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HomeMy WebLinkAbout06/02/1998, 5 - CERTIFICATION OF THE FINAL ENVIRONMENTAL IMPACT REPORT FOR THE SALINAS RESERVOIR EXPANSION PROJECT council June 2 1998 j acenba Rpm 'ft.Nm � CITY OF SAN LUIS OBISPO FROM: John Moss,Utilities Director Prepared By: Gary Henderson, Water Division Manager SUBJECT: Certification of the Final Environmental Impact Report for the Salinas Reservoir Expansion Project CAO RECOMMENDATION Adopt a resolution certifying that the Final Environmental Impact Report for the Salinas Reservoir Expansion Project is adequate. REPORT-IN-BRIEF The City of San Luis Obispo's adopted Water Management Element to the General Plan identifies the need to develop an additional 3,861 acre feet of water supplies to meet full build- out of the City. This amount of water includes 2,000 acre feet per year for a"reliability reserve", as well as 500 acre feet per year of yield lost due to siltation at Salinas and Whale Rock Reservoirs. To meet these water supply needs, the City is currently pursuing three water supply projects: the Water Reuse Project, Nacimiento Pipeline Project , and the Salinas Reservoir Expansion Project. This report provides a summary of the information contained in the Final Environmental Impact Report(EIR)for the Salinas Reservoir Expansion Project. The City of San Luis Obispo has been pursuing the Salinas Reservoir Expansion Project for many years and initiated work on the initial draft EIR for the project in 1992. The project involves installation of a spillway gate at the existing dam which would raise the maximum water surface level by approximately 19 feet and thereby increase the storage capacity from 23,843 acre feet (AF) to 41,792 AF. This additional storage capacity will increase the City of San Luis Obispo's water supply by approximately 1,650 acre feet per year(AFY). Following the release of the initial draft EIR and subsequent public comments, Council directed additional studies and analysis for the project which resulted in a revised draft EIR which was released for public review and comment in May of 1997. Based on the comments received on the revised draft, additional analysis and evaluations were undertaken to respond to the concerns. The Final EIR for the project has been completed and addresses all the comments received on both the initial and revised draft EIR's for the project. The Council is being asked to certify the document at this time but to defer the decision on whether to proceed with construction of the project until additional studies and approvals are completed. The additional studies and approvals include: 1.) resolution to the protest to the City's water rights permit, 2.) the transfer of ownership from the federal government to a local agency,and 3.)development of the detailed mitigation/mitigation monitoring plans. 1 r Council Agenda Report—Certification of EIR for the Salinas Reservoir Expansion Project Page 2 The final EIR incorporates the additional studies and work efforts associated with biological mitigation strategies, potential downstream flow reduction impacts, inundation related impacts and other areas of concern. The two main areas of potential impacts are associated with the inundation of an additional 395 acres around the lake and reductions in downstream flows resulting from the capture of additional water at the enlarged reservoir. The inundation of an additional 395 acres surrounding the lake will result in the loss of an estimated 2,470 oak trees and 469 gray pines. The project would also result in a net loss of 51.7 acres of wetland and riparian woodlands. In addition,the project will result in the degradation of 22.1 acres of riparian woodland understory due to periodic inundation. With the assistance of the Mitigation Advisory Committee (including resource management agency representatives, landowners, environmental group representatives, and members of the public), mitigation strategies and opportunities were identified to mitigate the project related biological impacts. The strategies include in-kind restoration or enhancement (both on-site and off-site), and long- term protection or purchase of property. There are a number of high priority areas that have been identified for potential mitigation sites. The majority of these are on private property which will require negotiations with property owners. The information developed indicates that there are sufficient sites which would be suitable for mitigation of the biological impacts associated with inundation of areas around the lake. Mitigation measures would likely reduce biological impacts in the long-term to a level of insignificance. It is estimated that in the short-term (5 to 15 years), some biological resource related impacts will be significant until mitigation measures are able to fully replace lost habitat value. A memorandum from the City's Natural Resource Manager is included as Attachment C to this report which addresses his views relative to potential project impacts, mitigation measures and likelihood of success and other various issues. Potential impacts due to downstream flow reductions have been extensively analyzed to address the concerns raised by individuals and north county agencies. Project related flow reductions were estimated using a computer model developed to simulate reservoir operations under various scenarios. Detailed information on the groundwater basin in Atascadero was obtained to correlate reductions in downstream flows to impacts to groundwater withdrawals. Additional analysis was also undertaken to address concerns associated with reduced "scouring" flows and potential impacts to biological resources downstream, including steelhead. The analysis confirmed previous findings that the reductions in downstream flows are not projected to have a significant impact on downstream water users, scouring flow events,or biological resources. The City of San Luis Obispo is required to release water from the lake under conditions of our water rights permit issued by the State Water Resources Control Board. These conditions are referred to as the "live stream agreement" which requires all water flowing into the lake to be released from the dam until a continuous visible stream exists between the dam and the confluence with Nacimiento River. These conditions were imposed by the State Board to protect downstream water rights below the dam. The analysis completed for the final EIR confirms that Council Agenda Report—Certification of EIR for the Salinas Reservoir Expansion Project Page 3 the "live stream agreement" does protect downstream water rights and therefore no additional mitigation measures are