMMENTS 12 Dr. Tom Williams March 16, 2015 Final Comment Letter 20 CCSC Project components such as ... setback levees, floodplain bench excavation, levee breaches, and other actions can increase... flood storage capacity... ...This project restored 1.2 miles of natural bottomed creek habitats, which are capable of infiltrating up to KKKK 118... million gallons of stormwater from the wash into the local groundwater aquifer. Cont. Plants in the wash also aid the biogeochemical removal of pollutants such as nitrogen. Actually bacteria and fungi attached to the cellousic stems and leaves that are periodically submerged. Few emergent plants can absorb or treat any aqueous pollutants. TO BE SUBMITTED 2-2812 ...centralized BMPs ... presented in Table 2-4. The locations of these examples of planned and implemented centralized BMP ... in Figure 2-3. Table 2-4 ... the centralized BMPs ... structural BMPs that are part of the EWMP.... of potential and priority BMPs, where data areic available,. ..BMP Implementation Strategies. 2-26[2 Typical constructed wetland projects require extensive grading of site soils, though excavated soils are often balanced on- site to provide material for levees, berms, ecotones, and other flood control/habitat features. 2-2712 Multi -benefit flood management projects. This category... designed to result in direct or indirect benefits to flood management. ...Tujunga Wash Greenway project that incorporates ... detention elements can improve flood management by reducing stormwater flow rates and/or volumes. 2-2713 Construction Impacts. Multi -benefit flood management protects are typically expansive projects that range from a few to tens of acres in size... Because of their scale, multi -benefit flood 2-28/1 management projects... 230 TABLE 24 EXAMPLES OF PLANNED CENTRALIZED BMP PROJECTS This project will also have educational signage on a riparian zone and the stormwater cleanup objectives of this project. 2-30/Table 2-4 Item 2 Malibu Creek Lindero Parkway Improvements The project ... streetscape improvement project that ... this parkway was originally a flood control maintenance road ... new project .... Stormwater runoff would then be treated in the bio-swale followed by discharge into Westlake Lake ... also have educational signage on a riparian zone and the stormwater cleanup objectives of this project. FP 2-31/Table 2-4 Item 4 Palos Verdes Peninsula San Ramon Canyon Stormwater Flood Reduction Project The San Ramon Canyon... near Palos Verdes Drive East.... landslide induced rock and soil deposits in the canyon bottom are transported during heavy rainfall events... creates flooding of the roadway, overwhelming existing drainage facilities, endangering nearby roadway integrity and threatening downstream residents ... (SRCSFRP) involves significant drainage restoration work to stabilize... FP 2-32/Table 2-4, Item 2 Phase II of the Penmar project... Replacing this volume of potable water with treated storm water... provides 34.7 million gallons per year increase to annual runoff diversion capacity ... By installing the reuse option, the overall project capacity will increase, thereby also increasing the volume of urban runoff that can be retained by the project for use as an alternative source of water to potable water for landscape irrigation. 2-3411 2.4.5 Regional Structural BMPs Regional structural BMPs are those that can capture the volume of water from an 85th percentile. 24 -hr storm in a contributina watershed. known as the desian volume /...85th percentile storm ... 0.75 inches over 24 hours). The project's BMPs... alleviate local flooding by collecting runoff from a 21 -acre drainage area ... into two underground infiltration galleries... 2-3412 Anticipated Construction Activities: The construction activities...are generally similar to those of their centralized counterparts, with the exception of regional retention BMPs .... adequate storage capacity to hold runoff from the design storm.... Larger, multi - benefit regional BMPs are similar to centralized multi -benefit regional flood management proiects... LACo EWMP COMMENTS 13 Dr. Tom Williams March 16, 2015 Final Comment Letter 20 CCSC 2-3511 ...regional BMPs... of planning and implementation and that are part of the EWMP are presented in Table 2-5. The locations of these examples of regional BMPs are shown in Figure 2-5. Table 2-5 ... of the regional BMPs to further illustrate these types of structural BMPs that are concepts being developed through the EWMP process. ...of potential and priority BMPs, where data am& available... BMP Implementation Strategies. The complex repetitive wording and slight but several differences in these texts cause considerable confusion for the public review and participation in this CEQA process. Without clear table -ed presentation meaning and clarity are lost, rending these important issues inadequately treated in this PEIR. 2-4011 Summarized below are the general characteristics of the watersheds within the EWMP Groups and the overall strategies for BMP implementation ... twelve EWMPs are consolidated to six watershed areas... summary provides additional detail on the distribution and location of potential and priority BMPs, where data is available,... for each EWMP and show the location and distribution of planned and priority regional/centralized BMPs for which data are available at the time of publication of this PEIR. The priority BMPs ... subset of the potential BMPs that have undergone a site review and project evaluation that has identified these BMPs as a priority. These priority projects are shown based upon available data at the time of publication of this PEIR. EWMP groups, EWMPs, and watershed areas are inadequately associated and defined; presumably 12 EWMPs may be associated into 6 EWMP Groups based on watershed associations. Similarly designations as to: Potential, Planned, and Priority BMPs - Priority BMPs are part of Potential BMPs Regional and centralized BMPs - excluding distributed Priority projects or BMPs; require clear definitions and ordering in order to have adequate clarity for public review. 2-4011 Appendix G provides the location and general description of the priority BMPs ... Distributed BMPs are planned to be implemented throughout the urbanized areas of each EWMP. 2-4313 ...Figures 2-5 through 2-16, each of the EWMPs ... wide distribution of BMPs to achieve permit compliance. Appendix G provides the locations and general descriptions of the priority BMPs (where data is available),... Priority Projects are projects that have been identified through the EWMP process as targeted for implementation within the first years following the EWMPs approval by the LARWQCB. Identification of Priority Projects is underway and has not been completed by all EWMPs at this time. [For any??] ... PEIR is being prepared in parallel to the EWMPs. Priority Projects [proper noun] will be defined in all the EWMPs to be submitted for public comment in June 2015. Priority Projects that have been identified at this time through the EWMP process are shown on the following figures. Priority Projects may be regional, centralized or distributed type BMPs. For potential proiects... location of potential regional and centralized BMPs are shown. Distributed BMP will be distributed throughout the urbanized areas and are not shown on the following figures ...2-4411... No "general description" is provided for the program, projects, and BMPs, as summarized below, only listings and figures found in the Vol. 1. Apdx. G EWMP Proposed BMP and Priority Project Data and Figures A -L, pages unnumbered items renders the entire appendix confusing and un - reviewable for the general public and the only "General Description" is APN numbers. LLLL 2-4117 This watershed is further differentiated by the importance of groundwater recharge basins that are supplied by a series of reservoirs further upstream... No information is provided regarding the basins, total projected annual recharge flows, and NNNN relationships between "reservoirs" and "recharge basins" presumably the augmented groundwater storage basins, rather than basins used for recharge. TO BE SUBMITTED 2-4214 The Los Angeles River—natural hydrology of the Los Angeles River watershed has been altered by channelization and the construction of dams and flood control reservoirs... Because of the greater extent and number of pollutant priorities, the BMP strategy in the Upper Los Angeles River watershed includes well over a hundred planned regional and centralized retention and infiltration BMPs [Estimated unfunded projects: 400] that take advantage of the favorable groundwater recharge LACo EWMP COMMENTS 14 Dr. Tom Williams March 16, 2015 Final Comment Letter 20 CCSC characteristics... BMP strategy also includes distributed smaller BMPs located throughout the urbanized areas of the watershed as retrofits in existing developments and streets. i to comply with dry -weather bacteria TMDLs may also be included. 2-42/4 ...BMP strategy in the Upper Los Angeles River watershed includes well over a hundred planned regional and centralized retention and infiltration BMPs that take advantage of the favorable groundwater recharge characteristics.... No definition of BMPs has been applied to the projects proposed. 0000 No map or other descriptive information of the 100+ retention/infiltration BMPs have not been provided. No comparison or prioritization or even definition of favorability or recharge characterization have been provided. 2-57/1 2.6 EWMP BMP Implementation Schedule The EWMPs that are being prepared in parallel to the PEIR will provide a timeline for the implementation of the BMPs [as define in MS4/TMDLs]... priority BMPs... that have undergone a site review and project evaluation and ... based on available data at the time of publication of this PEIR... Implementation of priority BMPs will begin following approval of the EWMPs by the LARWQCB... depend on the approval of the EWMPs, 1) further environmental assessment, 2) permitting, and 3) availability of funding sources. The EWMPs will be submitted to the LARWQCB in June 2015. The entire process of LACo-EWMP, EWMPs, BMPs, etc. and implementation of "Priority BMPs" have not been fully provided nor adequately documented. As indicated above, a fully scheduled/timed EWMP/EWMPs implementation schedule for all BMP and for further - annual - updating must be included in the Final PEIR perhaps as part of the MMRPIan for PEIR and within each EWMPs' CEQA documents. Statements as to the submittal dates in less than three months clearly indicates that undue pressure is being attempted in order to force the CEQA and project development processes through without due consideration as to the completeness and adequacy of project, program, and CEQA documents and processes. 2-57/4 Each EWMP will define priority projects, and installation of these projects will move forward depending on the availability of funding and outcome of further project -specific CEQA review. Funding options for implementing agencies would include obtaining grant funds, low-interest loans, tax - based general funds, or special assessments. Each jurisdiction will be responsible for securing the necessary funds over time to achieve permit compliance. References to but absence of information regarding funding, funds, and other related economic/financial elements and their pivotal importance to any "Project" renders continued discussion of projects inadequate and incomplete and subject to major changes of any PEIR referenced "project between now and July 1, 2015 and thereafter. Introduction of 'jurisdiction" renders the discussion meaningless, incomplete and inadequate. TO BE SUBMITTED 3.1-1213 BMP maintenance is also important... Wet ponds and constructed wetlands can also become mosquito -breeding grounds...can usually be reduced or eliminated through proper design and/or organic controls.[=maintenance]..all BMPs need to have trash and debris removed periodically to prevent odor and preserve aesthetic values. With proper maintenance... impacts would be less than significant. Nothing about public health Public Health not well discussed at Program levels PH not discussion Odor Disease vector Mosquito 3.1-15/TABLE 3.1-1 SUMMARY OF ... IMPACTS REQUIRING MITIGATION MEASURES Distributed BMP LID - Green Infrastructure - Capture and Use - Cisterns, Rain Barrels, Green roofs, Planter Boxes 3.5-19/2 City of Los Angeles Low Impact Development Manual LACo EWMP COMMENTS 15 777, QQQQ Dr. Tom Williams March 16, 2015 Final Comment Letter 20 CCSC In November 2011, the City of Los Angeles adopted the Stormwater Low Impact Development (LID) Ordinance #181899) with the stated purpose of: Requiring the use of LID standards and practices in future developments and redevelopments to encourage the beneficial use of rainwater and urban runoff Reducing stormwater/urban runoff while improving water quality Promoting rainwater harvesting Reducing offsite runoff and providing increased groundwater recharge Reducing erosion and hydrologic impacts downstream Enhancing the recreational and aesthetic values in our communities 3.5-19/3 The City institutionalized the use of LID techniques... adoption of the Stormwater LID Ordinance, the City prepared the Development Best Management Practices Handbook, Low Impact Development Manual,... required BMPs (City of Los Angeles, 2011). 3.7-17/2 The LID Standards... provide protocols for designing regional and centralized BMPs that minimize the potential for contaminant loading. For example, the LID Manual requires a certain distance to groundwater to ensure that adequate soil filtration occurs prior to the percolating water reaching a drinking water aquifer. 3.8-1/3 Annual precipitation can vary significantly between drought and flood conditions; periodic and occasionally severe droughts and floods within the area are well-documented (LARWQCB, 1994), and the potential for extreme precipitation (maximum intensity of precipitation for periods of 12 hours or longer which might be expected at intervals of ten to 100 years) is greater in portions of the San Gabriel RRRR Mountains than practically anywhere else in the continental United States (WERC, 2014). Average annual rainfall within the Los Angeles Basin is approximately 14.5 inches, though local averages can vary considerably depending on location within the basin (WERC, 2012). No adequate stormwater flow forecast 85%ile No forecast as to effects Climate changes is provided. TO BE SUBMITTED 3.8-812 5. Dominguez Channel Watersheds (Figure 3.8-6) (Dominguez Channel EWMP and Beach Cities EWMP— ...Dominquez Channel EWMP and a portion of the Beach Cities EWMP... differentiated by a larger area of industrial land use. Because of the high density... large regional and centralized infiltration -type BMPs will be limited. The structural BMP strategy will be more LFDs, both large (centralized) and small (distributed), located at M84 outfalls ... The other BMP strategy is the use of smaller distributed BMPs ... low -impact development (LID) type of BMPs, such as green streets and biofiltration BMPs. 3.8-4/3 EWMP Groups The proposed program has been divided into 12 EWMP Areas that have been organized by watershed groups that share comparable conditions. The 12 EWMPs are consolidated into six watershed areas that are grouped by similar watershed characteristics ... and also provide hydrologic features and the locations and distribution of planned and SSSS priority regional/centralized BMPs. No comparable, similar, or differing watershed conditions or characteristics have been identified other than physical channel connections. 3.8-4/3 The priority BMPs are a subset of the planned BMPs and have been selected as priority projects based on a screening assessment of the planned projects. Priority projects will be implemented before additional planned projects. TTTT Define and compare priority, planned, and potential BMPs and projects. Referenced "screening assessment" has not been described. 3.8-4/3 Distributed BMPs are planned to be implemented throughout the urbanized areas of the EWMPs. No plan provided for distributed BMPs within the EWMP or available EWMPs. UUUU No designation as to whether distributed BMPs/Projects will be priority, potential, or just planned projects; as provide after the priority projects. TO BE SUBMITTED 3.8-20/1 ...these LFDs could potentially increase the amount of water available for recycling, reuse, and groundwater recharge. LACo EWMP COMMENTS 16 Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC 3.8-21/1 ...45 percent are supplied by local groundwater basins that are recharged naturally... through constructed recharge facilities (MWD, 2010). 3.8-21/1 ...stormwater recharge facilities currently augment local groundwater supplies in the region by an estimated 477,000 acre-feet per year (MWD, 2014). 3.8-21/1 One of the primary goals of the EWMP program... increase the amount of stormwater that is recharged... particularly in portions of the Central Basin that experience a high degree of hydraulic connectivity between surface water and groundwater. Infiltration BMPs proposed within the EWMPs are expected to increase the rates and amounts of groundwater recharge... 3.8-31/3 County of Los Angeles Low Impact Development Manual The County... prepared the 2014 Low Impact Development Standards Manual (LID Standards Manual, County of Los Angeles, 2014b) to comply with the requirements of the 2012 MS4 Permit... provides guidance for the implementation of stormwater quality control measures in new development and redevelopment projects in unincorporated areas of the County with the intention of improving water quality and mitigating potential water quality impacts from stormwater and non-stormwater discharges. 3.8-31/4 The LID Standards Manual addresses... objectives and goals: Lessen the adverse impacts of stormwater runoff from development and urban runoff on natural drainage systems, receiving waters, and other water bodies. Minimize pollutant loadings from impervious surfaces by requiring development projects to incorporate properly -designed, technically -appropriate BMPs and other LID strategies. Minimize erosion and other hydrologic impacts on natural drainage systems by requiring development projects to incorporate properly -designed, technically appropriate hvdromodificat control development principles and technologies. Not objective - goals yes. City of Los Angeles Low Impact Development Manual 3.8-3115 In November 2011, the City of Los Angeles adopted the Stormwater Low Impact Development Ordinance #181899 with the stated purpose of: Requiring the use of LID standards and practices in future developments and redevelopments to encourage the beneficial use of rainwater and urban runoff Reducing stormwater/urban runoff while improving water quality Promoting rainwater harvesting Reducing off-site runoff and providing increased groundwater recharge Reducing erosion and hydrologic impacts downstream • Enhancing the recreational and aesthetic values in our communities 3.8-31/6 The City of Los Angeles institutionalized the use of LID techniques... Subsequent to the adoptio of the Stormwater LID Ordinance, the City prepared the Development Best Management Practices Handbook, Low Impact Development Manual, dated June 2011, to describes the required BMPs (City of Los Angeles, 2011). LID provisions for rain barrels for single family dwellings are only 10-20% of the total detention required for the design storm. TO BE SUBMITTED 3.8-3512 Mitigation Measure HYDRO -1 requires Permittees to evaluate the suitability of BMP locations for groundwater recharge. Infiltration BMPs would not be suitable in areas of low permeability where subsurface structures could be adversely affected by groundwater mounding. 3.8-4115 Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs ...Implementation of the proposed structural BMPs,... other reasonably foreseeable future projects... result in improved stormwater quality and reduced non storm flows.... will experience reduced dry -weather runoff, a more natural hydrology, and improved receiving water 3.8-42/1 quality. In addition, new infiltration projects will incrementally augment groundwater drinking water supplies. Although the increased infiltration projects may increase pollutant loads to groundwater aquifers, pretreatment systems coupled with regional Significance Determination: Less than Same as Comment 20-0 above Same as Comment 20-P above LACo EWMP COMMENTS 17 Dr. Tom Williams March 16, 2015 Final Comment Letter 20 3.8-431TABLE 3.8-3 SUMMARY OF HYDROLOGICAL RESOURCE IMPACTS REQUIRING MITIGATION MEASURES Cumulative Impacts, No mitigation required Without a hydrologic model and analyses especially for the "design storm" no objective assessment of. CCSC 3.14-15/5 Water Supply Impact 3.14-3: The proposed program (=EWMP] could require new or expanded water supply resources or entitlements or require or result in the construction ... could cause significant environmental effects. Given the general purpose of the EWMP is to recharge groundwater in a urban -suburban context where groundwater is used for water supply, such "conditional -could" appears totally inappropriate and must be technically defined/determined in order to fully and adequately discussed environmental, cost-effectiveness, and compliance with discharge water quality limits over the life of the projects. 5-3/1 The proposed program is not a land use project and its implementation would not introduce new ... or any other growth -inducing land uses. The structural BMPs would augment the physical structure of established communities .... and enhancing the water quality of existing communities. As a result, the proposed program would not induce population growth. Most infrastructure projects do not involve much in the way of direct structured development; however, operations of such facilities support development of user structures especially where water and other service may be constraining support factors. 5-3/2 The nature of reducing the proposed program is to increase stormwater recharge and improve stormwater quality;... would not result in increased economic activity or population growth in the EWMP areas ... water recharged... is anticipated to support existinq water supply needs and reduce Mechanisms or rules are NOT provided as to how various project waters would be assigned to reducing imported water dependence while others may be used for supporting growth. 5-3/3 5.4 Secondary Effects of Growth Implementation ... would not result in a direct or indirect increase in population or employment. The proposed program itself, therefore, is not growth -inducing and would not induce secondary effects of growth. Such a broad reaching statement cannot be justified as implementation (?=construction) and presumed operations (say 10% of total capital costs annually) would generate new employmem within the project area and would divert funds for imported water sources outside the project area to the more local based water sources and operators employed therein. 5-3/3 While one of the main goals of the EWMPs is to increase infiltration and potentially increase recharge of stormwater ... the amount of water potentially recharged would not be enough to indirectly support population growth and is intended to support existing water supply needs. This potential additional recharge would contribute to local water supply needs but would not alter population demographics. Therefore, there would be no secondary effects of growth. Mechanisms or rules are NOT provided as to how various project waters would be assigned to onl reducing imported water dependence while others may be used for supporting growth. Again, such a statement cannot be justified as local sources can easily augment existing or future distribution without specific assignment to service areas. 6-1/1 ...Environmental Impact Report (EIR) must describe... reasonable range of alternatives to a proposed project... could feasibly attain most of the basic project objectives... would avoid or substantially lessen... proposed project's significant environmental effects. 6-2/2 Alternatives may be eliminated... if they fail to meet most of the project objectives, are infeasible, or do not avoid any significant environmental effects. LACo EWMP COMMENTS 18 VVVV \rJ1rJlrirOOi XXXX Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC "Feasibly" is not clearly defined nor established as to whether the BMPs, EWMPs, or this EWMP can be done in technical and practical (=ECONOMIC) terms as required by the objectives and criteria for the program, the local programs/projects and BMPs. As technical feasibility is not at issue, the actual meaning of feasibly must relate to two of three goals having phrases of "cost- effectiveness". Therefore this use of feasibly and project objectives (not objectives but goal) are the costs and presumably capital and operations/maintenance. As no information is provided for costs and their fundings, these statements become totally inadequate and incomplete as no information is provided nor compared to demonstrate the alternatives compliance or lack of compliance with the MS4 permit conditions.. As two expressed "objectives" out of three include reference to "cost-effectiveness" the absence of demonstrated "cost-effectiveness" renders any comparison incomplete and inadequate for justifying an alternative discussion. The two objectives have no quantification nor scheduling and therefore are NOT OBJECTIVES but may remain as goals but without any supporting information as to costs and sources of revenues to support such costs. 6-1/3 "Feasible" means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors. No economic factors have been provided in the PEIR, including sources of revenues and abilities for LACo and all permittees. Therefore, the PEIR is incomplete and inadequate. 6-2/5 6.2 Review of Proposed Program Goals and Objectives The alternatives presented in this chapter were analyzed for their abilities to reduce significant program impacts and meet the objectives of the proposed program, which are: • To collaborate among agencies (Permittee jurisdictions) across the watershed to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the Municipal Separate Storm Sewer System (MS4) Permit. • To develop watershed -wide Enhanced Watershed Management Programs (EWMPs) that would, once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff in a cost- effective manner. • To reduce the impact of stormwater and non-stormwater on receiving water quality. Discussion starts with a title of Goals and Objectives then switches to objectives. These are goals not objectives as they are not quantified nor scheduled in any manner. Since two "objectives" refer to "cost-effectiveness" and no costs, revenues, economics, or financial information or assessment are not provided, all discussions of the achievements of goals and objectives becomes mute and the PEIR totally incomplete with regard to the "project" or "program" and its alternatives. Similarly reference to collaboration becomes mute as all related agencies and those in the county have already collaborated and therefore any "collaboration" discussion must be quantified which they have not been. As to compliance with permit conditions and reduction of impacts are only presumed without documentation which is under parallel preparation for June 2015 and without any hydrological modeling or calculations to support such contentions and comparisons amongst alternatives. Goals are not mentioned only objectives above. The entire PEIR appears incomplete without a clear statement as to typical goals and objectives - recharge dry and wet weather runoff and 20% recharge every five years for next 25 years. Total confusion as to goals and objectives renders the entire alternatives chapter totally inadequate. Absence of any costs/revenue information renders achievement of goals or objectives totally incomplete for both the development of the alternatives and their comparisons. The entire Alternatives section is incomplete and totally inadequate. 6-3/3 In accordance with the CEQA "rule of reason," an EIR is required to consider a range of alternatives that permit a reasoned choice and that are "limited to ones that would avoid or substantially lessen any of the significant effects of the project" (CEQA Guidelines Section 5126.6(f)). The Lead Agency conducted an alternatives screening process to identify feasible alternatives to the proposed program. The screening process for identifying viable alternatives included consideration of the following criteria: LACo EWMP COMMENTS 19 XXXX Cont. Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC • Ability to meet the program objectives • Ability to reduce significant environmental effects of the proposed program • Economic and engineering feasibility Since the program objectives require 2 of 3 items of "cost-effectiveness" and here a criterion requires meeting the program objectives, the PEIR appears inadequate and incomplete without the presence of and achievement of cost-effectiveness and economic feasibility -ability to pay for both vapital and O&M costs for at least 25 years. As no economic feasibility analyses and comparisons are provided, and no jurisdictional funding is provided throughout the PEIR, no reasoned or reasonable achievements of one of three criteria can be assessed or compared. 6-3/4 The Lead Agency conducted an alternatives screening process to identify feasible alternatives to the proposed program. The screening process for identifying viable alternatives included consideration of the following criteria: • Ability to meet the program objectives [presumes meet objectives or not considered] • Ability to reduce significant environmental effects of the proposed program • Economic and engineering feasibility [presumes to meet economic feasibility parameters and criteria not presents] Introduction of "Lead Agency" at this point would imply some agencies other than LACoDPW, perhaps LACoFCD (??); while reference to an "alternative screening process" indicates some formal process rather than that documented in the PEIR. Discussion of environmental effects or water -related compliance of flow and quality for a Water Resources project or program without a quantified and presumably computerized complex model for each watershed element is totally inadequate and incomplete at any level. Introduction of "feasible" and economics without definitions and the objectives which 213 include costs and therefore economics strongly distorts any screening or comparisons toward costs, economics, and financial for which no information is provided or believed to be even remotely available for the PEIR, the EWMP, and most if not all of the EWMPs. Such inadequacies and incompleteness renders Sec.6 irrelevant to the CEQA process with regard to the project, any alternatives, and any designation as to an "Environmentally Superior Alternative" compared to an "economically superior alternative". Presumptions and unsupported statement are not with the goals of CEQA to provide a complete, adequate, objective, and quantified review and assessment of a program's or project's effects and appropriate mitigation and alternatives to such. 6-3/5 Based on these criteria, the Lead Agency has identified the following alternatives: Introduction of "Lead Agency" at this point would imply some agencies other than LACoDPW, perhaps LACoFCD (??); while reference to an "alternative screening process" indicates some formal process rather than that documented in the PEIR. Identifications are not supported in comparisons primarily with regard to collaboration and presumed economies of scale and cost-effectiveness. 6-9/9 Ability to Meet Program Objectives The Distributed Structural BMPs Only Program Alternative would meet the objectives of the proposed program to collaborate among agencies to promote more cost-effective and multibeneficial water quality improvement projects. However, because distributed structural BMPs tend to be smaller in nature and typically are distributed widely throughout the watershed, more BMPs may be necessary to meet water quality objectives in the MS4 Permit. The ability to meet 6-10/1 the water quality objectives would be less certain under this alternative. This statement indicates that distributed BMPs are cost-effective for the program although they are smaller (may disagreed based on economies of scale and information provided by LACiDWP). "Less certain" is not defined nor is the statement supported; 100 times more sites may be sufficient and available but no presumption can be supported either way based on the PEIR. 6-1213 6.6 Alternatives Suggested in Scoping LACo EWMP COMMENTS 20 XXXX Cont. Comment Letter 20 Dr. Tom Williams March 16, 2015 Final CCSC ...comment letter... suggested that the PEIR include an assessment of several funding mechanism alternatives, including: Single Parcel Fee Assessment, Parcel Area Fee Assessment, Hybrid Parcel Area Fee Assessment, Zero Discharge Assessment, and Large Parcel Assessment. These suggested alternatives would not lessen any significant environmental impacts of the Program and were therefore not considered in this PEIR. Although CEQA allows for discussion of economic impacts and project costs as measures of feasibility, the funding mechanisms required to implement projects are generally not susceptible to environmental analysis. As the program objectives and criteria for alternatives both include economics and costs and as all BMPs require both capital and operation and maintenance costs to be effective, a full documentation using the above mentions financing package must be incorporated into the project description and alternatives, especially those presented to the LARWQCB in June 2015. Adequately funded projects within the ability to pay of the service population would assure continue environmental compliance and support of a wide array of mitigation measures compared to capital intensity project requiring longer term bonding and expensive project management. Comparisons of large projects with high capital costs to program of lots of small projects with low capital costs but with higher operating costs have been alluded to in discussions of other alternatives but without any documentation. As all publicly funded projects to be submitted to LARWQCB in June 2015 must be funded n have not been demonstrated at this time to be funded, any inclusion of projects in this program can not be assumed to have long-term funding to assure mitigation of impacts. XXXX Cont. 6-12/4 ... comment ... Full Capture and Recharge of Flows Greater than 100 cfs Alternative... rejected... because of the infeasibility of capturing all storm flows... unrealistic, requiring most of the developed land in the County to be accomplished... ...suggesting full capture of all flows less than 100 cfs... was rejected from further consideration for the same reason ... would require enormous areas of ... currently developed... recharge is only feasible in certain areas of the County because of the poor percolation capacity of surficial soils... accumulation of subsurface clay lenses creates recharge barriers in many places of the County, making retention and recharge of large quantities of stormwater infeasible in these locations. PEIR total lacks definitions for "feasibility" and "infeasibility" as to technically, financially, administrative, or politically aspects. As no surface or subsurface hydrologic model is available or referenced, and supporting documentation is not provided nor apparently available for either flow capture alternative dismissal. The PEIR does not provide maps of locations with clay lenses and their extents/depths and therebyTYYYY barrier effects. 1 6-1311 6.7 Environmentally Superior Alternative CEQA requires that an EIR identify the environmentally superior alternative(s) of a project other than the proposed program or the "no project' alternative (CEQA Guidelines Section 15126.6 (e)(2)). As stated at the beginning of this chapter, the purpose of this alternatives analysis is to consider a reasonable range of alternatives that could feasibly attain most of the basic project objectives and avoid or substantially lessen significant program impacts. Since no information is provided as to the actual cost-effectiveness of any projects or groups of project the requirement cannot be achieved, reviewed, or commented on with the currently available information. Based on DWP information distributed small projects could achieve the ZZZZ economy -of -scale that larger one could and therefore any plot -by -plot LID projects. If 10,000 single family dwellings would theoretically detain 460ga/11000sf roof, one design storm would generate 4.6114 gal for direct use (about one day piped water supply); however, cities do not require 460gal of rain barrels but generally only require two rain barrels of 100ga1 capacity. The PEIR does not provide the basis for development of the Environmentally Superior Stormwater Alternative and those with recognized "least worst" environmental effect could not meet two of the three goals of the Program, cost effectiveness with or without real requirements for the 85%ile rainfall event. 6-13/Table 6-2 Ability of Project Alternatives to Meet Project Objectives Project Objectives LACo EWMP COMMENTS 21 Dr. Tom Williams Comment Letter 20 March 16, 2015 Final CCSC 1. To Collaborate Among Agencies (Permittee Jurisdictions) Across the Watershed To Promote more cost-effective and multi -beneficial water quality improvement projects To comply with the MS4 Permit. [=portions of Objective 2 & 3] 2. To develop watershed -wide EWMPs that will, once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff [= Objective 1.] in a cost-effective manner. 3. To reduce the impact of stormwater and nonstormwater on receiving water quality. (=Objective 1.1 Comparisons of alternatives and "abilities" of Project GOALS and objectives without cost- effectiveness and any hydrological model for wet/storm and dry/storm water flows render all a totally inadequate and incomplete. As written, the objectives must be referred to as "Goals"; objectives must be measurable/monitorable with schedules and quantified levels of achievement, e.g., 4Qtr2016 and $100/ppm reduction. 6-1413 The Non -Structural BMPs Only Alternative would avoid all of the significant and unavoidable impacts associated with construction of the structural BMPs.... However, since the ability to achieve compliance with MS4 Permit water quality objectives would be substantially reduced, impacts to water quality would be greater under this alternative, and compliance with the MS4 Permit would be unlikely. Even if it could achieve permit compliance, the Program goals of cost-effectiveness most likely could not be achieved as the disperse detention could not attain any significant economies of scale and would require vastly greater plot -by -plot compliance which is beyond the typical nem additions, or replacement linkages with structured improvements. 6-1414 As a result, since the proposed alternative would provide the best chance of achieving regional water quality objectives, it is considered the environmentally superior alternative. The conclusion is not based on any documentation or projected/estimate successful implementation and does not include any comparisons and development of cost-effectiveness or revenue sources for a much larger implementation phase. The preparers have assumed a development condition without any concept of reality and without documentation as to implementability in order to have an "Environmentally Superior Alternative", which is incomplete and inadequate. Apdx A Appendix A Comment Letter to the LACFCD: Draft PEIR 18/#61(pdf-p.244) The overarching goal of the GRIP Recycled Water Project is to offset the current use of imported water by providing up to 21,000 acre-feet per year (AFY) of recycled water as a reliable supply source for groundwater basin replenishment via the Montebello Forebav within a reasonable timeframe. Although the watershed channel are well known and studies for almost 100 years, no hydrologic model has been developed and incorporated into the EWMP or its component EWMPs. The current efforts therefore cannot provide a factual and quantitative basis for assessing the environmental effects of existing water resources and their future states for water supply availability and locations, flood control, and water chemistry dilutions or reductions. ApdxA/NOP 212 The LACFCD, as a regional agency charged with our local water supply, has a vested interest in increasing opportunities for stormwater capture an groundwater recharge. The LACFCD has flood control infrastructure ... LACFCD will be an implementing agency only on those projects for which it has been identified in an EWMP as a responsible implementing party. Water supply reference without acknowledgement of growth stimulation. ApdxA Appendix A Comment Letter to the LACFCD: Draft PEIR 18/#61(pdf-p.244) The overarching goal of the GRIP Recycled Water Project is to offset the current use of imported water by providing up to 21,000 acre-feet per year (AFY) of recycled water as a reliable supply source for groundwater basin replenishment via the Montebello Forebav within a reasonable timeframe. Although the watershed channel are well known and studies for almost 100 years, no hydrologic model has been developed and incorporated into the EWMP or its component EWMPs. The current efforts therefore cannot provide a factual and quantitative basis for assessing the LACo EWMP COMMENTS 22 ZZZZ Cont. Dr. Tom Williams Comment Letter 20 March 16, 2015 Final CCSC environmental effects of existing water resources and their future states for water supply i availability and locations, flood control, and water chemistry dilutions or reductions. As indicated elsewhere, this NOP and letter statements clearly indicate the anticipated development of water supply resources which goes beyond the water quality and flood protection benefits and relates the EWMP to growth inducements for future populations needs for greater water resources without adding new imported water supply facilities. ApdxF 712 The Los Angeles River is approximately 55 miles long, and five of six reaches lie within the Upper Los Angeles River EWMP Area. The natural hydrology of the Los Angeles River watershed has been significantly altered by urbanization, channelization, and the construction of dams and flood control reservoirs. The river and many of its tributaries are lined with concrete for most or all of their length. Soft - bottom segments of the river occur where groundwater upwelling prevents armoring of the river bottom. Although the watershed channel are well known and studies for almost 100 years, no hydrologic model has been developed and incorporated into the EWMP or its component EWMPs. The current efforts therefore cannot provide a factual and quantitative basis for assessing the environmental effects of existing water resources and their future states for water supply availability and locations, flood control, and water chemistry dilutions or reductions. LACo EWMP COMMENTS 23 20- AAAAA Cont Anderson To: Subject: Laura Rocha RE: EWMP-PEIR Comments 2/4 From: Tom Williams [mailto:ctwilliams20l2a-vahoo.coml Sent: Friday, March 13, 2015 1:00 PM To: Gregg Begell Cc: Liz Crosson Subject: Re: Fwd: EWMP-PEIR Comments 2/4 FYI #3/4 03/13/15 Comment Letter 20 THIRD DRAFT COMMENTS SUBMITTED MARCH 13, 2015. SUBSEQUENT DRAFTS (FINAL) WAS BASED ON THIS THIRD DRAFT SUBMITTAL. THE FINAL SUBMITTAL WAS BRACKETED FOR RESPONSE. HOWEVER, COMMENTS 20-BBBBB and 20-CCCCC ARE UNIQUE TO THIS SUBMITTAL AND ARE BRACKETED FOR COMMENT BELOW. As of this morning sadly, nine/9 days have passed without contact from the City o - BrdPubWrks/DptPubWrks regarding their EWMP - BMPs - infamous 400+...as such I have incorporated pertinent comments into the PEIR comments.... Recirculate .... It is all draft today - but monday will be final.... I will also be circulating my comments to appropriate stakeholders. Tom Wms. On Wednesday, March 11, 2015 10:11 PM, Clyde Williams <ctwilliams2012(c)_yahoo.com> wrote: FYI #2/4 Sent from my iPhone Begin forwarded message: From: Gregg Begell <gbegell(cDdpw.lacounty.gov> Date: March 11, 2015 2:20:22 PM PDT To: Tom Williams <ctwilliams2012(a�yahoo.com> Subject: RE: EWMP-PEIR Comments 2/4 Thanks Tom This helps get us started on reviewing your comments. Gregg BeGell P E Project Manager Project Management Division II From: Tom Williams [mailto:ctwilliams20l2(a)yahoo.coml Sent: Wednesday, March 11, 2015 2:00 PM To: Gregg Begell Subject: EWMP-PEIR Comments 2/4 See attached Comment Letter 20 03/11/15 #2 of 4 Comments Will be integrated for final submission on 03/16/15 12-3pm Thanks Tom CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Dr. Tom Williams March 13, 2015 Comment Letter 20 March 13, 2015 Submittal #3 CCSC TO: Gregg BeGell, P.E. County of Los Angeles Department of Public Works, Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 gbegell@dpw.lacounty.gov FROM: Dr. Tom Williams, Sr. Techn. Advisor Citizens Coalition for A Safe Community Sierra Club, Angeles Chapter, Water Committee Subject: Enhanced Watershed Management Plan RE: Comments on Programmatic Draft EIR Specific Comments #3/4, 03/13 (16)/15. NEW Special Issue: LA City - EWMP 400+ projects (BMPs) and PEIR Inquiries, internet searches, and requests for public documents have been submitted to the DepartmendBoard of Public Works, City of Los Angeles for documents, reports, and other materials pertaining to the reported 400+ storm water related projects, BMPs, etc., that presumably would be part of the 12 EWMPs for the permittees to submit to the LAWQCB in June 2015 and which is referenced in the LACo EWMP and this PEIR. As of close -of -business 13 March, 2015, nine days after submission of the request to LA Ci-BPW, no contact has been made by the LACI-BPW or LACiDPW. This indicates that such EWMPs' projects may be erroneously reported herein or that they are not part of the PEIR and not available to the public. This is a clear example of importance of havin all information prior to preparation of the LACo EWMP and this PEIR. as the total number of stormwater related projects probably exceeds the total numbers of other permittees we must assume that the EWMP-PEIR is incomplete and inadequate for public review and meaningful comments. Please withdraw the current PEIR and recirculate at a later date when all relevant information is available for public review and comment. As a 40 year professional water resources specialist (now retired), I appreciate the physical, technical, and administrative complexity of the LA surface and ground water basins and the supply issues for 9+ million people. However, having participated in EPA Basin Studies in southern California, I also recognize that this is the first major attempt to update such earlier studies (in 40+ years) and only brought about because of regulatory issues and the drought which may be the foreword for more long term climate and hydrologic changes. As such I consider the Enhanced Watershed Management Plan (EWMP) and Draft Program Environmental Impact Report (D-PEIR or PEIR) as an important preliminary compilation requiring major updating and implementation of a comprehensive, computerized hydrologic model for the technical, administrative, and public stakeholders of the County Of Los Angeles (LACo) and as a "Work in Progress". Central to this issue, CCSC and some members of the Sierra Club, Angeles Chapter, Water Committee request that as part of the overall revision of the D-PEIR and the LACo EWMP that: • the LACo-EWMP/PEIR become the base online document for all storm, surface, and groundwater resources within LACo and that all related EWMPs and other water resources efforts of all permittees and preparers of EWMPs/Project EIR fully coordinate with and support integrate of teired efforts within the context and documentation of the LACo EWMP; • the LACo become the computerized online Watershed Model (WSM or LAWSM, or "Water -One" Model, WOM) for integrating all water resources within LACo for any administrative and regulator purposes; • the Los Angeles Water Quality Control Board (LAWQCB) only consider as complete and adequat submissions, permits, and monitoring that has been coordinated and integrated through the WSM • all tiered projects (EWMPs), best -management -practices (BMPs), and any other water -related projects (e.g., flows of greater than one acre-foot per year, >lacft/yr) LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Dr. Tom Williams More to Come SAME as 03/09/15 Comment Letter 20 March 13, 2015 Submittal #3 CCSC The following provides a brief review of the CEQA/D-PEIR documents of almost 70MB/1000 pages. We thank the LACo Department of Public Works and Flood Control District for this opportunity to review and comment on the PEIR and greatly appreciate the deadline extension for doing such. I will be submitting detailed comments during 03/13-03/16, and these final overall comments on 03/16/15. The overall CEQA review is that the documents are inadequate, incomplete, mostly inaccessibility and confusing for the general educated public due to the volume, technical character, overly -broad statements, lack of documentation and support of statements, and lack of consistency of terms and usage, The proposed Program does not provide a plan for tiered project CEQA considerations by the other permittees nor the County itself. No plan for the Program or the projects has been established for the Enhanced Watershed Management Plan to achieve and comply with the LA Regional Water Quality Control Board's permit requirements. A program may be more generalized but still must provide a plan of actions for both the lead and responsible agencies. The Program does not provide even the requirements, process, and procedures for subsequent CEQA compliance by other permittees and some projection as to whether EIRs, MNDs, ND, or CE will be used to tier down from this P-DEIR/P-FEIR. Conditions for Program Compliance by tiered projects have not been listed or even referenced other than some ill-defined listing of BMPs. No current listing of all planned and funded Projects has been provided and incorporated into a scheduled and quantified plan for submission in June. Although research has been underway for five -plus years, the EWMP and this EIR does not use nor even reference use of computerized modeling of the appropriate basins (Ballona Creek, Upper LA River, Middle LA River and Arroyo Seco, Lower LA River and San Gabriel River, and LA River Mouth/Estuary- Dominguez Channel) although the federal agencies (BLM, USGS, ACoE, etc.) and perhaps local agencies (some permittees and the Water Board) have some local or watershed models . Without a model and its components, the impacts and their significance of detention, retention, recharge, and flood protection cannot be assessed nor mitigated adequately or completely. Three goals are provided but no objectives (sub -tiered from goals) are provided with/without defined schedules and other quantitative parameters for program monitoring. Confusion is introduced in later text when both flood control and water supply "augmentation" are also introduced as "goals" and as "objectives". Specific goals are only to meet the MS4 Permit requirements and related water quality conditions and to meet them in a "Cost -Effectiveness" manner. However, costs, financial support, revenue, capital bonding, or economic effectiveness or efficiency are not provided, and thereby achievement of the cost effectiveness cannot be judged nor compared and must presumed by submission of any proposed project. Growth inducement is mentioned primarily with regard to direct housing construction and employment and incomes while dismissing potential effectts of recharged (diverted storm flows) water supplies. Additional benefits primarily for flood protection are mentioned in some statements while it is not sup by any text or analyses under water resources. No assessment of beneficial and adverse effects are provided for raising base flow levels from program-augmented/diverted-stormwater groundwater res( and their effects upon subsequent pollutant concentrations and flood flows. I am retired from 30 years in water and environmental resources with Parson Corp., Pasadena and URS San Francisco and over 10 years with Dubai (UAE) government and local water and environmental companies. I have prepared sections and entire documents for more than 300 EIRs, EISs, and EAs worldwide for local agencies, cities, counties, states, federal, and international agencies and organizations LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- CCCCC. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC These and have reviewed more than 100 additional assessments. Duringwork for URS, I was involved in the comments are development and environmental considerations for the 1970s EPA's Santa Ana and Santa Marguerita/San duplicative Luis Rey basins plans. My reviews have included the LACity's Recycled Water Management Plan and of Stormwater Capture Management Plan, and I am currently vice chair of the LA City's Floodplain comments Management Plan. in the Final Submittal. See Dr. Tom Williams responses 20-A through 20- CCCCC. LACo EWMP COMMENTS Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC NEW - NOT INCLUDING THOSE OF 03/09-11/15 EWMP - SPECIFIC COMMENTS Comments, recommendations, and additions are presented in Bolded Italics PEIR text specific to the comments are presented in plain text as was in the PEIR. Some specifically relevant PEIR text may be Bold Underlined. The Executive Summary (ES) has not been thoroughly reviewed as the ES supposedly represents limited version of the P-DEIR text content and cannot be assessed for adequacy and completeness as a stand-alone item. ES -212 The EWMPs will identify potential and priority structural and non-structural Best Management Practices (BMPs) within the region's stormwater collection system to improve runoff water quality. As indicated, this EWMP has no direct factual contributions from the individual EWMPs of other permittees within LACo. No formal organization and definitions of the EWMP, EWMPs, and all the "BMPs" has been provided and consistently applied throughout the document. As the statement refers to a future condition, not in evidence, such statements here and throughout the document must be verified and suported by commitments on the part of the other permittees. Potential and priority BMPs are referred to but are not adequately related to the EWMPs and the EWMP/PEIR and as indicated herein they ARE BEING developed, they are not developed. The EWMP and PEIR are not definitive at even a programmatic or conceptual deign level. ES -215 A few of the BMPs are currently well defined but most are yet to be fully developed under the EWMPs .... priority BMPs... detailed in each of the EWMPs; these are being developed in parallel with th PEIR.... describes the details that are available for each of the EWMPs currently... by the EWMP working groups. 1-3/3 A set of priority BMPs will be detailed in each of the EWMPs; these are being developed in parallel with the PEIR. The PEIR describes the details that are available for each of the EWMPs currently under preparation by the EWMP working groups. As indicated, this EWMP has no direct factual contributions from the individual EWMPs of other permittees within LACo. No definition of "Fully" or "Well" is provided for the PEIR and as they are being developed at the same time as this PEIR their entire discussion is so general as to render assessment impossible and open to any combination of current or future "projects" and BMPs as desired by the agencies. No reliable discretionary decision can be made and funded based on the PEIf 1-1/3 The MS4 Permit gives Permittees the option of implementing an innovative approach to permit compliance through development of an Enhanced Watershed Management Program (EWMP).... Will identify potential and priority structural and non-structural Best Management Practices (BMPs) within the region's stormwater collection system to improve runoff water quality. The LACFCD, along with participating Permittees, has opted to exercise this option and has submitted to the LARWQCB 12 separate Notices of Intent (NOls) for the development of EWMPs within 12 distinct watershed groups... Implementation of the EMWPs would be the responsibility of each Permittee and would occur following approval of the EWMPs by the LARWQCB. BMPs, groups of BMPs, and Projects are not defined at any engineering levels so as to determine cost-effectiveness, capabilities to achieve any project/program goal involving water quality or flows and their effects and impacts. 1-3/3 The EWMPs will identify management strategies including hundreds of structural Best Management Practices (BMPs) that may be designed and implemented by the Permittees to meet permit compliance objectives [Only one of the Program objectives]. LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC As indicated, this EWMP has no direct factual contributions from the individual EWMPs of other permittees within LACo. This clearly indicates that this document and tiered documents are NOT based on any quantitative model (RAA, discussed below) for water quality and is not completed prior to its CEQA assessment and that this assessment cannot adequately assure that even the water quality goals, objectives, and regulatory requirements can be realized. Water quality and flow models and proposed BMP depend on diversion or reduction of flows durinc both dry- and wet -weather flows, and therefore the RAA must be based on a hydrologic/hydraulic model which has not bee referenced or mentioned. This EWMP and PEIR must provide the programmatic management strategy guidelines for those of the tiered -down EWMPs-strategies and related CEQA documents. Use of the conditional: "may be" voids following verbs and leaves the statement as irrelevant to the Program and Project EIRs. 1-4/3 The EWMPs are to include a discussion of the environmental documents, assessments, and permitting required for the implementation of the priority projects. The PEIR can provide a basis for this discussion. The use of the PEIR in the development and implementation of the EWMPs is further discussed in this chapter in the Purpose of the Program Environmental Impact Report. As indicated, this EWMP has no direct factual contributions from the individual EWMPs of other permittees within LACo. Priority BMPs were discussed but have not been distinguished from "Priority Projects". The PEIR does not discuss the process of tiering to projects or to specific BMPs and whether Mitigated Negative Declarations will be tiered down from this PEIR or whether the project must require tiered/focused EIRs for full and adequate CEQA compliance. 1-7/1 • Other Receiving Water Considerations (second category): - The second highest priority shall be considered controlling pollutants for which data indicate impairment of exceedances of receiving water limitations and the findings from the source assessment implicates discharges from the MS4. As no hydrologic model for flows and concentrations has been provided even for the TMDL constituents, references to secondary pollutants appears totally inappropriate and purposeful attempts to elevate the credibility of compliance with the TMDL, which has not been achieved. 1-7/2 The EWMP prioritization process includes identifying the priority pollutants and... schedule for implementing BMPs to meet the following criteria: • For pollutants... same class as TMDLs.... consider these pollutants within... same time frame as ... TMDLs. • For ... 303(d) list ... EWMPs develop a schedule to address these pollutants as soon as possible with milestones. Priority pollutants have already been prioritized and identified, and the prioritization process has not been described although referred to, and no schedule for prioritization, definition of priority projects or priority BMPs has been provided. Prioritization process and schedule are rendered totally inadequate when modified by whenever "possible". MMRPIan must include a full and scheduled prioritization process for ALL EWMPs. 1-8/2 The RAA is being performed as part of the preparation of the EWMPs, and in parallel with ... this PEIR. The RAA... primary goal of the EWMP ... meet the water quality goals. The modeling being performed... will determine... number and distribution of the BMP types and specific projects identified in the EWMP Work Plans will meet the water quality goals. This PEIR will assess the types of BMPs that mal be implemented to meet these WATER QUALITY goals. As indicated, this EWMP and any related RAA performance has no direct factual contributions fron the individual EWMPs of other permittees within LACo. Management strategies (MSs) presumably are different from the BMPs and the EWMPs which they maybe be parts of, but MSs are not defined nor associated with BMPs and EWMPs. LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC The RAA and a supporting/integrated Hydrologic Model must be provided in a final form to be incorporated, not be performed in parallel, with full integration/incorporation. The MMRP/an must include a final RAA. 1-9/1 The LACFCD will consider the information presented in this PEIR, along with other factors, in the development and implementation of the EWMPs. The EWMPs are to include a discussion of the environmental documents, assessments and permitting required for the implementation of therip ority projects. The PEIR can provide a basis for this discussion. 1-10/2 The EWMPs are to include a discussion of the environmental documents, assessments, and permitting required for the implementation of the priority projects. Repeated Consider and other factors are not defined and as such allow the entire PEIR process to be set- aside. The PEIR does not fully define the roles and participations of the LACFCD in the development of tiered EWMPs and their CEQA documents. Again "priority projects" are mentioned and not defined with regard to "priority and potential BMPs. " CEQA texts must recognize differences between "can/could provide" and "will/would provide" and require clarity as to what will occur in the teiring of projects and CEQA documents. 1-11/1 Maps identifying potential and priority BMP locations are provided in Chapter 2 ... with the over EWMP watershed characteristics and BMP implementation strategy. No definition or specificity of potential and the subgroup priority BMPs and locations nor details are provided within the tables and generalized maps. No watershed characteristics are provid regarding runoff coefficients, design rainfall amounts, times of concentrations, are estimated flow levels are provided for any watershed, not even a ranking of highest to lowest flows or highest -lowest dry- and wet weather water qualities. 1-11/1 The PEIR focuses its assessment on construction and operation of these potential and priority BMPs to be installed throughout the watersheds—but primarily within urbanized areas where the pollutant loading is greatest and where these BMPs can be most cost-effective in meeting water quality goals. No focused information is given regarding the BMP operations and their effectiveness in removing pollutants and meeting water quality goals (not objectives). No information is provided regarding the degree of urbanization for each watershed, nor the assumed "loadings" being greater, median, or least. BMPs are presumed as cost effective without documentation and analyses as to pollutant - present/removed per 100 acft or any other quantified parameter and as to achievement of current reductions down to desired goals. 2-5/1 Additional information and figures on the location and distribution of potential and priority BMPs based on available data at the time of publication of this PEIR, are presented in Section 2.5, EWMP Watershed Characteristics and BMP Implementation Strategies. 2-15/2 Source Control BMPs. Source control structural BMPs are commercial products designed to trea runoff in highly urbanized environments. Mechanical separation, or more complex physicochemical processes, provides separation of gross solids and other pollutants... designed to sequester hydrocarbons and other pollutants. Residual pollutants and their disposition is not mentioned nor provided anywhere in the PEIR. No discussion is included regarding the soil sequestering of hydrocarbons, metals, and other pollutants in the ground materials (especially in/on clays). No estimate is provided as to anticipated sequestering per year and probable long-term removal of soil materrials before the) achieve "hazardous" levels. 2-16/2 Specific examples of distributed BMPs that are in various stages of planning and implementation and part of a possible EWMP are presented in Table 2-3. The locations of these examples of planned LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC distributed BMPs are shown in Figure 2-2. Table 2-3 presents the locations, project description, and key elements of the distributed BMPs to further illustrate these types of structural BMPs that may be part of an EWMP. Additional information and figures on the location and distribution of potential and priority BMPs, where data ar6a available, are presented in Section 2.5, EWMP Watershed Characteristics and BMP Implementation Strategies. Centralied and Regional BMP discussions repetitive from 2-16/2 except as highlighted. 2-28/2 ...centralized BMPs... presented in Table 2-4. The locations of these examples of planned and implemented centralized BMP ... in Figure 2-3. Table 2-4 ... the centralized BMPs ... structural BMPs that are part of the EWMP.... of potential and priority BMPs, where data ar" available,... BMP Implementation Strategies. 2-35/1 ...regional BMPs ... of planning and implementation and that are part of the EWMP are presented in Table 2-5. The locations of these examples of regional BMPs are shown in Figure 2-5. Table 2-5 ... of the regional BMPs to further illustrate these types of structural BMPs that are concepts being developed through the EWMP process. ...of potential and priority BMPs, where data ar" available... BMP Implementation Strategies. The complex repetitive wording and slight but several differences in these texts cause considerable confusion for the public review and participation in this CEQA process. Without clear table -ed presentation meaning and clarity are lost, rending these important issues inadequately treated in this PEIR. 2-40/1 Summarized below are the general characteristics of the watersheds within the EWMP Groups and the overall strategies for BMP implementation ... twelve EWMPs are consolidated to six watershed areas... summary provides additional detail on the distribution and location of potential and priority BMPs where data is available,... for each EWMP and show the location and distribution of planned and priority regional/centralized BMPs for which data are available at the time of publication of this PEIR. The priority BMPs ... subset of the potential BMPs that have undergone a site review and project evaluation the has identified these BMPs as a priority. These priority projects are shown based upon available data at the time of publication of this PEIR. EWMP groups, EWMPs, and watershed areas are inadequately associated and defined; presumabll 12 EWMPs may be associated into 6 EWMP Groups based on watershed associations. Similarly designations as to: Potential, Planned, and Priority BMPs - Priority BMPs are part of Potential BMPs Regional and centralized BMPs - excluding distributed Priority projects or BMPs require clear definitions and ordering in order to have adequate clarity for public review. 2-40/1 Appendix G provides the location and general description of the priority BMPs ... Distributed BMPs are planned to be implemented throughout the urbanized areas of each EWMP. 2-43/3 ...Figures 2-5 through 2-16, each of the EWMPs ... wide distribution of BMPs to achieve permit compliance. Appendix G provides the locations and general descriptions of the priority BMPs (where data is available),... Priority Projects are projects that have been identified through the EWMP process as targeted for implementation within the first years following the EWMPs approval by the LARWQCB. Identification of Priority Projects is underway and has not been completed by all EWMPs at this time. [For any??] ... PEIR is being prepared in parallel to the EWMPs. Priority Proiec [proper noun] will be defined in all the EWMPs to be submitted for public comment in June 2015. Priority Projects that have been identified at this time through the EWMP process are shown on the following figures. Priority Projects may be regional, centralized or distributed type BMPs. For potential proiects... location of potential regional and centralized BMPs are shown. Distributed BMP will be distributed throughout the urbanized areas and are not shown on the following figures ... 2-44/1... No "general description" is provided for the program, projects, and BMPs, as summarized below, only listings and figures found in the Vol. 1. Apdx. G EWMP Proposed BMP and Priority Proje LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC Data and Figures A -L, pages unnumbered items renders the entire appendix confusing and un T reviewable for the general public and the only "General Description" is APN numbers. 2-57/1 2.6 EWMP BMP Implementation Schedule The EWMPs that are being prepared in parallel t the PEIR will provide a timeline for the implementation of the BMPs [as define in MS4/TMDLs]... priority BMPs ... that have undergone a site review and project evaluation and ... based on available data at the time of publication of this PEIR ... Implementation of priority BMPs will begin following approval of the EWMPs by the LARWQCB... depend on the approval of the EWMPs, 1) further environmental assessment, 2) permitting, and 3) availability of funding sources. The EWMPs will be submitted to the LARWQCB in June 2015. The entire process of LACo-EWMP, EWMPs, BMPs, etc. and implementation of "Priority BMPs" have not been fully provided nor adequately documented. As indicated above, a fully scheduled/timed EWMP/EWMPs implementation schedule for all BMP and for further - annual - updating must be included in the Final PEIR perhaps as part of the MMRPlan for PEIR and within each EWMPs' CEQA documents. Statements as to the submittal dates in less than three months clearly indicates that undue pressure is being attempted in order to force the CEQA and project development processes through without due consideration as to the completeness and adequacy of project, program, and CEQA documents and processes. 2-57/4 Each EWMP will define priority projects, and installation of these projects will move forward depending on the availability of funding and outcome of further project -specific CEQA review. Funding options for implementing agencies would include obtaining grant funds, low-interest loans, to based general funds, or special assessments. Each jurisdiction will be responsible for securing the necessary funds over time to achieve permit compliance. References to but absence of information regarding funding, funds, and other related economic/financial elements and their pivotal importance to any "Project" renders continued discussion of projects inadequate and incomplete and subject to major changes of any PEIR referenced "project between now and July 1, 2015 and thereafter. Introduction of ' jurisdiction" renders the discussion meaningless, incomplete and inadequate. LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC NEW #3/4 1-9/3 Program-LACo EWMP 12 Local/Regional EWMPs Projects/BMPs LACo EWMP COMMENTS Dr. Tom Williams March 13, 2015 Submittal #3 BMPs 2-7/ Table 2-2 Typical Structural Best Management Practices Main BMP Category BMP Assessed Sub -Types Of BMPs 2-17/Table 2-3 Examples of Planned or Installed Distributed BMP Projects 2-29/Table 2-4 Examples of Planned Centralized BMP Projects 2-37/Table 2-5 Examples of Planned Regional Projects Comment Letter 20 CCSC Impacts not by EWMP but by BMP levels and cumulative per sector 3.2-30/Table by the LACFCD will be multi - 3.2-10 projects Summary of Air Quality Impacts flood risk Requiring Mitigation Measures BMP + Cum 3.3-32/Table 3.3-1 ...Biological Resources... 3.4-29/Table 3.4-2 ...Cultural Resources... 3.5-29/Table 3.5-3 ...Geologic Resources... 3.7-25/Table 3.7-1 ...Hazards... 3.8-43/Table 3.8-3 ...Hydrological Resources... 3.9-40/Table 3.9-16 ...Land Use and Agriculture... 3.14-24/Table 3.14-3 ...Utilities and Service Systems... 2-1/ The structural watershed control measures that will be implemented by the LACFCD will be multi - benefit stormwater projects that emphasize flood risk mitigation... Public Health and BMP Maintenance (ongoing annual costs) 2-9/1 Wet detention ponds may require engineering... to ensure that the permanent pool does not become stagnant and a magnet for mosquito production (must be emptied within 72 hours). Rain Barrels 2-13/2 Planter Boxes. Planter boxes are bioretention systems... where space constraints limit the implementation of other LID elements... designed to both filter and store runoff ... used in combination with rain barrels and cisterns that store the runoff and then direct it into these boxes to filter the runoff. 2-14/2 Rainfall Harvest. Rainfall harvesting improves water quality by intercepting rooftop runoff... rain barrels are storage tanks used to intercept and store rooftop runoff for nonpotable use such as landsce irrigation or gradual infiltration. p.2-18 Upper LA River Brandon Street and Green Street Improvements Project The project will reconstruct... roadway... design includes... Much of the runoff from the streets and private properties that would have otherwise drained to the Rio Hondo will be directed to the infiltration area. How much 2-19 Upper San Gabriel River Avocado Heights Multiuse Trail Project The project will ... thereby reducing the amount of impermeable surfaces as well as runoff. Approximately ... Combined together, up to 115 acre-feet of groundwater will be recharged annually. 2-26\2 Typical constructed wetland projects require extensive grading of site soils, though excavated soils are often balanced on-site to provide material for levees, berms, ecotones, and other flood control/habitat features. LACo EWMP COMMENTS 10 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- CCCCC. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC 2-27/2 Multi -benefit flood management projects. This category... designed to result in direct or indirect benefits to flood management. ...Tujunga Wash Greenway project that incorporates ... detention elements can improve flood management by reducing stormwater flow rates and/or volumes. 2-27/3 Construction Impacts. Multi -benefit flood management projects are typically expansive projects that range from a few to tens of acres in size... Because of their scale, multi -benefit flood 2-28/1 management projects... 2-30 TABLE 2-4 EXAMPLES OF PLANNED CENTRALIZED BMP PROJECTS This project will also have educational signage on a riparian zone and the stormwater cleanup objectives of this project. 2-30/Table 2-4 Item 2 Malibu Creek Lindero Parkway Improvements The project ... streetscape improvement project that ... this parkway was originally a flood control maintenance road ... new project, ... Stormwater runoff would then be treated in the bio-swale followed by discharge into Westlake Lake ... also have educational signage on a riparian zone and the stormwater cleanup objectives of this project. FP 2-31/Table 2-4 Item 4 Palos Verdes Peninsula San Ramon Canyon Stormwater Flood Reduction Project The San Ramon Canyon... near Palos Verdes Drive East.... landslide induced rock and soil deposits in the canyon bottom are transported during heavy rainfall events... creates flooding of the roadway, overwhelming existing drainage facilities, endangering nearby roadway integrity and threatening downstream residents ... (SRCSFRP) involves significant drainage restoration work to stabilize... FP 2-32/Table 2-4, Item 2 Phase II of the Penmar project... Replacing this volume of potable water with treated storm water... provides 34.7 million gallons per year increase to annual runoff diversion capacity... By installing the reuse option, the overall project capacity will increase, thereby also increasing the volume of urban runoff that can be retained by the project for use as an alternative source of water to potable water for landscape irrigation. 2-34/1 2.4.5 Regional Structural BMPs Regional structural BMPs are those that can capture the a 21 -acre drainage area ... into two underground infiltration 2-34/2 Anticipated Construction Activities: The construction activities... are generally similar to those of their centralized counterparts, with the exception of regional retention BMPs,... adequate storage capacity to hold runoff from the desiqn storm.... Larger, multi -benefit regional BMPs are similar to centralized multi -benefit reqional flood management proiects... 2-42/4 The Los Angeles River... natural hydrology of the Los Angeles River watershed has been altered by channelization and the construction of dams and flood control reservoirs... Because of the greater extent and number of pollutant priorities, the BMP strategy in the Upper Los Angeles River watershed includes well over a hundred planned regional and centralized retention and infiltration BMPs (Estimated LACo EWMP COMMENTS 11 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- CCCCC. Dr. Tom Williams Comment Letter 20 March 13, 2015 Submittal #3 CCSC These unfunded projects: 400] that take advantage of the favorable groundwater recharge comments characteristics ... BMP strategyalso includes distributed smaller BMPs located throughout the urbanized are g duplicative areas of the watershed as retrofits in existing developments and streets. LFDs to comply with dry -weather of bacteria TMDLs may also be included. comments in the Final Submittal. See responses 20-A through 20- CCCCC. LACo EWMP COMMENTS 12 3.1-12/3 BMP maintenance is also important... Wet ponds and constructed wetlands can also become mosquito -breeding grounds... can usually be reduced or eliminated through proper design and/or organic controls.(=maintenance]..all BMPs need to have trash and debris removed periodically to prevent odor and preserve aesthetic values. With proper maintenance... impacts would be less than significant. Nothing about public health Public Health not well discussed at Program levels PH not discussion Odor Disease vector Mosquito 3.1-15/TABLE 3.1-1 SUMMARY OF ... IMPACTS REQUIRING MITIGATION MEASURES Distributed BMP LID — Green Infrastructure — Capture and Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes 3.5-19/2 City of Los Angeles Low Impact Development Manual In November 2011, the City of Los Angeles adopted the Stormwater Low Impact Development (LID) Ordinance #181899) with the statedup rpose of: Requiring the use of LID standards and practices in future developments and redevelopments to encourage the beneficial use of rainwater and urban runoff Reducing stormwater/urban runoff while improving water quality Promoting rainwater harvesting These Reducing offsite runoff and providing inc comments undwater recharge • Reducing erosion and hvdrologic impacl are *earn Enhancing the recreational and aesthetic vof plicative Ir communities comments in the Final 3.5-19/3 The City institutionalized the use of LID t submittal. ..adoption of the Stormwater LID Ordinance, the City prepared the Development Best Managem see yes Handbook, Low Impact Development Manual,... required BMPs (City of Los Angeles, 201 responses 20-A through 20- CCCCC. 3.7-17/2 The LID Standards... provide protocols for oesigning regional and centralized BMPs that minimiz, the potential for contaminant loading. For example, the LID Manual requires a certain distance to groundwater to ensure that adequate soil filtration occurs prior to the percolating water reaching a drinking water aquifer. 3.8-1/3 Annual precipitation can vary significantly between drought and flood conditions; periodic and occasionally severe droughts and floods within the area are well-documented (LARWQCB, 1994), and the potential for extreme precipitation (maximum intensity of precipitation for periods of 12 hours or longer which might be expected at intervals of ten to 100 years) is greater in portions of the San Gabriel Mountains than practically anywhere else in the continental United States (WERC, 2014). Average annual rainfall within the Los Angeles Basin is approximately 14.5 inches, though local averages can vary considerably depending on location within the basin (WERC, 2012). No adequate stormwater flow forecast 85%ile Climate changes. LACo EWMP COMMENTS 13 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- CCCCC. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC 3.1-12/3 BMP maintenance is also important... Wet ponds and constructed wetlands can also become mosquito -breeding grounds... can usually be reduced or eliminated through proper design and/or organic controls.(=maintenance]..all BMPs need to have trash and debris removed periodically to prevent odor and preserve aesthetic values. With proper maintenance... impacts would be less than significant. Nothing about public health Public Health not well discussed at Program levels PH not discussion Odor Disease vector Mosquito 3.1-15/TABLE 3.1-1 SUMMARY OF ... IMPACTS REQUIRING MITIGATION MEASURES Distributed BMP LID — Green Infrastructure — Capture and Use — Cisterns, Rain Barrels, Green roofs, Planter Boxes 3.5-19/2 City of Los Angeles Low Impact Development Manual In November 2011, the City of Los Angeles adopted the Stormwater Low Impact Development (LID) Ordinance #181899) with the statedup rpose of: Requiring the use of LID standards and practices in future developments and redevelopments to encourage the beneficial use of rainwater and urban runoff Reducing stormwater/urban runoff while improving water quality Promoting rainwater harvesting These Reducing offsite runoff and providing inc comments undwater recharge • Reducing erosion and hvdrologic impacl are *earn Enhancing the recreational and aesthetic vof plicative Ir communities comments in the Final 3.5-19/3 The City institutionalized the use of LID t submittal. ..adoption of the Stormwater LID Ordinance, the City prepared the Development Best Managem see yes Handbook, Low Impact Development Manual,... required BMPs (City of Los Angeles, 201 responses 20-A through 20- CCCCC. 3.7-17/2 The LID Standards... provide protocols for oesigning regional and centralized BMPs that minimiz, the potential for contaminant loading. For example, the LID Manual requires a certain distance to groundwater to ensure that adequate soil filtration occurs prior to the percolating water reaching a drinking water aquifer. 3.8-1/3 Annual precipitation can vary significantly between drought and flood conditions; periodic and occasionally severe droughts and floods within the area are well-documented (LARWQCB, 1994), and the potential for extreme precipitation (maximum intensity of precipitation for periods of 12 hours or longer which might be expected at intervals of ten to 100 years) is greater in portions of the San Gabriel Mountains than practically anywhere else in the continental United States (WERC, 2014). Average annual rainfall within the Los Angeles Basin is approximately 14.5 inches, though local averages can vary considerably depending on location within the basin (WERC, 2012). No adequate stormwater flow forecast 85%ile Climate changes. LACo EWMP COMMENTS 13 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- CCCCC. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC 3.8-8/2 5. Dominguez Channel Watersheds (Figure 3.8-6) (Dominguez Channel EWMP and Beach Cities EWMP— ...Dominguez Channel EWMP and a portion of the Beach Cities EWMP... differentiated by a larger area of industrial land use. Because of the high density... large regional and centralized infiltration - type BMPs will be limited. The structural BMP strategy will be more LFDs, both large (centralized) and small (distributed), located at MS4 outfalls ... The other BMP strategy is the use of smaller distributed BMPs ... low -impact development (LID) type of BMPs, such as green streets and biofiltration BMPs. 3.8-4/3 EWMP Groups The proposed program has been divided into 12 EWMP Areas that have been organized by watershed groups that share comparable conditions. The 12 EWMPs are consolidated into six watershed areas that are grouped by similar watershed characteristics ... and also provide hydrologic features and the locations and distribution of planned and priority regional/centralized BMPs. No comparable, similar, or differing watershed conditions or characteristics have been identified other than physical channel connections. 3.8-4/3 The priority BMPs are a subset of the planned BMPs and have been selected as priority rp olects based on a screening assessment of the planned projects. Priority projects will be implemented before additional planned projects. Define and compare priority, planned, and potential BMPs and projects. Referenced "screening assessment" has not been described. 3.8-4/3 Distributed BMPs are planned to be implemented throughout the urbanized areas of the EWMPs. No plan provided for distributed BMPs within the EWMP or available EWMPs. No designation as to whether distributed BMPs/Projects will be priority, potential, or just planned projects; as provide after the priority projects. 3.8-20/1 ...these LFDs could potentially increase the amount of water available for recycling, reuse, and groundwater recharge. 3.8-21/1 ...45 percent are supplied by local groundwater basins that are recharged naturally... through constructed recharge facilities (MWD, 2010). 3.8-21/1 ...stormwater recharge facilities currently augment local groundwater supplies in the region by an estimated 477,000 acre-feet per year (MWD, 2014). 3.8-21/1 connectivity between surface water and groundwater. Infiltration BMPs proposed within the EWMPs are expected to increase the rates and amounts of groundwater recharge... 3.8-31/3 County of Los Angeles Low Impact Development Manual The County... prepared the 2014 Low Impact Development Standards Manual (LID Standards Manual, County of Los Angeles, 2014b) to comply with the requirements of the 2012 MS4 Permit... provides guidance for the implementation of stormwater quality control measures in new development and redevelopment projects in unincorporated areas of the County with the intention of improving water qual and mitigating potential water quality impacts from stormwater and non-stormwater discharges. 3.8-31/4 The LID Standards Manual addresses... objectives and goals: LACo EWMP COMMENTS 14 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- CCCCC. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC • Lessen the adverse impacts of stormwater runoff from development and urban runoff on natural drainage systems, receiving waters, and other water bodies. • Minimize pollutant loadings from impervious surfaces by requiring development projects to incorporate properly -designed, technically -appropriate BMPs and other LID strategies. • Minimize erosion and other hydrologic impacts on natural drainage systems by requiring development projects to incorporate properly -designed, technically appropriate hvdromodificat control development principles and technologies. Not objective - goals yes. City of Los Angeles Low Impact Development Manual 3.8-31/5 In November 2011, the City of Los Angeles adopted the Stormwater Low Impact Development Ordinance #181899 with the stated purpose of: • Requiring the use of LID standards and practices in future developments and redevelopments to encourage the beneficial use of rainwater and urban runoff • Reducing stormwater/urban runoff while improving water quality • Promoting rainwater harvesting Reducing off-site runoff and providing increased groundwater recharge • Reducing erosion and hydrologic impacts downstream • Enhancing the recreational and aesthetic values in our communities 3.8-31/6 The City of Los Angeles institutionalized the use of LID techniques... Subsequent to the adoption of the Stormwater LID Ordinance, the City prepared the Development Best Management Practices Handbook, Low Impact Development Manual, dated June 2011, to describes the required BMPs (City of Los Angeles, 2011). 3.8-35/2 Mitigation Measure HYDRO -1 requires Permittees to evaluate the suitability of BMP locations for groundwater recharge. Infiltration BMPs would not be suitable in areas of low permeability where subsurface structures could be adversely affected by groundwater mounding. 3.8-41/5 Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs ...Implementation of the proposed structural BMPs, ... other reasonably foreseeable future projects... result it improved stormwater quality and reduced non storm flows .... will experience reduced dry -weather runoff, a more natural hydrology, and improved receiving water 3.8-42/1 quality. In addition, new infiltration projects will incrementally augment groundwater drinking water supplies. Although the increased infiltration projects may increase pollutant loads to groundwater aquifers, pretreatment systems beneficial uses of groundwater basins are not significantly impaired....EWMPs will beneficially impact local surface water quality and groundwater supplies. Mitigation Measures: None required Significance Determination: Less than significant 3.8-43/TABLE 3.8-3 SUMMARY OF HYDROLOGICAL RESOURCE IMPACTS REQUIRING MITIGATION MEASURES Cumulative Impacts, No mitigation required 3.9-212 ...shows land uses in the Ballona Creek Watershed and the location of planned and priority regional/centralized Best Management Practices (BMPs). The location of distributed BMPs would be throughout the urbanized areas of the watershed. 3.9-4/1 land uses in the Beach Cities EWMP area... 3.9-6/1 land use in the Dominguez Channel EWMP area... LACo EWMP COMMENTS 15 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- CCCCC. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC 3.9-8/2 ...land uses in the Malibu Creek Watershed EWMP area... 3.9-10/2 ...land use in the Marina del Rey Watershed EWMP area... 3.9-12/1 North Santa Monica Bay EWMP area... 3.9-15/2 ...Palos Verdes Peninsula EWMP area... 3.9-17/2 ...Rio Hondo/ San Gabriel River EWMP area... 3.9-19/2 ... Santa Monica Bay EWMP area... 3.9-21/2 ... Upper Los Angeles River EWMP area... Define and described priority, planned, and potential BMPs and projects and provide sequential arrangements. Will distributed BMP be implemented before the end of the priority or planned BMP implementation? Absence of phased or scheduled implementation listing of the BMPs projects renders section inadequate if not incomplete. 3.14-9/4 ...EWMP comprehensively evaluates opportunities ... multi -benefit regional projects that, wherever feasible, retain (i) all nonstormwater runoff and (ii) all stormwater runoff from the 85th percentile, 24-hour storm event for the drainage areas tributary to the projects, while also achieving other benefits including flood control and water supply,... Feasible. within the participating Permittees' collective jurisdictional area in a Watershed Management Area, for collaboration among Permittees and other partners on (i) all nonstormwater runoff and (ii) all stormwi runoff from the 85th percentile, 24-hour storm event for the drainage areas tributary to the projects, while also achieving other benefits including flood control Other partners feasible 85th %ile Flood control Water supply Is this an objective 3.14-15/5 Water Supply Impact 3.14-3: The proposed program (=The EWMP] could require new or expanded water supply resources or entitlements or require or result in the construction ... could cause significant environmental effects. Any increase in recharge and safe yields of local groundwater will be used in water supplies and support larger populations and more intensive water uses unless physical capacities are reduced by physical removal of existing facilities. Herein, unlike other sections, the program is acknowledges as to being capable%ould affecting/impacting directly on water resources and their associated water rights/entitlements and related retail service areas and populations (users). Given the general purpose of the EWMP is to recharge groundwater in a urban -suburban context where groundwater is used for water supply, such "conditional -could" appears totally inappropriate and must be technically defined/determined in order to fully and adequately discussed environmental, cost-effectiveness, and compliance with discharge water quality limits over the life of the projects. These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. 3.14-20/5 Impacts to the existing water supplies are anticipated to be beneficial as a result of the stormwater and non-stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. Mitigation Measure UTIL-1 would require that implementing agencies evaluate impacts to downstream beneficial uses, including surface water rights prior to BMP approval. No adverse 3.14 20- 21/1 cumulative impacts related to new or expanded water supply resources or entitlements would CCCCC occur. "Evaluate" is not a mitigation measure; similarly establishment of "surface water rights" for recharged groundwater and "BMP approval" are left undefined and unassigned. LACo EWMP COMMENTS 16 Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC Clearly require as part of the MMRPIan that the County and all Permittees and EWMPs establish recharged groundwater entitlements for every facility capable of recharging more than 100acft per year. Clearly require as part of the MMRPIan that the County and all Permittees and EWMPs establish water supply monitoring and reporting of dependent service area expansions or increased total use and the portion which is sourced from recharged storm and recycled waters for every facility capable of recharging more than 100acft per year. Impacts are not defined and an assumption of beneficial is not defined but would be assumed to improved/increase supply and reliability/assurance of supply for a larger population or higher uses which would lead to expanded supply service areas. This statement contradicts the statements regarding little or no water supply growth inducements; this becomes a greater concern when stormwater recharge is combined/integrated with recharge of recycled water for storage and eventual local water supply services. Review and revise these statements and those regarding growth inducements from increase water supply and reliability of service deliveries arising from increased local storm and recycled water sources. Historic practices in adjudicated basins has been that whoever adds water to the basin become entitled to extract that water for their own interests. LACo EWMP COMMENTS 17 20- CCCC cont. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 4-4/Table 4-1 EWMP Projects 4-4/Table 4.1 5 Wildlife Road Storm Drain Improvements Distributed North Santa Monica Bay Coastal Watersheds Construction was scheduled to begin March -August 2014 8A -8C Torrance Stormwater Basin Recharge and Enhancement Project Regional Beach Cities WMG Construction was scheduled for Spring 2014. 13 Phase II of the Mar Vista Recreation Center Stormwater BMP Project Centralized Ballona Creek Phase II is expected to be completed by December 2014. 19 San Ramon Canyon Stormwater Flood Reduction Project Centralized Palos Verdes Peninsula Anticipated to be completed June 2015. 4-5/Fig. 4-1 Storm Drains - Delineated CCSC 4-6/1 4.3 Plan Consistency General Plans Construction of structural BMPs and adoption of non- structural BMPs would occur throughout each of the EWMP areas, encompassing 84 cities and large area; of unincorporated Los Angeles County. Each city has adopted land use plans and zoning codes covering development within their jurisdictions. Many cities including the City of Los Angeles have adopted LID ordinances that promote new development of storm flow retention and water quality BMPs. Each implementing agency would be required to evaluate the consistency of each BMP with local zoning codes. Compliance with city codes for placement of BMPs would ensure that the cumulative impact of installing multiple BMPs throughout the County would not conflict with local plans and policies. 4-6/2 The Los Angeles County General Plan includes land use designations ... provides a list of policies ... that promote storm water quality infrastructure. The installation of multiple BMPs ... wt regional conservation planning ettons... lncivaing critical naonat, signmcant ecological areas, naDl conservation planning areas, and... parks.... enhanced water quality and a more natural hydrology encouraged... consistent with the habitat conservation goals of each of these plans. Recent changes in Hauled Water Initiative constraints. 4-6/2 ...Permit describes the Watershed Management Program optional compliance approach as providing more opportunities for multi -benefit projects that would encourage goals of recreation and habitat value creation as part of the BMP. The proposed program would be consistent with regional General Plan goals and policies. Program Consistency General Plan Goals and Policies. 4-7/1 ...air quality, traffic, and water supply), the cumulative setting... specific regional boundaries... contributing to cumulative impacts... cumulative setting is based on development anticipated within the vicinity of the EWMP project. The impact analysis in Chapter 3 ... cumulative impacts for each resource area... conclusions of the cumulative analysis in Chapter 3 .... implementation of the BMPs would result in cumulative significant impacts to air quality, cultural resources, and noise. Hauled water, recycled water, and stormwater. LACo EWMP COMMENTS 18 These comments are duplicative Of comments in the Final Submittal. See responses 20-A through 20- CCCCC. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC p.4-8/Table 4-3 SUMMARY OF CUMULATIVE IMPACT ANALYSIS These Issue Significance comments are Area Determination duplicative Hydrology and Water Quality (Cumulative) LSM [Less than Significant with Mitigation]. of comments Given common usage of groundwater basins for recharged water storage for both storm and in the Final recycled waters revise the table and incorporate growth inducements amongst cumulative Submittal. See impacts for recharged stormwater. responses 20-A through 20- ccccc. LACo EWMP COMMENTS 19 Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC 6-2/5 6.2 Review of Proposed Program Goals and Objectives The alternatives presented in this chapter were analyzed for their abilities to reduce significant program impacts and meet the objectives of the proposed program, which are: • To collaborate among agencies (Permittee jurisdictions) across the watershed to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the Municipal Separate Storm Sewer System (MS4) Permit. • To develop watershed -wide Enhanced Watershed Management Programs (EWMPs) that would, once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff in a cost- effective manner. • To reduce the impact of stormwater and non-stormwater on receiving water quality. Discussion starts with a title of Goals and Objectives then switches to objectives. These are goals not objectives as they are not quantified nor scheduled in any manner. Since two "objectives" refer to "cost-effectiveness" and no costs, revenues, economics, or financial information or assessment are not provided, all discussions of the achievements of goals and objectives becomes mute and the PEIR totally incomplete with regard to the "project or "program" and its alternatives. Similarly reference to collaboration becomes mute as all related agencies and those in the county have already collaborated and therefore any "collaboration" discussion must be quantified which they have not been. As to compliance with permit conditions and reduction of impacts are only presumed without documentation which is under parallel preparation for June 2015 and without any hydrological modeling or calculations to support such contentions and comparisons amongst alternatives. The entire Alternatives section is incomplete and totally inadequate. 6-3/4 The Lead Agency conducted an alternatives screening process to identify feasible alternatives to the proposed program. The screening process for identifying viable alternatives included consideration of the following criteria: • Ability to meet the program objectives [presumes meet objectives or not considered] • Ability to reduce significant environmental effects of the proposed program • Economic and engineering feasibility [presumes to meet economic feasibility parameters an criteria not presents] Introduction of "Lead Agency" at this point would imply some agencies other than LACoDPW, perhaps LACoFCD (??); while reference to an "alternative screening process" indicates some formal process rather than that documented in the PEIR. Discussion of environmental effects or water -related compliance of flow and quality for a Water Resources project or program without a quantified and presumably computerized complex model for each watershed element is totally inadequate and incomplete at any level. Introduction of "feasible" and economics without definitions and the objectives which 213 include costs and therefore economics strongly distorts any screening or comparisons toward costs, economics, and financial for which no information is provided or believed to be even remotely available for the PEIR, the EWMP, and most if not all of the EWMPs. Such inadequacies and incompleteness renders Sec.6 irrelevant to the CEQA process with regard to the project, any alternatives, and any designation as to an "Environmentally Superior Alternative" compared to an "economically superior alternative". Presumptions and unsupported statement are not with the goals of CEQA to provide a complete, adequate, objective, and quantified review and assessment of a program's or project's effects and appropriate mitigation and alternatives to such. 6-3/5 Based on these criteria, the Lead Agency has identified the following alternatives: Introduction of "Lead Agency" at this point would imply some agencies other than LACoDPW, perhaps LACoFCD (??); while reference to an "alternative screening process" indicates some formal process rather than that documented in the PEIR. Identifications are not supported in comparisons primarily with regard to collaboration and presumed economies of scale and cost-effectiveness. LACo EWMP COMMENTS 20 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC 6-512 Ability to Meet Program Objectives The No Program Alternative... not meet... objective to collaborate among agencies... promote more cost-effective and multi -beneficial water quality improvement projects... meet the other objectives to remove or reduce pollutants from dry- and wet- urban eburban runoff and reduce the impact of stormwater and non-stormwater on receiving water quality... 6-717 The Non -Structural BMPs Only Project Alternative may not meet the objectives of the proposed program to collaborate among agencies to promote more cost-effective and multibeneficial water quality improvement projects because Non -Structural BMPs are generally implemented individually in each jurisdiction, so collaboration efforts for cost-effective solutions diminishes with implementation of non- structural BMPs only. 6-919 Ability to Meet Program Objectives The Distributed Structural BMPs Only Program Alternative would meet the objectives of the proposed program to collaborate among agencies to promote more cost-effective and multibeneficial water quality improvement projects. However, because distributed structural BMPs tend to be smaller in nature and typically are distributed widely throughout the watershed, more BMPs may be necessary to meet water quality objectives in the MS4 Permit. The ability to meet 6-10/1 the water quality objectives would be less certain under this alternative. This statement indicates that distributed BMPs are cost-effective for the program although they ar smaller (may disagreed based on economies of scale and information provided by LACiDWP). "Less certain" is not defined nor is the statement supported; 100 times more sites may be sufficient and available but no presumption can be supported either way based on the PEIR. 6-1213 6.6 Alternatives Suggested in Scoping ...comment letter... suggested that the PEIR include an assessment of several funding mechanism alternatives, including: Single Parcel Fee Assessment, Parcel Area Fee Assessment, Hybrid Parcel Area Fee Assessment, Zero Discharge Assessment, and Large Parcel Assessment. These suggested alternatives would not lessen any significant environmental impacts of the Program and were therefore not considered in this PEIR. Although CEQA allows for discussion of economic impacts and project costs as measures of feasibility, the funding mechanisms required to implement projects are generally not susceptible to environmental analysis. As the program objectives and criteria for alternatives both include economics and costs and as al BMPs require both capital and operation and maintenance costs to be effective, a full documentation using the above mentions financing package must be incorporated into the project description and alternatives, especially those presented to the LARWQCB in June 2015. Adequately funded projects within the ability to pay of the service population would assure continue environmental compliance and support of a wide array of mitigation measures compared to capital intensity project requiring longer term bonding and expensive project management. Comparisons of large projects with high capital costs to program of lots of small projects with low capital costs but with higher operating costs have been alluded to in discussions of other alternatives but without any documentation. As all publicly funded projects to be submitted to LARWQCB in June 2015 must be funded n have not been demonstrated at this time to be funded, any inclusion of projects in this program can not be assumed to have long-term funding to assure mitigation of impacts. 