required. The Final Environmental Impact Report for the Salinas Reservoir Expansion Project has involved years of work which included extensive field surveys, studies and analysis. The final document addresses all the comments and concerns raised on both the initial and revised draft EIR's for the project. The document identifies all project impacts and proposes mitigation measures which are expected to mitigate the project related impacts to a level of insignificance in the long-term. DISCUSSION Overview The City of San Luis Obispo has been pursuing expansion of the storage capacity of the Salinas Reservoir (i.e. Santa Margarita Lake) for many years. The project involves installation of a spillway gate at the existing dam which would raise the maximum water surface level by approximately 19 feet and thereby increase the storage capacity from 23,843 acre feet (AF) to 41,792 AF. This additional storage capacity will increase the City of San Luis Obispo's water supply by approximately 1,650 acre feet per year(AFY). The City's General Plan identifies the need for an additional 3,861 acre feet of water to meet future water demands, provide for a "reliability reserve" and offset reductions in safe annual yield resulting from siltation at Salinas and Whale Rock Reservoirs. This project is one of three water supply projects currently being pursued by the City to meet these additional water supply needs. The other projects being pursued are the Water Reuse Project and the Nacimiento Pipeline Project. For the past several years, the Council has directed staff to pursue a parallel track with the Salinas and Nacimiento Projects. The goal is to provide the Council the information relative to the environmental impacts of each project so that an informed decision can be made on which project(s) should be initiated to meet the City's projected water supply deficits. Both projects were originally planned to be certified within the same time period. Comments on the initial draft environmental impact report (EIR) for the Nacimiento Project have resulted in revisions to the project which will require additional studies and release of a revised draft EIR for the project The schedule for the completion of the EIR for the Nacimiento Project anticipates certification of the EIR by the County Board of Supervisors in October of 1999. The certification of the Salinas Reservoir Expansion Project Final Environmental Impact Report is essential at this time to allow completion of additional studies and approvals necessary prior to Council's decision to proceed with construction. The Council is being asked to certify the document at this time, but to defer the decision to proceed with construction until a future date once additional information is available and approvals have been obtained. The additional studies and approvals are discussed in more detail in the following sections of this report and Council Agenda Report—Certification of EIR for the Salinas Reservoir Expansion Project Page 4 include: 1.) resolution of the protest to the City's water rights permit for Salinas Reservoir, 2.) transfer of ownership of the dam and associated property from the federal government to a local agency, and 3.) development of detailed mitigation/mitigation monitoring plans which will require negotiations with private property owners. Background The City of San Luis Obispo has been pursuing the Salinas Reservoir Expansion Project since the late 1980's. The seismic and dam safety evaluation and the hydrology and reservoir yield evaluations were completed in 1989. Following the positive outcome of these evaluations,the City entered into a contract with Woodward-Clyde Consultants for preparation of the environmental impact report in March of 1992. The initial draft EIR was released for public review in November of 1993 and the comment period closed on January 3, 1994. Numerous comments and concerns were raised by agencies and individuals at that time and Council directed additional studies and analyses be prepared to address the concerns. The major areas of concern involved impacts to biological resources at the lake, potential impacts associated with reduction in downstream flows, and mitigation strategies to reduce identified impacts to acceptable levels. Additional biological surveys, hydrologic, and hydraulic studies were completed in response to the concerns raised on the initial draft EIR. The revised draft EIR incorporated these new studies and was released for public review in May of 1997. The comment and review period was open for approximately two months and included two public hearings, one held in the north county and the other in the City of San Luis Obispo. Thirty written comment letters were received, in addition to the public comments received at the two hearings. In addition to these comments on the revised draft EIR, twenty-two comment letters were received on the initial draft EIR. The final EIR responds to all of the comments received on the initial draft EIR as well as the revised ' draft EIR. The response to the comments are presented m Appendix J and M (separate volume) of the final EIR. The majority of the comments involve potential impacts associated with downstream flow reductions due to the expansion of the reservoir capacity and inundation impacts resulting from the 19 foot rise in water surface levels. Additional studies, analysis and involvement of outside interested individuals and agency staff were undertaken during the preparation of the revised draft EIR and in response to the comments received on the revised draft EIR. Additional Studies and Work Efforts Based on the comments received on the initial and revised draft EIR's, additional studies and work efforts were undertaken relative to three key areas: 1.) mitigation strategies and plans, 2.) additional analysis of potential impacts associated with downstream flow reductions, and 3.) additional biological surveys and analysis both downstream of the dam and in the potential inundation areas surrounding the lake. Council Agenda Report—Certification of EIR for the Salinas Reservoir Expansion Project Page 5 1.)Mitigation Strategies In response to the concerns raised relative to potential biological resource impacts and associated mitigation strategies,.the City formed a Mitigation Advisory Committee (MAC) to assist in the identification of suitable impact mitigation measures and opportunities to implement effective and appropriate mitigation. The MAC included resource management agency representatives, landowners, environmental group representatives, and members of the public. It was understood that participation on the MAC process would not be construed as an endorsement of the project and thus facilitated the participation from individuals who were opposed to the project. The focus of the MAC was the identification of mitigation measures to reduce the project related inundation impacts on oak woodland, wetland, and riparian woodland habitats. The group identified strategies and potential sites for mitigating the impacts. The detailed habitat mitigation plan is discussed in Appendix D of the Final EIR and is summarized in the following section of this report. 2.)Downstream Flow Reductions Concerns associated with potential reductions in downstream flows included: impacts to downstream water users, reduced scouring flows, and impacts to downstream biological resources (including steelhead). Extensive additional hydrologic analysis was undertaken to assess the potential impacts to downstream water users. The computer model utilized to estimate project related downstream flow impacts was verified and used to correlate reduced flows downstream to impacts to groundwater levels at Atascadero. Atascadero Mutual Water Company provided detailed information on their groundwater wells and pumping history which allowed the estimation of potential impacts to groundwater levels downstream as a result of reduced flows. The analysis confirmed that the reductions in downstream flows during the wet winter months, following the establishment of the "live stream", are not significant and will not adversely impact downstream water rights or users. This is summarized in more detail in the following section. 3.) Biological Surveys Additional biological surveys were undertaken in the potential inundation areas around the lake and in areas downstream of the dam. The surveys include a detailed survey of the number and type of trees which would be impacted by the higher water levels. The areas in the rear of the lake which contain significant wetland and riparian woodland areas were surveyed to quantify habitat values and replacement requirements. Additional surveys were also conducted downstream of the dam with a recognized fisheries (steelhead) biologist focusing on assessment of habitat suitability for steelhead trout access, spawning, and rearing. The results of these surveys were incorporated into the Final EIR for the project S� � Council Agenda Report—Certification of EIR for the Salinas Reservoir Expansion Project Page 6 Final Environmental Impact Report The Final Environmental Impact Report has identified the impacts associated with the Salinas Reservoir Expansion Project and proposes mitigation strategies to reduce long-term impacts to a level of insignificance. The two main areas of potential impacts are associated with the inundation of an additional 395 acres of land surrounding the lake and reductions in downstream flows resulting from the diversion of water to storage in the enlarged reservoir. The specific potential impacts and proposed mitigation measures for each of these issues are covered in detail in the following sections. Inundation Related Impacts The reservoir currently covers approximately 730 acres of land when full. The expansion project would result in periodic inundation of an additional 395 acres. Impacts associated with the inundation of these areas include impacts to biological resources (flora, fauna, and aquatic habitat), recreation facilities and associated roadways at the County Park, and cultural resources (historical and archaeological sites). Biological Impacts and Mitigation Measures: The inundation of the areas surrounding the lake will result in the loss of 73 acres of oak and pine woodland. It is estimated that 2,470 oak trees (1,639 coast live oaks, 633 blue oaks, and 198 valley oaks) would be lost due to periodic inundation. In addition, 469 gray pines would also be lost due to the raised water levels. The project will also result in a net loss of 51.7 acres of wetland and riparian woodlands (35.6 acres of willow scrub/woodland, 3.9 acres of mixed riparian woodland, and 12.2 acres of riparian forest). The project will also result in the degradation of 22.1 acres of riparian woodland understory due to periodic inundation. The Mitigation Advisory Committee (MAC) provided key input related to developing a habitat restoration plan for the project which is summarized below: • The primary mitigation approach should be in-kind restoration or enhancement, combined with long-tern protection, in the following order of preference: 1.) on-site locations; 2.) near-site locations; and 3.)off-site locations in the watershed. • If the primary approach cannot be achieved, or does not fully meet mitigation requirements, a secondary approach would be used consisting of purchasing and protecting high value existing habitat that is vulnerable (e.g., subject to development and/or degradation), incorporating an element of research and education on habitat restoration and management. • The primary criteria for evaluating alternative options are listed below. It is assumed that any candidate mitigation site would have the requisite physical and biological conditions for habitat restoration, and that the likelihood of success is high. Hence , the following criteria would be used to make a final selection on the best site or sites: S,6 Council Agenda Report—Certification of EIR for the Salinas Reservoir Expansion Project Page 7 1. Proximity to project site 2. Similarity to affected habitats 3. Capability of replacing affected habitat values and functions .4. Linkage with other habitat and/or open space 5. Potential for larger restoration or preservation by others 6. Self-sustainability of the restored habitat. Habitats to be mitigated include non-native grassland (191 acres), oak woodland (84 acres), riparian woodland/forest (16.1 acres), willow woodland (35.6 acres), freshwater marsh (0.9 acres), willow woodland understory (22.1 acres) and steam/aquatic habitat (16,050 linear feet). These habitats would be mitigated on an in-kind basis. Oak and riparian habitats would be mitigated on a 2:1 acreage ratio; grassland habitats would be mitigated on a 1:1 acreage ratio. The number of oak trees to be restored and/or protected would be equivalent to or greater than the number lost due to the project, taking into account unavoidable losses during the restoration process. Therefore, the number of trees to be planted would exceed the number of trees lost. The exact planting density and number of trees would be determined by a restoration specialist for each specific restoration site. There are eight high priority areas near the lake that have been identified by'the City which contain potential habitat mitigation sites. These areas were selected through the MAC process as the