6-1214 ... comment ... Full Capture and Recharge of Flows Greater than 100 cfs Alternative... rejected... because of the infeasibility of capturing all storm flows... unrealistic, requiring most of the developed land in the County to be accomplished... ...suggesting full capture of all flows less than 100 cfs... was rejected from further consideration for the same reason ... would require enormous areas of ... currently developed... recharge is only feasible in certail areas of the County because of the poor percolation capacity of surficial soils... accumulation of subsurface clay lenses creates recharge barriers in many places of the County, making retention and recharge of large quantities of stormwater infeasible in these locations. LACo EWMP COMMENTS 21 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- CCCCC. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC PE/R total lacks definitions for "feasibility" and "infeasiblity" as to technically, financially, administrative, or politically aspects. As no surface or subsurface hydrologic model is available or referenced, and supporting documentation is not provided nor apparently available for either flow capture alternative dismissal. The PEIR does not provide maps of locations with clay lenses and their extents/depths and tt barrier effects. 6-13/Table 6-2 Ability of Project Alternatives to Meet Project Objectives Project Objectives 1. To Collaborate Among Agencies (Permittee Jurisdictions) Across the Watershed To Promote more cost-effective and multi -beneficial water quality improvement projects To comply with the MS4 Permit. [=portions of Objectives 2 8 3] 2. To develop watershed -wide EWMPs that will, once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff [= Objective 1.] in a cost-effective manner. 3. To reduce the impact of stormwater and nonstormwater on receiving water quality. [=Objective 1.] Program and projects confused and confusing. As objectives, inadequately quantified and not scheduled. Comparisons of alternatives and "abilities" of Project GOALS and objectives without cost- effectiveness and any hydrological model for wet/storm and dry/storm water flows render all a totally inadequate and incomplete. As written, the objectives must be referred to as "Goals"; objectives must be measurable/monitorable with schedules and quantified levels of achievement, e.g., 4Qtr2016 and $100/ppm reduction. 6-14/1 The No Program Alternative... impacts... would be similar to the proposed alternative. None of the significant and unavoidable impacts of the proposed alternative would be avoided by this alternative. Furthermore, since the ability to achieve compliance with MS4 Permit water quality objectives would be reduced if each Permittee were on their own, impacts to water quality would be greater under this alternative. 6-14/2 The Distributed Structural BMPs Only Alternative... would avoid construction and operational impacts... However, since the ability to achieve compliance with MS4 Permit water quality objectives would be reduced without the larger -scale centralized and regional BMPs, impacts to water quality would be greater under this alternative. LACo EWMP COMMENTS 22 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 Stakeholder O Advisory Comte LACity Frank Acevedo SOAC Central Planning Commis. facevedo@rampartproperties.net Tunnel Profile Slopes -2.86 CNC Hellman -Valley 3% Drop 3/100 60ft x 3 180ft 5280ft to tunnel depth - 158.4 lower road deck for %slopes and for x2cover beneath URR 40+120 -3.50 CNC Valley-UPRR 1000ft = 35ft Dive! Dive! Dive! +1.75% Main Bored Tunnel +3.45 CNC Palmetto > DelMar Blow Ballast +3.00 CNC Delmar>Colorado AIR QUALITY Comply with 2012RTP/2015 FTIP Additional analyses for Prefferred Alternative Designs for Cost Estimates Designs for Air Modeling and Ventilation Size-Flows/Velocity-Temps/Compositions >1% slopes -5mi Intake vs Outflow Tunnel Plenum- above/below - Ventilation ECONOMICS - Property Acquisition Parking Employment Property and Sales Tax Revenues losses PPP Partnerships Lee Dolley Parking losses CCSC LACo EWMP COMMENTS 23 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 #28 PropertyAcquisitions/Relocations #29 Land Use - Parking Space/Te mpor./Permanent #30 Employment/Fiscal Impacts - O&M Jobs and Annual Earnings not using Million $ - separated Millions and $0-$50 #31 Construction Employment/Fiscal Impacts - Jobs and Annual Earning #32 Property and Sales Tax Revenue Loss -Annual $10K -$80K CCSC LACo EWMP COMMENTS 24 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC RESOLUTION Whereas the MTA/Metro and Caltrans remains supportive of the Freeway Tunnel for the SR 710 North Extension Project; Whereas the current route and portal location remains in and under the City of Los Angeles and is contrary to the City Council Resolution of 2012; Whereas the proposed portal buildings would foreclose any further expansion of high tech biotechnical developments; and Whereas the most probable favored alternative, Freeway Tunnel, would include tolled trucking witf a capacity of more than 40,000 trucks a day, every day. Therefore be it resolved, the Sunland Tujunga Neighborhood Council opposes the Freeway Tun either single or dual, for the selected alternative of the SR -710 North Extension project and supl a more transit and rail based alternative to serve passenger and goods movements for the central/western San Gabriel Valley and eastern City of Los Angeles. Dr. Tom Williams 323-528-9682 ctwilliams20l2@yahoo.com RESOLUTION Whereas the MTA/Metro and Caltrans remains supportive of the Freeway Tunnel for the SR 710 North Extension Project; Whereas the current route and portal location remains in and under the City of Los Angeles and is contrary to the City Council Resolution of 2012; Whereas the proposed portal buildings would foreclose any further expansion of high tech biotechnical developments; and Whereas the most probable favored alternative, Freeway Tunnel, would include tolled trucking with a capacity of more than 40,000 trucks a day, every day. Therefore be it resolved, the Sunland Tujunga Neighborhood Council opposes the Freeway Tunnel, either single or dual, for the selected alternative of the SR -710 North Extension project and support a more transit and rail based alternative to serve passenger and goods movements for the central/western San Gabriel Valley and eastern City of Los Angeles. Dr. Tom Williams 323-528-9682 ctwilliams20l2@yahoo.com RESOLUTION Whereas the MTA/Metro and Caltrans remains supportive of the Freeway Tunnel for the SR 710 North Extension Project; Whereas the current route and portal location remains in and under the City of Los Angeles and is contrary to the City Council Resolution of 2012; Whereas the proposed portal buildings would foreclose any further expansion of high tech biotechnical developments; and Whereas the most probable favored alternative, Freeway Tunnel, would include tolled trucking with a capacity of more than 40,000 trucks a day, every day; Therefore be it resolved, the Sunland Tujunga Neighborhood Council opposes the Freeway Tunnel, either single or dual, for the selected alternative of the SR -710 North Extension project and support a more transit and rail based alternative to serve passenger and goods movements for the central/western San Gabriel Valley and eastern City of Los Angeles. Dr. Tom Williams 323-528-9682 ctwilliams20l2@yahoo.com LACo EWMP COMMENTS 25 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. DAY 1 8.25 Course review, objectives, introductions 1.00 Completion design - objectives 0.50 Break 0.25 Completion design - key decisions 2.00 Lunch 1.00 Completion- integration with well construction 1.00 DAY 2 8.50 Completion equipment 1.25 Exercise 0.25 Completion equipment 1.25 Exercise 0.5 Perforating 0.75 Lunch 1.00 Perforating 0.50 DAY 3 8.50 Formation damage 1.25 Exercise 0.25 Break 0.25 Wells servicing fluids 1.00 Exercise 0.25 Lunch 1.00 Completion programming & exercise 1.00 DAY 4 8.25 Sand exclusion techniques 1.00 Exercise - sand exclusion selection 0.50 Break 0.25 Well problems and workover planning 1.00 Exercise - well diagnosis 0.5 Coiled Tubing 0.75 Lunch 1.00 Coiled tubing 0.75 DAY 5 4.75 Live well interventions 0.50 Hydraulic workover and snubbing units 1 Break 0.25 Frequently deployed workover operations 1 Exercise 1.00 Lunch Completion programming and course review ?????? Further discussion if required Complex wells - horizontal wells 0.75 Well stimulation - options 1.00 Coiled tubing 0.75 Completion - impact of well flow capacity 0.75 Complex wells - multilateralslmultiple 0.75 Well stimulation screening 0.50 LACo EWMP COMMENTS 26 These comments are duplicative Of comments in the Final Submittal. See responses 20-A through 20- CCCCC. Comment Letter 20 Dr. Tom Williams March 13, 2015 Submittal #3 CCSC DAY 1 8.25 Course review, objectives, introductions 1.00 Completion design - objectives 0.50 Break 0.25 Completion design - key decisions 2.00 Lunch 1.00 Completion- integration with well construction 1.00 DAY 2 8.50 Completion equipment 1.25 Exercise 0.25 Completion equipment 1.25 Exercise 0.5 Perforating 0.75 Lunch 1.00 Perforating 0.50 DAY 3 8.50 Formation damage 1.25 Exercise 0.25 Break 0.25 Wells servicing fluids 1.00 Exercise 0.25 Lunch 1.00 Completion programming & exercise 1.00 DAY 4 8.25 Sand exclusion techniques 1.00 Exercise - sand exclusion selection 0.50 Break 0.25 Well problems and workover planning 1.00 Exercise - well diagnosis 0.5 Coiled Tubing 0.75 Lunch 1.00 Coiled tubing 0.75 DAY 5 4.75 Live well interventions 0.50 Hydraulic workover and snubbing units 1 Break 0.25 Frequently deployed workover operations 1 Exercise 1.00 Lunch Completion programming and course review ?????? Further discussion if required Complex wells - horizontal wells 0.75 Well stimulation - options 1.00 Coiled tubing 0.75 Completion - impact of well flow capacity 0.75 Complex wells - multilateralslmultiple 0.75 Well stimulation screening 0.50 LACo EWMP COMMENTS 26 These comments are duplicative Of comments in the Final Submittal. See responses 20-A through 20- CCCCC. Dr. Tom Williams Wireline techniques 0.75 Completion - artificial lift options 0.50 (Break) 0.25 (Break) 0.25 (Break) 0.25 Exercise 0.50 Exercise 0.50 Exercise - stimulation screening 0.50 Wireline 1.00 Comment Letter 20 March 13, 2015 Submittal #3 CCSC Completions and Workovers (CAW) COURSE AGENDA Director Specialised completion/technologies 0.75 Sand production and management 1.00 Exercise 0.50 Exercise - sand size analysis 0.25 LACo EWMP COMMENTS 27 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- CCCCC. Paige Anderson To: Laura Rocha Subject: RE: EWMP-PEIR Comments 2/4 From: Tom Williams[mailto:ctwilliams20l2(a)vahoo.coml Sent: Wednesday, March 11, 2015 2:00 PM To: Gregg Begell Subject: EWMP-PEIR Comments 2/4 See attached 03/11/15 #2 of 4 Comments Will be integrated for final submission on 03/16/15 12-3pm Thanks Comment Letter 20 SECOND DRAFT COMMENTS SUBMITTED MARCH 11, 2015. SUBSEQUENT DRAFTS 3 AND 4 (FINAL) WERE BASED ON THIS SECOND DRAFT SUBMITTAL. THE FINAL SUBMITTAL WAS BRACKETED FOR RESPONSE. Tom CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 20 Dr. Tom Williams March 11, 2015 Submittal #2 CCSC March 11, 2015 TO: Gregg BeGell, P.E. County of Los Angeles Department of Public Works, Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 gbegell@dpw.lacounty.gov FROM: Dr. Tom Williams, Sr. Techn. Advisor Citizens Coalition for A Safe Community Sierra Club, Angeles Chapter, Water Committee Subject: Enhanced Watershed Management Plan RE: Comments on Programmatic Draft EIR Specific Comments #2/4, 03/11-13-16/15. SAME as 03109115 Following provides a brief review of the CEQA/P-DEIR (PEIR) documents of almost 70MB/1000 pages. We thank the LACo Department of Public Works and Flood Control District for this opportunity to review and comment on the PEIR and greatly appreciate the deadline extension for doing such. I will be submitting detailed comments during 03/09-03/16, and these overall comments on 03/09 & 16/15. Overall review is that the document(s) are inadequate, incomplete, inaccessibility for the general educated public due to the volume, technical character, overly -broad statements, lack of documentation and support These of statements, and lack of consistency of terms and usage, comments are The proposed Program does not provide a plan for tiered project CEQA considerations by the other duplicative permittees nor the County itself. No plan for the Program or the projects has been established for the of Enhanced Watershed Management Plan to achieve and comply with the LA Regional Water Quality comments 9 P Y 9 Y in the Final Control Board's permit requirements. A program may be more generalized but still must provide a plan of Submittal actions for both the lead and responsible agencies. I See The Program does not provide even the requirements, process, and procedures for subsequent CEQA compliance by other permittees and some projection as to whether EIRs, MNDs, ND, or CE will be used to tier down from this P-DEIR/P-FEIR. Conditions for Program Compliance by tiered projects have not been listed or even referenced other than some ill-defined listing of BMPs. No current listing of all planned and funded Projects has been provided and incorporated into a scheduled and quantified plan for submission in June. Although research has been underway for five -plus years, the EWMP and this EIR does not use nor even reference use of computerized modeling of the appropriate basins (Ballona Creek, Upper LA River, Middle LA River and Arroyo Seco, Lower LA River and San Gabriel River, and LA River Mouth/Estuary- Dominguez Channel) although the federal agencies (BLM, USGS, ACoE, etc.) and perhaps local agencies (some permittees and the Water Board) have some local or watershed models . Without a model and its components, the impacts and their significance of detention, retention, recharge, and flood protection cannot be assessed nor mitigated adequately or completely. Three goals are provided but no objectives (sub -tiered from goals) are provided with/without defined schedules and other quantitative parameters for program monitoring. Confusion is introduced in later text when both flood control and water supply "augmentation" are also introduced as "goals" and as "objectives". Specific goals are only to meet the MS4 Permit requirements and related water quality conditions and to meet them in a "Cost -Effectiveness" manner. However, costs, financial support, revenue, capital bonding, or economic effectiveness or efficiency are not provided, and thereby achievement of the cost effectiveness cannot be judged nor compared and must presumed by submission of any proposed project. LACo EWMP COMMENTS through 20- CCCCC. Comment Letter 20 Dr. Tom Williams March 11, 2015 Submittal #2 CCSC Growth inducement is mentioned primarily with regard to direct housing construction and employment and incomes while dismissing potential effectts of recharged (diverted storm flows) water supplies. Additional benefits primarily for flood protection are mentioned in some statements while it is not supporteC These by any text or analyses under water resources. No assessment of beneficial and adverse effects are comments provided for raising base flow levels from program-augmented/diverted-stormwater groundwater resourceE are and their effects upon subsequent pollutant concentrations and flood flows. duplicative of comments I am retired from 30 years in water and environmental resources with Parson Corp., Pasadena and URS in the Final San Francisco and over 10 years with Dubai (UAE) government and local water and environmental submittal. companies. I have prepared sections and entire documents for more than 300 EIRs, EISs, and EAS see worldwide for local agencies, cities, counties, states, federal, and international agencies and organizations responses 20-A and have reviewed more than 100 additional assessments. During work for URS, I was involved in the through 20 - development and environmental considerations for the 1970s EPA's Santa Ana and Santa Marguerita/San ccccc. Luis Rey basins plans. My reviews have included the LACity's Recycled Water Management Plan and Stormwater Capture Management Plan, and I am currently vice chair of the LA City's Floodplain Management Plan. Dr. Tom Williams LACo EWMP COMMENTS Comment Letter 20 Dr. Tom Williams March 11, 2015 Submittal #2 CCSC NEW - NOT INCLUDING THOSE OF 03/09/15 EWMP - SPECIFIC COMMENTS Comments, recommendations, and additions are presented in Bolded Italics PEIR text specific to the comments are presented in plain text as was in the PEIR. Some specifically relevant PEIR text may be Bold Underlined. ES -212 The EWMPs will identify potential and priority structural and non-structural Best Management Practices (BMPs) within the region's stormwater collection system to improve runoff water quality. Potential and priority BMPs are referred to but are not adequately related to the EWMPs and the EWMP/PEIR and as indicated herein they ARE BEING developed, they are not developed. The EWMP and PEIR are not definitive at even a programmatic or conceptual deign level. ES -215 A few of the BMPs are currently well defined but most are vet to be fully developed under the EWMPs .... priority BMPs... detailed in each of the EWMPs; these are being developed in parallel with th PEIR.... describes the details that are available for each of the EWMPs currently... by the EWMP working groups. 1-3/3 A set of priority BMPs will be detailed in each of the EWMPs; these are being developed in parall with the PEIR. The PEIR describes the details that are available for each of the EWMPs currently under preparation by the EWMP working groups. No definition of "Fully" or "Well" is provided for the PEIR and as they are being developed at the same time as this PEIR their entire discussion is so general as to render assessment impossible and open to any combination of current or future "projects" and BMPs as desired by the agencies. No reliable discretionary decision can be made and funded based on the PEII 1-113 The MS4 Permit gives Permittees the option of implementing an innovative approach to permit compliance through development of an Enhanced Watershed Management Program (EWMP).... Will identify potential and priority structural and non-structural Best Management Practices (BMPs) within the region's stormwater collection system to improve runoff water quality. The LACFCD, along with participating Permittees, has opted to exercise this option and has submitted to the LARWQCB 12 separate Notices of Intent (NOls) for the development of EWMPs within 12 distinct watershed groups... Implementation of the EMWPs would be the responsibility of each Permittee and would occur following approval of the EWMPs by the LARWQCB. BMPs, groups of BMPs, and Projects are not defined at any engineering levels so as to determine cost-effectiveness, capabilities to achieve any project/program goal involving water quality or flows and their effects and impacts. 1-3/3 The EWMPs will identify management strategies including hundreds of structural Best Management Practices (BMPs) that may be designed and implemented by the Permittees to meet permit compliance objectives [Only one of the Program objectives]. Clearly indicates that this RAA model for water quality is not completed prior to its assessment ant that the assessment cannot adequately assure that even the water quality goals and objectives cannot be realized. Water quality and flow models and proposed BMP depend on diversion or reduction of flows durin; both dry- and wet -weather flows, and therefore the RAA must be based on a hyrdo/ogic/hydraulic model which has not bee referenced or mentioned. This EWMP and PEIR must provide the programmatic management strategy guidelines for those of the tiered -down EWMPs-strategies and related CEQA documents. Use of the conditional: "may be" voids following verbs and leaves the statement as irrelevant to the Program and Project EIRs. 1-413 The EWMPs are to include a discussion of the environmental documents, assessments, and permitting required for the implementation of the priority projects. The PEIR can provide a basis for this LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 11, 2015 Submittal #2 CCSC discussion. The use of the PEIR in the development and implementation of the EWMPs is further discussed in this chapter in the Purpose of the Program Environmental Impact Report. Priority BMPs were discussed but have not been distinguished from "Priority Projects". The PEIR does not discuss the process of tiering to projects or to specific BMPs and whether Mitigated Negative Declarations will be tiered down from this PEIR or whether the project must require tiered/focused EIRs for full and adequate CEQA compliance. 1-7/1 • Other Receiving Water Considerations (second category): - The second highest priority shall be considered controlling pollutants for which data indicate impairment of exceedances of receiving water limitations and the findings from the source assessment implicates discharges from the MS4. As no hydrologic model for flows and concentrations has been provided even for the TMDL constituents, references to secondary pollutants appears totally inappropriate and purposefu0 attempts to elevate the credibility of compliance with the TMDL, which has not been achieved. 1-7/2 The EWMP prioritization process includes identifying the priority pollutants and... schedule for implementing BMPs to meet the following criteria: • For pollutants... same class as TMDLs.... consider these pollutants within... same time frame as ... TMDLs. • For ... 303(d) list ... EWMPs develop a schedule to address these pollutants as soon as possible with milestones. Priority pollutants have already been prioritized and identified, and the prioritization process has not been described although referred to, and no schedule for prioritization, definition of priorit, projects or priority BMPs has been provided. Prioritization process and schedule are rendered totally inadequate when modified by whenever "possible". MMRPIan must include a full and scheduled prioritization process for ALL EWMPs. 1-8/2 The RAA is being performed as part of the preparation of the EWMPs, and in parallel with ... this PEIR. The RAA... primary goal of the EWMP ... meet the water quality goals. The modeling being performed... will determine... number and distribution of the BMP types and specific projects identified in the EWMP Work Plans will meet the water quality goals. This PEIR will assess the types of BMPs that mal be implemented to meet these WATER QUALITY goals. Management strategies (MSs) presumably are different from the BMPs and the EWMPs which they maybe be parts of, but MSs are not defined nor associated with BMPs and EWMPs. The RAA and a supporting/integrated Hydrologic Model must be provided in a final form to be incorporated, not be performed in parallel, with full integration/incorporation. The MMRPIan must include a final RAA. 1-9/1 The LACFCD will consider the information presented in this PEIR, along with other factors, ±.!!1e. development and implementation of the EWMPs. The EWMPs are to include a discussion of the environmental documents, assessments and permitting required for the implementation of therip ority projects. The PEIR can provide a basis for this discussion. 1-10/2 The EWMPs are to include a discussion of the environmental documents, assessments, and permitting required for the implementation of the priority projects. Repeated Consider and other factors are not defined and as such allow the entire PEIR process to be set- aside. The PEIR does not fully define the roles and participations of the LACFCD in the development of tiered EWMPs and their CEQA documents. Again "priority projects" are mentioned and not defined with regard to "priority and potential BMPs." CEQA texts must recognize differences between "can/could provide" and "will/would provide" and require clarity as to what will occur in the teiring of projects and CEQA documents. LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 11, 2015 Submittal #2 CCSC 1-11/1 Maps identifying potential and priority BMP locations are provided in Chapter 2 ... with the oval EWMP watershed characteristics and BMP implementation strategy. No definition or specificity of potential and the subgroup priority BMPs and locations nor details are provided within the tables and generalized maps. No watershed characteristics are provid regarding runoff coefficients, design rainfall amounts, times of concentrations, are estimated flow levels are provided for any watershed, not even a ranking of highest to lowest flows or highest -lowest dry- and wet weather water qualities. 1-11/1 The PEIR focuses its assessment on construction and operation of these potential and priority BMPs to be installed throughout the watersheds—but primarily within urbanized areas where the pollutan loading is greatest and where these BMPs can be most cost-effective in meeting water quality goals No focused information is given regarding the BMP operations and their effectiveness in removing pollutants and meeting water quality goals (not objectives). No information is provided regarding the degree of urbanization for each watershed, nor the assumed "loadings" being greater, median, or least. BMPs are presumed as cost effective without documentation and analyses as to pollutant - present/removed per 100 acft or any other quantified parameter and as to achievement of current reductions down to desired goals. 2-5/1 Additional information and figures on the location and distribution of potential and priority BMPs based on available data at the time of publication of this PEIR, are presented in Section 2.5, EWMP Watershed Characteristics and BMP Implementation Strategies. 2-15/2 Source Control BMPs. Source control structural BMPs are commercial products designed to runoff in highly urbanized environments. Mechanical separation, or more complex physicochemical processes, provides separation of gross solids and other pollutants... designed to sequester hydrocarbons and other pollutants. Residual pollutants and their disposition is not mentioned nor provided any where in the PEIR. discussion is included regarding the soil sequestering of hydrocarbons, metals, and other pollutants in the ground materials (especially in/on clays). No estimate is provided as to anticipated sequestering per year and probable long-term removal of soil materrials before achieve "hazardous" levels. 2-16/2 Specific examples of distributed BMPs that are in various stages of planning and implementation and part of a possible EWMP are presented in Table 2-3. The locations of these examples of planned distributed BMPs are shown in Figure 2-2. Table 2-3 presents the locations, project description, and key elements of the distributed BMPs to further illustrate these types of structural BMPs that may be part of an EWMP. Additional information and figures on the location and distribution of potential and priority BMPs, where data areis available, are presented in Section 2.5, EWMP Watershed Characteristics and BMP Implementation Strategies. Centralied and Regional BMP discussions repetitive from 2-16/2 except as highlighted. 2-28/2 ...centralized BMPs ... presented in Table 2-4. The locations of these examples of planned and implemented centralized BMP ... in Figure 2-3. Table 2-4 ... the centralized BMPs ... structural BMPs that are part of the EWMP.... of potential and priority BMPs, where data ar" available,... BMP Implementation Strategies. 2-35/1 ...regional BMPs ... of planning and implementation and that are part of the EWMP are presented in Table 2-5. The locations of these examples of regional BMPs are shown in Figure 2-5. Table 2-5 ... of the regional BMPs to further illustrate these types of structural BMPs that are concepts being developed through the EWMP process. ...of potential and priority BMPs, where data areis available... BMP Implementation Strategies. LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 11, 2015 Submittal #2 CCSC The complex repetitive wording and slight but several differences in these texts cause considerable confusion for the public review and participation in this CEQA process. Without clear table -ed presentation meaning and clarity are lost, rending these important issues inadequately treated in this PEIR. 2-40/1 Summarized below are the general characteristics of the watersheds within the EWMP Groups and the overall strategies for BMP implementation ... twelve EWMPs are consolidated to six watershed areas... summary provides additional detail on the distribution and location of potential and priority BMPs where data is available,... for each EWMP and show the location and distribution of planned and priority regional/centralized BMPs for which data are available at the time of publication of this PEIR. The priority BMPs ... subset of the potential BMPs that have undergone a site review and project evaluation the has identified these BMPs as a priority. These priority projects are shown based upon available data at the time of publication of this PEIR. EWMP groups, EWMPs, and watershed areas are inadequately associated and defined; presumably 12 EWMPs may be associated into 6 EWMP Groups based on watershed associations. Similarly designations as to: Potential, Planned, and Priority BMPs - Priority BMPs are part of Potential BMPs Regional and centralized BMPs - excluding distributed Priority projects or BMPs; require clear definitions and ordering in order to have adequate clarity for public review. 2-40/1 Appendix G provides the location and general description of the priority BMPs ... Distributed BMPs are planned to be implemented throughout the urbanized areas of each EWMP. 2-43/3 ...Figures 2-5 through 2-16, each of the EWMPs ... wide distribution of BMPs to achieve permit compliance. Appendix G provides the locations and general descriptions of the priority BMPs (where data is available),... Priority Projects are projects that have been identified through the EWMP process as targeted for implementation within the first years following the EWMPs approval by the LARWQCB. Identification of Priority Projects is underway and has not been completed by all EWMPs at this time. [For any??] ... PEIR is being prepared in parallel to the EWMPs. Priority Proiect: [proper noun] will be defined in all the EWMPs to be submitted for public comment in June 2015. Priority Projects that have been identified at this time through the EWMP process are shown on the following figures. Priority Projects may be regional, centralized or distributed type BMPs. For potential proiects... location of potential regional and centralized BMPs are shown. Distributed BMP will be distributed throughout the urbanized areas and are not shown on the following figures ... 2-44/1... No "general description" is provided for the program, projects, and BMPs, as summarized below, only listings and figures found in the Vol. 1. Apdx. G EWMP Proposed BMP and Priority Projec Data and Figures A -L, pages unnumbered items renders the entire appendix confusing and un - reviewable for the general public and the only "General Description" is APN numbers. 2-57/1 2.6 EWMP BMP Implementation Schedule The EWMPs that are being prepared in parallel the PEIR will provide a timeline for the implementation of the BMPs [as define in MS4/TMDLs]... priority BMPs ... that have undergone a site review and project evaluation and ... based on available data at the time of publication of this PEIR... Implementation of priority BMPs will begin The entire process of LACo-EWMP, EWMPs, BMPs, etc. and implementation of "Priority BMPs" have not been fully provided nor adequately documented. As indicated above, a fully scheduled/timed EWMP/EWMPs implementation schedule for all BMP and for further - annual - updating must be included in the Final PEIR perhaps as part of the MMRPlan for PEIR and within each EWMPs' CEQA documents. Statements as to the submittal dates in less than three months clearly indicates that undue pressure is being attempted in order to force the CEQA and project development processes through without due consideration as to the completeness and adequacy of project, program, and CEQA documents and processes. LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 11, 2015 Submittal #2 CCSC 2-57/4 Each EWMP will define priority projects, and installation of these projects will move forward depending on the availability of funding and outcome of further project -specific CEQA review. Funding options for implementing agencies would include obtaining grant funds, low-interest loans, ta: based general funds, or special assessments. Each jurisdiction will be responsible for securing the necessary funds over time to achieve permit compliance. References to but absence of information regarding funding, funds, and other related economic/financial elements and their pivotal importance to any "Project" renders continued discussion of projects inadequate and incomplete and subject to major changes of any PEIR referenced "project between now and July 1, 2015 and thereafter. Introduction of ' jurisdiction" renders the discussion meaningless, incomplete and inadequate. LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. 3.14-15/5 Water Supply Impact 3.14-3: The proposed program (=EWMP] could require new or expanded water supply resources or entitlements or require or result in the construction ... could cause significant environmental effects. Given the general purpose of the EWMP is to recharge groundwater in a urban -suburban context where groundwater is used for water supply, such "conditional -could" appears totally inappropriate and must be technically defined/determined in order to fully and adequately discussed environmental, cost-effectiveness, and compliance with discharge water quality limits over the life of the projects. 6-2/5 6.2 Review of Proposed Program Goals and Objectives The alternatives presented in this chapter were analyzed for their abilities to reduce significant program impacts and meet the objectives of the proposed program, which are: • To collaborate among agencies (Permittee jurisdictions) across the watershed to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the Municipal Separate Storm Sewer System (MS4) Permit. • To develop watershed -wide Enhanced Watershed Management Programs (EWMPs) that would, once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff in a cost- effective manner. • To reduce the impact of stormwater and non-stormwater on receiving water quality. Discussion starts with a title of Goals and Objectives then switches to objectives. These are goals not objectives as they are not quantified nor scheduled in any manner. Since two "objectives" refer to "cost-effectiveness" and no costs, revenues, economics, or financial information or assessment are not provided, all discussions of the achievements of goals and objectives becomes mute and the PEIR totally incomplete with regard to the "project or "program" and its alternatives. Similarly reference to collaboration becomes mute as all related agencies and those in the county have already collaborated and therefore any "collaboration" discussion must be quantified which they have not been. As to compliance with permit conditions and reduction of impacts are only presumed without documentation which is under parallel preparation for June 2015 and without any hydrological modeling or calculations to support such contentions and comparisons amongst alternatives. The entire Alternatives section is incomplete and totally inadequate. 6-3/4 The Lead Agency conducted an alternatives screening process to identify feasible alternatives to the proposed program. The screening process for identifying viable alternatives included consideration of the following criteria: • Ability to meet the program objectives [presumes meet objectives or not considered] • Ability to reduce significant environmental effects of the proposed program • Economic and engineering feasibility [presumes to meet economic feasibility parameters an criteria not presents] Introduction of "Lead Agency" at this point would imply some agencies other than LACoDPW, perhaps LACoFCD (??); while reference to an "alternative screening process" indicates some formal process rather than that documented in the PEIR. Discussion of environmental effects or water -related compliance of flow and quality for a Water Resources project or program without a quantified and presumably computerized complex model for each watershed element is totally inadequate and incomplete at any level. Introduction of "feasible" and economics without definitions and the objectives which 2/3 include costs and therefore economics strongly distorts any screening or comparisons toward costs, economics, and financial for which no information is provided or believed to be even remotely available for the PEIR, the EWMP, and most if not all of the EWMPs. Such inadequacies and incompleteness renders Sec.6 irrelevant to the CEQA process with regard to the project, any alternatives, and any designation as to an "Environmentally Superior Alternative" compared to an "economically superior alternative". LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 11, 2015 Submittal #2 CCSC 3.14-15/5 Water Supply Impact 3.14-3: The proposed program (=EWMP] could require new or expanded water supply resources or entitlements or require or result in the construction ... could cause significant environmental effects. Given the general purpose of the EWMP is to recharge groundwater in a urban -suburban context where groundwater is used for water supply, such "conditional -could" appears totally inappropriate and must be technically defined/determined in order to fully and adequately discussed environmental, cost-effectiveness, and compliance with discharge water quality limits over the life of the projects. 6-2/5 6.2 Review of Proposed Program Goals and Objectives The alternatives presented in this chapter were analyzed for their abilities to reduce significant program impacts and meet the objectives of the proposed program, which are: • To collaborate among agencies (Permittee jurisdictions) across the watershed to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the Municipal Separate Storm Sewer System (MS4) Permit. • To develop watershed -wide Enhanced Watershed Management Programs (EWMPs) that would, once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff in a cost- effective manner. • To reduce the impact of stormwater and non-stormwater on receiving water quality. Discussion starts with a title of Goals and Objectives then switches to objectives. These are goals not objectives as they are not quantified nor scheduled in any manner. Since two "objectives" refer to "cost-effectiveness" and no costs, revenues, economics, or financial information or assessment are not provided, all discussions of the achievements of goals and objectives becomes mute and the PEIR totally incomplete with regard to the "project or "program" and its alternatives. Similarly reference to collaboration becomes mute as all related agencies and those in the county have already collaborated and therefore any "collaboration" discussion must be quantified which they have not been. As to compliance with permit conditions and reduction of impacts are only presumed without documentation which is under parallel preparation for June 2015 and without any hydrological modeling or calculations to support such contentions and comparisons amongst alternatives. The entire Alternatives section is incomplete and totally inadequate. 6-3/4 The Lead Agency conducted an alternatives screening process to identify feasible alternatives to the proposed program. The screening process for identifying viable alternatives included consideration of the following criteria: • Ability to meet the program objectives [presumes meet objectives or not considered] • Ability to reduce significant environmental effects of the proposed program • Economic and engineering feasibility [presumes to meet economic feasibility parameters an criteria not presents] Introduction of "Lead Agency" at this point would imply some agencies other than LACoDPW, perhaps LACoFCD (??); while reference to an "alternative screening process" indicates some formal process rather than that documented in the PEIR. Discussion of environmental effects or water -related compliance of flow and quality for a Water Resources project or program without a quantified and presumably computerized complex model for each watershed element is totally inadequate and incomplete at any level. Introduction of "feasible" and economics without definitions and the objectives which 2/3 include costs and therefore economics strongly distorts any screening or comparisons toward costs, economics, and financial for which no information is provided or believed to be even remotely available for the PEIR, the EWMP, and most if not all of the EWMPs. Such inadequacies and incompleteness renders Sec.6 irrelevant to the CEQA process with regard to the project, any alternatives, and any designation as to an "Environmentally Superior Alternative" compared to an "economically superior alternative". LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 11, 2015 Submittal #2 CCSC Presumptions and unsupported statement are not with the goals of CEQA to provide a complete, adequate, objective, and quantified review and assessment of a program's or project's effects and appropriate mitigation and alternatives to such. 6-3/5 Based on these criteria, the Lead Agency has identified the following alternatives: Introduction of "Lead Agency" at this point would imply some agencies other than LACoDPW, perhaps LACoFCD (??); while reference to an "alternative screening process" indicates some formal process rather than that documented in the PEIR. Identifications are not supported in comparisons primarily with regard to collaboration and presumed economies of scale and cost-effectiveness. 6-9/9 Ability to Meet Program Objectives The Distributed Structural BMPs Only Program Alternative would meet the objectives of the proposed program to collaborate among agencies to promote more cost-effective and multibeneficial water quality improvement projects. However, because distributed structural BMPs tend to be smaller in nature and typically are distributed widely throughout the watershed, more BMPs may be necessary to meet water quality objectives in the MS4 Permit. The ability to meet 6-10/1 the water quality objectives would be less certain under this alternative. This statement indicates that distributed BMPs are cost-effective for the program although they of smaller (may disagreed based on economies of scale and information provided by LACiDWP). "Less certain" is not defined nor is the statement supported; 100 times more sites may be sufficient and available but no presumption can be supported either way based on the PEIR. 6-1213 6.6 Alternatives Suggested in Scoping ...comment letter... suggested that the PEIR include an assessment of several funding mechanism alternatives, including: Single Parcel Fee Assessment, Parcel Area Fee Assessment, Hybrid Parcel Area Fee Assessment, Zero Discharge Assessment, and Large Parcel Assessment. These suggested alternatives would not lessen any significant environmental impacts of the Program and were therefore not considered in this PEIR. Although CEQA allows for discussion of economic impacts and project costs as measures of feasibility, the funding mechanisms required to implement projects are generally not susceptible to environmental analysis. As the program objectives and criteria for alternatives both include economics and costs and as a BMPs require both capital and operation and maintenance costs to be effective, a full documentation using the above mentions financing package must be incorporated into the project description and alternatives, especially those presented to the LARWQCB in June 2015 Adequately funded projects within the ability to pay of the service population would assure continue environmental compliance and support of a wide array of mitigation measures compared to capital intensity project requiring longer term bonding and expensive project management. Comparisons of large projects with high capital costs to program of lots of small projects with low capital costs but with higher operating costs have been alluded to in discussions of other alternatives but without any documentation. As all publicly funded projects to be submitted to LARWQCB in June 2015 must be funded n have not been demonstrated at this time to be funded, any inclusion of projects in this program can not be assumed to have long-term funding to assure mitigation of impacts. 6-12/4 ... comment ... Full Capture and Recharge of Flows Greater than 100 cfs Alternative... rejected... because of the infeasibility of capturing all storm flows... unrealistic, requiring most of the developed land in the County to be accomplished... ...suggesting full capture of all flows less than 100 cfs... was rejected from further consideration for the same reason ... would require enormous areas of ... currently developed... recharge is only feasible in certai areas of the County because of the poor percolation capacity of surficial soils... accumulation of subsurface clay lenses creates recharge barriers in many places of the County, making retention and recharge of large quantities of stormwater infeasible in these locations. PEIR total lacks definitions for "feasibility" and "infeasiblity" as to technically, financially, administrative, or politically aspects. LACo EWMP COMMENTS These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Dr. Tom Williams March 11, 2015 Submittal #2 CCSC As no surface or subsurface hydrologic model is available or referenced, and supporting documentation is not provided nor apparently available for either flow capture alternative dismissal. The PER does not provide maps of locations with clay lenses and their extents/depths and tf barrier effects. 6-13/Table 6-2 Ability of Project Alternatives to Meet Project Objectives Project Objectives 1. To Collaborate Among Agencies (Permittee Jurisdictions) Across the Watershed To Promote more cost-effective and multi -beneficial water quality improvement projects To comply with the MS4 Permit. [=portions of Objective 2 & 3] 2. To develop watershed -wide EWMPs that will, once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff [= Objective 1.] in a cost-effective manner. 3. To reduce the impact of stormwater and nonstormwater on receiving water quality. [=Objective 1.] Comparisons of alternatives and "abilities" of Project GOALS and objectives without cost- effectiveness and any hydrological model for wet/storm and dry/storm water flows render all a totally inadequate and incomplete. As written, the objectives must be referred to as "Goals"; objectives must be measurable/monitorable with schedules and quantified levels of achievement, e.g., 4Qtr2016 and $100/ppm reduction. LACo EWMP COMMENTS 10 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Paige Anderson To: Laura Rocha Subject: RE: EWMP-PEIR Comments - Submittal 1 From: Tom Williams[mailto:ctwilliams20l2(a)vahoo.coml Sent: Monday, March 09, 2015 11:11 AM To: Gregg Begell Cc: Paul Ferraai; Esq. Todd T. Cardiff Subject: Re: EWMP-PEIR Comments - Submittal 1 SORRY cancel the last attachment 4 pages of notes... See this one ONLY Tom Comment Letter 20 FIRST DRAFT COMMENTS SUBMITTED MARCH 9, 2015. SUBSEQUENT DRAFTS 27 3 AND 4 (FINAL) WERE BASED ON THIS INITIAL FIRST DRAFT SUBMITTAL. THE FINAL SUBMITTAL WAS BRACKETED FOR RESPONSE. On Monday, March 9, 2015 11:01 AM, Tom Williams <ctwilliams2012na yahoo.com> wrote: See attached MSWord Final - Submittal 1/4 Disregard File Title Still in San Anotnio - wanted to submit 1/4 today Thanks for the schedule - still looking for the good stuff for final next week ... before I go to Bakersfield for week's training. Dr. Tom Williams 323-528-9682 CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 20 Dr. Tom Williams March 9, 2015 Submittal #1 CCSC March 9, 2015 TO: Gregg BeGell, P.E. County of Los Angeles Department of Public Works, Project Management Division II 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 gbegell@dpw.lacounty.gov FROM: Dr. Tom Williams, Sr. Techn. Advisor Citizens Coalition for A Safe Community Sierra Club, Angeles Chapter, Water Committee Subject: Enhanced Watershed Management Plan RE: Comments on Programmatic Draft EIR Specific Comments #1/4, 03/09-11-13-16/15. Following provides a brief review of the CEQA/P-DEIR (PEIR) documents of almost 70MB/1000 pages. We thank the LACo Department of Public Works and Flood Control District for this opportunity to review and comment on the PEIR and greatly appreciate the deadline extension for doing such. I will be submitting detailed comments during 03/09-03/16, and these overall comments on 03/09 & 16/15. Overall review is that the document(s) are inadequate, incomplete, inaccessibility for the general educate public due to the volume, technical character, overly -broad statements, lack of documentation and Support These of statements, and lack of consistency of terms and usage, comments are duplicative The proposed Program does not provide a plan for tiered project CEQA considerations by the other of permittees nor the County itself. No plan for the Program or the projects has been established for the comments Enhanced Watershed Management Plan to achieve and comply with the LA Regional Water Quality in the Final Control Board's permit requirements. A program may be more generalized but still must provide a plan of Subsubmittal. actions for both the lead and responsible agencies. responses 20-A The Program does not provide even the requirements, process, and procedures for subsequent CEQA through 20 - compliance by other permittees and some projection as to whether EIRs, MNDs, ND, or CE will be used tc ccccc. tier down from this P-DEIR/P-FEIR. Conditions for Program Compliance by tiered projects have not been listed or even referenced other than some ill-defined listing of BMPs. No current listing of all planned and funded Projects has been provided and incorporated into a scheduled and quantified plan for submission in June. Although research has been underway for five -plus years, the EWMP and this EIR does not use nor even reference use of computerized modeling of the appropriate basins (Ballona Creek, Upper LA River, Middle LA River and Arroyo Seco, Lower LA River and San Gabriel River, and LA River Mouth/Estuary- Dominguez Channel) although the federal agencies (BLM, USGS, ACoE, etc.) and perhaps local agencies (some permittees and the Water Board) have some local or watershed models . Without a model and its components, the impacts and their significance of detention, retention, recharge, and flood protection cannot be assessed nor mitigated adequately or completely. Three goals are provided but no objectives (sub -tiered from goals) are provided with/without defined schedules and other quantitative parameters for program monitoring. Confusion is introduced in later text when both flood control and water supply "augmentation" are also introduced as "goals" and as "objectives". Specific goals are only to meet the MS4 Permit requirements and related water quality conditions and to meet them in a "Cost -Effectiveness" manner. However, costs, financial support, revenue, capital bondir or economic effectiveness or efficiency are not provided, and thereby achievement of the cost effectiveness cannot be judged nor compared and must presumed by submission of any proposed proje LACo EWMP COMMENTS Review Comments EWMP Pgrm DEIR #1 Comment Letter 20 Growth inducement is mentioned primarily with regard to direct housing construction and employment incomes while dismissing potential effectts of recharged (diverted storm flows) water supplies. CCSC Additional benefits primarily for flood protection are mentioned in some statements while it is not supporte These by any text or analyses under water resources. No assessment of beneficial and adverse effects are comments provided for raising base flow levels from program-augmented/diverted-stormwater groundwater resourceE are and their effects upon subsequent pollutant concentrations and flood flows. duplicative Of I am retired from 30 years in water and environmental resources with Parson Corp., Pasadena and URS comments San Francisco and over 10 ears with Dubai UAE government and local water and environmental S the Final y ( ) g Submittal. companies. I have prepared sections and entire documents for more than 300 EIRs, EISs, and EAs See worldwide for local agencies, cities, counties, states, federal, and international agencies and organizations responses and have reviewed more than 100 additional assessments. During work for URS, I was involved in the 20-A development and environmental considerations for the 1970s EPA's Santa Ana and Santa Marguerita/San through 20 - Luis Rey basins plans. My reviews have included the LACity's Recycled Water Management Plan and ccccc. Stormwater Capture Management Plan, and I am currently vice chair of the LA City's Floodplain Management Plan. Dr. Tom Williams Dr. Tom Williams 3/17/2015 Comment Letter 20 Review Comments EWMP Pgrm DEIR #1 MAJOR ISSUES: LA Co Water Computer Model No model has been used or referenced Project Storm References are made to the Project Storm event of 85th -percentile for daily (24 hour) rainfall and estimated at 0.75 inches but no primary references or sources for the storm distributions are provided. Choice of this particular criterion is not described but may be related to the permit requirements without any further considerations or its appropriateness. Provide references and demonstration that the storm precipitation applies to the entire southern LACo or where it does apply. CCSC Increased Water Supply and Growth Inducements Many statements of the use of diverted stormwater and other waters for recharge is not carried through to the ultimate effects of such recharge on base flow (exfiltration) from shallow groundwater into channels or on the available safe yields for potable water supplies. The entire PEIR is incomplete and totally inadequate for the discussion of the volumes, recharge areas, and pumping areas and uses for increased local water supplies either as a means of substitution for imported with the same population or to assure adequate total supplies for increasing or re- distributed populations. Environmental Justice for Water Supply Sources Also as an environmental justice issue, the PEIR does not address the distribution of recharge areas for both local stormwater and treated recycled waters (also part of LACo and LACity plans and projects), compared to those areas receiving the higher water quality and lower total delivered costs of imported waters. As both areas would presumably pay the same water supply rates, they must get the same quality water (e.g., TDS, nitrates, metals, etc.), else wise an environmental justice issue appears to exist. Provide the expected water quality and any treatment related to recharged storm and treated wastewater and to imported water (e.g., northern San Fernando Valley Santa Clarita vs Torrance -Compton -Whittier. Public Health Retention, detention, and recharge facilities create good habitats for mosquitoes and other vector.' but the PEIR mention mosquito and other water related vectors four times. No discussion is presented regarding the public health issues for water- and water-logged soil related habitats for disease vectors, especially give the concerns regarding West Nile and Dengue Fever vectors. Having suffered malaria, the reviewer may be overly concerned but some assessment and mitigation measures must be included. As a long term operations and maintenance issue, ongoin revenue sources and appropriate O&M funding and activities are vital to any assessment of water related projects in a dense board urban environment. Fungi -Mold (Valley Fever) are/is would be expected to expand especially in those areas with high soil moisture and perhaps near surface mounded groundwater. Accumulations of metals and hydrocarbons may occur due to treatment by soil -based systems stabilization of metals in project basin soils and vegetation. Watershed health is mentioned but only as this health relates to the presence or removal of contaminants from the dry -/wet -weather runoffs. No discussion is presented regarding any stormwater-related diseases. Operations and Maintenance and Revenues Proposed facilities would be expected to have high manual maintenance. Coordination and compliance with scheduled maintenance must be incorporated into a thorough scheduled and quantified Mitigation Monitoring and Reporting Plan/Program for all facilities and operations. Dr. Tom Williams 3/17/2015 These comments are duplicative of comments in the Final Submittal. responses 20-A through 20- ccccc. Review Comments EWMP Pgrm DEIR #1 Comment Letter 20 CCSC Revenues and Stormwater Fees Sources of revenues are not provided to support capital construction and replacement, financing, and long term operations and maintenance. No provision is made for revenues based on per -parcel or per -area assessments and fees. No assignment and delineations are made for benefits and effects/risks to the public and land owners for water quality, flood control, or recharged water supplies. No comparisons are offered to compare abilities for overall or percentile economic groups to pay for both owners and residents. Revenues from Groundwater Production Groundwater resources will be increased but it is unknown as to the ownership of the recharged water and to the process of recovery of increased local groundwater resources beyond the immediate vicinity of the recharge areas. Flood Control, Protection, Diversion, and Other Related Issues Flood protection, control, and management are mentioned as a goal/objective of the program but without delineation and definition, and significance to other related concerns (e.g., Growth inducement) Effects of Increased Base Flow (levels and flows) No discussion (Two mentions of base flows in all 504 pages) is presented as to both the beneficial and detrimental effects of higher base flow volumes and levels resulting indirectly from rising/mounding groundwater resources downslope of stormwater and recycled water recharge basins/projects. Increased low flow volumes for pollution dilution of existing and other permitted discharges are nc considered. Increased low flow levels for increased total flood level and expanded flood area are not considered. Dr. Tom Williams 3/17/2015 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Review Comments EWMP Pgrm DEIR #1 Comment Letter 20 EWMP - SPECIFIC COMMENTS Comments, recommendations, and additions are presented in Bolded Italics PEIR text specific to the comments are presented in plain text as was in the PEIR. Some specifically relevant PEIR text may be Bold Underlined. CCSC Apdx. A, NOP, p.914 4.1.1 Regional Structural BMPs "Regional EWMP projects" are defined by the MS4 Permit as multi -benefit regional projects that, wherever feasible, retain all non-stormwater runoff and all stormwater runoff from the 85th percentile, 24-hour storm event for the contributing drainage area, while also achieving other benefits such as flood control and/or water supply. The PEIR states consistently that the project storm is the 85th percentile/24-hour/approximately 0.75inch (some up to 1 inch). However no documentation/derivation of the 24 hr storm analyses has been provided. The 24-hour storm event is not equal to a daily storm event (any 24 -hr vs a 12:01:01am-11:59:59pm) and can be quite different based on moving 24-hour totals and frequency compared to that for calendar day. Similarly the runoff from a 0.75inch rainfall would not be expected to be the same as the amount of rain falling on the ground (467gals11000sgft vs 0.9x467gais= say 420gais) but no provision is made regarding runoff coefficients.. The PEIR is inadequate with regard to the absence of documentation/analyses demonstrating the total distribution from say 50%-100% of 24hr storm event. Furthermore no assumed runoff coefficient(s) has been provided for estimating the likely detention capacities required. ES -315 The LACFCD has a vested interest in increasing opportunities for stormwater capture and groundwater recharge as a means of assisting local water supply augmentation. Direct reference to increased water supply without delineation as to where augmentation and local supplies may be augmented. Without removal of existing facilities in order to reduce existing water supply flow capacities, increased local sources can increase and must be considered as increased total water supply and appropriate assessment of growth inducement. Local augmentation, in general, would be at lower elevations than imported water supplies would serve due to the State Water Project and Colorado River Project source elevations of imported supplies and those of most probable recharge areas and down -flow groundwater wells. ServicE areas of recharged stormwater and recycled waters are generally of lower elevations and of different economic status from those at higher elevations and served by imported water supplies.. p.1-3/23 ... timeline ... in the MS4 Permit requires that Permittees submit the 12 EWMPs to the LARWQCB by June 28, 2015, in order to be in compliance with the permit conditions. Should have started earlier. Mid March - Late June, 105 days, is a very tight, aggressive schedule and should have been better scheduled and implemented. Public participation should not be sacrificed for untimely agency coordination. Some issues may be resolved through tiering anc MMRP in the Final PEIR. LACo EWMP vs 12 additional EWMPs in 90 days following LACo BOS approval and certification may be in jeopardy. 12 EWMPs are required and presumably requires local jurisdictions to have discretionary actions by city councils. Presumably the cities will reference the LACo EWMP-PEIR as CEQA compliance but must have the project specific and local BMP E/Rs/MNDs processed to be in compliance with this PEIR and CEQA. As stated herein this PEIR, the PEIR does not complete the CEQA compliance for the 12 EWMPs and their CEQA considerations. p.1-3/2 As a result, the LACFCD has prepared this Program Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsit and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the 12 EWMPs. Relationship and contents of the master PEIR and tiered EIRs/MNDs and other CEQA documents are not clearly provided. The statement and others promote confusion between the EWMP at Dr. Tom Williams 3/17/2015 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Comment Letter 20 Review Comments EWMP Pgrm DEIR #1 CCSC the EWMPs and between the PEIR and CEQA considerations for the 12 EWMPs to be tiered off T of the PEIR and documented separately. p.1-3/2 The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior to submittal of the EWMPs. The EWMPs will be submitted by each EWMP group to the LARWQCB. Discretionary actions by the BOS do not substitute for the discretionary actions by the 12 jurisdictions of the "EWMP Groups" (cities) to approve the 12 local EWMPs and their incorporate BMP projects. What is an "EWMP Group"? Presumably one or more cities who will agree on an EWMP and vote I approve the EWMP before submission the the LARWCBrd. CEQA requires environmental considerations other than referencing this PEIR for the 12 local EWMPs. p.1-3/3 This PEIR describes and evaluates each of the EWMPs being prepared by the Permittees collectively. This statement suggests that this PEIR covers all EWMPs prepared by an "EWMP Groups" and the they have been prepared and incorporated herein. No documentation is provided as to whethe cities approved and authorized any local EWMP and its inclusion herein. Presumably one or more cities who will agree on an EWMP and vote to approve the EWMP before submission the the LACo for inclusion in the PEIR and submission to the LARWCBrd. CEQA requires environmental considerations of the local discretionary actions other than referencing this PEIR for the 12 local EWMPs. p.1-3/3 The discretionary action prompting the need for CEQA compliance is the submittal of the completed EWMPs to the LARWQCB. Submission is not a discretionary action but a ministerial action on the part of a department following the discretionary action of a Board of Supervisors, city council, or other public elected body to approve the local EWMP and its shcedule and funding. p.1-3/3 A few of the BMPs [=Projects] are currently well defined but most are yet to be fully developed under the 12 local EWMPs. A set of priority BMPs (=Projects] will be detailed in each of the EWMPs; these are being developed in parallel with the PEIR. The PEIR describes the details that are available for each of the 12 local EWMPs currently under preparation by the EWMP working groups. Confused and demonstrates that this PEIR may be incorporating projects, BMPs (if different), somE portions of the other 12 EWMPs, and the LACo EWMP which has not been approved by the LACo BOS. Is it EWMP group, EWMP Working Group, or Permittees? Are they the same or different? Have any been approved and funded by a council in a discretionary action? Clarification is needed. p.1-4/par.3 The EWMPs...discussion of the environmental documents, assessments, and permitting required for the implementation of the priority projects. The PEIR can provide a basis for this discussion... PEIR in the development and implementation of the EWMPs is further discussed in this chapter in the Purpose of the Program Environmental Impact Report. A "priority project(s)" are not defined and therefore the statement is rendered meaningless. Throughout the referenced section 1.3 (p.1-9 - 1-10), statements are made as to "can" rather "shall and thereby the PEIR does not establish a procedure for the tiered environmental documents shall assess their environmental impacts and provide mitigation. The PEIR must provide a procedural context for most if not all elements for the Project EIR/MND b, the local agencies as the LA Co shall be a responsible if not a lead agency for each Project. As provided the PEIR is incomplete and inadequate for establishing an expected or required procedure and process for preparation of a project specific CEQA document. 1-5/3 Watershed Management Programs The MS4 Permit Section VI.0 (page 47) includes provisions that allow Permittees to voluntarily choose to implement a Watershed Management Program (WMP). The purpose of this program is to "allow Permittees the flexibility to develop Watershed Management Programs to implement the requirements of [the] Order on a watershed scale through customized Dr. Tom Williams 3/17/2015 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Review Comments EWMP Pgrm DER #1 Comment Letter 20 CCSC strategies, control measures, and BMPs." The permit states that "participation in a Watershed Management Program is voluntary and allows a Permittee to address the highest watershed priorities." CEQA is not voluntary and the "Program" must provide the structure for the tiered CEQA process to operate and satisfy CEQA for each project or tiered PEIR. The permittee is not the department but the City or County. Provide a listing of all councils which have approved development and submission of an EWMP to the Regional Board. As a program, provide all documentation as to whether the subsidiary agencies have committed to the Watershed program or whether they have voluntarily chosen not to participate. No priorities are provided - references are made to conservation priorities, pollutant priorities, renewable priorities water quality priorities, and watershed priorities (and highest watershed pr...), but only some water quality priorities are discussed. 1-9/3 Purpose of the Program Environmental Impact Report The LACFCD determined that implementation of the 12 EWMPs could have a significant effect on the environment and therefore req preparation of a PEIR...- to provide... information about... significant environmental effects of the proposed program, to identify possible ways to minimize potentially significant effects [Mitigation measures], and to describe and evaluate feasible alternatives to the proposed program [Alternatives]. Use of EWMP, EWMPs, and Program cause confusion as to what is what and what will be presf in each. 1-9/4 This document has been prepared as a PEIR ... one type of environmental review document that may be used to evaluate a plan or program that has multiple components (projects and actions) or to address a series of actions that are related in any of the following ways: Geographically. As logical parts in the chain of contemplated actions. • ...issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program. • As individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental effects that can be mitigated in similar ways. No logical chain has been graphically depicted/modeled and arranged to demonstrate and monitor progress to and through the permit and compliance process for such a wide variety and mammoth scale of the projects and their components (e.g., diversion -transmission -spreading - recharging -production). 1-11/2 Scoping Period ...A Notice of Preparation (NOP) ... was circulated to ... other interested parties ...discussed the purpose of the EWMPs and their management strategies, identified the EWMP Study Areas, and provided a brief and preliminary list of environmental issue areas that could be impacted. As indicated in Scoping Comments, the PEIR does not reflect comments provided during the Scoping period and for the Initial Study and Notice. -Socio-economics and revenue sources to assure operations and maintenance, - Environmental justice - Water models or Other Quantitative Estimates/Flowcharts 1-18/2 Chapter 1.0, Introduction. This chapter discusses... the background and purpose of the PEIR f the proposed program. The PEIR does not provide the objective, full disclosure, complete, and adequate purposes of the EWMP, and therefore the purposes of the PEIR cannot be satisfied. HYDROLOGICAL MODEL References to Hydrological Model Apdx A NOP 8/5 In accordance with the provisions of the MS4 permit, the work plans describe the following steps to EWMP development: 2. Characterization of existing and potential control measures within the watershed 3. Addressing the approach to incorporate reasonable assurance analysis (RAA) in the optimization of watershed control measures Dr. Tom Williams 3/17/2015 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Review Comments Comment Letter 20 EWMP Pgrm DEIR #1 CCSC 1-8/1 Reasonable Assurance Analysis ...(RAA) is ... to demonstrate "that the activities and control measures will achieve applicable water -quality -based effluent limitations and/or RWLs with compliance deadlines ........ as a quantitative demonstration that control measures (such as BMPs) will be effective, the RAA also provides an opportunity to use a modeling process to identify and prioritize potential control measures. The RAA for each EWMP uses a model to simulate a critical storm (design storm) and ... achieve compliance with the TMDLs and water -quality -based effluent limitations. As indicated in the PEIR text and appendices, the PEIR lacks any quantified Hydrologic Model for watershed controls and has focused the only "modeling" on meeting the water quality requirements of the MS4 at discharges, not watershed controls. 3.2 Air Resources and 3.6 GHGs These sections reference many air -related models and modeled/modeling results. Apdx A. Comment Letter to the LACFCD: Draft PEIR p.16/I1tem 56: Foothill Municipal Water District Recycled Water Project ... Cal Poly Pomona has partnered with FMWD and is developing a model that will also capture stormwater for recharge using the same infiltration galleries. pdf-254 Comments - Model ...no cost/benefit analysis or any modeling completed to substantiate the "cost-effectiveness" of these methods. Please identify any additional documentation supporting this claim. Enrique Huerta Downey, CA ehuerta28@gmail.com Scoping Comment Letter indicated that minor agencies/permittees may have conducted some forn of hydrological model but not the EWMP or the PEIR. Issue -Water Supply p.2-1/par.3 This Project Description describes types of BMPs ... to illustrate the function, type of construction, and general locations of the BMP types for the purpose of the environmental assessment of the BMP types identified in the EWMPs. As indicated elsewhere, the local conditions govern where the optimal locations for BMP would be and general assessments cease to be appropirate for CEQA compliance unless the forms and procedures are provided to reflect the local assessment in the project E/Rs/MNDs. 2-22/1 Infiltration BMPs. Infiltration facilities are designed to decrease runoff volume through groundwater recharge and improve water quality through filtration and sorption. No discussion of beneficial effects is provided for rising base flow providing greater dilution volumes assuming that discharges remain constant, or providing higher water levels when stormwater arrives at downstream locations and thereby elevating the flood water levels and inundation extent. 2-41/7 This watershed is further differentiated by the importance of groundwater recharge basins that are supplied by a series of reservoirs further upstream... No information is provided regarding the basins, total projected annual recharge flows, and relationships between "reservoirs" and "recharge basins" presumably the augmented groundwater storage basins, rather than basins used for recharge. 2-42/4 ...BMP strategy in the Upper Los Angeles River watershed includes well over a hundred pi regional and centralized retention and infiltration BMPs that take advantage of the favorable groundwater recharge characteristics.... No definition of BMPs has been applied to the projects proposed. No map or other descriptive information of the 100+ retention/infiltration BMPs have not been provided. No comparison or prioritization or even definition of favorability or recharge characterization have been provided. ES -3/3 ES.3 Project Objectives The primary goals and objectives of the EWMPs are: Dr. Tom Williams 3/17/2015 These comments are duplicative Of comments in the Final Submittal. See responses 20-A through 20- CCCCc. Review Comments EWMP Pgrm DEIR #1 Comment Letter 20 CCSC • To collaborate among agencies... to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the MS4 Permit. • To develop watershed -wide EWMPs that will... remove or reduce pollutants from dry- and wet - weather urban runoff in a cost-effective manner. • To reduce the impact of stormwater and non-stormwater on receiving water quality. Elsewhere goals and objectives are mentioned and then supposed objectives are provided. Here these are largely "goals" as they have no specification of schedule or quantification. As these are stated as "primary" with no mention of secondary or tertiary goals or objectives, the entire EWMP is without adequate or complete goals and objectives and various statement totally confuse the basis for the "project" and related " alternatives" and their compparisons and assessments. Report is unclear as to definition and has inconsistent usage of Goals and Objectives of the Program. These are Goals only, while objectives must have specifics as to schedule and quantitative indicators of compliance (e.g., acre-feet/year recharged, return rate changes by 2020, etc. 2-2/2 2.2 Project Goals awd-Objccii as Therip mare goals and objectives of the EWMPs are: • To collaborate among agencies (Permittee jurisdictions) ... to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the MS4 Permit. • To develop watershed -wide EWMPs ... remove or reduce pollutants from dry- and wet -weather urban runoff in a cost-effective manner. • To reduce the impact of stormwater and non-stormwater on receiving water quality. [#2 and #3 are virtually identical and only differ by the "terms" used: Wet vs Dry Weather Flow vs Stormwater and Non-Stormwater, which would be defined the same] [In #1 and #2, references are made to cost-effectiveness although never discussed and compared.] Reference to costs requires a description, assessment of impacts, and provisions for the life of the project - at least 25 years. Most importantly are provisions sufficient annual funding for operations and maintenance of all facilities through and beyond 2040. Assessment must include best -available information and projections economic, financial, bonding, costs (both capital and O&M), and ability to pay by the service populations. This is particularly important as the LACo and associated cities are promoting changes of "Storm Water Fees on the LACo annual property taxes and fees. This deficiency and conflict clearly indicate that the entire PE/R is incomplete and inadequate with regard to costs and other related issues for the proposed program. Table 2-3 Project Feature - Flood Protection No description of flood protection is developed for the EWMP and thereby must not be included, mentioned, without development and assessment of benefits and impacts. No coordination/collaboration has been referenced or known in the LACity Floodplain Managem Plan. 2-26\3 Creek/River/Floodplain/Estuary Restoration. This category includes multi -benefit projects the typically combine elements of habitat new ... restoration... BMPs would augment the as flood management and water quality improvemer Project components such as ... setback levees, floodplain bench excavation, levee breaches, and other actions can increase... flood storage capacity... ...This project restored 1.2 miles of natural bottomed creek habitats, which are capable of infiltrating up to 118... million gallons of stormwater from the wash into the local groundwater aquifer. Plants in the wash also aid the bioaeochemical removal of D011utants such as nitroaen. Actually bacteria and fungi attached to the cellousic stems and leaves that are periodically submerged. Few emergent plants can absorb or treat any aqueous pollutants. More to come 5-3/1 The proposed program is not a land use project and its implementation would not introduce new ... or any other growth -inducing land uses. The structural BMPs would augment the physical structure Dr. Tom Williams 3/17/2015 These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Review Comments Comment Letter 20 EWMP Pgrm DEIR #1 CCSC of established communities .... and enhancing the water quality of existing communities. As a result, the proposed program would not induce population growth. Most infrastructure projects do not involve much in the way of direct structured development; however, operations of such facilities support development of user structures especially m water and other service may be constraining support factors. 5-3/2 The nature of the proposed program is to increase stormwater recharge and improve stormv quality;... would not result in increased economic activity or population growth in the EWMP areas ... water recharged... is anticipated to support existing water supply needs and reduce dependence on imported water supplies. Mechanisms or rules are NOT provided as to how various project waters would be assigned to reducing imported water dependence while others may be used for supporting growth. 5-3/3 5.4 Secondary Effects of Growth Implementation ... would not result in a direct or indirect increase in population or employment. The proposed program itself, therefore, is not growth -inducing and would not induce secondary effects of growth. Such a broad reaching statement cannot be justified as implementation (?=construction) and presumed operations (say 10% of total capital costs annually) would generate new employmen within the project area and would divert funds for imported water sources outside the project area to the more local based water sources and operators employed therein. 5-3/3 While one of the main goals of the EWMPs is to increase infiltration and potentially increase recharge of stormwater... the amount of water potentially recharged would not be enough to These indirectly support population growth and is intended to support existing water supply needs. This comments potential additional recharge would contribute to local water supply needs but would not alter are duplicative population demographics. Therefore, there would be no secondary effects of growth. of Mechanisms or rules are NOT provided as to how various project waters would be assigned to onl comments reducing imported water dependence while others may be used for supporting growth. in the Final Again, such a statement cannot be justified as local sources can easily augment existing or future submittal. distribution without specific assignment to service areas. See responses 20-A 6-1/1 ...Environmental Impact Report (EIR) must describe... through 20 - reasonable range of alternatives to a proposed project... ccccc. could feasibly attain most of the basic project objectives... would avoid or substantially lessen... proposed project's significant environmental effects. 6-2/2 Alternatives may be eliminated... if they fail to meet most of the project objectives, are infeasible, or do not avoid any significant environmental effects. "Feasibly" is not clearly defined nor established as to whether the BMPs, EWMPs, or this EWMP can be done in technical and practical (=ECONOMIC) terms as required by the objectives and criteria for the program, the local programs/projects and BMPs. As technical feasibility is not a issue, the actual meaning of feasibly must relate to two of three goals having phrases of "cost- effectiveness". Therefore this use of feasibly and project objectives (not objectives but goal) are the costs and presumably capital and operations/maintenance. As no information is provided for costs and their fundings, these statements become totally inadequate and incomplete as no information is provided nor compared to demonstrate the alternatives compliance or lack of compliance with the MS4 permit conditions.. As two expressed "objectives" out of three include reference to "cost-effectiveness" the absence of demonstrated "cost-effectiveness" renders any comparison incomplete and inadequate for justifying an alternative discussion. The two objectives have no quantification nor scheduling and therefore are NOT OBJECTIVES but may remain as goals but without any supporting information as to costs and sources of revenues to support such costs. 6-2/5 6.2 Review of Proposed Program Goals and Objectives Dr. Tom Williams 3/17/2015 10 Review Comments Comment Letter 20 EWMP Pgrm DER #1 CCSC The alternatives presented in this chapter were analyzed for their abilities to reduce significant program impacts and meet the objectives of the proposed program, which are: To collaborate among agencies (Permittee jurisdictions) across the watershed to promote... 6-2/5 The alternatives presented... analyzed for their abilities to reduce significant program impacts and meet the objectives of the proposed program,...: • To collaborate among agencies (Permittee jurisdictions)... promote more cost-effective... multi -beneficial water quality improvement projects... comply with the Municipal Separate Storm Sewer System (MS4) Permit. • To develop watershed -wide Enhanced Watershed Management Programs (EWMPs)... once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff cost-effective manner. • To reduce the impact of stormwater and non-stormwater on receiving water quality. Goals are not mentioned only objectives above. The entire PEIR appears incomplete without a clear statement as to typical goals and objectives - recharge dry and wet weather runoff and 20% recharge every five years for next 25 years. Total confusion as to goals and objectives renders the entire alternatives chapter totally inadequate. Absence of any costs/revenue information renders achievement of goals or objectives totally incomplete for both the development of the alternatives and their comparisons. 6-3/3 In accordance with the CEQA "rule of reason," an EIR is required to consider a range of alternative that permit a reasoned choice and that are "limited to ones that would avoid or substantially lessen any c the significant effects of the project' (CEQA Guidelines Section 5126.6(f)). The Lead Agency conducted a alternatives screening process to identify feasible alternatives to the proposed program. The screening process for identifying viable alternatives included consideration of the following criteria: • Ability to meet the program objectives • Ability to reduce significant environmental effects of the proposed program • Economic and engineering feasibility Since the program objectives require 2 of 3 items of "cost-effectiveness" and here a criterion requires meeting the program objectives, the PEIR appears inadequate and incomplete withou the presence of and achievement of cost-effectiveness and economic feasibility -ability to pay for both vapital and O&M costs for at least 25 years. As no economic feasibility analyses and comparisons are provided, and no jurisdictional funding provided throughout the PEIR, no reasoned or reasonable achievements of one of three criteri can be assessed or compared. 6-1/3 "Feasible" means capable of being accomplished in a successful manner within a reasonable peri of time, taking into account economic, environmental, legal, social, and technological factors. No economic factors have been provided in the PEIR, including sources of revenues and abilities for LACo and all permittees. Therefore, the PEIR is incomplete and inadequate. 6-13/1 6.7 Environmentally Superior Alternative CEQA requires that an EIR identify the environmentally superior alternative(s) of a project other than the proposed program or the "no project' alternative (CEQA Guidelines Section 15126.6 (e)(2)). As stated at the beginning of this chapter, the purpose of this alternatives analysis is to consider a reasonable range of alternatives that could feasibly attain most of the basic project objectives and avoid or substantially lessen significant program impacts. Since no information is provided as to the actual cost-effectiveness of any projects or groups of project the requirement cannot be achieved, reviewed, or commented on with the currently available information. Based on DWP information distributed small projects could achieve the economy -of -scale that larger one could and therefore any plot -by -plot LID projects. If 10,000 single family dwellings would theoretically detain 460ga/11000sf roof, one design storm would generate 4.614 gal for direct use (about one day piped water supply); however, cities do not require 460gal of rain barrels but generally only require two rain barrels of 100ga1 capacity. These comments are duplicative of comments in the Final Submittal. See responses 20-A through 20- ccccc. Dr. Tom Williams 3/17/2015 11 Review Comments Comment Letter 20 EWMP Pgrm DEIR #1 CCSC The PEIR does not provide the basis for development of the Environmentally Superior Stormwater Alternative and those with recognized "least worst" environmental effect could not meet two of the three goals of the Program, cost effectiveness with or without real requirements for the 85%ile rainfall event. 6-14/3 The Non -Structural BMPs Only Alternative would avoid all of the significant and unavoidable impacts associated with construction of the structural BMPs.... However, since the ability to achieve compliance with MS4 Permit water quality objectives would be substantially reduced, impacts to water quality would be greater under this alternative, and compliance with the MS4 Permit would be unlikely. Even if it could achieve permit compliance, the Program goals of cost-effectiveness most likely could not be achieved as the disperse detention could not attain any significant economies of scale and would require vastly greater plot -by -plot compliance which is beyond the typical new additions, or replacement linkages with structured improvements. 6-14/4 As a result, since the proposed alternative would provide the best chance of achieving regional water quality objectives, it is considered the environmentally superior alternative. The conclusion is not based on any documentation or projected/estimate successful implementation and does not include any comparisons and development of cost-effectiveness These or revenue sources for a much larger implementation phase. The preparers have assumed a comments development condition without any concept of reality and without documentation as to are implementability in order to have an "Environmentally Superior Alternative", which is duplicative incomplete and inadequate. of comments in the Final Apdx A Appendix A Comment Letter to the LACFCD: Draft PEIR 18/#61(pdf-p.244) The overarching goa Submittal. of the GRIP Recycled Water Project is to offset the current use of imported water by providing up to See 21,000 acre-feet per year (AFY) of recycled water as a reliable supply source for groundwater basin responses replenishment via the Montebello Forebay within a reasonable timeframe. 20-A through 20- A/though the watershed channel are well known and studies for almost 100 years, no hydrologic ccccc. model has been developed and incorporated into the EWMP or its component EWMPs. The current efforts therefore cannot provide a factual and quantitative basis for assessing the environmental effects of existing water resources and their future states for water supply availability and locations, flood control, and water chemistry dilutions or reductions. ApdxA/NOP 2/2 The LACFCD, as a regional agency charged with conservinq stormwater for use in our local water supply, has a vested interest in increasing opportunities for stormwater capture an groundwater recharge. The LACFCD has flood control infrastructure ... LACFCD will be an implementing agency only on those projects for which it has been identified in an EWMP as a responsible implementing party. Apdx A Appendix A Comment Letter to the LACFCD: Draft PEIR 18/#61(pdf-p.244) The overarching goal of the GRIP Recycled Water Project is to offset the current use of imported water bV providingu to 21,000 acre-feet per year (AFY) of recycled water as a reliable supply source for groundwater basin replenishment via the Montebello Forebay within a reasonable timeframe. Although the watershed channel are well known and studies for almost 100 years, no hydrologic model has been developed and incorporated into the EWMP or its component EWMPs. The current efforts therefore cannot provide a factual and quantitative basis for assessing the environmental effects of existing water resources and their future states for water supply availability and locations, flood control, and water chemistry dilutions or reductions. As indicated elsewhere, this NOP and letter statements clearly indicate the anticipated development of water supply resources which goes beyond the water quality and flood protection benefits and relates the EWMP to growth inducements for future populations needs for greater water resources without adding new imported water supply facilities. ApdxF 7/2 The Los Angeles River is approximately 55 miles long, and five of six reaches lie within the Upper Los Angeles River EWMP Area. The natural hydrology of the Los Angeles River watershed has been significantly altered by urbanization, channelization, and the construction of dams and flood control Dr. Tom Williams 3/17/2015 12 Comment Letter 20 Review Comments EWMP Pgrm DEIR #1 CCSC These reservoirs. The river and many of its tributaries are lined with concrete for most or all of their length. Soft- comments bottom segments of the river occur where groundwater upwelling prevents armoring of the river bottom. are Although the watershed channel are well known and studies for almost 100 years, no hydrologic duplicative model has been developed and incorporated into the EWMP or its component EWMPs. The of current efforts therefore cannot provide a factual and quantitative basis for assessing the comments in the Final environmental effects of existing water resources and their future states for water supply Submittal. availability and locations, flood control, and water chemistry dilutions or reductions. See responses 20-A through 20- ccccc. Dr. Tom Williams 3/17/2015 13 to Comments Response to Comment Letter 20 (Sierra Club, Angeles Chapter, Water Committee — March 16, 2015) Response to Comment 20-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The Upper LA River Brandon Street and Green Street Improvements Project is under construction as noted on page 2-18. Approximately 1,800 feet of biorentention planter boxes (bioswales) will be constructed throughout the project limits. In addition, an underground infiltration basin system will be installed at the cul-de-sac of Green Street with 5,800 cubic feet of infiltration capacity. Trees and drought -tolerant plants will also be added throughout the project. As an advanced planning document, the PEIR does not provide substantial detail for any individual project. Section 2.4 of the PEIR defines categories of projects that may be incorporated into the EWMPs to achieve regional water quality objectives. Tables 2-3, 2-4, and 2-5 list some of the projects that have been planned or already installed in the region that will assist in achieving the receiving water quality objectives, including the Brandon Street project. This information on Upper LA River Brandon Street and Green Street Improvements Project was taken from the Notice of Intent to prepare a EWMP by the Upper Los Angeles River Watershed Group. Response to Comment 20-B: Tables 2-3, 2-4, and 2-5 list some of the projects that have been planned or already installed in the region that will assist in achieving the receiving water quality objectives, including the Upper San Gabriel River Avocado Heights Multiuse Trail Project, which has already undergone environmental analysis and been approved for implementation. As a result, details of certain projects may already be known. The projects presented in Chapter 2 include some projects that are already approved and under construction or recently constructed. Approximately 2,300 feet of the multiuse trail on 5th Avenue will be constructed with decomposed granite to provide 14,000 cubic feet of infiltration capacity. In addition, an infiltration swale will be constructed at the end of 5th Avenue immediately adjacent to San Jose Creek to provide 3,200 cubic feet of capacity. Combined together, up to 115 acre-feet of groundwater will be recharged annually. This information was obtained from the Avocado Heights Multiuse Trail Fact Sheet, located in Appendix E of the Notice of Intent for the Enhanced Watershed Management Program and Coordinated Integrated Monitoring Program. However, several of the projects listed in Chapter 2 have not been fully defined and have not undergone environmental review and additional details are not yet known. a County Flood Control District 11-251 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Comment 20-C: The Tujunga Wash Greenway project was mentioned on page 2-27 of the PEIR as an example of a multi -benefit flood management project that has already been approved and implemented, providing water conservation, water quality protection, flood control, recreational, and aesthetic benefit. The Tujunga Wash Greenway project involved the creation of a naturalized streamcourse designed to accept low flows diverted from the Tujunga Wash (LADPW, 2015). This project was identified only to give an idea of what other multi -benefit EWMP projects may look like once identified fully in the EWMP. As noted in Section 1, each individual project that has not yet been approved will undergo subsequent CEQA determination by the lead implementing agency prior to installation. Response to Comment 20-1): Flood control is defined as "the act or technique of controlling river flow with dams, dikes, artificial channels, etc., so as to minimize the occurrence of floods" (Dictionary.com, 2015). Floodplain management is defined by FEMA as "the operation of a community program of preventive and corrective measures to reduce the risk of current and future flooding, resulting in a more resilient community" (FEMA, 2015). Floodplain management considers all efforts to mitigate the effects of flooding including efforts on private property. Flood Control is one of many components of floodplain management in order to reduce the risk of flooding. Both terms generally refer to the avoidance of damages from flood events through physical structures or specific management measures. The PEIR generally uses these terms interchangeably. Flood control benefits are realized when BMPs retain local storm flows, however small in volume, that help to buffer peak flows downstream. The supporting information or analyses for quantification of levels of management/control in addition to other beneficial sectors, e.g., groundwater sourcing for suburban and urban water supplies would be assessed at the individual project level. Management of groundwater as a drinking water source for urban and suburban consumers would continue to be the responsibility of the local groundwater management agencies subject to adjudicated water rights. Response to Comment 20-E: Centralized BMPs are a type of structural BMP that treats runoff from a 10 acres or more tributary area, typically. The priority projects can be a centralized BMP that will be included as a project that will be immediately pursued in each EWMP. The potential projects can be a centralized BMP that may be pursued at a future date. The EWMPs are currently being prepared; the priority and potential projects listed in the PEIR are in various stages of planning and development. Page 2-28 of the PEIR notes that information for specific projects is provided in the document in cases where it is available at the time of publication of the Draft PEIR. As an advanced planning document, the PEIR does not provide substantial detail for any individual project. Individual projects requiring subsequent CEQA analyses would be determined by the lead implementing agency prior to installation. LA County Flood Control District 11-252 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Comment 20-F: The water quality objectives identified in EWMP areas provide the basis for the selection and scheduling of BMPs (or projects). The priority BMPs have undergone a site review and project evaluation that has identified them as having a greater opportunity to achieve the water quality objectives for their specific EWMP area. These priority BMPs were listed based upon available data at the time of publication of this PEIR. Appendix G provides the location and general description of the priority BMPs. These priority projects will be further developed with conceptual plans in the draft EWMPs. The term planned centralized projects is used to reflect project opportunities where it may not be feasible to construct a BMP to retain the 85`h percentile storm but would have a substantial water quality benefit for a larger watershed. The term potential means that a concept will not be developed in the draft EWMP but the site will be identified as a potential project site for the future. Planned project is used to reflect projects that are already being planned to be constructed in the near future. They would not be a priority or potential project. These planned projects were part of the "30 month project" identified in each EWMP's Notice of Intent that was approved by the Regional Board. Table 2-4 includes a column that notes the status of the project as complete or planned to be installed and provides an approximate date of completion where available. Response to Comment 20-G: The requirement to fully capture the 85`h percentile storm in a regional BMP is a Permit requirement. Providing the hydrology calculations (design volume, runoff coefficients, time of concentrations) is beyond the scope of the PEIR, as it is an advanced planning document. The PEIR evaluates typical project types to assess potential impacts of implementing the entire program throughout the region over a long period of time. More information about these projects can be obtained from the individual implementing agencies. Response to Comment 20-H: As stated on page 3.8-23 of the PEIR, the EWMP areas overlie various groundwater basins; these groundwater basins are summarized in Table 3.8-2. Each groundwater basin contains multiple recharge areas. Providing the specific recharge area locations and recharge capacities for all groundwater basins receiving infiltration from the EWMP areas is beyond the scope of the PEIR, as it is an advanced planning document. Therefore, a priority assessment based on this recharge and capacity information will need to be considered on an individual project basis. As noted in Section 2.4.2, the EWMPs include infiltration projects that are installed where the soils and groundwater capacity are favorable. The PEIR acknowledges that depth to groundwater and infiltration capacity are important factors for locating effective infiltration BMPs. Mitigation Measures GEO-1 and HYDRO -1 require that implementing agencies evaluate site suitability prior to installation and would reduce potentially significant impacts to less than significant levels. a County Flood Control District 11-253 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Comment 20-I: The PEIR discusses potential impacts to public health in Impact 3.7-2. The PEIR acknowledges that accumulation of contaminants in BMPs over time could result in hazardous conditions. Mitigation Measure HAZ-1 is included to ensure that maintenance plans are prepared and implemented to reduce the risk to public health. BMPs may detain water that stagnates or generates odors. Mitigation Measure AIR -4 requires implementing agencies to consider odor controls to reduce impacts to the public. Other vectors such as mosquitos and rodents could be attracted to standing water. Local vector control agencies would employ measures to reduce public health impacts from areas of standing water in cooperation with the LACFCD as a standard practice. In response to the comment, Mitigation Measure HAZ-1 has been modified to ensure that vector control plans are incorporated into BMP maintenance plans. Both mitigation measures AIR -4 and HAZ-1 would reduce potentially significant impacts to less than significant levels. Mitigation Measure HAZ-1 has been updated as follows: HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The Maintenance Plan shall include vector control requirements. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. This modification has been included in Chapter 12, Clarifications and Modifications of the Final PEIR. The potential impact to public health is noted on page 3.7-16 of the Draft EIR. The modification clarifies that vectors are public health hazards that need to be considered along with other hazards. The modification does not identify any new significant impact or trigger the need to recirculate the Draft PEIR under Section 15088.5 of the CEQA Guidelines. Response to Comment 20-J: The addition of rain barrels as potentially effective distributed BMPs is noted in on page 2-14. Table 3.1-1 notes which mitigation measures would apply to rain barrel installation. The quantified impact to downstream hydrology from installing individual rain barrels would depend on the location, watershed, and rate of LID implementation. This information will be addressed LA County Flood Control District 11-254 ESA / 140494 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments in the applicable environmental analysis applicable to the individual BMPs once details are available. Response to Comment 20-K: The Low Impact Development (LID) standards included in the City of Los Angeles LID Manual are a part of the overall storm water quality improvement framework being developed within the EWMPs. Schedules for LID implementation will depend on redevelopment rates and will vary by watershed area; however, the EWMPs will include implementation schedules as required in the Permit. Also see response to Comment 20-J. Response to Comment 20-L: The term "high density" was used to reflect an urbanized area. The terms "large" and "small" in reference to BMPs were used to describe the expected amount of area and/or footprint of the BMPs. In the PEIR, BMP types are defined on page 2-6. Distributed Structural BMPs, treat runoff close to the source and are typically implemented at a single- or few -parcel level (e.g., facilities typically serving a contributing area less than one acre). Centralized Structural BMPs treat runoff from a contributing area of multiple parcels (e.g., facilities typically serving a contributing area on the order of tens or hundreds of acres or larger). However, additional quantification information specific to each type of BMP (distributed and centralized) was provided under the headings, Anticipated Construction Activities. For example, page 2-8 identifies, ground disturbance for distributed detention is typically less than 1 to 2 acres in extent, but may extend in some limited applications up to 5 acres where space is available. And on page 2-23, centralized infiltration facilities are generally larger than distributed BMPs and can vary from 2 to 10 acres in size, depending on the number of parcels (drainage area). The sizing of BMPs typically refers to designing BMPs to capture, store, and/or infiltrate a specific volume of water, and is based on a variety of factors including the adjacent topography, storm event type, base flow, etc. These details will be known on a project -specific basis, and therefore could not be provided at this level of analysis. Response to Comment 20-M: In addition to the discussions on pages 3.8-20 and 3.8-21 of the PEIR mentioned by the commenter, in regard to growth inducement, the PEIR acknowledges that increased stormwater recharge will augment groundwater supplies. The overall recharge volume will vary from basin to basin and from season to season and will increase over time as more BMPs are installed. This additional benefit of the EWMPs is consistent with the goals and plans of the regional groundwater basin managers and water suppliers as described in Section 3.14-1. Water retailers in Los Angeles County generally have two water sources available to them: imported water supplied by a water wholesaler (e.g., Metropolitan, Castaic Lake Water Agency) or groundwater. The two large groundwater basins in Los Angeles County are adjudicated, with established water rights made available to pumpers. The pumpers' allocations are constricted to prevent over -drafting the aquifer. The groundwater managers (Water Replenishment District of Southern California, Upper a County Flood Control District 11-255 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Los Angeles River Area Water Master) augment the groundwater basins with imported surface water when available to meet demands. Population growth is expected in the region and the local water suppliers have prepared urban water management plans that explain how they intend to meet the growing demand. The current conditions throughout the State of California indicate that imported water supplies will be more limited in the future than they have been historically. Emphasis is being placed on local supplies to replace imported water. For example, the Water Replenishment District of Southern California is actively pursuing a policy of Water Independence Now (WIN) that will eliminate imported water for replenishment and replace it with storm water and recycled water recharge. The LACFCD has no authority over population growth, land use jurisdiction, or water supplies. As noted in Section 5.3 of the PEIR, the augmentation of water supplies as a secondary outcome of the EWMPs would not induce growth or remove an obstacle to growth, but may help to replace the use of imported water over time as a part of the regional water supply portfolio managed by others. Furthermore, the PEIR evaluates the potential impacts of increased recharge to groundwater quality and groundwater levels in Impact 3.8-1. The potential for groundwater to exfrltrate in creeks, road cuts, and areas of lower elevation is recognized on page 3.8-35. However, as low flow BMPs are installed throughout the region, base flows fed from landscape runoff are predicted to decrease throughout the region. Any new contribution to surface water flows from new groundwater seepage would be accommodated by the drainage system and would reflect a more natural condition. As stated on page 3.14-20 of the PEIR, cumulative impacts in regard to existing water supplies are anticipated to be beneficial as a result of stormwater and non-stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. Response to Comment 20-N: The Hauled Water Initiative will determine the feasibility of using hauled water as a potable water source for new single-family residential development where there is no feasible source of municipal or well water available. The Notice of Preparation and Initial Study for the Hauled Water Initiative was released in September of 2014; the Initiative has not yet been approved and no public schedule has been released for completion of the environmental review (LA County Planning, 2015). Because the proposed program involves implementation of storm water infrastructure and not development of new single-family residential, the discussion of impacts relating to the promotion of hauled water developments is not relevant. Population growth is expected in the region and the local water suppliers have prepared urban water management plans that explain how they intend to meet the growing demand. The current conditions throughout the State of California indicate that imported water supplies will be more limited in the future than they have been historically. Emphasis is being placed on local supplies to replace imported water. For example, the Water Replenishment District of Southern California is actively pursuing a policy of Water Independence Now (WIN) that will eliminate imported LA County Flood Control District 11-256 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments water for replenishment and replace it with storm water and recycled water recharge. The LACFCD has no authority over population growth, land use jurisdiction, or water supplies. As noted in Section 5.3 of the PEIR, the augmentation of water supplies as a secondary outcome of the EWMPs would not induce growth or remove an obstacle to growth, but may help to replace the use of imported water over time as a part of the regional water supply portfolio managed by others. Response to Comment 20-0: The priority projects were initially selected to be further investigated as part of the EWMPs. The future projects will be selected based on engineering feasibility, water quality reduction benefit, and other factors such as soil investigations, partnership opportunities, etc. Mitigation Measures AES -1 and HAZ-1 both require that implementing agencies prepare and implement maintenance plans as part of the project approval and would reduce potentially significant impacts to less than significant levels. These mitigation measures will be adopted with the Mitigation Monitoring and Reporting Plan. The EWMPs will summarize project costs and funding mechanisms available to implementing agencies. Implementing agencies are responsible for identifying funding mechanisms needed to effectuate Permit compliance. The PEIR does not evaluate costs or funding sources for BMP implementation since providing funding is not an environmental impact. Revenue sources will vary for each implementing agency but will likely include grant funding, low interest loans, or local fee assessment. As no other definition for it has been stated in the LID Manual, the term "minimize" as referenced by the commenter LID Manual has been interpreted to have the following meaning: "to make as small as possible." As no other definition for it has been stated in the LID Manual, the term "lessen" as referenced by the commenter LID Manual has been interpreted to have the following meaning: "to become less or cause something to become less" (Merriam Webster, 2015a; Merriam Webster, 2015b). The LID ordinance does not apply to existing streets, however it would apply to future streets that are part of a tract development. Response to Comment 20-P: Population growth is expected in the region and the local water suppliers have prepared urban water management plans that explain how they intend to meet the growing demand. The current conditions throughout the State of California indicate that imported water supplies will be more limited in the future than they have been historically. Emphasis is being placed on local supplies to replace imported water. For example, the Water Replenishment District of Southern California is actively pursuing a policy of Water Independence Now (WIN) that will eliminate imported water for replenishment and replace it with storm water and recycled water recharge. The LACFCD has no authority over population growth, land use jurisdiction, or water supplies. As noted in Section 5.3 of the PEIR, the augmentation of water supplies as a secondary outcome of the EWMPs would not induce growth or remove an obstacle to growth, but may help to replace a County Flood Control District 11-257 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments the use of imported water over time as a part of the regional water supply portfolio managed by others. Please also refer to Response to Comment 20-G above regarding the rainfall analysis. Please also refer to Response to Comment 20-K and 20-J regarding the sufficiency of detention containers. Response to Comment 20-Q: As noted on Section 2.4.2, the EWMPs include infiltration projects to be installed where the soils and groundwater capacity are favorable. The PEIR acknowledges that depth to groundwater and infiltration capacity are important factors for locating effective infiltration BMPs. Mitigation Measures GEO-1, GEO-2, and HYDRO -1 require that implementing agencies evaluate site suitability prior to installation and would reduce potentially significant impacts to less than significant levels. Response to Comment 20-R: The priority projects were initially selected to be further investigated as part of the EWMPs. The future projects will be selected based on engineering feasibility, water quality reduction benefit, and other factors such as soil investigations, partnership opportunities, etc. More information will be provided in each EWMP. The PEIR provides a cumulative assessment in Section 3.8. The PEIR notes that future projects could directly or cumulatively impact local soil stability. As a result, the PEIR identifies Mitigation Measure GEO-2 that requires implementing agencies notify local groundwater managers prior to installing infiltration BMPs. Implementation of this mitigation measure would reduce potentially significant impacts to less than significant levels. The goal of the infiltration BMPs is to increase stonnwater infiltration for water quality benefits but also for water supply benefits. Future increase in stormwater infiltration is consistent with regional water supply planning efforts underway by the groundwater managers (Water Replenishment District of Southern California, the ULARA Watermaster, and Santa Clarita River Valley stakeholders) and water suppliers such as Metropolitan Water District of Southern California (MWD, 20 10) and the City of Los Angeles (City of Los Angeles, 2009). Implementing agencies would evaluate cumulative projects for future projects as necessary to comply with CEQA. An analysis of cumulative impacts would be included in each EIR developed by the lead agencies associated with future EWMP projects. In regard to growth inducement as a cumulative effect of EWMP implementation, population growth is expected in the region and the local water suppliers have prepared urban water management plans that explain how they intend to meet the growing demand. The current conditions throughout the State of California indicate that imported water supplies will be more limited in the future than they have been historically. Emphasis is being placed on local supplies to replace imported water. For example, the Water Replenishment District of Southern California is actively pursuing a policy of Water Independence Now (WIN) that will eliminate imported water for replenishment and replace it with storm water and recycled water recharge. The LACFCD has no authority over population growth, land use jurisdiction, or water supplies. As LA County Flood Control District 11-258 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments noted in Section 5.3 of the PEIR, the augmentation of water supplies as a secondary outcome of the EWMPs would not induce growth or remove an obstacle to growth, but may help to replace the use of imported water over time as a part of the regional water supply portfolio managed by others. Response to Comment 20-S: Each EWMP employs water quality predictive modeling as part of the process of identifying BMP locations and designs. Each watershed within the region has focused on using predictive modeling tailored to its own needs. The Permit requires that Reasonable Assurance Analysis be conducted to predict the outcome of the BMPs to be employed throughout the individual watersheds. The PEIR evaluates the potential environmental impacts of implementing structural and non-structural BMPs. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. The requirement to fully capture the 85" percentile storm in a regional BMP is a Permit requirement. Providing the hydrology calculations (design volume, runoff coefficients, time of concentrations) is beyond the scope of the PEIR, as it is an advanced planning document. The PEIR evaluates typical project types to assess potential impacts of implementing the entire program throughout the region over a long period of time. More information about these projects can be obtained from the individual implementing agencies. The capacity of each regional BMP identified will be subject to subsequent site specific analysis, which is dependent on local geology, precipitation trends and contributing area. Each regional BMP will be subject to further design, CEQA compliance, and approval by the implementing agencies. Response to Comment 20-T: Because project details are largely incomplete since the EWMPs are being drafted concurrently, each individual project will be subject to a CEQA compliance evaluation prior to approval by the implementing agencies as noted in Section 1 of the Draft PEIR. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of its proposed projects. The PEIR provides the LACFCD a foundation for any necessary future environmental review that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. As noted on page 1-3, the PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual projects. The process for incorporating the PEIR or tiering from the PEIR pursuant to Section 15152 of the CEQA Guidelines may be employed by lead agencies for use regarding individual BMPs at their discretion. No uniform tiering plan of action a County Flood Control District 11-259 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments has been established for subsequent project approvals since each project will require specific consideration by varying Permittees. Response to Comment 20-U: As noted on page 1-3, the PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual projects. Implementation of CEQA is at the lead agency's discretion. No uniform tiering plan of action has been established for subsequent project approvals since each project will require specific consideration by varying Permittees. The process for incorporating the PEIR or tiering from the PEIR pursuant to Section 15152 of the CEQA Guidelines may be employed by lead agencies for use regarding individual BMPs at their discretion. Response to Comment 20-V: The proposed EWMP BMPs as described in the PEIR are under development. Potential priority projects are shown in Figures 2-5 through 2-16 and Appendix G of the PEIR. More site investigations are needed to fully vet these projects and define the project scope needed to satisfy the respective EWMP requirements; these analyses will be done following the certification of this EIR in the individual EWMPs themselves. Response to Comment 20-W: Each BMP will affect flood control facilities differently. Direct benefits may include reduced hyrdomodification, reduced erosion, and reduced peak flows. Retention of storm flows, whatever the volume, assists in reducing peak flows downstream. Some BMPs will reduce dry -weather flows as well. The reduction in dry weather base flow will vary from watershed to watershed and season to season and will increase over time as more BMPs are installed. A more -detailed prediction of future dry weather and wet weather flows is currently unavailable. Each EWMP employs water quality predictive modeling as part of the process of identifying BMP locations and designs. Each watershed within the region has focused on using predictive modeling tailored to its own needs. The Permit requires that Reasonable Assurance Analysis be conducted to predict the outcome of the BMPs to be employed throughout the individual watersheds. The PEIR evaluates the potential environmental impacts of implementing structural and non-structural BMPs. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. Providing the hydrology calculations (design volume, runoff coefficients, time of concentrations) is beyond the scope of the PEIR, as it is an advanced planning document. The PEIR evaluates typical project types to assess potential impacts of implementing the entire program throughout the region over a long period of time. More information about these projects can be obtained from the implementing agency. LA County Flood Control District 11-260 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Comment 20-X: The program objectives are provided in Section 2.2 of the PEIR. Quantitative objectives and success criteria are mandated in the Permit. No additional program objectives are necessary. Response to Comment 20-Y: The EWMPs will summarize project costs and funding mechanisms available to implementing agencies. Implementing agencies are responsible for identifying funding mechanisms needed to effectuate Permit compliance. The PEIR does not evaluate costs or funding sources for BMP implementation since providing funding is not an environmental impact. Revenue sources will vary for each implementing agency but will likely include grant funding, low interest loans, or local fee assessment. Response to Comment 20-Z: The PEIR acknowledges that increased stormwater recharge will augment groundwater supplies. The overall recharge volume will vary from basin to basin and from season to season and will increase over time as more BMPs are installed. This additional benefit of the EWMPs is consistent with the goals and plans of the regional groundwater basin managers and water suppliers as described in Section 3.14-1. Water retailers in Los Angeles County generally have two water sources available to them: imported water supplied by a water wholesaler (e.g., Metropolitan, Castaic Lake Water Agency) or groundwater. The two large groundwater basins in Los Angeles County are adjudicated, with established water rights made available to pumpers. The pumpers' allocations are constricted to prevent over -drafting the aquifer. The groundwater managers (Water Replenishment District of Southern California, Upper Los Angeles River Area Water Master) augment the groundwater basins with imported surface water when available to meet demands. Population growth is expected in the region and the local water suppliers have prepared urban water management plans that explain how they intend to meet the growing demand. The current conditions throughout the State of California indicate that imported water supplies will be more limited in the future than they have been historically. Emphasis is being placed on local supplies to replace imported water. For example, the Water Replenishment District of Southern California is actively pursuing a policy of Water Independence Now (WIN) that will eliminate imported water for replenishment and replace it with storm water and recycled water recharge. The LACFCD has no authority over population growth, land use jurisdiction, or water supplies. As noted in Section 5.3 of the PEIR, the augmentation of water supplies as a secondary outcome of the EWMPs would not induce growth or remove an obstacle to growth, but may help to replace the use of imported water over time as a part of the regional water supply portfolio managed by others. Furthermore, the PEIR evaluates the potential impacts of increased recharge to groundwater quality and groundwater levels in Impact 3.8-1. The potential for groundwater to exfiltrate in creeks, road cuts, and areas of lower elevation is recognized on page 3.8-35. However, as low a County Flood Control District 11-261 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments flow BMPs are installed throughout the region, base flows fed from landscape runoff are predicted to decrease throughout the region. Any new contribution to surface water flows from new groundwater seepage would be accommodated by the drainage system and would reflect a more natural condition. As stated on page 3.14-20 of the PEIR, cumulative impacts in regard to existing water supplies are anticipated to be beneficial as a result of stormwater and non-stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. Response to Comment 20 -AA: As low flow BMPs are installed throughout the region, base flows fed from landscape runoff are predicted to decrease throughout the region. Any new contribution to surface water flows from new groundwater seepage would be accommodated by the drainage system and would reflect a more natural condition. The PEIR acknowledges on page 3.5-27 that increased recharge could raise groundwater levels in some areas and could impact shallow infrastructure such as concrete channel bottoms, bridge footings, buildings, and utilities. Response to Comment 20 -BB: The commenter's background and qualifications are noted. Response to Comment 20 -CC: Each EWMP employs water quality predictive modeling as part of the process of identifying BMP locations and designs. A single surface water quality model for the entire County has not been employed since such an effort would provide minimal value for the amount of effort required. Rather, each watershed within the region has focused on using predictive modeling tailored to its own needs. The Permit requires that Reasonable Assurance Analysis or modeling be conducted to predict the outcome of the BMPs to be employed throughout the individual watersheds. The PEIR evaluates the potential environmental impacts of implementing structural and non-structural BMPs. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. Response to Comment 20 -DD: The requirement to fully capture the 85" percentile storm in a regional BMP is a Permit requirement. Providing the hydrology calculations (design volume, runoff coefficients, time of concentrations) is beyond the scope of the PEIR, as it is an advanced planning document. The PEIR evaluates typical project types to assess potential impacts of implementing the entire program throughout the region over a long period of time. More information about these projects can be obtained from the individual implementing agencies. The capacity of each regional BMP identified will be subject to subsequent site specific analysis, which is dependent on local geology, precipitation trends and contributing area. Each regional BMP will be subject to further design, CEQA compliance, and approval by the implementing agencies. More information LA County Flood Control District 11-262 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments regarding the precipitation rainfall across the County can be found http://www.ladpw. org/wrd/publication/engineering/Final_Report- Probability_Analysis_of 85th_Percentile_24-hr_Rainfalll.pdf Response to Comment 20 -EE: The PEIR acknowledges that increased stormwater recharge will augment groundwater supplies. The overall recharge volume will vary from basin to basin and from season to season and will increase over time as more BMPs are installed. This additional benefit of the EWMPs is consistent with the goals and plans of the regional groundwater basin managers and water suppliers as described in Section 3.14-1. Water retailers in Los Angeles County generally have two water sources available to them: imported water supplied by a water wholesaler (e.g., Metropolitan, Castaic Lake Water Agency) or groundwater. The two large groundwater basins in Los Angeles County are adjudicated, with established water rights made available to pumpers. The pumpers' allocations are constricted to prevent over -drafting the aquifer. The groundwater managers (Water Replenishment District of Southern California, Upper Los Angeles River Area Water Master) augment the groundwater basins with imported surface water when available to meet demands. Population growth is expected in the region and the local water suppliers have prepared urban water management plans that explain how they intend to meet the growing demand. The current conditions throughout the State of California indicate that imported water supplies will be more limited in the future than they have been historically. Emphasis is being placed on local supplies to replace imported water. For example, the Water Replenishment District of Southern California is actively pursuing a policy of Water Independence Now (WIN) that will eliminate imported water for replenishment and replace it with storm water and recycled water recharge. The LACFCD has no authority over population growth, land use jurisdiction, or water supplies. As noted in Section 5.3 of the PEIR, the augmentation of water supplies as a secondary outcome of the EWMPs would not induce growth or remove an obstacle to growth, but may help to replace the use of imported water over time as a part of the regional water supply portfolio managed by others. Furthermore, the PEIR evaluates the potential impacts of increased recharge to groundwater quality and groundwater levels in Impact 3.8-1. The potential for groundwater to exfiltrate in creeks, road cuts, and areas of lower elevation is recognized on page 3.8-35. However, as low flow BMPs are installed throughout the region, base flows fed from landscape runoff are predicted to decrease throughout the region. Any new contribution to surface water flows from new groundwater seepage would be accommodated by the drainage system and would reflect a more natural condition. Response to Comment 20 -FF: Implementation of the EWMPs would not disproportionately affect areas with lower than average incomes. Local water supplies are largely shared resources, managed by regional agencies (e.g., Metropolitan, Castaic Lake Water Agency) responsible for supplying drinking water equitably to a County Flood Control District 11-263 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments the population. Local water retailers receive their water generally from imported water wholesalers and groundwater pumping. Groundwater recharge resulting from infiltration BMPs will occur throughout the region. Some areas will experience greater volumes of recharge than others due to the local topography and geology. However, local demographics will not influence water quality control infrastructure locations. The equitable delivery of high quality drinking water is the responsibility of water retailers as regulated by the State Water Resources Control Board and the California Department of Public Health. Response to Comment 20 -GG: The PEIR discusses potential impacts to public health in Impact 3.7-2. The PEIR acknowledges that accumulation of contaminants from water and water-logged habitats in BMPs over time could result in hazardous conditions. Mitigation Measure HAZ-1 is included to ensure that maintenance plans are prepared and implemented to reduce the risk to public health. BMPs may detain water that stagnates or generates odors. Mitigation Measure AIR -4 requires implementing agencies to consider odor controls to reduce impacts to the public. Other vectors such as mosquitos and rodents could be attracted to standing water. Local vector control agencies would employ measures to reduce public health impacts from areas of standing water in cooperation with the LACFCD. In response to the comment Mitigation Measure HAZ-1 has been modified to ensure that vector control plans are incorporated into BMP maintenance plans. Both mitigation measures AIR -4 and HAZ-1 would reduce potentially significant public health impacts to less than significant levels. HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The Maintenance Plan shall include vector control requirements. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. Response to Comment 20 -HH: Mitigation Measures AES -1 and HAZ-1 both require that implementing agencies prepare and implement maintenance plans as part of the project approval and would reduce potentially LA County Flood Control District 11-264 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments significant impacts to less than significant levels. These mitigation measures will be adopted with the Mitigation Monitoring and Reporting Plan. The EWMPs will summarize project costs and funding mechanisms available to implementing agencies. Implementing agencies are responsible for identifying funding mechanisms needed to effectuate Permit compliance. The PEIR does not evaluate costs or funding sources for BMP implementation since providing funding is not an environmental impact. Revenue sources will vary for each implementing agency but will likely include grant funding, low interest loans, or local fee assessment. Response to Comment 20 -II: The EWMPs will summarize project costs and funding mechanisms available to implementing agencies. Implementing agencies are responsible for identifying funding mechanisms needed to effectuate Permit compliance. The PEIR does not evaluate costs or funding sources for BMP implementation since providing funding is not an environmental impact. Revenue sources will vary for each implementing agency but will likely include grant funding, low interest loans, or local fee assessment. Each BMP will affect flood control facilities differently. Direct benefits may include reduced hyrdomodifrcation, reduced erosion, and reduced peak flows. Retention of storm flows, whatever the volume, assists in reducing peak flows downstream. Some BMPs will reduce dry -weather flows as well. The reduction in dry weather base flow will vary from watershed to watershed and season to season and will increase over time as more BMPs are installed. A more -detailed prediction of future dry weather and wet weather flows is currently unavailable. The PEIR acknowledges that increased stormwater recharge will augment groundwater supplies. The overall recharge volume will vary from basin to basin and from season to season and will increase over time as more BMPs are installed. This additional benefit of the EWMPs is consistent with the goals and plans of the regional groundwater basin managers and water suppliers as described in Section 3.14-1. Water retailers in Los Angeles County generally have two water sources available to them: imported water supplied by a water wholesaler (e.g., Metropolitan, Castaic Lake Water Agency) or groundwater. The two large groundwater basins in Los Angeles County are adjudicated, with established water rights made available to pumpers. The pumpers' allocations are constricted to prevent over -drafting the aquifer. The groundwater managers (Water Replenishment District of Southern California, Upper Los Angeles River Area Water Master) augment the groundwater basins with imported surface water and other water sources when available to meet demands. Response to Comment 20 -JJ: The PEIR acknowledges that increased stormwater recharge will augment groundwater supplies. The overall recharge volume will vary from basin to basin and from season to season and will increase over time as more BMPs are installed. The recharge would not be considered a water banking resource that would be eligible for extraction by the recharging permittee. Once infiltrated, the water is subject to the authority of groundwater basin managers or watermaster in a County Flood Control District 11-265 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments managed basins or otherwise subject to adjudicated settlements and the California Water Code rules governing groundwater use in California. Page 3.8-35 of the PEIR states that in areas with shallow groundwater tables or impermeable soils, recharge could result in mounding that affects subsurface infrastructure such as building or bridge foundations. This would be a potential impact of regional BMPs that recharge large volumes of captured stormwater, but could also occur for distributed BMPs in areas with limited permeability. For example, the EWMP Areas of Malibu Creek, Northern Santa Monica Bay, and Palos Verdes are located in areas where no significant groundwater basin occurs. In addition, the West Coast Basin consists of a series of aquitards near the surface that prevent surface water percolation into the productive aquifers. Infiltration BMPs in these areas would result in shallow infiltration followed by lateral movement and seepage to nearby areas that could include creek cuts, areas of lower elevation, or basements and underground vaults. Mitigation Measure HYDRO -1 would require Permittees to evaluate the suitability of BMP locations for groundwater recharge. Infiltration BMPs would not be suitable in areas of low permeability where subsurface structures could be adversely affected by groundwater mounding. Response to Comment 20 -KK: Each BMP will affect flood control facilities differently. Direct benefits may include reduced hyrdomodification, reduced erosion, and reduced peak flows. Retention of storm flows, whatever the volume, assists in reducing peak flows downstream. These benefits would not be growth - inducing. Some BMPs will reduce dry -weather flows as well. The reduction in dry weather base flow will vary from watershed to watershed and season to season and will increase over time as more BMPs are installed. A more -detailed prediction of future dry weather and wet weather flows is unavailable since it will depend on multiple variables including the implementation schedules of multiple BMPs. Response to Comment 20 -LL: The PEIR evaluates the potential impacts of increased recharge to groundwater quality and groundwater levels in Impact 3.8-1. The potential for groundwater to exfiltrate in creeks, road cuts, and areas of lower elevation is recognized on page 3.8-35. However, as low flow BMPs are installed throughout the region, base flows fed from landscape runoff are predicted to decrease throughout the region. Any new contribution to surface water flows from new groundwater seepage would be accommodated by the drainage system and would reflect a more natural condition. The PEIR acknowledges on page 3.5-27 that increased recharge could raise groundwater levels in some areas and could impact shallow infrastructure such as concrete channel bottoms, bridge footings, buildings, and utilities. Mitigation Measure GEO-2 commits the LACFCD to coordinate with local groundwater managers to "mitigate high groundwater levels." This mitigation measure would reduce potentially significant impacts to less than significant levels. The changes to dry weather base flow will vary from watershed to watershed and season to season and will increase over time as more BMPs are installed. A more -detailed prediction of future dry weather and wet weather flows is currently unavailable since it will depend on multiple variables including the implementation schedules of multiple BMPs. LA County Flood Control District 11-266 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Each BMP will affect flood control facilities differently. Direct benefits may include reduced hyrdomodification, reduced erosion, and reduced peak flows. Retention of storm flows, whatever the volume, assists in reducing peak flows downstream. These benefits would not be growth - inducing. Some BMPs will reduce dry -weather flows as well. The reduction in dry weather base flow will vary from watershed to watershed and season to season and will increase over time as more BMPs are installed. A more -detailed prediction of future dry weather and wet weather flows is currently unavailable since it will depend on multiple variables including the implementation schedules of multiple BMPs. Response to Comment 20 -MM: Subsequent to receiving this comment letter, the commenter's requested information was provided to the commenter by the City of Los Angeles. The EWMPs containing a list of proposed priority projects and locations will be submitted to the RWQCB in June 2015. Appendix G of the PEIR provides some location information on the priority projects known at time of publication of the PEIR. Otherwise, the PEIR describes typical project types that would be employed within each EWMP, but does not provide specific details to any individual project. The analysis in the PEIR focuses on construction impacts of typical projects, the overall cumulative impacts associated with the program, and an assessment of program alternatives. Individual projects will be identified and subject to CEQA compliance on a case by case basis by the implementing agency. Response to Comment 20 -NN: The documentation that identifies the 85" percentile, 24 hour storm as the most cost effective storm can be obtained at http://dpw.lacounty.gov/wmd/wmmns/docs/DesignStonnReport.pdf Also, the 85th percentile, 24 hour storm is a theoretical storm based on historical rainfall data and not a specific storm at a specific time. More information can be found at http://www.ladpw.org/wrd/publication/engineering/Final Report - Probability Analysis of 85th Percentile 24 -hr Rainfalll.pdf The runoff coefficients will vary from project to project and will not be part of the PEIR, but the calculations will be provided in the EWMPs. The requirement to fully capture the 85" percentile storm in a regional BMP is a Permit requirement. Providing the hydrology calculations (design volume, runoff coefficients, time of concentrations) is beyond the scope of the PEIR, as it is an advanced planning document. The PEIR evaluates typical project types to assess potential impacts of implementing the entire program throughout the region over a long period of time. More information about these projects can be obtained from the individual implementing agencies. The capacity of each regional BMP identified will be subject to subsequent site specific analysis, which is dependent on local geology, precipitation trends and contributing area. Each regional BMP will be subject to further design, CEQA compliance, and approval by the implementing agencies. a County Flood Control District 11-267 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Comment 20-00: The EWMPs are under development and input was received from each participating permittee. The PEIR provides available information, acknowledging that projects will be changed and added over time to meet Permit objectives. The PEIR as an advanced planning tool provides an early environmental assessment of the overall EWMP compliance approach to assist Permittees in assessing individual projects. Project types are defined clearly in Section 2.4. The requirements of the Permit are defined in Section 1.2. Each concept identified in the PEIR is defined as needed to support the reader in understanding the analysis. However, individual projects are not yet designed to the detail requested by the commenter. As projects are designed, they will be evaluated by the implementing agencies and subject to a CEQA compliance determination. Response to Comment 20 -PP: The EWMPs are under development. The PEIR provides available information, acknowledging that projects will be changed and added overtime to meet Permit objectives. Tables 2-3, 2-4, and 2-5 provide available details on planned and proposed BMPs. Appendix G provides available location information for the priority projects that were identified at the time of publication. Response to Comment 20-QQ: The PEIR acknowledges that most of the projects to be included in the EWMPs are either currently undefined or currently under development. The PEIR explains that EWMPs are being prepared that will contain road maps to permit compliance for each of the 12 watersheds, without yet being fully detailed. The PEIR states on page ES -2 that "The PEIR analysis is not intended to focus on site-specific construction and operational details of each management strategy and project included in the EWMP. Rather this PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution." The use of a PEIR pursuant to CEQA Guidelines Section 15168 is intended to evaluate broad-based impacts early in the planning process and is the appropriate CEQA compliance document for the EWMPs at this time. Response to Comment 20 -RR: The projects objectives provided on page ES -3 and 2-2 are appropriate objectives for a CEQA compliance evaluation. Quantitative objectives and success criteria for water quality are mandated in the Permit. No additional or altered program objectives are necessary. Response to Comment 20 -SS: In addition to the discussions on pages 3.8-20 and 3.8-21 of the PEIR, in regard to growth inducement, the PEIR acknowledges that increased storrnwater recharge will augment groundwater supplies. The overall recharge volume will vary from basin to basin and from season to season and will increase over time as more BMPs are installed. This additional benefit of the EWMPs is consistent with the goals and plans of the regional groundwater basin managers and water suppliers as described in Section 3.14-1. Water retailers in Los Angeles County generally LA County Flood Control District 11-268 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments have two water sources available to them: imported water supplied by a water wholesaler (e.g., Metropolitan, Castaic Lake Water Agency) or groundwater. The two large groundwater basins in Los Angeles County are adjudicated, with established water rights made available to pumpers. The pumpers' allocations are constricted to prevent over -drafting the aquifer. The groundwater managers (Water Replenishment District of Southern California, Upper Los Angeles River Area Water Master) augment the groundwater basins with imported surface water when available to meet demands. Population growth is expected in the region and the local water suppliers have prepared urban water management plans that explain how they intend to meet the growing demand. The current conditions throughout the State of California indicate that imported water supplies will be more limited in the future than they have been historically. Emphasis is being placed on local supplies to replace imported water. For example, the Water Replenishment District of Southern California is actively pursuing a policy of Water Independence Now (WIN) that will eliminate imported water for replenishment and replace it with storm water and recycled water recharge. The LACFCD has no authority over population growth, land use jurisdiction, or water supplies. As noted in Section 5.3 of the PEIR, the augmentation of water supplies as a secondary outcome of the EWMPs would not induce growth or remove an obstacle to growth, but may help to replace the use of imported water over time as a part of the regional water supply portfolio managed by others. Furthermore, the PEIR evaluates the potential impacts of increased recharge to groundwater quality and groundwater levels in Impact 3.8-1. The potential for groundwater to exfiltrate in creeks, road cuts, and areas of lower elevation is recognized on page 3.8-35. However, as low flow BMPs are installed throughout the region, base flows fed from landscape runoff are predicted to decrease throughout the region. Any new contribution to surface water flows from new groundwater seepage would be accommodated by the drainage system and would reflect a more natural condition. As stated on page 3.14-20 of the PEIR, cumulative impacts in regard to existing water supplies are anticipated to be beneficial as a result of stormwater and non-stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. Environmental justice is discussed in Section 3.11, Population and Housing and Environmental Justice, Impact 3.11-4 on page 3.11-7. The PEIR concludes that impacts would be less than significant due to the broad distribution of water quality BMPs to be implemented throughout the communities. No mitigation was determined to be necessary to reduce environmental justice impacts to less than significant levels. Response to Comment 20 -TT: In regard to the identification of potential and priority structural and non-structural BMPs mentioned in on page 1-1 of the PEIR, the commenter states that BMPs, groups of BMPs, and Projects are not defined at any engineering levels so as to determine cost-effectiveness, capabilities to achieve any project/program goal involving water quality or flows and their effects a County Flood Control District 11-269 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments and impacts. To define the projects at "engineering levels" as stated by the commenter is interpreted to mean providing specific design details. Appendix G of the PEIR provides some location information on the priority projects known at time of publication of the PEIR; however, the EWMPs are currently in development and project details are not currently known. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. The EWMPs will summarize project costs and funding mechanisms available to implementing agencies. Implementing agencies are responsible for identifying funding mechanisms needed to effectuate Permit compliance. The PEIR does not evaluate costs or funding sources for BMP implementation since providing funding is not an environmental impact. Revenue sources will vary for each implementing agency but will likely include grant funding, low interest loans, or local fee assessment. Response to Comment 20-UU: The Permit sets the schedule for preparation and delivery of the EWMPs. EWMPs are due to the RWQCB in June 2015. In an effort to maximize public involvement and participation, the LACFCD conducted six public meetings, placed numerous ads in regional and local newspapers, and maintained information including audio presentation on a dedicated website. Individual project approvals will require CEQA compliance by implementing agencies. Response to Comment 20-W: Because project details are largely incomplete since the EWMPs are being drafted concurrently, each individual project will be subject to a CEQA compliance evaluation prior to approval by the implementing agencies as noted in Section 1 of the Draft PEIR. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of its proposed projects. The PEIR provides the LACFCD a foundation for any necessary future environmental review that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. As noted on page 1-3, the PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual projects. The process for incorporating the PEIR or tiering from the PEIR pursuant to Section 15152 of the CEQA Guidelines may be employed by lead agencies for use regarding individual BMPs at their discretion. No uniform tiering plan of action has been established for subsequent project approvals since each project will require specific consideration by varying Permittees implementing the requirements of CEQA at their discretion. LA County Flood Control District 11-270 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Comment 20 -WW: Each jurisdiction has its own responsibility and discretion to comply with CEQA for individual EWMP projects. Because project details are largely incomplete since the EWMPs are being drafted concurrently, each individual project will be subject to a CEQA compliance evaluation prior to approval by the implementing agencies as noted in Section 1 of the Draft PEIR. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of its proposed projects. The PEIR provides the LACFCD with a foundation for any necessary future environmental review that focuses on individual projects of the EWMPs for which the LACFCD is the designated lead agency. Response to Comment 20 -XX: EWMP groups were formed by Permittees from each jurisdiction in common watersheds electing to achieve Permit compliance through the EWMP process as outlined in the Permit. Each Permittee within the EWMP group has provided staff to assist in formulating strategies for compliance that include water quality modeling and preparation of a Reasonable Assurance Analysis, otherwise known as the EWMP Working Group. EWMP group and EWMP Working Group may be used interchangeably. Response to Comment 20 -YY: The EWMPs are being developed concurrently and will be submitted to the RWQCB in June 2015. The PEIR includes information on the content of the EWMPS that was available at the time of publication and was based on the EWMP work plans. The comment is correct in stating that individual projects will require a subsequent CEQA compliance determination by implementing agencies prior to project approval. Response to Comment 20 -ZZ: The discretionary action of the Board of Supervisors as noted on page 1-3 of the PEIR is to approve the submittal of the EWMPs to the RWQCB. Response to Comment 20 -AAA: The EWMPs are in the process of being developed. As such, the PEIR identifies and analyzes the impacts of project types that the EWMPs are considering within each watershed to achieve Permit compliance. As individual projects are identified, the implanting agencies will conduct a CEQA determination prior to project approval and implementation. Implementing agencies adopting this PEIR are subject to the mitigation measures developed herein and included in the MMRP. a County Flood Control District 11-271 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Comment 20 -BBB: EWMP groups were formed by Permittees from each jurisdiction in common watersheds electing to achieve Permit compliance through the EWMP process as outlined in the Permit. Each Permittee within the EWMP group has provided staff to assist in formulating strategies for compliance that include water quality modeling and preparation of a Reasonable Assurance Analysis, otherwise known as the EWMP Working Group. EWMP group and EWMP Working Group may be used interchangeably. Response to Comment 20 -CCC: Each EWMP employs water quality predictive modeling as part of the process of identifying BMP locations and designs. Each watershed within the region has focused on using predictive modeling tailored to its own needs. The Permit requires that Reasonable Assurance Analysis be conducted to predict the outcome of the BMPs to be employed throughout the individual watersheds. The PEIR evaluates the potential environmental impacts of implementing structural and non-structural BMPs. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. Providing the hydrology calculations (design volume, runoff coefficients, time of concentrations) is beyond the scope of the PEIR, as it is an advanced planning document. The PEIR evaluates typical project types to assess potential impacts of implementing the entire program throughout the region over a long period of time. More information about these projects can be obtained from the implementing agency Subsequent CEQA analysis will be performed for the implementation of specific BMPs, which will be able to use site-specific environmental setting and BMP design details to more accurately assess whether water quality goals and objectives will be met. Response to Comment 20 -DDD: Each jurisdiction has its own responsibility and discretion to comply with CEQA for individual EWMP projects. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Pennittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of its proposed projects. As noted on page 1-3, the PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual projects. The process for incorporating the PEIR or tiering from the PEIR pursuant to Section 15152 of the CEQA Guidelines may be employed by lead agencies for use regarding individual BMPs at their discretion. No uniform tiering plan of action has been established for subsequent project approvals since each project will require specific consideration by varying Permittees implementing the requirements of CEQA at their discretion. LA County Flood Control District 11-272 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Comment 20 -EEE: The priority BMPs are defined as those BMPs that have undergone a site review and project evaluation that has identified them as having a greater opportunity to achieve the water quality objectives for their specific EWMP area. These priority BMPs were listed based upon available data at the time of publication of this PEIR. A priority BMP and priority project can be used interchangeably. Appendix G provides the location and general description of the priority BMPs. Response to Comment 20-FFF: Because project details are largely incomplete since the EWMPs are being drafted concurrently, each individual project will be subject to a CEQA compliance evaluation prior to approval by the implementing agencies as noted in Section 1 of the Draft PEIR. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of its proposed projects. The PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis outlines mitigation strategies to be followed by the LACFCD and other implementing agencies that rely on the PEIR to avoid or minimize impacts wherever feasible. The PEIR provides the LACFCD a foundation for any necessary future environmental review that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. The process for incorporating the PEIR or tiering from the PEIR pursuant to Section 15152 of the CEQA Guidelines may be employed by lead agencies for use regarding individual BMPs at their discretion. No uniform tiering plan of action has been established for subsequent project approvals since each project will require specific consideration by varying Permittees. Response to Comment 20-GGG: Because project details are largely incomplete since the EWMPs are being drafted concurrently, each individual project will be subject to a CEQA compliance evaluation prior to approval by the implementing agencies as noted in Section 1 of the Draft PEIR. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of its proposed projects. a County Flood Control District 11-273 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments The PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis outlines mitigation strategies to be followed by the LACFCD and other implementing agencies that rely on the PEIR to avoid or minimize impacts wherever feasible. The PEIR provides the LACFCD a foundation for any necessary future environmental review that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. The process for incorporating the PEIR or tiering from the PEIR pursuant to Section 15152 of the CEQA Guidelines may be employed by lead agencies for use regarding individual BMPs at their discretion. No uniform tiering plan of action has been established for subsequent project approvals since each project will require specific consideration by varying Permittees. Response to Comment 20- HHH: The PEIR does not state that CEQA is voluntary. The PEIR states that participation in an EWMP is optional. The process for incorporating the PEIR or tiering from the PEIR pursuant to Section 15152 of the CEQA Guidelines may be employed by lead agencies for use regarding individual BMPs at their discretion. No uniform tiering plan of action has been established for subsequent project approvals since each project will require specific consideration by varying Permittees. Each jurisdiction has its own responsibility and discretion to comply with CEQA for individual EWMP projects. Response to Comment 20- III: The PEIR has been prepared by the LACFCD to assess the EWMP program and to make conclusions regarding projects that will require LACFCD approval. The actions of other Permittees including those that may adopt the PEIR are not subject to LACFCD approval. The list of Permittees actively involved in the EWMP process is included Table 2-1. Response to Comment 20- JJJ: The text on page 1-5 of the PEIR is provided to summarize the requirements of the Permit in lay- person terms. The details of pollutant priorities and water quality objectives are different for each EWMP and will be included in the EWMP submittals. The PEIR evaluates at a program level, typical projects that will be installed throughout the County to improve surface water quality. Response to Comment 20- KKK: In regard to the hydrologic model, each EWMP employs water quality predictive modeling as part of the process of identifying BMP locations and designs. Each watershed within the region has focused on using predictive modeling tailored to its own needs, including consideration of existing TMDLs. The Permit requires that Reasonable Assurance Analysis be conducted to LA County Flood Control District 11-274 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments predict the outcome of the BMPs to be employed throughout the individual watersheds. The PEIR evaluates the potential environmental impacts of implementing structural and non-structural BMPs. The effectiveness of each EWMP to achieve permit compliance, including with TMDLs, will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. Response to Comment 20- LLL: The priority BMPs are defined as those BMPs that have undergone a site review and project evaluation that has identified them as having a greater opportunity to achieve the water quality objectives for their specific EWMP area. These priority BMPs were listed based upon available data at the time of publication of this PEIR. Appendix G provides the location and general description of the priority BMPs. The text on page 1-5 of the PEIR is provided to summarize the requirements of the Permit in lay- person terms. The details of pollutant priorities and water quality objectives are different for each EWMP and will be included in the EWMP submittals. The PEIR evaluates at a program level, typical projects that will be installed throughout the County to improve surface water quality. Response to Comment 20- MMM: Regarding the hydrologic model, each EWMP employs water quality predictive modeling as part of the process of identifying BMP locations and designs. A single surface water quality model for the entire County has not been employed since such an effort would provide minimal value for the amount of effort required. Further, CEQA does not require that a predictive hydrology model be conducted. Each watershed within the region has focused on using predictive modeling tailored to its own needs. The Permit requires that Reasonable Assurance Analysis be conducted to predict the outcome of the BMPs to be employed throughout the individual watersheds. The PEIR evaluates the potential environmental impacts of implementing structural and non-structural BMPs. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. Response to Comment 20- NNN: Management strategies include policies, actions, and activities which are intended to minimize or eliminate pollutant sources. Management strategies also include the various structural BMPs identified in the EWMPs. Response to Comment 20- 000: Regarding the hydrologic model, each EWMP employs water quality predictive modeling as part of the process of identifying BMP locations and designs. A single surface water quality model for the entire County has not been employed since such an effort would provide minimal value for the amount of effort required. Rather, each watershed within the region has focused on using predictive modeling tailored to its own needs. The Permit requires that Reasonable Assurance Analysis be conducted to predict the outcome of the BMPs to be employed throughout the a County Flood Control District 11-275 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments individual watersheds. The PEIR evaluates the potential environmental impacts of implementing structural and non-structural BMPs. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. Response to Comment 20- PPP: The commenter provides a statement that Appendix A and Sections 3.2 and 3.6 reference many air -related models and modeled/modeling results and comparable to requirements for surface recharging and groundwater. However, no specific comment has been identified and as such no response is necessary. Response to Comment 20- QQQ: Regarding the hydrologic model, each EWMP employs water quality predictive modeling as part of the process of identifying BMP locations and designs. A single surface water quality model for the entire County has not been employed since such an effort would provide minimal value for the amount of effort required. Further, CEQA does not require that a predictive hydrology model be conducted. Each watershed within the region has focused on using predictive modeling tailored to its own needs. The Permit requires that Reasonable Assurance Analysis be conducted to predict the outcome of the BMPs to be employed throughout the individual watersheds. The PEIR evaluates the potential environmental impacts of implementing structural and non-structural BMPs. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. Response to Comment 20- RRR: The priority BMPs have undergone a site review and project evaluation that has identified them as having a greater opportunity to achieve the water quality objectives for their specific EWMP area. These priority BMPs were listed based upon available data at the time of publication of this PEIR. A priority BMP and priority project can be used interchangeably. Appendix G provides the location and general description of the priority BMPs. The PEIR provides the LACFCD a foundation for any necessary future environmental review that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. The LACFCD, as a regional agency, is a member of each of the 12 EWMP working groups, and as such provides a commonality within each EWMP group. However, LACFCD does not have a special status or authority designated by the MS4 Permit over any of the other Permittees and cannot enforce those mitigation measures outside their jurisdiction. The LACFCD will be working with the applicable Permittees in all 12 EWMP watersheds as an equal partner to identify the types and locations of BMPs needed to achieve permit compliance within each watershed. Each Pennittee may choose to rely upon this PEIR and its identified mitigation measures, as appropriate, for BMPs within its jurisdiction. Individual projects will undergo subsequent CEQA analysis and documentation, as appropriate under the requirements of CEQA, by implementing agencies. The determinations of significance after mitigation in the PEIR apply to the LACFCD and other implementing agencies that choose to rely on this PEIR and the LA County Flood Control District 11-276 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments mitigation measures proposed herein. This PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual EWMP projects should they also adopt the findings within this PEIR. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is needed with compliance with the mitigation measures identified in this PEIR. The process for incorporating the PEIR or tiering from the PEIR pursuant to Section 15152 of the CEQA Guidelines may be employed by lead agencies for use regarding individual BMPs at their discretion. No uniform tiering plan of action has been established for subsequent project approvals since each project will require specific consideration by varying Permittees. Each jurisdiction has its own responsibility and discretion to comply with CEQA for individual EWMP projects. Response to Comment 20- SSS: Page 1-9 of the PEIR provides basic descriptions of the CEQA process and the purpose of a PEIR in lay -person terms. The comment does not clarify what is difficult to understand about the page in question. Response to Comment 20- TTT: The PEIR evaluates the potential impacts of project implementation, but does not evaluate the effectiveness of the strategies for achieving Permit compliance. The EWMP process includes a mechanism for the RWQCB to determine effectiveness of the BMPs over time. Response to Comment 20- UUU: The priority BMPs have undergone a site review and project evaluation that has identified them as having a greater opportunity to achieve the water quality objectives for their specific EWMP area. These priority BMPs were listed based upon available data at the time of publication of this PEIR. A priority BMP and priority project can be used interchangeably. Appendix G provides the location and general description of the priority BMPs. The PEIR evaluates the potential impacts of project implementation, but does not evaluate the effectiveness of the strategies for achieving Permit compliance. Nor does the PEIR evaluate the suitability of the proposed EWMP development methodologies. The EWMP process includes a mechanism for the RWQCB to determine effectiveness of the BMPs over time. Each watershed is described in general in Section 2.5, as well as section 3.8, Hydrology and Water Quality, and Appendix F Supplemental Hydrology and Water Quality Data. Providing the hydrology calculations (design volume, runoff coefficients, time of concentrations) is beyond the scope of the PEIR, as it is an advanced planning document. The PEIR evaluates typical project types to assess potential impacts of implementing the entire program throughout the region over a long period of time. More information about these projects can be obtained from a County Flood Control District 11-277 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments the individual implementing agencies. The capacity of each regional BMP identified will be subject to subsequent site specific analysis, which is dependent on local geology, precipitation trends and contributing area. Each regional BMP will be subject to further design, CEQA compliance, and approval by the implementing agencies. Response to Comment 20- VVV: The PEIR evaluates the potential impacts of project implementation, but does not evaluate the effectiveness of the strategies for achieving Permit compliance. Nor does the PEIR evaluate the suitability of the proposed EWMP development methodologies. The EWMP process includes a mechanism for the RWQCB to determine effectiveness of the BMPs over time. The degree of urbanization for each watershed is described in general in Section 2.5, as well as section 3.8, Hydrology and Water Quality, and Appendix F Supplemental Hydrology and Water Quality Data. Response to Comment 20- WWW: The PEIR acknowledges that most of the projects to be included in the EWMPs are either currently undefined or currently under development. The PEIR explains that EWMPs are being prepared that will contain road maps to permit compliance for each of the 12 watersheds, without yet being fully detailed. The priority BMPs have undergone a site review and project evaluation that has identified them as having a greater opportunity to achieve the water quality objectives for their specific EWMP area. These priority BMPs were listed based upon available data at the time of publication of this PEIR. Appendix G of the PEIR provides the location and general description of the priority BMPs. Response to Comment 20- XXX: The EWMPs will summarize project costs and funding mechanisms available to implementing agencies. Implementing agencies are responsible for identifying funding mechanisms needed to effectuate Permit compliance. The PEIR does not evaluate costs or funding sources for BMP implementation since providing funding is not an environmental impact. Revenue sources will vary for each implementing agency but will likely include grant funding, low interest loans, or local fee assessment.. Response to Comment 20- YYY: Eight scoping period comment letters were not included in the PEIR as part of an accidental omission. These comment letters generally expressed support for the restoration of Baldwin Lake, which was a topic mentioned in Dale Carter's letter that was included in Table 1-1 and considered as part of the PEIR development. These omitted letters have been listed in Table 1. 1, NOP Commenter List, as shown in Chapter 12, Clarifications and Modifications. These letters are also included as a part of this Final PEIR as part of Appendix A. Environmental justice is discussed in Section 3.11, Population and Housing and Environmental Justice, Impact 3.11-4 on page 3.11-7. The PEIR concludes that impacts would be less than significant due to the broad distribution of water quality BMPs to be implemented throughout the LA County Flood Control District 11-278 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments communities. No mitigation was determined to be necessary to reduce environmental justice impacts to less than significant levels. The EWMPs will summarize project costs and funding mechanisms available to implementing agencies. Implementing agencies are responsible for identifying funding mechanisms needed to effectuate Permit compliance. The PEIR does not evaluate costs or funding sources for BMP implementation since providing funding is not an environmental impact. Revenue sources will vary for each implementing agency but will likely include grant funding, low interest loans, or local fee assessment. Response to Comment 20- ZZZ: The project objectives are provided in Section 2.2 of the Draft PEIR. Response to Comment 20- AAAA: The EWMPs provide multiple benefits, but the project objectives are to improve water quality as defined in Section 2.2 of the Draft PEIR. Response to Comment 20- BBBB: The use of a PEIR pursuant to CEQA Guidelines Section 15168 is intended to evaluate broad- based impacts early in the planning process and is the appropriate CEQA compliance document for the EWMPs at this time. Response to Comment 20- CCCC: The EWMPs will summarize project costs and funding mechanisms available to implementing agencies. Implementing agencies are responsible for identifying funding mechanisms needed to effectuate Permit compliance. The PEIR does not evaluate costs or funding sources for BMP implementation since providing funding is not an environmental impact. Revenue sources will vary for each implementing agency but will likely include grant funding, low interest loans, or local fee assessment. Response to Comment 20-DDDD: Each BMP will affect flood control facilities differently. Direct benefits may include reduced hyrdomodifrcation, reduced erosion, and reduced peak flows. Retention of storm flows, whatever the volume, assists in reducing peak flows downstream. These benefits would not be growth - inducing. Some BMPs will reduce dry -weather flows as well. The reduction in dry weather base flow will vary from watershed to watershed and season to season and will increase over time as more BMPs are installed. Table 2-3 identifies multi -benefit flood management project as BMP types to be assessed. a County Flood Control District 11-279 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Comment 20-EEEE: The PEIR acknowledges that most of the projects to be included in the EWMPs are either currently undefined or currently under development. The PEIR explains that EWMPs are being prepared that will contain road maps to permit compliance for each of the 12 watersheds, without yet being fully detailed. Appendix G includes a list of the locations of priority projects identified as of the time of publication of the PEIR. Response to Comment 20-FFFF: The PEIR assesses various potential impacts of BMP implementation including wet and dry detention ponds in Section 3. Table ES -1 summarizes all mitigation measures identified in the Section 3 analysis to avoid or minimize potentially significant impacts. The term "engineering mitigation measures" as used by the commenter likely refers to specific design components incorporated as part of wet and dry detention ponds to reduce environmental impacts during their operation. Table 3.1-1 of the PEIR states that Mitigation Measure AES -1 would apply to detention regional BMPs. The following Mitigation Measures listed below pertain to the design of the BMPs. • Mitigation Measure AES -1 would require aboveground structures to designed to be consistent with local zoning codes and applicable design guidelines and to minimize features that contrast with neighboring development. • Mitigation Measure GEO-1 requires a geotechnical investigation that would recommend design measures necessary to prevent excessive lateral spreading that could destabilize neighboring structures. • Mitigation Measure HAZ-1 requires structural BMPs to be designed to prevent migration of constituents that may impact groundwater. • Mitigation Measure HYDRO -2 requires BMP design to consider pre-treatment technologies, type, and depth of filtration media; depth to groundwater; stormwater quality data within the BMP's collection area to assess the need and type of treatment and filtration controls; and local design manuals and ordinances requiring minimum separation distance to groundwater. • Mitigation Measure HYDRO -4 requires that BMP discharge locations are designed to minimize any hydromodification impacts includine erosion and scour. Designs could include velocity dissipaters and bank re -enforcement components. • Mitigation Measure NOISE -2 requires mechanized stationary equipment used for BMPs to be designed with noise -attenuating features. As noted in Section 1, each individual project will undergo subsequent CEQA determination by the lead implementing agency prior to installation; more specific design components will be known at this level of analysis. LA County Flood Control District 11-280 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Comment 20-GGGG: The PEIR discusses potential impacts to public health in Impact 3.7-2. The PEIR acknowledges that accumulation of contaminants in BMPs over time could result in hazardous conditions. Mitigation Measure HAZ-1 is included to ensure that maintenance plans are prepared and implemented to reduce the risk to public health. BMPs may detain water that stagnates or generates odors. Mitigation Measure AIR -4 requires implementing agencies to consider odor controls to reduce impacts to the public. Other vectors such as mosquitos and rodents could be attracted to standing water. Local vector control agencies would employ measures to reduce public health impacts from areas of standing water in cooperation with the LACFCD. In response to the comment Mitigation Measure HAZ-1 has been modified to ensure that vector control plans are incorporated into BMP maintenance plans. Both mitigation measures AIR -4 and HAZ-1 would reduce potentially significant impacts to less than significant levels. Mitigation Measure HAZ-1 has been revised as follows: HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The Maintenance Plan shall include vector control requirements. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. The addition of rain barrels as potentially effective distributed BMPs is noted in on page 2-14. Table 3.1-1 notes which mitigation measures would apply to rain barrel installation. The quantified impact to downstream hydrology from installing individual rain barrels would depend on the location, watershed, and rate of LID implementation. The LID write-ups on page 3.8-31 of the PEIR do not need to include specific rain barrel requirements; the basic LID objectives and goals need only be described. The detailed LID requirements will be applied to each project developed. Response to Comment 20-HHHH: The PEIR acknowledges that accumulation of contaminants in BMPs over time could result in hazardous conditions. Mitigation Measure HAZ-1 is included to ensure that maintenance plans are prepared and implemented to reduce the risk to public health. BMPs may detain water that a County Flood Control District 11-281 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments stagnates or generates odors. Mitigation Measure HAZ-1 would require the removal of contaminated soils and reduce potentially significant impacts to less than significant levels. Mitigation Measure HAZ-1 has been updated as follows: HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The Maintenance Plan shall include vector control requirements. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. Response to Comment 20-IIII: The commenter's statement that the centralized and regional BMP discussions are repetitive has been noted; however, repetitive language does not affect the impact conclusions of the PEIR. Centralized Structural BMPs treat runoff from a contributing area of multiple parcels (e.g., facilities typically serving a contributing area on the order of tens or hundreds of acres or larger). Regional Structural BMPs are similar but are meant to retain the 85th percentile storm over 24 hours from a contributing area. Response to Comment 20-JJJJ: The potential for groundwater to exfiltrate in creeks, road cuts, and areas of lower elevation is recognized on page 3.8-35. However, as low flow BMPs are installed throughout the region, base flows fed from landscape runoff are predicted to decrease throughout the region. Therefore, rising base flow is not expected to occur as mentioned by the commenter. Any new contribution to surface water flows from new groundwater seepage would be accommodated by the drainage system and would reflect a more natural condition. Response to Comment 20-KKKK: The commenter disagrees with the statement on page 2-26 that states that plants in the wash also aid the biogeochemical removal of pollutants such as nitrogen. The commenter's statement that few emergent plants can absorb or treat any aqueous pollutants is not substantiated with information. LA County Flood Control District 11-282 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Comment 20-LLLL: The Draft PEIR reflects a good faith effort to investigate and disclose environmental impacts of the project in full compliance with the requirements of CEQA. The suggestion that the Draft PEIR is complex with repetitive wording that causes confusion in relation to public review and participation in the CEQA process is not supported by substantial evidence. The Draft PEIR includes an Introduction and a clear, accurate Project Description that include all the information required by CEQA to comprise an adequate description of the project without supplying extensive detail beyond that needed for evaluation and review of the environmental impacts (14 Cal. Code Regs. Section 15124). Chapter 12, Clarifications and Modifications, outlines the revisions to the Draft PEIR. Response to Comment 20-MMMM: EWMP groups were formed by Permittees from each jurisdiction in common watersheds electing to achieve Permit compliance through the EWMP process as outlined in the Permit. Each Permittee within the EWMP group has provided staff to assist in formulating strategies for compliance that include water quality modeling and preparation of a Reasonable Assurance Analysis, otherwise known as the EWMP Working Group. EWMP group and EWMP Working Group may be used interchangeably. The priority BMPs are defined as those BMPs that have undergone a site review and project evaluation that has identified them as having a greater opportunity to achieve the water quality objectives for their specific EWMP area. These priority BMPs were listed based upon available data at the time of publication of this PEIR. Appendix G provides the location and general description of the priority BMPs. Each program will implement multiple projects. Projects and BMPs can be used interchangeably. Response to Comment 20-NNNN: The proposed EWMP BMPs as described in the PEIR are under development; therefore, total projected annual recharge flows resulting from the BMPs cannot be predicted at this time. Reservoir is defined as "usually artificial lake that is used to store a large supply of water for use in people's homes, in businesses, etc." (Merriam -Webster, 2015c). The terms "recharge basin" and "infiltration basin" are often used synonymously; an infiltration basin is defined as "an infiltration basin is a shallow impoundment which is designed to infiltrate stormwater into the soil" (EPA, 2014). Therefore, a reservoir is usually used to describe an above -ground structure that retains water for water supply purposes and does not necessarily infiltrate water, and a recharge basin is designed to capture and infiltrate water for recharge purposes. Response to Comment 20-0000: Figure 2-14 provides the location and distribution of potential regional/centralized BMPs (which would include any retention basins) in the Upper Los Angeles River EWMP as noted on page 2- a County Flood Control District 11-283 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments 42. Each potential location will be evaluated for site suitability by implementing agencies for inclusion in the EWMP. Response to Comment 20-PPPP: The proposed EWMP BMPs as described in the PEIR are under development. More site investigations are needed to fully vet the proposed projects and define the project scope needed to satisfy the respective EWMP requirements; these analyses will be done following the certification of this EIR in the individual EWMPs themselves. The decision to implement projects as part of the individual EWMPs will be decided by respective jurisdictions. The MMRP for the PEIR will include the appropriate implementation of the mitigation measures identified in the PEIR. Implementation schedules for individual BMPs will be developed within each EWMP by the Permittees. The Permit sets the schedule for preparation and delivery of the EWMPs. EWMPs are due to the RWQCB in June 2015. In an effort to maximize public involvement and participation, the LACFCD conducted six public meetings, placed numerous ads in regional and local newspapers, and maintained information including audio presentation on a dedicated website. Individual project approvals will require CEQA compliance by implementing agencies. Response to Comment 20-000Q: The term each jurisdiction refers to each lead agency or implementing agency. The PEIR does not evaluate costs or funding sources for BMP implementation since providing funding is not an environmental impact. Response to Comment 20-RRRR: The PEIR assesses green -house gas emissions and climate change in Section 3.6. The EWMPs identify BMPs designed to meet the Permit limits under existing climate conditions. The EWMPs include an adaptive management process which can incorporate future climate conditions once data is collected. More information regarding the precipitation rainfall across the County can be found http://www.ladpw.org/wrd/publication/engineering/Final_Report- Probability_Analysis_of 85th—Percentile 24 -hr Rainfalll.pdf. Response to Comment 20 -SSSS: The commenter states that no comparable, similar, or differing watershed conditions or characteristics have been identified other than physical channel connections. The EWMPs cover distinct watersheds described in Section 2.5, Section 3.3.1 and in Section 3.8.1. Response to Comment 20-TTTT: The referenced screening assessment will be provided in the EWMPs. The EWMPs are under development. Planned projects are projects that are currently being implemented and identified in LA County Flood Control District 11-284 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments each EWMP's Notice of Intent. The term planned project is used to reflect projects that are already being planned to be constructed in the near future. They would not be a priority or potential project. Table 2-4 includes a column that notes the status of the project as complete or planned to be installed and provides an approximate date of completion where available. The priority projects mentioned in the PEIR were initially selected to be further investigated as part of the EWMPs. The future projects will be selected based on engineering feasibility, water quality reduction benefit, and other factors such as soil investigations, partnership opportunities, etc. Priority projects known at the time of the publication of the PEIR are listed in Appendix G. Potential projects being developed by each EWMP group will be submitted to the RWQCB in June 2015. The screening assessment referenced will be provided in the EWMPs. Response to Comment 20-UUUU: Distributed BMPs do not fall into the priority, potential, or planned projects category as they will be implemented in areas where the regional/centralized BMPs are unable to capture or treat it's tributary runoff. The term planned project is used to reflect projects that are already being planned to be constructed in the near future. They would not be a priority or potential project. Table 2-4 includes a column that notes the status of the project as complete or planned to be installed and provides an approximate date of completion where available. The priority projects mentioned in the PEIR were initially selected to be further investigated as part of the EWMPs. The future projects will be selected based on engineering feasibility, water quality reduction benefit, and other factors such as soil investigations, partnership opportunities, etc. Priority projects known at the time of the publication of the PEIR are listed in Appendix G. Potential projects being developed by each EWMP group will be submitted to the RWQCB in June 2015. Response to Comment 20-VWV: The use of the word "could" is appropriate when analyzing potential impacts according to CEQA thresholds. The analysis that follows that threshold statement indicates the project would not require new or expanded water supplies. The PEIR evaluates types of projects that may be installed to comply with the Permit. Each individual project will require subsequent CEQA determination by the implementing agency. Response to Comment 20-WWWW: The structural BMPs would require construction and would generate some temporary employment. Maintenance of structural BMPs could potentially generate permanent employment within the maintenance staffs of the Permittees. However, implementation of the EWMPs is not expected to substantially increase or generate employment in the area. In addition to the discussions on pages 3.8-20 and 3.8-21 of the PEIR, in regard to growth inducement, the PEIR acknowledges that increased stormwater recharge will augment groundwater supplies. The overall recharge volume will vary from basin to basin and from season a County Flood Control District 11-285 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments to season and will increase over time as more BMPs are installed. This additional benefit of the EWMPs is consistent with the goals and plans of the regional groundwater basin managers and water suppliers as described in Section 3.14-1. Water retailers in Los Angeles County generally have two water sources available to them: imported water supplied by a water wholesaler (e.g., Metropolitan, Castaic Lake Water Agency) or groundwater. The two large groundwater basins in Los Angeles County are adjudicated, with established water rights made available to pumpers. The pumpers' allocations are constricted to prevent over -drafting the aquifer. The groundwater managers (Water Replenishment District of Southern California, Upper Los Angeles River Area Water Master) augment the groundwater basins with imported surface water when available to meet demands. Population growth is expected in the region and the local water suppliers have prepared urban water management plans that explain how they intend to meet the growing demand. The current conditions throughout the State of California indicate that imported water supplies will be more limited in the future than they have been historically. Emphasis is being placed on local supplies to replace imported water. For example, the Water Replenishment District of Southern California is actively pursuing a policy of Water Independence Now (WIN) that will eliminate imported water for replenishment and replace it with storm water and recycled water recharge. The LACFCD has no authority over population growth, land use jurisdiction, or water supplies. As noted in Section 5.3 of the PEIR, the augmentation of water supplies as a secondary outcome of the EWMPs would not induce growth or remove an obstacle to growth, but may help to replace the use of imported water over time as a part of the regional water supply portfolio managed by others. Response to Comment 20-XXXX: The term "feasibility," the noun form of "feasible," is used in the PEIR in a manner consistent with its definition, which is "possible to do" (Merriam -Webster, 2015d). The term "infeasibility," the noun form of "infeasible," is used in the PEIR in a manner consistent with its definition, which is "not feasible; impracticable" (Merriam -Webster, 2015e). The project objectives provided on page ES -3 and 2-2 are appropriate objectives for a CEQA compliance evaluation. Quantitative objectives and success criteria for water quality are mandated in the Permit. No additional or altered program objectives are necessary. Regarding a hydrologic model, each EWMP employs water quality predictive modeling as part of the process of identifying BMP locations and designs. Each watershed within the region has focused on using predictive modeling tailored to its own needs. The Permit requires that Reasonable Assurance Analysis be conducted to predict the outcome of the BMPs to be employed throughout the individual watersheds. The PEIR evaluates the potential environmental impacts of implementing structural and non-structural BMPs. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. In regard to cost-effectiveness, the EWMPs will summarize project costs and funding mechanisms available to implementing agencies. Implementing agencies are responsible for LA County Flood Control District 11-286 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments identifying funding mechanisms needed to effectuate Permit compliance. The PEIR does not evaluate costs or funding sources for BMP implementation since providing funding is not an environmental impact. Revenue sources will vary for each implementing agency but will likely include grant funding, low interest loans, or local fee assessment. Each BMP will affect flood control facilities differently. Direct benefits may include reduced hyrdomodifrcation, reduced erosion, and reduced peak flows. Retention of storm flows, whatever the volume, assists in reducing peak flows downstream. Some BMPs will reduce dry -weather flows as well. The reduction in dry weather base flow will vary from watershed to watershed and season to season and will increase over time as more BMPs are installed. A more -detailed prediction of future dry weather and wet weather flows is currently unavailable The project objectives are provided in Section 2.2 of the Draft PEIR. Response to Comment 20- YYYY: Mitigation Measure GEO-I requires that implementing agencies conduct site specific geotechnical studies to confirm that infiltration is feasible; this mitigation measure would reduce potentially significant impacts to less than significant levels. Response to Comment 20- ZZZZ: The EWMPs will summarize project costs and funding mechanisms available to implementing agencies. Implementing agencies are responsible for identifying funding mechanisms needed to effectuate Permit compliance. The PEIR does not evaluate costs or funding sources for BMP implementation since providing funding is not an environmental impact. Revenue sources will vary for each implementing agency but will likely include grant funding, low interest loans, or local fee assessment. In regard to the hydrologic model, each EWMP employs water quality predictive modeling as part of the process of identifying BMP locations and designs. Each watershed within the region has focused on using predictive modeling tailored to its own needs. A single surface water quality model for the entire County has not been employed since such an effort would provide minimal value for the amount of effort required. Further, CEQA does not require that a predictive hydrology model be conducted. The Permit requires that Reasonable Assurance Analysis be conducted to predict the outcome of the BMPs to be employed throughout the individual watersheds. The PEIR evaluates the potential environmental impacts of implementing structural and non-structural BMPs. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. Response to Comment 20-AAAAA: In regard to the hydrologic model, each EWMP employs water quality predictive modeling as part of the process of identifying BMP locations and designs. A single surface water quality model for the entire County has not been employed since such an effort would provide minimal a County Flood Control District 11-287 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments value for the amount of effort required. Further, CEQA does not require that a predictive hydrology model be conducted. Each watershed within the region has focused on using predictive modeling tailored to its own needs. The Permit requires that Reasonable Assurance Analysis be conducted to predict the outcome of the BMPs to be employed throughout the individual watersheds. The PEIR evaluates the potential environmental impacts of implementing structural and non-structural BMPs. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. In addition to the discussions on pages 3.8-20 and 3.8-21 of the PEIR, in regard to growth inducement, the PEIR acknowledges that increased stormwater recharge will augment groundwater supplies. The overall recharge volume will vary from basin to basin and from season to season and will increase over time as more BMPs are installed. This additional benefit of the EWMPs is consistent with the goals and plans of the regional groundwater basin managers and water suppliers as described in Section 3.14-1. Water retailers in Los Angeles County generally have two water sources available to them: imported water supplied by a water wholesaler (e.g., Metropolitan, Castaic Lake Water Agency) or groundwater. The two large groundwater basins in Los Angeles County are adjudicated, with established water rights made available to pumpers. The pumpers' allocations are constricted to prevent over -drafting the aquifer. The groundwater managers (Water Replenishment District of Southern California, Upper Los Angeles River Area Water Master) augment the groundwater basins with imported surface water when available to meet demands. Population growth is expected in the region and the local water suppliers have prepared urban water management plans that explain how they intend to meet the growing demand. The current conditions throughout the State of California indicate that imported water supplies will be more limited in the future than they have been historically. Emphasis is being placed on local supplies to replace imported water. For example, the Water Replenishment District of Southern California is actively pursuing a policy of Water Independence Now (WIN) that will eliminate imported water for replenishment and replace it with storm water and recycled water recharge. The LACFCD has no authority over population growth, land use jurisdiction, or water supplies. As noted in Section 5.3 of the PEIR, the augmentation of water supplies as a secondary outcome of the EWMPs would not induce growth or remove an obstacle to growth, but may help to replace the use of imported water over time as a part of the regional water supply portfolio managed by others. Furthermore, the PEIR evaluates the potential impacts of increased recharge to groundwater quality and groundwater levels in Impact 3.8-1. The potential for groundwater to exfiltrate in creeks, road cuts, and areas of lower elevation is recognized on page 3.8-35. However, as low flow BMPs are installed throughout the region, base flows fed from landscape runoff are predicted to decrease throughout the region. Any new contribution to surface water flows from new groundwater seepage would be accommodated by the drainage system and would reflect a more natural condition. LA County Flood Control District 11-288 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments As stated on page 3.14-20 of the PEIR, cumulative impacts in regard to existing water supplies are anticipated to be beneficial as a result of stormwater and non-stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. Implementation of the EWMPs would not disproportionately affect areas with lower than average incomes. Local water supplies are largely shared resources, managed by regional agencies (e.g., Metropolitan, Castaic Lake Water Agency) responsible for supplying drinking water equitably to the population. Local water retailers receive their water generally from imported water wholesalers and groundwater pumping. Groundwater recharge resulting from infiltration BMPs will occur throughout the region. Some areas will experience greater volumes of recharge than others due to the local topography and geology. However, local demographics will not influence water quality control infrastructure locations. The equitable delivery of high quality drinking water is the responsibility of water retailers as regulated by the State Water Resources Control Board and the California Department of Public Health. Response to Comment 20-BBBBB: It should be noted that as part of Response to Comment 4-13 above, a new Mitigation Measure UTIL-1 has been added to the PEIR. Therefore, the original Mitigation Measure UTIL-1 has been renumbered to Mitigation Measure UTIL-2. Page 3.14-14 has been edited as follows: UTIL-1: Prior to implementation of BMPs, the implementing agency shall conduct a search for local utilities above and below ground that could be affected by the proiect. The implementing agencies shall contact each utility potentially affected to address relocation of the utility if necessary to ensure access and services are maintained. Mitigation Measure UTIL-2 requires that implementing agencies consider the potential for BMPs to adversely affect downstream beneficial uses and water rights, and would reduce potentially significant impacts to less than significant levels. Response to Comment 20-CCCCC: It should be noted that a new Mitigation Measure UTIL-1 has been added to the PEIR. Therefore, the original Mitigation Measure UTIL-1 has been renumbered to Mitigation Measure UTIL-2. UTIL-1: Prior to implementation of BMPs, the implementing agency shall conduct a search for local utilities above and below ground that could be affected by the project. The implementing agencies shall contact each utility potentially affected to address relocation of the utility if necessary to ensure access and services are maintained. UTIL42: Prior to approval of BMPs, implementing agencies shall evaluate the potential for impacts to downstream beneficial uses, including surface water rights. Implementing agencies shall not approve BMPs that result in preventing access to previously appropriated surface water downstream. Mitigation Measure UTIL-2 states that implement agencies shall not approve BMPs that result in preventing access to previously appropriated surface water downstream. This measure ensures the a County Flood Control District 11-289 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments protection of downstream surface water rights and would reduce potentially significant impacts to less than significant levels. Specific projects will undergo subsequent CEQA determination prior to implementation. In addition to the discussions on pages 3.8-20 and 3.8-21 of the PEIR, in regard to growth inducement, the PEIR acknowledges that increased storrnwater recharge will augment groundwater supplies. The overall recharge volume will vary from basin to basin and from season to season and will increase over time as more BMPs are installed. This additional benefit of the EWMPs is consistent with the goals and plans of the regional groundwater basin managers and water suppliers as described in Section 3.14-1. Water retailers in Los Angeles County generally have two water sources available to them: imported water supplied by a water wholesaler (e.g., Metropolitan, Castaic Lake Water Agency) or groundwater. The two large groundwater basins in Los Angeles County are adjudicated, with established water rights made available to pumpers. The pumpers' allocations are constricted to prevent over -drafting the aquifer. The groundwater managers (Water Replenishment District of Southern California, Upper Los Angeles River Area Water Master) augment the groundwater basins with imported surface water when available to meet demands. Population growth is expected in the region and the local water suppliers have prepared urban water management plans that explain how they intend to meet the growing demand. The current conditions throughout the State of California indicate that imported water supplies will be more limited in the future than they have been historically. Emphasis is being placed on local supplies to replace imported water. For example, the Water Replenishment District of Southern California is actively pursuing a policy of Water Independence Now (WIN) that will eliminate imported water for replenishment and replace it with storm water and recycled water recharge. The LACFCD has no authority over population growth, land use jurisdiction, or water supplies. As noted in Section 5.3 of the PEIR, the augmentation of water supplies as a secondary outcome of the EWMPs would not induce growth or remove an obstacle to growth, but may help to replace the use of imported water over time as a part of the regional water supply portfolio managed by others. LA County Flood Control District 11-290 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 21 Paige Anderson To: Crumpacker, Andrea Subject: RE: Save Baldwin Lake at LA County Arboretum From: Connie <conhef(&earthlink.net> Date: February 10, 2015 at 4:28:12 PM PST To: <Qbegell(a,dpw.lacounty.Qov> Subject: Save Baldwin Lake at LA County Arboretum Mr. Gregg BeGell, As a member of Los Voluntarios, the volunteer organization at the Los Angles County Arboretum and Botanical Gardens would like to tell you why the restoration of Baldwin Lake is so important to me. I have been a volunteer for many decades and give tours to the public. It is one of the most visible parts of the Arboretum and is historically significant. The lake enhances the beauty of the historic Queen Ann Cottage, the historic Adobe and the jungle area. It enables the birds and water fowl to live in on the grounds which are very important to the Arboretum. The lake is one of the few natural water features in the area and a result of the Raymond Hill Fault and at times has been a mud hole due to the drought. The lake level is only 18 inches deep now, very cloudy with the stone edging collapsing into the lake. I would like to see Baldwin Lake return to its previous beautiful self which was reportedly 18 feet deep about 100 years ago. Please do whatever is necessary to restore this critical resource and historical beauty. Connie Heflin V CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comments Response to Comment Letter 21 (Connie Heflin — February 10, 2015) Response to Comment Letter 21-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. IA County Flood Control District 11-292 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 22 Paige Anderson To: Crumpacker, Andrea Subject: RE: Baldwin Lake renovation From: Harry Heflin[mailto:harrvhef(o)earthlink.netl Sent: Friday, February 13, 2015 3:40 PM To: Gregg Begell Subject: Baldwin Lake renovation Dear Mr. BeGell, I volunteer at the L.A. County Arboretum and several times a month take school children on Plant or History Tours through the Arboretum. The students and I always walk through the Prehistoric Forest to the shore of Baldwin Lake since the lake is so interesting to the kids with all its plants, birds, turtles, and fishes, and they also enjoy the marvelous view of the Queen Ann Cottage across the lake. But as I'm sure you know, Baldwin Lake is in a state of serious disrepair with crumbling banks and rock walls surrounding a silted -in basin that used to be about 15 feet deep but apparently now is only a foot or two deep. I_ I understand also that the mud and silt that have filled in the lake are potentially contaminated with residues that have washed into the lake over the years and settled on the bottom, possibly endangering the health of visitors and also of the wildlife that call the lake home. I hope that in the near future the County will give the cleanup and renovation of Baldwin Lake the priority that it deserves in order to restore the beauty and safety of one of the very few natural lakes in California. Studios often rent the Arboretum for'filming', and I have to believe that restoring the lake to its former glory would attract more film-makers and as a result garner more filming revenues to help balance the budget. Thank you kindly for your consideration of my request. Sincerely, Harry Heflin M: 626-374-1970 CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comments Response to Comment Letter 22 (Harry Heflin — February 13, 2015) Response to Comment Letter 22-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. IA County Flood Control District 11-294 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 23 Genevieve Osmena From: Leelee Doughty [mailto:nodoughts@dslextreme.coml Sent: Tuesday, February 24, 2015 4:11 PM To: Gregg Begell; Genevieve Osmena Subject: Restore Baldwin Lake I am very interested in the outcome of your meetings regarding the draft Rio Hondo/San Gabriel River Enhanced Watershed Management Plan (EWMP) on March 9th. Unfortunately, I will be unable to attend, but this is to say that I sincerely hope the DPW will include the restoration of Baldwin Lake in its final recommendations, for the following reasons: 1. It is eligible and scores high in 5 of the 6 criteria.