most promising areas for habitat restoration based on ecological factors only. All of the areas are located on private property which will require negotiations with the property owners to implement the mitigation strategies. The City has sent correspondence to all property owners of potential mitigation sites to inform them that their properties would be included in the EIR document. A number of property owners contacted staff to express their interest in working with the City relative to mitigation approaches. No property owners contacted the City to request that their property be removed from consideration and not included in the EIR. Stream/aquatic restoration will likely pose the greatest challenge for mitigation. Potential areas have been identified, but sites are obviously limited to streams and creeks with seasonal flows. Table 1 in Appendix D lists the candidate mitigation areas and the degree to which each site could meet some or all of the habitat replacement goals. The information indicates that there are several candidate mitigation areas that contain sufficient acreage and stream habitat for enhancement and restoration. At this time, the City is not ranking these opportunities, pending determination on the availability of these areas. Recreational Imipacts and Mitigation Measures: Impacts to recreation facilities and access roads will occur as a result of the raised water levels. The major areas impacted include the marina and cafd buildings, the marina parking area and boat ramp, the swimming pool and parking area,,the White Oak picnic area and boat ramp, and the access roads to Vaca Flat. Additionally, the north shore access road, which is used for 6--- 7 Council Agenda Report—Certification of EIR for the Salinas Reservoir Expansion Project Page 8 equestrian, bicycle and hiking activities, would be periodically inundated during periods when the lake is full. Extensive recreation facilities relocation plans have been developed in conjunction with the County Parks Division staff to mitigate impacts to recreation activities at the lake. In general, all affected recreation facilities would be relocated or replaced as part of the construction project. The recreation relocation plans are designed to improve existing park facilities with respect to parking, layout, traffic circulation and aesthetics. With the implementation of the proposed recreational facility relocation plans, no residual, long-term significant effects are anticipated. However, the proposed project would result in significant, short-term impacts on recreational activities at the County park for one summer season during the construction phase.due to access limitations. Cultural Resources Impacts and Mitigations: Cultural resources known to exist within the area of inundation associated with the expansion project include two locations with bedrock milling stations, a grave of the infant son of the Rector family (who resided in the area in the 1880's), an old homestead site (foundations, trash and privy pits, and other features), and a complex of historic buildings and foundations, and an earthen dam on property which was operated as a dairy prior to the construction of the dam. Potential effects on cultural resources in the inundation zone would be mitigated via site evaluation, documentation, data recovery, and/or relocation. Implementation of these strategies will reduce potential impacts to a level of insignificance prior to project implementation. Additionally, potential adverse impacts on the historical significance and integrity of the Salinas Dam due to spillway modifications and dam strengthening measures would also be mitigated to the standards of the State Office of Historic Preservation and the National Park Service. Downstream Flow Reduction Impacts Numerous concerns have been raised by agencies and individuals in the north county relative to impacts associated with reductions in downstream flows. Concerns included impacts to groundwater recharge, reductions in scouring flows, and impacts to biological resources including steelhead. The proposed project would periodically reduce downstream flows during the winter months of wet years. During drought periods or low rainfall years, which do not typically result in the development of a "live stream" downstream of the dam to the confluence of Nacimiento River, there would be no impacts to downstream flows. Salinas Dam normally captures runoff during large storm events in wet years when there is already an abundance or surplus of water downstream. Groundwater Rechar¢e Impacts The impacts to the groundwater basins downstream of the dam has been a major concern raised by agencies and individuals in the north county. To address these concerns, significant analysis Council Agenda Report—Certification of EIR for the Salinas Reservoir Expansion Project Page 9 of the potential impacts was undertaken to correlate estimated reductions in downstream flows with associated reductions in groundwater levels. Extensive information was obtained from Atascadero Mutual Water Company records relative to groundwater levels and pumping history. This information was used to correlate river flows with associated recharge rates of wells in the vicinity of the river. The computer modeling indicates that the project would reduce groundwater levels in shallow and deep wells in Atascadero by approximately 0.14 and 0.46 feet, respectively, on an average annual basis. Groundwater level impacts would be less discernible further downstream. The additional hydrologic analysis confirms previous conclusions that the reduction in flows associated with capture of additional water during wet winter months will not have a significant impact on downstream water resources. The proposed project will not affect the existing "live stream agreement" which requires the release of all flows into the lake until a visible continuous stream is developed from the dam to the confluence with Nacimiento River. The analysis confirms that the provisions of the "live stream agreement", which were stipulated by the State Water Resources Control Board,do protect downstream water rights. Scouring Impacts Concerns were raised that reductions in downstream flows could result in less "scouring" of the river bed which could result in a reduction of percolation rates, impacts to periodic "cleansing" of in-stream gravels used for spawning trout and reduction in vegetation removal during high flow events. To address these concerns, operations and hydraulic models were developed to estimate peak flows and velocities below the dam. The average peak flow during spills under current conditions was 318 cubic feet per second (cfs). With