(ownership) the Lake is publicly owned; (opportunity site) offers a water body nearly four acres in size; (catchment area) the collection basin is over 100 acres; (likely pollutants) cleanses runoff that likely exceeds allowances; and perhaps most importantly (multi -use opportunities and connectivity) offers very substantial direct public benefit. A 2. Watershed Role: Baldwin Lake serves as an important collection basin for Arcadia's urban watershed, receiving runoff from over 150 acres of suburban neighborhood to the north. This officially designated watershed area served by the Lake is bounded to the west by Michillinda Avenue, to the north by the 210 freeway, to the cast by Arcadia Wash, and to the south by the Arboretum and Monte Verde Drive. Comment Letter 23 I understand there are four restoration concepts the Arboretum has recommended and I agree with all of them. They are: 1. Create a bioswale at Tule Pond, where urban runoff first enters the Arboretum during storms. 2. Dredge the lake to create greater depth, thereby reducing water temperatures and enhancing water quality and ecosystem health. If Baldwin Lake is returned to its original depth, it could provide over twelve million gallons of storage capacity. Further modification could also provide aquifer recharge. 3. Stabilize the shoreline to stop erosion, restore historic character and enhance scenic quality. 4. Enhance the community value of Baldwin Lake as a key educational, scenic, wildlife, and historic resource serving over 330,000 visitors per year, including over 16,000 elementary school students. The project would provide an unrivaled opportunity to educate a broad public about regional water management, home and community water conservation, and the role of the Raymond Basin and other key water resources that sustain us. The Arboretum has just received significant funding for, and is in the process of, creating a certified organic and sustainable garden called the Crescent Garden, demonstrating its commitment to educating children and the community about the importance of conserving and ways to use water properly in our gardens. Thank you in advance for listening to me, a very concerned neighbor, and again, I hope you include saving Baldwin Lake per the Arboretum proposals in the final recommendations. Sincerely, Leelee Clement Doughty, resident of Pasadena A cont to Comments Response to Comment Letter 23 (Leelee Doughty — February 24, 2015) Response to Comment 23-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. a County Flood Control District 11-297 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 24 Paige Anderson To: Crumpacker, Andrea send it to me; I'm the point of contact Subject: RE: Enhanced Watershed Management Programs PEIR From: Jonathan Weiss [mailto:iw Ioiw.coml Sent: Tuesday, February 24, 2015 9:31 AM To: Gregg Begell Subject: RE Enhanced Watershed Management Programs PEIR Thanks, Here's my letter. Jonathan Weiss From: Gregg Begell[mailto:abeaell()dow.lacountv.aovl Sent: Monday, February 23, 2015 3:57 PM To: Jonathan Weiss Subject: RE Enhanced Watershed Management Programs PEIR Jonathan Yes, the comment period is open until March 9, 2015. You can send it to me; I'm the point of contact for the PEIR. You can also send it through the website: www.lacoh2osheds.com. Gregg BeGeCCP E Project Manager Project Management Division II From: Jonathan Weiss [mailto:iwMoiw.coml Sent: Monday, February 23, 2015 3:52 PM To: Gregg Begell Subject: Enhanced Watershed Management Programs PEIR Is the comment period open? Where can I sent a comment? CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Jonathan Weiss Comment Letter 24 10576 Troon Avenue Los Angeles, California 90064-4436 Telephone: (310) 558-0484 Email: jon@expogreenway.org February 24, 2015 Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont, 5th Floor Alhambra, California 91803 gbegell(&dnw.lacounty. gov Dear Mr. BeGell: Via Email I write to support the Westwood Neighborhood Greenway as part of the Enhanced Watershed Management Plan (EWMP) for the Ballona Creek Watershed. The WNG will be a multi -benefit project to provide (1) urban runoff treatment, (2) native habitat, and (3) public access via transit, bicycle and pedestrian paths. By pumping water from a perennial stream (Brown Canyon Creek) that formerly ran across the Expo ROW and the WNG area (but is now carried in the storm drain under Overland Avenue), the WNG will reduce the amount of ocean runoff and use natural and sustainable water treatment methods to remove lead, zinc, copper, and other pollutants from up to 48 million gallons of water per year. Also, the WNG will eliminate the need for potable water to irrigate both the Expo ROW and the WNG area. As importantly, the WNG will provide unparalleled institutional BMPs, as it will be adjacent to the busiest station on the Expo Light Rail line, which itself is part of the growing Metro transit network. Sustainability education will be carried on by and offered to students and public, including USC, UCLA, Los Angeles Audubon, Dorsey High School, and Overland Avenue Elementary School. Very truly yours, Jonathan Weiss U Comments Response to Comment Letter 24 (Jonathan Weiss — February 24, 2015) Response to Comment 24-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. More site investigations are needed to fully vet the proposed Westwood Neighborhood Greenway project and define the project scope needed to satisfy the EWMP's requirements. The City of Los Angeles is the primary agency who will benefit from a water quality project at the Westwood Neighborhood Greenway project. The City of Los Angeles will likely play a major role in the decision to implement an EWMP project at Westwood Neighborhood Greenway project. IA County Flood Control District 11-300 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 25 Paige Anderson To: Laura Rocha Subject: RE: PLEASE READ THIS ONE - the Rio Hondo/San Gabriel River Enhanced Watershed Management Plan (EWMP) From: George Brumder [mailto:brumderiyearthlink.netl Sent: Tuesday, February 24, 2015 8:21 PM To: Genevieve Osmena; Gregg Begell Cc: Richard Schulhof; Kenneth Hill Subject: PLEASE READ THIS ONE- the Rio Hondo/San Gabriel River Enhanced Watershed Management Plan (EWMP) Dear Ms. Osmena and Mr. BeGell, I am an honorary trustee of the Los Angeles Arboretum Foundation, the County's non-profit partner in operating and funding the Los Angeles County Arboretum & Botanic Garden. Baldwin Lake, created by Lucky Baldwin in the 1880s from a naturally -occurring wetland along the Raymond Fault, is today an important collection basin for Arcadia's urban watershed and an important and much -beloved feature of the Arboretum -- itself a wonderful resource for Southern California, with over 10,000 members and well over 300,000 visitors, including over 15,000 elementary school students, each year. The restoration of Baldwin Lake will enhance Baldwin Lake's watershed function and, in addition, bring the public extraordinary educational, ecological and scenic benefits. My wife Marilyn and I strongly urge that the restoration of Baldwin Lake be included as a high priority project within the Rio Hondo/San Gabriel River Enhanced Watershed Management Plan. We thank you for your efforts in this direction. George A. Brumder 399 California Terrace Pasadena, CA 91105 626.795.0315 CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. 0 Comments Response to Comment Letter 25 (George Brumder — February 24, 2015) Response to Comment 25-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. IA County Flood Control District 11-302 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 26 SAVE BALDWIN LAKE Ms. Pam Warner 2625 Las Lunas St. Pasadena, Ca. 91107 626-683-4906 pbwarner2@gmail.com Feb. 26, 2015 Mr. George BeGill, P.E County of L.A. Dept. of Public Works Project Management Division II 900 S. Fremont, 5th floor Alhambra, Ca. 91803 d Dear Mr. BeGill, Et T. r ua ,I = I am writing to ask for your help in saving The Los Angeles County Arboretum's Baldwin Lake, and am hoping that The Enhanced Watershed Management Plan will see fit to offer assistance. Baldwin Lake is the heart of The Arboretum. It is historical and A educational as well as part of the Rio Hondo Watershed, and is in great need of attention. Not too long ago I saw a school child in great distress. He had fallen into the lake and was covered in slime. I will never forget his attempt at courage and the clean marks of his tears. Comment Letter 26 Baldwin Lake is an environmental, historical and education gem. It has been ignored and become a hazard, full of urban runoff and in great need of assistance. I hope you and the A cont March 9th meeting on water quality will acknowledge this, and attempt to solve the effects of years of mismanagement. Thank you, & Save Baldwin Lake, Pamela B. Warner to Comments Response to Comment Letter 26 (Pamela Warner — February 26, 2015) Response to Comment 26-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. a County Flood Control District 11-305 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 27 Genevieve Osmena From: Kathleen BonEske <kbon1011@roadrunner.com> Sent: Monday, March 02, 2015 7:36 PM To: Genevieve Osmena Subject: Restore Baldwin Lake Baldwin Lake is the jewel of the LA County Botanical Gardens. It is common sense to restore this beauty.I A K.R. BonEske to Comments Response to Comment Letter 27 (Kathleen BonEske — March 2, 2015) Response to Comment 27-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. a County Flood Control District 11-307 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 28 Genevieve Osmena From: Dan Foliart <danfordf@earthlink.net> Sent: Friday, February 06, 2015 12:06 PM To: Genevieve Osmena Subject: Re: Baldwin Lake > -----Original Message----- • From: Dan Foliart [mailto:danfordf@earthlink.netl > Sent: Monday, February 02, 2015 3:29 PM > To: Gregg Begell; Genevieve Osmena > Cc: Dan Foliart > Subject: Baldwin Lake > Dear Mr. BeGell and Ms.Osmena, > Thank you for inviting comments regarding the Rio Hondo Enhanced > Watershed Management Plan. Please allow me to strongly advocate for A > The Los Angeles County Arboretum's Baldwin Lake inclusion in this plan > as you formulate your objectives. 1 Comment Letter 28 > As you are well aware, the lake was created by Elias 3Luckyz Baldwin > in the late nineteenth century as the frontispiece for his grandiose > estate and as such has become part of the lore and history of Southern > California. The lake has played an important role in local commerce, > serving as a backdrop for such disparate filmic contributions as the > Tarzan movies, 3Fantasy Island and within the last year, Katy Perry's 3Roar2 music video. > However compelling the romance of Hollywood might be to its essence, > the joy Baldwin Lake has brought to generations of parents and > children, far outweigh the gravitas of its celluloid legacy. As a > father, my children were treated to a weekly sojourn to the lake, > where catfish and carp swam and such diverse species of bird life as > the Wood Duck, the Black -crowned Night Heron and the Double -crested > Cormorant nested. In fact, the lake served as a real-life learning > center for my children, as it does for thousands of our region's school children every year. > It is my hope that the lake will bring the same joy to generations of > children to come as it has for my own. However, the lake is being > polluted to an extent that I fear that that dream may not become a > reality. With your help this body of water that has become a run-off > for contaminants that endanger the wildlife and the healthful use of > Southern California families can become the fresh and unpolluted > reservoir that it was during the Baldwin era. Please consider this > irreplaceable gem as a top priority as you move forward into the future with this project. > Sincerely yours, > Dan Foliart U Comments Response to Comment Letter 28 (Dan Foliart — March 2, 2015) Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. IA County Flood Control District 11-310 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 29 Paige Anderson To: Laura Rocha Subject: RE: RESTORE BALDWIN LAKE From: Catherine Heinlein [mailto:cheinleiW( aou.edul Sent: Monday, March 02, 2015 9:07 PM To: Gregg Begell; Genevieve Osmena Cc: Richard Schulhof Subject: RES -FORE BALDWINLAKE Dear Mr. BeGell and Ms. Osmena, I am respectfully submitting my letter in support of the restoration project at Baldwin Lake. My letter is attached to this email. Very Sincerely, Catherine Heinlein Catherine Heinlein, EdD, RN, PHN, RD, CDE Assistant Professor Certified Diabetes Educator Registered Nurse Registered Dietitian School of Nursing Azusa Pacific University 701 E. Foothill Blvd. Azusa, CA 91702 626-815-6000 Ext. 5558 CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 29 Catherine R. Heinlein 29 Genoa Street, Apt. D Arcadia, CA 91006 March 2, 2015 Dear Mr. BeGell and Ms. Osmena, I am writing this letter as a community member of Arcadia and volunteer at the Los Angeles County Arboretum and Botanic Garden. I could include all the statistics about Baldwin Lake that you are fully aware of, however, I am writing more to share my personal stance on the importance of protecting and preserving Baldwin Lake. The restoration and preservation of Baldwin Lake through the collection of rain water runoff seems to make logical sense. I've been a local for many years, primarily living against the San Gabriel Mountains. It doesn't take much for a storm to flood our streets and backyards; including overflowing residents swimming pools. Why not allow runoff to come through the Arboretum? I have been coming to the Arboretum most of my life to enjoy the plant life, birds, insects, and Baldwin Lake. It dismays me (and the students I take on medicinal plant tours) to walk by a lake that now looks more like the tar pits of La Brea. How disconcerting that our community and hard-working staff at the Arboretum have had to watch the decay and wasting of a once vibrant attraction! You have a great number of supporters rallying for the restoration of Baldwin Lake. It is the people who devote their own time, money, and energy into this historic landmark who are here making the most noise! Please do not disappoint them (me) by allowing an opportunity to do something significant for our community slip by. Sincerely, Catherine Heinlein Assistant Professor School of Nursing Azusa Pacific University Arboretum Volunteer 0 to Comments Response to Comment Letter 29 (Catherine Heinlein — March 2, 2015) Response to Comment 29-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. a County Flood Control District 11-313 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 30 Paige Anderson To: Laura Rocha Subject: RE: Save Baldwin Lake From: Andy E [mailto:toandve(a)vahoo.coml Sent: Tuesday, March 03, 2015 1:21 PM To: Genevieve Osmena Subject: Save Baldwin Lake Dear Ms. Osmena, Please take a few moments to read the attached letter to add my voice to those already crying out for help in saving Baldwin Lake. Thank you, Andy Edmonds CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 30 Dear Mr. BeGell and Ms. Osmena, Please add my voice to those already crying out for county funding to save Baldwin Lake at the LA Co Arboretum. The reasons for this project already have been pointed out via emails, letters and meetings with people much more articulate than I. I will not waste your time reiterating those points. You already know why this needs to be done and how to go about doing it. 0 I did previously send letters to both of you as well as Supervisor Antonovich's office but was informed that those either did not reach you or had not been counted in the official "tally" We were told to send this letter as an email attachment. I greatly appreciate your time and consideration in funding this project. Sincerely, Andy Edmonds Comments Response to Comment Letter 30 (Andy Edmonds — March 3, 2015) Response to Comment 30-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. IA County Flood Control District 11-316 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 31 L.''.t 17 1•x':.1.. �*:. •, -..._ i� n7' - [k+L« .. .-r 0 /! y L. hr•� li,� � �. I�•f I:.r� N.3 L�.. ' e iii 10 r. L.''.t 17 1•x':.1.. �*:. •, -..._ i� n7' - [k+L« .. .-r 0 Comment Letter 31 �.. A cont If - ! i y j i' 1 to Comments Response to Comment Letter 31 (Shake Manigonian — March 3, 2015) Response to Comment 31-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. a County Flood Control District 11-319 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 32 Paige Anderson To: Laura Rocha Subject: RE: FW: From: Gna Shaw [mailto:ainashaw(cilaol.coml Sent: Tuesday, March 03, 2015 11:59 AM To: Gregg Begell Su bj act: Dear Mr Begell, I am writing you to urge action in regards to L.A. County Arboretum Baldwin Lake. This historic site is used to teach thousands of students about early California history. It is unique and must be preserved. It was used as a water source for the Tongva Indians as well as a resting and rejuvenating spot for countless migrating birds. Our arboretum would be greatly diminished by its loss or neglect. A I am an arboretum volunteer and former docent. I know there are many demands for funds but I hope you will place Baldwin Lake high on your priorities. Gina Shaw, PhD J. Sent from AOL Mobile Mail CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. to Comments Response to Comment Letter 32 (Gina Shaw — March 3, 2015) Response to Comment 32-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. a County Flood Control District 11-321 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 33 Paige Anderson To: Laura Rocha Subject: RE: Rio Hondo/San Gabriel River Enhanced Watershed Management Plan Baldwin Lake Los Angeles County Arboretum From: Gloria Cox[mailto:aloriachriscox6Hilaol.coml Sent: Wednesday, March 04, 2015 8:25 PM To: Gregg Begell; Genevieve Osmena Subject: Rio Hondo/San Gabriel River Enhanced Watershed Management Plan Baldwin Lake Los angeles County Arboretum CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 33 Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont, 51' Floor Alhambra, CA 91803 gbegell(a)dpw.lacounty.gov Ms. Genevieve Osmena County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont, 5`h Floor Alhambra, CA 91803 gosmena(cDdpw.lacounty.gov March 4, 2015 Re: Rio Hondo/San Gabriel River Enhanced Watershed Management Plan This letter is to urge you to include the restoration of Baldwin Lake at the Los Angeles County Arboretum and Botanic Garden as a high priority project within the Rio Hondo/San Gabriel River Enhanced Watershed Management Plan. The restoration of Baldwin Lake will both enhance watershed function and serve the public with educational, and ecological benefits. Baldwin Lake is a valuable public resource. This Lake is publicly owned; it offers a body of water nearly four acres in size with a collection basin of over 100 acres; it cleanses runoff that exceeds allowances and it offers a very substantial direct public benefit. At present, the lake is so shallow it creates low water oxygen levels that are harmful to the fish, turtles and a huge variety of ducks, other birds and species. Baldwin Lake is a key educational, scenic, wildlife, and historic resource that serves the public including both elementary, high school and college students from various school district with a large percentage of them from the underserved area of Los Angeles Unified School District. This project would provide a huge opportunity to educate not only the students but also the general public about regional water management, home and community water conservation, and the role of the Raymond Basin and other key water resources that sustain the people of Los Angeles County. Thank you for you consideration of this project. Chris Cox and Gloria Cox 0 Comments Response to Comment Letter 33 (Chris and Gloria Cox — March 4, 2015) Response to Comment 33-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. IA County Flood Control District 11-324 ESA / 140494 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 34 Paige Anderson To: Laura Rocha Subject: RE: Baldwin Lake Restoration From: Margaret Page[mailto:Dennis.N.Paoenaverizon.netl Sent: Wednesday, March 04, 2015 3:03 PM To: Gregg Begell; Genevieve Osmena Subject: Baldwin Lake Restoration I understand that my e-mail, sent to you on November 11, was not recorded, so I am re -sending it below. I will also attach it as a word document in case that is more convenient for you. I am writing in support of the restoration of Baldwin Lake at the Los Angeles Arboretum. I have loved The Arboretum as a child, as a parent, and now as a volunteer docent. Thousands of visitors consider the lake an important reason to visit the garden, and it is a critical part of the environment of many of the birds and other animals that call The Arboretum home. On history tours, children A learn how important Baldwin Lake has been since its earliest history, when Tongva Indians called their home Aleupkigna or Place of Many Waters. Our visitors have expressed dismay and concern as the water levels have declined and the quality of the water deteriorated. Please know how important Baldwin Lake is to many in our community and beyond, and take advantage of the opportunity now available to restore the health and beauty of Baldwin Lake. Sincerely, Margaret Page CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comments Response to Comment Letter 34 (Margaret Page — March 4, 2015) Response to Comment 34-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. IA County Flood Control District 11-326 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 35 Paige Anderson To: Laura Rocha Subject: RE: Baldwin Lake From: Virginia Stein [mailto:oinnchazzCcilomail.coml Sent: Wednesday, March 04, 2015 9:05 AM To: Gregg Begell Subject: Baldwin Lake Mr. BeGell: I would appreciate your efforts to assist in the restoration of Baldwin Lake at the Arboretum in Arcadia. Having been a volunteer there for 35 years with over 7,000 hours of volunteer service I know how A much the visitors enjoyed the walks around the lake in the good old days. Virginia Stein CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comments Response to Comment Letter 35 (Virginia Stein — March 4, 2015) Response to Comment 35-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. IA County Flood Control District 11-328 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 36 Genevieve Osmena From: Martini Arden <martini1526@yahoo.com> Sent: Thursday, March 05, 2015 7:55 AM To: Genevieve Osmena Subject: Arboretum/Baldwin Lake To All Concerned: Please help save our Historic Baldwin Lake!! A Arboretum Volunteer/Rose Garden Martini Arden # Comments Response to Comment Letter 36 (Martini Arden — March 5, 2015) Response to Comment 36-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. IA County Flood Control District 11-330 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 37 Paige Anderson To: Laura Rocha Subject: RE: Save Baldwin Lake From: Kristine Hannibal [mailto:kmhanni(a)vahoo.coml Sent: Thursday, March 05, 2015 8:53 AM To: Gregg Begell; Genevieve Osmena Subject: Save Baldwin Lake Please see attached letter asking for your help ,in funding, to restore Baldwin Lake at the L.A. Arboretum to its orginal glory, and improve the conditions of the lake for all. Thank you so much, -Kristine Hannibal CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 37 3/5/2015 To Whom it may concern at L.A. County Department of Public Works, I'm writing to express my concern for the condition of Baldwin Lake at the L.A. Arboretum at this time and the future preservation of it as well. There seems to have been no proactive measures to keep this deterioration from happening in the past. The original retaining wall that was built by Lucky Baldwin is to the point of crumbling and is ready to fall over into the lake. This will cause further deterioration of the banks of the lake and will ultimately need to be fenced off to avoid any danger to visitors. There is also a need to clean out the mud and silt at the bottom of the lake that has built up over many years. This has made the lake very shallow, where it used to be 12-15ft deep, it is now only approx. 30inches deep. This clean-out would give the lake the capacity to hold more water. Currently the lake is filled with irrigation water, which is costly and doesn't help with the drought conditions in Southern California. It also covers up the deteriorating retaining wall and makes things appear as if all is well. There are also a number of pollutants that trickle into the lake from local runoff that needs to be addressed as well. Baldwin Lake is and has always been a major draw for visitors young and old that come to visit and explore the Arboretum. It is also a major focal point for the Queen Anne Cottage that sits on the bank of the Lake. With the Hugo Reid Adobe under construction and fenced off for the last 2 years, the last thing the Arboretum needs is another major attraction to be fenced off as well. I believe this would raise many questions from members and the general public as well. Lastly, there are many animals and fish that consider the lake to be a home and a source of food. Please consider adding Baldwin Lake to your final list of EWMP projects submitted for funding, it will be money, and time well spent with a lasting impact. Save Baldwin Lake. Thank you, Kristine Hannibal Los Voluntarios member IV to Comments Response to Comment Letter 37 (Kristine Hannibal — March 5, 2015) Response to Comment 37-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. a County Flood Control District 11-333 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 38 Paige Anderson To: Laura Rocha Subject: RE: Baldwin Lake at The LA Arboretum From: EMILY ROSEDALE[mailto:emily rosedale(o)vahoo.coml Sent: Sunday, March 08, 2015 11:31 PM To: Gregg Begell Subject: Baldwin Lake at The LA Arboretum Hello Mr. Gregg Be Gill, P.E.- I am writing you to please consider helping and include Baldwin Lake at The LA Arboretum in the Enhanced Watershed Management Plan. I believe that Baldwin Lake is a huge part of our community and is multi -dimensional in serving the community and also by being educational. We have an opportunity to educate children and the community about water conservation and we cannot do this without the help to fund its restoration. The restoration of Baldwin Lake will A both enhance watershed function AND serve the public with exceptional educational, ecological and scenic benefits. Annually, over 330,000 people visit Baldwin Lake; I myself have been going there since I was a child and hold the fondest memories of school field trips and family visits. My hope is this will continue as an Arcadia tradition and a historical landmark. Did you know? 1. Petrochemicals and other pollutants enter the Lake as unfiltered runoff from Arcadia's I B urban watershed. T 2. High velocity runoff flows and the unobstructed channel exacerbates shoreline erosion 11 C issues. D 3. Heavy siltation continues to reduce lake depth. The original depth of 12-15 feet has been I reduced to an average 30 inches. 4. Habitat quality and species diversity is degraded'by diminished lake depth and low water I E oxygen. 5. Shoreline erosion and structural collapse continue to degrade scenic quality and reduce F lake depth. 6. High bacteria counts result from abundant wildlife occupying a shallow lake with low G water circulation. I believe that this is a great opportunity to educate our youth and community about water H I conservation, Thank you for your time, Emily Comment Letter 38 Emily Rosedale-Kousoulis CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comments Response to Comment Letter 38: (Emily Rosedale-Kousoulis — March 8, 2015) Response to Comment 38-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. Response to Comment 38-B: Refer to page 3.8-7 of the PEIR that includes a general discussion of the water quality within the Rio Hondo/San Gabriel Watershed and how it has been affected by various pollutants. Table F-3 also includes applicable TMDLs within the Rio Hondo/San Gabriel Watershed. Response to Comment 38-C: Refer to page 3.8-18 of the PEIR that recognizes how urbanization can increase dry weather flows within the project area; Impact 3.8-3 on page 3.8-37 of the PEIR analyzes potential impacts related to erosion and siltation resulting from implementation of the EWMPs. Mitigation Measure HYDRO -4 has been added under Impact 3.8-3 as shown below to ensure any hydromodification impacts including those related to erosion and scour remain less than significant. HYDRO -4: Prior to approving a structural BMP, the implementing agencies shall conduct an evaluation of the potential hydromodification impacts of the project. The evaluation shall recommend design measures necessary to prevent or minimize any identified impacts, including flooding, erosion and/or scour. Design measures could include velocity dissipaters and bank re -enforcement components. Implementing agencies shall include these measures in moiect designs. Response to Comment 38-13: Impact 3.8-3 on page 3.8-37 of the PEIR analyzes potential impacts related to erosion and siltation resulting from implementation of the EWMPs. Should the EWMP group decide to implement Baldwin Park restoration as an EWMP project, details regarding lake depth remediation from heavy siltation would need to be analyzed further. LA County Flood Control District 11-336 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Comment 38-E: Implementation of the Enhanced Watershed Management Programs as required by the MS4 Permit will involve multi -benefit regional projects that retain stormwater and non-stormwater runoff. Such benefits of water quality improvement also include habitat quality improvements. Refer to page 3.1-11 of the PEIR, which states that implementation of the structural BMPs as part of the EWMPs is anticipated to have an overall positive impact on the aesthetic environment. For example, there is anticipated to be more green space areas and less impermeable surfaces from pavement and concrete, thereby enhancing the level of greenness in the watersheds. Should the EWMP group decide to implement Baldwin Park restoration as an EWMP project, details regarding habitat restoration would need to be analyzed further. Response to Comment 38-F: Impact 3.8-3 on page 3.8-37 of the PEIR analyzes potential impacts related to erosion and siltation resulting from implementation of the EWMPs. Should the EWMP group decide to implement Baldwin Park restoration as an EWMP project, details regarding lake depth remediation from heavy siltation would need to be analyzed further. Implementation of the Enhanced Watershed Management Programs as required by the MS4 Permit will involve multi -benefit regional projects that retain stormwater and non-stormwater runoff. Such benefits of water quality improvement also include habitat quality improvements. Refer to page 3.1-11 of the PEIR, which states that implementation of the structural BMPs as part of the EWMPs is anticipated to have an overall positive impact on the aesthetic environment. For example, there is anticipated to be more green space areas and less impermeable surfaces from pavement and concrete, thereby enhancing the level of greenness in the watersheds. Should the EWMP group decide to implement Baldwin Park restoration as an EWMP project, details regarding habitat restoration would need to be analyzed further. Response to Comment 38-G: As discussed on page 3.8-7 of the Draft PEIR, the Rio Hondo/San Gabriel Watershed in which Baldwin Lake is located, has several priority pollutants and includes not only bacteria but also nutrients, trash, metals, and sediment impacted by metals and organic compounds (DDT, PCBs, PAHs). The BMP strategy in the Upper Los Angeles River watershed and Rio Hondo watershed includes well over a hundred planned regional and centralized retention and infiltration BMPs that take advantage of the favorable groundwater recharge characteristics in defined areas of the watershed. Also planned are centralized treatment wetlands and bioinfiltration BMPs in parks and open spaces with favorable subsurface soils that promote higher infiltration rates. The BMP strategy also includes distributed smaller BMPs located throughout the urbanized areas of the watershed as retrofits in existing developments and streets. LFDs to comply with dry -weather bacteria TMDLs will also be included. Should the EWMP group decide to implement Baldwin Park restoration as an EWMP project, details regarding high bacteria counts from abundant wildlife occupying a shallow lake with low water circulation would need to be analyzed further.. a County Flood Control District 11-337 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Comment 38-H: Refer to page 2-1 of the PEIR, which states that educational and outreach measures would be implemented as part of EWMP non-structural BMPs. LA County Flood Control District 11-338 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 39 Genevieve Osmena From: Margaux Viera <gauxviera@gmail.com> Sent: Sunday, March 08, 2015 1:21 PM To: Genevieve Osmena Cc: Sandy Snider; Pam Warner; Richard Schulhof; richard.schulhof@thearboretum.org; Ken Hill; Kenneth Hill Subject: Fwd: Speech- Final Draft Hello Genevieve, Here is a copy of the speech I prepared to say at the end of tomorrow's meeting. Thank you, Mrs. Margaux L. Viera Good morning. My name is Margaux Viera. I am the great great great granddaughter of Elias Jackson "Lucky" Baldwin, who once owned Rancho Santa Anita and what is now known as, The Los Angeles Arboretum & Botanical Gardens. I am honored to be a part of The Los Angeles Arboretum's past, present and future. I am on the board of trustees and am part of the, "Save Baldwin Lake" task force. Baldwin Lake was once a natural reservoir for artesian water. Lucky Baldwin set a gold standard for water conservation when he deepened the lake basin in the late 1880's and created a water retention system that helped him irrigate acres and acres of crops. Now historic Baldwin Lake is in serious trouble. We can return Baldwin Lake to its water retention function as part of the Enhanced Watershed Management Plan, and we can also use Baldwin Lake to educate the public that the history of responsible use of water goes back much further than most people realize. VJ Comment Letter 39 Please help to protect Baldwin Lake and it's beautiful natural resource. The Los Angeles Arboretum is very special to my family as well as to the hundreds of thousands of individuals, families and school children who visit it each year. Thank you. z A cont to Comments Response to Comment Letter 39: (Margaraux Viera — March 9, 2015) Response to Comment 39-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. a County Flood Control District 11-341 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 40 Paige Anderson To: Laura Rocha Subject: RE: In support of Baldwin Lake restoration From: Robin Kirk [mailto:robinkirkl(a)vahoo.coml Sent: Monday, March 09, 2015 4:54 PM To: Gregg Begell Subject: In support of Baldwin Lake restoration Dear Mr. Begell: - As a volunteer/docent of nearly ten years at the Arboretum I have seen the rapid degradation of Baldwin Lake. Until now, we have felt there was no hope for its restoration. I would like to tell the visiting public that we do have hope, that we care about this resource and as a County facility we are stepping up to the responsibility of its desperately needed restoration. Most importantly, because the lake is a collection basin for Arcadia's runoff, we have allowed its quality to be compromised with unfiltered pollutants, destabilization of its banks and siltation that threaten the viability of its storage capacity. The inclusion of the Lake in the Rio-Hondo/San Gabriel EWMP will finally give us the means to take responsibility for our lake by managing the runoff productively enabling us to restore the needed depth and give us much needed water storage capacity and aquifer recharge. We need water storage capacity and we need to be responsible for the quality of the water we share with the community and provide for our wildlife. The inclusion of the Lake in the EWMP is a major step toward its restoration enabling the Arboretum to meet the needs of our community for a lake with water storage capacity and thereby promoting its scenic, wildlife and historic value. Thank you for your support. Sincerely, Robin A. Kirk CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Is to Comments Response to Comment Letter 40: (Robin Kirk — March 9, 2015) Response to Comment 40-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. The restoration of Baldwin Lake is shown as a potential priority project to be implemented as part of the Rio Hondo/San Gabriel River EWMP in Figure 2-13 of the PEIR. More site investigations by implementing agencies are needed to fully vet the proposed project and define the project scope needed to satisfy the EWMP's requirements. The City of Arcadia is the primary agency who will benefit from a water quality project at the Baldwin Lake. The City of Arcadia will likely play a major role in the decision to implement an EWMP project at Baldwin Lake. a County Flood Control District 11-343 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 41 Paige Anderson To: Laura Rocha Subject: RE: Comments to LACFCD Draft PEIR Enhanced Watershed Management Programs due 3.16.2015 From: Joyce Dillard[mailto:dillardiovice(a)vahoo.coml Sent: Monday, March 16, 2015 3:50 PM To: Gregg Begell Su bj act: Comments to LACFCD Draft PEI R Enhanced Watershed Management Programs due 3.16.2015 Attached. Joyce Dillard P.O. Box 31377 Los Angeles, CA 90031 CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comment Letter 41 Comments to LACFCD Draft PER Enhanced Watershed Management Programs due 3.16.2015 You state: And /_1T The 2012 MS4 Permit for Los Angeles County gives Permittees the option of implementing an innovative approach to Permit compliance through development of an Enhanced Watershed Management Program (EWMP). The EWMPs will identify potential and priority structural and non-structural Best Management Practices (BMPs) within the region's stormwater collection system to improve runoff water quality. The LACFCD has limited jurisdictional authority for ordinance and code enactment or enforcement and therefore is limited in nonstructural BMPs to education and outreach measures. The structural watershed control measures that will be implemented by the LACFCD will be multi -benefit stormwater projects that emphasize flood risk mitigation and water conservation and supply. LAI The LACFCD has limited jurisdictional authority for ordinance and code enactment or enforcement and therefore is limited in nonstructural BMPs to education and outreach measures. The structural watershed control measures that will be implemented by the LACFCD will be multi -benefit stormwater projects that emphasize flood risk mitigation and water conservation and supply. The LACFCD has a vested interest in increasing opportunities for stormwater capture and groundwater recharge as a means of assisting local water supply augmentation. The LACFCD will be working with the applicable Permittees and other stakeholders in all 12 EWMP watersheds to develop such projects. The EWMPs will be implemented by the Permittees that have jurisdiction within each EWMP area. The implementing agencies will be responsible for the contents of the EWMPs affecting their jurisdictions and for implementing the projects developed by the EWMPs. Comments: We do not agree that the LA County Flood Control District LACFCD qualifies as a LEAD AGENCY. CEQA 15051(d) states: Comment Letter 41 Where the provisions of subdivisions (a), (b), and (c) leave two or more public agencies with a substantial claim to be the Lead Agency, the public agencies may by agreement designate an agency as the Lead Agency. An agreement may also provide for cooperative efforts by two or more agencies by contract, joint exercise of powers, or similar devices. The WATERSHED MANAGEMENT GROUPS, through the Notices of Intent and/or Memorandums of Understanding have determined Lead Agencies as: 1. Ballona Creek- City of Los Angeles A 2. Beach Cities- City of Redondo Beach cont 3. Dominguez Channel- City of Los Angeles 4. Malibu Creek- City of Calabasas 5. Marina del Rey Harbor -County of Los Angeles 6. North Santa Monica Bay Coastal- City of Malibu 7. Palos Verdes Peninsula- City of Rancho Palos Verdes 8. Rio Hondo/San Gabriel River- City of Arcadia (not City of Sierra Madre) 9. Santa Monica Bay- Jurisdictional Groups 2 & 3- City of Los Angeles 10. Upper Los Angeles River- City of Los Angeles 11. Upper San Gabriel River- County of Los Angeles 12. Upper Santa Clara River- City of Santa Clarita You state: The EWMPs will identify management strategies including hundreds of structural Best Management Practices (BMPs) that may be designed and implemented by the Permittees to meet permit compliance objectives. Comments: APPENDIX G-EWMP Proposed BMP and Priority Project Data identified proposed projects, making this PEIR irrelevant as a programming document. They are site- specific. You state: The PEIR analysis is not intended to focus on the site-specific construction and operation details of each management strategy and project included in the EWMP. Rather, this PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis outlines mitigation strategies to be followed by implementing agencies to avoid or minimize impacts wherever feasible. Comments: Comment Letter 41 URBAN RUNOFF POLLUTION is mentioned twice in the MS4 PERMIT: /_TTI And ATTACHMENT A—DEFINITIONS Structural BMP Any structural facility designed and constructed to mitigate the adverse impacts of storm water and urban runoff pollution (e.g. canopy, structural enclosure). The category may include both Treatment Control BMPs and Source Control BMPs a. Permit Structure: Watershed Management Approach and Total Maximum Daily Load (TMDL) Implementation A single permit will ensure consistency and equitability in regulatory requirerr within Los Angeles County, while watershed -based sections within the single permit will provide flexibility to tailor permit provisions to address distinct watershed characteristics and water quality issues. Additionally, an internal watershed -based structure comports with the Regional Water Board's Watershed Management Initiative, its watershed -based TMDL requirements, and the LACFCD's funding initiative passed in Assembly Bill 2554. Watershed -based sections will help promote watershed -wide solutions to address water quality problems, which in many cases are the most efficient and cost-effective means to address storm water and urban runoff pollution. Project Description The 12 EWMPs will vary for each watershed group, but will generally provide the opportunity for Permittees to customize their stormwater programs to achieve compliance with applicable receiving water limitations (RWLs) and water -quality -based effluent limits (WQBELs) in accordance with the MS4 Permit through implementation of stormwater best management practices (BMPs) or watershed control measures. BMPs vary in function and type, with each BMP providing unique design characteristics and benefits from implementation. The overarching goal of BMPs in the EWMP is to reduce the impact of stormwater and non- stormwater on receiving water quality and address the water quality priorities as defined by the MS4 Permit PEIR does not have a main focus on Receiving Water compliance required by the MS4 Permit and intention of Enhanced Watershed Management Plans. This PEIR is unnecessary. C cont Comment Letter 41 You state: LACFCD is the CEQA Lead Agency for this PEIR. This PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual EWMP projects Comments: LACFCD is not the Lead Agency for any EWMP Watershed Management Group. This could only apply to their own projects. This document covers URBAN RUNOFF and would not streamline any review. You state: The timeline identified in the MS4 Permit requires that Permittees submit the EWMP to the LARWQCB by June 28, 2015, in order to be in compliance with the permit conditions. The LACFCD recognizes that implementation of the EWMPs may potentially result in changes to environmental conditions. As a result, the LACFCD has prepared this Program Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the EWMPs. The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior to submittal of the EWMPs. The EWMPs will be submitted by each EWMP group to the LARWQCB. This PEIR describes and evaluates each of the EWMPs being prepared by the Permittees collectively. The discretionary action prompting the need for CEQA compliance is the submittal of the completed EWMPs to the LARWQCB. The EWMPs will identify management strategies including hundreds of structural Bes Management Practices (BMPs) that may be designed and implemented by the Permittees to meet permit compliance objectives. A few of the BMPs are currently well defined but most are yet to be fully developed under the EWMPs. A set of priority BMPs will be detailed in each of the EWMPs; these are being developed in parallel with the PEIR. The PEIR describes the details that are available for each of the EWMPs currently under preparation by the EWMP working groups. Comments: LACFCD and the Los Angeles County Board of Supervisors have no authority over the municipal GENERAL PLAN and Its Elements, required by each city. Neither body represents a METROPOLITAN PLANNING ORGANIZATION with its required Regional Housing Needs Assessment which related to infrastructure needs assessment. u E Comment Letter 41 CITY OF LOS ANGELES has not prepared its GENERAL PLAN UPDATE or the E CIRCULATION ELEMENT, both critical to any MS4 compliance issues. cont You state: T The PEIR provides the LACFCD a foundation for any necessary future environmental review documents that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. In addition, the PEIR can provide several advantages during the development and implementation of the EWMPs that may include: More exhaustive consideration of effects and alternatives than would be practical in an environmental impact report (EIR) for an individual BMP project. Consideration of cumulative impacts that might not be evident in a case-by- case or project -by -project analysis. Consideration by LACFCD as Lead Agency of broad policy alternatives and program -wide mitigation measures early in the process when there is greater flexibility to deal with basic problems or cumulative impacts. Comments: The PEIR should be limited to LACFCD projects ONLY and all other projects in Appendix G should be removed. You state: Instead, the PEIR frames the nature and magnitude of the expected environmental impacts associated with these proposed EWMP projects and identifies program mitigation measures to reduce the impacts of the projects as proposed. Comments: The following Mitigation Measures are not under the LACFCD jurisdiction, per the limited jurisdiction over for ordinance and code enactment or enforcement: Aesthetics Mitigation Measures AES -1: Aboveground structures shall be designed to be consistent with local zoning codes and applicable design guidelines and to minimize features that contrast with neighboring development. AES -2: Implementing agencies shall develop BMP maintenance plans that are approved concurrently with each structural BMP approval. The maintenance plans must include measures to ensure functionality of the structural BMPs for G Comment Letter 41 the life of the BMP. These plans may include general maintenance guidelines that apply to a number of smaller distributed BMPs. Air Quality Mitigation Measures AIR -1: Implementing agencies shall require for large Regional or Centralized BMPs the use of low -emission equipment meeting Tier II emissions standards at a minimum and Tier III and IV emissions standards where available as CARB- required emissions technologies become readily available to contractors in the region. AIR -2: For large construction efforts that may result in significant air emissions, implementing agencies shall encourage contractors to use lower -emission equipment through the bidding process where appropriate. AIR -3: For large construction efforts associated with Regional or Centralized BMPs, implementing agencies shall conduct a project -specific LST analysis where necessary to determine local health impacts to neighboring land uses. Where it is determined that construction emissions would exceed the applicable LSTs or the most stringent applicable federal or state ambient air quality standards, the structural BMP project shall reduce its daily construction intensity (e.g., reducing the amount of equipment used daily, reducing the amount of soil graded/excavated daily) to a level where the structural BMP project's construction emissions would no longer exceed SCAQMD's LSTs or result in pollutant emissions that would cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standards. AIR -4: During planning of structural BMPs, implementing agencies shall assess the potential for nuisance odors to affect a substantial number of people. BMPs that minimize odors shall be considered the priority when in close proximity to sensitive receptors. Biological Resources Mitigation Measures BI0-1: Prior to approving a Regional or Centralized BMP., the Permittee shah conduct an evaluation of the suitability of the BMP location. Appropriate BMP sites should avoid impacting large areas of native habitats including upland woodlands and riparian forests that support sensitive species to the extent feasible. The evaluation shall include an assessment of potential downstream impacts resulting from flow diversions. BI0-2: Prior to ground disturbing activities in areas that could support sensitive biological resources, a habitat assessment shall be conducted by a qualified biologist to determine the potential for special -status wildlife species to occur G cont Comment Letter 41 within affected areas, including areas directly or indirectly impacted by construction or operation of the BMPs. BI0-3: If a special -status wildlife species is determined to be present or potentially present within the limits of construction activities, a qualified biologist shall conduct pre -construction surveys of proposed work zones and within an appropriately sized buffer around each area as determined by a qualified biologist within 14 days prior to ground disturbing activities. Any potential habitat capable of supporting a special -status wildlife species shall be flagged for avoidance if feasible. BI0-4: If avoidance of special -status species or sensitive habitats that could support special -status species (including, but not limited to, critical habitat, riparian habitat, and jurisdictional wetlands/waters) is not feasible, the Permittee shall consult with the appropriate regulating agency (USAGE/USFWS or CDFM to determine a strategy for compliance with the Endangered Species Act, California Fish and Game Code, and other regulations protecting special -status species and sensitive habitats. The Permittee shall identify appropriate impact minimization measures and compensation for permanent impacts to sensitive habitats and species in consultation with regulatory agencies. Construction of the project will not begin until the appropriate permits from the regulatory agencies are approved. BI0-5: If construction and vegetation removal is proposed between February 1 and August 31, a qualified biologist shall conduct a pre -construction survey for breeding and nesting birds and raptors within 500 -feet of the construction limits to determine and map the location and extent of breeding birds that could be affected by the project. Active nest sites located during the pre -construction surveys shall be avoided until the adults and young are no longer reliant on the nest site for survival as determined by a qualified biologist. BI0-6: All construction areas, staging areas, and right-of-ways shall be staked, flagged, fenced, or otherwise clearly delineated to restrict the limits of construction to the minimum necessary near areas that may support special - status wildlife species as determined by a qualified biologist. BI0-7: Prior to construction in areas that could support special status plants, a qualified botanist shall conduct a pre -construction floristic inventory and focused rare plant survey of project areas to determine and map the location and extent of special -status plant species populations within disturbance areas. This survey shall occur during the typical blooming periods of special -status plants with the potential to occur. The plant survey shall follow the CDFW Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (November 24, 2009). G cont Comment Letter 41 BI0-8: If temporary construction -related impacts to special -status plant populations are identified within a disturbance area, the implementing agencies shall prepare and implement a special -status species salvage and replanting plan. The salvage and replanting plan shall include measures to salvage, replant, and monitor the disturbance area until native vegetation is re-established under the direction of CDFW and USFWS. BI0-9: Prior to construction, a qualified wetland delineator shall be retained to conduct a formal wetland delineation in areas where potential jurisdictional resources (i.e., wetlands or drainages) subject to the jurisdiction of USACE, RWQCB, and CDFW, may be affected by the project. If jurisdictional resources are identified in the EWMP area and would be directly or indirectly impacted by individual projects, the qualified wetland delineator shall prepare a jurisdictional delineation report suitable for submittal to USACE, RWQCB, and CDFW for purposes of obtaining the appropriate permits. Habitat mitigation and compensation requirements shall be implemented prior to construction in accordance with Mitigation Measure BIO -4. BIO -10: Oak trees and other protected trees shall be avoided to the extent feasible. If trees may be impacted by project construction, a certified arborist shall conduct a tree inventory of the construction impact area. If any oak trees or other protected trees will be impacted by BMP construction, the implementing agency shall obtain any required County or City permits. Cultural Resources Mitigation Measures CUL -1: For individual EWMP projects that could impact buildings or structures (including infrastructure) 45 years old or older, implementing agencies shall ensure that a historic built environment survey is conducted or supervised by a qualified historian or architectural historian meeting the Secretary of the Interior's Professional Qualification Standards for Architectural History. Historic built environment resources shall be evaluated for their eligibility for listing in the CRHR or local register prior to the implementing agency's approval of project plans. If eligible resources that would be considered historical resources under CEQA are identified, demolition or substantial alteration of such resources shall be avoided. If avoidance is determined to be infeasible, the implementing agency shall require the preparation of a treatment plan to include, but not be limited to, photo -documentation and public interpretation of the resource. The plan will be submitted to the implementing agency for review and approval prior to implementation. CUL -2: Implementing agencies shall ensure that individual EWMP projects that require ground disturbance shall be subject to a Phase I cultural resources inventory on a project -specific basis prior to the implementing agency's approval G cont Comment Letter 41 of project plans. The study shall be conducted or supervised by a qualified archaeologist, defined as an archaeologist meeting the Secretary of the Interior's Professional Qualifications Standards for Archaeology, and shall be conducted in consultation with the local Native American representatives expressing interest. The cultural resources inventory shall include a cultural resources records search to be conducted at the South Central Coastal Information Center; scoping with the NAHC and with interested Native Americans identified by the NAHC; a pedestrian archaeological survey where deemed appropriate by the qualified archaeologist; and formal recordation of all identified archaeological resources on California Department of Parks and Recreation 523 forms and significance evaluation of such resources presented in a technical report following the guidelines in Archaeological Resource Management Reports (ARMR): Recommended Contents and Format, Department of Parks and Recreation, Office of Historic Preservation, State of California, 1990. If potentially significant archaeological resources are encountered during the survey, the implementing agency shall require that the resources are evaluated by the qualified archaeologist for their eligibility for listing in the CRHR and for significance as a historical resource or unique archaeological resource per CEQA Guidelines Section 15064.5. Recommendations shall be made for treatment of these resources if found to be significant, in consultation with the implementing agency and the appropriate Native American groups for prehistoric resources. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred manner of mitigation to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project re-route or re -design, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, which may include data recovery or other appropriate measures, in consultation with the implementing agency, and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. CUL -3: The implementing agency shall retain archaeological monitors during ground -disturbing activities that have the potential to impact archaeological resources qualifying as historical resources or unique archaeological resources, as determined by a qualified archaeologist in consultation with the implementing agency, and any local Native American representatives expressing interest in the project. Native American monitors shall be retained for projects that have a high potential to impact sensitive Native American resources, as determined by the implementing agency in coordination with the qualified archaeologist. CUL -4: During project -level construction, should subsurface archaeological resources be discovered, all activity in the vicinity of the find shall stop and a G cont Comment Letter 41 qualified archaeologist shall be contacted to assess the significance of the find according to CEQA Guidelines Section 15064.5. If any find is determined to be significant, the archaeologist shall determine, in consultation with the implementing agency and any local Native American groups expressing interest, appropriate avoidance measures or other appropriate mitigation. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred means to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project re-route or re -design, project cancellation, or identification of protection measure: such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, such as data recovery or other appropriate measures, in consultation with the implementing agency and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. CUL -5: For individual structural BMP projects that require ground disturbance, the implementing agency shall evaluate the sensitivity of the project site for paleontological resources. If deemed necessary, the implementing agency shall retain a qualified paleontologist to evaluate the project and provide recommendations regarding additional work, potentially including testing or construction monitoring. CUL -6: In the event that paleontological resources are discovered during construction, the implementing agency shall notify a qualified paleontologist. The paleontologist will evaluate the potential resource, assess the significance of the find, and recommend further actions to protect the resource. CUL -7: The implementing agency shall require that, if human remains are uncovered during project construction, work in the vicinity of the find shall cease and the County Coroner shall be contacted to evaluate the remains, following the procedures and protocols set forth in Section 15064.5 (e)(1) of the CEQA Guidelines. If the County Coroner determines that the remains are Native American, the Coroner will contact the Native American Heritage Commission, in accordance with Health and Safety Code Section 7050.5, subdivision (c), and Public Resources Code 5097.98 (as amended by AB 2641). The NAHC will then designate a Most Likely Descendant of the deceased Native American, who will engage in consultation to determine the disposition of the remains. Geologic and Mineral Resources Mitigation Measures G cont Comment Letter 41 GEO-1: Prior to approval of infiltration BMPs, implementing agencies shall conduct a geotechnical investigation of each infiltration BMP site to evaluate infiltration suitability. If infiltration rates are sufficient to accommodate an infiltration BMP, the geotechnical investigation shall recommend design measures necessary to prevent excessive lateral spreading that could destabilize neighboring structures. Implementing agencies shall implement these measures in project designs. GEO-2: Prior to installing BMPs designed to recharge local groundwater supplies, the Implementing Agency shall notify local groundwater managers including the Upper Los Angeles River Area Water Master, the Water Replenishment District of Southern California, or the San Gabriel Water Master as well as local water producers such as local municipalities and water companies. The Implementing Agency shall coordinate BMP siting efforts with groundwater managers and producers to mitigate high groundwater levels while increasing local water supplies. Hazards and Hazardous Materials Mitigation Measures HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the individual BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. HAZ-2: Prior to the initiation of any construction requiring ground -disturbing activities in areas where hazardous material use or management may have occurred, the implementing agencies shall complete a Phase I Environmental Site Assessment (ESA) in accordance with American Society for Testing and Materials (ASTM) Standard E1527-13 for each construction site. Any recommended follow up sampling (Phase II activities) set forth in the Phase I ESA shall be implemented prior to construction. The results of Phase II studies, necessary, shall be submitted to the local overseeing agency and any required G cont Comment Letter 41 remediation or further delineation of identified contamination shall be completed prior to commencement of construction. HAZ-3: Implementing Agencies shall require that those BMPs that are within an airport land use plan area are compatible with criteria specified in FAA Advisory Circular No: 150/5200-33B (FAA, 2007). If the proposed BMP is within the minimum separation criteria, the Implementing Agency shall consult with the airport and collaboratively evaluate whether the potential increase in wildlife hazards can be mitigated. Hydrology and Water Quality Mitigation Measures HYDRO -1: Prior to approving an infiltration BMP, the Permittee shall conduct an evaluation of the suitability of the BMP location. Appropriate infiltration BMP sites should avoid areas with low permeability where recharge could adversely affect neighboring subsurface infrastructure. HYDRO -2: Prior to approving an infiltration BMP, the Permitee shall identify pre- treatment technologies, type, and depth of filtration media; depth to groundwater; and other design considerations necessary to prevent contaminants from impacting groundwater quality. The design shall consider stormwater quality data within the BMP's collection area to assess the need and type of treatment and filtration controls. Local design manuals and ordinances requiring minimum separation distance to groundwater shall also be met as part of the design. HYDRO -3: Prior to the installation of an infiltration BMP, the Permitee shall conduct a database review for contaminated groundwater sites within a quarter mile of the proposed infiltration facility. The Permittee shall identify whether any contaminated groundwater plumes are present and whether coordination with tt local and state environmental protection overseeing agency and responsible party is warranted prior to final design of infiltration facility. Noise Mitigation Measures NOISE -1: The implementing agencies shall implement the following measures during construction as needed: Include design measures necessary to reduce the construction noise levels where feasible. These measures may include noise barriers, curtains, or shields. Place noise -generating construction activities (e.g., operation of compressors and generators, cement mixing, general truck idling) as far as possible from the nearest noise -sensitive land uses. Locate stationary construction noise sources as far from adjacent noise - sensitive receptors as possible. G cont Comment Letter 41 • If construction is to occur near a school, the construction contractor shall coordinate the with school administration in order to limit disturbance to the campus. Efforts to limit construction activities to non -school days shall be encouraged. • For the centralized and regional BMP projects located adjacent to noise - sensitive land uses, identify a liaison for these off-site sensitive receptors, such as residents and property owners, to contact with concerns regardinc construction noise and vibration. The liaison's telephone number(s) shall be prominently displayed at construction locations. • For the centralized and regional BMP projects located adjacent to noise - sensitive land uses, notify in writing all landowners and occupants of properties adjacent to the construction area of the anticipated construction schedule at least 2 weeks prior to groundbreaking. NOISE -2: All structural BMPs that employ mechanized stationary equipment that generate noise levels shall comply with the applicable noise standards established by the implementing agency with jurisdiction over the structural BMP site. The equipment shall be designed with noise -attenuating features (e.g., enclosures) and/or located at areas (e.g., belowground) where nearby noise - sensitive land uses would not be exposed to a perceptible noise increase in their noise environment. Public Services and Recreation Mitigation Measures PS -1: The Permittee implementing the EWMP project shall provide reasonable advance notification to the service providers such as fire, police, local businesses, home owners and residents of adjacent to and within areas potentially affected by the proposed EWMP project about the nature, extent and duration of construction activities. Interim updates should be provided to inform them of the status of the construction activities. Transportation and Circulation Mitigation Measures TRAF-1: For projects that may affect traffic, implementing agencies shall require that contractors prepare a construction traffic control plan. Elements of the plan should include, but are not necessarily limited to, the following: • Develop circulation and detour plans to minimize impacts to local street circulation. Use haul routes minimizing truck traffic on local roadways to the extent possible. • To the extent feasible, and as needed to avoid adverse impacts on traffic flow, schedule truck trips outside of peak morning and evening commute hours. • Install traffic control devices as specified in Caltrans' Manual of Traffic Controls for Construction and Maintenance Work Zones where needed to G cont Comment Letter 41 maintain safe driving conditions. Use flaggers and/or signage to safely direct traffic through construction work zones. Coordinate with facility owners or administrators of sensitive land uses such as police and fire stations, hospitals, and schools. Provide advance notification to the facility owner or operator of the timing, location, and duration of construction activities. Utilities and Service Systems Mitigation Measures UTIL-1: Prior to approval of BMPs, implementing agencies shall evaluate the potential for impacts to downstream beneficial uses including surface water rights. Implementing agencies shall not approve BMPs that result in preventing access to previously appropriated surface water downstream. UTIL-2: Implementing agencies shall encourage construction contractors to recycle construction materials and divert inert solids (asphalt, brick, concrete, dirt, fines, rock, sand, soil, and stone) from disposal in a landfill where feasible. Implementing agencies shall incentivize construction contractors with waste minimization goals in bid specifications where feasible. Land Use and Agriculture Mitigation Measures were omitted as jurisdiction belongs to the Municipalities and to the County of Los Angeles for the unincorporated areas. G cont Alternatives should be based on Projects under the jurisdictional authority of the I H LACFCD only. Joyce Dillard P.O. Box 31377 Los Angeles, CA 90031 to Comments Response to Comment Letter 41 (Joyce Dillard — March 16, 2015) Response to Comment 41-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The LACFCD, as a regional agency, is a member of each of the 12 EWMP working groups, and as such provides a commonality within each EWMP group. However, LACFCD does not have a special status or authority designated by the MS4 Permit over any of the other Permittees. The LACFCD will be working with the applicable Permittees in all 12 EWMP watersheds as an equal partner to identify the types and locations of BMPs needed to achieve permit compliance within each watershed. The timeline identified in the MS4 Permit requires that Permittees submit the EWMP to the LARWQCB by June 28, 2015, in order to be in compliance with the permit conditions. The LACFCD recognizes that implementation of the EWMPs may potentially result in changes to environmental conditions. The discretionary action prompting the need for CEQA compliance is the submittal of the completed EWMPs to the LARWQCB. As a result, the LACFCD, as lead agency, has prepared this Program Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the EWMPs. The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior to submittal of the EWMPs. The EWMPs will be submitted by each EWMP group to the LARWQCB. Each Permittee may rely upon this PEIR, as appropriate, for BMPs within its jurisdiction. Individual projects will undergo subsequent CEQA analysis and documentation, as appropriate under the requirements of CEQA, by implementing agencies. The determinations of significance after mitigation in the PEIR apply to the LACFCD and other implementing agencies that choose to rely on this PEIR and the mitigation measures proposed herein. This PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual EWMP projects. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of their proposed projects. Response to Comment 41-B: The PEIR acknowledges that most of the projects to be included in the EWMPs are either currently undefined or currently under development. The PEIR explains that EWMPs are being prepared that will contain road maps to permit compliance for each of the 12 watersheds, without a County Flood Control District 11-359 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments yet being fully detailed. Appendix G includes location information about potential priority projects available at the time of publication. The use of a PEIR pursuant to CEQA Guidelines Section 15168 is intended to evaluate broad-based impacts early in the planning process and is the appropriate CEQA compliance for the EWMPs at this time. This PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual EWMP projects, as they identified and further refined. As individual projects identified in the EWMPs are moved forward, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects as appropriate or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of their proposed projects. The PEIR provides the LACFCD a foundation for any necessary future environmental review documents that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. Response to Comment 41-C: As noted on page 1-1 of the PEIR, the Regional Water Quality Control Board issued Order No. R4-2012-0175; NPDES No. CAS004001 in December 2012 covering discharges from multiple municipalities within the Los Angeles Region. The requirements of the MS4 permit are described in Section 1.2 of the PEIR. A primary objective of the proposed program noted on page 2-2 is to comply with the permit requirements. The EWMPs include a methodology required by the MS4 permit to evaluate the effectiveness of the BMPs as they are implemented. The commenter's opinion about the PEIR does not have the main focus on Receiving Water compliance required by the MS4 Permit and intention of Enhanced Watershed Management Plans does not address the adequacy of the PEIR. The PEIR does not critique the effectiveness on Receiving Water compliance required by the MS4 Permit, but rather it evaluates the potential environmental effects that could result from implementing the types of projects proposed in the EWMPs. Response to Comment 41-1): The LACFCD, as a regional agency, is a member of each of the 12 EWMP working groups, and as such provides a commonality within each EWMP group. However, LACFCD does not have a special status or authority designated by the MS4 Permit over any of the other Permittees. The LACFCD will be working with the applicable Permittees in all 12 EWMP watersheds as an equal partner to identify the types and locations of BMPs needed to achieve permit compliance within each watershed. The timeline identified in the MS4 Permit requires that Permittees submit the EWMP to the LARWQCB by June 28, 2015, in order to be in compliance with the permit conditions. The LACFCD recognizes that implementation of the EWMPs may potentially result in changes to environmental conditions. The discretionary action prompting the need for CEQA compliance is the submittal of the completed EWMPs to the LARWQCB. As a result, the LACFCD, as lead agency, has prepared this Program Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the EWMPs. The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior LA County Flood Control District 11-360 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments to submittal of the EWMPs. The EWMPs will be submitted by each EWMP group to the LARWQCB. Each Permittee may rely upon this PEIR, as appropriate, for BMPs within its jurisdiction. Individual projects will undergo subsequent CEQA analysis and documentation, as appropriate under the requirements of CEQA, by implementing agencies. The determinations of significance after mitigation in the PEIR apply to the LACFCD and other implementing agencies that choose to rely on this PEIR and the mitigation measures proposed herein. This PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual EWMP projects. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is needed. Response to Comment 41-E: The Draft PEIR acknowledges on page 1-3 that LACFCD does not have a special status or authority designated by the MS4 Permit over any of the other Permittees. The LACFCD will be working with the applicable Permittees, including with the City of Los Angeles, in the EWMP watersheds as an equal partner to identify the types and locations of BMPs needed to achieve permit compliance within each watershed. The LACFCD, as a regional agency, is a member of each of the 12 EWMP working groups, and as such provides a commonality within each EWMP group. Although each Permittee will be responsible for its own General Plan preparation and MS4 permit compliance, the LACFCD has prepared this Program Environmental Impact Report (PEIR) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the EWMPs throughout the County. Each Permittee may rely upon this PEIR, as appropriate, for BMPs within its jurisdiction. Individual projects will undergo subsequent CEQA analysis and documentation, as appropriate under the requirements of CEQA, by implementing agencies. The determinations of significance after mitigation in the PEIR apply to the LACFCD and other implementing agencies that choose to rely on this PEIR and the mitigation measures proposed herein. This PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual EWMP projects. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is needed. Response to Comment 41-F: The MS4 Permit Section VI.C. Lg (page 48) allows for watersheds to collaborate in preparing an EWMP to achieve Permit compliance with RWLs. The intent of the EWMP is to comprehensively evaluate opportunities for collaboration on multi -benefit regional projects that retain MS4 discharges and also address flood control and/or water supply within the participating Permittees' collective jurisdictional boundaries. The LACFCD will be working with the a County Flood Control District 11-361 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments applicable Permittees in all 12 EWMP watersheds as an equal partner to identify the types and locations of BMPs needed to achieve permit compliance within each watershed. The LACFCD, as a regional agency, is a member of each of the 12 EWMP working groups, and as such provides a commonality within each EWMP group. The LACFCD will be working with the applicable Permittees in all 12 EWMP watersheds as an equal partner to identify the types and locations of BMPs needed to achieve permit compliance within each watershed. The LACFCD recognizes that implementation of the EWMPs may potentially result in changes to environmental conditions. The discretionary action prompting the need for CEQA compliance is the submittal of the completed EWMPs to the LARWQCB. As a result, the LACFCD, as lead agency, has prepared this Program Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the EWMPs. The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior to submittal of the EWMPs. The EWMPs will be submitted by each EWMP group to the LARWQCB. Each Permittee may rely upon this PEIR, as appropriate, for BMPs within its jurisdiction. Individual projects will undergo subsequent CEQA analysis and documentation, as appropriate under the requirements of CEQA, by implementing agencies. The determinations of significance after mitigation in the PEIR apply to the LACFCD and other implementing agencies that choose to rely on this PEIR and the mitigation measures proposed herein. This PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual EWMP projects. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is needed. Response to Comment 41-G: The LACFCD, as a regional agency, is a member of each of the 12 EWMP working groups, and as such provides a commonality within each EWMP group. However, LACFCD does not have a special status or authority designated by the MS4 Permit over any of the other Permittees and cannot enforce those mitigation measures outside their jurisdiction. The LACFCD will be working with the applicable Permittees in all 12 EWMP watersheds as an equal partner to identify the types and locations of BMPs needed to achieve permit compliance within each watershed. Each Permittee may choose to rely upon this PEIR and its identified mitigation measures, as appropriate, for BMPs within its jurisdiction. Individual projects will undergo subsequent CEQA analysis and documentation, as appropriate under the requirements of CEQA, by implementing agencies. The determinations of significance after mitigation in the PEIR apply to the LACFCD and other implementing agencies that choose to rely on this PEIR and the mitigation measures proposed herein. This PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual EWMP projects should they also adopt the findings within this PEIR. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no LA County Flood Control District 11-362 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments additional CEQA analysis is needed with compliance with the mitigation measures identified in this PEIR. Response to Comment 41-H: The alternatives analyzed in the Chapter 6 of the Draft PEIR included the No Project Alternative, Non -Structural BMPs Only Alternative, and the Distributed Structural/Non-Structural BMPs Only Alternative. The majority of BMPs proposed as part of the EWMPs would be implemented within existing LACFCD facilities. However, non-structural BMPs, including street sweeping and educational programs, would be required to be implemented outside of LACFCD flood control facilities and thus outside of their jurisdiction. LACFCD does not have a special status or authority designated by the MS4 Permit over any of the other Permittees and cannot enforce BMPs outside their jurisdiction. The LACFCD will be working with the applicable Permittees in all 12 EWMP watersheds as an equal partner to identify the types and locations of BMPs needed to achieve permit compliance within each watershed. Therefore, implementation of alternatives outside of the LACFCD jurisdiction is appropriate at this level of analysis. a County Flood Control District 11-363 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 42 Paige Anderson To: Laura Rocha Subject: RE: comments on PEIR for the EWMP From: Rex Frankel (mailto:rexfrankeI0)vahoo.coml Sent: Monday, March 16, 2015 4:59 PM To: Gregg Begell Su bj act: comments on PEI R for the EWMP COMMENTS ON THE PEIR FOR THE LA COUNTY FLOOD CONTROL DISTRICT EWMPs by Rex Frankel, March 16, 2015, 4:58PM We agree with the concerns of the SMMC in that this plan does not discuss land acquisition, but attempts to focus its regional urban runoff compliance strategies on using the existing inadequate supply of public land and parks. It is clear from the 3 project objectives that this project is about surface water quality, be it in creeks, rivers or the local beaches. This goal is tied to compliance with the Federal Clean Water Act as required by the consent decree between local governments and the NRDC, Heal the Bay, etc. The consent decree, unfortunately has a drawback in that compliance with numerical limits on pollutants in waterways so far is leading to a plan that shifts those pollutants to public schools, parks, street parkways as the engineering A departments tries to comply while not upsetting big landowners whose properties could become parkland as part of a multiple benefit strategy. The PEIR's drafters make the mistake of forgetting the multiple benefits approach that has gained local agencies a compliance deadline of 18 years instead of 10 from the RWQCB, and therefore, this plan has forgotten the goal of creating new parkland in parks -poor Los Angeles. Questions not answered in this PEIR: what percentage of streets in each of the 12 EWMP areas are capable of being converted into B I "green streets" with so-called "distributed" water cleanup facilities? What is the potential human health risk of converting street parkways, existing heavily used public parks and school playgrounds into T these pollution catching and cleaning facilities? What areas of parkway conversions or new developments with these parkway filtration 1111 C facilities have been where street parking is allowed, such that people will be inclined to walk across them? What is the slip and fall risk from the public walking through them from parked cars to homes and businesses? PIECEMEALING AND THE LEGAL CONCEPT OF INDEPENDENT UTILITY A program EIR can be justified under CEQA when the individual parts of the project can stand on their own and do not require completion of the others to complete their goal. Goals of the EWMP, however, are very specific: attaining numerical compliance with the Clean Water Act's pollution limits county -wide. A PEIR might be sufficient if the goal was a general plan to improve water quality and D there was no standard of success. That is not the case here. Unless all the projects are completed, the CWA and consent decree will be violated. Instead this project has become a case of divide and conquer, so that the impacts of the full CWA compliance project at each watershed are never considered by those who have to pay for it. Instead, each sub -project will be up for impacts review separately, subject to separate public hearings, all conveniently designed to exhaust and spread out the members of the public interested in this project. The costly choice of spending billions on cleanup projects or not swimming by a drain pipe for three days after a storm is not E considered here. What the taxpayers are facing is incremental tax increases to pay for this project that will have "inertia" from all the previous funds spent, wherein taxpayers who want to say no will be reminded that all which was already spent would be wasted unless the taxpayers pay even more to finish the project. That is the essence of illegal piecemealing. This improper segmenting of one project into hundreds of small ones also biases the range of alternatives to be considered, and is itself internally inconsistent. Only one alternative, the proposed project, attains the MS4/Clean Water Act goals. But only when the entire IF project is built are those goals satisfied. So based on the alternatives discussion, the County is admitting this is all one project, not 100 or more smaller projects. That is why we need an EIR that analyzes the specific projects all at once. That is all have to say at this time. Rex Frankel 310-738-0861 6038 west 75th street, L.A. CA 90045 CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written Comment Letter 42 permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. Comments Response to Comment Letter 42 (Rex Frankel — March 16, 2015) Response to Comment 42-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The objectives of the EWMPs are listed in Section 2.2. Although multi -benefit projects are encouraged, the primary goal is compliance with water quality objectives established by the MS4 Permit. The creation of new parklands can be an ancillary benefit of many projects, and LACFCD is actively promoting benefits to parks within the EWMPs. The PEIR evaluates the potential impacts of project implementation, but does not evaluate the effectiveness of the strategies for achieving Permit compliance. Nor does the PEIR evaluate the suitability of the proposed EWMP development methodologies. The EWMP process includes a mechanism for the RWQCB to determine effectiveness of the BMPs over time. Response to Comment 42-B: Potential regional and centralized BMP locations are included in Appendix G for each EWMP area. Distributed projects could be installed in addition to the identified locations throughout each watershed. Hundreds of distributed projects could be installed, including gutter screens and small- scale green street renovations over the next 25 years and beyond. The percentage of streets that are capable of being converted into "green streets" to benefit surface water quality is not known at this time; most of the specific projects to be included in the EWMPs are either currently undefined or currently under development. Response to Comment 42-C: The PEIR evaluates potential impacts to public health from implementation of BMPs on page 3.7-18. The PEIR acknowledges that storm water detention BMPs will concentrate pollutants overtime. Mitigation Measure HAZ-1 requires that BMPs receive appropriate maintenance to reduce potential impacts to public health. Each individual project will be evaluated for potential impacts to public health including slip -trip impacts and public access on an individual basis as they are developed. It should be noted in that Mitigation Measure HAZ-1 has been revised as follows HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth LA County Flood Control District 11-366 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The Maintenance Plan shall include vector control requirements. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. Response to Comment 42-D: The PEIR acknowledges that most of the projects to be included in the EWMPs are either currently undefined or currently under development. The PEIR explains that EWMPs are being prepared that will contain road maps to permit compliance for each of the 12 watersheds, without yet being fully detailed. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. The PEIR evaluates typical project types to assess potential impacts of implementing the entire program throughout the region over a long period of time. The use of a PEIR pursuant to CEQA Guidelines Section 15168 is intended to evaluate broad-based impacts early in the planning process and is the appropriate CEQA compliance for the EWMPs at this time. Response to Comment 42-E: The use of a PEIR pursuant to CEQA Guidelines Section 15168 is appropriate and is intended to evaluate cumulative impacts of the long-term implementation of a multi -project program in order to avoid piecemealing of impact analysis. Each Permittee may rely upon this PEIR at their discretion for approval of projects under the EWMPs. Individual projects will undergo subsequent CEQA review and documentation, as appropriate, by implementing agencies. For projects where the LACFCD will be the lead agency, the mitigation measures included in the MMRP will be incorporated. Response to Comment 42-F: The PEIR acknowledges that most of the specific projects to be included in the EWMPs are either currently undefined or currently under development. The PEIR explains that EWMPs are being prepared that will contain road maps to permit compliance for each of the 12 watersheds, without yet being fully detailed. The effectiveness of each EWMP to achieve permit compliance will be evaluated by the RWQCB, which may require additional projects or management actions to ensure compliance. The PEIR evaluates typical project types to assess potential impacts of implementing the entire program throughout the region over a long period of time. The use of a PEIR pursuant to CEQA Guidelines Section 15168 is appropriate and is intended to evaluate a County Flood Control District 11-367 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments broad-based impacts early in the planning process and is the appropriate CEQA compliance for the EWMPs at this time. LA County Flood Control District 11-368 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 43 Paige Anderson To: Laura Rocha Subject: RE: comments on the PEIR for water enhancement: thank you for considering them From: Theresa Brady[mailto:terriebradyCo)amail.coml Sent: Wednesday, March 18, 2015 9:40 AM To: Gregg Begell Su bj act: comments on the PEI R for water enhancement: thank you for considering them From Theresa Brady 21844 Corvo Way Topanga, Ca 90290 To Greg Begell Department of Public Works When nonnative trees are being considered for removal in a water enhancement project I would like to ask that two considerations are made paramount: Their importance in mitigation of global warming and their A importance as habitat. There is a recently passed law at the state level that requires that every project consider its impact on globalT B warming. 1 The second issue is illustrated by the removal of 650 eucalyptus trees in the Oxford Lagoon. There were monarch butterflies overwintering on these trees when they were felled. The monarchs can also use other large mature trees, such as coast live oak and sycamore. The Monarchs overwinter on all of these kinds of trees up and down the California Coast. However predominantly they overwinter on stands of eucalyptus. This information is available on the internet in a booklet titled "where to see the monarchs in California". It includes many sites, the vast majority of which are groves of eucalyptus. Therefore, it is my contention that the stands of eucalyptus should be protected unless and until it has been observed that the newly established native grove has become the preferred site for the monarchs. The Monarch has recently been considered for endangered status by the federal department of Fish and wildlife. The result of that review will be publicized soon. I would like to see more caution and consideration in deliberating about the removal of mature trees even nonnative. Thank you for considering my comments. Theresa Brady C Comment Letter 43 CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. to Comments Response to Comment Letter 43 (Theresa Brady — March 18, 2015) Response to Comment 43-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. Mitigation Measures BIO -1 through BIO -9 would ensure that habitat values are not significantly impacted and would reduce potentially significant impacts to less than significant levels. The PEIR assesses green -house gas emissions and climate change in Section 3.6. The PEIR concludes that implementation of EWMPs would be consistent with greenhouse gas emissions reductions plans. Response to Comment 43-B: The PEIR assesses green -house gas emissions and climate change in Section 3.6. The PEIR concludes that implementation of EWMPs would be consistent with greenhouse gas emissions reductions plans. Response to Comment 43-C: Mitigation Measures BIO -1 through BIO -9 would ensure that habitat values are not significantly impacted and would reduce potentially significant impacts to less than significant levels. a County Flood Control District 11-371 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 44 Paige Anderson To: Tom Barnes Subject: RE: Public Comment - Draft EIR of the Enhanced Watershed Management Programs From: Enrique Huerta [mailto:ehuerta28(@gmail.coml Sent: Thursday, March 12, 2015 11:09 PM To: Gregg Begell Sobj ect: Public Comment - Draft EI R of the Enhanced Watershed Management Programs Hi Gregg, The attached pdf contains my comments on the DPEIR. Thanks for all of your hard work. -Enrique Comment Letter 44 March 12, 2015 Enrique Huerta At -Large Stakeholder Los Angeles County ehuerta28@gmail.com County of Los Angeles Department of Public Works Project Management Division II ATTN: Gregg BeGell, P.E. 900 South Fremont Avenue, 5th Floor Alhambra, CA 91803 (626) 300-3298 Sent via e-mail to gbegell@dpw.lacounty.gov RE: Public Comment: Notice of Availability (NOA) of the Draft Program Environmental Impact Report for Enhanced Watershed Management Programs Dear Mr. BeGell: Thank you for preparing the Draft Program Environmental Impact Report (DPEIR) of the Enhanced Watershed Management Programs (EWMPs). My comments are in reference to the following disclosure issues: • The criteria used to prepare this DPEIR are not tailored to assess the unique circumstances of the EWMPs. The requirements outlined in the state CEQA Guidelines are the statutory floor, rather than the limit, and not guaranteed as a safe harbor for compliance. The Los Angeles County Flood Control District maintains the discretion to modify or impose additional criteria or expand the project scope/activity as they determine appropriate. • The environmental analysis in this DPEIR acknowledges the importance of doing a thorough and comprehensive analysis, but many sections lack substantial evidence in the form of facts, reasonable assumptions predicated on facts and expert opinion supported by facts. Since the DPEIR acknowledges that the EWMPs schedules and measures are presently incomplete, in draft form and not referenced as available for public review, the statements in this document cannot be verified by the public. Speculation, unsubstantiated opinion or narrative is not substantial evidence and undermines the informational purpose of a PEIR. • The DPEIR draws a glaring distinction between a Program EIR and a project EIR which misses the opportunity to identify the impacts of large number of existing and fully - developed projects in the pipeline. At hand is whether or not the PEIR is providing the public and decision -makers with sufficient cumulative analysis to intelligently consider the environmental consequences of existing multi -benefit stormwater activities. • Some of the mitigation measures identified in this DPEIR lack weight since they may go unnoticed by an implementing agency. Future projects may be categorically exempt from conducting an Initial Study resulting in projects that do not account and monitor for potential significant environmental impacts, as identified, in the DPEIR biological resources and cultural resources mitigation measures. • The location of water supply recharge areas underlying the location of overly polluted and unfairly burdened low-income communities present environmental justice concerns resulting from the over concentration of future construction activities. • The use of non-objective terms to frame the discussion of Climate Change. V Comment Letter 44 COMMENTS ON THE CONTENT OF THE DEIR Executive Summary — ES.2 Background COMMENT NO. 1. According to Page No. ES -2, "The PEIR analysis is not intended to focus on the site-specific construction and operation details of each management strategy and project included in the EWMP. Rather, this PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution." This seems to overlook the intent of both the new MS4 Permit, adopted November 2012 and effective December 2012 by the Los Angeles Regional Water Quality Control Board (LARWQCB), which "Encourages merging water quality watershed management approaches with the strategic Integrated Regional Water Management planning process resulting in additional economies of scale," and Section 15168(c)(5) of the 2014 California Environmental Quality Act (CEQA) Statute and Guidelines, which states that the goal is to assist in the creation of a PEIR "that deals with the effects of the program as specifically and comprehensively as possible... with a good and detailed analysis of the program, many subsequent activities could be found to be within the scope of the project described in the program EIR, and no further environmental documents would be required." The courts have recently downplayed (see Cleveland National Forest Foundation v. San Diego Association of Governments) the distinction between a Program and a project EIR in favor of environmental assessments that do a thorough job analyzing the reasonable foreseeable impacts of relevant activities — regional or site specific in nature. In the coming decades, water supply, and conservation projects and programs will compete for limited fiscal resources with concurrent efforts to improve urban and stormwater runoff quality. With the cost of compliance with surface water quality regulations estimated to range from $43 to $284 billion (Brown and Caldwell, 1989 and Gordon, et al, 2002), jurisdictions and agencies in the Region face difficult funding choices. The integration of multiple water management strategies via multipurpose programs creates opportunities for a `one -stop -shop" analysis through a PEIR to efficiently use fiscal resources and significantly reduce the ask amount of future water resources grant funds. There is an opportunity for synergy by collectively comparing how the existing multi -benefit stormwater projects of the 2014 Greater Los Angeles County Integrated Regional Water Management Plan (GLAC-IRWMP) database fare with the integrated goals of the EWMPs. This DPEIR does not reference the GLAC-IRWMP nor identifies any collaboration or overlap between multi -benefit activities. There are over 190 fully developed integrated water resources 19 Comment Letter 44 projects in the Los Angeles County Department of Public Works GLAC-IRWMP OPTI website. These projects in the database also identify the implementing agencies and each of the B permittees. Incorporating these existing regional -scale projects into the PEIR could better cont determine whether the incremental effects of this program are cumulatively considerable when viewed in connection with the effects of past, present, and probable future activities. COMMENT NO. 2. On Page ES.2, there is no reference to the location of the EWMPs for public review. It seems the individual EWMP documents are incomplete and on a parallel schedule with this PEIR. According to this paragraph, "This PEIR describes and evaluates each of the EWMPs being prepared by the Permittees collectively ... A few of the BMPs are currently well defined but most are yet to be fully developed under the EWMPs. A set of priority BMPs will be detailed in each of the EWMPs; these are being developed in parallel with the PEIR. The PEIR C describes the details that are available for each of the EWMPs currently under preparation by the EWMP working groups." Are the individual EWMPs available for public review? How can the public rely on a CEQA analysis "that deals with the effects of the program as specifically and comprehensively as possible," when there is no reference material available for comparison purposes? ESA Project Description COMMENT NO. 3. The following text on Page ES.3 (and repeated in Chapter 2, Page No. 2-1) is difficult to understand. Please elaborate. "The Los Angeles County Flood Control District (LACFCD) has limited jurisdictional authority for ordinance and code enactment or enforcement D and therefore is limited in nonstructural BMPs to education and outreach measures." 1.1 CHAPTER 1 - Introduction COMMENT NO. 4. On Page No. 1-1, was the new 2012 MS4 permit drafted in response or anticipation of the judgment issued by the United States Supreme Court for LACFCD vs. Natural Resources Defense Council (NRDC)? If so, please consider adding background information (or preferably, a new section) outlining the 2008 Clean Water Act citizen lawsuit filed by the NRDC and Santa Monica Baykeeper (Baykeeper). The case can be located here: http://www.scotusblog.com/case-files/cases/los-angeles-cou nty-flood-control-district-v-national- resou rces-defense-cou nci I/. It is important to provide a complete record of the reason and motivation behind the new MS4 permit. Specifically, please contextualize the need (and the targeted ecological functions that E Comment Letter 44 will improve the problem) by adding a description of the problem in relation to the mission of the NRDC and the Baykeeper, an ecological context, statutory background (legal challenge to Order No. R4-2006-0074, etc.), and a chronological list of events related to the ultimate E Supreme Court decision finding that the Los Angeles County Flood Control District was cont "responsible for discharges of pollutants at the end of concrete channels in two rivers, the Los Angeles River and the San Gabriel River." COMMENT NO. 5. On Page No. 1-1, please add a discussion pertaining to the agency partnership existing between the LARWQCB and the Los Angeles Area Environmental Justice Enforcement Collaborative. There is a concern that the piecemeal approach to the MS4 permit will overlook the importance of issuing a permit that ensures non-discrimination as it pertains to the potential for over -concentrated construction and facilities maintenance activities in these communities (San Fernando Valley, San Gabriel Valley, South -Central Los Angeles and the Southeast LA County cities) due to their prime and underlying soil infiltration characteristics (refer to the maps identified on Comment No. 13), which could produce an unfair overconcentration of environmental pollution burdens. According to Executive Order 12898, the LARWQCB is required to promote "meaningful engagement of overburdened communities in EPA's permitting process." The DPEIR states that, "The LACFCD, along with participating Permittees, has opted to exercise this option and has submitted to the LARWQCB 12 separate Notices of Intent (NOls) for the development of EWMPs within 12 distinct watershed groups. Implementation of the EMWPs would be the responsibility of each Permittee and would occur following approval of the EWMPs by the LARWQCB." However, this piecemeal approach to the MS4 permit does not guarantee that environmental justice will be a priority. 1.2 Project Background. Reasonable Assurance Analysis. 1.3 CEQA Environmental Review Process. Purpose of the PEIR. COMMENT NO. 6. On Page No. 1-10, there is a reference to the environmentally integrated approach of EWMPs. Specifically, "The analyses focus on the environmental effects of implementing the EWMPs as a program to improve surface water quality and increase water conservation." In an effort to avoid the displacement of pollution from one area (water bodies) to another (soil)—how environmentally sensitive is the EWMP approach? Will the physical control measures require the use of potable water for landscape maintenance (for example, according to the 2014 County of Los Angeles Department of Public Works Low Impact Development Standards Manual, "One potential problem with using green roofs in the Los Angeles County 0 F G Comment Letter 44 area is the long, hot and dry summers, which may kill the plants if they are not watered)? Will EWMPs maintain the same quality level for soils? How will this impact groundwater quality? G What is the relevancy of the EWMPs to the Groundwater Management Plan and the California cont Systemwide Groundwater Elevation Monitoring? COMMENT NO. 7. On Page No. 1-9, the sentence that reads, "Significance criteria have been developed for each environmental resource analyzed in this Draft PEIR," seems troublesome H since the significance criteria is cut -and -pasted from the CEQA Guidelines. Did the Technical Advisory Committees from each respective EWMP create the criteria? COMMENT NO. 8. On Page No. 1-10, this sentence is repeated several times throughout the DPEIR: `The PEIR analysis is not intended to focus on the site-specific construction and operation details of each management strategy and project included in the EWMPs. Rather, this PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs overall as a plan to reduce urban runoff pollution." It can be found at a) Executive Summary on Page No. ES -2; and, b) Chapter 1, Section 1.1 -Introduction on Page No. 1-3. CHAPTER 2 Project Description COMMENT NO. 9. On Page No. 2-1, the following statement, "The 12 EWMPs will vary for each watershed group, but will generally provide the opportunity for Permittees to customize their stormwater programs to achieve compliance with applicable receiving water limitations and/or water -quality -based effluent limits in accordance with the Municipal Separate Storm Sewer J System (MS4) Permit through implementation of stormwater Best Management Practices (BMPs) or watershed control measures," is repeated verbatim from the Executive Summary on Page No. ES -3. COMMENT NO. 10. On Page No. 2-1, the following statement, "Each of the Permittees identified in the MS4 permit is responsible for meeting the conditions of the permit for MS4 K discharges occurring within their jurisdiction, is repeated verbatim from the Executive Summary on Page No. ES -2. COMMENT NO. 11. On Page No. 2-7, under Section Distributed Structural BMPs — Overview T and Example BMP, please add the "advantages' and "disadvantages' as identified and I L summarized in Appendix E, Stormwater Quality Control Measure Fact Sheets, of the 2014 5 Comment Letter 44 County of Los Angeles Department of Public Works Low Impact Development Standards L Manual, in order to compare and contrast the BMPs with a do-nothing scenario. I cont COMMENT NO. 12. On Page No. 2-5 under Section 2.4.1, the fifth bullet point makes reference to Planning and Land Development Programs, "which encourage the application of smart growth and low -impact development (LID) practices to development and redevelopment M projects." However, `redevelopment projects" were eliminated in 2011 by order of Governor Jerry Brown when he dissolved redevelopment agencies throughout the state. I think a more appropriate and up-to-date term would be to substitute Enhanced Infrastructure Financing Districts. COMMENT NO. 13. On Page 2-57, consider adding a section titled Environmental Justice which discusses the unfair burden and disproportionate impacts of the proposed physical control measures on low-income and inland communities. These low-income areas, when superimposed on areas identified for their infiltration benefits, stand to overly concentrate construction and facilities maintenance activities and associated pollution. These potential recharge areas are identified as "Supply: Recharge Areas' in the 2014 GLAC-IRWMP Update and shown on the map below titled Map 5-1: GLAC Region Potential Benefits Geodatabase layers: Iik Comment Letter 44 LJ rte. u G * w. e E IMq and PeNnllel Vnde Ra�maG � ' 1 _ ': Swdr: Rechwe Aresa Hetilsel HeWICAI and C hftr LLL {t RNfta iN Av�k ((77 Re[:teaaon: High Priority (/ F ❑ -. Wader a ally: High Prosy [4 j x ism Rrwayl�k aadaft aama. awn" ©ruirids We Maf defo&d data lar tba NSMP Subreglaa is MV &t: GLAC Rag*w Pot rdW 8errefda Geod&fabase layevS mirmatly absenf. twf will be 7mpv and oxer&we. The map above identifies beneficial stormwater recharge areas that could increase the County's water supply. All of these areas are located away from the coastal areas, a hydrologic region associated with middle to upper income beach communities. Most of the areas offering stormwater recharge benefits are inland and near low-income communities like those in the San Fernando Valley, the San Gabriel Valley, South -Central Los Angeles and Southeast Los Angeles County. According to the Department of Water Resources, a Disadvantaged Community (DACs) is one whose median household income is 80% or less of the statewide average. As the following map shows (Map 2 below), DACs overlie most of these stormwater recharge areas, which can be correlated with a higher degree of future construction and operation activities associated with centralized structural, distributed structural and regional structural physical control measures that may continue to unfairly overburden these communities with added air quality, greenhouse gases, hazards and hazardous materials, land use and agricultural, noise, public service and recreation, and transportation and circulation pollution as it has historically been the case. Compounding this situation is the potential increase in the production, manufacturing, and pollution activities associated with the 7 N cont Comment Letter 44 manufacturing of toxic construction materials like cement, plastics, and filtration/pretreatment hardware that come from factories that are also located in DACs. m r Hit III it I It I HL111tingtOl u..,... ESL HERE. D,L,ri,i uses. NCIE usoa FPA, NILS II , Map 2 — DACs in Los Angeles County 3.2 Air Quality 3.2.1 Environmental Setting COMMENT NO. 14. Under the Regional Setting section on Page No. 3.2-1, please include a discussion about the partnership between the LARWQCB and Los Angeles Area Environmental Justice Collaborative and the need to improve the living conditions of densely populated inland communities severely impacted by pollution stemming from traffic congestion and industrial activities. In addition, please reference current law which states that, "Under EPA's Title VI implementing regulations found at 40 C.F.R. Part 7 (PDF), (11 pp, 40K) EPA -funded agencies are prohibited from taking acts, including permitting actions, that are intentionally discriminatory or have a discriminatory effect based on race, color, or national origin." How will the LARWQCB promote, "its responsibilities under Executive Order 12898 by increasing meaningful engagement of overburdened communities in EPA's permitting process," if this DPEIR does not disclose and take into consideration the consequences of piecemealing the MS4 permit? E N cont V Comment Letter 44 3.11.1 Environmental Setting COMMENT NO. 15. The total population for Los Angeles County may not seem that significant in it of itself, but when put into a percentage of the entire population of California, the number is staggering. According to Figure 2-1 of the GLAC-IRWMP, the 2010 population of Los Angeles County represented over 25% of the entire state population. In addition, the stormwater conveyance system is among the largest in the nation and responsible for a host of diminished resources and increased pollution sinks and accumulated toxicity. Throughout the 201' Century, consumption and the one-way throughput system of stormwater conveyance became increasingly concentrated in cities that were strung together into large counties that developed adjacent to other counties and formed larger and continuous (and impervious land surfaces) megalopolis', demanding ever increasing volumes of material and water from distant sources. These megalopolis' stretch for hundreds of miles across counties and are home to millions and P millions of people. Cities now cover about 2% of the global land area, but include over 60% of the total population. Los Angeles County is considered one of the largest metropolitan areas in the world. With a region so densely populated and developed in a seemingly endless sprawl development pattern, will the increased infiltration of polluted water negatively impact an already limited amount of groundwater supply? Will the polluted water negatively affect the soil for BMPs incorporating percolation of water into underlying soils? How will the redirection of polluted water from entering water bodies and redirected to a soil medium negatively impact the ecological properties of soil as they relate to conversion, distribution, infiltration, assimilation and conversion of beneficial nutrients? 3.11.2 Regulatory Setting COMMENT NO. 16. Under the heading, Local, the County General Plan, as do municipal General Plans all have procedures and mechanisms for amending land use plans, zoning plans and codes in order to accommodate changes in land use designations and densities. A General Q Plan and Zoning Code are not static documents. Instead, they are adaptable to changing circumstances like increases in population growth. COMMENT NO. 17. Under the heading, Local, there is currently a widely used county plan that provides a vision for water resources management. The GLAC-IRWMP provides incentives for implementing sustainable stormwater capture, storage and recharge. Additionally, the GLAC R IRWMP has collected an extensive list of developed projects in the pipeline for each respective 9 Comment Letter 44 EWMP that identifies implementing agencies, permittees, and design characteristics that seem worthy of review by this PER. In light of such information, do these projects comply with the MS4 permit? Have project sponsors collaborated with the agencies and permittees across the watershed to promote more cost-effective and multi -beneficial water quality improvement projects? Will the fully developed water -wide EWMPs contained in the GLAC-IRWMP OPTI database remove or reduce pollutants from dry -and -wet -weather urban runoff in a cost-effective manner? Will the fully developed water -wide EWMPs contained in the GLAC-IRWMP OPTI database reduce the impact of stormwater and non-stormwater on receiving water quality? 3.6 Greenhouse Gas Emissions — Climate Change Overview COMMENT NO. 18. On Page No. 3.6-1, your reference language contained in the 2007 report by the International Panel on Climate Change (IPCC) seems outdated. Since 2007, climate science has made many important advances since the last IPCC assessment report, thanks to improvements in measurements and data analysis in the cryosphere, atmosphere, land, biosphere and ocean systems. Scientists also have better understanding and tools to model the role of clouds, sea ice, aerosols, small-scale ocean mixing, the carbon cycle and other processes. More observations mean that models can now be evaluated more thoroughly, and projections can be better constrained. Additionally, there is a higher level of confidence among the science community about the validity of findings as determined through evaluation of the available evidence and the degree of scientific agreement. Increasing levels of evidence and degrees of agreement are correlated with increasing confidence that climate change is directly linked to human activities and human caused. The problematic language in question reads, "...Much of the scientific literature suggests... While there is some debate regarding this issue, it is unlikely that global climate change of the past 50 years can be explained without contribution from human activities (IPCC, 2007)." Please remove the term "suggest," since the peer-reviewed scientific literature has always maintained a direct correlation between an increase in greenhouse gases and anthropogenic activities since the 1790s with a small degree of uncertainty (refer to http://www.ipcc.ch/publications and data/ar4/syr/en/spms2.html). Additionally, please replace the word "debate' with the word "uncertainty." The only debate stems from the non-scientific cultural and political opinions meant to muddy the science of greenhouse gases and climate change. 10 R cont S Comment Letter 44 Please consider replacing the outdated language I just referenced with a more up-to-date description, as contained in the 2013 Executive Summary of Climate Change 2013: The Physical Science Basis, which states, "Human activities are continuing to affect the Earth's energy budget by changing the emissions and resulting atmospheric concentrations of radiatively important gases and aerosols and by changing land surface properties. Previous assessments have already shown through multiple lines of evidence that the climate is changing across our planet, largely as a result of human activities. The most compelling evidence of climate change derives from observations of the atmosphere, land, oceans and cryosphere. Unequivocal evidence from in situ observations and ice core records shows that the atmospheric concentrations of important greenhouse gases such as carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O) have increased over the last few centuries due to anthropocentric activities. (page no. 121)" COMMENT NO. 19. On Page No. 3.6-12, Impact Assessment, the DPEIR mentions that, "As noted, the increased concentration of GHGs in the atmosphere has been linked to global warming, which can lead to climate change," however, there is consensus in the scientific community that unless drastic measures take place soon, we will be unable to move back from our current 405 parts per million (ppm) threshold of carbon dioxide (CO2) in the atmosphere to the necessary 350 ppm that scientists have identified as necessary to maintain a healthy environment. Furthermore, the language contained referenced above makes it seem like the scientific community does not know that this will happen. Again, the irrevocable effects of climate change will happen, unless drastic and swift measures are implemented, which does not seem likely. The United States Environmental Protection Agency states that, "CO2 is the primary greenhouse gas emitted through human activities... Human activities are altering the carbon cycle—both by adding more CO2 to the atmosphere and by influencing the ability of natural sinks, like forests, to remove CO2 from the atmosphere. While CO2 emissions come from a variety of natural sources, human -related emissions are responsible for the increase that has occurred in the atmosphere since the industrial revolution. The main human activity that emits CO2 is the combustion of fossil fuels (coal, natural gas, and oil) for energy and transportation, although certain industrial processes and land -use changes also emit CO2." (http:/ /www.epa.gov/climatechange/ghgemissions /gases/co2.htm 1). Chapter 5 — Growth Inducement Potential S cont T COMMENT NO. 20. Section 5.1 CEQA Requirements. This chapter, per the CEQA I U "Guidelines," consider the minimum requirement for analysis. In this case, this chapter only WII. 11 Comment Letter 44 analyzes the growth inducing effects associated with the proposed action. However, whether or not the proposed action will cause direct or indirect growth is partially addressing the underlying reason for creative sustainable programs like EWMPs. It is no secret that the population in Los Angeles County continues to grow on a daily basis and EWMPs are designed to accommodate that growth. According to the Public Policy Institute of California, population in Los Angeles County by the year 2025 will reach 11.5 million people. This represents an increase of approximately 15% from the 10,017,068 million current residents living within the EWMP project boundary (http://www.ppic.org/content/pubs/report/R 610HJR.pdf). As population increases, so does human activity resulting in the accumulation of trash, debris, chemicals, sediment or other pollutants that could adversely affect water quality if the runoff is discharged untreated. This begs the question: What effect will projected increases in population have on EWMPs? Will increased urban runoff have a negative impact on the availability of the already limited usable water supply in the region? 12 U cont to Comments Response to Comment Letter 44 (Enrique Huerta — March 12, 2015) Response to Comment 44-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These summaries of the comments in the comment letter have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. Response to Comment 44-B: The PEIR defines typical project types in Section 2 and then in Section 3 evaluates potential impacts of implementing hundreds of these types of projects throughout the region over a long period of time. The use of a PEIR pursuant to CEQA Guidelines Section 15168 is intended to evaluate broad-based impacts early in the planning process and is the appropriate CEQA compliance for the EWMPs at this time. As projects are refined in the future, each individual project will undergo subsequent CEQA determination by the lead implementing agency prior to approval. The 2014 Integrated Regional Water Management Plan (IRWMP) prepared by the Los Angeles County Department of Public Works is a parallel planning process that is being implemented to identify projects that may provide multiple benefits including surface water quality improvement. As stated in Chapter 1 of the Greater Los Angeles County (GLAC) 2014 IRWMP, the IRWMP reflects the region's collaborative efforts to ensure a sustainable water supply through the more efficient use of water, the protection and improvement of water quality, and environmental stewardship. The EWMPs are consistent with this IRWMP, and projects developed through the IRWMP process are being considered for inclusion within the EWMPs. However, the LACFCD would not be the lead agency for a PEIR prepared for the IRWMP, and a combined PEIR covering both the EWMP and IRWMP process is not under consideration at this time. In response to the comment the following discussion on the IRWMP is included in the Final PEIR within Section 3.8.2, Regulatory Setting. Integrated Regional Water Management Plan The 2013 Integrated Regional Water Management Plan (IRWMP) Update, approved by the Los Angeles County Board of Supervisors in 2014, was formulated to define a clear vision and direction for the sustainable management of water resources in the Greater Los Angeles County (GLAC) Region. The IRWMP, which is chaired by the Los Angeles County Flood Control District (LACFCD), covers the GLAC Region, an area of approximately 2,058 square miles, spanning from Ventura County to Orange County and from the coast to the San Gabriel Mountains. The IRWMP region includes the Los Angeles River Watershed, the Santa Monica Bay Watershed, the Dominguez Channel Watershed, and the San Gabriel River Watershed, overlapping with four of the five watersheds covered in the EWMP. Several subcommittees were involved in the IRWMP development process, covering a range of both project objectives and physical areas, to ensure successful regional collaboration. The objectives of the 2013 IRWMP Update a County Flood Control District 11-385 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments include: reducing the Region's reliance on imported water; comply with water quality regulations by improving the quality of urban runoff, stormwater and wastewater; protect, restore and enhance natural processes and habitats; increase watershed friendly recreational space for all communities; reduce flood risk in flood prone areas by either increasing protection or decreasing needs using integrated flood management approaches; and adapt to and mitigate against climate change vulnerabilities. Response to Comment 44-C: Appendix G of the PEIR provides the location information on the priority projects that was available at the time of publication. The PEIR acknowledges that most of the projects to be included in the EWMPs are either currently undefined or currently under development. Otherwise, the PEIR defines typical project types in Section 2 and then in Section 3 evaluates potential impacts of implementing hundreds of these types of projects throughout the region over a long period of time. The use of a PEIR pursuant to CEQA Guidelines Section 15168 is intended to evaluate broad-based impacts early in the planning process and is the appropriate CEQA compliance for the EWMPs at this time. Because project details are largely incomplete since the EWMPs are being drafted concurrently, each individual project will be subject to a CEQA compliance evaluation prior to approval by the implementing agencies as noted in Section 1 of the Draft PEIR. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of its proposed projects. The public will be able to provide the Regional Water Quality Control Board with comments on the EWMPs. Upon their completion, the EWMPs shall be made available to the public for a 30 -day period to allow for public comment. The PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis outlines mitigation strategies to be followed by the LACFCD and other implementing agencies that rely on the PEIR to avoid or minimize impacts wherever feasible. The PEIR provides the LACFCD a foundation for any necessary future environmental review that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. Response to Comment 44-D: The comment notes that the LACFCD does not have the authority to impose ordinances or code modifications within cities, as that authority is left to the cities. However, education and outreach efforts are effective non-structural BMPs that the LACFCD may employ throughout the County because they do not require ordinances or code modifications to achieve. IA County Flood Control District 11-386 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Comment 44-E: As noted on page 1-I of the PEIR, the Regional Water Quality Control Board issued Order No. R4-2012-0175; NPDES No. CAS004001 in December 2012 covering discharges from multiple municipalities within the Los Angeles Region. The requirements of the MS4 permit are described in Section 1.2 of the PEIR. A primary objective of the proposed program noted on page 2-2 is to comply with the permit requirements. The EWMPs include a methodology required by the MS4 permit to evaluate the effectiveness of the BMPs as they are implemented. The commenter's question as to whether the abovementioned Supreme Court decision lead to the drafting of the 2012 MS4 Permit does not address the adequacy of the PEIR. Response to Comment 44-F: Environmental Justice was addressed in Section 3.11, Population and Housing and Environmental Justice. Implementation of the EWMPs would not disproportionately affect areas with lower average incomes or specific racial distributions, nor unfairly concentrate environmental pollution burdens. Structural BMPs are not expected to be concentrated in any one area or city in particular within the EWMP areas. The structural BMPs are expected to be located on public lands (e.g., schools, parks, sidewalks, and road rights-of-way) throughout the EWMP areas and would be designed to capture, convey, and/or filter stormwater and surface runoff. Local water supplies are largely shared resources, managed by regional agencies (e.g., Metropolitan, Castaic Lake Water Agency) responsible for supplying drinking water equitably to the population. Local water retailers receive their water generally from imported water wholesalers and groundwater pumping. Groundwater recharge resulting from infiltration BMPs will occur throughout the region. Some areas will experience greater volumes of recharge than others due to the local topography and geology. However, local demographics will not influence water quality control infrastructure locations. The equitable delivery of high quality drinking water is the responsibility of water retailers as regulated by the State Water Resources Control Board and the California Department of Public Health. Response to Comment 44-G: A discussion of impacts to soil quality is included on pages 3.7-16 and 3.7-17 of the PEIR. Mitigation Measure HAZ-1 would reduce potential impacts to soil quality by requiring preparation and implementation of maintenance practices including periodic removal and replacement of surface soils that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A discussion of impacts to groundwater quality is located on pages 3.8-35 and 3.8-36 of the PEIR; implementation of Mitigation Measures HYDRO -1, HYDRO -2 and HYDRO -3 would reduce potential impacts to groundwater quality to less than significant levels. Mitigation Measure GEO-1 require that implementing agencies consult with groundwater managers prior to implementation of infiltration projects to ensure consistency with existing groundwater management plans within the South Coast Hydrologic Region; this mitigation measure would reduce potential impacts to less than a County Flood Control District 11-387 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments significant levels. The California Statewide Groundwater Elevation Monitoring would continue to monitor groundwater levels augmented by increased stormwater recharge. Response to Comment 44-H: As lead agency, the County of Los Angeles Environmental Document Reporting Procedures and Guidelines adopted by the Board of Supervisors in 1987 were utilized in the environmental analysis of the PEIR. No additional significance thresholds have been adopted by the County of Los Angeles. Response to Comment 44-I: The commenter's statement regarding the repetition of the text from page 1-10 on pages ES -2 and 1-3 is typical since language identified in the Executive Summary (ES) is a short compilation of information found in the rest of the document. As a result, the ES is repetitious of the entire document. In this instance, the ES is summarizing language found in the Introduction. Repetition of text within the document does not affect the impact conclusions of the document. Response to Comment 44-J: The commenter's statement regarding the repetition of the text from page 2-1 on page ES -3 is typical since language identified in the Executive Summary (ES) is a short compilation of information found in the rest of the document. As a result, the ES is repetitious of the entire document. In this instance, the ES is summarizing language found in the Project Description. Repetition of text within the document does not affect the impact conclusions of the document. Response to Comment 44-K: The commenter's statement regarding the repetition of the text from page 2-1 on page ES -2 is typical since language identified in the Executive Summary (ES) is a short compilation of information found in the rest of the document. As a result, the ES is repetitious of the entire document. In this instance, the ES is summarizing language found in the Introduction. Repetition of text within the document does not affect the impact conclusions of the document. Response to Comment 44-L: The listing of all "advantages" and "disadvantages" of each BMP is not necessary to evaluate impacts of their implementation. Chapter 6 of the Draft PEIR includes analysis of a No Project Alternative, which is equivalent to a "do-nothing" scenario, in comparison to the proposed Program. The analysis concludes that the proposed Program itself is environmentally superior to implementation of the No Project Alternative. No addition will be made as recommended by the commenter. Response to Comment 44-M: The usage of the term "redevelopment project" was taken from language on page 94 the current Municipal Separate Storm Sewer System (MS4) Permit (Order No. R4-2012-0175; NPDES LA County Flood Control District 11-388 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Permit No. CAS004001). Redevelopment Projects are defined beginning on page 96 of the Permit. No changes are required as recommended by the commenter. Response to Comment 44-N: BMPs would be distributed throughout the watershed irrespective of local land uses. Though some BMPs such as infiltration BMPs are limited to areas with appropriate soils, implementation of the EWMPs would not disproportionately affect areas with lower average incomes. Environmental Justice was addressed in Section 3.11, Population and Housing and Environmental Justice of the PEIR. Implementation of the EWMPs would not disproportionately affect areas with lower average incomes or specific racial distributions, nor unfairly concentrate environmental pollution burdens. Structural BMPs are not expected to be concentrated in any one area or city in particular within the EWMP areas. The structural BMPs are expected to be located on public lands (e.g., schools, parks, sidewalks, and road rights-of-way) throughout the EWMP areas and would be designed to capture, convey, and/or filter stormwater and surface runoff. The coastal EWMPs will install BMPs to address runoff water quality in similar ways as inland EWMPs. Groundwater recharge resulting from infiltration BMPs will occur throughout the region in locations with soils that accommodate infiltration. Some areas will experience greater volumes of recharge than others due to the local topography and geology. However, local demographics will not influence water quality control infrastructure locations. Response to Comment 44-0: Implementation of the EWMPs would not disproportionately affect areas with a specific racial distribution. The MS4 Permit does not address pollution from industrial land uses. Environmental Justice was addressed in Section 3.11, Population and Housing and Environmental Justice. Implementation of the EWMPs would not disproportionately affect areas with lower average incomes or specific racial distributions, nor unfairly concentrate environmental pollution burdens. Structural BMPs are not expected to be concentrated in any one area or city in particular within the EWMP areas. The structural BMPs are expected to be located on public lands (e.g., schools, parks, sidewalks, and road rights-of-way) throughout the EWMP areas and would be designed to capture, convey, and/or filter stormwater and surface runoff. To address the accumulation of contaminants in soil at BMPs, operations and maintenance plans for BMPs that might accumulate constituents in surface soils and media will be developed to include periodic removal and replacement of these potentially impacted surface materials to reduce the potential for long-term loading leading to hazardous concentrations in soils and groundwater. Implementation of Mitigation Measure HAZ-1 would reduce the potential for impacts to less -than -significant levels. Response to Comment 44-P: A discussion of impacts to groundwater quality is located on pages 3.8-35 and 3.8-36 of the PEIR; implementation of Mitigation Measures HYDRO -1, HYDRO -2 and HYDRO -3 would reduce potential impacts to groundwater quality to less than significant levels. The PEIR acknowledges that infiltration projects could adversely affect groundwater quality and identifies mitigation measures to minimize potential impacts. Mitigation Measure HYDRO -1 requires a County Flood Control District 11-389 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Permittees to evaluate the suitability of BMP locations for groundwater recharge. Infiltration BMPs would not be suitable in areas of low permeability where subsurface structures could be adversely affected by groundwater mounding or in areas with soil contamination. Regarding polluted water negatively affect the soil for BMPs, a discussion of impacts to soil quality is included on pages 3.7-16 and 3.7-17 of the PEIR. Mitigation Measure HAZ-1 would reduce potential impacts to soil quality by requiring preparation and implementation of maintenance practices including periodic removal and replacement of surface soils that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. Mitigation Measure GEO-1 require that implementing agencies consult with groundwater managers prior to implementation of infiltration projects to ensure consistency with existing groundwater management plans within the South Coast Hydrologic Region; this mitigation measure would reduce potential impacts to less than significant levels. The California Statewide Groundwater Elevation Monitoring would continue to monitor groundwater levels augmented by increased stormwater recharge Response to Comment 44-Q: The numerous cities encompassed by the EWMP area all have their own respective city General Plans, which may contain policies that address land use and agriculture. As implementation of the individual structural BMP projects proceed, specific policies and objectives pertaining to land use and agriculture from applicable city General Plans will be identified and evaluated on a project - by -project basis during subsequent CEQA environmental processes. Response to Comment 44-R: As noted on page 1-1 of the PEIR, the Regional Water Quality Control Board issued Order No. R4-2012-0175; NPDES No. CAS004001 in December 2012 covering discharges from multiple municipalities within the Los Angeles Region. The requirements of the MS4 permit are described in Section 1.2 of the PEIR. A primary objective of the proposed program noted on page 2-2 is to comply with the permit requirements. The EWMPs include a methodology required by the MS4 permit to evaluate the effectiveness of the BMPs as they are implemented. The projects are a part of MS4 compliance. Each EWMP group comprises many permittees who are working together to develop cost- effective and multi -benefit water quality improvement projects. Projects that infiltrate runoff will remove the associated pollutants. As described in the PEIR, Mitigation Measures HYDRO -1 through HYDRO -3 would lessen potential impacts from naturally occurring pollutants to a less than significant level. Mitigation Measure HYDRO -3 has been edited as follows: HYDRO -3: Prior to the installation of an infiltration BMP, the Permittee shall conduct a database review for contaminated groundwater sites within a quarter mile of the proposed infiltration facility. The database review shall include locations of on-site wastewater treatment systems that could be affected by the BMP. The Permittee shall identify LA County Flood Control District 11-390 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments whether any contaminated groundwater plumes or leach fields are present and whether coordination with the local and state environmental protection overseeing agency and responsible party is warranted prior to final design of infiltration facility. Furthermore, Mitigation Measure HYDRO -4 has been added, which would reduce any hydromodification impacts including related to erosion and scour, thereby reducing sedimentation of water and resulting impacts to water quality. HYDRO -4: Prior to approving a structural BMP, the implementing agencies shall conduct an evaluation of the potential hvdromodification impacts of the project. The evaluation shall recommend design measures necessary to prevent or minimize any identified impacts, including flooding, erosion and/or scour. Design measures could include velocity dissipaters and bank re -enforcement components. Implementing agencies shall include these measures in project designs. The PEIR defines typical project types in Section 2 and then in Section 3 evaluates potential impacts of implementing hundreds of these types of projects throughout the region over a long period of time. The use of a PEIR pursuant to CEQA Guidelines Section 15168 is intended to evaluate broad-based impacts early in the planning process and is the appropriate CEQA compliance for the EWMPs at this time. As projects are refined in the future, each individual project will undergo subsequent CEQA determination by the lead implementing agency prior to approval. The 2014 Integrated Regional Water Management Plan (IRWMP) prepared by the Los Angeles County Department of Public Works is a parallel planning process that is being implemented to identify projects that may provide multiple benefits including surface water quality improvement. As stated in Chapter 1 of the Greater Los Angeles County (GLAC) 2014 IRWMP, the IRWMP reflects the region's collaborative efforts to ensure a sustainable water supply through the more efficient use of water, the protection and improvement of water quality, and environmental stewardship. The EWMPs are consistent with this IRWMP, and projects developed through the IRWMP process are being considered for inclusion within the EWMPs. The following discussion on the IRWMP is included in the Final PEIR within Section 3.8.2, Regulatory Setting. Integrated Regional Water Management Plan The 2013 Integrated Regional Water Management Plan (IRWMP) Update, approved by the Los Angeles County Board of Supervisors in 2014, was formulated to define a clear vision and direction for the sustainable management of water resources in the Greater Los Angeles County (GLAC) Region. The IRWMP, which is chaired by the Los Angeles County Flood Control District (LACFCD), covers the GLAC Region, an area of approximately 2,058 square miles, spanning from Ventura County to Orange County and from the coast to the San Gabriel Mountains. The IRWMP region includes the Los Angeles River Watershed, the Santa Monica Bay Watershed, the Dominguez Channel Watershed, and the San Gabriel River Watershed, overlapping with four of the five watersheds covered in the EWMP. Several subcommittees were involved in the IRWMP development process, covering a range of both project objectives and physical areas, to a County Flood Control District 11-391 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments ensure successful regional collaboration. The obiectives of the 2013 IRWMP Update include: reducing the Region's reliance on imported water; comply with water quality regulations by improving the quality of urban runoff, stormwater and wastewater; protect, restore and enhance natural processes and habitats; increase watershed friendly recreational space for all communities; reduce flood risk in flood prone areas by either increasing protection or decreasing needs using integrated flood management approaches; and adapt to and mitigate against climate change vulnerabilities. The EWMPs may include project developed for the IRWMP. The EWMPs are consistent with the IRWMP and share goals of multi -beneficial projects that promote increased local water supplies and water quality protection. Response to Comment 44-S: Section 3.6 describes the regulatory background that shapes our current greenhouse gas emissions regulations. The discussion provides an accurate summary of the history of the scientific evaluation of the issue. The PEIR evaluates the potential emissions associated with temporary construction activities. No modifications are required. Response to Comment 44-T: The discussion provides accurate summarizes of the history of the scientific evaluation of the issue. The PEIR evaluates the potential emissions associated with temporary construction activities. No modifications are required. Response to Comment 44-U: The purpose of CEQA is to analyze the effects of the project on the environment, and not the effects of the environment on the project. The implementation of water efficient practices such as stormwater harvesting and recharge would assist in increasing reliability of water supplies, but would not directly or indirectly induce growth or remove an obstacle to growth. LA County Flood Control District 11-392 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 45 Paige Anderson To: Neal Shapiro Subject: RE: Announcing the Release of the EWMP PEIR In lieu of getting the Word doc for tracking changes, here are my written comments for the Executive Summary, since I'll be out rest of week. I'm not sure I will read the rest of the chapters. My point is that the PEIR needs to emphasize the water supply goal, A offsetting potable water use, harvesting for direct and passive uses, just as much or more so than water Quality, throughout the document. If my comments have merit to include, if you need me to go through other parts of the EIR to add similar text, I can Best regards, neal Neal Shapiro, CPSWQ®, CSM Supervisor, Watershed Section City of Santa Monica Office of Sustainability & the Environment 17174 1h St., Suite 100 Santa Monica. CA 90401-3126 OSE Office: 310.458.2213 Direct: 310.458.8223 Cell: 310.429.6417 Fax: 310.393.1279 www.sustainablesm.ore www.sustainablesm.org/runo ff "Give a man a fish and you feed him for a day; teach a man to fish and you feed him for a lifetime." Maimonides From: Gregg Begell[mailto:gbegell(o)dpw.lacounty.govl Sent: Monday, January 26, 2015 7:03 AM To: Neal Shapiro Subject: RE Announcing the Release of the EWMP PEIR Neal Comment Letter 45 Thank you for your interest, we are interested in seeing your comments. Gregg BeGel(P E Project Manager Project Management Division II From: Neal Shapiro[mailto:Neal. Shaoiro(a)SIVIGOV.NETI Sent: Sunday, January 25, 2015 10:00 PM To: Gregg Begell Subj ect: Re: Announcing the Release of the EWMP PEI R I have what I consider a critically important addition to the argument for EWMP BMP projects. The document fails to include adequately and properly water supply, rain harvesting for direct uses locally to reduce dependence on imported. I can send a marked up peir to demonstrate my point and important edits to better make the case. The document is short changing and/or ignoring half the importance of a BMP. Respectively Neal Sent from my Verizon Wireless 4G LTE DROID Los Angeles County Flood Control District <Qbeeell(a,dnw.lacounty.Qov> wrote: ANNOUNCING THE RELEASE OF THE EWMP PEIR Dear Stakeholder or Interested Party, The Program Environmental Impact Report (PEIR) for the Enhanced Watershed Management Program (EWMP) has been released for public review. Please check www.LACoH2Osheds.com for more information. Thank you for your continued interest in the project. Click here for an informational fact sheet Comment Letter 45 Forward this email This email was sent to neal.shapiro(cDsm gov. net by gbegellCa)dpw.lacountv.gov I Update Profile/Email Address 1 Rapid removal with SafeUnsubscribe TM I Privacy Policy. MIG, Inc. 800 Hearst Avenue Berkeley CA 94710 Comment Letter 45 EXECUTIVE SUMMARY ESA Introduction The Los Angeles County Flood Control District (LACFCD) has prepared this Draft Program Environmental Impact Report (Draft PEIR) to provide the public and responsible and trustee agencies with information about the potential effects, both beneficial and adverse, on the local and regional environment associated with implementation of the Enhanced Watershed Management Programs (proposed program). This Draft PEIR has been prepared pursuant to the California Environmental Quality Act (CEQA) of 1970 (amended), codified at California Public Resources Code Sections 21000 et. seq., and the CEQA Guidelines in the Code of Regulations, Title 14, Division 6, Chapter 3. This document is being circulated to local, state and federal agencies, and to interested organizations and individuals who may wish to review and comment on the Draft PEIR. Publication of this Draft PEIR marks the beginning of a 45 -day public review period, during which written comments may be directed to the address below. Comments on the project should be directed to: Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division H 900 South Fremont Avenue, 5`h Floor Alhambra, CA 91803 gbeeel] cnr dpw.lacountv.uov ES.2 Background The Los Angeles County Flood Control District (LACFCD) was created in 1915 when the State Legislature adopted the Los Angeles County Flood Control Act to provide flood risk management, water conservation, and recreation and aesthetic enhancement within its boundaries. The LACFCD owns and maintains a broad network of flood control facilities that convey stormwater to the local rivers and ultimately to the ocean. The LACFCD is governed as a separate entity by the County of Los Angeles Board of Supervisors, and is operated by the County's Department of Public Works. The LACFCD, the County of Los Angeles, and 84 incorporated cities within Los Angeles County (collectively referred to as Permittees) are covered under a Municipal Separate Storm Sewer System (N4S4) Permit (Order No. R4-2012-0175; National Pollutant Discharge Elimination System [NPDES] Permit No. CAS004001) for the discharge of urban runoff to waters of the United States. The propose of the MS4 Permit is to achieve and LA county Flood Coni District ES -1 ESA 1140474 Enhanced Watershed Management Programs January 2015 Oran Program EnNronmental Impact Report Executive maintain water quality objectives to protect beneficial uses of the receiving waters in the Los Angeles region. Each of the Permittees identified in the MS4 permit is responsible for meeting the conditions of the permit for MS4 discharges occurring within their jurisdiction. The 2012 MS4 Permit for Los Angeles County gives Permittees the option of implementing an innovative approach to Permit compliance through development of an Enhanced Watershed Management Program (EWMP). The EWMPs will identify potential and priority structural and non-structural Best Management Prac ' s (BMPs) within the region's storrnwater collection [� system to improve runoff water qua li he LACFCD, along with participating Permittees, has s opted to exercise this option and has su mitted to the LARWQCB 12 separate Notices of Intent (NOIs) for the development of EWMPs within 12 distinct watershed groups (refer to Figure 1-1). Implementation of the EMWPs would be the responsibility of each Permittee and would occur following approval of the EWMPs by the LARWQCB. The LACFCD, as a regional agency, is a member of each of the 12 EWMP working groups, and as such provides a commonality within each EWMP group. However, LACFCD does not have a special status or authority designated by the MS4 Permit over any of the other Permittees. The LACFCD will be working with the applicable Permittees in all 12 EWMP watersheds as an equal partner to identify the types and locations of BMPs needed to achieve permit compliance within each watershed. The timeline identified in the MS4 Permit requires that Permittees submit the EWMP to the LARWQCB by June 28, 2015, in order to be in compliance with the permit conditions. The LACFCD recognizes that implementation of the EWMPs may potentially result in changes to environmental conditions. As a result, the LACFCD has prepared this Program Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the EWMPs. The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior to submittal of the EWMPs. The EWMPs will be submitted by each EWMP to the LARWQCB. 4 This PEIR describes and evaluates each of the EWMPs being prepared by the Permittees ,� Q collectively. The discretionary action prompting the need for CEQA compliance is the submittal' of the completed EWMPs to the LARWQCB. The EWMPs will identify management strategies a . including hundreds of structural Best Management Practices (BMPIOat may be designed and implemented by the Permittees to meet permit compliance objectiveX{A00tew of the BMPs are (� currently well defined but most are yet to be fully developed under the s. A set of priority BMPs will be detailed in each of the EWMPs; these are being developed in parallel with the PEIR. The PEIR describes the details that are available for each of the EWMPs currently under preparation by the EWMP working groups. The PEIR analysis is not intended to focus on the site-specific construction and operation details of each management strategy and project included in the EWMP. Rather, this PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPS to LA Caunty Flood Can"] District ES -2 ESA! 740474 e Enhanced Watershed Management Programs - / f, January 2074 - Dnaft Program Environmental impact Report h3 U m " " "S-t�'r'1 -' P s ww ���'a �e J a/t & s Comment Letter 45 Executive reduce urban runoff pollution. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis outlines mitigation strategies to be followed by implementing agencies to avoid or minimize impacts wherever feasible. LACFCD is the CEQA Lead Agency for this PEIR. This PEIR can be used by the LACFCD or other Permittees to streamline environmental review of individual EWMP projects. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects as appropriate or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. ES.3 Project Objectives The primary goals and objectives of the EWMPs are: t)vt1\(A • To collaborate among agencies (Permittee jurisdictions) =M7111trevatershed to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the MS4 Permit. 7 41111 rycU • To develop watershed -wide EWMPs that will, once implemented, remove or reduce pollutants from dry- and wet -weather urban runof in a cost-effective manner. • To reduce the impact of stormwater and non-stormwater o receiving water quality. ai t ESA Project Description `� The 12 EWMPs will vary for each watershed group, but will generally provide the opportunity for Permittees to customize their stormwater programs to achieve compliance with applicable receiving water limitations (RWLs) and water -quality -based effluent limits (WQBELS) in accordance with the MS4 Permit through implementation of stormwater best management practices (BMPs) or watershed control measures. BMPs vary in function and type, with each �Svr BB roviding unique desig it cteristics and benefits from implementation. The overarching ) JU a BMPs in the E educe the impact of stormwater and non-stormwater on �(( receiving water quality and address the water quality priorities as defined by the MS4 Perm. The M + development of each EWP will involve the evaluation and selection of multiple BMP types 4 including nonstructural (institutional) and distributed, centralized, and regional structural watershed control measures, that will be implemented to meet compliance goals and strategies under the 2012 MS4 Permit. The LACFCD has limited jurisdictional authority for ordinance and rqAkJL code enactment or enforcement and therefore is limited in nonstructural BMPs to education and outreach measures. The structural watershed control measures that will be implemented by the LACFCD will be multi -benefit stormwater projects that emphasize flood risk mitigation and f water conservation and suUply. ( r f The LACFCD has a vested interest in increasing opportunities for stormwater capture and Wim' groundwater recharge as a means of assisting local water supply augmentation. The LACFCD s�" 1 will be working with the applicable Permittees and other stakeholders in all 12 EWMP LA County Flocd Control ustuct ES -3 ESA 1140474 Enhanced Watershed Management Programs January 2015 Grafi Pmgram Environmental Impact Repou Comment Lettey 45, aTVr S`i,ar-p.ell �S/-�/ Executive Summary `� NoT ti4iLo watersheds to develop such project The EWMPs will be implemented by the Permittees that have jurisdiction within each E area. The implementing agencies will be responsible for the contents of the EWMPs affecting their jurisdictions and for implementing the projects developed by the EWMPs.. r _ 6 6t�fJ Structural control measures are constru ted BMPs that reduce the impact of stormwater and non- stormwater on receiving water quality, They are broken filto th cecategories: • Distributed Structural BMPs, which treaW unoff close to the source and are typically implemented at a single- or few -parcel level (e.g., facilities typically serving a contributing area less than one acre). • Centralized Structural BMPs, which treatnoff from a contributing area of multiple parcels (e.g., facilities typically serving a contributing area on the order of tens or y hundreds of acres or larger). • Regional Structural BMPs, which are meant to retain the 85th percentile storm over 24 hours from a contributing area. Generally, the 85°i percentile storm is approximately 0.75 inches over 24 hoursn a,,) H L Whether distributed, centralized, or regional, the major structural BMP functions are infiltration, S treatment, and storage, which may be used individually Aorcombim natio • Infiltration, where runoff is directed to percolate into the underlying soils. Infiltration generally reduces the volume of runoff and creaseigroundwater recharge. • Treatment, where pollutants are removed throughh various unit processes, including filtration, settling, sedimentation, sorption, straining, and biological or chemical transformations, Storage, where runoff is captured, stored (detained), and slowly released into downstream waters, Storage can reduce the peak flow rate from a site, but does not / V� directly reduce runo volume. C E?� The types of structural BMPs to be implemented will vary between EWMPs, but most EMWPs will include a variety of distributed, centralized, and regional BMPs. These are policies, actions, and activities which are intended to minimize or eliminate pollutant �source . Most institutional BMPs are implemented to meet Minimum Control Measure (MCM) requhe ents in the MS4 permit; MCMs are considered a subset of institutional BMPs. These au4L BMPs are not constructed, but may have costs associated with the procurement and installation of t n _ ` L-m� items such as signage or spill response kits reA0cvl--a-�5 ES,5 Project Alternatives An EIR must describe a range of reasonable alternatives to the proposed project or alternative project locations that could feasibly attain most of the basic project objectives and would avoid or substantially lessen any of the significant environmental impacts to the proposed project. The LA County Flood Control Disldct ES -4 ESA/ 140474 Enhanced Watershed Management Progmms January 2015 Deft Program Environmental Impact Report Comment Letter 45 Executive Summary alternatives analysis must include the "No Project Alternative" as a point of comparison. The No Project Alternative includes existing conditions and reasonably foreseeable future conditions that would exist if the proposed project were not approved (CEQA Guidelines §15126.6). ES.6 Summary of Impacts Table ES -1, at the end of this chapter, presents a summary of the impacts and mitigation measures identified for the proposed project. The complete impact statements and mitigation measures are presented in Chapter 3. The level of significance for each impact was determined using significance criteria (thresholds) developed for each category of impacts; these criteria are presented in the appropriate sections of Chapter 3. Significant impacts are those adverse environmental impacts that meet or exceed the significance thresholds; less -than -significant impacts would not exceed the thresholds. Table ES -1 indicates the measures that will avoid, minimize, or otherwise reduce significant impacts to a less -than -significant level if implemented by the Permittees. ES.7 Areas of Controversy Several comment letters from agency and public comments were received during the scoping period. Public comments received are provided in Appendix A of this PEIR. Some of the comments from non-governmental organizations and the public expressed concerns regarding the lack of project -specific details provided in the NOP for individual BMPs. Several comments were received questioning the funding strategies to be employed by Permittees. The full list of comments highlighting areas of potential controversy received during the public scoping period is included in Appendix A. ES.8 Issues to be Resolved Section 15123(b)(3) of the CEQA Guidelines requires that an EIR contain issues to be resolved, which includes the choice among alternatives and whether or how to mitigate significant impacts. The following major issues are to be resolved: • Determine whether the PEIR adequately describes the environmental impacts of the proposed program; • Choose among alternatives; • Determine whether the recommended mitigation measures should be adopted or modified; and • Determine whether additional mitigation measures need to be applied to the project. LA county Flood control District ES -5 ESA 1140474 Enhanced Watershed Management Programs January 2015 Oran Program EmAronmenlal Impact Report to Comments Response to Comment Letter 45 (City of Santa Monica — March 12, 2015) Response to Comment 45-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. Page 47 of the revised MS4 Permit (Order No. R4-2012-0175) states that watershed management programs (including EWMPs) allow the permittees to address the highest watershed priorities, including complying with receiving water limitations and total maximum daily load provisions. According to page 48 of the revised MS4 Permit, an EWMP is a form of compliance with the MS4 Permit provisions that comprehensively evaluates opportunities within watershed management areas for collaboration on multi -benefit regional projects that, wherever feasible, retain (i) all non -storm water runoff and (ii) all storm water runoff from the 85th percentile, 24- hour storm event for the drainage areas tributary to the projects, while also achieving other benefits including flood control and water supply. Therefore, flood control and water supply are listed as secondary benefits of EWMP implementation (as opposed to the primary purpose of protecting water quality), and therefore do not require the kind of emphasis as suggested by the commenter. As a result, the handwritten text edits provided by the commenter regarding water supply, as well as other minor text edits, were not included as revisions. a County Flood Control District 11-401 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comment Letter 46 Paige Anderson To: Sarah Hays Subject: RE: Westwood Neighborhood Greenway -----Original Message ----- From: Sarah Hays [mailto:sirrahh@sbcglobal.netl Sent: Friday, February 27, 2015 1153 AM To: Gregg Begell - Consultant Subject: Westwood Neighborhood Greenway Please see attached letter of support for Westwood Neighborhood Greenway. Thank you. Comment Letter 46 10509@IyltieAvenue • Los Angeles California 9€064.310J558.3538a sirrahn4sbcglabal_net 27 February 2015 Qregg. BeQGell, P, . County of Los Angeles Department of Pubkc Works Project Management Division II WO South Fremont, 5th Floor AlhormbrCa, Cofifomia 91803 ai:be�je.11 .Y dw.locourily guv Dear Mr. BeGell, I am writing in support of the Westwood Neighborhood Greenway, Project 193 of your Enhancecd Watershed Mgnagement Pion (EWMPj for the 63cllonca Creep Watershed', The Greenway will be 4 multi -benefit project which will provide [1) urban runoff trectment, 12) native habitat, and [3j public access via transit. bicycle and pedestrian paths. By pumping water from the storm drain Under Civerlond Avenue tinct doyFghtirig this'woter in a stream flowing through the project area, the Greenway will use natural and suslainable water treatment methods to remove pollutants from up to 48 million gallons of water per year. Also, the Greenway project will eliminate the need for potob4e water to irrigate bath the Expo POW and the Greenway area. _I But one exceptionol feature of the Greenway projeai is that it will be adjacent to the busiest station on the Expo Light Rail fine, which itself is part of the growling Metro transit network. Commuters riding the train ar waiting for their train at the Westwood/Rancho Pork Station will see it. Students walking either to school or to take the train or bus to school will see 0. Signage will make it an education on watershed health for everyone who passes_ Arid eduoatiorial programs led by LA Audubon and Rancho Santa Ano Botanic Garden will introduce the Greenwoy+ to even more Students; high-schoolmcge intem5 con da waiter - quality studies as a port of their science curricOurn: elementary school OjdlentS can come to the Greenway to discuss watersheds and how to protect them. The adjacency to the Expo Lne links the Greenway to many schools including USC, UCLA, Dorsey High Schao9, Foshay Learning Center, Santa Monies High School, and Overland Avenue Elementary Schaal. Thunk you fpr your support of this wonderful project! Sincerely. hHYHa Comments Response to Comment Letter 46 (Sarah Hays — February 27, 2015) Response to Comment 46-A: Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assesses the environmental impacts associated with implementation of EWMPs as a form of compliance with the MS4 Permit. More site investigations are needed to fully vet the proposed Westwood Neighborhood Greenway project and define the project scope needed to satisfy the EWMP's requirements. The City of Los Angeles is the primary agency who will benefit from a water quality project at the Westwood Neighborhood Greenway project. The City of Los Angeles will likely play a major role in the decision to implement an EWMP project at Westwood Neighborhood Greenway project. IA County Flood Control District 11-404 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments 11.3 PUBLIC MEETING COMMENT SUMMARIES AND RESPONSES This section excerpts those spoken comments transcribed during the public meetings that specifically pertain to the scope and content of the PEIR. The six public meetings that were made available for public comments are listed below: • Public Meeting 1 (Florence -Firestone Service Center — January 29, 2015) • Public Meeting 2 (LA County Fire Camp — February 3, 2015) • Public Meeting 3 (San Pedro Service Center—February 5, 2015) • Public Meeting 4 (Topanga Library — February 10, 2015) • Public Meeting 5 (Hacienda Heights Community Center — February 11, 2015) • Public Meeting 6 (East Los Angeles Library — February 17, 2015) a County Flood Control District 11-405 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Public Meeting 1 Comments (Florence -Firestone Service Center — January 29, 2015) 7807 S. Compton Ave., Los Angeles, CA 90001 6:00 P.M. — 8:00 P.M. The commenter is inquiring as to whether Grey Water Plumbing is legal. Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The commenter is referred to the Los Angeles County Department of Building and Safety or local municipal building department for further information regarding grey water plumbing. A plumbing permit is typically required to be obtained from the jurisdictional agency in which the grey water system would be located, prior to the erection, construction, reconstruction, installation, relocation or alteration of any graywater system. Under State regulations, graywater is defined as untreated wastewater that has not been contaminated by toilet waste or unhealthy bodily wastes. Graywater includes wastewater from bathtubs, showers, bathroom washbasins, clothes washing machines, and laundry tubs, but does not include wastewater from kitchen sinks or dishwashers. A graywater system uses graywater for subsurface irrigation and may include tanks, valves, filters, pumps or other appurtenances along with piping and receiving landscape. Graywater should not be used in spray irrigation and should not be allowed to pond, runoff or be discharged directly into or reach any storm water system or any surface body of water. Additionally, graywater shall not be used to irrigate root crops or edible parts of food crops that touch the soil. IA County Flood Control District 11406 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Public Meeting 2 Comments (LA County Fire Camp — February 3, 2015) 4810 Oak Grove Drive, La Canada Flintridge, CA 91011 6:00 P.M. — 8:00 P.M. No comments were received at this meeting. a County Flood Control District 11-407 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Public Meeting 3 Comments (San Pedro Service Center — February 5, 2015) 769 W. Third St., San Pedro, CA 90731 6:00 P.M. — 8:00 P.M. No comments were received at this meeting. LA County Flood Control District 11-408 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Public Meeting 4 Comments (Topanga Library — February 10, 2015) 122 N. Topanga Canyon Blvd., Topanga, CA 90290 6:00 P.M. — 8:00 P.M. Response to Comment PM4-A: The commenter asks how the PEIR deals with open space areas Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. The PEIR assumes that BMPs may be installed in any location, whether urbanized or previously undisturbed. The impact analysis assumes some projects may be proposed in open space areas and evaluates impact avoidance and minimization measures. The PEIR provides maps in Appendix G to the PEIR showing prospective locations for BMPs. The locations are broadly distributed throughout the watersheds. The LACFCD acknowledges that BMPs are not limited to urban areas but may be installed throughout a watershed if necessary to achieve water quality objectives. The PEIR acknowledges on page 1-11 that BMPs may be proposed in any location including open space areas. The impact analysis and mitigation measures have been prepared to reflect the wide diversity of potential project locations and evaluate worse -case conditions that may include the presence of sensitive habitats. Response to Comment PM4-B: The commenter is inquiring as to whether this area (Topanga Canyon) is differentiated from urban areas. The project area is generally differentiated by the Watershed Management Areas delineated by the Regional Water Quality Control Board, shown on Figure 2-1 of the Draft PEIR. As a result of the programmatic nature of the Draft PEIR, many of the subareas located within the Watershed Management Areas were not differentiated. The PEIR assumes that BMPs may be installed in any location, whether urbanized or previously undisturbed. The impact analysis assumes some projects may be proposed in open space areas and evaluates impact avoidance and minimization measures. The PEIR provides maps in Appendix G to the PEIR showing prospective locations for BMPs. The locations are broadly distributed throughout the watersheds. The LACFCD acknowledges that BMPs are not limited to urban areas but may be installed throughout a watershed if necessary to achieve water quality objectives. The PEIR acknowledges on page 1-11 that BMPs may be proposed in any location including open space areas. The impact analysis and mitigation measures have been prepared to a County Flood Control District 11-409 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments reflect the wide diversity of potential project locations and evaluate worse -case conditions that may include the presence of sensitive habitats. Because project details are largely incomplete since the EWMPs are being drafted concurrently, each individual project will be subject to a CEQA compliance evaluation prior to approval by the implementing agencies as noted in Section 1 of the Draft PEIR. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of its proposed projects. The PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis outlines mitigation strategies to be followed by the LACFCD and other implementing agencies that rely on the PEIR to avoid or minimize impacts wherever feasible. The PEIR provides the LACFCD a foundation for any necessary future environmental review that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. Response to Comment PM4-C: The commenter states that there are fewer engineered channels in open space areas. The PEIR assumes that BMPs may be installed in any location, whether urbanized or previously undisturbed. The impact analysis assumes some projects may be proposed in open space areas and evaluates impact avoidance and minimization measures. The PEIR provides maps in Appendix G to the PEIR showing prospective locations for BMPs. The locations are broadly distributed throughout the watersheds. The LACFCD acknowledges that BMPs are not limited to urban areas but may be installed throughout a watershed if necessary to achieve water quality objectives. The PEIR acknowledges on page 1-11 that BMPs may be proposed in any location including open space areas. The impact analysis and mitigation measures have been prepared to reflect the wide diversity of potential project locations and evaluate worse -case conditions that may include the presence of sensitive habitats. The project area is generally differentiated by the Watershed Management Areas delineated by the Regional Water Quality Control Board, shown on Figure 2-1 of the Draft PEIR. As a result of the programmatic nature of the Draft PEIR, many of the subareas located within the Watershed Management Areas were not differentiated. Because project details are largely incomplete since the EWMPs are being drafted concurrently, each individual project will be subject to a CEQA compliance evaluation prior to approval by the implementing agencies as noted in Section 1 of the Draft PEIR. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is required or that a project is exempt from IA County Flood Control District 11-410 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Rupert to Comments CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of its proposed projects. The PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis outlines mitigation strategies to be followed by the LACFCD and other implementing agencies that rely on the PEIR to avoid or minimize impacts wherever feasible. The PEIR provides the LACFCD a foundation for any necessary future environmental review that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. Response to Comment PM4-D: The commenter states that the Los Angeles River is being evaluated for re -design. The commenter is asking if there is an intention to cement over the creeks in the watershed. The EWMPs are developing projects to retain stormwater within the watershed as much as possible. Cementing creeks would act to increase the speed of water conveyed toward the ocean, which is opposite to one of the many goals of the EWMP Program. However, some projects will include armoring to protect certain areas from erosion, which may require additional concrete. Response to Comment PM4-E: The commenter is asking if Madera Creek was on the priority project list. Priority projects identified at the time of publication of the PEIR are included in Appendix G. Madera Creek improvements are currently not identified on the priority projects list for the North Santa Monica Bay Coastal Watersheds EWMP. Response to Comment PM4-F: The commenter is inquiring as to whether the priority projects will be included as examples of proposed projects in PEIR. Priority projects identified at the time of publication of the PEIR are included in Appendix G. Examples of regional, centralized and distributed BMP projects are identified in Chapter 2, Project Description, of the Draft PEIR. Response to Comment PM4-G: The commenter inquires as to whether the PowerPoint from the presentation is on the website. Yes, the PowerPoint from the public meeting is available on the following website: www.LACoH20sheds.com. a County Flood Control District 11-411 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Response to Comment PM4-H: The commenter asks if there are any priority projects in the Topanga Creek watershed. Priority projects identified at the time of publication of the PEIR are included in Appendix G. Projects have been identified in the North Santa Monica Bay Coastal Watersheds for Topanga. Response to Comment PM4-I: The commenter states that Caltrans is not a Permittee, and asks if the County is working with Caltrans in cooperation. Caltrans is not a Permittee of the MS4 Permit and is therefore not an active member of the EWMP development groups. Stormwater conveyance facilities owned by Caltrans facilities are covered under a separate stormwater discharge permit. However, Caltrans shares responsibility for certain TMDLs with MS4 Permittees and continues to work collaboratively with MS4 Permittees in addressing the TMDLs. Response to Comment PM4-J: The commenter asks if the permittees will engage with Caltrans for individual projects. Caltrans is not a Permittee of the MS4 Permit and is therefore not an active member of the EWMP development groups. Stormwater conveyance facilities owned by Caltrans facilities are covered under a separate stormwater discharge permit. However, Caltrans shares responsibility for certain TMDLs with MS4 Permittees and continues to work collaboratively with MS4 Permittees in addressing the TMDLs. Response to Comment PM4-K: The commenter inquires about the extent Caltrans needs to engage to achieve results. Caltrans is not a Permittee of the MS4 Permit and is therefore not an active member of the EWMP development groups. Stormwater conveyance facilities owned by Caltrans facilities are covered under a separate stormwater discharge permit. However, Caltrans shares responsibility for certain TMDLs with MS4 Permittees and continues to work collaboratively with MS4 Permittees in addressing the TMDLs. Response to Comment PM4-L: The commenter asks if we can identify projects where we can engage with Caltrans. For example on SR 27, SR 1, US 101, or any State Route in the County. Caltrans is not a Permittee of the MS4 Permit and is therefore not an active member of the EWMP development groups. Stormwater conveyance facilities owned by Caltrans facilities are covered under a separate stormwater discharge permit. However, Caltrans shares responsibility for certain TMDLs with MS4 Permittees and continues to work collaboratively with MS4 Permittees in addressing the TMDLs. LA County Flood Control District 11-412 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Rupert to Comments Response to Comment PM4-M: The commenter asks what the County's degree of influence is in the ULARA Watershed. LACFCD is a participant of the Upper Los Angeles River EWMP. LACFCD owns and maintains flood control facilities in unincorporated areas of the watershed, and is a partner with the watershed group to develop BMPs. Appendix G of the PEIR includes priority projects as identified at the time of publication of the PEIR for the Upper Los Angeles River watershed (Figure 2-14). Response to Comment PM4-N: The commenter asks what projects are being proposed in the north slope of the SM Mountains — headwaters to the LA River. LACFCD is a participant of the Upper Los Angeles River EWMP. LACFCD owns and maintains flood control facilities in unincorporated areas of the watershed, and will partner with the watershed group to develop BMPs. Appendix G of the PEIR includes priority projects as identified at the time of publication of the PEIR for the watershed. Response to Comment PM4-0: The commenter asks how the inclusion of open natural space and parkland will affect water quality estimates within the EWMPs. The water quality modeling underway for each watershed incorporates existing open space areas. Areas that are restored from developed areas to open space may provide water quality benefits and can be reflected in the EWMP adaptive management process. Some of the structural BMPs associated with the proposed program are anticipated to be located on existing parkland, as these open space areas offer ample area for potential subsurface spreading and infiltration. Response to Comment PM4-P: The commenter inquires as to whether we can calculate carbon footprint of undeveloped/preserved space. Areas that are restored from developed areas to open space may provide water quality benefits and reduce carbon emissions. However, existing open space areas are part of the baseline condition. Response to Comment PM4-Q: The commenter inquires as to whether preservation can be a BMP, and how we can get preservation to be a BMP. A variety of BMP types are defined in the EWMP Work Plans and NOIs. Section 2.4, EWMP BMP Types, provides an overview of non-structural and structural BMP types that will be part of the EWMPs. Additional information and figures on the location and distribution of potential and a County Flood Control District 11-413 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments priority BMPs based on available data at the time of publication of the PEIR, are presented in Section 2.5, EWMP Watershed Characteristics and BMP Implementation Strategies. Response to Comment PM4-R: The commenter asks if restoration qualifies as a BMP Creek/river/floodplain/estuary restoration is identified as a potential Centralized Structural BMPs. Table 2-2 of the Draft PEIR describes the sub -types of distributed, centralized, and regional structural BMPs that form the basis of the water quality improvements proposed in the EWMPs. Creek, river, and estuary restoration projects provide a unique opportunity to restore natural cleansing processes, reestablish habitats and address impacts from hydromodification and urban runoff. These projects are the only BMPs that are implemented within the receiving water. Response to Comment PM4-S: The commenter asks what residents in Topanga need to be concerned with, as this EWMP is such big picture. The PEIR assumes that BMPs may be installed in any location, whether urbanized or previously undisturbed. The impact analysis assumes some projects may be proposed in open space areas and evaluates impact avoidance and minimization measures. The PEIR provides maps in Appendix G to the PEIR showing prospective locations for BMPs. The locations are broadly distributed throughout the watersheds. The LACFCD acknowledges that BMPs are not limited to urban areas but may be installed throughout a watershed if necessary to achieve water quality objectives. The PEIR acknowledges on page 1-11 that BMPs may be proposed in any location including open space areas. The impact analysis and mitigation measures have been prepared to reflect the wide diversity of potential project locations and evaluate worse -case conditions that may include the presence of sensitive habitats. The project area is generally differentiated by the Watershed Management Areas delineated by the Regional Water Quality Control Board, shown on Figure 2-1 of the Draft PEIR. Because project details are largely incomplete since the EWMPs are being drafted concurrently, each individual project will be subject to a CEQA compliance evaluation prior to approval by the implementing agencies as noted in Section 1 of the Draft PEIR. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of its proposed projects. The PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis outlines mitigation strategies to be followed by the LACFCD and other implementing agencies that rely on the PEIR to avoid or minimize impacts wherever feasible. LA County Flood Control District 11-414 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments The PEIR provides the LACFCD a foundation for any necessary future environmental review that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. The Topanga watershed includes large open space areas with steep slopes and natural creeks. BMPs in these areas may be considered that slow runoff down to reduce scouring and erosion and promote infiltration. Appendix G of the PEIR includes priority projects identified at the time of publication. Response to Comment PM4-T: The commenter asks how he/she can find out and participate in the EWMP process. Information on the development of the EWMPs is posted on the following website: www.LACoH2Osheds.com. The public is encouraged to attend meetings as they are posted. Response to Comment PM4-U: The commenter asks if there is an assessment of existing resource management plans being considered to ensure goals and objectives. These could either inform or conflict with the proposed project. The PEIR summarizes land use management plans within the Section 3.9, Land Use and Section 3.3, Biological Resources. The Santa Monica Mountains Conservancy Plan, Los Angeles County General Plan Significant Ecological Areas, and local tree preservation ordinances are described on page 3.3-16. The PEIR evaluates consistency with local land use plans in Impact 3.9-2 on page 3.9-34. Response to Comment PM4-V: The commenter inquires as to whether this compliance process can assist with goals and objectives of other plans and programs. Although the primary goals of resource plans may be different, multiple benefits are achievable. As noted on page 1-5 of the PEIR, implementation of BMPs through the EWMP process may result in ancillary benefits to water supply, flood control, and recreation. Response to Comment PM4-W: The commenter asks if LADWP will send responses to all meeting participants in tonight's meeting. Responses to public agency comments will be made available to commenters within 10 days prior to the consideration of the adequacy of the PEIR by the Board of Supervisors as required by Section 15088 of the CEQA Guidelines. The responses and the Final PEIR will be available on- line at www.LACoH2Osheds.com. Response to Comment PM4-X: The commenter asks when permittees will go to RWQCB with their final projects a County Flood Control District 11-415 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments The EWMPs will be submitted to the RWQCB by June 28, 2015. Response to Comment PM4-Y: The commenter asks when LA watershed meetings will take place. Information pertaining to this project and meetings related to this project will be available on-line at www.LACoH2Osheds.com. LA County Flood Control District 11-416 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Public Meeting 5 Comments (Hacienda Heights Community Center — February 11, 2015) 1234 Valencia Avenue, Hacienda Heights CA 91745 6:00 P.M. — 8:00 P.M. Response to Comment PM5-A: The commenter asks who should be called if one observes someone irrigating when it rains Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. Each city and water utility in the County may impose differing outdoor water use restrictions during this period of drought. Please contact your local water purveyor. For enquiries and information regarding lawn watering restrictions and reporting in Los Angeles, please call the following hot-line: 1 -888 -CLEAN LA (1-888-253-2652). One can also visit www.CleanLA.com. Response to Comment PM5-B: The commenter inquires about the regulations in place to control irrigation wasting. In regard to irrigation wasting, each city and water utility in the County may impose differing outdoor water use restrictions during this period of drought. Please contact your local water purveyor. For enquiries and information regarding lawn watering restrictions and reporting in Los Angeles, please call the following hot-line: 1 -888 -CLEAN LA (1-888-253-2652). One can also visit www.CleanLA.com. Response to Comment PM5-C: The commenter is inquiring about the benefits of a PEIR compared to an individual EIR The rationale for preparing a PEIR is described on page 1-3. The PEIR defines typical project types in Section 2 and then in Section 3 evaluates potential impacts of implementing hundreds of these types of projects throughout the region over a long period of time. The use of a PEIR pursuant to CEQA Guidelines Section 15168 is intended to evaluate broad-based impacts early in the planning process and is the appropriate CEQA compliance for the EWMPs at this time. As projects are refined in the future, each individual project will undergo subsequent CEQA determination by the lead implementing agency prior to approval. Response to Comment PM5-D: The commenter asks if these projects improve drinking water a County Flood Control District 11-417 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments The PEIR discusses potential impacts to local groundwater basins on page 3.8-35. The projects under the EWMPs include regional centralized retention and infiltration projects that can recharge local aquifers. These projects can augment local water supplies. Local water supplies are largely shared resources, managed by regional agencies (e.g., Metropolitan, Castaic Lake Water Agency) responsible for supplying drinking water equitably to the population. Local water retailers receive their water generally from imported water wholesalers and groundwater pumping. Groundwater recharge resulting from infiltration BMPs will occur throughout the region. Some areas will experience greater volumes of recharge than others due to the local topography and geology. The delivery of high quality drinking water is the responsibility of water retailers as regulated by the State Water Resources Control Board and the California Department of Public Health. Response to Comment PM5-E: The commenter asks if the projects can be used to help save trees in local parks. As described in Section 2 of the PEIR, several types of BMPs would promote multiple benefits to water supply, flood control and recreation. Some projects (e.g., rain barrels) may include the capture, retention, and re -use of both dry weather flows and storrnwater flows to supplement irrigation of community parks to help preserve native trees and other landscape. Response to Comment PM5-F: The commenter is asking if the PEIR assesses the issue of public health, in particular mosquito breeding habitat. The commenter also suggests that Operation and Maintenance (O&M) issues need to address this concern. The PEIR discusses potential impacts to public health in Impact 3.7-2. The PEIR acknowledges that accumulation of contaminants in BMPs over time could result in hazardous conditions. Mitigation Measure HAZ-1 is included to ensure that maintenance plans are prepared and implemented to reduce the risk to public health. BMPs may detain water that stagnates or generates odors. Other vectors such as mosquitos and rodents could be attracted to standing water. Local vector control agencies would employ measures to reduce public health impacts from areas of standing water in cooperation with the LACFCD. In Response to Comment 20 -GG above, Mitigation Measure HAZ-1 has been revised as follows: HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The Maintenance Plan shall include vector control requirements. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller LA County Flood Control District 11-418 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. Response to Comment PM5-G: The commenter identifies that the key issue is Operation and Maintenance. He explains that sedimentation and vegetation growth results in ponding of water, which creates vector breeding habitats, a serious public health issue. The PEIR discusses potential impacts to public health in Impact 3.7-2. The PEIR acknowledges that accumulation of contaminants in BMPs over time could result in hazardous conditions. Mitigation Measure HAZ-1 is included to ensure that maintenance plans are prepared and implemented to reduce the risk to public health. BMPs may detain water that stagnates or generates odors. Other vectors such as mosquitos and rodents could be attracted to standing water. Local vector control agencies would employ measures to reduce public health impacts from areas of standing water in cooperation with the LACFCD. Mitigation Measure HAZ-1 has been revised as follows: HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The Maintenance Plan shall include vector control requirements. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. Response to Comment PM5-H: The commenter expresses that maintenance plans need to define frequency of O&M, and it needs to address issues such as creation of habitats which restrict and/or limit O&M activities. The PEIR discusses potential impacts to public health in Impact 3.7-2. The PEIR acknowledges that accumulation of contaminants in BMPs over time could result in hazardous conditions. Mitigation Measure HAZ-1 is included to ensure that maintenance plans are prepared and a County Flood Control District 11-419 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments implemented to reduce the risk to public health. BMPs may detain water that stagnates or generates odors. Other vectors such as mosquitos and rodents could be attracted to standing water. Local vector control agencies would employ measures to reduce public health impacts from areas of standing water in cooperation with the LACFCD. Response to Comment PM5-I: The commenter is asking if citizen/community groups can be encouraged to help with maintenance such as removing trash at curb inlets. The PEIR discusses potential impacts to public health in Impact 3.7-2. The PEIR acknowledges that accumulation of contaminants in BMPs over time could result in hazardous conditions. Mitigation Measure HAZ-1 is included to ensure that maintenance plans are prepared and implemented to reduce the risk to public health. BMPs may detain water that stagnates or generates odors. Other vectors such as mosquitos and rodents could be attracted to standing water. Local vector control agencies would employ measures to reduce public health impacts from areas of standing water in cooperation with the LACFCD. Each BMP would require its own maintenance plan. Maintenance plans would not rely on public volunteers, but many watershed clean-up activities could be supported by volunteer organizations. Response to Comment PM5-J: The commenter is inquiring about how detailed the evaluation of impacts to downstream resources is in the PEIR. The PEIR evaluates the potential for impact to downstream biological resources in Impact 3.3-1 and Impact 3.3-2. Mitigation Measures BIO -1 through BIO -8 were identified to ensure that significant impacts would be avoided. Mitigation Measure BIO -1 requires that project implementers conduct a biological assessment of downstream resources prior to project approval to ensure downstream beneficial uses are not adversely affected. Because these impacts vary between site and project type, this measure is best performed on a site by site basis. LA County Flood Control District 11-420 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments Response to Public Meeting 6 Comments (East Los Angeles Library — February 17, 2015) 4837 3rd Street, Los Angeles, CA 90022 6:00 P.M. — 8:00 P.M. Response to Comment PM6-A: The commenter requests a two week extension for public comment submittal. Thank you for submitting comments to the Los Angeles County Board of Supervisors (Board of Supervisors), governing Board of the Los Angeles County Flood Control District regarding the Proposed Program (or "Program"). These comments have been noted and will be provided to the Board of Supervisors for their consideration at such time as the Project is considered by the Board of Supervisors. A one-week extension was granted and notice of the extension was sent to interested parties. The public comment period ended March 16, 2015. Response to Comment PM6-B: The commenter recommends having more interactive mapping tool that allows the community to type in an address and see what projects are planned and/or prioritized near them. This suggestion will be passed to the County Flood Control District as part of the EWMP preparation. Response to Comment PM6-C: The commenter suggests that the EWMP should consider projects in areas where flooding frequently occurs in the LA River and Ballona Creek EWMP areas that can capture storm water and reduce flooding. This suggestion will be passed on to the County Flood Control District as part of the EWMP preparation. Response to Comment PM6-D: The commenter suggests that the EWMP should look into railroad crossing flooding because the pumps are currently undersized. This suggestion will be passed on to the County Flood Control District as part of the EWMP preparation. Response to Comment PM6-E: The commenter inquires about how priority projects are identified in the EWMP. a County Flood Control District 11-421 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments Priority projects undergo a detailed analysis that includes a site review and project evaluation, including an evaluation of soil types, land use, potential for multi -benefit projects and other factors which identified them as a priority. The Permit requires that a Reasonable Assurance Analysis be conducted using modeling tools to predict water quality benefits of the overall group of projects within a EWMP. Appendix G of the PEIR includes priority projects identified at the time of publication. Response to Comment PM6-F: The commenter inquires why there aren't more priority projects in the East Los Angeles community. Maps showing the planned and priority projects have not yet been finalized, but there are BMPs planned throughout the watershed in all neighborhoods. The distributed BMPs that are not shown on the maps include projects such as Green Streets that will have wide distribution and will be located throughout the urban areas. Appendix G of the PEIR includes priority projects identified at the time of publication. Response to Comment PM6-G: The commenter is inquiring about the discretionary action for the PEIR. The discretionary action prompting the need for CEQA compliance is the submittal of the completed EWMPs to the LARWQCB. As a result, the LACFCD, as lead agency, has prepared this Program Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the EWMPs. The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior to submittal of the EWMPs. The EWMPs will be submitted by each EWMP group to the LARWQCB. Response to Comment PM6-H: The commenter is asking if the PEIR includes an economic analysis. The EWMPs will summarize project costs and funding mechanisms available to implementing agencies. Implementing agencies are responsible for identifying funding mechanisms needed to effectuate Permit compliance. The PEIR does not evaluate costs or funding sources for BMP implementation since providing funding is not an environmental impact. Revenue sources will vary for each implementing agency but will likely include grant funding, low interest loans, or local fee assessment. Response to Comment PM6-I: The commenter is asking if the certification by the Board of Directors includes a means to pay for the program. LA County Flood Control District 11-422 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments The EWMPs will summarize project costs and funding mechanisms available to implementing agencies. The Board of Directors is certifying the PEIR and approving the submittal of the EWMPS to meet the requirements of the MS4 Permit. This discretionary action does not include providing funds for any specific project. Response to Comment PM6-J: The commenter is asking if the system can be maintained, and what the cost is for such maintenance. Mitigation Measure HAZ-1 is included in the PEIR to ensure that maintenance plans are prepared and implemented to reduce the risk to public health. As stated in Mitigation Measure HAZ-1, the plans shall identify the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. Mitigation Measure HA -Z-1 has been revised as follows: HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The Maintenance Plan shall include vector control requirements. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. The EWMPs will summarize project costs and funding mechanisms regarding operations and maintenance available to implementing agencies. Implementing agencies are responsible for identifying funding mechanisms needed to effectuate Permit compliance. The PEIR does not evaluate costs or funding sources for BMP implementation since providing funding is not an environmental impact. Revenue sources will vary for each implementing agency but will likely include grant funding, low interest loans, or local fee assessment. Response to Comment PM6-K: The commenter is inquiring about what would happen if a project is planned that is not currently covered or listed in the PEIR. a County Flood Control District 11-423 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments The PEIR acknowledges that most of the projects to be included in the EWMPs are either currently undefined or currently under development. Appendix G of the PEIR includes priority projects identified at the time of publication. Some background on the MS4 Permit is provided in Section 1, explaining the policies guiding the implementation of the BMPs. As noted in Section 1, each individual project will undergo subsequent CEQA determination by the lead implementing agency prior to approval. Response to Comment PM6-L: The commenter is asking if the PEIR identifies the process to update the PEIR if and/or when the project/program changes. Because project details are largely incomplete since the EWMPs are being drafted concurrently, each individual project will be subject to a CEQA compliance evaluation prior to approval by the implementing agencies as noted in Section 1 of the Draft PEIR. As individual projects identified in the EWMPs are fully developed, the implementing agency (i.e., the Permittee responsible for implementing the project) will conduct CEQA analysis for individual projects, as appropriate, or may determine that no additional CEQA analysis is required or that a project is exempt from CEQA. Each implementing agency would determine the significance after mitigation for potential impacts of its proposed projects. The PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis outlines mitigation strategies to be followed by the LACFCD and other implementing agencies that rely on the PEIR to avoid or minimize impacts wherever feasible. The PEIR provides the LACFCD a foundation for any necessary future environmental review that focus on individual projects of the EWMPs for which the LACFCD is the designated Lead Agency. Response to Comment PM6-M: The commenter is inquiring about the methods used to reach out to community members that don't have computers. Notices of the public meetings were posted at the meeting sites, advertisements were placed in local papers and a list of over700 stakeholders was contacted through email. It was noted that the library has computers that provided free of charge use to the community. Response to Comment PM6-N: The commenter is asking about what projects are being considered to improve the trash screening curb inlet devices. LA County Flood Control District 11-424 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report to Comments LADPW is continuing to investigate new devices and BMPs that provide more effective trash screening and pollutant removal. These distributed BMPs will continue to be implemented throughout the watershed as needed. Response to Comment PM6-0: The commenter is recommending that the PEIR reference the 2004 Landscaping Guidelines, Plant Palettes LA River Master Plan. The 1996 Los Angeles River Master Plan provides design goals for the enhancement of multiple beneficial uses provided by the Los Angeles River. The landscape guidelines were updated in 2004. The landscape guidelines are specific to the Los Angeles River. Development of the EWMPs is consistent with this Master Plan. a County Flood Control District 11-425 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report Comments 11A REFERENCES Federal Emergency Management Agency (FEMA). 2015. Floodplain Management. Last updated April 1, 2015. Accessed at https://www.fema.gov/floodplain-management on April 2, 2015. Dictionary.com. 2015. "flood control." Accessed at http://dictionary.reference.com/browse/flood+control on April 2, 2015. Environmental Protection Agency (EPA). 2014. Water: Best Management Practices. Infiltration Basin. Last updated on July 2, 2014. Accessed at hM://water.epa. og_v/polwaste/npdes/swbmp/Infiltration-Basin.cfm on April 9, 2015. Los Angeles County Department of Public Works (LADPW). 2015. Tujunga Wash Restoration. Accessed at h!W://www.ladpw.org/wmd/watershed/LA/projects/roroiect view.cfm?prroiid=51 on April 10, 2015. Los Angeles County Department of Regional Planning (Los Angeles County Planning). 2015. "Hauled Water Initiative." Accessed at http://planning.lacounty.gov/dev/hauled#anc-s on April 2, 2015. Merriam -Webster. 2015a. Dictionary: minimize. Accessed at http://www.merriam- webster.com/dictionary/minimize on April 2, 2015. Merriam -Webster. 2015b. Dictionary: lessen. Accessed at http://www.merriam- webster.com/dictionary/lessen on April 2, 2015. Merriam -Webster. 2015c. Dictionary: reservoir. Accessed at http://www.merriam- webster.com/dictionary/reservoir on April 9, 2015. Merriam -Webster. 2015d. Dictionary: feasible. Accessed at http://www.merriam- webster.com/dictionary/feasibility on April 10, 2015. Merriam -Webster. 2015e. Dictionary: infeasible. Accessed at http://www.merriam- webster.com/dictionary/infeasibility on April 10, 2015. United States Geological Survey (USGS). 2015. Porosity, Permeability, and Ground Water. Last modified January 26, 2015. Accessed at http://online.wr.usgs.gov/outreach/landpeople/students/cc_rpg.html on April 1, 2015. LA County Flood Control District 11-426 ESA / 140474 Enhanced Watershed Management Programs Aiml 2015 Final Environmental Impact Report CHAPTER 12 CLARIFICATIONS AND MODIFICATIONS 12.1 Introduction The following clarifications and revisions are intended to update the Draft EIR in response to the comments received during the public review period. These changes, which have been incorporated into the Draft EIR, constitute the Final EIR, to be presented to the County of Los Angeles Board of Supervisors for certification and approval. These modifications clarify, amplify, or make insignificant changes to the EIR. Revisions to the EIR have not resulted in new significant impacts or mitigation measures or increased the severity of an impact. None of the criteria for recirculation set forth in the CEQA Guidelines section 15088.5(a) have been met, and recirculation of the EIR is not required. CEQA Guidelines Section 15088.5(a): (a) A lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review under Section 15087 but before certification... "Significant new information" requiring recirculation include, for example, a disclosure showing that: (1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented. (2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance. (3) A feasible project alternative or mitigation measure considerably different from the others previously analyzed would clearly lessen the environmental impacts of the project, but the project's proponents decline to adopt it. (4) The draft FIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. The revisions compiled in this Chapter do not constitute "Significant new information" noted in Section 15088.5(a)(1) since no new significant environmental impacts have been identified following the publication of the Draft PEIR. Although new mitigation measures have been added based on input from commenters to ensure impacts remain less than significant, these new measures would not in and of themselves result in significant impacts nor do they represent that a new impact was identified. Rather, the measures provide for greater assurance of less than significant impacts. The revisions compiled in this Chapter do not constitute "Significant new information" noted in Section 15088.5(a)(2) since none of the modifications would result in a substantial increase in impacts already identified. Rather, the revisions are designed to further reduce the potential for significant impacts. a County Flood Control District 12-1 ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report Clarifications and Modifications The revisions compiled in this Chapter do not constitute "Significant new information" noted in Section 15088.5(a)(3) since no new alternatives have been identified that would clearly lessen impacts. Finally, the revisions compiled in this Chapter do not constitute "Significant new information" noted in Section 15088.5(a)(4) since the PEIR is not fundamentally and basically inadequate and conclusory in nature. The PEIR compiles information available at the time of publication to assist in evaluating the values and risks of moving forward with a Permit compliance program. The PEIR as an advanced planning tool is meant to set the stage for future analysis of projects within the program as they are proposed for implementation as explained in Chapter 1 on pages 1-10 and 1-11. 12.2 Clarification and Modifications The changes to the Draft EIR are listed by section and page number. Text which has been removed is shown in this chapter with a strikethrough line, while text that has been added is shown with an underline. All of the changes shown in this section have also been made in the corresponding Final EIR sections. Minor editorial corrections (e.g., typographical, grammatical, etc.) have been made throughout the document and are not indicated by strikethrough or underline text. The addition of the cumulative impact conclusions shown as underlined in Table ES -1 do not reflect new conclusions, but rather that the conclusions from Chapter 3 have been compiled into the table, since they were inadvertently left off the table in the Draft EIR. Please refer to Chapter 11, Response to Comments, for referenced comment letters and corresponding comments. See next page showing entire Table ES -1 containing Mitigation Measure refinements. a County Flood Control District l Z -Z ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report LA County Flood Control District l Z -S ESA 1140379 Enhanced watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications TABLE ES -1 SUMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE ENHANCED WATERSHED MANAGEMENT PROGRAMS Significance before Significance if Mitigation Mitigation is Impacts Mitigation Measures Implemented Aesthetics 3.1-1: The proposed program could create a AES -1: Aboveground structures shall be designed to be Significant Less than significant substantial adverse effect on a scenic vista. consistent with local zoning codes and applicable design guidelines and to minimize features that contrast with neighboring development. 