an enlarged reservoir, the average peak flow would be reduced to 316 cfs. The average peak velocities would be reduced from 4.84 feet per second to 4.74 feet per second. The analysis indicates that the project will not have a significant impact on flow velocities downstream of the dam. Based on these results, the project ' is not anticipated to result in significant reduction in downstream scouring events or other related impacts downstream. Biological Impacts Potential impacts to biological habitat and to steelhead spawning associated with flow reductions were expressed by several individuals commenting on the EIR. To address these concerns, additional surveys and studies were undertaken to determine if suitable steelhead spawning and rearing habitat were available downstream of the dam. Field surveys confirmed two small private dams along the Salinas River between Las Pilitas Road and Highway 58. These structures pose a significant obstacle to steelhead passage. In addition, the river immediately downstream of the dam was determined marginal for steelhead.spawning and rearing even if access were not a problem, due to limited riparian cover and land use impacts in the area. Suitable spawning and rearing habitat between the dam and Atascadero occurs in several tributaries but requires a unique combination of special hydrologic conditions to allow successful migration of steelhead. Based on these studies and surveys, it is concluded that the steelhead population below the dam is very limited and sporadic. The project related impacts to biological Council Agenda Report—Certification of EIR for the Salinas Reservoir Expansion Project Page 10 resources below the dam based on flow reductions have been determined to be insignificant, therefore no mitigation measures are required. Legal Review Several agencies expressed concerns that the revised draft EIR did not meet the legal requirements of the California Environmental Quality Act (CEQA). Based on these concerns, Council directed staff to hire independent counsel experienced in CEQA guidelines to review the document to insure that the requirements have been met. This review was undertaken and the document has been modified in several areas to address the concerns which were raised. The Final Environmental Impact Report for the Salinas Reservoir Expansion Project fully meets all requirements of CEQA and identifies all impacts and provides mitigation strategies for reducing or eliminating identified significant impacts. Project Milestones There are-several other steps which must be undertaken prior to proceeding with construction of the project. Certification of the final EIR at this time will allow the City to proceed with the additional studies and approvals required to determine if the project can be initiated in the future. The main issues that will need to be resolved prior to project approval include: 1.) resolution of the protest to the City's water rights permit; 2.) transfer of ownership from the federal government to a local agency; and 3.) development of the detailed mitigation/mitigation monitoring plans. Water Rights Permit The protest to the City's water rights permit was filed by California Sportsfishing Alliance (Ca1Spa). The resolution of the protest may require a hearing before the State Water Resources Control Board. Board staff have been waiting for the City to certify the EIR for the project so that the information contained in the document can be used for the resolution of the protest. Following certification of the document, City and Board staff plan to meet with representatives from CalSpa to pursue withdrawal of the protest based on the information in the final EIR. If the protest is not withdrawn, resolution before the Board will be initiated. The hearing before the State Board is likely to take 12 to 18 months to accomplish. Ownership Transfer The second major step towards project implementation involves the transfer of ownership of the dam and surrounding property from the federal government to a local agency. The U.S. Army Corps of Engineers is the responsible agency relative to the dam and surrounding property and has indicated a desire for many years to transfer ownership of the facilities to a local agency. The dam and related water supply do not serve a federal purpose, so federal ownership is not deemed necessary. Based on this desire, the Corps staff have indicated that the ownership should be transferred prior to modification of the facilities. Council Agenda Report—Certification of EIR for the Salinas Reservoir Expansion Project Page 11 Several years ago, the City Council supported transfer of ownership to San Luis Obispo County Flood Control and Water Conservation District. Subsequent to this action, City and County staff began discussions and development of the agreements necessary to protect each agencies interests relative to the transfer of ownership. The negotiations required significant staff time and took over a year to finalize. Prior to approval of the agreements by the City Council and Board of Supervisors, staff was directed to place the decision on hold until certification of the EIR for the project. Members of the County Board of Supervisors indicated reluctance to consider the property transfer until the EIR was completed. Following certification of the EIR, staff will again initiate discussions with the County relative to ownership transfer. Additional studies will be required by the Corps of Engineers to allow for the disposal of the federally owned property. In addition, the U.S. Army Corps of Engineers will incur costs for which they will require reimbursement from the City and County. Staff will return to the Council for approval of the additional studies and agreements necessary to implement ownership transfer. Detailed Mitigation and Mitigation Monitoring Plans The development of detailed mitigation and mitigation monitoring plans is not proposed to begin until the previous two issues (water rights permit and ownership transfer) are resolved or are sufficiently assured of success. Development of the detailed mitigation plans will require negotiations with private property owners which will require significant staff resources. Development of the detailed mitigation plans will be necessary prior to Council's approval of project construction, adoption of CEQA findings, and filing the Notice of Determination. Depending on the level of success of negotiations with private property owners, Council may have to make findings of overriding considerations relative to the project related biological impacts. Summary The Final Environmental Impact Report for the Salinas Reservoir Expansion Project has involved