3.1.2: The proposed program could Implement Mitigation Measure ;;4ple� AES -1 Significant Less than significant substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway. 3.1-3: The proposed program could Implement Mitigation Measure kaplemeRtatieaei AES -1 Significant Less than significant substantially degrade the existing visual AES -2: Implementing agencies shall develop BMP character or quality of the site and its maintenance plans that are approved concurrently with each surroundings. structural BMP approval. The maintenance plans must include measures to ensure functionality of the structural BMPs for the life of the BMP. These plans may include general maintenance guidelines that apply to a number of smaller distributed BMPs. 3.1.4: The proposed program could create a None required Less than significant Not applicable new source of substantial light or glare which would adversely affect day or nighttime views in the area. Cumulative Aesthetics Impacts Implement Mitigation Measures AES -1 and AES -2 Significant Less than significant Air Quality 3.2.1: The project could conflict with or None required Less than significant Not applicable obstruct implementation of the applicable air quality plan. 3.2.2: The project could violate any air AIR -1: Implementing agencies shall require for large Regional Significant Significant and quality standard or contribute substantially or Centralized BMPs the use of low -emission equipment unavoidable for to an existing or projected air quality meeting Tier II emissions standards at a minimum and Tier III construction; Less than violation. and IV emissions standards where available as CARB- significant for required emissions technologies become readily available to operations. contractors in the region LA County Flood Control District l Z -S ESA 1140379 Enhanced watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications Impacts Mitigation Measures Significance before Mitigation Significance if Mitigation is Implemented receptors to substantial pollutant AIR -2: For large construction efforts that may result in concentrations. significant air emissions, implementing agencies shall encourage contractors to use lower -emission equipment through the bidding process where appropriate. 3.2.3: The program could result in a Implement Mitigation Measures lmplemeutatieaef AIR -1 and Significant Significant and cumulatively considerable net increase of AIR -2 unavoidable for any criteria pollutant for which the project shall reduce its daily construction intensity (e.g., reducing the construction; less than region is non -attainment under an amount of equipment used daily, reducing the amount of soil significant for applicable federal or state ambient air graded/excavated daily) to a level where the structural BMP operations. quality standard (including releasing project's construction emissions would no longer exceed emissions which exceed quantitative SCAQMD's LSTs or result in pollutant emissions that would thresholds for ozone precursors). cause or contribute to an exceedance of the most stringent 3.2.4: The project could expose sensitive AIR -3: For large construction efforts associated with Regional Significant Less than significant receptors to substantial pollutant or Centralized BMPs, implementing agencies shall conduct a concentrations. project -specific LST analysis where necessary to determine local health impacts to neighboring land uses. Where it is determined that construction emissions would exceed the applicable LSTs or the most stringent applicable federal or state ambient air quality standards, the structural BMP project shall reduce its daily construction intensity (e.g., reducing the amount of equipment used daily, reducing the amount of soil graded/excavated daily) to a level where the structural BMP project's construction emissions would no longer exceed SCAQMD's LSTs or result in pollutant emissions that would cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standards. 3.2.5: The proposed program could create AIR -4: During planning of structural BMPs, implementing Significant Less than significant objectionable odors affecting a substantial agencies shall assess the potential for nuisance odors to number of people. affect a substantial number of people. BMPs that minimize odors shall be considered the priority when in close proximity to sensitive receptors. Cumulative Air Quality Impacts Implement Mitigation Measures AIR -1 through AIR -2 Significant Significant and unavoidable for construction; less -than - significant for operations Biological Resources 3.3-1: The proposed project could have a BIO -1: Prior to approving a Regional or Centralized BMP., Significant Less than significant LA County Flood Control District l Z-4 ESA 11403]9 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications Significance before Significance if Mitigation Mitigation is Impacts Mitigation Measures Implemented substantial adverse effect, either directly or the Permittee shall conduct an evaluation of the suitability of through habitat modifications, on any the BMP location. Appropriate BMP sites should avoid sensitive species identified as special -status impacting large areas of native habitats including upland in local or regional plans, policies, or woodlands and riparian forests that support sensitive species regulations or by the California Department to the extent feasible. The evaluation shall include an of Fish and Wildlife or U.S. Fish and Wildlife assessment of potential downstream impacts resulting from Service. Flow diversions. BIO -2: Prior to ground disturbing activities in areas that could support sensitive biological resources, a habitat assessment shall be conducted by a qualified biologist to determine the potential for special -status wildlife species to occur within affected areas, including areas directly or indirectly impacted by construction or operation of the BMPs. BIO3: If a special -status wildlife species is determined to be present or potentially present within the limits of construction activities, a qualified biologist shall conduct pre -construction surveys of proposed work zones and within an appropriately sized buffer around each area as determined by a qualified biologist within 14 days prior to ground disturbing activities. Any potential habitat capable of supporting a special -status wildlife species shall be Flagged for avoidance if feasible. BIO -4: If avoidance of special -status species or sensitive habitats that could support special -status species (including, but not limited to, critical habitat, riparian habitat, and jurisdictional wetlands/waters) is not feasible, the Permittee shall consult with the appropriate regulating agency (USACE/USFWS or CDFW) to determine a strategy for compliance with the Endangered Species Act, California Fish and Game Code, and other regulations protecting special - status species and sensitive habitats. The Permittee shall identify appropriate impact minimization measures and compensation for permanent impacts to sensitive habitats and species in consultation with regulatory agencies. Construction of the project will not begin until the appropriate permits from the regulatory agencies are approved. BIO -5: If construction and vegetation removal is proposed between February 1 and August 31, a qualified biologist shall conduct a pre -construction survey for breeding and nesting birds and raptors within 500 -feet of the construction limits to determine and map the location and extent of breeding birds that could be affected by the project. Active nest sites located LA County Flood Control District I Z -O ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications Significance before Significance if Mitigation Mitigation is Impacts Mitigation Measures Implemented during the pre -construction surveys shall be avoided until the adults and young are no longer reliant on the nest site for survival as determined by a qualified biologist. 13I0-6: All construction areas, staging areas, and right-of- ways shall be staked, flagged, fenced, or otherwise clearly delineated to restrict the limits of construction to the minimum necessary near areas that may support special -status wildlife species as determined by a qualified biologist. 13I0-7: Prior to construction in areas that could support special status plants, a qualified botanist shall conduct a pre - construction floristic inventory and focused rare plant survey of project areas to determine and map the location and extent of special -status plant species populations within disturbance areas. This survey shall occur during the typical blooming periods of special -status plants with the potential to occur. The plant survey shall follow the CDFW Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (November 24, 2009). 13I0-6: If temporary construction -related impacts to special - status plant populations are identified within a disturbance area, the implementing agencies shall prepare and implement a special -status species salvage and replanting plan. The salvage and replanting plan shall include measures to salvage, replant, and monitor the disturbance area until native vegetation is re-established under the direction of CDFW and USFWS. 3.3-2: The proposed project could have a Implement Mitigation Measures BIOA through BI0-8 Significant Less than significant substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the CDFW or USFWS. 3.3.3: The proposed project could have a Implement BIO -1 through BIO -8 Significant Less than significant substantial adverse effect on federally 13I0-9: Prior to construction, a qualified wetland delineator protected wetlands as defined by Section shall be retained to conduct a formal wetland delineation in 404 of the Clean Water Act (including, but areas where potential jurisdictional resources (i.e., wetlands not limited to, marsh, vernal pool, coastal, or drainages) subject to the jurisdiction of USACE, RWQCB, etc.) through direct removal, filling, and CDFW, may be affected by the project. If jurisdictional hydrological interruption, or other means. resources are identified in the EWMP area and would be LA County Flood Control District I Z -g ESA 1140379 Enhanced watershed Management Programs April 2015 Final Program Environmental Impact Report Impacts Mitigation Measures directly or indirectly impacted by individual projects, the qualified wetland delineator shall prepare a jurisdictional delineation report suitable for submittal to USACE, RWQCB, and CDFW for purposes of obtaining the appropriate permits. Habitat mitigation and compensation requirements shall be implemented prior to construction in accordance with Mitigation Measure BIO -4. 3.3.4: The proposed project could interfere None required substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. Clarifications and Modifications Significance before Significance if Mitigation Mitigation is Implemented Less than significant Not applicable 3.3.5: The proposed project could conflict BIO -10: Oak trees and other protected trees shall be avoided Significant Less than significant with any local policies or ordinances to the extent feasible. If trees may be impacted by project protecting biological resources, such as a construction, a certified arborist shall conduct a tree inventory tree preservation policy or ordinance. of the construction impact area. If any oak trees or other protected trees will be impacted by BMP construction, the implementing agency shall obtain any required County or City permits. 3.3.6: The proposed project could conflict None required with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan. Cumulative Biological Resources Impacts Implement Mitigation Measures BIO -1 through BIO -10 Cultural Resources 3.4.1: The proposed program could cause a substantial adverse change in the significance of an historical resource as defined in §15064.5. CUL -1: For individual EWMP projects that could impact buildings or structures (including infrastructure) 45 years old or older, implementing agencies shall ensure that a historic built environment survey is conducted or supervised by a qualified historian or architectural historian meeting the Secretary of the Interior's Professional Qualification Standards for Architectural History. Historic built environment resources shall be evaluated for their eligibility for listing in the CRHR or local register prior to the implementing agency's approval of project plans. If eligible resources that would be considered historical resources under CEQA are identified, Less than significant Not applicable Significant Less than significant Significant Significant and Unavoidable LA County Flood Control District I Z -f ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications Significance before Significance if Mitigation Mitigation is Impacts Mitigation Measures Implemented demolition or substantial alteration of such resources shall be avoided. If avoidance is determined to be infeasible, the implementing agency shall require the preparation of a treatment plan to include, but not be limited to, photo- documentation and public interpretation of the resource. The plan will be submitted to the implementing agency for review and approval prior to implementation. CUL -2: Implementing agencies shall ensure that individual EWMP projects that require ground disturbance shall be subject to a Phase I cultural resources inventory on a project - specific basis prior to the implementing agency's approval of project plans. The study shall be conducted or supervised by a qualified archaeologist, defined as an archaeologist meeting the Secretary of the Interior's Professional Qualifications Standards for Archaeology, and shall be conducted in consultation with the local Native American representatives expressing interest. The cultural resources inventory shall include a cultural resources records search to be conducted at the South Central Coastal Information Center; scoping with the NAHC and with interested Native Americans identified by the NAHC; a pedestrian archaeological survey where deemed appropriate by the qualified archaeologist; and formal recordation of all identified archaeological resources on California Department of Parks and Recreation 523 forms and significance evaluation of such resources presented in a technical report following the guidelines in Archaeological Resource Management Reports (ARMR): Recommended Contents and Format, Department of Parks and Recreation, Office of Historic Preservation, State of California, 1990. If potentially significant archaeological resources are encountered during the survey, the implementing agency shall require that the resources are evaluated by the qualified archaeologist for their eligibility for listing in the CRHR and for significance as a historical resource or unique archaeological resource per CEQA Guidelines Section 15064.5. Recommendations shall be made for treatment of these resources if found to be significant, in consultation with the implementing agency and the appropriate Native American groups for prehistoric resources. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred manner of mitigation to avoid impacts to LA County Flood Control District l Z-0 ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications Significance before Significance if Mitigation Mitigation is Impacts Mitigation Measures Implemented archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project re-route or re -design, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, which may include data recovery or other appropriate measures, in consultation with the implementing agency, and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. CUL -3: The implementing agency shall retain archaeological monitors during ground -disturbing activities that have the potential to impact archaeological resources qualifying as historical resources or unique archaeological resources, as determined by a qualified archaeologist in consultation with the implementing agency, and any local Native American representatives expressing interest in the project. Native American monitors shall be retained for projects that have a high potential to impact sensitive Native American resources, as determined by the implementing agency in coordination with the qualified archaeologist. CUL -4: During project -level construction, should subsurface archaeological resources be discovered, all activity in the vicinity of the find shall stop and a qualified archaeologist shall be contacted to assess the significance of the find according to CEQA Guidelines Section 15064.5. If any find is determined to be significant, the archaeologist shall determine, in consultation with the implementing agency and any local Native American groups expressing interest, appropriate avoidance measures or other appropriate mitigation. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred means to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project re-route or re -design, project LA County Flood Control District l Z -`J ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications Impacts Mitigation Measures cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, such as data recovery or other appropriate measures, in consultation with the implementing agency and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. 3.4.2: The program could cause a Implement Mitigation Measure ska9lemeatatieu-ei CUL -2 substantial adverse change in the through CUL -4 significance of unique archaeological resources as defined in §15064.5. 3.4.3: The program could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature. 3.4.4: The program could disturb any human remains, including those interred outside of a formal cemetery. CUL -5: For individual structural BMP projects that require ground disturbance, the implementing agency shall evaluate the sensitivity of the project site for paleontological resources. If deemed necessary, the implementing agency shall retain a qualified paleontologist to evaluate the project and provide recommendations regarding additional work, potentially including testing or construction monitoring. CUL -6: In the event that paleontological resources are discovered during construction, the implementing agency shall notify a qualified paleontologist. The paleontologist will evaluate the potential resource, assess the significance of the find, and recommend further actions to protect the resource. CUL -7: The implementing agency shall require that, if human remains are uncovered during project construction, work in the vicinity of the find shall cease and the County Coroner shall be contacted to evaluate the remains, following the procedures and protocols set forth in Section 15064.5 (e)(1) of the CEQA Guidelines. If the County Coroner determines that the remains are Native American, the Coroner will contact the Native American Heritage Commission, in accordance with Health and Safety Code Section 7050.5, subdivision (c), and Public Resources Code 5097.98 (as amended by AB 2641). The NAHC will then designate a Most Significance before Significance if Mitigation Mitigation is Implemented Significant Less than significant Significant Less than significant Significant Less than significant LA County Flood Control District I Z- -1 U ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report LA County Flood Control District l L- I l ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications Significance before Significance if Mitigation Mitigation is Impacts Mitigation Measures Implemented Likely Descendant of the deceased Native American, who will engage in consultation to determine the disposition of the remains. Cumulative Cultural Resources Impacts Implement Mitigation Measures CUL -1 throuah CUL -7. Significant Significant and unavoidable Geologic and Mineral Resources 3.5.1: The proposed program could locate None required Less than significant Not applicable new facilities in areas susceptible to seismic impacts such as (1) rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault, (2) strong seismic groundshaking, or (3) seismically induced liquefaction or landslides, which could expose people, structures, or habitat to potential risk of loss, damage, injury, or death. 3.5.2: The proposed program could result in None required Less than significant Not applicable substantial soil erosion or the loss of topsoil. 3.5-3: The proposed program could be GEO-1: Prior to approval of infiltration BMPs, implementing Significant Less than significant located on a geologic unit or soil that is agencies shall conduct a geotechnical investigation of each unstable, or that would become unstable as a infiltration BMP site to evaluate infiltration suitability. If result of the program, and potentially result in infiltration rates are sufficient to accommodate an infiltration on-site or off-site non -seismically induced BMP, the geotechnical investigation shall recommend design geologic hazards such as landslides, lateral measures necessary to prevent excessive lateral spreading spreading, subsidence, collapse or sinkholes, that could destabilize neighboring structures. Implementing settlement, or slope failure. agencies shall implement these measures in project designs. 3.5.4: The proposed program could be None required Less than significant Not applicable located on expansive soil as defined in 24 CCR 1803.5.3 of the California Building Code (2013), creating substantial risks to life or structures. 3.5.5: The proposed program could have None required Less than significant Not applicable soils incapable of adequately supporting the use of a septic tank or alternative LA County Flood Control District l L- I l ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications Impacts wastewater treatment systems where sewers are not available for the disposal of wastewater. Mitigation Measures Significance before Significance if Mitigation Mitigation is Implemented 3.": The proposed program could result in None required Less than significant Not applicable the loss of availability of a known mineral resource that would be of value to the region and the residents of the state or a locally important mineral resource recovery site delineated on a local General Plan, Specific Plan, or other land use plan. Cumulative Geologic Resources Impacts Implement Mitigation Measure GEO-1 Significant Less than significant GEO-2: Prior to installing Bli designed to recharge local groundwater supplies, the Implementing Agency shall notify local groundwater managers including the Upper Los Angeles River Area Water Master, the Water Replenishment District of Southern California, or the San Gabriel Water Master as well as local water producers such as local municipalities and water companies. The Implementing Agency shall coordinate BMP siting efforts with groundwater managers and producers to mitigate high groundwater levels while increasing local water supplies. Greenhouse Gas Emissions 3.6.1: The proposed program could None required Less than significant Not applicable generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment. 3.6.2: The proposed program could conflict None required Less than significant Not applicable with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs. Cumulative Greenhouse Gas Emissions None required Less than significant Not applicable Impacts Hazards and Hazardous Materials 3.7-1: The proposed program would create None required Less than significant Not applicable a significant hazard to the public or the LA County Flood Control District I Z - 'I Z ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report Impacts environment through the routine transport, use, or disposal of hazardous materials or the accidental release during construction and maintenance activities. Mitigation Measures Clarifications and Modifications Significance before Significance if Mitigation Mitigation is Implemented 3.7-2: The proposed program could create a HAZ-1: Implementing agencies shall prepare and implement Significant significant hazard to the public or the maintenance practices that include periodic removal and environment through the accumulation of replacement of surface soils and media that may accumulate potentially hazardous materials into BMPs. constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the individual BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The Maintenance Plan shall include vector control requirements. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. 3.7.3: The proposed program could emit Implement Mitigation Measure I^ar HAZ-1 Less than significant hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing school. Less than significant Not applicable 3.7.4: The proposed program could be HAZ-2: Prior to the initiation of any construction requiring Significant Less than significant located on a site which is included on a list ground -disturbing activities in areas where hazardous of hazardous materials sites compiled material use or management may have occurred, the pursuant to Government Code Section implementing agencies shall complete a Phase 1 65962.5 and, as a result, could create a Environmental Site Assessment (ESA) in accordance with significant hazard to the public or the American Society for Testing and Materials (ASTM) Standard El 527-13 for each construction site. Any recommended LA County Flood Control District Enhanced Watershed Management Programs Final Program Environmental Impact Report ESA 1140379 April 2015 Clarifications and Modifications Impacts Mitigation Measures Significance before Significance if Mitigation Mitigation is Implemented environment. follow up sampling (Phase II activities) set forth in the Phase I Hazardous ESA shall be implemented prior to construction. The results of Mitigation Phase II studies, if necessary, shall be submitted to the local Measures HAZ-1, overseeing agency and any required remediation or further Materials Impacts delineation of identified contamination shall be completed prior to commencement of construction. 3.7.5: For a project located within an airport HAZ-3: Implementing Agencies shall require that those BMPs Significant Less than significant land use plan or, where such a plan has not that are within an airport land use plan area are compatible been adopted, within two miles of a public with criteria specified in FAA Advisory Circular No: 150/5200 - airport or public use airport, for a project 33B (FAA, 2007). If the proposed BMP is within the minimum within the vicinity of a private airstrip, the separation criteria, the Implementing Agency shall consult project could result in a safety hazard for with the airport and collaboratively evaluate whether the people residing or working in the project potential increase in wildlife hazards can be mitigated. area. 3.7.8: The proposed program could impair None required implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. 3.7.7: The proposed program could expose None required people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands. Cumulative Hazards and Hazardous Implement Mitigation Measures HAZ-1, HAZ-2 and HAZ 3 Materials Impacts Hydrology and Water Quality 3.8-1: The proposed project would violate None required water quality standards or waste discharge requirements or further degrade water quality. 3.842: The proposed project would result in HYDRO -1: Prior to approving an infiltration BMP, the higher groundwater levels and could Permittee shall conduct an evaluation of the suitability of the potentially affect groundwater quality. BMP location. Appropriate infiltration BMP sites should avoid areas with low permeability where recharge could adversely affect neighboring subsurface infrastructure. HYDRO -2: Prior to approving an infiltration BMP, the LA County Flood Control District Enhanced Watershed Management Programs Final Program Environmental Impact Report Less than significant Not applicable Less than significant Not applicable Significant Less than significant Less than significant Not applicable Significant Less than significant ESA 1140379 April 2015 Impacts 3.8-23: The proposed project could substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river, or by other means, in a manner that would result in substantial erosion or siltation on - or off-site. 3.834: The project could substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river or, by other means, substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site. Mitigation Measures Permitee shall identify pre-treatment technologies, type, and depth of filtration media; depth to groundwater; and other design considerations necessary to prevent contaminants from impacting groundwater quality. The design shall consider stormwater quality data within the BMP's collection area to assess the need and type of treatment and filtration controls. Local design manuals and ordinances requiring minimum separation distance to groundwater shall also be met as part of the design. HYDRO -3: Prior to the installation of an infiltration BMP, the Permitee shall conduct a regulatory database review for contaminated groundwater sites within a quarter mile of the proposed infiltration facility. The review shall include locations of on-site wastewater treatment systems. The Permittee shall identify whether any contaminated groundwater plumes or leach fields are present within close proximity to the BMP location that could be affected by infiltrated water and whether coordination with the local and state environmental protection overseeing agency and responsible party is warranted prior to final design of infiltration facility. NoAa-reguiredHYDRO.4: Prior to approving a structural BMP, the implementing agencies shall conduct an evaluation of the potential hydromodifcation impacts of the project. The evaluation shall recommend design measures necessary to Prevent or minimize any identified impacts, including flooding, erosion and/or scour. Design measures could include velocity dissipaters and bank re -enforcement components. Implementing agencies shall include these measures in roiact designs Implement Mitigation Measures HYDRO -4 3.8.45: The proposed project could create None required or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide LA County Flood Control District Enhanced Watershed Management Programs Final Program Environmental Impact Report Clarifications and Modifications Significance before Significance if Mitigation Mitigation is Implemented Less than significant Not applicable Less than significant Not applicable Less than significant Not applicable ESA 1140379 April 2015 Clarifications and Modifications Impacts Mitigation Measures Significance before Mitigation Significance if Mitigation is Implemented substantial additional sources of polluted runoff. 3.8.58: The project could place housing None required No impact Not applicable within a 100 -year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other authoritative flood hazard delineation map. 3.8.87: The project could place within a None required Less than significant Not applicable 100 -year flood hazard area structures that would impede or redirect flood flows. 3.8-78: The proposed project could expose None required Less than significant Not applicable structures to a significant risk of loss, including flooding as a result of the failure of a levee or dam. 3.8.89: The proposed project could place None required Less than significant Not applicable structures in areas subject to inundation by seiche, tsunami, or muciflow. Cumulative Hydrology and Water Quality None required Less than significant Not applicable Impacts Land Use and Agriculture 3.9-1: The proposed program could None required No Impact Not applicable physically divide an established community. 3.9.2: The proposed program could conflict None required No Impact Not applicable with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the program (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect. 3.9.3: The proposed program could conflict None required No Impact Not applicable with any applicable habitat conservation plan or natural community conservation LA County Flood Control District I Z- I0 ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report 3.9.6: The proposed program could conflict None required No Impact Not applicable with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)). The proposed program could result in the loss of forest land or conversion of forest land to non -forest use. Cumulative Land Use and Agriculture None required Less than significant Not applicable Impacts Noise 3.10-1: The proposed program could result NOISE -1: The implementing agencies shall implement the Significant Significant and in exposure of persons to, or generation of, following measures during construction as needed:: unavoidable for noise levels in excess of standardsconstruction; less than Include design measures necessary to reduce the established in the local general plan or significant for noise ordinance, or applicable standards of construction noise levels where feasible. These measures operations may include noise barriers, curtains, or shields. LA County Flood Control District I L-1 t ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications Significance before Significance if Mitigation Mitigation is Impacts Mitigation Measures Implemented plan. 3.9.4: The proposed program could convert None required No Impact Not applicable Prime Farland, Unique Farmland, or Farland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use. The proposed program could involve other changes in the existing environment which, due to their location or nature, could result in conversion of agricultural land to non- agricultural use or conversion of forest land to non -forest use. 3.9-5: The proposed program could conflict None required No Impact Not applicable with existing zoning for agricultural use, or a Williamson Act contract. 3.9.6: The proposed program could conflict None required No Impact Not applicable with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)). The proposed program could result in the loss of forest land or conversion of forest land to non -forest use. Cumulative Land Use and Agriculture None required Less than significant Not applicable Impacts Noise 3.10-1: The proposed program could result NOISE -1: The implementing agencies shall implement the Significant Significant and in exposure of persons to, or generation of, following measures during construction as needed:: unavoidable for noise levels in excess of standardsconstruction; less than Include design measures necessary to reduce the established in the local general plan or significant for noise ordinance, or applicable standards of construction noise levels where feasible. These measures operations may include noise barriers, curtains, or shields. LA County Flood Control District I L-1 t ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications Impacts Mitigation Measures other agencies. Place noise -generating construction activities (e.g., operation of compressors and generators, cement mixing, general truck idling) as far as possible from the nearest noise -sensitive land uses. • Locate stationary construction noise sources as far from adjacent noise -sensitive receptors as possible. • If construction is to occur near a school, the construction contractor shall coordinate the with school administration in order to limit disturbance to the campus. Efforts to limit construction activities to non -school days shall be encouraged. • For the centralized and regional BMP projects located adjacent to noise -sensitive land uses, identify a liaison for these off-site sensitive receptors, such as residents and property owners, to contact with concerns regarding construction noise and vibration. The liaison's telephone numbers) shall be prominently displayed at construction locations. • For the centralized and regional BMP projects located adjacent to noise -sensitive land uses, notify in writing all landowners and occupants of properties adjacent to the construction area of the anticipated construction schedule at least 2 weeks prior to groundbreaking. NOISE -2: All structural BMPs that employ mechanized stationary equipment that generate noise levels shall comply with the applicable noise standards established by the implementing agency with jurisdiction over the structural BMP site. The equipment shall be designed with noise -attenuating features (e.g., enclosures) and/or located at areas (e.g., belowground) where nearby noise -sensitive land uses would not be exposed to a perceptible noise increase in their noise environment. Significance before Significance if Mitigation Mitigation is Implemented 3.10-2: The proposed program could result None required Less than significant Not applicable in exposure of persons to, or generation of, excessive groundborne vibration. 3.103: The proposed program could result lmplemeatatiea a Implement Mitigation Measures NOISE -1 Significant Less than significant in a substantial permanent increase in and NOISE -2 ambient noise levels in the project vicinity LA County Flood Control District l Y= I t5 ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report 3.11-1: Implementation of the proposed None required No Impact Not applicable program could induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure). 3.11-2: Implementation of the proposed None required No Impact Not applicable program could displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere. LA County Flood Control District l Z- -1 `J ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications Significance if Significance before Mitigation Mitigation is Impacts Mitigation Measures Implemented above levels existing without the project. 3.10-4: The proposed program could result fmplemeataElew a Implement Mitigation Measure NOISE -1 Significant Significant and in a substantial temporary or periodic unavoidable increase in ambient noise levels in the project vicinity above levels existing without the project. 3.105: For a project located within an None required Less than significant Not applicable airport land use plan area, or, where such a plan has not been adopted, in an area within 2 miles of a public airport or public use airport, implementation of the proposed program could expose people residing or working in the area to excessive noise levels. 3.105: For a project located in the vicinity None required Less than significant Not applicable of a private airstrip, the proposed program could expose people residing or working in the project area to excessive noise levels. Cumulative Noise Impacts Implement Mitigation Measures NOISE -1 and NOISE -2 Significant Significant and unavoidable for construction; less than significant for operation Population and Housing and Environmental Justice 3.11-1: Implementation of the proposed None required No Impact Not applicable program could induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure). 3.11-2: Implementation of the proposed None required No Impact Not applicable program could displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere. LA County Flood Control District l Z- -1 `J ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications Impacts Mitigation Measures Significance before Mitigation Significance if Mitigation is Implemented 3.11-3: Implementation of the proposed None required No Impact Not applicable program could displace substantial numbers of people, necessitating the construction of replacement housing elsewhere. 3.114: Implementation of the proposed None required Less than significant Not applicable program could affect the health or environment of minority or low income populations disproportionately. Cumulative Population and Housing and None required No impact Not applicable Environmental Justice Impacts Public Services and Recreation 3.12-1: The proposed program could result PS -1: The Permittee implementing the EWMP project shall Significant Less than significant in substantial adverse physical impacts provide reasonable advance notification to the service associated with the provision of, or the need providers such as fire, police, local businesses, home owners for, new or physically altered governmental and residents of adjacent to and within areas potentially fire protection facilities, the construction of affected by the proposed EW MP project about the nature, which could cause significant environmental extent and duration of construction activities. Interim updates impacts, in order to maintain acceptable should be provided to inform them of the status of the service ratios, response times, or other construction activities. performance objectives for fire protection services. 3.12-2: The proposed program could result None required Less than significant Not applicable in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered governmental police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for police protection services. 3.12-3: The proposed program could result None required Less than significant Not applicable in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered schools, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, LA County Flood Control District I Z-ZU ESA 1140379 Enhanced Watershed Management Programs April 2015 Final Program Environmental Impact Report Impacts response times, or other performance objectives for schools. Mitigation Measures 3.12-4: The proposed program could None required increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. 3.125: The proposed program could None required include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. Cumulative Public Services and Implement Mitigation Measure PS -1 Recreation Impacts Transportation and Circulation 3.13-1: The proposed program could intermittently and temporarily increase traffic levels and traffic delays due to vehicle trips generated by construction workers and construction vehicles on area roadways. TRAF-1: For projects that may affect traffic, implementing agencies shall require that contractors prepare a construction traffic control plan. Elements of the plan should include, but are not necessarily limited to, the following: • Develop circulation and detour plans to minimize impacts to local street circulation. Use haul routes minimizing truck traffic on local roadways to the extent possible. • To the extent feasible, and as needed to avoid adverse impacts on traffic flow, schedule truck trips outside of peak morning and evening commute hours. • Install traffic control devices as specified in Caltrans' Manual of Traffic Controls for Construction and Maintenance Work Zones where needed to maintain safe driving conditions. Use flaggers and/or signage to safely direct traffic through construction work zones. • Coordinate with facility owners or administrators of sensitive land uses such as police and fire stations, hospitals, and schools. Provide advance notification to the facility owner or operator of the timing, location, and duration of construction activities. Clarifications and Modifications Significance before Significance if Mitigation Mitigation is Implemented Less than significant Not applicable Less than significant Not applicable Less than significant Not applicable Significant Less than significant LA County Flood Control District I Z -Z -I ESA 1140379 Enhanced watershed Management Programs April 2015 Final Program Environmental Impact Report Clarifications and Modifications Impacts Mitigation Measures 3.13-2: Construction of the proposed None required program could potentially cause traffic safety hazards for vehicles, bicyclists, and pedestrians on public roadways, and could increase traffic hazards due to possible road wear. 3.133: The proposed program could result None required. in inadequate emergency access during construction. 3.13-4: Construction of the proposed Implement Mitigation Measure',...fale...e:�..'^'�^^a` TRAF-1 program could contribute to cumulative impacts to traffic and transportation (traffic congestion, traffic safety, and emergency vehicle access). Utilities and Service Systems 3.14-1: Implementation of the proposed program could exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board or result in the construction of new treatment facilities or expansion of existing facilities if the wastewater treatment provider has inadequate capacity to serve the proposed program. Significance before Mitigation Less than significant Less than significant Significant Significance if Mitigation is Implemented Not applicable Not applicable Less than significant Nene-Fegdirei Prior to implementation of Bli the Less than significant Not applicable implementing agency shall conduct a search for local utilities above and below ground that could be affected by the pro act. The implementing agencies shall contact each utility potentially affected to address relocation of the utility if necessary to ensure access and services are maintained. 3.14-2: The proposed program could None required require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. 3.143: The proposed program could Implement Mitigation Measure UTIL-1. require new or expanded water supply UTIL42: Prior to approval of BMPs, implementing agencies resources or entitlements or require or shall evaluate the potential for impacts to downstream result in the construction of new water beneficial uses including surface water rights. Implementing facilities or expansion of existing facilities, agencies shall not approve BMPs that result in preventing the construction of which could cause access to previously appropriated surface water downstream. LA County Flood Control District Enhanced Watershed Management Programs Final Program Environmental Impact Report Less than significant Significant Not applicable Less than significant ESA 1140379 April 2015 Impacts Mitigation Measures Clarifications and Modifications Significance before Significance if Mitigation Mitigation is Implemented significant environmental effects. 3.14-4: The proposed program could be UTIL-23: Implementing agencies shall encourage Significant Less than significant served by a landfill with insufficient construction contractors to recycle construction materials and permitted capacity to accommodate the divert inert solids (asphalt, brick, concrete, dirt, fines, rock, project solid waste disposal needs or the sand, soil, and stone) from disposal in a landfill where project could not comply with federal, state, feasible. Implementing agencies shall incentivize construction and local statutes and regulations related to contractors with waste minimization goals in bid specifications solid waste. where feasible. 3.145: Construction and operation of the None required proposed program would require additional energy use that could result in wasteful consumption, affect local and regional energy supplies, or conflict with applicable energy efficiency policies or standards. Cumulative Utilities and Service Systems Implement Mitigation Measures UTIL-1, UTIL-2 and UTIL-3 Impacts LA County Flood Control District Enhanced Watershed Management Programs Final Program Environmental Impact Report Less than significant Not applicable Significant Less than significant ESA 1140379 April 2015 Clarifications and Modifications Section Chapter 1, Introduction Page Clarification/Revision 1-1 Text has been added regarding EWMP benefits in Chapter 1, Introduction as shown below. The MS4 Permit gives Permittees the option of implementing an innovative approach to permit compliance through development of an Enhanced Watershed Management Program (EWMP). Development of an EWMP is optional, but allows Permittees a longer timeline to develop and implement Best Management Practices (BMPs) needed to achieve compliance. The EWMPS will result in additional benefits including provision of open space and parkland, habitat creation, and stormwater retention. Permittees not preparing Watershed Management Programs must achieve compliance within a year of permit adoption. The EWMPs will identify potential and priority structural and non- structural Best ,,,.......,.e. ent B_..,.4ee. 'BMPs) within the region's stormwater collection system to improve runoff water quality. The LACFCD, along with participating Permittees, has opted to exercise this option and has submitted to the LARWQCB 12 separate Notices of Intent (NOIs) for the development of EWMPs within 12 distinct watershed groups (refer to Figure 1-1). Implementation of the EMWPs would be the responsibility of each Permittee and would occur following approval of the EWMPs by the LARWQCB. 1-3 Text has been added regarding EWMP preparation in Chapter 1, Introduction as shown below. The timeline identified in the MS4 Permit requires that Permittees who elect to prepare Watershed Management Programs submit them t.s PIALA411 to the LARWQCB by June 28, 2015, in order to be in compliance with the permit conditions. The LACFCD recognizes that implementation of the EWMPs may potentially result in changes to environmental conditions. As a result, the LACFCD has prepared this Program Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the EWMPs. The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior to submittal of the EWMPs. The EWMPs will be submitted by each EWMP group to the LARWQCB. 1-3 Text has been added regarding EWMP preparation in Chapter 1, Introduction as shown below. The PEIR analysis is not intended to focus on the site-specific construction and operation details of each management strategy and project included in the LA County Flood Control District l Z -Z4 ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications EWMP. Rather, this PEIR serves as a first-tier environmental document that focuses on the effects of implementing the EWMPs to reduce urban runoff pollution anywhere in the watershed. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources whether in urban environments or previously undisturbed open space. The analysis outlines mitigation strategies to be followed by the LACFCD and other implementing agencies that rely on this PEIR to avoid or minimize impacts wherever feasible. The determinations of significance after mitigation in this PEIR will apply to the LACFCD and other implementing agencies that rely on this PEIR and the mitigation measures proposed herein. 1-11 The LACFCD acknowledges that BMPs are not limited to urban areas but may be installed throughout a watershed if necessary to achieve water quality objectives. Text has been added in Chapter 1, Introduction as shown below. The analysis assesses worst case situations where construction or operation of projects may significantly impact environmental resources. The analysis also considers potential impacts and mitigation for BMPs implemented in less developed and urbanized areas of the EWMP where water Duality issues may exist that are not directly linked to urbanization but are still regulated under the MS4 Permit. The analysis outlines mitigation strategies to be followed by Implementing Agencies to avoid or minimize impacts wherever feasible. Exact locations and BMP designs are not defined. Rather, the overall compliance strategy of BMP type, quantity, and geographic distribution is assessed on a cumulative, regional scale. 1-12 Table 1-1 has been revised to include the full list of commenters Text has been added in Chapter 1, Introduction as shown below. TABLE 1-1 NOP COMMENTERS on the NOP. Date Name Organization 1 10/16/2014 Enrique Huerta At -Large Stakeholder (Downey, CA) 2 10/23/2014 Enrique Huerta At -Large Stakeholder (Downey, CA) 3 10/28/2014 George Ball Citizen 4 10/29/2014 Jane Williams Los Angeles County Arboretum 5 10/27/2014 Kenneth Hill Los Angeles County Arboretum Foundation, President 6 10/23/2014 Marsha Perez Citizen, Los Angeles County Arboretum 7 09/29/2014 Rex Frankel Ballona Ecosystem Education Project, Director 8 10/29/2014 Rex Frankel Ballona Ecosystem Education Project, Director 9 10/29/2014 Tom Williams Sierra Club, Water Committee LA County Flood Control District I Z-ZO ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications Section Chapter 2, Project Description Page Clarification/Revision 2-18 The Wildlife Road project is anticipated to be complete in early 2015 as opposed to August 2014. The correct date has been updated in Chapter 2, Project Description, as shown below. Construction work on the Wildlife Road Storm Drain Improvements project was scheduled to begin March 2014 and continue through "ugost -2;4-4eyly 2015. 2-25 The picture caption containing "Flat" gate should be changed to "flap" gate when referring to the Marie Canyon low -flow diversion system. The correction has been made in Chapter 2, Project Description, as shown below. Marie Canyon Low -Flow Diversion — Flatp Gate Diverting flow to treatment unit for bacteria 2-31 In Table 2-4, "treating stormwater and urban runoff prior to the entering into..." should read, "treating stormwater and dry -weather runoff prior to flowing into... LA County Flood Control District I L -LO ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Date Name Organization 10 10/08/2014 Elizabeth Byrne Los Angeles Arboretum Foundation Debreu 11 09/29/2014 Dianna Watson Department of Transportation 12 09/24/2014 Deirdre West Metropolitan Water District 13 09/25/2014 Katy Sanchez NAHC 14 09/29/2014 Douglas Fay Citizen 15 09/29/2014 Donna Murray Citizen 16 09/29/2014 Joyce Dillard Citizen 17 10/03/2014 Patricia Grassroots Coalition McPherson 18 10/14/2014 Jane Florentinus Citizen 19 10/29/2014 Dale Carter Arboretum volunteer and docent 20 08/29/2014 Scott Morgan State Clearinghouse 21 10/21/2014 L. Gavle San Citizen Miguel 22 9/16/2014 Rchard Schulhof Los Angeles County Arboretum and Botanic Garden 23 10/28/2014 George Ball Citizen 24 12/1/2014 William Lincoln Citizen 25 11/11/2014 Margaret Page Citizen 26 12/2/2014 Pat Wilmot Citizen 27 12/17/2014 Margaux Vera Citizen 28 10/19/2014 Sandy Snider Citizen Section Chapter 2, Project Description Page Clarification/Revision 2-18 The Wildlife Road project is anticipated to be complete in early 2015 as opposed to August 2014. The correct date has been updated in Chapter 2, Project Description, as shown below. Construction work on the Wildlife Road Storm Drain Improvements project was scheduled to begin March 2014 and continue through "ugost -2;4-4eyly 2015. 2-25 The picture caption containing "Flat" gate should be changed to "flap" gate when referring to the Marie Canyon low -flow diversion system. The correction has been made in Chapter 2, Project Description, as shown below. Marie Canyon Low -Flow Diversion — Flatp Gate Diverting flow to treatment unit for bacteria 2-31 In Table 2-4, "treating stormwater and urban runoff prior to the entering into..." should read, "treating stormwater and dry -weather runoff prior to flowing into... LA County Flood Control District I L -LO ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications The correction has been made in Chapter 2, Project Description, as shown below. The Project consists of the installation of different types of biofilters at nine catch basins within the City of Malibu Right of Way, treating storrnwater and dry - weather ur4�m runoff prior to the ante. ing 89 a,,.,,., flowing into City -owned catch basins, which discharge to privately owned storm drain systems. 2-31 The sentence portion reading, "with potential to incorporate harvest and use systems for Malibu Drains" should be deleted. The sentence, "Three types of biofilters are contemplated; pre -manufactured and custom designed biofilters" should read, "Two types of biofilters are included; pre -manufactured and custom designed biofilters." The corrections have been made in Chapter 2, Project Description, as shown below. The Project includes a combination of biofilters, and flow control,' to in ratig ti,.,.,.e..t and u .stems few Mali u drain... T�.,gTwo types of biofilters are ^emsincluded; small footprint biofilters, biofilters with volume control, and harvest and use systems. 2-37 In Table 2-4, "compliance with Malibu Creek Bacteria TMDL requirements" should be changed to "compliance with Santa Monica Bay and Malibu Creek Bacteria TMDL requirements." The corrections have been made in Chapter 2, Project Description, as shown below. The project exceeds requirements to put over 300 acres of Malibu (including City Hall) into full compliance with Santa Monica Bay and Malibu Creek Bacteria TMDL requirements, providing a capture volume consistent with Los Angeles Standard Urban Stormwater Mitigation Plan requirements (assuming no upstream LID or source control measures). Section Section 3.1, Aesthetics Page Clarification/Revision 3.1-2 "Large -acreage residential properties" should be changed to large -acre and rural residential properties." The corrections have been made in Section 3. 1. Aesthetics, as shown below. The Malibu Creek area contains mostly undeveloped mountain areas, large - acreage and rural residential properties, and many natural streams, while Ballona Creek is predominantly channelized and highly developed with both residential and commercial properties (LARWQCB, 2011). Section Section 3.2, Air Quality Page Clarification/Revision 3.2-1 The sentence that states "The majority of the County is highly urbanized and consists of several cities, communities, and unincorporated areas" should be LA County Flood Control District I L -L / ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications changed to "The majority of the County is highly urbanized with some adjacent rural areas and consists of several cities, communities, and unincorporated areas." The corrections have been made in Section 3.2, Air Quality, as shown below. The majority of the County is highly urbanized with some adiacent rural areas and consists of several cities, communities, and unincorporated areas." Section Section 3.3, Biological Resources Page Clarification/Revision 3.3-2 The sentence that states "These watersheds are characterized by dense residential development along the coast and less development and greater open space areas inland" should be changed to "These watersheds are characterized by dense residential development immediately along the coast and less development and greater open space areas as you move off the shoreline and head inland." The corrections have been made in Section 3.3, Biological Resources, as shown below. These watersheds are characterized by dense residential development immediately along the coast and less development and greater open space areas as you move off the shoreline and head inland. 3.3-19 The text including "Malibu watershed" needs to be updated to read "Malibu Creek watershed" (this needs to be added to all instances in which "Malibu Creek Watershed" is the intent). The change has been included in Section 3.3, Biological Resources, as shown below. This potential effect is most likely to occur within suburban areas, which are more prevalent in the Santa Clara River watershed, Malibu Creek watershed, and San Gabriel watershed. 3.3-20 These conditions may be most prevalent in the Santa Clara River watershed, Malibu Creek Watershed, the Upper Los Angeles River Watershed, and San Gabriel River Watershed where suburban landscape irrigation runoff has created isolated patches of riparian vegetation. 3.3-21 Northern Coastal EWMP Watersheds (Malibu Creek and Upper Santa Monica Bay) 3.3-24 Groundwater seepage would continue to support the major riparian corridors in the Malibu Creek, Santa Clara, Upper Los Angeles, and San Gabriel watersheds. 3.3-26 Groundwater seepage would continue to support the major riparian corridors in the Malibu Creek, Santa Clara, Upper Los Angeles, and San Gabriel watersheds LA County Flood Control District I L -L6 ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications 3.3-30 Under the cumulative impact discussion, the Mitigation Measures heading should be updated to match the mitigation measures referenced in the cumulative impact discussion. Implementation of BMPs would ensure compliance with Section 402 of the CWA that requires MS4s to reduce dry -weather flows in this region. Although compliance with Section 402 of the CWA may result in a reduction of wetlands in the region supported by surface flow, the infiltration of surface water into the ground would offset the potential impact, resulting in a less than significant cumulative impact to biological resources in the region. Mitigation Measures: None reImplement Mitigation Measures BIO -1 through 13I0-10. Significance Determination: Less than significant Section Section 3.5, Geologic Resources Page Clarification/Revision 3.5-28 Mitigation Measure GEO-1 is referred to as reducing cumulative impacts in the cumulative impacts discussion but its implementation is not listed under the Mitigation Measures heading for cumulative impacts. The change has been included in Section 3.5, Geological Resources, as shown below. Mitigation Measures: Implement Mitigation Measure GEO-1. GEO-2: Prior to installing BMPs designed to recharge the local groundwater supplies, the Implementing Agency shall notify local groundwater managers, including the Upper Los Angeles River Area Water Master, the Water Replenishment District of Southern California, or the San Gabriel Water Master as well as local water producers such as local municipalities and water companies. The Implementing Agency shall coordinate BMP siting efforts with groundwater managers and producers to mitigate high groundwater levels while increasing local water supplies. Section Section 3.7, Hazards and Hazardous Materials Page Clarification/Revision 3.7-17 Mitigation Measure HAZ-1 has been modified to ensure that vector control plans are incorporated into BMP maintenance plans. The change has been included in Section 3.7, Hazards and Hazardous Materials, as shown below. HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and LA County Flood Control District I Z-ZF/ ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The Maintenance Plan shall include vector control requirements. The BMP Maintenance Plan may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. 3.7-23 Mitigation Measure HAZ-3 has been incorporated into the cumulative impact discussion and listed mitigation measures. The change has been included in Section 3.7, Hazards and Hazardous Materials, as shown below. Cumulative Impact Discussion Structural (Regional, Centralized, and Distributed) BMPs BMPs would be constructed throughout the watersheds. Most of the distributed BMPs would be small in scale and would not result in cumulatively significant impacts due to increased hazards from construction or operation. However, the combination of BMPs throughout the region would change the flow paths of stormwater and urban runoff that currently occurs in the region, resulting in the retention of pollutants generally within the soil of the BMPs that use soil for filtration and retention. Mitigation Measure HAZ-1 would reduce the potential for concentrations of these pollutants to result in localized hazardous conditions at individual BMP locations. Mitigation Measure HAZ-2 would mitigate the accumulation of contaminants in soil at BMPs. For all BMPs within an airport land use area, Mitigation Measure HAZ-3 would require them to be compatible with FAA criteria. BMPs within the minimum separation criteria would trigger collaboration with the airport regarding potential wildlife hazard mitigation. Cumulatively, throughout the region, the retention and treatment of pollutants within each watershed and the reduction of pollutant loading in waterways will substantially benefit water and sediment quality of the region's habitats, rivers, and beaches. Therefore, the project's potential contribution to cumulative effects on hazards and hazardous materials is considered beneficial. LA County Flood Control District I Z -SV ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications Mitigation Measures: Implement Mitigation Measures HAZ-1, an& HAZ-2 and HAZ-3. Section Section 3.8, Hydrology and Water Quality Page Clarification/Revision 3.8-4 The sentence that includes, "in the urbanized areas along Santa Monica Bay" should be changed to "in the urbanized areas along central and south Santa Monica Bay." The corrections have been made in Section 3.8, Hydrology and Water Quality, as shown below. In the urbanized areas along central and south Santa Monica Bay, the streams have been channelized. 3.8-6 The sentence containing, "address bacteria loading" should be changed to "prevent possible bacteria loading." The corrections have been made in Section 3.8, Hydrology and Water Quality, as shown below. Key BMP strategies are to address prevent possible bacteria loading to the beaches and inland waters, but because of the lower development and largely decentralized infrastructure, LFDs are not the only strategy to address this priority issue. 3.8-27 Los Angeles County is part of a General Exception of ASBS discharge prohibitions. The corrections have been made in Section 3.8, Hydrology and Water Quality, as shown below. In 44ffeh-2012, the SWRCB adopted a General Exception and its amendments (Resolutions 2012-0012 and 2012-0031), (SAIRCB, 20"b), which exempts certain listed dischargers including Los Angeles County from certain Ocean Plan ASBS discharge prohibitions. The conditions in the General Exception are designed to protect beneficial uses of the receiving water, yet allow continuation of essential public services, such as flood control, slope stability, erosion prevention, maintenance of the natural hydrologic relationship between terrestrial and marine ecosystems, public health and safety, public recreation and coastal access, commercial and recreational fishing, navigation, and essential military operations (national security)'OTx'nrco b). 3.8-27 The following sentence required clarification regarding ASBS dischargers. The corrections have been made in Section 3.8, Hydrology and Water Quality, as shown below. The General Exception designates the LACFCD, the City of Malibu, the California Department of Parks and Recreation and the California Department of Transportation (Caltrans) as dischargers to ASBS 24, Laguna Point to Latigo a the r..rf,......:.. POltlt.,;�-a�v�m�� LA County Flood Control District l Y -Sl ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications 3.8-27 Within the sentence containing "provided that it," "it" should be changed to "the discharge:" The corrections have been made in Section 3.8, Hydrology and Water Quality, as shown below. The General Exception authorizes these dischargers to discharge into ASBS 24, provided that 4 the discharge: 3.8-29 Text has been added under the Local Regulations header to describe the status of Salt and Nutrient Management Plans in the region. The corrections have been made in Section 3.8, Hydrology and Water Quality, as shown below. Salt and Nutrient Management Plans In February 2009, the State Water Resources Control Board adopted Resolution No. 2009-0011, which established a statewide Recycled Water Policy. The Recycled Water Policy encourages increased use of recycled water and local stormwater, together with enhanced water conservation. It also requires local water and wastewater entities, together with local salt and nutrient (S/N) contributing stakeholders to develop Salt and Nutrient Management Plans (SNMPs) for each groundwater basin in California in a way that optimizes recycled water use while ensuring protection of groundwater supply and beneficial uses, agricultural beneficial uses, and human health. The Recycled Water Policy encourages development of regional S/N management strategies rather than relying on the past local RWOCB approach of imposing requirements on individual recycled water projects with no recognition of the relative and cumulative impacts when all projects and loading sources are considered regionally. Accordingly, the SNMP is intended to provide support and justification for elimination of separate anti -degradation analyses and individual site monitoring requirements for proposed recycled water projects and so that the vast majority of proposed recycled water projects may be streamlined. The intent of this streamlined permitting process is to expedite the implementation of recycled water projects in a manner that complies with State and Federal water quality laws. The SNMPs will be approved by the Regional Water Quality Control Boards (RWOCBs). The Central and West Coast Basins SNMP was developed by the Water Replenishment District of Southern California (WRD) as the lead agency. The SNMP was submitted to LARWOCB for approval in November 2014, and was approved as a Basin Plan Amendment on February 12, 2015. The Upper Los Angeles River Area (ULARA) SNMP is currently being prepared by the ULARA Watermaster. An SNMP for the Santa Clarita River Valley East Subbasin is being prepared by a group of local stakeholders comprised of Castaic Lake Water Agency (CLWA), City of Santa Clarita, Los Angeles County Flood Control District (LACFCD), Newhall County Water District (NCWD), San Gabriel & Lower Los Angeles Rivers and Mountains Conservancy, Sanitation Districts of Los Angeles County (SDLAC) and Valencia Water Company (VWC). 3.8-30 Text has been added regarding the Los Angeles Integrated Regional Water Management Plan in Section 3.8.2, Hydrology and Water Quality, Regulatory Setting. LA County Flood Control District I L -3L ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications Integrated Regional Water Management Plan The 2013 Integrated Regional Water Management Plan (IRWMP) Update, approved by the Los Angeles County Board of Supervisors in 2014, was formulated to define a clear vision and direction for the sustainable management of water resources in the Greater Los Angeles County (GLAC) Region. The IRWMP, which is chaired by the Los Angeles County Flood Control District (LACFCD), covers the GLAC Region, an area of approximately 2,058 square miles, spanning from Ventura County to Orange County and from the coast to the San Gabriel Mountains. The IRWMP region includes the Los Angeles River Watershed, the Santa Monica Bay Watershed, the Dominguez Channel Watershed, and the San Gabriel River Watershed, overlapping with four of the five watersheds covered in the EWMP. Several subcommittees were involved in the IRWMP development process, covering a range of both project objectives and physical areas, to ensure successful regional collaboration. The objectives of the 2013 IRWMP Update include: reducing the Region's reliance on imported water; comply with water quality regulations by improving the quality of urban runoff, stormwater and wastewater; protect, restore and enhance natural processes and habitats; increase watershed friendly recreational space for all communities; reduce flood risk in flood prone areas by either increasing protection or decreasing needs using integrated flood management approaches; and adapt to and mitigate against climate change vulnerabilities. 3.8-36 Mitigation Measure HYDRO -3 has been revised as follows in Section 3.8, Hydrology and Water Quality. HYDRO -3: Prior to the installation of an infiltration BMP, the Permittee shall conduct a regulatory database review for contaminated groundwater sites within a quarter mile of the proposed infiltration facility. The review shall include locations of on-site wastewater treatment systems. The Permittee shall identify whether any contaminated groundwater plumes or leach fields are present and whether coordination with the local and state environmental protection overseeing agency and responsible party is warranted prior to final design of infiltration facility. 3.8-37 Mitigation Measure HYDR04 has been added as follows in Section 3.8, Hydrology and Water Quality. Structural (Regional, Centralized, and Distributed) BMPs The proposed structural BMPs would be designed to minimize off-site discharge of urban runoff pollutants including siltation and sedimentation. Many of the structural BMPs would include on-site infiltration of stormwater runoff which would also be effective in minimizing erosion or transport of sedimentation into receiving waters. Through increased infiltration prior to discharge into receiving waters, flows within existing streams or rivers would receive reduced stormwater flow volumes thereby decreasing flow energies. Furthermore, as part of implementation of Mitigation Measure HYDRO -4, implementing agencies would design BMP discharge locations to minimize any ydromodification impacts including erosion and scour. As a result, the potential for erosion or siltation LA County Flood Control District l Y-33 ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications within existing streams or rivers would be reduced and the potential impact less than significant. Mitigation Measures: HYDRO -4: Prior to approving a structural BMP, the implementing agencies shall conduct an evaluation of the potential hydromodification impacts of the project. The evaluation shall recommend design measures necessary to prevent or minimize any identified impacts, including flooding, erosion and/or scour. Design measures could include velocity dissipaters and bank re -enforcement components. Implementing agencies shall include these measures in project designs. 3.8-38 The following sentence should be revised from "Drainage patterns would change through implementation of these non-structural institutional BMPs, implementation of LID strategies, which include on-site infiltration, that would minimize off-site flows as well as the potential for erosion and off-site siltation" to "Drainage patterns would change through implementation of these non- structural institutional BMPs. However, implementation of LID strategies, which include on-site infiltration, -would minimize off-site flows as well as the potential for erosion and off-site siltation." The corrections have been made in Section 3.8, Hydrology and Water Quality, as shown below. Drainage patterns would change through implementation of these non-structural institutional BMPs]. 13However implementation of LID strategies, which include on-site infiltration, that would minimize off-site flows as well as the potential for erosion and off-site siltation. 3.8-39 The sentence, "The structural BMPs would also provide improvements to water quality of receiving waters" should read, "The structural BMPs would also provide protections to water quality of receiving waters." The corrections have been made in Section 3.8, Hydrology and Water Quality, as shown below. "The structural BMPs would also provide imprevemeuts protections to water quality of receiving waters." 3.8-39 The sentence containing, "BMPs but would be designed to improve water quality and reduce stormwater flow volumes" should read, `BMPs but would be designed to improve runoff water quality and reduce stormwater flow volumes." The change has been included in Section 3.8, Hydrology and Water Quality, as shown below. "BMPs but would be designed to improve runoff water quality and reduce stormwater flow volumes" LA County Flood Control District l Z-54 ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications Section Section 3.9, Land Use and Agriculture Page Clarification/Revision 3.9-1 The sentence, "The majority of the County is highly urbanized and consists of several cities, communities and unincorporated areas" be changed to "The majority of the County is highly urbanized with some adjacent rural areas and consists of several cities, communities and unincorporated areas." The change has been included in Section 3.9, Land Use and Agriculture, as shown below. The majority of the County is highly urbanized with some adjacent rural areas and consists of several cities, communities and unincorporated areas." 3.9-1 The sentence, "The EWMP agencies have no jurisdiction over the land that is owned by the State of California (i.e., California Department of Fish and Wildlife, the State Lands Commission, and the California Department of Transportation) or the U.S. Government" should be revised to add the California Department of Parks and Recreation and the National Parks Service. The change has been included in Section 3.9, Land Use and Agriculture, as shown below. The EWMP agencies have no jurisdiction over the land that is owned by the State of California (i.e., California Department of Parks and Recreation, California Department of Fish and Wildlife, the State Lands Commission, and the California Department of Transportation) or the U.S. Government (i.e., National Parks Service). 3.9-28 Low Impact Development (LID) standards are required to be in place within the jurisdictions of Permittees that have chosen EWMPs as their form of compliance with the MS4 Permit. Therefore, a statement regarding LID ordinance requirements should be added. Page 3.9-28 of the Program EIR has been updated to reflect this information as shown below. Other Cities LID Various other cities within the County also have LID standards or guidance. The revised MS4 Permit states that permittees that choose to collaborate on the development of a Watershed Management Program (or preparers of an EWMP) shall demonstrate that there are LID ordinances in place and/or have commenced development of a LID ordinance meeting the requirements of this the MS4's Planning and Land Development Program within 60 days of the MS4 effective date (December 28. 2012) and have a draft ordinance within six months of the effective date. The goals, objectives, and content of the LID document are similar to that of the County and City of Los Angeles, and are not referenced here. 3.9-36 "Creek" needs to be added to all instances in which "Malibu Creek Watershed" is the intent. The change has been included in Section 3.9, Land Use and Agriculture, as shown below. Only small areas of Designated Prime, Unique and Important Farmlands exist within the EWMP area, limited to the Santa Clara and Malibu Creek Watersheds. LA County Flood Control District I Z-30 ESA / 140379 Enhanced Watershed Management Programs Aiml 2015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications 3.9-38 The statement, "EWMPs would be implemented in already established urban areas" be revised to read, "EWMPs would be implemented in already established developed areas." The change has been included in Section 3.9, Land Use and Agriculture, as shown below. EWMPs would be implemented in already established urban developed areas. Section Section 3,14, Utilities and Service Systems Page Clarification/Revision 3.14-14 Mitigation Measure UTIL-1 has been added to the project. The change has been included in Section 3.14, Utilities and Service Systems, as shown below. Construction requiring ground disturbance could encounter buried utilities including water supply infrastructure. As part of Mitigation Measure UTIL-1, toe projeet design, Implementing Agencies myould be _agiii_ad t., ide tic, the potential C r tmd.,. g ,.hind utilities and detenni..e whether tl..,.. would need to be implementing A ,.enei,.., would conduct an underground utility search prior to excavation and would coordinate with utility providers in advance to ensure no disruption in services to the utility customers. With implementation of UTIL-1, jImpacts to water supply infrastructure would be less than significant. 3.14-14 Mitigation Measure UTIL-1 has been added to the project. The change has been included in Section 3.14, Utilities and Service Systems, as shown below. Mitigation Measures: None roquiFed UTIL-1: Prior to implementation of BMPs, the implementing agency shall conduct a search for local utilities above and below ground that could be affected by the project. The implementing agencies shall contact each utility potentially affected to address relocation of the utilitv if necessary to ensure access and services are maintained 3.14-16 Mitigation Measure UTIL-1 also applies to Impact 3.14-3. The change has been included in Section 3.14, Utilities and Service Systems, as shown below. Construction requiring ground disturbance could encounter buried utilities including water supply infrastructure. As part of Mitigation Measure UTIL-1, the Implementing Agencies patel4tial GF ofid...-gFRI.«d ut litieg ..«d determine 10. 40th ff 41485F 'A'1314114 R08d 4,. W Folep,awd, to tl,o BMA As standard ,. ngtruption P aetiG@s . hHpi. wating A g@fl,.ies lArauld conduct an underground utility search prior to excavation and would coordinate with utility providers in advance to ensure no disruption in services to the utility customers. With implementation of UTIL-1, jImpacts to water supply infrastructure would be less than significant. LA County Flood Control District I Z-310 ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications 3.14-16 The sentence containing "Malibu watershed where surface water diversions..." should be updated to include "Malibu Creek watershed." The change has been included in Section 3.14, Utilities and Service Systems, as shown below. In areas with natural unimproved streams, such as in the Santa Clara River watershed and Malibu Creek watershed where surface water diversions may be more common, stormwater flows are conveyed downstream quickly. 3.14-16 The introduction of the new Mitigation Measure UTIL-1 impacts the numbering of the existing Mitigation Measure UTIL-1. The change has been included in Section 3.14, Utilities and Service Systems, as shown below. These flows would not be affected by infiltration BMPs. However, implementation of Mitigation Measure UTIL42 would ensure that downstream water rights would not be affected by upstream diversions. 3.14-17 Mitigation Measure UTIL-I also applies to Impact 3.14-3. The change has been included in Section 3.14, Utilities and Service Systems, as shown below. Mitigation Measure: Implement Mitigation Measure UTIL-1. UTIL42: Prior to approval of BMPs, implementing agencies shall evaluate the potential for impacts to downstream beneficial uses, including surface water rights. Implementing agencies shall not approve BMPs that result in preventing access to previously appropriated surface water downstream. 3.14-18 The introduction of the new Mitigation Measure UTIL-1 impacts the numbering of the existing Mitigation Measure UTIL-2. The change has been included in Section 3.14, Utilities and Service Systems, as shown below. Development of a waste management or recycling plan (Mitigation Measure UTIL-33) would reduce this impact. 3.14-18 The statement that includes, "it is feasible to recycle or reuse at least 50 percent or construction" should be changed to "it is feasible to recycle or reuse at least 50 percent of construction." The change has been included in Section 3.14, Utilities and Service Systems, as shown below. According the County of Los Angeles, except under unusual circumstances, it is feasible to recycle or reuse at least 50 percent off construction and demolition debris (RWQCB, 2008). 3.14-18 The introduction of the new Mitigation Measure UTIL-1 impacts the numbering of the existing Mitigation Measure UTIL-2. The change has been included in Section 3.14, Utilities and Service Systems, as shown below. Mitigation Measure: UTIL-23: Implementing agencies shall encourage construction contractors to recycle construction materials and divert inert solids (asphalt, brick, concrete, dirt, fines, rock, sand, soil, and stone) from disposal in a landfill, where feasible. LA County Flood Control District I Z-3 / ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications Implementing agencies shall incentivize construction contractors with waste minimization goals in bid specifications where feasible. 3.14-19 New Mitigation Measure UTIL-1 applies to Impact 3.14-5. The change has been included in Section 3.14, Utilities and Service Systems, as shown below. Construction requiring ground disturbance could encounter buried or overhead utilities including electric or gas conveyance infrastructure. As part of Miti ag tion Measure UTIL-1 t4a projest design, Implementing Agencies wooldbe re"ired to identify the potential for underground titilities and deteFmine v.1...ther they _..,.ti,.,.s Folquif 0, inApI,... eating A ,.ene:,.., would conduct an underground utility search prior to excavation and would coordinate with utility providers in advance to ensure no disruption in services to the utility customers. Impacts to electric or gas infrastructure would be less than significant. 3.14-20 New Mitigation Measure UTIL-1 applies to Impact 3.14-5. The change has been included in Section 3.14, Utilities and Service Systems, as shown below. Mitigation Measures: Nene FeqImplement Mitigation Measure UTIL-1. 3.14-21 New Mitigation Measure UTIL-1 applies to cumulative impacts. The change has been included in Section 3.14, Utilities and Service Systems, as shown below. The proposed program consists of improvements to existing storm drainage facilities as well as new storm drain facilities within the EWMP program areas. This PEIR contains an analysis on the potential environmental effects that might result from the installation of storm drainage facilities identified in the proposed EWMPs. Mitigation Measure UTIL-1 would reauire the implementing agencv to search for local utilities that could be affected by the project, thereby avoiding impacts to existing utilities. Cumulative impacts to storm drain facilities would be less than significant. Impacts to the existing water supplies are anticipated to be beneficial as a result of the stormwater and non-stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. Mitigation Measure UTIL-42 would require that implementing agencies evaluate impacts to downstream beneficial uses, including surface water rights prior to BMP approval. No adverse cumulative impacts related to new or expanded water supply resources or entitlements would occur. Construction and operation of the structural BMPs would generate solid waste; however, landfills serving the program area are expected to have sufficient capacity to accommodate the amount of waste generated. Development of a waste management or recycling plan (Mitigation Measure UTIL4�) would LA County Flood Control District I Z-30 ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT 3.14-21 Section Page 4-4 4-4 Clarifications and Modifications reduce this impact. Disposal of the solid waste generated during construction and operation would comply with all pertinent regulations and statutes. All other projects implemented in the area would also be required to comply with federal, state, and local solid waste regulations and statutes. Cumulative impacts would be less than significant. New Mitigation Measure UTIL-1 applies to cumulative impacts. The change has been included in Section 3.14, Utilities and Service Systems, as shown below. Mitigation Measures: Implement Mitigation Measure UTIL-1,7ari4 Mitigation Measure UTIL-2, and Mitigation Measure UTIL-3, Chapter 4, Cumulative Impacts Clarification/Revision In Table 4. 1, the timeline for Wildlife Road should be changed from "August 2014" to "early 2015." The change has been included in Chapter 4, Cumulative Impacts, as shown below. Wildlife Road Storm Distributed Drain Improvements North Santa Construction was Monica Bay scheduled to Coastal begin March 2014 Watersheds and continue through August 2044ewr 2015 In Table 4. 1, the timeline for Broad Beach Biofiltration Project should be changed to "early 2015." The change has been included in Chapter 4, Cumulative Impacts, as shown below. 14 Broad Beach Centralized North Santa d1,Re-2044 Biofiltration Monica Bay (Gempletian a Project Coastal 6eRstrastieR)Early Watersheds 2015 Section Chapter 6, Alternatives Page Clarification/Revision 6-5 "Reduce pollutants from dry- and wet -weather urban runoff' be changed to "reduce pollutants from dry- and wet -weather runoff." The change has been included in Chapter 6, Alternatives, as shown below. The No Program Alternative would not meet the EWMP objective to collaborate among agencies across the watershed to promote more cost-effective and multi - beneficial water quality improvement projects, but it would meet the other IA County Flood Control District I Z -3`d ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications objectives to remove or reduce pollutants from dry- and wet -weather urban runoff and reduce the impact of stormwater and non-stormwater on receiving water quality through implementation of structural and non-structural BMPs. 6-13 "Pollutants from dry- and wet -weather urban runoff in a cost-effective manner" should be changed to "pollutants from dry- and wet -weather runoff in a cost- effective manner." The change has been included in Chapter 6, Alternatives, as shown below. Distributed Structural/ Non- Non - Proposed Structural Structural Program No Project BMPs Only BMPs Only Project Objectives To collaborate among agencies (Permittee jurisdictions) across the watershed to promote more cost-effective and multi- Yes No No No beneficial water quality improvement projects to comply with the MS4 Permit. To develop watershed -wide EWMPs that will, once implemented, remove or reduce Yes No No No pollutants from dry- and wet - weather wbaa runoff in a cost- effective manner. Section Chapter 9, References Page Clarification/Revision 9-16 The Basin Plan for the Santa Ana Regional Water Quality Control Board is mistakenly included as a reference on page 9-16. The correct reference has been updated in Chapter 9, References, as shown below. California Regional Water Quality Control Board, �;Ai3tA A BA Los Angeles Region - 19945 Water Quality Control Plan for the Sang. Ana Rive_ Los Angeles Region Basin (Basin Plan) updated in Febf .ary -2008 June 1994. Section Appendix B, Scoping Report and Comment Letters (Attachment 9: Public Comment Letters Received) Page Clarification/Revision N/A The following eight NOP comment letters have been added to the end of the group of letters included. 21 10/21/2014 L. Gavle San Citizen Miguel 22 9/16/2014 Rchard Schulhof Los Angeles County Arboretum and Botanic Garden LA County Flood Control District I Z -4U ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Clarifications and Modifications 23 10/28/2014 Georae Ball Citizen 24 12/1/2014 William Lincoln Citizen 25 11/11/2014 Margaret Page Citizen 26 12/2/2014 Pat Wilmot Citizen 27 12/17/2014 Maraaux Yera Citizen 28 10/19/2014 Sandy Slider Citizen LA County Flood Control District 1 Z-4 1 ESA / 140379 Enhanced Watershed Management Programs Apd12015 Final Program Environmental Impact Report CONFIDENTIAL -ATTORNEY-CLIENT PRIVILEGEMORK PRODUCT Appendix A Additional NOP Public Comment Letters Received r ESA J 2195 Sherwood Road San Marino, CA 91108 October 28, 2014 Ms. Genevieve Osmena County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont, 5th Floor Alhambra, CA 91803 Dear Ms. Osmena, The purpose of this letter is to register my support for the restoration of Baldwin Lake as part of the Enhanced Watershed Management Plan (EWMP) for the Rio Hondo Watershed. The lake has experienced significant deterioration in recent decades as a consequence of surface run-off and its very future is very much at risk. Establishing the restoration of Baldwin Lake as a priority project as part of the EWMP will ensure its status as an important ecological and historic asset for generations to come. Many thanks for attention to this matter. Very truly yours, George L. Ball i 05 \ § } \OL � } \ J G \ $ i 05 \ § } Genevieve Osmena From: Genevieve Osmena Sent: Monday, December 22, 2014 9:30 AM To: 'Lincoln, Bill' Subject: RE: Baldwin Lake From: Lincoln, Bill[mailto:blincolnCabatkaudiotek.coml Sent: Monday, December 01, 2014 4:40 PM To: Genevieve Osmena Subject: Baldwin Lake Dear Ms. Osmena, I am writing you as an advocate for the Enhanced Watershed Management Plan for the Rio Hondo Watershed to include Baldwin Lake. In addition to its function for water conservation/management, Baldwin Lake is integral to the history of the region and a centerpiece of the Los Angeles Arboretum which is a major County attraction. Thank you. William Lincoln Chief Financial Officer ATK AudioTek Office; 661-705-3700 Fax: 661-705-3707 I am writing in support of the restoration of Baldwin Lake at the Los Angeles Arboretum. I have loved The Arboretum as a child, as a parent, and now as a volunteer docent. Thousands of visitors consider the lake an important reason to visit the garden, and it is a critical part of the environment of many of the birds and other animals that call The Arboretum home. On history tours, children learn how important Baldwin Lake has been since its earliest history, when Tongva Indians called their home Aleupkigna or Place of Many Waters. Our visitors have expressed dismay and concern as the water levels have declined and the quality of the water deteriorated. Please know how important Baldwin Lake is to many in our community and beyond, and take advantage of the opportunity now available to restore the health and beauty of Baldwin Lake. Sincerely, Margaret Page Genevieve Osmena From: Osmena, Genevieve Sent: Tuesday, October 28, 2014 11:22 AM To: 'gaylesanmig@aol.com' Subject: RE: Baldwin Lake at the Arboretum Ms. San Miguel, Thank you for your email regarding Baldwin Lake at the LA Arboretum. I have added your contact information to the stakeholder list for the Rio Hondo/San Gabriel River Water Quality Group to receive notifications of future stakeholder meetings regarding the group's Enhanced Watershed Management Program (EWMP). We anticipate the next stakeholder meeting to occur in early to mid -Spring of next year to discuss the progress of the EWMP process with interested stakeholders. I have also forwarded your email to the group members for their consideration as they continue to discuss and develop their EWMP plan. Thanks again for your comments. Genevieve Osmen"a, P.E. County of Los Angeles Department of Public Works East Unincorporated County M54 Permit Compliance Watershed Management Division (626) 458-3978 gosmena@dpw.lacounty.gov From: gavlesanmig(aaol.com [mailto:gavlesanmigCabaol.com] Sent: Tuesday, October 21, 2014 8:57 AM To: Osmena, Genevieve Subject: Baldwin Lake at the Arboretum I am writing this note to ask you to do what you can to help restore Baldwin Lake in the LA County Arboretum. The historical center of the property is in need of dredging and repair work to the sides. The lake has a water supply that is covered with debris and water level has dropped from the original 18 feet to 18 inches. We are losing too many historical places in the country today. Please support any projects that will help restore the lake. The Baldwin Queen Anne Cottage and the lake are important draws for visitors from all over the world. Thank you for your time, L.Gayle San Miguel 2132 Highland Oaks Dr. Arcadia, Ca. 1 bbd' %od. .*���� The Arboretum LOSANGELES COON TYARBOREn1M & BOTANIC GARDEN September 16, 2014 Ms. Genevieve Osmena County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont, 5h Floor Alhambra, CA 91803 Dear Ms. Osmena: On behalf the Arboretum community, I propose that the re-engineering of Arcadia's Baldwin Lake be included as an important priority in the Rio Hondo/San Gabriel River Enhanced Watershed Management Plan. Located within the Los Angeles County Arboretum, Baldwin Lake is a magnificent 19te century landmark that began as a naturally occurring wetland along the Raymond Fault. The lake was created by Elias Jackson Baldwin in the 1880s to serve as the centerpiece of the Baldwin Ranch, one of the largest agricultural enterprises in the region. In the early 1950s, Baldwin Lake was repurposed to serve as the collection basin for Arcadia's urban watershed to the north, today receiving runoff from nearly 200 acres of mostly paved surfaces. During the last storm event in our area, this past March, over three million gallons of water moved into the lake with little or no bio -filtration. Within 24 hours of the start of the storm, a slick of oil across the water's surface became an almost dominant feature. In sum, Baldwin Lake and its connecting systems were never designed to serve a very significant collection function for a large urban watershed. Consequently, annual delivery of petrochemicals and other contaminants has created a dysfunctional drainage as well as a degraded aquatic ecosystem in a highly public location of scenic, educational and historic value. A 2012 study of water and sediments found significant deposits of oil and tar, toxic pesticide residues, and bacteria counts that exceeded the limits for recreational water. Mitigating these issues promises the ideal multi -benefit regional project. Please note the following points: 1. Baldwin Lake, with a current capacity of just under 4 million gallons, if returned to its original depth, would provide over twelve million gallons in storage capacity. With modification, it could also serve as a significant infiltration basin for aquifer recharge. 2. Tule Pond to the north, a canal roughly 600ft. in length, is the point of entry for the urban watershed, feeding directly into Baldwin Lake. Its size, shape and location offer great potential for water quality enhancement through modification as a bioswale. Page 2, Ms. Genevieve Osmena 3. The Lake is a key educational, scenic, wildlife, and historic resource serving over 330,000 visitors per year, including over 16,000 elementary school students on field trips. The project would provide an unrivaled opportunity to educate a broad public about regional water management, home and community water conservation, and the role of the Raymond Basin and the other key water resources that sustain us. 4. The Arboretum Foundation, the County's non-profit partner in operating the Arboretum, stands ready to help leverage public dollars to realize the site's unique educational potential. Also, please note that in the stated ranking criteria for proposed multi -benefit regional projects, Baldwin Lake scores highly in 5 of the 6 categories. It is publicly owned, offers a water body four acres in size, is within a potential surrounding catchment area of over 100 acres, cleanses runoff that likely exceeds allowances, and perhaps most importantly, offers very substantial multi -use opportunities and connectivity. I urge your consideration of Baldwin Lake as a key project within the Rio Hondo/Upper San Gabriel Enhanced Watershed Management Plan. I thank you for your time and consideration. Sincerely, Richard Schulhof, CEO Los Angeles County Arboretum and Botanic Garden 301 North Baldwin Arcadia, CA 91007 richard.schulhofna,arboretum.orm 626.821.3231 www.arboretum.org cc. Mr. Gregg BeGell Genevieve Osmena From: Sandy Snider [mailto:ssnider626@charter.net] Sent: Sunday, October 19, 2014 5:07 PM To: Osmena, Genevieve Subject: Arboretum's Baldwin Lake as part of Rio Hondo Watershed Management plans Dear Ms. Osmena, I write in support of the inclusion of the Arboretum's Baldwin lake in Public Work's ongoing efforts to create an Enhanced Watershed Management Plan for the Rio Hondo watershed in which the Arboretum resides. I understand that many projects must be considered, but Baldwin Lake can be a jewel in this effort, perhaps even part of the Emerald Necklace one day. I enjoyed a 35 year career as a County employee, all of those years spent at the Arboretum as the History Curator. My Master's thesis centered on land use by entrepreneur Elias Jackson "Luck" Baldwin, founder of the City of Arcadia and premier owner of the land now known as the Arboretum. Lucky Baldwin found a sag pond on his property upon purchase in 1875, but it was already a geologic feature that worked well for Baldwin as a holding reservoir for his vast irrigation system. Baldwin acquired water rights to half of each Big and Little Santa Anita Canyon waters to supplement the natural artesian sources that came with Rancho Santa Anita, and his irrigation designs were noted and reportedly photographed by the US Geologic Service in the early 1890's. At approximately this same time, Baldwin dredged and deepened the natural basin now called Baldwin Lake, taking it to some 15-18 feet in depth. Runoff from multiple natural streams were channeled into Baldwin Lake, and outflow went south and east into orchards and vineyards. From there, waters travelled their current route through the Rio Hondo watershed, eventually reaching Whittier Narrows (where Baldwin owned numerous parcels of adjacent land). Lucky Baldwin created an estate garden of note during his ownership years (1875-1909), and Baldwin Lake with its granite boulder -topped retaining walls was a popular feature. Period postcards document this era, as do oral histories and other primary sources of note. It is rare to find such pristine land largely undeveloped in Southern California, but Baldwin's daughters ensured that the land remain intact, and in 1947 the County of Los Angeles purchased the remaining acreage of Baldwin Ranch for public purposes. I wrote the National Register of Historic Places nomination for Baldwin's Queen Anne Cottage and matching Coach Barn in 1980, and it was with significant urging from the State Office of Historic Preservation that the four -acre Baldwin Lake and surrounding landscape were included in this application. The entire 9 -acre parcel with two structures and the entire Baldwin Lake became part of the National Register, and almost 35 years later we remain the primary caretakers of this precious resource. The addition of the strong voice and professional resources of Public Works would be greatly appreciated. I retired in 2006, but immediately became a volunteer at the Arboretum and have continued my efforts to preserve the historic integrity of this amazing facility. I am now in my fourth year as President of the Arboretum's 300 -person strong Los Voluntarios, and I am sure you will hear from others in our ranks who share the Lake every day with thousands of visiting adults and school children. We see the magic every day as children without such magnificent resources nearby enjoy both the beauty of the land and the wildlife that Baldwin Lake supports. The gradual degradation of the lake over the years has been hard to watch. I have seen the Lake go dry in past droughts, but the build-up of sediment over the past ten years has drastically exacerbated matters. What was once 12 feet or so of relatively healthy water during my working years is now perhaps 18 inches at best. I believe that Baldwin Lake is the last remaining sag pond along the Raymond Hill Fault still functioning as a body of water; to lose this incredible resource after 125 years of effort by so many would be tragic. Not every concerned Arboretum volunteer will write despite their frequently voiced concerns, but please be assured that I confidently speak for at least our 30 member Los Voluntarios Board. We have previously written to Supervisor Antonovich with our concerns about the future well-being of Baldwin Lake, and we would be happy to share that letter with you if it is of any help in current efforts to prioritize projects within the Enhanced Watershed Management Plan. I thank you for your consideration, Sandy Snider 841 Junipero Dr. Duarte, CA 91010 626/358-4601 Paige Anderson From: Crumpacker, Andrea <Andrea.Crum packer@WestonSolutions.com> Sent: Thursday, February 19, 2015 7:53 AM To: Laura Rocha; David Pohl; Tom Barnes Subject: Fwd: Arboretum's Baldwin Lake as part of Rio Hondo Watershed Management plans Sent from my iPhone Begin forwarded message: From: Gregg Begell <gbegell@dpw.lacountv.gov> Date: February 19, 2015 at 7:48:04 PST To: "Crumpacker, Andrea" <Andrea.Crumpacker@WestonSolutions.com> Subject: FW: Arboretum's Baldwin Lake as part of Rio Hondo Watershed Management plans Andrea Let's list these people with Sandy Sniders letter of support. We can't find their e-mails. • Pat Wilmot, First VP Los Voluntarios • Margaret Page, Los Voluntarios History Preservation chair • Andy Edmonds, Los Voluntarios Herb Garden chair • Gayle San Miguel, Los Voluntarios community liaison • Laura gene Swenson, Los Voluntarios communications chair (though she sent to Sup. Antonovich directly and may not have cc'd either of you) • Pam Warner. Arboretum Trustee I haven't seen Heflin or Moore's e-mail yet. I'll forward when I get them. Gregg BeGe[[P E Project Manager Project Management Division II From: Sandy Snider [mailto:ssnider626@charter.net l Sent: Wednesday, February 18, 2015 10:24 PM To: Gregg Begell; Genevieve Osmena Subject: RE Arboretum's Baldwin Lake as part of Rio Hondo Watershed Management plans Gregg: I would appreciate 4 or 5 discs for distribution .... thank you for the offer. Unfortunately, most of the volunteers I have spoken with say they did not save their 'sent' email items, so not sure I can retrieve them for inclusion in the PEIR. I am hearing from most of those I listed below that they are receiving notifications of the March 9 public meeting, so I am hoping that at least their email addresses can be included in the final PEIR as having sent comments. Since my last communication, I have heard from a couple of other constituents that they are sending a second letter/email ..... hopefully, those will be received and recorded (Heflin, Moore). You and Gennie have been so helpful with your prompt answers to our inquiries .... we do appreciate it. By the way, in the course of studying past reports on the Arboretum's Baldwin Lake, I find reference to LA County Flood Control being onsite in April, 1975 with recommendations about storm water management re both Tule Pond and Baldwin Lake. The report does not list a specific citation with report number/author; is there someone with whom I could speak or some way I can access this archived report? The report (Baldwin Lake Study) is from 2007, written by Morton Price as part of a Masters project for his degree from Cal State University Los Angeles (my own alma mater). Sandy Snider 841 Junipero Dr. Duarte, CA. 91010 626/358-4601 From: Gregg Begell [mailto:abeaell(a)dow.lacountv.aovl Sent: Wednesday, February 18, 2015 2:47 PM To: Sandy Snider; Genevieve Osmena Subject: RE Arboretum's Baldwin Lake as part of Rio Hondo Watershed Management plans Sandy I have several disc's with PER How many would you like, I'll mail them to you. Also, please resend the letters from your members (below) and we will include them in the final PER Gregg BeGeffP E Project Manager Project Management Division II From: Sandy Snider [mailto: ssnider626(a)charter.netl Sent: Wednesday, February 11, 2015 7:34 PM To: Gregg Begell; Genevieve Osmena Subject: RE Arboretum's Baldwin Lake as part of Rio Hondo Watershed Management plans Thank you, Gregg. We are tracking down the names of all our Foundation Trustees who sent comments, but trying to piece together all the volunteers (from our core of 300) isn't easy. Please do add Harriet Furin to the list of volunteers who sent correspondence. Sandy From: Gregg Begell [ mai Ito: obeaell(o)dow.lacountv.coy l Sent: Wednesday, February 11, 2015 2:40 PM To: Sandy Snider; Genevieve Osmena Subject: RE Arboretum's Baldwin Lake as part of Rio Hondo Watershed Management plans Sandy I'm sorry to hear that your letter didn't get listed in the PEIR; I am tracking down the reason. The team writing the PEIR did receive it and reviewed it in their preparation of the PER We will be including any missing letters in the final PEIR. I apologize for this error, your comments are appreciated. I'll contact the other people listed. Gregg BeGed)o E Project Manager Project Management Division II From: Sandy Snider[mailto:ssnider626a.charter.net l Sent: Wednesday, February 11, 2015 1:12 PM To: Genevieve Osmena Cc: Gregg Begell Subject: RE Arboretum's Baldwin Lake as part of Rio Hondo Watershed Management plans Hello Gennie (and Gregg), Thank you for your reply. Not that my single letter is of great importance, but I have since learned of other Arboretum volunteers and Trustees whose comment letters are also not in the Draft PER All confirm that they sent letters/email and received acknowledgment of receipt from either you or Gregg. Beside myself, names omitted include: • Pat Wilmot, First VP Los Voluntarios • Margaret Page, Los Voluntarios History Preservation chair • Andy Edmonds, Los Voluntarios Herb Garden chair • Gayle San Miguel, Los Voluntarios community liaison • Lauragene Swenson, Los Voluntarios communications chair (though she sent to Sup. Antonovich directly and may not have cc'd either of you) • Pam Warner, Arboretum Trustee We haven't checked in with everyone, of course, butjust a quick email to those I work with closely caused some alarm about how comment letters were accounted for. I am fairly sure that Trustees Leelee Doughty (Secretary) and Bill Lincoln (Treasurer) were intending to write; perhaps also Trustee Dan Foliart (First VP). Those bulleted above are the ones I am sure sent letters/email. Many thanks for looking into this. Sandy From: Genevieve Osmena [mailto:gosmenaC)dpw.lacounty.aovl Sent: Wednesday, February 11, 2015 12:20 PM To: Sandy Snider Cc: Gregg Begell Subject: RE Arboretum's Baldwin Lake as part of Rio Hondo Watershed Management plans Hi Sandy, I apologize that your comment letter was not included in the Draft PEIR document. We are looking into why it was omitted and how to incorporate it now. Gregg Begell is the project manager for the preparation of the document and I believe he is planning to contact you with a response as well. Gennie Genevieve Osmena, P.E. County of Los Angeles Department of Public Works East Unincorporated County MS4 Permit Compliance Watershed Management Division (626) 458-3978 gosmena@dpw.locoun ty. gov From: Sandy Snider [mailto: ssnider626(o)charter.netl Sent: Monday, February 09, 2015 4:43 PM To: Genevieve Osmena Subject: FW: Arboretum's Baldwin Lake as part of Rio Hondo Watershed Management plans Hello Gennie —At our Arboretum Los Voluntarios general meeting this morning, Richard Schulhof and I were handed a DVD by one of our volunteers (Jane Florentinus) that she said came from the Dept. of Public Works. Richard was unable to open it at work, so I took it home with me. Very interesting reading, but I was left wondering why I didn't receive a direct copy as a 'stakeholder' who sent my comments in on Oct. 20, 2014 (see below). I looked at the relatively brief list of those who sent comments, but my name was not included .... I am sure this was not done on purpose, but I hope others who may have commented were not also inadvertently omitted. I do see some of our Arboretum Trustees plus others in our volunteer ranks. Should I re -submit my comments and ask others who I know sent in letters/email to do the same? Many thanks, Sandy Snider From: Begell, Gregg - Consultant [mailto:gbegell(@dpw.lacounty.govl Sent: Monday, October 20, 2014 7:20 AM To: Sandy Snider Subject: RE Arboretum's Baldwin Lake as part of Rio Hondo Watershed Management plans Sandy Thank you for your comment. We'll review it as part of the PEIR. Gregg BeGe[[P E Project Manager Project Management Division II From: Sandy Snider [mailto: ssnider626(a)charter.netl Sent: Sunday, October 19, 2014 5:09 PM To: Begell, Gregg - Consultant Subject: Arboretum's Baldwin Lake as part of Rio Hondo Watershed Management plans Dear Mr. BeGell, I write in support of the inclusion of the Arboretum's Baldwin Lake in Public Work's ongoing efforts to create an Enhanced Watershed Management Plan for the Rio Hondo watershed in which the Arboretum resides. I understand that many projects must be considered, but Baldwin Lake can be a jewel in this effort, perhaps even part of the Emerald Necklace one day. I enjoyed a 35 year career as a County employee, all of those years spent at the Arboretum as the History Curator. My Master's thesis centered on land use by entrepreneur Elias Jackson "Lucky' Baldwin, founder of the City of Arcadia and premier owner of the land now known as the Arboretum. Lucky Baldwin found a sag pond on his property upon purchase in 1875, but it was already a geologic feature that worked well for Baldwin as a holding reservoir for his vast irrigation system. Baldwin acquired water rights to half of each Big and Little Santa Anita Canyon waters to supplement the natural artesian sources that came with Rancho Santa Anita, and his irrigation designs were noted and reportedly photographed by the US Geologic Service in the early 1890's. At approximately this same time, Baldwin dredged and deepened the natural basin now called Baldwin Lake, taking it to some 15-18 feet in depth. Runoff from multiple natural streams were channeled into Baldwin Lake, and outflow went south and east into orchards and vineyards. From there, waters travelled their current route through the Rio Hondo watershed, eventually reaching Whittier Narrows (where Baldwin owned numerous parcels of adjacent land). Lucky Baldwin created an estate garden of note during his ownership years (1875-1909), and Baldwin Lake with its granite boulder -topped retaining walls was a popular feature. Period postcards document this era, as do oral histories and other primary sources of note. It is rare to find such pristine land largely undeveloped in Southern California, but Baldwin's daughters ensured that the land remain intact, and in 1947 the County of Los Angeles purchased the remaining acreage of Baldwin Ranch for public purposes. I wrote the National Register of Historic Places nomination for Baldwin's Queen Anne Cottage and matching Coach Barn in 1980, and it was with significant urging from the State Office of Historic Preservation that the four -acre Baldwin Lake and surrounding landscape were included in this application. The entire 9 -acre parcel with two structures and the entire Baldwin Lake became part of the National Register, and almost 35 years later we remain the primary caretakers of this precious resource. The addition of the strong voice and professional resources of Public Works would be greatly appreciated. I retired in 2006, but immediately became a volunteer at the Arboretum and have continued my efforts to preserve the historic integrity of this amazing facility. I am now in my fourth year as President of the Arboretum's 300 -person strong Los Voluntarios, and I am sure you will hear from others in our ranks who share the Lake every day with thousands of visiting adults and school children. We see the magic every day as children without such magnificent resources nearby enjoy both the beauty of the land and the wildlife that Baldwin Lake supports. The gradual degradation of the lake over the years has been hard to watch. I have seen the Lake go dry in past droughts, but the build-up of sediment over the past ten years has drastically exacerbated matters. What was once 12 feet or so of relatively healthy water during my working years is now perhaps 18 inches at best. I believe that Baldwin Lake is the last remaining sag pond along the Raymond Hill Fault still functioning as a body of water; to lose this incredible resource after 125 years of effort by so many would be tragic. Not every concerned Arboretum volunteer will write despite their frequently voiced concerns, but please be assured that I confidently speak for at least our 30 member Los Voluntarios Board. We have previously written to Supervisor Antonovich with our concerns about the future well-being of Baldwin Lake, and we would be happy to share that letter with you if it is of any help in current efforts to prioritize projects within the Enhanced Watershed Management Plan. I thank you for your consideration, Sandy Snider 841 Junipero Dr. Duarte, CA 91010 626/358-4601 CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. 