years of work which included extensive field surveys, studies and analysis. The final document addresses all the comments and concerns raised on both the initial and revised draft EIR's for the project. The document identifies all project impacts and proposes mitigation measures which are expected to mitigate the project related impacts to a level of insignificance in the long-term. It is anticipated that in the short-tens (5 to 15 years), some biological resource related impacts will be significant until mitigation measures are able to fully replace lost habitat values. FISCAL IIAPACT There is no fiscal impact associated with certification of the Final Environmental Impact Report for the Salinas Reservoir Expansion Project. Council Agenda Report—Certification of EIR for the Salinas Reservoir Expansion Project Page 12 ALTERNATIVES • No Action: If the Council takes no action on the EIR, staff should be given directions for subsequent action on this project. This action is not recommended since the certification is necessary to allow for the resolution of the protest to the City's water rights permit. ATTACHMENTS A.Resolution Certifying the Environmental Impact Report for the Salinas Reservoir Expansion Project B. Summary of Potential Adverse Environmental Impacts and Proposed Mitigation Measures C. Memorandum from the City's Natural Resource Manager RESOLUTION NO. (1998 Series) A RESOLUTION OF THE COUNCIL OF THE CITY OF SAN LUIS OBISPO CERTIFYING THE ENVIRONMENTAL IMPACT REPORT FOR THE SALINAS RESERVOIR EXPANSION PROJECT (SCH No. 92071018) WHEREAS,the City has published and made available for public comment an initial and revised Draft Environmental Impact Report for the Salinas Reservoir Expansion Project, in accordance with the California Environmental Quality Act and the City's Environmental Impact Procedures and Guidelines; and WHEREAS, the City has prepared a Final Environmental Impact Report (Final EIR) incorporating public comments and responses thereto and has made the Final EIR available to the public; and WHEREAS, on June 2, 1998, the City Council conducted a public hearing on the Final EIR. NOW,THEREFORE, BE IT RESOLVED by the Council of the City of San Luis Obispo as follows: SECTION 1. The Council hereby certifies, finds, and determines that the Final EIR has been completed in compliance with the California Environmental Quality. Act. The Final EIR has been presented to the City Council and has been reviewed and considered by the City Council.prior to approval of the project, (which approval shall occur at a subsequent meeting of the City Council). The City Council has reviewed and analyzed the Final EIR and determines that it represents and reflects the independent judgment of the City Council. SECTION 2. The City Council further certifies, fords, and determines that the Final EIR is adequate under the California Environmental Quality Act and that the potentially significant environmental impacts of the project will be reduced to a level of less than significant through the incorporation of the recommended mitigation measures contained in the FEIR, including Appendix D,into the project at the time of approval at a subsequent meeting of the City Council. Upon motion of , seconded by and on the following roll call vote: AYES: NOES: ABSENT: S-!3 the foregoing resolution was adopted this day of. ' 1998. 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SC ... wdy _y...wdO .0 aO m d 0 0 .0 O a >> a a 0 '0 oad d L e °C5°'° SL 4 d m da to a dai •Goa �p a�i a y° cCi > •o p,O, 0 o m ..00 3 •'Oo ._. m > _Z �c+ v m E v Ca W WC dd ° O m z • C• CC C ym W t.• y 'O '60. cLi 5 d E E W Q y m m .= a a C " m "�- v a o N y wdi —r6 ca n 5 rdii v = boyo. � nme w � � s =° E12. OLc°ao � � nc°iEEy F Q � w •. C W f/2 m y �" a a0 0o cpm - "� 0 m �. m r. W m 0 d W ai O C: 9 3 �C d 4m. 7 O F 5 'm 0 4) d cc v 0a' fl Ed d � c S:6 p" z � m � .3 O E 00 m cis r: 3 ° .. m 0 ° :: _ .x Qom°, as CL EC v m an m C m o V ui —dv C G m a O d GS^ 0 y d O0 0 r C O H _a > 0 y C y d m m O 0 d d d m CIOm E a oo y d m C 0 d d > Vm m V 'm6 'O p fn O rA « C tr Q C 4) m f%J W 4 P 9 � d c - c Lu V o v r Q c�. d u m W C H V C c W W • Y a 0 co o=o m •o u = r F, T e O v cur CIDQ - •a 2 8 = '� � N V O mcis O ., = y q =Cc �N.. O = 0 an u j0 qtj = m m N m u a o C, IE Qo 03 = Q e Q = CA o en m u a m o d o is to m d � 3 0 � � � d� � � � as �ZDa - � 0 0 0 = W U o -o is o cS C/� v rh N O N .- m a u m m za = > w � = 3N0r= ca gym -ww 0 o Q aqi 3 v .a u o o — e o v e0a chi fl = m ay ed qm °' a u .. mac az aYgim3 � EQ � � a N ai aaas0jN :9 o . m Z 0 L mE q .) e • = =o B•o 0 IS r a< cv oC m ° uaa : P 0 ' E 1411) v rr , 0 o m q N a .O d .q Qr x N = = O O Z0 = U Q s o C P+ a ,,, z N O = 'v WRei U < z m = at' e 'a m n 0 0.i O O E v,$ E a e N m u E 0 a a m _�• o �; m v CS ca 0 u ie fs. coo . ya 3.Yp � oQ a � o . s 2 P' u u `' — d ` o m a N L 7 5 7 V Z..= O y ' s QQ W Vo O O V N Cm V cuo U Q o o $ �+n "' ' m s 2 r7 a. C=m = a = z � 03 = F m3c`ia co x 0 a - v o m NYJ {_ •y N y a Vm N0 '� _ V v 0 W91. 0 `n. m F voice va W_ � 1 H m tr7 c $ �. 0 < a a _ < d Ea W a C < p < 3a g s--�7 W I� W V � ^ a % Y V C r, C6 v v E � �_ Ta e = =O W h Y a W V W w y _ q = o V d � C e QC = Y . Y Aaj y m d 7 0 = 07 7 Y E Y I.a e00 6 ci m a m = � O y y = w � eu _ F 3 E �Dm 165> E L = o m 0 0 0 a w y o .o a s m = W m y o y 4) r� 3 m m A 0 = c ^ 3 m = � �'e z d = d E ' e C v X n Om V u ami pap as '° = 460.2G E d t � � � c � epE � = ga' �y ,• Y -cc "Wo ors r- y W v1I = 3 ,m, � 0 ca o = W . ' O L l'1 d o e�er 0%m W o m C W m W e C:CO ^ ++ = Q R E m a o m� =Nnho E C = E m0 In 9eO` ` y nn ZO Toc3d aC4 fleeo; <r go 0 u cc 43 v L' mo L w e w d E _ Q' p = Tm E - L 'O ODd3 e� r� QNb OE 030 C' %q n -t en .. 'o m o a LE o L E v�eich .0 L d V m C � Nn �OO O O. ` y iy nen Fey N V3. = o < _ Ce y m E m o m . L o Co vi O o i 3 G _ 'Ocl � u co cd = u = > eu U a o... n u yr e o ? o c d e Deoa d a 3. S m <aorn` N C. N 4 'O Q V r r y r a C O F in 0. • _ N {�l � P C O C b F = ea a 3a s • U 6 C O « 2 C a3 C 6Cp O + C a7 4.= 0 C C 7 C ^OCD`Om0 d v � T 'O 66 CA .� W O %V1 d 00* a • = U `o a' 'o n.< CEo J este r >% 0 00430 FW E °oa>iaacc E 00. W 0.pi 'o' m es m z 3 s m a Cm� o s � ,, .. 3 0. m s s = a a ba °' 3 C6d 3 c. z o � pr > d 0 a>i .: FC. W rWi� Q a ° aoac o 00 W. W a EQ a. Us $ a • F Q a7 LL d 06 aal -e F. p 01 Q as a a d a as :: C C o as u o o > n. C £ e as .e a s m ; a °' 3 m ai e 3 = v F py ai 9 O m .0.. 3 O �r = d o _m m W 04-3 as a C C W u C O O u a A i = C c d m 3 " = z m m E C e ° o a£ai o c `C" 0 � .�.? g aQ £ A 6 V d ri e .6 .o w. — a Z m m = 1° o.o 0 o W. °' % c o W e `6 ° cii m q m 6 i d C o 0 C gm " V Oao sax m o .pa a dee mdl0zWday `�Q YoCa �W e ° a ia i« CL. 6fqe �a-m W - 0 CD M ca m N Y > 3 W 3 cc a0 .Z d C .yn m y O N a1 W m � d C C °� C cc F F m° m ami A 3 m E `o i = =W 3 a S 5 v m a o • a N y m fs7 a _ � C S � e Z h o O [s7 •co• c m C g Q ca .� ra u 3a > 5-4 W « U m 4 E 7 d a U 0 — Jabo 0 a Q _ C.. me d e a - =o u as a to IS cto F m `oso � o ' maoE � ov � > EE om CL s 0 •`. C w L ? m • d o C �r .7 d m o mo = e r o u m C e2! 0 Cts os w E d m= o 0 .0 oFri wZ iCc cmLcQV mY � °y •m ci d CoZ mv °m ° m ° o ao L) ooo•° o 's , = > m BrL as . ccU 1 & t C C o rLs ° Cm € o VmomoamaZa -0 g ydUa " 'ZC , Tdm« ° oo � `° roao to 0.4 T;I w F •EcCL mm .y_ =«my + •-�:r 'C U =«meot/D mVd o o U E e L 3 E F Q � A aw QCA 0 w0 O^� 14 A m . oQ � Q v T •C � U m O LL P S A O b z m F IE a Q a S-e�D 4r L d W O O O O m m OD.r �' Y J2 r ti V r. M p V O `� p. C u C �+ C 7 W W O tma = 4. W as y C L ^ V m W W .m.. .°O .Y as p O E ni �' L 'D 4, :+ p aLi `" .mC N 0 3 m a0 COL.. O m m p ° L q OCD O_ S ° � •'i d O y •1 ^ M C wn .� _p �. � E r C :s N m « N V y y r 3 07 4. � Q' L L _ V d 'O r C* r m C 9 O C ' K O « p E 00 O p h W W m C E c e o eZ m p � aei d C m 0 0 c m m 'o a = E `m' ... 1.0—, C C e e C = W .. 0 c e.�— c i0 vO :: >, d — C y C C .•'. .p C opi " C eD C �D m ° ^ y u .�... a r: v OCD OD OD— m O to m W 3 OD q aD V� " d C m sae p d s u inyy � OaW � aas° _ 5 vi :. Ea W Ew ° 3 � 3 ° D: • 'v � h 3 v '> v � W • • 0 F � dee q •e e w oar � 034. 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R u n %m = % .= Z :. ._. 7 0 - m C w is Co C ._� 7 �. O Q L 3 a' o. a 'm m m c y CD E u ° e c e E v o > > � E „;S r c = u m 0 W q » u u4. ._ m = 0 Ea(, Y m u4` � •O O � L Y � U9.9 a> 'C =rn m ° w 5 = CLO E o o m m rn : . to CD a=i E a 3 c m :. a U o u •� Q W m Qo d � o r^ L r: ._ Z.. 0 ., d w 'a m Z Q m Coa :. « y d Grp is x � = = o z 2 _ M � £ y ,.. W � 0 = uu aEi aEi e Q o > = _ a m ot = W a+ ►V.r o S .0 E u a vn E �e W � m Q w O T W Q O c m m w o O U o Lm W = � •= d •C o o Q u � as 0 = ai u 7 = 7 s -'. s L o v v E a = c co o- E .xyQaso aC9Eoep � m eo •'� o U C360 W — = %. O.« �= IG Ep � 0 C �V " _ > C m � ami B �y u % ca y = y L •� y L t LL, =, QY Ey G .=u.. E y C aui m y d 0 > a=i = au+ u O s o c a y $ 3 3 � a° v hUU � c < } LL m OI A O O m U � k7 Q Q c CO W N Y3i1 ✓ CJ e C Ldppp" V 00 m+ C � � •DTa�i •� L C 3 G 'O V �r = v � N 7 m Y V d d 'r_• V �.• tcCJ mi u 6 � a 0 (D e G 4 W _ V 00 L Can C C m aD 00 d H 'v i�. 7 m � r "'• n E„y m0 C m 0 4.. A vi C. C. d ? y it 4 0 0 0 4) Q C — a1 •� 7 C O 0 0 •- 0. n oa m ° '° 4) 0 o m a V1 C •- c d p a � L H d p = d E aE an r m G V m m _• 61 N r0 0 0 OG 10.. y' Naw I rm 93 EEoa EVA d °T' o an 40 >.� -0 Cc* Z 0 4 d € Q 0 m $ a = p p m go Q W O o 1 m 0 « " m V � N _ L .D o ; d a 1O u cc ��j Z ��1 Co .°'c a aci CJ E e gym• E m 0 a z Q F. C eo uNi an d `. ca L E d c " E d ca �� 47 `� W H d m —cv `°" c E m m m °m' H p aEi m u E Wtci) a c CL. C, o d� � � s N ai V' L c L e L N L L fl E E v v 3 N m m Z 1 CO ~ W Q Q w 10 LA o 4) a"isN, E 3 a' ECS J0 L O d a) 4r .. O .O. C 0 m L O _ 3EcZdN ea � goc do, m � a Z Q U'ra � .� c EUO+ ap m m F N m u Q` is m c : E o ._ d u p T o dOv, 3 4) tic J= ,, .0 0 CL. Q no a o w c e m aci a Z m E ,� �- e . ep, y o c p 3 L o o d ° o d a �T+ d cmi '' m _ v 0 .- c v° v m ua v v OQ E vcwm �' aivS c oo . NE ca 0 a m 93. U W 4) 7 7 _c = 7 r .V O 4) 0 d U �' - vE occa e°° 3D. m • — c _m i md N $ - 3 E 3L' aao as .7o C Q mN = ` GO a) m c u3vo0 EE O . LN C13 0L ro 0 -0a) c m d N m $ Is '+ = d v c d p CO acv a � i 3 m a G v U c`+.m a JS F m96 N m m a ti u yu V f (Uig Q 0 f U a < C q [s] _ _ a < ZU � o ;0 acs .N < .. .3CC .� • S-Z3 W W rE� � L r u s N a .. m u u V u V = C ba 00 to OO'N d us r r 4= F FK • e • V y ° Ea e 'o cc o o d m s 3 ,v o m __ d v E v t 0. e m E c aUi m y ` m y m m °N Ay o E ~ CV C U y y d u O '- y m � Q Q� C an d 0 > y c y H C m C m E 0 8s d v = v cc m d o 1:6-0 0 G. Z v� U v 06 y � s -Y.m s N N y 3 oG y ° m p cc s c te m o A d N _ y _ m o • a' _ a m m d c.. _ N V Z Q c a'j3 d s e 0 -0 E X oa E d >o d u o co as m u C W ? o Ca .d. d u 'V m y m ie w t w aj m m " �° = ycis b a�m �- N t m s v m _ Lu v E m e 2 v CD 3 m m 0 v m r aci V 'O an d a o - m t 3 c c m a d Emom ° E .3 � � > = cE � '3E WQ '� E ami c = � _ � o3 � m :: > o y OD W C o, a ° � ° � aas 8 E ° :: o — ° Eu c o = me m ai (' m > ° " o m N d d = E E o E s m o a� = cti .ai v E E is :5 cC %° v > :_ °' ° e E _ > cv p > "" W Q c � F QQ e a m O N N f c y O = O C 9 s D y C m eo �.., ° e u d d > E U [� = m d w 2 H ° 3 u Ca wO �. r .w O N 'D a v c ° ami " F, o'er c � Y. W v ` � an d L w mo Pr G d m v oo m ami m Lr, 'Z Q, o o a CL W Y� .O„ m L' a 2 E o m Q E o m E ' a Q m ` > H > y o 03 °- c 12. Ocmg a m �. m m mCm V y I.w m m d O tma O O H G � m € d C 61 .' G' m •o e o ° e m o �+ e s d c ; 3 :. cc d '� d e T V •O •m l C a _ co O ce Q W Cc y 4. o o N o E - S o c a; m Y 3 Y a c a m s amj m f� N 7 a E ° ar CL. � 0 oNe oEo2om 0 a a A to E o a. m w lL m m rn a P L S q ° Z Z U < F m u DW faAN � C a �] a CC > < FU i • W « d p=p e=0 •0=D CLO m C C C z y r r Wcc rm • • • • UAm Otto N m = = = p d 00 ° = ` u E v u y d � oSc `omd o � h a E oo `o W eo o M 'o m C. Y .° E QY C v C •i0 m V E cis u d es Zii 91o � a > Cmc = C.) w N ¢ u v m o a o q t E m r .V+ id m Q+ 00 N = .m•. m m �• p Is o = Rasa y �° mz r � ZQ o � .mYuz0. m 65d s Ow o 00 » asp .o` ,e°' v to Eas V ON O C ti O m v 3 S. "Cc* C) foo ani =°. E0.` U°_ m I cn � Q �••� m tL V d 00 4.. v 3 V �'N d V9 a d 3 V c c Z -a m U o a m ^ q `•° a c' a� Z O E . _ o V y N d N 0t a = v m c m c ai H m N V a• C _ « m C13v p F•' C. 0 2 = ci �:. C2 = s o m o s E w v m a� w e s o ca ' m e d ao 0 0 m �., `m d s °`' v Z m v.-` —vim, a"i a=i = E E _ a m = Q LTM Q > r m 3 00 v �„ o = JD d m o 3 0 7 2 :o ,i0`„ eo u _ m m a = a C.. `yr 5 € •� m ° d ui H •"o .. 'o ° y m ami •0 a o d m c a•m 0 "o�r a r m m•O m E _ m .•m 3 a=i a� N. m e 0 a. y H o E o $ o o m E to N N 3 3 G o = o .. z.- -a se = " '� m ° E m `o u 3 = c o m c > a E eo u e U o °-' e q r o < a� �no.o 'cnma o`oa a N IL IL N S F e Z W � o: go, S2 3 a F � W o C rh CZ 3 Z U a r 5-Z.5� W W V V 6 cm .y .N tyi • • N U moe Q toQ 0. so E d •� � N E o CIO a 2 y e a a d C a m o MIC _ u otr = � c0 CCI 'oma M C ee o N ao d d c 'Q m � V2 w Hc- Oa� 3Em '° w � N 47 � •� 'v C to m Q w y d a N N Z C 'D. d y a � _ : ., CLO m O 3 3 v ,•,,O Q O QO v c� .r W N d o :: m C. to C '' L Q E d E o e Q u v w [/WEU W w�] 0ae ° E =' .' l e CL. im > AepO . °: vy Q. a 0e° Z E O .�0, ° N = W aw TTa°s m N y WW >, 0 3 b 4) E d o " C3 �, - E Q �e v ? .