9 Genevieve Osmena From: Margaux Viera [mailto:oauxviera(a)gmail.com] Sent: Wednesday, December 17, 2014 10:20 AM To: Genevieve Osmena; Gregg Begell Cc: Linda Lee Miller Subject: Baldwin Lake restoration project Mr. Gregg BeGell, P.E. County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont, Sth Floor Alhambra, CA 91803 Ms. Genevieve Osmena County of Los Angeles Department of Public Works Project Management Division II 900 South Fremont, Sth Floor Alhambra, CA 91803 Dear Gregg BeGell & Genevieve Osmena, Since the Los Angeles Regional Water Quality Control Board has released all of the submitted EWMP Workplans and CIMPs for public comment, I have decided to write you. My name is Margaux L. Viera. I am the great great great granddaughter of Elias Jackson "Lucky" Baldwin, who was a previous land owner of Rancho Santa Anita now know as, The Los Angeles County Arboretum & Botanical Gardens. On the land site there is a natural lake, named Baldwin Lake. I have recently joined the board of trustees at The Los Angeles Arboretum, their cultural heritage committee and lastly the group fore running the campaign to, "SAVE BALDWIN LAKE". Baldwin Lake has been the anchor of this site since it's founding. The lake has been a natural source of artesian water, going back to the Baldwin era as well as being featured in thousands of film and television features. Most named is the original Tarzan feature film and the Fantasy Island television series. Hundreds of thousands of people travel each year to The Los Angeles Arboretum to experience the natural serenity, discover plant & animal species, learn about it's founders and rich history. Many of which are grade school students coming here for the first time to experience a natural setting hidden in the middle of Los Angeles County. That is one of the things that makes, The Los Angeles Arboretum so unique and special. The EWMP Work Plan approaches to prioritize stormwater pollutants, identify sites that are suitable for water quality and conservation projects, and conduct reasonable assurance analyses with a peer-reviewed model. Baldwin Lake should be placed on the top of the list and be a county priority. The CIMP details the watershed groups' collaborative plan to conduct long-term monitoring in the watersheds in an effort to continuously assess the water quality of urban discharges and their impact on our waterways. Baldwin Lake is in dire need of your aid and attention. The current conditions of the lake fall under all your plans and could be a great model and learning tool. The preservation of this natural resource is critical for the future of our county's natural resources and the future of our children's environment. Thank you for your time and I look forward to seeing Los Angeles county take the necessary actions needed to preserve our counties assets. Happy holidays, z Margaux L. Viera 820 North Verano Drive Glendora, CA 91741 (626)399-9621 gauxviera(&,Rmail.com Paige Anderson To: Laura Rocha Subject: RE: Los Angeles Arboretum - Baldwin Lake (Letter Resend) -----Original Message ----- From: Pat Wilmot [mailto:britbird05(&aol.coml Sent: Saturday, March 07, 2015 6:22 PM To: Gregg Begell Subject: Los Angeles Arboretum - Baldwin Lake (Letter Resend) Dear Mr BeGell, Attached is a resend of a letter originally sent as an email on December 2, 2014. My understanding is that since the original was an email and not a separate attachment, my letter would not have been included in the compilation of letters sent to your office. Thank you for your time and attention. Patricia Wilmot 1428 S Stoneman Ave Alhambra, CA 91801 CONFIDENTIALITY: This email and attachments may contain information which is confidential and proprietary. Disclosure or use of any such confidential or proprietary information without the written permission of Weston Solutions, Inc. is strictly prohibited. If you received this email in error, please notify the sender by return e-mail and delete this email from your system. Thank you. From: Pat Wilmot <britbird05@aol.com> Subject: Los Angeles Arboretum - Baldwin Lake Date: December 2, 2014 at 11:37:41 AM PST To: "Mr. BeGell" <gbegell@dpw.lacounty.gov> Dear Mr. BeGell, I am writing in support of the efforts to restore Baldwin Lake at the Los Angeles Arboretum. I have lived in the Alhambra area since 1985 and over the years have been a regular visitor to the Arboretum. The decline of the lake is very obvious. It used to be a flourishing home for all kinds of birds and wildlife, but now, sadly, it just looks dirty and neglected. It is really a shame since the beautiful Queen Anne cottage forms a backdrop to the lake. Since retiring I have become a volunteer at the Arboretum and lead groups of school kids on history tours - mostly 3rd and 4th graders. The beauty of the Arboretum fascinates them, especially the inner-city kids, but all express concerns about how dirty the water in the lake looks and want to know "Why?" Please do whatever you can to support the restoration of the lake. It is part of a beautiful and historic area and deserves to be shown to it's full potential. If you have never visiited the Arboretum, (or if it has been a long time since your last visit), please come and see for yourself what a beautiful, fascinating and restful place it is. We have volunteer docents that would be more than happy to lead you on a tour! Sincerely, Patricia Wilmot Exhibit A FINDINGS OF FACT IN SUPPORT OF FINDINGS RELATED TO SIGNIFICANT ENVIRONMENTAL IMPACTS State CEQA Guidelines Section 15091 for Enhanced Watershed Management Programs Final Program Environmental Impact Report SCH# 2014081106 Lead Agency: Los Angeles County Flood Control District 1.0 Introduction The following findings of fact are based in part on the information contained in the Draft and Final Program Environmental Impact Report (Program EIR) for the Enhanced Watershed Management Program, as well as additional facts found in the complete record of proceedings. The Final Program EIR is hereby incorporated by reference and is available for review at the Department of Public Works, 900 south Fremont Avenue, 11" Floor, Alhambra, CA 91803, during normal business hours, and is also available on the District's website www.LACoH20sheds.com. In December 2012, the Los Angeles Regional Water Quality Control Board (LARWQCB) issued a Municipal Separate Storm Sewer System (MS4) Permit (Order No. R4-2012-0175; National Pollutant Discharge Elimination System [NPDES] Permit No. CAS004001) covering discharges within coastal watersheds from the collective storm sewer systems in Los Angeles County (except from the City of Long Beach). The Permit regulates the discharge of stormwater runoff to waters of the United States from facilities owned and maintained by the Los Angeles County Flood Control District (LACFCD or District), the County of Los Angeles, and 84 incorporated cities within Los Angeles County (collectively referred to as Permittees). The purpose of the MS4 Permit is to achieve and maintain water quality objectives to protect beneficial uses of the receiving waters in the Los Angeles region. Each of the Permittees identified in the MS4 permit is responsible for meeting the conditions of the permit for MS4 discharges occurring within their jurisdiction. The MS4 Permit gives Permittees the option of implementing an innovative approach to permit compliance through development of an Enhanced Watershed Management Program (E)NIMP). The EWMPs will identify potential and priority structural and non-structural Best Management LA county Flood control Distinct t ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Practices (BMWs) within the region's stormwater collection system to improve runoff water quality. The LACFCD, along with participating Permittees, has opted to exercise this option and has submitted to the LARWQCB 12 separate Notices of Intent (NOls) for the development of EWMWs within 12 distinct watershed groups. Implementation of the EMWPs would be the responsibility of each Permittee and would occur following approval of the EWMPs by the LARWQCB. The LACFCD, as a regional agency, is a member of each of the 12 EWMP working groups, and as such provides a commonality within each EWMP group. However, LACFCD does not have a special status or authority designated by the MS4 Permit over any of the other Permittees. The LACFCD will be working with the applicable Permittees in all 12 EWMP watersheds as an equal partner to identify the types and locations of BMWs needed to achieve permit compliance within each watershed. The timeline identified in the MS4 Permit requires that Permittees submit the EWMP to the LARWQCB by June 28, 2015, in order to be in compliance with the permit conditions. The LACFCD recognizes that implementation of the EWMWs may potentially result in changes to environmental conditions. As a result, the LACFCD has prepared this Program Environmental Impact Report (PEIR) in compliance with the California Environmental Quality Act (CEQA) to provide the public and the responsible and trustee agencies with information about the potential effects on the local and regional environment associated with implementation of the EWMPs. The LACFCD will submit the PEIR to its governing body, the Los Angeles County Board of Supervisors, for approval prior to submittal of the EWMWs. The EWMWs will be submitted by each EWMP group to the LARWQCB. The LACFCD issued a notice of preparation of a Draft Program FIR on July 27, 2012. The notice of preparation stated that the Draft Program FIR would contain a comprehensive analysis of environmental issues identified in Appendix G of the California Environmental Quality Act (CEQA) Guidelines. With respect to all impacts identified as "less than significant" or as having "no impacts' in the Final Program EIR, the District finds that those impacts have been described accurately and are less than significant or have no impact. In addition, some impacts in the Final Program FIR were found to be potentially "significant" but are able to be mitigated to less -than - significant levels, and others were found to be "significant and unavoidable." The District finds that those impacts have been described accurately and are less than significant with the implementation of mitigation or are significant and unavoidable. The District further finds that the application of mitigation measures identified in the Final Program FIR would be the responsibility of each agency implementing projects identified in the program (implementing agencies). The District finds that the mitigation measures identified in the Final FIR are reasonable and readily implementable under foreseeable circumstances, such that it is reasonably assumed that implementing agencies can and should adopt and implement them for their projects. The conclusions of significance for each impact in the Final Program FIR therefore assume that mitigation measures identified in the Final Program FIR would be applied as described therein. LA county Flood control Distinct 2 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact The District has adopted the mitigation measures identified in the Final Program EIR, and will implement those measures for projects it implements under the Program. However, as explained more fully in Section 5.0, because the District will not be the implementing agency for all projects being implemented as part of the proposed program, the District cannot state with certainty that all impacts capable of being mitigated to less -than -significant levels will in fact be mitigated to a less -than -significant level. Accordingly, the District finds that as to projects where the District will not be an implementing agency, the impacts described in the Program FIR as being potentially "significant" but capable of being mitigated to less -than -significant levels must be found to be "significant and unavoidable." 2.0 Project Description The 12 EW -MPs will vary for each watershed group, but will generally provide the opportunity for Permittees to customize their stormwater programs to achieve compliance with applicable receiving water limitations (RWLs) and water -quality -based effluent limits (WQBELs) in accordance with the MS4 Permit through implementation of stormwater best management practices (BMWs) or watershed control measures. BMPs vary in function and type, with each BMP providing unique design characteristics and benefits from implementation. The overarching goal of BMPs in the EWMP is to reduce the impact of stormwater and non-stormwater on receiving water quality and address the water quality priorities as defined by the MS4 Permit. The development of each EWMP will involve the evaluation and selection of multiple BMP types, including nonstructural (institutional) and distributed, centralized, and regional structural watershed control measures, that will be implemented to meet compliance goals and strategies under the 2012 MS4 Permit. The LACFCD has limited jurisdictional authority for ordinance and code enactment or enforcement and therefore is limited in nonstructural BMPs to education and outreach measures. The structural watershed control measures that will be implemented by the LACFCD will be multi -benefit stormwater projects that emphasize flood risk mitigation and water conservation and supply. The LACFCD has a vested interest in increasing opportunities for stormwater capture and groundwater recharge as a means of assisting local water supply augmentation. The LACFCD will be working with the applicable Permittees and other stakeholders in all 12 EWMP watersheds to develop such projects. The EWMPs will be implemented by the Permittees that have jurisdiction within each EWMP area. The implementing agencies will be responsible for the contents of the EW -MPs affecting their jurisdictions and for implementing the projects developed by the EW -MPs. Structural control measures are constructed BMPs that reduce the impact of stormwater and non- stormwater on receiving water quality. They are broken into three categories: Distributed Structural BMPs, which treat runoff close to the source and are typically implemented at a single- or few -parcel level (e.g., facilities typically serving a contributing area less than one acre). LA county Flood control Distinct 3 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Centralized Structural BMPs, which treat runoff from a contributing area of multiple parcels (e.g., facilities typically serving a contributing area on the order of tens or hundreds of acres or larger). Regional Structural BMPs, which are meant to retain the 85th percentile storm over 24 hours from a contributing area. Generally, the 85" percentile storm is approximately 0.75 inches over 24 hours Whether distributed, centralized, or regional, the major structural BMP functions are infiltration, treatment, and storage, which may be used individually or combination: • Infiltration, where runoff is directed to percolate into the underlying soils. Infiltration generally reduces the volume of runoff and increases groundwater recharge. Treatment, where pollutants are removed through various unit processes, including filtration, settling, sedimentation, sorption, straining, and biological or chemical transformations. • Storage, where runoff is captured, stored (detained), and slowly released into downstream waters. Storage can reduce the peak flow rate from a site, but does not directly reduce runoff volume. The types of structural BMPs to be implemented will vary between EWMPs, but most EMWPs will include a variety of distributed, centralized, and regional BMPs. Non-structural BMPs are policies, actions, and activities which are intended to minimize or eliminate pollutant sources. Most institutional BMPs are implemented to meet Minimum Control Measure (MCM) requirements in the MS4 permit; MCMs are considered a subset of institutional BMPs. These BMPs are not constructed, but may have costs associated with the procurement and installation of items such as signage or spill response kits. 3.0 CEQA Review and Public Participation A Notice of Preparation (NOP)/Initial Study (SCH No. 2014081106) was circulated for a 30 -day public review period beginning on August 29, 2014. Twenty (20) individual written comment letters were received and used in the preparation of the Draft PEIR. The Draft PEIR for the proposed project was initially circulated for a 45 -day public review period beginning on January 21, 2015 and ending on March 9, 2015. Per an announcement via e-mail blast on March 6, the comment period was extended through March 16, 2015 at SPM. A total of 46 individual written comment letters were received on the Draft PEIR. Section 15088 of the CEQA Guidelines requires that the lead agency evaluate comments on environmental issues received from persons and agencies that reviewed the Draft PEIR and prepare a written response addressing each of the comments received. The response to comments LA county Flood control Distinct 4 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact is contained in this document Volume 3, Chapter 12 of the Final PEIR. Volumes 1 through 3 together constitute the Final PEIR. A list of agencies and interested parties who have commented on the Draft PEIR is provided below. A copy of each numbered comment letter and a lettered response to each comment are provided in Chapter 12, Response to Comments, of this Final PEIR. LACFCD held 6 community meetings on January 29 and February 3, 5, 10, 11 and 17, 2015 to discuss the Draft PEIR analysis and alternatives. The six public meetings that took place at 6PM each night listed are as follows: • Public Meeting 1 (Florence -Firestone Service Center — January 29, 2015) • Public Meeting 2 (LA County Fire Camp — February 3, 2015) • Public Meeting 3 (San Pedro Service Center —February 5, 2015) • Public Meeting 4 (Topanga Library—February 10, 2015) • Public Meeting 5 (Hacienda Heights Community Center — February 11, 2015) • Public Meeting 6 (East Los Angeles Library — February 17, 2015) 4.0 No Environmental Impacts 4.1 Structural BMPs 4.1.1 Aesthetics The proposed program would not create a new source of substantial light or glare that would adversely affect day or nighttime views in the area (Impact 3.1-4). Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the creation of new sources of substantial light or glare that would adversely affect day or nighttime views in the area. 4.1.2 Air Quality The proposed program would not conflict with or obstruct implementation of the applicable air quality plan (Impact 3.2-1). Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to conflicting with or obstructing implementation of the AQMP prepared by SCAQMD and SCAG. LA county Flood control Distinct 5 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact 4.1.3 Biological Resources The proposed program would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. (Impact 3.3-4) The proposed program would not conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan. (Impact 3.3-6) Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the Proposed Program would result in no impact relating to the interference with the movement of any native resident or migratory fish or wildlife or with established native resident or migratory wildlife corridors, or the impediment of the use of native wildlife nursery sites. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to conflict with the provisions of an adopted habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan. 4.1.4 Cultural Resources The proposed program would not have any environmental effects related to cultural resources that would result in no impacts or less than significant impacts unmitigated. 4.1.5 Geologic and Mineral Resources The proposed program would not locate new facilities in areas susceptible to seismic impacts such as (1) rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area based on other substantial evidence of a known fault, (2) strong seismic groundshaking, or (3) seismically induced liquefaction or landslides, which could expose people, structures, or habitat to potential risk of loss, damage, injury, or death (Impact 3.5-1). The proposed program would not result in substantial soil erosion or the loss of topsoil (Impact 3.5-2). The proposed program would not be located on expansive soil as defined in 24 CCR 1803.5.3 of the California Building Code (2013), creating substantial risks to life or structures. (Impact 3.5- 4). The proposed program would not have soils incapable of adequately supporting the use of a septic tank or alternative wastewater treatment systems where sewers are not available for the disposal of wastewater (Impact 3.5-5). The proposed program would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state or a locally important mineral LA county Flood control Distinct 6 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact resource recovery site delineated on a local General Plan, Specific Plan, or other land use plan (Impact 3.5-6). Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to location of new facilities in areas susceptible to seismic impacts of various kinds. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to substantial soil erosion or loss of topsoil. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to location on expansive soil. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to having soils incapable of adequately supporting the use of septic tank or alternative wastewater treatment systems. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the loss of availability of a known mineral resource that would be of value to the region and the residents of the state, or a locally important mineral resource recovery site delineated on a local General Plan, Specific Plan, or other land use plan. 4.1.6 Greenhouse Gas Emissions The proposed program would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment (Impact 3.6-1). The proposed program would not conflict with an applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs (Impact 3.6-2). The proposed program would not result in significant cumulative impact to GHGs. Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the Proposed Program would result in no impact relating to generation of GHG emissions. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to confliction with an applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program does not have the potential to result in significant cumulative impacts to GHGs. LA county Flood control Distinct 7 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact 4.1.7 Hazards and Hazardous Materials The proposed program would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials or the accidental release during construction and maintenance activities (Impact 3-7.1). The proposed program would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing school (Impact 3.7-3). The proposed program would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan (Impact 3.7-6). The proposed program would not expose people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands (Impact 3.7-7). Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the creation of a significant hazard to the public or environment through routine transport, use, or disposal of hazardous materials or accidental release during construction and maintenance activities. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the Proposed Program would result in no impact relating to hazardous emissions or handling of hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing school. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the implementation of an adopted emergency response or emergency evacuation plan. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to exposure of people or structures to significant risk of loss, injury or death involving wildland fires. 4.1.8 Hydrology and Water Quality The proposed program would not violate water quality standards or waste discharge requirements or further degrade water quality (Impact 3.8-1). The proposed program would not substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river, or by other means, in a manner that would result in substantial erosion or siltation on- or off-site (Impact 3.8-3). The proposed program would not substantially alter the existing drainage pattern of a site or area through the alteration of the course of a stream or river or, by other means, substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site (Impact 3.8-4). LA county Flood control Distinct 8 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact The proposed program would not create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff (Impact 3.8-5). The proposed program would not place housing within a 100 -year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other authoritative flood hazard delineation map (Impact 3.8-6). The proposed program would not place within a 100 -year flood hazard area structures that would impede or redirect flood flows (Impact 3.8-7). The proposed program would not expose structures to a significant risk of loss, including flooding as a result of the failure of a levee or dam (Impact 3.8-8). The proposed program would not place structures in areas subject to inundation by seiche, tsunami, or mudflow (Impact 3.8-9). The proposed program would not result in significant cumulative impact to hydrology and water quality. Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the violation of water quality standards or waste discharge requirements. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the alteration of the existing drainage pattern of a site in a manner that would result in substantial erosion or siltation on- or off-site. In response to comment received on the Draft EIR, Mitigation Measure HYDRO -4 has been added to ensure that Impact 3.8-3 and Impact 3.8-4 remain less than significant. The modification does not identify any new significant impact or trigger the need to recirculate the Draft PEIR under Section 15088.5 of the CEQA Guidelines. HYDRO -4: Prior to approving a structural BMP, the implementing agencies shall conduct an evaluation of the potential hydromodification impacts of the project. The evaluation shall recommend design measures necessary to prevent or minimize any identified impacts, including flooding, erosion and/or scour. Design measures could include velocity dissipaters and bank re -enforcement components. Implementing agencies shall include these measures in project designs. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the alteration of the existing drainage pattern of a site which would increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the creation or contribution to runoff water. LA county Flood control Distinct 9 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to placement of housing within a 100 -year flood hazard area. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to placement of structures within a 100 -year flood hazard area that would impede or redirect flood flows. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to exposure of structures to a significant risk of loss, including flooding as a result of the failure of a levee or dam. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to placement of structures in areas subject to inundation by seiche, tsunami, or mudflow. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program does not have the potential to result in significant cumulative impacts to hydrology and water quality. 4.1.9 Land Use and Agriculture The proposed program would not physically divide an established community (Impact 3.9-1). The proposed program would not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the program (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect (Impact 3.9-2). The proposed program would not conflict with any applicable habitat conservation plan or natural community conservation plan (Impact 3.9-3). The proposed program would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use. The proposed program would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of agricultural land to non-agricultural use or conversion of forestland to non -forest use. (Impact 3.9-4) The proposed program would not conflict with existing zoning for agricultural use, or a Williamson Act contract (Impact 3.9-5). The proposed program would not conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)). The proposed program would not result in the loss of forest land or conversion of forest land to non -forest use (Impact 3.9-6). The proposed program would not result in significant cumulative impact to land use and agriculture. LA county Flood control Distinct 10 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the physical division of an established community. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to confliction with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the program adopted for the purpose of avoiding or mitigating an environmental impact. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to confliction with any applicable habitat conservation plan or natural community conservation plan. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, or conversion of agricultural land to non-agricultural use or conversion of forest land to non -forest use. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to confliction with existing zoning for agricultural use, or a Williamson Act contract. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to confliction with existing zoning for forest land or timberland, or the loss of forest land or conversion of forest land to non -forest use. The Board of Supervisors finds, based on the Final Program FIR, and the whole of the record, that the proposed program does not have the potential to result in significant cumulative impacts to land use and agriculture. 4.1.10 Noise The proposed program would not result in exposure of persons to, or generation of, excessive groundborne vibration (Impact 3.10-2). For a project located within an airport land use plan, or, where such a plan has not been adopted, in an area within 2 miles of a public airport or public use airport, implementation of the proposed program would not expose people residing or working in the area to excessive noise levels (Impact 3.10-5) For a project located in the vicinity of a private airstrip, the proposed program would not expose people residing or working in the project area to excessive noise levels (Impact 3.10-6). LA county Flood control Distinct t t ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to exposure of persons to, or generation of, excessive groundborne vibration. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to projects located within an airport land use plan or within 2 miles of a public airport or public use airport. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to projects located in the vicinity of a private airstrip. 4.1.11 Population and Housing and Environmental Justice Implementation of the proposed program would not induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure) (Impact 3.11-1). Implementation of the proposed program would not displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere (Impact 3.11-2). Implementation of the proposed program would not displace substantial numbers of people, necessitation the construction of replacement housing elsewhere (Impact 3.11-3). Implementation of the proposed program would not affect the health or environment of minority or low income populations disproportionately (Impact 3.11-4). The proposed program would not result in significant cumulative impact to population and housing and environmental justice. Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to introduction of substantial population growth in an area, either directly or indirectly. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to displacement of substantial numbers of existing housing. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to displacement of substantial numbers of people. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the Proposed Program would result in no impact relating to impacting the health or environment of minority or low income populations disproportionately. LA county Flood control Distinct 12 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program does not have the potential to result in significant cumulative impacts to population and housing and environmental justice. 4.1.12 Public Services and Recreation The proposed program would not result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered governmental police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for police protection services (Impact 3.12-2). The proposed program would not result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered schools, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for schools (Impact 3.12-3). The proposed program would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated (Impact 3.12-4). The proposed program would not include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment (Impact 3.12-5). The proposed program would not result in significant cumulative impact to public services and recreation. Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the provision of, or need for, new or physically altered governmental police protection facilities. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the provision of, or need for, new or physically altered schools. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to increased use of existing neighborhood and regional parks or other recreational facilities. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would not result significant cumulative impact to public services and recreation. However, Mitigation Measure PS -1 has been included to ensure that cumulative impacts remain less than significant. LA county Flood control Distinct 13 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact PS -1: The Permittee implementing the EWMP project shall provide reasonable advance notification to service providers such as fire, police, and emergency medical services as well as to local businesses, homeowners, and other residents adjacent to and within areas potentially affected by the proposed EWMP project about the nature, extent, and duration of construction activities. Interim updates should be provided to inform them of the status of the construction activities. 4.1.13 Transportation and Circulation Construction of the proposed program would not potentially cause traffic safety hazards for vehicles, bicyclists, and pedestrians on public roadways, and would not increase traffic hazards due to possible road wear (Impact 3.13-2). The proposed program would not result in inadequate emergency access during construction (Impact 3.13-3). Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to traffic safety hazards for vehicles, bicyclists, and pedestrians on public roadways. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to inadequate emergency access during construction. 4.1.14 Utilities and Service Systems Implementation of the proposed program would not exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board or result in the construction of new treatment facilities or expansion of existing facilities if the wastewater treatment provider has inadequate capacity to serve the proposed program (Impact 3.14-1). The proposed program would not require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which would cause significant environmental effects (Impact 3.14-2). Construction and operation of the proposed program would not require additional energy use that could result in wasteful consumption, affect local and regional energy supplies, or conflict with applicable energy efficiency policies or standards (Impact 3.14-5). Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to exceedance of wastewater treatment requirements of the applicable Regional Water Quality Control Board or result in the construction of new treatment facilities or expansion of existing facilities. LA county Flood control Distinct 14 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to construction of new storm water drainage facilities or expansion of existing facilities. The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in no impact relating to additional energy use. 4.2 Non -Structural (Institutional) BMPs Non-structural control measures are policies, actions, and activities which are intended to minimize or eliminate pollutant sources. Most institutional BMPs are implemented to meet Minimum Control Measure (MCM) requirements in the MS4 permit; MCMs are considered a subset of institutional BMPs. These BMPs are not constructed, but may have costs associated with the procurement and installation of items such as signage or spill response kits. The MS4 Permit categorizes institutional BMPs into six program categories: • Development Construction Programs, which establish standards for stormwater management from construction sites of all sizes (e.g., with or without a stormwater pollution prevention plan [SWPPP]). • IndustriaFCommercial Facilities Programs, which establish standards for pollutant reduction and control measures at industrial and commercial facilities. • Illicit Connection and Illicit Discharges (IC/ID) Detection and Elimination Programs, which describe procedures for identifying, eliminating, and reporting illicit connections and discharges to the stormwater system. • Public Agency Activities Programs, which describe a broad range of municipal practices such as street cleaning, landscape management, storm drain operation, and more. • Planning and Land Development Programs, which encourage the application of smart growth and low -impact development (LID) practices to development and redevelopment projects. • Public Information and Participation Programs, which educate and engage the public on a broad range of pollution- and stormwater-related issues. Permittees can evaluate the MCMs, identify potential modifications that will address water quality priorities, and provide justification for modification or elimination of any MCM that is determined to be ineffective (with the exception of the Planning and Land Development Program, which may not be eliminated or modified). MCM customization may include replacement, reduced implementation, augmented implementation, focused implementation, or elimination. Because the LACFCD has limited jurisdictional authority for ordinance and code enactment or enforcement, it is limited in application of MCMs to activities such as public information and participation programs. LA county Flood control Distinct 15 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Non-structuraVinstitutional BMPs do not include construction of new facilities. Consequently, the Final Program FIR finds no significant environmental impacts associated with this type of BMP, and no mitigation is required for any of the environmental resource areas. Finding The Board of Supervisors finds, based on the Final Program EIR, and the whole of the record, that the proposed program would result in either less than significant impacts or no impacts to all environmental topic areas analyzed in the Final Program FIR relating to implementation of non- structural/institutional BMPs within the program area. 5.0 Less than Significant Environmental Impacts The significant impacts identified in this section are capable of being mitigated to levels of less than significant through the mitigation identified in the Final Program EIR. This mitigation has been adopted by the District. Thus, for projects implemented under the program where the District has jurisdiction over the project, the significant impacts will be mitigated to a level of less than significant. However, the EW -NPs cover numerous jurisdictions and include potential projects that will be entirely within the jurisdiction of a different implementing agency. Because the District cannot ensure that these Implementing Agencies will adopt and implement the proposed mitigation measures, the District finds that the impacts identified in this section may also be significant and unavoidable with respect to projects where the District will not be an implementing agency. The conclusions of "less than significant" below will apply to the extent the Implementing Agencies adopt the proposed mitigation. 5.1 Aesthetics Significant Effect The proposed program could create a substantial adverse effect on a scenic vista (Impact 3.1-1) Description of Specific Impact During construction, equipment and materials required for temporary ground disturbances would be visible from public vantage points, but would not affect any scenic vistas past the temporary construction periods. Given the predominantly urban character of potential pump station sites and temporary nature of construction activities, impacts would be considered less than significant. A majority of structural BMPs would be located underground and would not introduce impacts to scenic vistas. Aboveground structures such as pump stations would be located in urbanized areas and would generally be single -story buildings. Such aboveground structures have the potential to impact scenic vistas, but will be required to be designed so as not to contrast existing neighborhood aesthetic features. LA county Flood control Distinct 16 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Finding Permanent aboveground structures associated with certain BMPs have the potential to create substantial adverse effects on scenic vistas in the project area. The implementation of Mitigation Measure AES -1 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce the impacts caused by the project relating to the creation of a substantial adverse effect on a scenic vista. Implementation of Mitigation Measure AES -1 would reduce the impact to a less -than - significant level by designing aboveground structures in a way that would avoid obstructing scenic vistas or views from public vantage points, and would ensure design consistency with neighboring structures. AES -1: Aboveground structures shall be designed to be consistent with local zoning codes and applicable design guidelines and to minimize features that contrast with neighboring development. Significant Effect The proposed program could substantially damage scenic resources, including but not limited to, trees, rocks, outcroppings, and historic buildings within a state scenic highway (Impact 3.1-2). Description of Specific Impact Parts of the proposed program may be visible from designated scenic highways or other locally designated scenic roadways in the project area. Rock outcroppings and historic buildings would likely not be disturbed by the project as most of the BMPs will be underground and not visible after construction is complete. Construction of the proposed program would involve removal of vegetation from individual project sites. Smaller aboveground structures would not substantially damage scenic resources, and impacts from larger structures would be reduced to a less -than - significant level with implementation of Mitigation Measure AES -1. Finding Permanent aboveground structures associated with certain BMPs have the potential to substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway. The implementation of Mitigation Measure AES -1 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts. Implementation of Mitigation Measure AES -1 would serve to ensure design consistency with neighboring structures in individual project areas, thereby reducing damage to scenic resources within a state scenic highway. AES -1: Aboveground structures shall be designed to be consistent with local zoning codes and applicable design guidelines and to minimize features that contrast with neighboring development. LA county Flood control Distinct 17 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Significant Effect The proposed program could substantially degrade the existing visual character or quality of the site and its surroundings (Impact 3.1-3). Description of Specific Impact Construction activities would visually degrade the project site and its surroundings as a result of the appearance of demolition materials, excavated areas, stockpiles, and other materials. Due to the temporary nature of construction, these adverse effects are considered less than significant. Once constructed, the BMPs would be located predominantly in urban areas and largely underground, which will not have a permanent effect on the visual character or quality of an area. Aboveground structures may degrade existing visual character of project areas as they will add to the visual landscape. Without proper maintenance of BMPs, especially wet ponds or constructed wetlands, there is a potential for substantial degradation of existing visual quality of project sites due to algal growth or public littering. Finding Operation of the proposed program has the potential to result in impacts related to substantial degradation of existing visual character or quality of the site and its surroundings. The implementation of Mitigation Measures AES -1 and AES -2 would reduce impacts to a less -than - significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce the impacts caused by the project relating to the substantial degradation of existing visual character or quality of the site and its surroundings. Implementation of Mitigation Measures AES -1 and AES - 2 would reduce the impact to a less -than -significant level. AES -1: Aboveground structures shall be designed to be consistent with local zoning codes and applicable design guidelines and to minimize features that contrast with neighboring development. AES -2: Implementing agencies shall develop BMP maintenance plans that are approved concurrently with each structural BMP approval. The maintenance plans must include measures to ensure functionality of the structural BMPs for the life of the BMP. These plans may include general maintenance guidelines that apply to a number of smaller distributed BMPs. Significant Effect The proposed program would result in a less than significant cumulative aesthetic impact with mitigation. Description of Significant Impact Cumulative projects in the program region have the potential to result in cumulative impacts to aesthetic resources if they would result in the removal or substantial adverse change of visual LA county Flood control Distinct 18 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact character or image of a neighborhood, community, state scenic highway, or localized area. Given that the BMPs will be located in primarily urbanized areas, introduction of structural BMPs would result in only minor changes to the visual landscape. The cumulative impacts of aboveground structures could have a significant impact to the aesthetic environment due to their potential size and location. Finding The proposed program's cumulative aesthetic impact is considered cumulatively significant, but would be reduced to less -than -significant with mitigation. Overall, implementation of BMPs is anticipated to have a positive impact on the aesthetic environment through the creation of open space areas and less impervious surfaces in urbanized or residential areas. After implementation of Mitigation Measures AES -1 and AES -2, cumulative impacts associated with aesthetics would be considered less -than -significant. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce the impacts caused by the project that results in a cumulative aesthetic impact. With the implementation of Mitigation Measures AES -1 and AES -2, implementation of the proposed projects would result in less -than -significant cumulative aesthetics impacts. 5.2 Air Quality Significant Effect The proposed program could expose sensitive receptors to substantial pollutant concentrations (Impact 3.2-4). Description of Significant Impact While construction -related traffic on local roadways would occur during construction, the net increase of construction vehicle trips to the existing traffic volumes on local roadways would be relatively small and would not result in carbon monoxide (CO) hotspots. These construction - related trips would only occur in the short-term, and because trip -generating land uses are not associated with the proposed program, impacts associated with CO hotspots would be less than significant. Off-road heavy-duty diesel equipment would be used only temporarily at each individual structural BMP site, therefore the construction activities associated with each structural BMP project in the EWMP areas would not expose sensitive receptors to substantial emissions of TACs. During construction of the individual structural BMPs in the project area, sensitive receptors such as residences, schools, hospitals, and daycare centers would be exposed to significant adverse localized air quality impacts. Operation of structural BMPs would not involve the emission of toxic air contaminants (TAC), and would operate passively without use of mechanical equipment. Project operation would not introduce health risks associated with TAC emissions. Construction activities could expose sensitive receptors to criteria air pollutants from vehicle exhaust and dust. Depending on the size and scope of the individual structural BMPs, a localized significance threshold (LST) analysis may be required to ensure construction emissions LA county Flood control Distinct 19 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact would not exceed SCAQMD's LSTs or result in pollutant emissions that would cause or contribute to the exceedance of the most stringent applicable federal or state ambient air quality standards. Finding The proposed program has the potential to expose sensitive receptors to substantial criteria air pollutant concentrations. However, implementation of Mitigation Measure AIR -3 would reduce this impact to a less -than -significant level. Brief Explanation of the Rationale for Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts to the exposure of sensitive receptors to substantial pollutant concentrations. Implementation of Mitigation Measure AIR -3 would reduce this impact to a less -than -significant level. AIR -3: For large construction efforts associated with regional or centralized BMPs, implementing agencies shall conduct a project -specific LST analysis where necessary to determine local health impacts to neighboring land uses. Where it is determined that construction emissions would exceed the applicable LSTs or the most stringent applicable federal or state ambient air quality standards, the structural BMP project shall reduce its daily construction intensity (e.g., reducing the amount of equipment used daily, reducing the amount of soil graded/excavated daily) to a level where the structural BMP project's construction emissions would no longer exceed SCAQMD's LSTs or result in pollutant emissions that would cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standards. Significant Effect The proposed program could create objectionable odors affecting a substantial number of people (Impact 3.2-5). Description of Significant Impact The proposed program does not include any uses typically associated with odor complaints including agricultural uses, wastewater treatment plants, food processing plans, and landfills, among others. During the construction phase, exhaust odors from equipment may produce discernible odors typical of most construction sites and would be a temporary source of nuisance to adjacent uses. These odors would be temporary and intermittent in nature, so would not be considered a significant environmental impact. Certain BMPs such as restored creeks and estuaries may result in odors from saturated mud or algal blooms when left permanently wet. This may result in a severe nuisance for sensitive receptors near such BMPs, and regular maintenance may be sufficient to reduce odors in some situations. Finding The proposed program has the potential to create objectionable odors affecting a substantial number of people. However, implementation of Mitigation Measures AES -2 and AIR -4 would reduce impacts to a less -than -significant levels. LA county Flood control Distinct 20 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Brief Explanation of the Rationale for Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce the potential creation of objectionable odors affecting substantial numbers of people. Implementation of Mitigation Measures AES -2 and AIR -4 would reduce this impact to a less -than -significant level. AES -2: Implementing agencies shall develop BMP maintenance plans that are approved concurrently with each structural BMP approval. The maintenance plans must include measures to ensure functionality of the structural BMPs for the life of the BMP. These plans may include general maintenance guidelines that apply to a number of smaller distributed BMPs. AIR -4: During planning of structural BMPs, implementing agencies shall assess the potential for nuisance odors to affect a substantial number of people. BMPs that minimize odors shall be considered the priority when in close proximity to sensitive receptors. 5.3 Biological Resources Significant Effect The proposed program would have a substantial adverse impact, either directly or through habitat modifications, on species identified as special -status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service (Impact 3.3-1). Description of Significant Impact Construction of structural BMPs may affect large open space or riparian habitats that would have a higher potential to support special -status wildlife species, such as streams, wetlands, and upland scrub or oak woodlands. Mitigation Measures 13I0-1 through BIO -8 require suitability studies for potential BMP sites for their potential to impact valued habitats, and require impact characterization, minimization and compensation for impacts to highly valued habitats in consultation with the USFWS and CDFW. The proposed program will implement BMPs that are designed to retain dry -weather flows, which could reduce wetted area or completely eliminate flows in certain drainages that support sensitive species. Implementation of Mitigation Measures BIO -1 through BIO -8 would help ensure that impacts to downstream biological resources are less than significant for regional and centralized BNM. The smaller distributed BMPs would not result in significant impacts and would not be required to implement the mitigation measures. Finding The proposed program would have a substantial adverse impact, either directly or through habitat modifications, on species identified as special -status species in local or regional plans, policies, or regulations, or by California Department of Fish and Wildlife or the U.S. Fish and Wildlife LA county Flood control Distinct 21 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Service. These impacts would be reduced to a less -than -significant level with the implementation of the mitigation measures described below. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would have a substantial adverse impact, either directly or through habitat modifications, on any sensitive species identified as special -status in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service. In consideration of the potential use of the project site by special -status wildlife species, impacts on special -status wildlife species would be significant. Implementation of Mitigation Measures 13I0-1 through 13I0-8 would reduce impacts to a less -than -significant level. 13I0-1: Prior to approving a regional or centralized BMP, the Permittee shall conduct an evaluation of the suitability of the BMP location. Appropriate BMP sites should avoid impacting large areas of native habitats including upland woodlands and riparian forests that support sensitive species to the extent feasible. The evaluation shall include an assessment of potential downstream impacts resulting from flow diversions. 13I0-2: Prior to ground -disturbing activities in areas that could support sensitive biological resources, a habitat assessment shall be conducted by a qualified biologist to determine the potential for special -status wildlife species to occur within affected areas, including areas directly or indirectly impacted by construction or operation of the BMPs. 13I0-3: If a special -status wildlife species is determined to be present or potentially present within the limits of construction activities, a qualified biologist shall conduct preconstruction surveys of proposed work zones and within an appropriately sized buffer around each area as determined by a qualified biologist within 14 days prior to ground disturbing activities. Any potential habitat capable of supporting a special -status wildlife species shall be flagged for avoidance if feasible. 13I0-4: If avoidance of special -status species or sensitive habitats that could support special -status species (including, but not limited to, critical habitat, riparian habitat, and jurisdictional wetlands/waters) is not feasible, the Permittee shall consult with the appropriate regulating agency (USACE/USFWS or CDFW) to determine a strategy for compliance with the Endangered Species Act, California Fish and Game Code, and other regulations protecting special -status species and sensitive habitats. The Permittee shall identify appropriate impact minimization measures and compensation for permanent impacts to sensitive habitats and species in consultation with regulatory agencies. Construction of the project will not begin until the appropriate permits from the regulatory agencies are approved. 13I0-5: If construction and vegetation removal is proposed between February 1 and August 31, a qualified biologist shall conduct a pre -construction survey for breeding and nesting birds and raptors within 500 -feet of the construction limits to determine and map LA county Flood control Distinct 22 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact the location and extent of breeding birds that could be affected by the project. Active nest sites located during the pre -construction surveys shall be avoided until the adults and young are no longer reliant on the nest site for survival as determined by a qualified biologist 13I0-6: All construction areas, staging areas, and right-of-ways shall be staked, flagged, fenced, or otherwise clearly delineated to restrict the limits of construction to the minimum necessary near areas that may support special -status wildlife species as determined by a qualified biologist. 13I0-7: Prior to construction in areas that could support special -status plants, a qualified botanist shall conduct a pre -construction floristic inventory and focused rare plant survey of project areas to determine and map the location and extent of special -status plant species populations within disturbance areas. This survey shall occur during the typical blooming periods of special -status plants with the potential to occur. The plant survey shall follow the CDFW Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (November 24, 2009). 13I0-8: If temporary construction -related impacts to special -status plant populations are identified within a disturbance area, the implementing agencies shall prepare and implement a special -status species salvage and replanting plan. The salvage and replanting plan shall include measures to salvage, replant, and monitor the disturbance area until native vegetation is re-established under the direction of CDFW and USFWS. Significant Effect The proposed program would have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the CDFW orUSFWS. (Impact 3.3-2) Description of Significant Impact Significant Ecological Areas (SEA), as identified by the Los Angeles County General Plan, riparian, and other sensitive communities are not expected to occur within the disturbance areas of the BMP projects since the majority of the structural BMPs would occur in developed or disturbed areas. While some regional and centralized structural BMPs could occur within or adjacent to SEAs, riparian habitat or other sensitive natural communities, these types of BMPs would provide multi -beneficial water quality and habitat restoration improvements to the applicable EWMP watershed. Additionally, each development proposed within a designated SEA must undergo a performance review process for compliance with the SEA design compatibility criteria and other standards for approval by the LA County Department of Regional Planning. Finding Future project -level environmental review processes would consider all proposed projects on a case-by-case basis to determine whether an individual project would impact riparian or other sensitive natural communities. Site-specific mitigation measures would be required to minimize LA county Flood control Distinct 23 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact and reduce potentially significant impacts to riparian and other sensitive natural communities. These impacts would be reduced to a less -than -significant level with the implementation of Mitigation Measures BIO -1 through 13I0-8. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the CDFW or USFWS. Implementation of Mitigation Measure 13I0-1 through 13I0-8 would reduce impacts to a less -than -significant level. Significant Effect The proposed program would have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. (Impact 3.3-3) Description of Significant Impact Wetlands occur throughout the EWMP areas, and once project facility locations are determined, exact locations and acreages of jurisdictional areas located within or adjacent to impact areas shall be determined through a formal jurisdictional delineation. For projects impacting native vegetation within jurisdictional drainages, the implementing agency would be required to obtain California Fish and Game Code Section 1602 compliance and Section 404 compliance from the USACE and Section 401 Certification from the RWQCB. In addition, implementation of Mitigation Measures 13I0-1 through 13I0-9 would ensure compliance with state and federal regulations relating to potentially jurisdictional features, including wash habitat vegetation that may fall under CDFW jurisdiction. Finding Any projects impacting native vegetation within jurisdictional drainages would be required to comply with California Fish and Game Code Section 1602 compliance and Section 404 compliance from the USACE and Section 401 Certification from the RWQCB. These impacts would be further reduced to a less -than -significant level with the implementation of the mitigation measures described below. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act through direct removal, filling, hydrological interruption, or other means. Implementation of Mitigation Measures 13I0-1 through 13I0-9 would reduce impacts to a less -than -significant level. 13I0-9: Prior to construction, a qualified wetland delineator shall be retained to conduct formal wetland delineation in areas where potential jurisdictional resources (i.e., wetlands or drainages) subject to the jurisdiction of USACE, RWQCB, and CDFW may be LA county Flood control Distinct 24 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact affected by the project. If jurisdictional resources are identified in the EWMP area and would be directly or indirectly impacted by individual projects, the qualified wetland delineator shall prepare a jurisdictional delineation report suitable for submittal to USACE, RWQCB, and CDFW for purposes of obtaining the appropriate permits. Habitat mitigation and compensation requirements shall be implemented prior to construction in accordance with Mitigation Measure BIO -4. Significant Effect The proposed program would conflict with local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. (Impact 3.3-5) Description of Significant Impact The proposed program would mainly be constructed within highly urbanized and disturbed areas within existing infrastructure. Any impacts to oak trees within Los Angeles County would be required to comply with the Oak Tree Preservation Ordinance (or other tree ordinances established by the local city). A tree permit may be required if impacts to oak trees or other protected trees are determined to be necessary. Finding No impacts to oak trees or other protected tree species is anticipated. However, the exact locations of the BMP projects have not been established. Implementation of Mitigation Measure BIO -10 would reduce any potential impacts to protected tree species to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. Implementation of Mitigation Measure BIO -10 would reduce impacts to a less -than -significant level. BIO -10: Oak trees and other protected trees shall be avoided to the extent feasible. If trees may be impacted by project construction, a certified arborist shall conduct a tree inventory of the construction impact area. If any oak trees or other protected trees will be impacted by BMP construction, the implementing agency shall obtain any required County or City permits. Significant Effect The proposed program would result in cumulative biological resource impacts Description of Significant Impact Cumulatively, throughout the region, the retention of stormwater and treatment of pollutants within each watershed, and the reduction of pollutant loading in waterways would substantially benefit the water quality of the region's aquatic and coastal habitats, as well as the plants and wildlife dependent on them. Implementation of the BMPs would also return the local hydrology LA county Flood control Distinct 25 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact to a more natural condition. Although some drainage segments may exhibit reduced riparian habitat or wetlands over time due to the reduced dry -weather flow, the cumulative effect would be offset by increased groundwater recharge and seepage supporting expanded wetland and riparian vegetation supporting local flora and fauna populations. Therefore, the program's potential contribution to cumulative effects on biological resources is considered less than significant. Finding Most of the distributed BMPs would be small in scale and would not result in cumulatively significant impacts, as they would occur within existing developed or disturbed areas at existing stormwater infrastructure/facilities. For regional and centralized BMPs at the larger scale, Mitigation Measures BIO -1 through BIO -10 would reduce potentially significant impacts to biological resources, and any additional or more site-specific mitigation measures developed during the future project -level environmental review processes may further reduce potential impacts. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts to biological resources. Any potentially significant cumulative impacts to biological resources in the project region would be reduced by the implementation of Mitigation Measures BIO -1 through BIO -10. 5.4 Cultural Resources Significant Effect The proposed program could cause a substantial adverse change in the significance of unique archaeological resources as defined in §15064.5 (Impact 3.4-2). Description of Significant Impact The program area, which spans most of Los Angeles County, should be considered sensitive for archaeological resources, with degree of sensitivity varying across the program area based on specific environmental factors. Any structural BMP which involves grading, trenching, excavation, vegetation removal, or other forms of ground disturbance could impact archaeological resources. Finding The proposed program's potential to cause a substantial adverse change in the significance of unique archaeological resources is considered significant; however, potential adverse effects caused by the proposed program could be mitigated to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would cause a substantial adverse change in the significance of unique LA county Flood control Distinct 26 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact archaeological resources. The project impacts are considered significant but would be reduced to a level that is less than significant with implementation of Mitigation Measures CUL -2 through CUL -2. CUL -2: Implementing agencies shall ensure that individual EWMP projects that require ground disturbance shall be subject to a Phase I cultural resources inventory on a project - specific basis prior to the implementing agency's approval of project plans. The study shall be conducted or supervised by a qualified archaeologist, defined as an archaeologist meeting the Secretary of the Interior's Professional Qualifications Standards for Archaeology, and shall be conducted in consultation with the local Native American representatives expressing interest. The cultural resources inventory shall include a cultural resources records search to be conducted at the South Central Coastal Information Center; scoping with the NAHC and with interested Native Americans identified by the NAHC; a pedestrian archaeological survey where deemed appropriate by the qualified archaeologist; and formal recordation of all identified archaeological resources on California Department of Parks and Recreation 523 forms and significance evaluation of such resources presented in a technical report following the guidelines in Archaeological Resource Management Reports (ARMR): Recommended Contents and Format, Department of Parks and Recreation, Office of Historic Preservation, State of California, 1990. If potentially significant archaeological resources are encountered during the survey, the implementing agency shall require that the resources are evaluated by the qualified archaeologist for their eligibility for listing in the CRHR and for significance as a historical resource or unique archaeological resource per CEQA Guidelines Section 15064.5. Recommendations shall be made for treatment of these resources if found to be significant, in consultation with the implementing agency and the appropriate Native American groups for prehistoric resources. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred manner of mitigation to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project reroute or redesign, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, which may include data recovery or other appropriate measures, in consultation with the implementing agency, and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. CUL -3: The implementing agency shall retain archaeological monitors during ground - disturbing activities that have the potential to impact archaeological resources qualifying as historical resources or unique archaeological resources, as determined by a qualified archaeologist in consultation with the implementing agency, and any local Native LA county Flood control Distinct 27 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact American representatives expressing interest in the project. Native American monitors shall be retained for projects that have a high potential to impact sensitive Native American resources, as determined by the implementing agency in coordination with the qualified archaeologist. CUL -4: During project -level construction, should subsurface archaeological resources be discovered, all activity in the vicinity of the find shall stop and a qualified archaeologist shall be contacted to assess the significance of the find according to CEQA Guidelines Section 15064.5. If any find is determined to be significant, the archaeologist shall determine, in consultation with the implementing agency and any local Native American groups expressing interest, appropriate avoidance measures or other appropriate mitigation. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred means to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project reroute or redesign, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, such as data recovery or other appropriate measures, in consultation with the implementing agency and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. Significant Effect The proposed program could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature (Impact 3.4-3). Description of Significant Impact The program area is underlain by a number of high or undetermined paleontological sensitivity units, which may contain significant paleontological resources. Significant paleontological resources can be uncovered even in areas of low sensitivity, though, and it is possible that ground -disturbing construction activities associated with structural BMPs could result in the inadvertent discovery of paleontological resources, which could be a significant impact. Finding The proposed program's potential to directly or indirectly damage or destroy unique paleontological resources or sites or unique geologic features is considered significant; however, potential adverse effects caused by the proposed program could be mitigated to a less -than - significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would damage or destroy paleontological resources or sites or unique geologic LA county Flood control Distinct 28 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact features. The project impacts are considered significant but would be reduced to a level that is less than significant with implementation Mitigation Measures CUL -5 and CUL -6. CUL -5: For individual structural BMP projects that require ground disturbance, the implementing agency shall evaluate the sensitivity of the project site for paleontological resources. If deemed necessary, the implementing agency shall retain a qualified paleontologist to evaluate the project and provide recommendations regarding additional work, potentially including testing or construction monitoring. CUL -6: In the event that paleontological resources are discovered during construction, the implementing agency shall notify a qualified paleontologist. The paleontologist will evaluate the potential resource, assess the significance of the fmd, and recommend further actions to protect the resource. Significant Effect The proposed program could disturb human remains, including those interred outside of formal cemeteries (Impact 3.4-4). Description of Significant Impact There is no indication, either from the archival research results or the archaeological survey, that any particular location in the project area has been used for human burial purposes in the recent or distant past. However, in the event that human remains are inadvertently discovered during project construction activities, the human remains could be inadvertently damaged, which could be a significant impact Finding The proposed program's potential to uncover buried archaeological deposits including human remains is considered significant; however, potential adverse effects caused by the project could be mitigated to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to the disturbing of any human remains, including those interred outside of a formal cemetery. The project impacts are considered significant but would be reduced to a level that is less than significant with implementation of Mitigation Measure CUL -7. CUL -7: The implementing agency shall require that, if human remains are uncovered during project construction, work in the vicinity of the find shall cease and the County Coroner shall be contacted to evaluate the remains, following the procedures and protocols set forth in Section 15064.5 (e)(1) of the CEQA Guidelines. If the County Coroner determines that the remains are Native American, the Coroner will contact the Native American Heritage Commission, in accordance with Health and Safety Code Section 7050.5, subdivision (c), and Public Resources Code 5097.98 (as amended by AB 2641). The NAHC will then designate a Most Likely Descendant of the deceased LA county Flood control Distinct 29 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Native American, who will engage in consultation to determine the disposition of the remains. 5.5 Geologic and Mineral Resources Significant Effect The proposed program could be located on a geological unit or soil that is unstable, or that would become unstable as a result of the program, and potentially result in on-site or off-site non - seismically induced geologic hazards such as landslides, lateral spreading, subsidence, collapse or sinkholes, settlement, or slope failure (Impact 3.5-3). Description of Significant Impact Infiltration of water into subsurface soils can increase soil instability and result in saturated soils, soil piping through preferential pathways, breakouts due to infiltrated water finding utility trenches and other preferential pathways, and raising the local groundwater levels such that infrastructure foundations and underground structures could be affected by unstable soils. Structural BMPs could potentially be undermined by unstable soils or impact adjacent infrastructure and buildings; Mitigation Measure GEO-1 would reduce the impact to a less -than - significant level. Finding The proposed program's potential to be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the program, and potentially result in on-site or off-site non - seismically induced geologic hazards such as landslides, lateral spreading, subsidence, collapse or sinkholes, settlement, or slope failure is considered significant; however, potential adverse effects caused by the proposed program would be mitigated to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to the project being located on a geologic unit or soil that is unstable, or that would become unstable as a result of the program, and potentially result in on-site or off-site non - seismically induced geologic hazards such as landslides, lateral spreading, subsidence, collapse or sinkholes, settlement, or slope failure. The project impacts are considered significant but would be reduced to a level that is less than significant with implementation of Mitigation Measure GEO-1. GEO-1: Prior to approval of infiltration BMPs, implementing agencies shall conduct a geotechnical investigation of each infiltration BMP site to evaluate infiltration suitability. If infiltration rates are sufficient to accommodate an infiltration BMP, the geotechnical investigation shall recommend design measures necessary to prevent excessive lateral spreading that could destabilize neighboring structures. Implementing agencies shall implement these measures in project designs. LA county Flood control Distinct 30 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Significant Effect Cumulative impacts on geology and soils would have a less than significant impact on the environment with implementation of mitigation. Description of Significant Impact The cumulative effect of multiple infiltration projects could increase the severity of perched or migrating water, which has the potential to inundate underground utilities or structures. Mitigation Measure GEO-1 would minimize the cumulative impact to regional infrastructure from perched or migrating water. The management of groundwater pumping among regional managers prevents impacts to structural foundations resulting from groundwater mounding from existing recharge efforts. Mitigation Measure GEO-2 would reduce the cumulative effects to soil stability from elevated groundwater levels to a less -than -significant level. Finding The proposed program's cumulative impact to geology and soils is considered significant; however, potential adverse effects caused by the proposed program would be mitigated to a less - than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce cumulative impacts related to geology and soils. significant but would be reduced to a level that Mitigation Measures GEO-1 and GEO-2. The cumulative project impacts are considered is less than significant with implementation of GEO-1: Prior to approval of infiltration BMPs, implementing agencies shall conduct a geotechnical investigation of each infiltration BMP site to evaluate infiltration suitability. If infiltration rates are sufficient to accommodate an infiltration BMP, the geotechnical investigation shall recommend design measures necessary to prevent excessive lateral spreading that could destabilize neighboring structures. Implementing agencies shall implement these measures in project designs. GEO-2: Prior to installing BMPs designed to recharge the local groundwater supplies, the implementing agency shall notify local groundwater managers, including the Upper Los Angeles River Area Water Master, the Water Replenishment District of Southern California, or the San Gabriel Water Master as well as local water producers such as local municipalities and water companies. The implementing agency shall coordinate BMP siting efforts with groundwater managers and producers to mitigate high groundwater levels while increasing local water supplies. 5.6 Greenhouse Gas Emissions The proposed program would not have any environmental effects related to greenhouse gas emissions that are potentially significant but can be mitigated to less -than -significant levels. LA county Flood control Distinct 31 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact 4*AMT.To Wlr♦iFFFTsrsM LT1FMMP Significant Effect The proposed program would create a significant hazard to the public or the environment through the accumulation of potentially hazardous materials into BMPs (Impact 3.7-2). Description of Significant Impact Because of their function as water conveyance systems, the entire storm sewer system, as augmented by structural BMPs, would collect and retain sediment and chemicals from urban runoff, along with any accidental or illicit spills of hazardous materials. The introduction of hazardous materials into the storm sewer system could occur in large events as in a catastrophic spill, or could occur in small concentrations as in petroleum hydrocarbons and heavy metals picked up and carried by stormwater in urban runoff from the streets. Contaminants in the runoff water or as discrete concentrated spills could accumulate in the soils and vegetation of structural BMPs. To address the accumulation of contaminants in soil at BMPs, operations and maintenance plans for BMPs that might accumulate constituents in surface soils and media will be developed to include periodic removal and replacement of these potentially impacted surface materials to reduce the potential for long-term loading leading to hazardous concentrations in soils and groundwater. Finding The proposed program has the potential to create a significant hazard to the public or the environment through the accumulation of potentially hazardous materials into BMPs. The implementation of Mitigation Measure HAZ-1 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to the creation of a significant hazard to the public or the environment through the accumulation of potentially hazardous materials into BMPs to less -than -significant. With the implementation of Mitigation Measure HAZ-1, these impacts would be considered less than significant. HAZ-1: Implementing agencies shall prepare and implement maintenance practices that include periodic removal and replacement of surface soils and media that may accumulate constituents that could result in further migration of constituents to sub -soils and groundwater. A BMP Maintenance Plan shall be prepared by Implementing Agencies upon approval of the BMP projects that identifies the frequency and procedures for removal and/or replacement of accumulated debris, surface soils and/or media (to depth where constituent concentrations do not represent a hazardous conditions and/or have the potential to migrate further and impact groundwater) to avoid accumulation of hazardous concentrations and the potential to migrate further to sub -soils and groundwater. The Maintenance Plan shall include vector control requirements. The BMP Maintenance Plan LA county Flood control Distinct 32 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact may consist of a general maintenance guideline that applies to several types of smaller distributed BMPs. For smaller distributed BMPs on private property, these plans may consist of a maintenance covenant that includes requirements to avoid the accumulation of hazardous concentrations in these BMPs that may impact underlying sub -soils and groundwater. Structural BMPs shall be designed to prevent migration of constituents that may impact groundwater. Significant Effect The proposed program would be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, could create a significant hazard to the public or the enviromnent (Impact 3.7-4). Description of Significant Impact It is possible that a proposed BMP may be located on a hazardous materials site listed on the Cortese List, which would expose construction workers, the public, and the environment to hazardous materials during earth -moving activities, introducing a significant impact. Finding The proposed program has the potential to result in significant impacts related to the project location on a site which is included on a list of hazardous materials sites, and, as a result, could create a significant hazard to the public or the environment. The implementation of Mitigation Measure HAZ-2 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to hazardous materials to less -than -significant With the implementation of Mitigation Measures HAZ-2, these impacts would be considered less than significant HAZ-2: Prior to the initiation of any construction requiring ground -disturbing activities in areas where hazardous material use or management may have occurred, the implementing agencies shall complete a Phase I Environmental Site Assessment (ESA) in accordance with American Society for Testing and Materials Standard E1527-13 for each construction site. Any recommended follow up sampling (Phase 11 activities) set forth in the Phase I ESA shall be implemented prior to construction. The results of Phase II studies, if necessary, shall be submitted to the local overseeing agency and any required remediation or further delineation of identified contamination shall be completed prior to commencement of construction. Significant Effect For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, for a project within the vicinity of a private airstrip, the proposed program could result in a safety hazard for people residing or working in the project area (Impact 3.7-5). LA county Flood control Distinct 33 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Description of Significant Impact Some structural BMPs, such as detention basins that store water for a period of time or constructed wetlands that would increase or improve wildlife habitat, could be constructed on or near airports and could result in attracting wildlife. Deer and birds are known wildlife hazards to airports. If the proposed project is at or near an airport, this could increase hazards to aircraft from wildlife. Finding The proposed program, if located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, for a project within the vicinity of a private airstrip, has the potential to result in safety hazard for people residing or working in the project area. The implementation of Mitigation Measures HAZ-3 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to hazardous materials to less -than -significant With the implementation of Mitigation Measures HAZ-3, these impacts would be considered less than significant HAZ-3: Implementing Agencies shall require that those BMPs that are within an airport land use plan area are compatible with criteria specified in FAA Advisory Circular No: 150/5200-33B (FAA, 2007). If the proposed BMP is within the minimum separation criteria, the implementing agency shall consult with the airport and collaboratively evaluate whether the potential increase in wildlife hazards can be mitigated. Significant Effect The proposed program would result in cumulatively significant impacts to hazardous materials Description of Significant Impact Most of the distributed BMPs would be small in scale and would not result in cumulatively significant impacts due to increased hazards from construction or operation. However, the combination of BMPs throughout the region would change the flow paths of stormwater and urban runoff that currently occurs in the region, resulting in the retention of pollutants generally within the soil of the BMPs that use soil for filtration and retention. Cumulatively, throughout the region, the retention and treatment of pollutants within each watershed and the reduction of pollutant loading in waterways will substantially benefit water and sediment quality of the region's habitats, rivers, and beaches. Therefore, the project's potential contribution to cumulative effects on hazards and hazardous materials is considered beneficial. Finding The proposed program has the potential to result in cumulatively considerable impacts related to hazardous resources. Hazardous material could be released during project construction or operation. The implementation of appropriate safety measures during construction of the proposed project, as well as any other cumulative project, would reduce the impact to a level that LA county Flood control Distinct 34 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact would not contribute to cumulative effects. Implementation of Mitigation Measures HAZ-1, HAZ-2, and HAZ-3 would reduce impacts to less -than -significant levels. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce cumulative impacts caused by the project. With the implementation of Mitigation Measures HAZ-1, HAZ-2, and HAZ-3, impacts would be less than significant. 5.8 Hydrology and Water Quality Significant Effect The proposed program would result in higher groundwater levels and could potentially affect groundwater quality (Impact 3.8-2). Description of Significant Impact Regional BMPs would recharge stormwater into the groundwater basin and could raise local groundwater levels following major storm events. Distributed infiltration BMPs would typically be too small to have a measureable effect on local groundwater levels. The increased water supplies captured by the infiltration basins through the EWMP areas would be a beneficial impact of the projects. Infiltration BMPs would not be suitable in areas of low permeability, though, and potential locations would need to be evaluated for suitability. Concentrations of contaminants found in stormwater runoff could increase, resulting in contaminated shallow soils and groundwater. Finding The proposed program has the potential to result significant impacts related to higher groundwater levels and degradation of groundwater quality. The implementation of Mitigation Measures HYDRO -1 through HYDRO -3 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to higher groundwater levels and potential degradation of groundwater quality to less -than -significant. With the implementation of Mitigation Measures HYDRO -1 through HYDRO -3, these impacts would be considered less than significant. HYDRO -1: Prior to approving an infiltration BMP, the Permittee shall conduct an evaluation of the suitability of the BMP location. Appropriate infiltration BMP sites should avoid areas with low permeability where recharge could adversely affect neighboring subsurface infrastructure. HYDRO -2: Prior to approving an infiltration BMP, the Permittee shall identify pretreatment technologies, type, and depth of filtration media; depth to groundwater; and other design considerations necessary to prevent contaminants from impacting groundwater quality. The design shall consider stormwater quality data within the BMP's LA county Flood control Distinct 35 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact collection area to assess the need and type of treatment and filtration controls. Local design manuals and ordinances requiring minimum separation distance to groundwater shall also be met as part of the design. HYDRO -3: Prior to the installation of an infiltration BMP, the Permittee shall conduct a regulatory database review for contaminated groundwater sites within a quarter mile of the proposed infiltration facility. The review shall include locations of on-site wastewater treatment systems. The Permittee shall identify whether any contaminated groundwater plumes or leach fields are present and whether coordination with the local and state environmental protection overseeing agency and responsible party is warranted prior to final design of infiltration facility. 5.9 Land Use and Agriculture The proposed program would not have any environmental effects on land use that are potentially significant and that cannot be mitigated to less -than -significant levels. 5.10 Noise Significant Effect The proposed program would result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project (Impact 3.10-3). Description of Significant Impact No operational noise levels would be generated by the structural BMPs given their passive manner of operation. However, it is anticipated that some of the centralized and regional structural BMPs would require the use of irrigation pump stations and associated components to divert the collected stormwater. At these structural BMP sites, noise levels generated from the long-term operation of the pumps and associated components could result in increased noise levels in the surrounding noise environment. Finding The proposed program has the potential to result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project. The implementation of Mitigation Measures NOISE -1 and NOISE -2 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project. With the implementation of Mitigation Measures NOISE -1 and NOISE -2 included below, these impacts would be considered less than significant. LA county Flood control Distinct 36 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact NOISE -1: The implementing agencies shall implement the following measures during construction as needed: • Include design measures necessary to reduce the construction noise levels to where feasible. These measures may include noise barriers, curtains, or shields. • Place noise -generating construction activities (e.g., operation of compressors and generators, cement mixing, general truck idling) as far as possible from the nearest noise -sensitive land uses. • Locate stationary construction noise sources as far from adjacent noise -sensitive receptors as possible. • If construction is to occur near a school, the construction contractor shall coordinate the with school administration in order to limit disturbance to the campus. Efforts to limit construction activities to non -school days shall be encouraged. • For the centralized and regional BMP projects located adjacent to noise -sensitive land uses, identify a liaison for these off-site sensitive receptors, such as residents and property owners, to contact with concerns regarding construction noise and vibration. The liaison's telephone number(s) shall be prominently displayed at construction locations. • For the centralized and regional BMP projects located adjacent to noise -sensitive land uses, notify in writing all landowners and occupants of properties adjacent to the construction area of the anticipated construction schedule at least 2 weeks prior to groundbreaking. NOISE -2: All structural BMWs that employ mechanized stationary equipment that generate noise levels shall comply with the applicable noise standards established by the implementing agency with jurisdiction over the structural BMP site. The equipment shall be designed with noise -attenuating features (e.g., enclosures) and/or located at areas (e.g., belowground) where nearby noise -sensitive land uses would not be exposed to a perceptible noise increase in their noise environment. 