� E m m d N > d $ F O c ° on•- m o o d v d N fl o i7 V 3 y „ el z ° C7 Y Z D d to ¢ o f t.: — E rQ V. '0 o d = w o ea d T N >, N0 ca ca h W 1 y C r 0 O C � ° M E C O a 0 O (� E >► O O '9 m .A O p m 3 d d e°'„ y eu'o > v a a e E 'x e m ` 3 0 o E V N N p 7i E m m a e Opo = v >, = c•m o o y t a cVa E t •LQ o (� Q a E — o oew a= - a mom. p :: '- agy ,�, hd - c30E E a � " '= .a03a � fimE 3a"°o o 0 cc�, Edoac= >, M = 0 c a_ �i 'red' eC m a y t,-°„ d m u e,°. y� ° ea T ` •_ 'a 3° o w = o m e ° aai >, 3 `a•v e° `` � � _ o c 00 .0 m 3 cDO .o u e o o d a 0 e ' d _ R O m = 6 p ` y V ° °° y T FA C T E O .'�.. d ° O 6) N O N a O d N U R t= M Y d l6 o N 0 u t E � >+ N d $ m O Y O° p ,�, �°, p t m t� v a' C v vii `oi i C v •-`- m m d ° e 11. 0 v d W d 3 00 � X FF o d o 0 0 0 ; r u CL. d .o k CO m ,. v � .. a 's 'N a F .. c ej a ci a._ 3 as .o a at a m Cb V ti U2 0.2 rA • a pQ � � % 4yi Z t.7 3 Se W LL Y C m t — A OO— y .°. � p u h W UY C Y Y Y m v u v F � C �0 00 pCp OCO O=0 � d OC • e • • ` m � s F s is r c U 3w _3o e a u a m sc. o k7 c M d e - v eC m Q m s Rtw 5 m 3 'c a ami Q a m T m oo .. W m � wca a Do r OD— VJ a � as = d � cr Eq ISI M Q 0 C � 0 H � o y �' V $ D a m C c ° d W rWi1 � a cm c4) LL ., L E a U m c Q , ••za s N > E Pr • • • • m LSI] M > m u u = F J W 3 m= " `` m �. S m p N 40U VJ m 7 3 .ami e u .a 'v Q m v] E o m p ° s -m+ -a 2 m a C o Q 9 = m d °m E y E vd a m m i zw m � ami0' dH = a � .. o0 oc� mo W s :2m m R+ E m 3 .gym_' e s o o b a ami a' = v. �6 ° o c Z o 3 a s 3 °u Ca o; m `om c u mai 3 do m m ° m m CL z E m e V .c u 9 m m m e to GTM p y i MW Z+;a s t aci a o 2 c o ami v ; a Z -a p Q. s E = 3 = = o m = .- m m os y i m di O O' H C m m 0 e m 'O �` m m •o a`� m = a = r a' L 40 E e s as o. Y II o E U > c 8 C ca M a Q y a; o o m , m m is o S Q 6: S o 00 p m c .d m E E `^ ca o m o i • m `m yE � u 'o TA H m, o m s a = oo3m cs v3 amz es ?J ancisCJ ao m ocsd U E C a too -0 m o u es� ca 3 c• y F a . • w i a LL u w = C 8 3 Q n W u fry u C u > erg L a .. pp G MEMORANDUM DATE: May 22, 1998 TO: John Moss, Utilities Director FROM: Neil Havlik, Natural Resources Manager P71� . SUBJECT: Mitigations for the Salinas Project At your request, I have prepared this memo as I will be unable to attend the City Council meeting on June 2, 1998. The purpose of the memo is to share my view as the City's Natural Resources Manager of the overall issue of impacts of the Salinas Reservoir Expansion Project, mitigation of those impacts, the community's commitment to mitigation, and our prospects for success. Since starting to work in the position of Natural Resources Manager for the City of San Luis Obispo in February 1996, 1 have been struck by the scale of the impacts of the Salinas Reservoir Project , the City Council's and staff awareness of the magnitude of those impacts, and the honest desire and intent to truly mitigate for them. The impacts are significant. They involve disruption (albeit temporary) of the recreational use of the reservoir. They involve the inundation of over 300 acres of land that is currently above the high-water level. Associated with that inundation is the loss of oak woodland and pine-oak woodland habitat, grassland habitat and, most significantly, a high-quality riparian woodland habitat at the upper end of the reservoir where the Salinas River enters it. Other impacts, such as to the downstream flow regime, groundwater recharge, and effects on aquatic species in the Salinas River below the dam appear not to be significant and not requiring mitigation. City staff, the City Council and most citizens with interest and/or knowledge of the site recognize that the impacts at the lake are very significant. This is perhaps one of the most ambitious projects that the City of San Luis Obispo has ever undertaken. In the spirit of that recognition, the City staff created the Mitigation Advisory Committee (MAC), wherein a number of interested parties, countywide, were asked to provide input into what would be appropriate mitigations for the impacts of the project. It was made very clear to these individuals that their participation in the MAC would not be construed by City staff, nor be advertised in any way, as representing endorsement of the project by those individuals. By doing this, City staff was able to elicit the positive input of individuals who may have been (and may still be) opposed to the project. But, by doing so, the effort was able to utilize local expertise and better understand people's perceptions of the project and what would be expected of the community to provide true mitigation for project impacts. Following conclusion of the MAC process, the City's consultants undertook considerable evaluation of lands around the reservoir to look for areas suitable for mitigation. This was broken into two efforts: (1) mitigation for the upland impacts (oak EXHIBIT C woodland, pine-oak woodland, and grassland) and (2) mitigation for riparian woodland impacts. This evaluation led to the identification of as many as eight areas that would accommodate mitigation for one or both of the impact categories. A part of my role as Natural Resources Manager is to assist staff in judging the environmental effects of some projects, including whether mitigation is acceptable, or whether the project should be modified because of environmental impacts. After giving a great deal of thought to the project and its biological impacts, it is my professional judgment that the impacts of the Salinas Dam Expansion Project are capable of mitigation. This is not to say that such mitigation will be easily accomplished; it will be quite a difficult thing to do. However, I do believe that the expertise is available to permit true mitigation to be undertaken as part of this project and incorporated as an integral part of the project. I also believe that the sites which have been identified in areas surrounding the reservoir have favorable soil and climatic conditions that will lend themselves to the mitigation efforts. Thus, while indeed-the impacts of this project are significant, I believe that mitigation for them can be successfully accomplished. No one is happy about the impacts of the project on the beautiful environment of Santa Margarita Lake. It should be pointed out, however, that after the project is completed, Santa Margarita Lake will still be a beautiful place, and it will still have a healthy environment surrounding it. We have identified areas where the oak woodland has been destroyed and can be restored. We have done the same with riparian areas. So we have mitigation that is doable. It will be difficult. It will be challenging. It will take time. However, if this project goes forward we will have an opportunity to set a new standard of mitigation, and it will be true mitigation. The key ingredient is commitment, and it is my observation that the City has demonstrated sincere commitment and dedication to doing the best possible job in mitigation that can be expected of any community. - GtaAk.moss.memo s=�5