5.11 Population and Housing and Environmental Justice The proposed program would not have any environmental effects related to population, housing and environmental justice that would be potentially significant, but could be mitigated to less than significant levels. LA county Flood control Distinct 37 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact 5.12 Public Services and Recreation Significant Effect The proposed program would not result in substantial adverse physical impacts associated with the provision of, or need for, new or physically altered governmental fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for fire protective services (Impact 3.12-1). Description of Significant Impact The structural BMPs are not habitable structures, would not be constructed with flammable materials, and would not require fire protection services. Because of the relative scale of these infrastructure improvements, the construction of the various structural BMPs are not expected to result in the need for new or physically altered fire protection facilities. However, construction of new structural BMPs in streets, sidewalks, parkland, or other facilities (these may include public service facilities such as police stations, fire stations, and municipal maintenance yards) within existing high-density urban, commercial, industrial, and transportation areas, as well as associated staging areas, could temporarily disrupt the provision of fire services, resulting in potentially significant impacts. Finding The proposed program has the potential to result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered governmental fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for fire protection services. Implementation of Mitigation Measure PS -1 would reduce impacts to a less -than -significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project related to significant cumulative impacts associated with public services. With the implementation of Mitigation Measure PS -1, these impacts would be considered less than significant. PS -1: The Permittee implementing the EWMP project shall provide reasonable advance notification to service providers such as fire, police, and emergency medical services as well as to local businesses, homeowners, and other residents adjacent to and within areas potentially affected by the proposed EWMP project about the nature, extent, and duration of construction activities. Interim updates should be provided to inform them of the status of the construction activities. LA county Flood control Distinct 38 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact 5.13 Transportation and Circulation Significant Effect The proposed program would intermittently and temporarily increase traffic levels and traffic delays due to vehicle trips generated by construction workers and construction vehicles on area roadways (Impact 3.13-1). Description of Significant Impact Vehicle trips would be generated primarily by construction workers commuting to and from the BMP work sites, and by trucks hauling materials and equipment to and from the sites. The construction traffic impacts associated with each individual structural BMP project would be short-term in nature and limited to the period of time when construction activity is taking place for that particular project Although project -related traffic would be temporary, supplemental project -level analysis of potential site-specific impacts could determine that addition of project - generated traffic would be considered substantial in relation to traffic flow conditions on local roadways. For this program -level assessment, this impact is considered potentially significant. Finding The proposed program will potentially intermittently and temporarily increase traffic levels and traffic delays due to vehicle trips generated by construction workers and construction vehicles on area roadways; however, implementation of Mitigation Measure TRAF-1 would reduce impacts to a less -than- significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to temporary and intermittent increase in traffic levels and traffic delays due to vehicle trips generated by construction workers and construction vehicles on area roadways to less -than -significant. With the implementation of Mitigation Measure TRAF-1, below, this impact would be considered less than significant. TRAF-1: For projects that may affect traffic, implementing agencies shall require that contractors prepare a construction traffic control plan. Elements of the plan should include, but are not necessarily limited to, the following: • Develop circulation and detour plans to minimize impacts to local street circulation. Use haul routes minimizing truck traffic on local roadways to the extent possible. • To the extent feasible, and as needed to avoid adverse impacts on traffic flow, schedule truck trips outside of peak morning and evening commute hours. • Install traffic control devices as specified in Caltrans' Manual of Traffic Controls for Construction and Maintenance Work Zones where needed to maintain safe driving conditions. Use flaggers and/or signage to safely direct traffic through construction work zones. LA county Flood control Distinct 39 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact • Coordinate with facility owners or administrators of sensitive land uses such as police and fire stations, hospitals, and schools. Provide advance notification to the facility owner or operator of the timing, location, and duration of construction activities. Significant Effect The proposed program would contribute to cumulative impacts to traffic and transportation (Impact 3.13-4). Description of Significant Impact During construction of the structural BMPs, intermittent and temporary traffic -related impacts in the cumulative context would occur. The proposed program has the potential to contribute to potentially significant cumulative construction -related impacts as a result of (1) cumulative projects (such as land development projects) that generate increased traffic at the same time on the same roads as would the proposed program, causing increased congestion and delays; and (2) infrastructure projects in roads that would be used by project construction workers and trucks, which could delay project -generated vehicles past the work zones of those other projects. Finding The proposed program is expected to cumulatively impact traffic and transportation; however, implementation of Mitigation Measure TRAF-1 is expected to reduce impacts to a less -than - significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to cumulative impacts to traffic and transportation to less than significant. With the implementation of Mitigation Measure TRAF-1, these impacts would be considered less than significant. 5.14 Utilities and Service Systems Significant Effect The proposed program would require new or expanded water supply resources or entitlements or require or result in the construction of new water facilities or expansion of existing facilities, the construction of which could cause significant environmental effects (Impact 3.14-3). Description of Significant Impact Implementation of the EWMPS would not increase water demand due to the relatively short construction period for structural BMPs. Impacts to the existing water supplies are anticipated to be beneficial as a result of the stormwater and non-stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. Construction requiring ground disturbance could encounter buried utilities including water supply infrastructure. Construction of BMPs to detain stormwater and dry -weather flows may reduce flows downstream, thereby LA county Flood control Distinct 40 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact reducing access to beneficial uses downstream. As part of the project design, Implementing Agencies would be required to identify the potential for underground utilities and determine whether they would need to be relocated to accommodate the BMP. Dry -weather flows in coastal streams and foothills are largely fed by groundwater seepage or wastewater discharges. Any detention of storm flows upstream would not substantially reduce storm flows downstream or significantly impede access to storm flow. Finding The proposed program is not expected to require expansion of existing water entitlements or result in the construction of new facilities that could result in environmental effects; the proposed program would further reduce its impact by implementing Mitigation Measure UTIL-1. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to landfill capacity to less than significant. With the implementation of Mitigation Measure UTIL-1, these impacts would be considered less than significant. UTIL-1: Prior to implementation of BMPs, the implementing agency shall conduct a search for local utilities above and below ground that could be affected by the project. The implementing agencies shall contact each utility potentially affected and relocate the utility if necessary to ensure access and services are maintained. UTIL-2: Prior to approval of BMPs, implementing agencies shall evaluate the potential for impacts to downstream beneficial uses including surface water rights. Implementing agencies shall not approve BMPs that result in preventing access to previously appropriated surface water downstream. Significant Effect The proposed program would be served by a landfill with insufficient permitted capacity to accommodate the proposed program's solid waste disposal needs or the proposed program could not comply with federal, state, and local statuses and regulations related to solid waste (Impact 3.14-4). Description of Significant Impact Construction activities associated with the structural BMPs would include excavation and demolition of some existing infrastructure, which would produce solid waste requiring disposal in the nearest landfill. Some of the EWMPs are required to implement trash Total Maximum Daily Limits (TMDLs) and associated trash removal structural BMPs, which would require the disposal of the trash collected by the BMPs, thereby increase the amount of trash being sent to landfills. The non-structural BMPs would include street cleaning, landscape management, and storm drain operation, which produce debris and trash requiring disposal, which could exceed landfill limits. The new trash collected that is associated with proposed trash removal structural BMPs and non- structural BMPs such as street cleaning and landscape management would be accommodated with existing and planned trash disposal facilities. Based on landfill capacity in the Los Angeles LA county Flood control Distinct 41 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact region, there appears to be ample availability to receive the expected trash generated by the program. The program would comply with all federal, state, and local statutes and regulations related to solid waste, including the Los Angeles County Construction and Demolition Debris Recycling and Reuse Program. Finding The program is not expected to be served by a landfill with insufficient capacity to accommodate its waste disposal needs and would comply with all solid waste regulations; however, implementation of Mitigation Measure UTIL-2 would further reduce impacts to a less -than - significant level Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to landfill capacity to less than significant. With the implementation of Mitigation Measure UTIL-2, these impacts would be considered less than significant. UTIL-3: Implementing agencies shall encourage construction contractors to recycle construction materials and divert inert solids (asphalt, brick, concrete, dirt, fines, rock, sand, soil, and stone) from disposal in a landfill where feasible. Implementing agencies shall incentivize construction contractors with waste minimization goals in bid specifications where feasible. Significant Effect The proposed program would result in less than significant cumulative impacts to utilities and service systems. Description of Significant Impact Structural BMPS constructed to treat, infiltrate, and/or store stormwater and non-stormwater throughout the watershed would not generate wastewater or require wastewater treatment or result in adverse cumulative impacts from operation or construction. Installation of storm drainage facilities identified in the proposed EWMPs would not substantially affect existing storm drain facilities. Impacts to the existing water supplies are anticipated to be beneficial as a result of the stormwater and non-stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. Construction and operation of the structural BMPs would generate solid waste; however, landfills serving the program area are expected to have sufficient capacity to accommodate the amount of waste generated. Disposal of the solid waste generated during construction and operation would comply with all pertinent regulations and statutes. All other projects implemented in the area would also be required to comply with federal, state, and local solid waste regulations and statutes. The use of energy anticipated for the proposed program is minor when compared to the County -wide use of electricity. The proposed program would use energy-efficient equipment and would not result in wasteful consumption. The non-structural BMPs would include street cleaning, landscape management, and storm drain operation, which would produce debris and trash for disposal. LA county Flood control Distinct 42 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Finding The proposed program would not likely result in cumulative impacts to utilities and service systems. The proposed program would further reduce its cumulative impact on utilities and service systems to a less -than -significant -level by implementing Mitigation Measures UTIL-1 and UTIL-2. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce cumulative impacts related to utilities and service systems. With the implementation of Mitigation Measure UTIL-1 and UTIL-2, these impacts would be considered less than significant. 6.0 Significant and Unavoidable Environmental Impacts As described above in Section 5.0, the impacts identified above as being less than significant with the implementation of mitigation measures could be significant and unavoidable if the proposed mitigation measures are not adopted and implemented by the Implementing Agencies for projects within their jurisdiction. Because the District cannot ensure that these Implementing Agencies will adopt and implement the proposed mitigation measures, the District finds that the impacts identified in section 5.0 may also be significant and unavoidable with respect to projects where the District will not be an implementing agency. The impacts discussed below were identified in the Final Program EIR as being "significant and unavoidable" for the program because they cannot be mitigated to a less -than -significant level. 6.1 Aesthetics The proposed program would not have any environmental effects on aesthetics that cannot be mitigated to a less -than -significant level. 6.2 Air Quality Significant Effect The proposed program could violate air quality standards or contribute substantially to an existing or projected air quality violation (Impact 3.2-2). Description of Significant Impact Construction activities at the individual project sites would temporarily create emissions of dust, fumes, equipment exhaust, and other air contaminants. Through representative "worst-case" construction scenarios of each structural BMP type, ranging from small-, medium-, and large- scale projects, the magnitude of the daily emissions that can be generated by each structural BMP type is presented. The maximum daily construction emissions for the three structural BMP project types were estimated using the California Emissions Estimator Model (CalEEMod). The LA county Flood control Distinct 43 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact construction -related emissions of criteria air pollutants for the three structural BMP types were modeled based on general information provided in the project description and CalEEMod default settings along with reasonable assumptions based on other similar types of projects. The model found that for smaller BMPs including distributed BMPs, air emissions would not be significant and would not require mitigation measures. For some of the larger regional and centralized BMPs, the model shows that the maximum daily level of construction -generated emissions of NOx would exceed the applicable SCAQMD-recommended thresholds under the worst-case construction scenarios. Implementation of Mitigation Measures AIR -1 and AIR -2 would reduce emissions, but they may not reduce these emissions to levels below the SCAQMD thresholds for every structural BMP project, as the amount of emissions generated, the land area that would need disturbing, and the length of the construction schedule for each structural BMP project would vary. Implementation of large regional or centralized BMPs could result in temporary significant and unavoidable air emissions during peak periods of construction. Long term operation of the proposed program would not result in substantial emissions of criteria air pollutants. There would be no new land use projects which would generate daily vehicle emissions. Inspection and maintenance activities would occur to the project site, but would be periodic throughout the year and would result in minimal emissions. Equipment for pump stations and ancillary components would be electrically powered, so would not generate emissions at the project site. Finding The proposed program would implement projects that could exceed identified emissions thresholds, and therefore have the potential to violate any air quality standard or substantially contribute to an existing or projected air quality violation. Implementation of Mitigation Measures AIR -1 and AIR -2 would help reduce this impact, but construction emissions would remain significant and unavoidable for some larger projects. Impacts from operational emissions would be considered less -than -significant. Brief Explanation of the Rationale for Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to the violation of any air quality standard or substantial contribution to an existing or projected air quality violation. Implementation of Mitigation Measures AIR -1 and AIR -2 would help reduce the impact, but impacts from construction emissions would remain significant and unavoidable for some of the larger projects. Impacts from operational emissions would be less than significant. AIR -1: Implementing agencies shall require for large regional or centralized BMPs the use of low -emission equipment meeting Tier II emissions standards at a minimum and Tier III and IV emissions standards where available as CARB-required emissions technologies become readily available to contractors in the region. AIR -2: For large construction efforts that may result in significant air emissions, implementing agencies shall encourage contractors to use lower -emission equipment through the bidding process where appropriate. LA county Flood control Distinct 44 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Significant Effect The proposed program could result in a cumulatively considerable net increase of any criteria pollutant for which the program region is non -attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors) (Impact 3.2-3). The proposed program could result in a significant cumulative impact to air quality. Description of Significant Impact As the Basin is currently in nonattainment for ozone, PMI,, and PM2.,, cumulative development consisting of the proposed program along with other reasonably foreseeable future projects in the Basin as a whole could violate an air quality standard or contribute to an existing or projected air quality violation. Under conditions where multiple structural BMPs would be constructed concurrently in the EWMP areas, it is anticipated that the total aggregate construction emissions generated from these multiple structural BMP projects on a daily basis would exceed the SCAQMD's significance thresholds for criteria pollutants. Even with implementation of Mitigation Measures AIR -1 and AIR -2, the resulting aggregate daily emissions may not be reduced to levels below the SCAQMD thresholds should multiple structural BMP projects be constructed concurrently. Thus, construction -related air quality impacts associated with the proposed program would be considered significant and unavoidable. With respect to operational emissions, program implementation would not result in substantial long-term regional emissions of criteria air pollutants and would not exceed the SCAQMD thresholds of significance for criteria pollutants. As such, the proposed program's operational emissions would not be cumulatively considerable and cumulative air quality impacts would be less than significant. Finding As air pollutants for which the Basin is in nonattainment (i.e., ozone, PMI,, and PM2.,) would be emitted as a result of the proposed program in excess of SCAQMD's thresholds for construction activities, these pollutant emissions would, in conjunction with other past, current, and probable future projects, be cumulatively considerable, and cumulative impacts would be significant and unavoidable. Implementation of Mitigation Measures AIR -1 and AIR -2 would reduce cumulative air quality impacts, but not to a level that is less than significant. With respect to operational emissions, program implementation would not result in substantial long-term regional emissions of criteria air pollutants and would not exceed the SCAQMD thresholds of significance for criteria pollutants. As such, the proposed program's operational emissions would not be cumulatively considerable and cumulative air quality impacts would be less than significant. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts. Even after the implementation of Mitigation Measures AIR -1 and AIR -2, impacts related to cumulatively considerable net increase of any criteria pollutant for which the project region is nonattairment under an applicable federal or state ambient air quality standard remain significant and unavoidable for construction. Program implementation would not result in substantial long - LA county Flood control Distinct 45 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact term regional emissions of criteria pollutants with respect to operational emissions, therefore operational emissions would be less than significant. AIR -1: Implementing agencies shall require for large regional or centralized BMPs the use of low -emission equipment meeting Tier II emissions standards at a minimum and Tier III and IV emissions standards where available as CARB-required emissions technologies become readily available to contractors in the region. AIR -2: For large construction efforts that may result in significant air emissions, implementing agencies shall encourage contractors to use lower -emission equipment through the bidding process where appropriate. 6.3 Biological Resources The proposed program would not have any environmental effects on biological resources that cannot be mitigated to a less -than -significant level. 6.4 Cultural Resources Significant Effect The proposed program would cause a substantial adverse change in the significance of an historical resource as defined in §15064.5. (Impact 3.4-1) Description of Significant Impact Implementation of structural BMPs could impact significant historic built environment resources that exist within the program area, which may include not only buildings and structures, but also built infrastructure such as concrete channels, dams, sidewalks, and roads. Impacts to the could include not only physical demolition or alteration of built environment resources, but also changes to the historic setting of a resource, and impacts that may adversely affect that ability of a resource to convey its significance. Similarly, potentially significant buried archaeological resources could still exist within the program area, beneath and between structures and roads. If previously undiscovered artifacts or buried archaeological resources are uncovered during excavation or construction, significant impacts could occur. Not all EWNIP projects may result in a significant and unavoidable impact with regard to historical resources, as impacts associated with each project would be dependent on location; presence, nature, and significance of any historical resources within the construction area; and specific impacts to historical resources. In some circumstances, no mitigation is sufficient to maintain the historic integrity of the affected archaeological and other cultural resource or its surroundings, therefore implementation of the proposed program may ultimately result in a substantial adverse change. Finding The proposed program's potential to cause a substantial adverse change in the significance of an historical resource is considered significant. Potential adverse effects caused by the proposed LA county Flood control Distinct 46 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact program could be minimized by mitigation measures; however the impact would remain significant and unavoidable. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts that would cause a substantial adverse change in the significance of an historical resource. The project impacts are considered significant and unavoidable; implementation of Mitigation Measures CUL -1 through CUL -4 would help minimize impacts. CUL -1: For individual EWMP projects that could impact buildings or structures (including infrastructure) 45 years old or older, implementing agencies shall ensure that a historic built environment survey is conducted or supervised by a qualified historian or architectural historian meeting the Secretary of the Interior's Professional Qualification Standards for Architectural History. Historic built environment resources shall be evaluated for their eligibility for listing in the CRHR or local register prior to the implementing agency's approval of project plans. If eligible resources that would be considered historical resources under CEQA are identified, demolition or substantial alteration of such resources shall be avoided. If avoidance is determined to be infeasible, the implementing agency shall require the preparation of a treatment plan to include, but not be limited to, photo -documentation and public interpretation of the resource. The plan will be submitted to the implementing agency for review and approval prior to implementation. CUL -2: Implementing agencies shall ensure that individual EWMP projects that require ground disturbance shall be subject to a Phase I cultural resources inventory on a project - specific basis prior to the implementing agency's approval of project plans. The study shall be conducted or supervised by a qualified archaeologist, defined as an archaeologist meeting the Secretary of the Interior's Professional Qualifications Standards for Archaeology, and shall be conducted in consultation with the local Native American representatives expressing interest. The cultural resources inventory shall include a cultural resources records search to be conducted at the South Central Coastal Information Center; scoping with the NAHC and with interested Native Americans identified by the NAHC; a pedestrian archaeological survey where deemed appropriate by the qualified archaeologist; and formal recordation of all identified archaeological resources on California Department of Parks and Recreation 523 forms and significance evaluation of such resources presented in a technical report following the guidelines in Archaeological Resource Management Reports (ARMR): Recommended Contents and Format, Department of Parks and Recreation, Office of Historic Preservation, State of California, 1990. If potentially significant archaeological resources are encountered during the survey, the implementing agency shall require that the resources are evaluated by the qualified archaeologist for their eligibility for listing in the CRHR and for significance as a historical resource or unique archaeological resource per CEQA Guidelines Section 15064.5. Recommendations shall be made for treatment of these resources if found to be LA county Flood control Distinct 47 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact significant, in consultation with the implementing agency and the appropriate Native American groups for prehistoric resources. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred manner of mitigation to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project reroute or redesign, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, which may include data recovery or other appropriate measures, in consultation with the implementing agency, and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. CUL -3: The implementing agency shall retain archaeological monitors during ground - disturbing activities that have the potential to impact archaeological resources qualifying as historical resources or unique archaeological resources, as determined by a qualified archaeologist in consultation with the implementing agency, and any local Native American representatives expressing interest in the project. Native American monitors shall be retained for projects that have a high potential to impact sensitive Native American resources, as determined by the implementing agency in coordination with the qualified archaeologist. CUL -4: During project -level construction, should subsurface archaeological resources be discovered, all activity in the vicinity of the find shall stop and a qualified archaeologist shall be contacted to assess the significance of the find according to CEQA Guidelines Section 15064.5. If any find is determined to be significant, the archaeologist shall determine, in consultation with the implementing agency and any local Native American groups expressing interest, appropriate avoidance measures or other appropriate mitigation. Per CEQA Guidelines Section 15126.4(b)(3), preservation in place shall be the preferred means to avoid impacts to archaeological resources qualifying as historical resources. Methods of avoidance may include, but shall not be limited to, project reroute or redesign, project cancellation, or identification of protection measures such as capping or fencing. Consistent with CEQA Guidelines Section 15126.4(b)(3)(C), if it is demonstrated that resources cannot be avoided, the qualified archaeologist shall develop additional treatment measures, such as data recovery or other appropriate measures, in consultation with the implementing agency and any local Native American representatives expressing interest in prehistoric or tribal resources. If an archaeological site does not qualify as an historical resource but meets the criteria for a unique archaeological resource as defined in Section 21083.2, then the site shall be treated in accordance with the provisions of Section 21083.2. Significant Effect The proposed program would result in cumulatively significant impacts to cultural resources. LA county Flood control Distinct 48 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Description of Significant Impact Cumulative impacts to cultural resources in the cultural resources geographic scope of analysis could occur if other existing or proposed projects, in conjunction with the proposed program, had or would have impacts on cultural resources that, when considered together, would be significant. With implementation of Mitigation Measures CUL -2, CUL -3 and CUL -4, cumulatively significant environmental impacts to unique archaeological resources would be reduced to a less than significant level. With implementation of Mitigation Measures CUL -5 and CUL -6, cumulative impacts to paleontological resources would be less than significant. Further, implementation of CUL -7 would reduce potentially significant impacts to human remains should they be encountered during ground -disturbing activities to a less -than -significant level. Implementation of the proposed program may ultimately result in a substantial adverse change to historical resources through various development activities for which no possible mitigation may be available to maintain the historic integrity of the affected resource or its surroundings, and impacts to historical resources would remain significant and unavoidable at a program level. Therefore, the implementation of structural BMFs may contribute to a cumulatively significant environmental impact to historical resources. Finding The proposed program has the potential to result in cumulatively considerable impacts related to cultural resources, specifically in regard to substantial adverse changes in the significance of historical resources resulting from excavation activities associated with projects in the cumulative impacts scenario. The implementation of Mitigation Measures CUL -1 through CUL -7 would reduce impacts relating to unique archaeological resources, paleontological resources, and human remains to a less -than -significant level, however, these mitigation measures would not reduce impacts to historical resources below a significant level. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce cumulative impacts caused by the project. With the implementation of Mitigation Measures CUL - 1 through CUL -7, these cumulative cultural resource impacts would be reduced, but still considered significant and unavoidable. 6.5 Geologic and Mineral Resources The proposed program would not have any environmental effects related to geology and soils that cannot be mitigated to a less -than -significant level. 6.6 Greenhouse Gas Emissions The proposed program would not have any environmental effects related to greenhouse gas emissions that cannot be mitigated to a less -than -significant level. LA county Flood control Distinct 49 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact 6.7 Hazards and Hazardous Materials The proposed program would not have any environmental effects related to hazards and hazardous materials that cannot be mitigated to a less -than -significant level. 6.8 Hydrology and Water Quality The proposed program would not have any environmental effects on hydrology and water quality that cannot be mitigated to a less -than -significant level. 6.9 Land Use and Agriculture The proposed program would not have any environmental effects on land use and planning that cannot be mitigated to a less -than -significant level. 6.10 Noise Significant Effect The proposed program would result in exposure of persons to, or generation of, noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies (Impact 3.10-1). Description of Significant Impact The proposed program would result in a temporary increase in noise levels during construction at the project sites. Noise generated during temporary construction is anticipated, and because of the possibility that certain structural BMP projects may exceed noise levels established by their respective local jurisdictions, this impact would be significant and unavoidable. Finding The proposed program has the potential to result in exposure of persons to, or generation of, noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. Implementation of Mitigation Measures NOISE -1 and NOISE -2 would reduce the proposed program's construction -related noise levels by requiring the project contractor to locate equipment such that noise is directed away from sensitive receptors and to maintain noise controls on standard construction equipment. In addition, the mitigation measures would require a construction noise coordinator to resolve complaints about noise. However, even with the project's adherence to all applicable noise requirements and guidelines in addition to implementation of Mitigation Measures NOISE -1 and NOISE -2, it is anticipated that there would be times during the project's construction activities where the nearest sensitive receptors would be exposed to a perceptible increase in noise levels. Therefore, the project would result in perceptible increases in noise levels during construction and this impact would be considered significant and unavoidable. LA county Flood control Distinct 50 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to exposure of persons to, or generation of, noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. Even with the implementation of Mitigation Measures NOISE -1 and NOISE -2, these impacts would still be considered significant and unavoidable. Significant Effect The proposed program would result in a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project (Impact 3.10-4). Description of Significant Impact During construction of the distributed, centralized, and regional structural BMPs, temporary or periodic increases in noise levels in and around each structural BMP site would result from the operation of construction equipment. Where a structural BMP site is located within 25 feet of an existing noise -sensitive land use, the resulting construction noise levels at that existing land use could reach as high as 95 dBA Leq during excavation activities, which would result in a substantial noise increase over existing ambient noise levels at that existing land use. Therefore this impact would be significant and unavoidable. The identification of a significant and unavoidable program -level impact in this Program EIR for the proposed program, however, does not preclude the finding of future less -than -significant impacts for individual structural BMP projects. Finding The proposed program has the potential to result in a substantial temporary or periodic increase in ambient noise levels above levels existing without the project in the vicinity of individual projects. Implementation of Mitigation Measure NOISE -1 would reduce the project's construction -related noise levels by requiring the project contractor to locate equipment such that noise is directed away from sensitive receptors and to maintain noise controls on standard construction equipment. In addition, the mitigation measures would require a construction noise coordinator to resolve complaints about noise. However, even with the project's adherence to all applicable noise requirements and guidelines in addition to implementation of the mitigation measure, it is anticipated that there would be times during the project's construction activities where the nearest sensitive receptors would be exposed to a perceptible change in noise levels. Therefore, the proposed program would result in perceptible increases in noise levels during construction and this impact would be considered significant and unavoidable. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to a substantial temporary or periodic increase in ambient noise levels. With the implementation of Mitigation Measure NOISE -1 included, impacts would still be significant and unavoidable during construction. LA county Flood control Distinct 51 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact Significant Effect The proposed program would result in significant cumulative construction noise impacts. Description of Significant Impact Noise and vibration are both defined as localized phenomena that significantly reduce in magnitude as distance from the source increases. The structural BMPs associated with the proposed program would be constructed in multiple jurisdictions of Los Angeles County, which aside from the County also includes 46 cities and LACFCD. As such, these structural BMP projects would be generally spread over a large geographic area within the County. These structural BMPs in combination with other current and planned projects in the County would result in an increase in construction -related noise levels, which would temporarily increase the ambient noise levels of the existing noise environment in areas where a construction project would occur. This would result in significant and unavoidable impacts for construction. Finding The proposed program has the potential to result in the exposure of persons to noise levels in excess of applicable standards. Even with implementation of Mitigation Measures NOISE -1 and NOISE -2, impacts would still be significant and unavoidable during construction. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation be applied to the project to reduce impacts related to inappropriate noise levels. Even with implementation of Mitigation Measures NOISE -1 and NOISE -2, impacts would still be significant and unavoidable during construction. 6.11 Population and Housing and Environmental Justice The proposed program would not have any environmental effects on population, housing and environmental justice that cannot be mitigated to a less -than -significant level. 6.12 Public Services and Recreation The proposed program would not have any environmental effects on public services and recreation that cannot be mitigated to a less -than -significant level. 6.13 Transportation and Circulation The proposed program would not have any environmental effects on transportation and traffic that cannot be mitigated to a less -than -significant level. 6.14 Utilities and Service Systems The proposed program would not have any environmental effects on utilities that cannot be mitigated to a less -than -significant level. LA county Flood control Distinct 52 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact 7.0 Findings Regarding Project Alternatives The following findings and brief explanation of the rationale for the findings regarding program alternatives identified in the EIR are set forth to comply with the requirements of Section 15091(s)(3) of the CEQA Guidelines. The consideration of alternatives is an integral component of the CEQA process. The selection and evaluation of a reasonable range of alternatives provides the public and decision -makers with information on ways to avoid or lessen environmental impacts created by a proposed program. When selecting alternatives for evaluation, CEQA requires alternatives that meet most of the basic objectives of the project, while avoiding or substantially lessening the program's significant effects. Thus, objectives for the proposed program were considered by this board in evaluating the alternatives. These objectives are: • To collaborate among agencies (Permittee jurisdictions) across the watershed to promote more cost-effective and multi -beneficial water quality improvement projects to comply with the MS4 Permit; • To develop watershed -wide EWMPs that will, once implemented, remove or reduce pollutants from dry- and wet -weather urban runoff in a cost-effective manner; and • To reduce the impact of stormwater and non-stormwater on receiving water quality. 7.1 No Program Alternative Under this alternative, the existing land uses on the project site would continue to operate as they do under existing conditions. The existing land uses would continue for an indefinite period and no physical changes within the proposed program area would occur. In addition, existing ancillary structures, such as buildings, roadways and parkways within the project area, would remain in their current capacity. The No Project Alternative would maintain the current zoning and land use designations Finding This alternative would not meet the first and second objectives to collaborate among agencies across the watershed to prepare EWMPs that promote more cost-effective and multi -beneficial water quality improvement projects. However, compliance with the MS4 Permit is still required regardless of implementation of the EWMP. Under the No Project Alternative some water quality projects would be implemented in an effort to achieve compliance with the MS4 permit. This alternative would result in slightly greater impacts to air quality with regards to emissions generated, because the programs would need to be installed rapidly and more BMPs would likely be required as a result of the inefficiencies of multiple boundaries. Hydrology and water quality impacts would also be greater, as an installation grace period would not be granted for BMPs outside of the EWMP, increasing the likelihood of noncompliance with the MS4 Permit. All other impacts would be similar under this alternative when compared with the proposed program. This LA county Flood control Distinct 53 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact alternative would not eliminate significant and unavoidable impacts when associated with the proposed project. 7.2 Non -Structural BMPs Only Project Alternative This alternative would involve implementation of the proposed program and its associated non- structural BMPs only. No structural BMPs would be implemented. Finding This alternative would not meet any of the objectives of the proposed program to collaborate among agencies to promote more cost-effective and multi -beneficial water quality improvement projects and to prepare EWMPs to reduce pollutant loading. Non -Structural BMPs are generally implemented individually in each jurisdiction. Since no facilities would be constructed, temporary impacts to the environment would be less than the proposed program for many topic areas. However, impacts to population and housing, land use, and recreation would be greater than the proposed program. This alternative would result in greater impacts to aesthetics, as it would not include green -streets and grassy swales that would improve local aesthetics. Impacts to hydrology and water quality would also be greater under this alternative, as achieving water quality objectives with no structural BMPs would be unlikely. 7.3 Distributed Structural and Non -Structural BMPs Only Program Alternative (No Centralized or Regional) This alternative would involve implementation of the proposed program and only its associated distributed structural BMPs and non-structural BMPs. Finding This alternative would achieve the first and third project objectives to collaborate among agencies to promote more cost-effective and multi -beneficial water quality improvement projects that reduce the impact of stormwater on receiving water quality. However, it would likely require more BMPs to meet the MS4 Permit water quality objectives, as distributed structural BMPs tend to be smaller in nature and are located in a wide distribution throughout the watershed. Therefore, it would not meet the second project objective (developing EWNIPS that will remove or reduce pollutants from urban runoff and removal of stormwater and non-stormwater impacts on receiving water quality). Since much of the impacts of program implementation would occur during construction of the large-scale regional and centralized BMPs, this alternative would result in fewer construction impacts than the proposed project and fewer impacts to aesthetics. However, the alternative would result in greater impacts to land use planning/agriculture, as eliminating the use of large open space areas for BMPs would require a more dispersed land use acquisition for small scale BMPs, thereby increasing potential land use compatibility impacts. This alternative would LA county Flood control Distinct 54 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact eliminate the water quality benefit and more likely potential to comply with the MS4 Permit provided by large-scale regional BMPs, and would therefore result in greater hydrology and water quality impacts. All other impacts under this alternative would be similar to the proposed program. 7.4 Environmentally Superior Alternative The purpose of the alternatives analysis is to consider a reasonable range of alternatives that could feasibly attain most of the basic project objectives and avoid or substantially lessen significant program impacts. The CEQA Guidelines require the identification of an environmentally superior alternative of a project other than or the "no projects' alternative (CEQA Guidelines Section 15126.6 (e)(2)). An environmentally superior alternative is an alternative to the project that would reduce and/or eliminate the significant environmental impacts associated with the project without creating other significant impacts and without substantially reducing and/or eliminating the environmental benefits attributable to the project. Finding The Environmentally Superior Alternative would be the proposed program itself. The proposed program would avoid increasing the impacts to hydrology and water quality that would occur under all three of the alternatives. The No Program Alternative would require that individual Permittees design and construct BMPs locally to achieve MS4 Permit compliance. None of the significant and unavoidable impacts of the proposed alternative would be avoided by this alternative. Furthermore, since the ability to achieve compliance with MS4 Permit water quality objectives would be reduced if each Permittee were on their own, impacts to hydrology and water quality would be greater under this alternative. The Distributed Structural BMPs Only Alternative would result in construction of an increased number of distributed BMPs This alternative would result in fewer impacts to air quality, cultural resources and noise, and would therefore reduce the significant and unavoidable impacts associated with the proposed program. However, since the ability to achieve compliance with MS4 Permit water quality objectives would be reduced without the larger -scale centralized and regional BMPs, impacts to hydrology and water quality would be greater under this alternative. The Non -Structural BMPs Only Alternative would avoid all of the significant and unavoidable impacts associated with construction of the structural BMPs. In addition, nearly all of the impacts associated with the proposed alternative would be avoided, including impacts from infiltration to neighboring subsurface structures, mobilization of contaminants, and site-specific impacts to cultural and biological resources. However, since the ability to achieve compliance with MS4 Permit water quality objectives would be substantially reduced, impacts to water quality would be greater under this alternative, and compliance with the MS4 Permit would be unlikely. Even though this alternative would avoid significant and unavoidable impacts of construction and LA county Flood control Distinct 55 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact Findings of Fact operation of structural BMWs, the failure to meet water quality objectives and achieve MS4 Permit compliance would outweigh the avoidance of the other impacts. Since the proposed alternative would provide the best chance of achieving regional water quality objectives, it is considered the environmentally superior alternative. LA county Flood control Distinct 56 ESA / 140474 Enhanced Watershed Management Programs Carl 2015 Findings of Fact r 1 Exhibit B STATEMENT OF OVERRIDING CONSIDERATIONS State CEQA Guidelines Section 15093 For Enhanced Watershed Management Programs Final Program Environmental Impact Report (SCH# 2014081106) Lead Agency: Los Angeles County Flood Control District The California Environmental Quality Act (CEQA) requires a public agency to balance the benefits of a proposed project against its significant unavoidable adverse impacts in determining to approve the project. The Enhanced Watershed Management Programs (EWMP) would result in some environmental effects that, although mitigated to the extent feasible by the implementation of mitigation measures proposed for the program, would remain significant and unavoidable adverse impacts, as discussed in the final program environmental impact report (PEIR) and CEQA findings of fact. These impacts are summarized below and constitute those impacts for which this statement of overriding considerations is made. Air Quality 1) Impact 3.2-2 (The project would violate air quality standards or contribute substantially to an existing or projected air quality violation). Construction of large regional or centralized BMPs associated with the proposed program could result in temporary significant and unavoidable air emissions during peak periods of construction. The exceedance of applicable SCAQMD- recommended air quality thresholds would be generated primarily during the grading phase of proposed projects, when emissions associated with off-road construction equipment and on -road soil hauling activities would occur. Mitigation measures are incorporated to reduce the severity of the emissions during construction by requiring the use of low -emission equipment which meets Tier II emissions standards at a minimum. However, because there are no feasible mitigation measures that can be implemented to prevent violation of air quality standards during construction, impacts to air quality would remain significant and unavoidable despite implementation of Mitigation Measures AIR -1 and AIR -2. 2) Impact 3.2-3 (The project could result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)). The proposed project would result in a cumulatively considerable net increase of criteria pollutants for which the project region is nonattainment. The Los Angeles Basin is currently in nonattainment for ozone, PMH and PM2.5, which indicates that combined LA County Flood Control District 1 ESA / 140474 Enhanced Watershed Management Programs April 2015 statement orOverriding Considerations Prelinrinun•—Suhjecr to Revision with other reasonably foreseeable future projects in the Basin, the proposed program could violate an air quality standard. Even with implementation of mitigation measures, the resulting aggregate daily emissions may not be reduced to levels below the SCAQMD thresholds should multiple structural BMP projects be constructed concurrently throughout the Basin. As pollutants for which the Basin is in nonattainment (i.e., ozone, PM10, and PM2.5) could exceed SCAQMD's respective thresholds for construction, these pollutant emissions would be cumulatively considerable, and impacts would be significant and unavoidable despite implementation of Mitigation Measures AIR -1 and AIR -2. Operational emissions for the program would not exceed air quality standards therefore would not be cumulatively considerable; cumulative air quality impacts would be less than significant after implementation of structural BMPs. Cultural Resources 3) Impact 3.4-1 (The project would cause a substantial adverse change in the significance of an historical resource as defined in � 15064.5.). The proposed project would result in significant and unavoidable impacts to historical resources in the project area. Historical resources can include not only buildings and structures, but also any object, site area, place, record, or manuscript which a lead agency determines to be historically significant, or which is listed in or determined eligible for listing in the CRHR. Known archaeological resources, as well as unknown and unrecorded archaeological resources that may be unearthed during construction activities associated with implementation of structural BMPs, could be impacted by individual projects. As program implementation actions move forward, individual projects would undergo additional CEQA review prior to construction to assess impacts to specific cultural resources not addressed in this program -level EIR. Mitigation measures will be implemented to lessen impacts to historical resources through historic built environment surveys, cultural resources inventories, archaeological monitoring, and assessment of findings if applicable during ground -disturbing operations. However, because the degree of impact and the applicability, feasibility, and success of these measures cannot be accurately predicted for each specific project at this time, the program level impact related to archaeological and cultural resources that qualify as historical resources is considered significant and unavoidable. With implementation of Mitigation Measures CUL -I through CUL4, impacts would remain significant and unavoidable. 4) Cumulative Impact, Cultural Resources (The project would result in cumulative impacts to cultural resources). Development of the proposed project together with simultaneous development of nearby, reasonably foreseeable planned projects in the area would result in significant cumulative cultural resources impacts. The program could cause impacts on cultural and paleontological resources during the construction period or as a result of operation and maintenance or closure and decommissioning activities. Cumulative impacts to cultural resources in the cultural resources geographic scope of analysis could occur if other existing or proposed projects, in conjunction with the proposed program, had or would have impacts on cultural resources that, when considered together, would be significant. While implementation of mitigation measures would reduce impacts to historical resources, the proposed program may ultimately result in a substantial adverse change to historical resources through development activities for which no possible mitigation may be available to maintain historic integrity of an affected resource or its surroundings. Therefore, despite implementation of Mitigation Measures CUL -1 through CUL -7, the program would have cumulatively significant and unavoidable environmental impact to historical resources. LA County Flood Control District 2 ESA / 140474 Enhanced Watershed Management Programs April 2015 Statement o(Overriding Considerations Prelintim i-—Suhjecl to R -kion .1 ' Noise L� 5) Impact 3.10-1 (The proposed project would result in exposure of persons to, or generation of, noise levels in excess of standards established in the localeng eral plan or noise ordinance, or applicable standards of other agencies). During construction of the proposed program, noise levels would be increased temporarily and intermittently to levels substantially greater than existing ambient noise levels in the area. Mitigation measures would help reduce construction noise impacts, requiring construction activities to be conducted in accordance with the applicable local noise regulations and standards, the implementation of noise reduction devices and techniques during construction activities, and advance notification to the surrounding noise - sensitive receptors of a structural BMP site about upcoming construction activities and their hours of operation. Certain structural BMP projects may exceed noise levels established by their respective local jurisdictions, though, which would make this impact significant and unavoidable despite implementation of Mitigation Measures NOISE -1 and NOISE -2. 6) Impact 3.10-4 (The proposed project would result in a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project). During construction of the distributed, centralized, and regional structural BMPs, temporary or periodic increases in noise levels in and around each structural BMP site would result from the operation of construction equipment. Under circumstances where structural BMP sites are located immediately adjacent to existing sensitive land uses, the noise impacts related to a substantial temporary or periodic increase in ambient noise levels above levels existing without the structural BMPs would remain significant, even with implementation of mitigation measures. Individual project -level assessment in the future, though, may result in a finding of less -than -significant for temporary increases in noise levels. Despite implementation of Mitigation Measure NOISE -1, the impact would remain significant and unavoidable for this program. 7) Cumulative Impact, Noise (The project would result in significant cumulative construction noise impacts). Construction of the structural BMPs, in combination with other current and planned projects in the County would result in an increase in construction -related noise levels, which would temporarily increase the ambient noise levels of the existing noise environment in areas where a construction project would occur. Despite implementation of Mitigation Measures NOISE -1 and NOISE -2, cumulative impacts for construction would remain significant and unavoidable. In addition to the impacts identified above, the District finds that the following impacts are significant and ' unavoidable solely because the mitigation proposed to reduce these impacts to less -than -significant levels is within the control and jurisdiction of other public agencies who will be implementing the EWMPs. Although the District will implement these mitigation measures for projects over which it has jurisdiction, ' the District cannot ensure that other Implementing Agencies will adopt and implement the proposed mitigation measures for projects over which they have jurisdiction. The District therefore cannot state with certainty that these impacts will be mitigated to less -than -significant levels, meaning that they may remain significant and unavoidable. The statement of overriding considerations is therefore also made for the following impacts: Aesthetics 8) Impact 3.1-1 (The proposed program could create a substantial adverse effect on a scenic vista)_ During construction, equipment and materials required for temporary ground disturbances would LA County Flood Control District 3 GSA / 140474 Enhanced Watershed Management Programs April 2015 Statement of Overriding Considerations ' Preliminar7—SnAjecr In Revision be visible from public vantage points, but would not affect any scenic vistas past the temporary construction periods. Given the predominantly urban character of potential pump station sites and temporary nature of construction activities, impacts would be considered less than significant. A majority of structural BMPs would be located underground and would not introduce impacts to scenic vistas. Aboveground structures such as pump stations would be located in urbanized areas and would generally be single -story buildings. Such aboveground structures have the potential to impact scenic vistas, but will be required to be designed so as not to contrast existing neighborhood aesthetic features. The Program EIR identified Mitigation Measure AES -1 that would reduce impacts to a less -than -significant level. However, without implementation of this mitigation measure, the impact would be significant and unavoidable. 9) Impact 3.1-2 (The proposed program could substantially damage scenic resources, including but not limited to, trees, rocks, outcroppings, and historic buildings within a state scenic hi hwa .Parts of the proposed program may be visible from designated scenic highways or other locally designated scenic roadways in the project area. Rock outcroppings and historic buildings would likely not be disturbed by the project as most of the BMPs will be underground and not visible after construction is complete. Construction of the proposed program would involve removal of vegetation from individual project sites. Larger structures may result in significant impacts to scenic resources within state scenic highway. The Program EIR identified Mitigation Measure AES -1 that would reduce impacts to a less -than -significant level. However, without implementation of this mitigation measure, the impact would be significant and unavoidable. 10) Impact 3.1-3 (The proposed program could substantially degrade the existing visual character or quality of the site and its surroundings). Construction activities would visually degrade the project site and its surroundings as a result of the appearance of demolition materials, excavated areas, stockpiles, and other materials. Due to the temporary nature of construction, these adverse effects are considered less than significant. Once constructed, the BMPs would be located predominantly in urban areas and largely underground, which will not have a permanent effect on the visual character or quality of an area. Aboveground structures may degrade existing visual character of project areas as they will add to the visual landscape. Without proper maintenance of BMPs, especially wet ponds or constructed wetlands, there is a potential for substantial degradation of existing visual quality of project sites due to algal growth or public littering. The Program EIR identified Mitigation Measures AES -1 and AES -2 that would reduce impacts to a less -than - significant level. However, without implementation of these mitigation measures, the impact would be significant and unavoidable. 11) Cumulative Impact, Aesthetics (The proposed program would result in a less than significant cumulative aesthetic impact with mitigation). Cumulative projects in the program region have the potential to result in cumulative impacts to aesthetic resources if they would result in the removal or substantial adverse change of visual character or image of a neighborhood, community, state scenic highway, or localized area. Given that the BMPs will be located in primarily urbanized areas, introduction of structural BMPs would result in only minor changes to the visual landscape. The cumulative impacts of aboveground structures could have a significant impact to the aesthetic environment due to their potential size and location. Overall, implementation of BMPs is anticipated to have a positive impact on the aesthetic environment through the creation of open space areas and less impervious surfaces in urbanized or residential areas. The Program EIR identified Mitigation Measures AES -1 and AES -2 that would reduce cumulative impacts LA County Flood Control District Enhanced Watershed Management Programs Statement o(Overriding Considerations -4 Preliuti—ri —.Subject to Revision GSA / 140474 April 2015 associated with aesthetics to a less -than -significant level. However, without implementation of these mitigation measures, the impact would be significant and unavoidable. Air Quality 12) Impact 3.2-4 (The proposed program could expose sensitive receptors to substantial pollutant concentrations). While construction -related traffic on local roadways would occur during construction, the net increase of construction vehicle trips to the existing traffic volumes on local roadways would be relatively small and would not result in carbon monoxide (CO) hotspots. These construction -related trips would only occur in the short-term, and because trip -generating land uses are not associated with the proposed program, impacts associated with CO hotspots would be less than significant. Off-road heavy-duty diesel equipment would be used only temporarily at each individual structural BMP site, therefore the construction activities associated with each structural BMP project in the EWMP areas would not expose sensitive receptors to substantial emissions of TACs. During construction of the individual structural BMPs in the project area, sensitive receptors such as residences, schools, hospitals, and daycare centers would be exposed to significant adverse localized air quality impacts. Operation of structural BMPs would not involve the emission of toxic air contaminants (TAC), and would operate passively without use of mechanical equipment. Project operation would not introduce health risks associated with TAC emissions. Construction activities could expose sensitive receptors to criteria air pollutants from vehicle exhaust and dust. Depending on the size and scope of the individual structural BMPs, a localized significance threshold (LST) analysis may be required to ensure construction emissions would not exceed SCAQMD's LSTs or result in pollutant emissions that would cause or contribute to the exceedance of the most stringent applicable federal or state ambient air quality standards. The Program EIR identified Mitigation Measure AIR -3 that would reduce this impact to a less -than -significant level. However, without implementation of this mitigation measure, the impact would be significant and unavoidable. 13) The proposed program could create objectionable odors affecting a substantial number of people (Impact 3.2-5). The proposed program does not include any uses typically associated with odor complaints including agricultural uses, wastewater treatment plants, food processing plans, and landfills, among others. During the construction phase, exhaust odors from equipment may produce discernible odors typical of most construction sites and would be a temporary source of nuisance to adjacent uses. These odors would be temporary and intermittent in nature, so would not be considered a significant environmental impact. Certain BMPs such as restored creeks and estuaries may result in odors from saturated mud or algal blooms when left permanently wet. This may result in a severe nuisance for sensitive receptors near such BMPs, and regular maintenance may be sufficient to reduce odors in some situations. The Program EIR identified Mitigation Measures AES -2 and AIR -4 that would reduce impacts to a less -than -significant levels. However, without implementation of these mitigation measures, the impact would be significant and unavoidable. Biological Resources 14) Impact 3.3-1 (The proposed program would have a substantial adverse impact, either directly or through habitat modifications, on species identified as special -status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service). Construction of structural BMPs may affect large open space or LA County Flood Control District 5 Enhanced Watershed Management Programs Statement o(Overriding Considerations Prelinrinun' —Subject m Revision ESA / 140474 April 2015 riparian habitats that would have a higher potential to support special -status wildlife species, such as streams, wetlands, and upland scrub or oak woodlands. Mitigation Measures BIO -1 through 13I0-8 require suitability studies for potential BMP sites for their potential to impact valued habitats, and require impact characterization, minimization and compensation for impacts to highly valued habitats in consultation with the USFWS and CDFW. The proposed program will implement BMPs that are designed to retain dry -weather flows, which could reduce wetted area or completely eliminate flows in certain drainages that support sensitive species. The Program EIR identified Mitigation Measures BIO -1 through 13I0-8 that would reduce the impact to a less - than -significant level. However, without implementation of these mitigation measures, the impact would be significant and unavoidable. 15) Impact 3.3-2 (The proposed program would have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the CDFW or USF)YS). Significant Ecological Areas (SEA), as identified by the Los Angeles County General Plan, riparian, and other sensitive communities are not expected to occur within the disturbance areas of the BMP projects since the majority of the structural BMPs would occur in developed or disturbed areas. While some regional and centralized structural BMPs could occur within or adjacent to SEAS, riparian habitat or other sensitive natural communities, these types of BMPs would provide multi -beneficial water quality and habitat restoration improvements to the applicable EWMP watershed. Additionally, each development proposed within a designated SEA must undergo a performance review process for compliance with the SEA design compatibility criteria and other standards for approval by the LA County Department of Regional Planning. Future project -level environmental review processes would consider all proposed projects on a case-by-case basis to determine whether an individual project would impact riparian or other sensitive natural communities. Site-specific mitigation measures would be required to minimize and reduce potentially significant impacts to riparian and other sensitive natural communities. The Program EIR identified Mitigation Measures BIO -1 through 13I0-8 that would reduce this impact to less than significant levels. However, without implementation of these mitigation measures, the impact would be significant and unavoidable. 16) Impact 3.3-3 (The proposed program would have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, arsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means). Wetlands occur throughout the EWMP areas, and once project facility locations are determined, exact locations and acreages of jurisdictional areas located within or adjacent to impact areas shall be determined through a formal jurisdictional delineation. For projects impacting native vegetation within jurisdictional drainages, the implementing agency would be required to obtain California Fish and Game Code Section 1602 compliance and Section 404 compliance from the USACE and Section 401 Certification from the RWQCB. In addition, implementation of Mitigation Measures BIO -1 through 13I0-9 would ensure compliance with state and federal regulations relating to potentially jurisdictional features, including wash habitat vegetation that may fall under CDFW jurisdiction. Any projects impacting native vegetation within jurisdictional drainages would be required to comply with California Fish and Game Code Section 1602 compliance and Section 404 compliance from the USACE and Section 401 Certification from the RWQCB. The Program EIR identified Mitigation Measures 13I0-1 through BIO -9 that would reduce this impact to less than significant levels. However, without implementation of these mitigation measures, the impact would be significant and unavoidable. LA County Floud Control District 6 GSA / 140474 Enhanced Watershed Management Programs April 2015 Statement of Overriding Considerations Porelindn.ry—Subjec•l to Revision 17) Impact 3.3-5 (The proposed program would conflict with local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance). The proposed program would mainly be constructed within highly urbanized and disturbed areas within existing infrastructure. Any impacts to oak trees within Los Angeles County would be required to comply with the Oak Tree Preservation Ordinance (or other tree ordinances established by the local city). A tree permit may be required if impacts to oak trees or other protected trees are determined to be necessary. The Program EIR identified Mitigation Measure BIO -10 that would reduce this impact to less than significant levels. However, without implementation of this mitigation measure, the impact would be significant and unavoidable. 18) Cumulative Impacts, Biological Resources (The proposed program would result in cumulative biological resource impacts). Cumulatively, throughout the region, the retention of stormwater and treatment of pollutants within each watershed, and the reduction of pollutant loading in waterways would substantially benefit the water quality of the region's aquatic and coastal habitats, as well as the plants and wildlife dependent on them. Implementation of the BMPs would also return the local hydrology to a more natural condition. Although some drainage segments may exhibit reduced riparian habitat or wetlands over time due to the reduced dry - weather flow, the cumulative effect would be offset by increased groundwater recharge and seepage supporting expanded wetland and riparian vegetation supporting local flora and fauna populations. Therefore, the program's potential contribution to cumulative effects on biological resources is considered less than significant. For regional and centralized BMPs at the larger scale, the Program EIR identified Mitigation Measures BIO -1 through BIO -10 that would reduce this impact to less than significant levels. However, without implementation of these mitigation measures, the impact would be significant and unavoidable. Cultural Resources 19) Impact 3.4-2 (The proposed program could cause a substantial adverse change in the significance of unique archaeological resources as defined in § 15064.5). The program area, which spans most of Los Angeles County, should be considered sensitive for archaeological resources, with degree of sensitivity varying across the program area based on specific environmental factors. Any structural BMP which involves grading, trenching, excavation, vegetation removal, or other forms of ground disturbance could impact archaeological resources. The Program EIR identified Mitigation Measures CUL -2 through CUL -4 that would reduce this impact to less than significant levels. However, without implementation of these mitigation measures, the impact would be significant and unavoidable. 20) Impact 3.4-3 (The proposed program could directly or indirectly destroy a unique paleontological resource or site or unique geologic feature). The program area is underlain by a number of high or undetermined paleontological sensitivity units, which may contain significant paleontological resources. Significant paleontological resources can be uncovered even in areas of low sensitivity, though, and it is possible that ground -disturbing construction activities associated with structural BMPs could result in the inadvertent discovery of paleontological resources, which could be a significant impact. The Program EIR identified Mitigation Measures CUL -5 and CUL -6 that would reduce this impact to less than significant levels. However, without implementation of these mitigation measures, the impact would be significant and unavoidable. LA County Floud Control District 7 ESA / 141474 Enhanced Watershed Management Programs April 2015 Statement of Overriding Considerations P-liminmy —Subject to Revision 21) Impact 3.44 (The proposed program could disturb human remains, including those interred outside of formal cemeteries). There is no indication, either from the archival research results or the archaeological survey, that any particular location in the project area has been used for human burial purposes in the recent or distant past. However, in the event that human remains are inadvertently discovered during project construction activities, the human remains could be inadvertently damaged, which could be a significant impact. The proposed program's potential to uncover buried archaeological deposits including human remains is considered significant. The Program EIR identified Mitigation Measures CUL -7. However, without implementation of this mitigation measure, the impact would be significant and unavoidable. Geologic and Mineral Resources 22) Impact 3.5-3 (The proposed program could be located on a geological unit or soil that is unstable, or that would become unstable as a result of the program, and potentially result in on-site or off- site non -seismically induced geologic hazards such as landslides, lateral spreading, subsidence, collapse or sinkholes, settlement, or slope failure). Infiltration of water into subsurface soils can increase soil instability and result in saturated soils, soil piping through preferential pathways, breakouts due to infiltrated water finding utility trenches and other preferential pathways, and raising the local groundwater levels such that infrastructure foundations and underground structures could be affected by unstable soils. Structural BMPs could potentially be undermined by unstable soils or impact adjacent infrastructure and buildings. The Program EIR identified Mitigation Measure GEO-1 that would reduce this impact to less than significant levels. However, without implementation of this mitigation measure, the impact would be significant and unavoidable. 23) Cumulative Impacts, Geologic and Mineral Resources (Cumulative impacts on geology and soils would have a less than significant impact on the environment with implementation of mitigation). The cumulative effect of multiple infiltration projects could increase the severity of perched or migrating water, which has the potential to inundate underground utilities or structures. Mitigation Measure GEO-1 would minimize the cumulative impact to regional infrastructure from perched or migrating water. The management of groundwater pumping among regional managers prevents impacts to structural foundations resulting from groundwater mounding from existing recharge efforts. Mitigation Measure GEO-2 would reduce the cumulative effects to soil stability from elevated groundwater levels to a less -than -significant level. The Program EIR identified Mitigation Measures GEO-1 and GEO-2 that would reduce this impact to less than significant levels. However, without implementation of these mitigation measures, the impact would be significant and unavoidable. Hazards and Hazardous Materials 24) Impact 3.7-2 (The proposed program would create a significant hazard to the public or the environment through the accumulation of potentially hazardous materials into BMPs). Because of their function as water conveyance systems, the entire storm sewer system, as augmented by structural BMPs, would collect and retain sediment and chemicals from urban runoff, along with any accidental or illicit spills of hazardous materials. The introduction of hazardous materials into the storm sewer system could occur in large events as in a catastrophic spill, or could occur in small concentrations as in petroleum hydrocarbons and heavy metals picked up and carried by stormwater in urban runoff from the streets. Contaminants in the runoff water or as discrete LA County Flood Control District 8 BSA 1140474 Enhanced Watershed Management Programs April 2015 Statement of Overriding Considerations Preliminary —Subject hi Revision concentrated spills could accumulate in the soils and vegetation of structural BMPs. To address the accumulation of contaminants in soil at BMPs, operations and maintenance plans for BMPs that might accumulate constituents in surface soils and media will be developed to include periodic removal and replacement of these potentially impacted surface materials to reduce the potential for long-term loading leading to hazardous concentrations in soils and groundwater. The Program EIR identified Mitigation Measure HAZ-1 that would reduce this impact to less than significant levels. However, without implementation of this mitigation measure, the impact would be significant and unavoidable. 25) Impact 3.711 (The proposed program would be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, could create a significant hazard to the public or the environment). It is possible that a proposed BMP may be located on a hazardous materials site listed on the Cortese List, which would expose construction workers, the public, and the environment to hazardous materials during earth -moving activities, introducing a significant impact. The Program EIR identified Mitigation Measure HAZ-2 that would reduce this impact to less than significant levels. However, without implementation of this mitigation measure, the impact would be significant and unavoidable. 26) Impact 3.7-5 (For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, for a project within the vicinity of a private airstrip, the proposed program could result in a safety hazard for people residing or working in the project area). Some structural BMPs, such as detention basins that store water for a period of time or constructed wetlands that would increase or improve wildlife habitat, could be constructed on or near airports and could result in attracting wildlife. Deer and birds are known wildlife hazards to airports. If the proposed project is at or near an airport, this could increase hazards to aircraft from wildlife. The Program EIR identified Mitigation Measure HAZ-3 that would reduce this impact to less than significant levels. However, without implementation of this mitigation measure, the impact would be significant and unavoidable. 27) Cumulative Impacts, Hazards and Hazardous Materials (The proposed program would result in cumulatively significant impacts to hazardous materials). Most of the distributed BMPs would be small in scale and would not result in cumulatively significant impacts due to increased hazards from construction or operation. However, the combination of BMPs throughout the region would change the flow paths of stormwater and urban runoff that currently occurs in the region, resulting in the retention of pollutants generally within the soil of the BMPs that use soil for filtration and retention. Cumulatively, throughout the region, the retention and treatment of pollutants within each watershed and the reduction of pollutant loading in waterways will substantially benefit water and sediment quality of the region's habitats, rivers, and beaches. Therefore, the project's potential contribution to cumulative effects on hazards and hazardous materials is considered beneficial. The Program EIR identified Mitigation Measures HAZ-1 and HAZ-2 that would reduce this impact to less than significant levels. However, without implementation of these mitigation measures, the impact would be significant and unavoidable. Hydrology and Water Quality 28) Impact 3.8-2 (The proposed program would result in higher groundwater levels and could potentially affect groundwater quality). Regional BMPs would recharge stormwater into the LA County Flood Control District 9 GSA / 141474 Entranced Watershed Management Programs April 2015 Statement of Overriding Considerations Preliminary —Subject Gr Revision groundwater basin and could raise local groundwater levels following major storm events. Distributed infiltration BMPs would typically be too small to have a measureable effect on local groundwater levels. The increased water supplies captured by the infiltration basins through the EWMP areas would be a beneficial impact of the projects. Infiltration BMPs would not be suitable in areas of low permeability, though, and potential locations would need to be evaluated for suitability. Concentrations of contaminants found in stormwater runoff could increase, resulting in contaminated shallow soils and groundwater. The Program EIR identified Mitigation Measures HYDRO -1 through HYDRO -4 that would reduce this impact to less than significant levels. However, without implementation of Mitigation Measures HYDRO -1 through HYDRO -3, the impact would be significant and unavoidable. Noise 29) Impact 3.10-3 (The proposed program would result in a substantial permanent increase in ambient noise levels in the proiect vicinity above levels existing without the project). No operational noise levels would be generated by the structural BMPs given their passive manner of operation. However, it is anticipated that some of the centralized and regional structural BMPs would require the use of irrigation pump stations and associated components to divert the collected stormwater. At these structural BMP sites, noise levels generated from the long-term operation of the pumps and associated components could result in increased noise levels in the surrounding noise environment. The Program EIR identified Mitigation Measures NOISE -1 and NOISE -2 that would reduce this impact to less than significant levels. However, without implementation of these mitigation measures, the impact would be significant and unavoidable. Public Services and Recreation 30) Impact 3.12-1 (The proposed program would not result in substantial adverse physical impacts associated with the provision of, or need for, new or physically altered governmental fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for fire protective services). The structural BMPs are not habitable structures, would not be constructed with flammable materials, and would not require fire protection services. Because of the relative scale of these infrastructure improvements, the construction of the various structural BMPs are not expected to result in the need for new or physically altered fire protection facilities. However, construction of new structural BMPs in streets, sidewalks, parkland, or other facilities (these may include public service facilities such as police stations, fire stations, and municipal maintenance yards) within existing high-density urban, commercial, industrial, and transportation areas, as well as associated staging areas, could temporarily disrupt the provision of fire services, resulting in potentially significant impacts. The Program EIR identified Mitigation Measure PS -1 that would reduce this impact to less than significant levels. However, without implementation of this mitigation measure, the impact would be significant and unavoidable. Transportation and Circulation 31) Impact 3.13-1 (The proposed program would intermittently and temporarily increase traffic levels and traffic delays due to vehicle trips generated by construction workers and construction vehicles on area roadways). Vehicle trips would be generated primarily by construction workers commuting to and from the BMP work sites, and by trucks hauling materials and equipment to LA County Flood Control District 10 GSA / 141474 Enhanced Watershed Management Programs Apri12015 Statement or Overriding Considerations !'rrlintinary—SxAjrcr 1n R-i.sinn l and from the sites. The construction traffic impacts associated with each individual structural BMP project would be short-term in nature and limited to the period of time when construction activity is taking place for that particular project. Although project -related traffic would be temporary, supplemental project -level analysis of potential site-specific impacts could determine that addition of project -generated traffic would be considered substantial in relation to traffic flow conditions on local roadways. For this program -level assessment, this impact is considered potentially significant. The Program EIR identified Mitigation Measure TRAF-I that would reduce this impact to less than significant levels. However, without implementation of this mitigation measure, the impact would be significant and unavoidable. 32) Impact 3.134 (The proposed program would contribute to cumulative impacts to traffic and transportation). During construction of the structural BMPs, intermittent and temporary traffic - related impacts in the cumulative context would occur. The proposed program has the potential to contribute to potentially significant cumulative construction -related impacts as a result of (l) cumulative projects (such as land development projects) that generate increased traffic at the same time on the same roads as would the proposed program, causing increased congestion and delays; and (2) infrastructure projects in roads that would be used by project construction workers and trucks, which could delay project -generated vehicles past the work zones of those other projects. The Program EIR identified Mitigation Measure TRAF-1 that would reduce this impact to less than significant levels. However, without implementation of this mitigation measure, the impact would be significant and unavoidable. Utilities and Service Systems 33) Impact 3.14-3 (The proposed program would require new or expanded water supply resources or entitlements or require or result in the construction of new water facilities or expansion of existing facilities, the construction of which could cause significant environmental effects). Construction requiring ground disturbance could encounter buried utilities including water supply infrastructure. Construction of BMPs to detain stormwater and dry -weather flows may reduce flows downstream, thereby reducing access to beneficial uses downstream. Dry -weather flows in coastal streams and foothills are largely fed by groundwater seepage or wastewater discharges. Any detention of dry weather flows or storm flows upstream could substantially reduce flows downstream or significantly impede access to flows. The Program EIR identified Mitigation Measures UTIL-1 through UTIL-3 that would reduce this impact to less than significant levels. However, without implementation of Mitigation Measures UTIL-2 and UTIL-3, the impact would be significant and unavoidable. 34) Impact 3.144 (The proposed program would be served by a landfill with insufficient permitted capacity to accommodate the proposed program's solid waste disposal needs or the proposed program could not comply with federal, state, and local statuses and regulations related to solid waste). Construction activities associated with the structural BMPs would include excavation and demolition of some existing infrastructure, which would produce solid waste requiring disposal in the nearest landfill. Some of the EWMPs are required to implement trash Total Maximum Daily Limits (TMDLs) and associated trash removal structural BMPs, which would require the disposal of the trash collected by the BMPs, thereby increase the amount of trash being sent to landfills. The non-structural BMPs would include street cleaning, landscape management, and storm drain operation, which produce debris and trash requiring disposal, which could exceed landfill limits. The new trash collected that is associated with proposed trash removal structural BMPs and non - LA County Flood Control District ] ] HSA 1140474 Enhanced Watershed Management Program- April 2015 Statenxnt of Overriding Considerations Nelimin y —Subject to Revision structural BMPs such as street cleaning and landscape management would be accommodated with existing and planned trash disposal facilities. Based on landfill capacity in the Los Angeles region, there appears to be ample availability to receive the expected trash generated by the program. The program would comply with all federal, state, and local statutes and regulations related to solid waste, including the Los Angeles County Construction and Demolition Debris Recycling and Reuse Program. The Program EIR identified Mitigation Measures UTIL-2 that would reduce this impact to less than significant levels. However, without implementation of this mitigation measure, the impact would be significant and unavoidable. 35) Cumulative Impacts, Utilities and Service Systems (The proposed program could result in significant cumulative impacts to utilities and service systems). Structural BMPS constructed to treat, infiltrate, and/or store stormwater and non-stormwater throughout the watershed would not generate wastewater or require wastewater treatment or result in adverse cumulative impacts from operation or construction. Installation of storm drainage facilities identified in the proposed EWMPs would not substantially affect existing storm drain facilities. Impacts to the existing water supplies are anticipated to be beneficial as a result of the stormwater and non-stormwater runoff infiltration and conservation BMPs implemented across the EWMP areas. Construction and operation of the structural BMPs would generate solid waste; however, landfills serving the program area are expected to have sufficient capacity to accommodate the amount of waste generated. Disposal of the solid waste generated during construction and operation would comply with all pertinent regulations and statutes. All other projects implemented in the area would also be required to comply with federal, state, and local solid waste regulations and statutes. The use of energy anticipated for the proposed program is minor when compared to the County -wide use of electricity. The proposed program would use energy-efficient equipment and would not result in wasteful consumption. The non-structural BMPs would include street cleaning, landscape management, and storm drain operation, which would produce debris and trash for disposal. The Program EIR identified Mitigation Measures UTIL-1 through UTIL-3 that would reduce this impact to less than significant levels. However, without implementation of Mitigation Measures UTIL-2 and UTIL-3, the impact would be significant and unavoidable. Findings The Los Angeles County Flood Control District finds and determines that it has considered the identified means of lessening or avoiding the project's significant effects and that to the extent any significant direct or indirect environmental effects, including cumulative project impacts, remain unavoidable or not reduced to below a level of significance after mitigation, such impacts are at an unacceptable level in light of the social, legal, economic, environmental, technological, and other project benefits discussed below, and such benefits override, outweigh, and make "acceptable" any such remaining environmental impacts of the project (CEQA Guidelines Section 15092(b)). The following benefits and considerations outweigh the identified significant and unavoidable adverse environmental impacts. All of these benefits and considerations are based on the facts set forth in the findings, the Final PEIR, and the record of proceedings for the project. Each of these benefits and considerations is a separate and independent basis that justifies approval of the project, so that if a court were to set aside the determination that any particular benefit or consideration would occur and justifies project approval, this Commission would otherwise stand by its determination that the remaining benefit(s) or considerations are sufficient to justify and substantiate project approval. LA County Flood Control District 12 GSA / 141474 Enhanced Watershed Management Programs April 2015 Statement o(Overriding Considerations Preliminary—Snbjech/n Revision Facts Each benefit set forth below constitutes an overriding consideration warranting approval of the project, independent of the other benefits, and the District determines that the adverse environmental impacts of the project are "acceptable" if any of these benefits would be realized. The project would provide benefits to the County of Los Angeles as follows: 1) The proposed program would help the District, in partnership with 85 other Permittees, to achieve compliance with the MS4 permit issued by the Los Angeles RWQCB in 2012. 2) The proposed program would result in improved water quality in receiving waters throughout the County including the major rivers, streams, and the ocean through the retention, detention, or treatment of stormwater and dry weather flow. 3) The proposed program would help the District, in partnership with 85 other Permittees, to achieve TMDL water quality objectives identified by the Los Angeles RWQCB. 4) The proposed program would benefit communities within the County in developing multi -benefit facilities. 5) The proposed project would benefit certain communities within the County in augmenting groundwater supplies with captured stormwater. 6) Implementation of the proposed program would help support and be consistent with the State of California Ocean Plan promoting improved ocean water quality for multiple beneficial uses. 7) Implementation of the proposed program would be consistent with the stated goals and policies of the Los Angeles Region Basin Plan prepared by the Regional Water Quality Control Board pursuant to California Water Code Section 13240. 8) Implementation of the proposed program would promote and be consistent with the County of Los Angeles 2014 Low Impact Development Standards Manual. LA County Flood Control District 13 GSA / 140474 Enlmnced Watershed Management Programs April 2015 Statement ol'Overriding Considerations Prelin,inuq• —Subject In Revision 1 s r n C MITIGATION MONITORING AND REPORTING PROGRAM Public Resources Code, Section 21081.6 (Assembly Bill 3180) requires that mitigation measures identified in environmental review documents prepared in accordance with California Environmental Quality Act (CEQA) are implemented after a project is approved. Therefore, this Mitigation Monitoring and Reporting Program (MMRP) has been prepared to ensure compliance with the adopted mitigation measures during the implementation of the Enhanced Watershed Management Programs (EWMPs) (proposed program). LACFCD is the agency responsible for implementation of the mitigation measures identified in the EIR. This MMRP provides LACFCD with a convenient mechanism for quickly reviewing all the mitigation measures including the ability to focus on select information such as timing. The MMRP includes the following information for each mitigation measure: • The phase of the project during which the required mitigation measure must be implemented; • The phase of the project during which the required mitigation measure must be monitored; • The enforcement agency; and • The monitoring agency. The MMRP includes a checklist to be used during the mitigation monitoring period. The checklist will verify the name of the monitor, the date of the monitoring activity, and any related remarks for each mitigation measure. LA County Flood Control District Enhanced Watershed Management Programs Final Program Environmental Impact Report ESA 1140379 April 2015 L a r_ J t Q O N _ O C U O a Q R N w R n. U w E O > U . ++ C N Q C U C U N 0 N O C U C U O y 0 C C a O CD O D C C C U 01 m R a) C U R N C tRj 'y 'y C R >R 0) EA C N C C O ' C C C @'2 C C C C d U r tL6 O U.0 7.�o cc cc L w O N t_ p N N ENn R C M 0 0)R C a) N N N J J N m U.L. O U 7 U.L.. 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N C 0 U C m O 'U o m y n U o O O C p p 0, E m m U7 O m c n 0 O Cp NO N N O c6 y m 0) a) umi E E a E y Y A m O` '0 On .2 n N U N C Y C U N C LL m U) N 0 Y Q@ 'd C � U >. m- p o d n n C 0 c O E R O U e N U O .0 c .0 >` 3 j C C O n -, N m N a` m a �` C .. (Q N d o c E o C :- - U U y N •y_.. Ls G LL U 'O OU N I-- L C U E@ U (Mn C U '70 U C N J C of N J U "w 2E �r J -6 I c • • • > > U m am 0-, m -o E J E r ' E o rn a o � a c m v n v E E 76d O � � Q � E c o O U Q m W )° E 3 � o W U c Jc c W IL 7 1 n ORIGINAL FILED Print Form MAY 272015 Notice of Determination LOSANGELSS, COUNTY CLERK Appendix D To: From: ® Office of Planning and Research Public Agency: LA County Flood Control District Address: 900 South Fremont Avenue, 5th Floor U.S. Mail: Street Address: Alhambra, CA 91803 P.O. Box 3044 1400 Tenth St., Rm 113 Sacramento, CA 95812-3044 Sacramento, CA 95814 ® County Clerk County of: Los Angeles Address: P.9 -96x 1208 Norwalk, CA 90650-1208 _ Contact: Gregg BeGell Phone: (626) 300-3298 M Lead Agency (if different from above): Address: Contact: Phone,.-.- SUBJECT: hone:. SUBJECT: Filing of Notice of Determination in compliance with Section 21108 or 21152 of the Public Resources Code. State Clearinghouse Number (it submitted to State Clearinghouse): 2014081106 Project Title: Enhanced Watershed Management Programs (EWMP) Project Applicant: Los Angeles County Flood Control District (LACFCD) Project Location (include county): Throughout Los Angeles County Project Description: EWMPs are customized water quality improvement programs developed through computer modeling to determine projects and practices that can be implemented in a watershed to meet water quality standards while achieving other benefits such as flood control, water conservation, and recreational improvements. Certain MS4 Permittees have developed EWMPs for watersheds throughout the county to comply with the 2012 MS4 Permit. The EWMPs will be submitted to the LA Regional Water Quality Control Board for review and approval. Permittees implementing individual projects proposed in EWMPs will perform further environmental review as necessary. This is to advise that the LA County Flood Control District has approved the above (xN Lead Agency or ❑ Responsible Agency) described project on May 26, 2015_ and has made the following determinations regarding the above (date) described project. 1. The project [® will ❑ will not] have a significant effect on the environment. 2. © An Environmental Impact Report was prepared for this project pursuant to the provisions of CEQA. ❑ A Negative Declaration was prepared for this project pursuant to the provisions of CEQA. 3. Mitigation measures [® were ❑ were not] made a condition of the approval of the project. 4. A mitigation reporting or monitoring plan [® was ❑ was not] adopted for this project. 5. A statement of Overriding Considerations [© was ❑ was not] adopted for this project. 6. Findings [® were [I were not] made pursuant to the provisions of CEQA. This is to certify that the final EIR with co negative Declaration, is available to th www.tACoH2Osheds.com or LADPW 091 Signature (Puby Agency): Date: ;9ponses and record of project approval, or the at: 5th Floor, Alhambra, CA Title:.. (r -�+4�%. ^. -e"z�_._. Date Received for filing at OPR: Authority cited: Sections 21083, Public Resources Code. Reference Section 21000-21174, Public Resources Code. Revised 2011 State of California—Natural Resources Agency ' CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE 2015 ENVIRONMENTAL FILING FEE CASH RECEIPT RECEIPT # 201505271220028 ' STATE CLEARING HOUSE # (if applicable) SEE INSTRUCTIONS ON REVERSE. TYPE OR PRINT CLEARLY 2014081106 LEAD AGENCY DATE ' LA COUNTY FLOOD CONTROL DISTRICT 05/27/2015 COUNTY/STATE AGENCY OF FILING DOCUMENT NUMBER ' LACC 2015141443 PROJECT TITLE ENHANCED WATERSHED MANAGEMENT PROGRAMS (EWMP) ' PROJECT APPLICANT NAME PHONE NUMBER GREGG BEGELL (626)300-3298 PROJECT APPLICANT ADDRESS CITY STATE ZIP CODE ' 900 SOUTH FREMONT AVE 5TH FLOOR 1ALHAMBRA ICA 91803 PROJECT APPLICANT (Check appropriate box): 0 Local Public Agency ❑ School District ❑ Other Special District ❑ State Agency ❑ Private Entity ' CHECK APPLICABLE FEES: Q Environmental Impact Report (EIR) $3,069.75 $ 3,069.75 ' ❑ Negative Declaration (ND)(MND) $2,210.00 $ 0.00 ❑ Application Fee Water Diversion (State Water Resources Control Board Only) $650.00 $ 0.00 ❑ Projects Subject to Certified Regulatory Programs (CRP) $1,043.75 $ 0.00 ' RI County Administrative Fee $60.0 $ 75.00 ❑ Project that is exempt from fees ' ❑ Notice of Exemption ❑ CDFW No Effect Determination (Form Attached) ' F] Other $ 0.00 PAYMENT METHOD: ❑ Cash ❑ Credit R1 Check ❑ Other $ 3,144.75 SIGNATURE ORIGINAL - PROJECT APPLICANT COPY - CDFW/ASB COPY - LEAD AGENCY COPY - COUNTY CLERK FG 753.5a (Rev. 01/15 Los Angeles County Registrar / Recorder 12400 Imperial Highway, Norwalk, CA (800)201-8999 Business Filings NORWALK Cashier: �i. DAVIS li�111[I1III11llIII111�111�11I1i1111�If111iEllll1111 � 2�271211111111111111111�I1NNI11111111 o02a Wednesday, MaY 27, 2015 2:10 PM Items) Fee Qty.. NOD - County Posting Fee 1 2015141443 $75.00 NOD - Environmental Impac 1 $3,069.75 2015141443 Total - , 744._75 Total Documents: $3 1 Customer payment(s); Check Check List; $3,144,75 #155250 $3,144.75 r