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R-10700 - ADDENDUM TO THE FINAL ENVIRONMENTAL IMPACT REPORT FOR THE NACIMIENTO WATER PROJECT AND AUTHORIZING AN AMENDMENT NO. 3 TO THE NACIMIENTO PROJECT
RESOLUTION NO. 10700 (2016 SERIES) A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN LUIS OBISPO, CALIFORNIA, ADOPTING AN ADDENDUM TO THE FINAL ENVIRONMENTAL IMPACT REPORT FOR THE NACIMIENTO WATER PROJECT AND AUTHORIZING AN AMENDMENT NO. 3 TO THE NACIMIENTO PROJECT WATER DELIVERY ENTITLEMENT CONTRACT REFLECTING AN ADDITIONAL ALLOCATION OF WATER TO THE CITY WHEREAS, the City of San Luis Obispo ("City") is a municipal corporation and charter city; WHEREAS, the City is a participant pursuant to the Nacimiento Project Water Delivery Entitlement Contract ("NWP contract"); WHEREAS, the City was a responsible agency under the Nacimiento Water Project Final Environmental Impact Report (the "NWP FEIR") which was certified on January 6, 2004; WHEREAS, under the NWP contract, the City is entitled to receive 3,380 acre feet of Nacimiento water; WHEREAS, the City joined other participants in applying for an additional delivery entitlement in accordance with applicable provisions of the NWP contract; WHEREAS, the action would proportionally distribute reserve water as an "additional delivery entitlement share" among participants. In the City's case, it would receive an additional delivery entitlement of 2,102 acre feet of water (the "Additional Allocation"); WHEREAS, the City has analyzed the potential environmental impacts of the Additional Allocation and has prepared an Addendum to the NWP FEIR (the "Addendum") pursuant to CEQA Guidelines section 15164, because some changes or additions are necessary and none of the conditions described in CEQA Guidelines section 15162 calling for preparation of a subsequent EIR have occurred; WHEREAS, the City Clerk has caused notice to be duly given of a hearing in this matter in accordance with law. NOW, THEREFORE, BE IT RESOLVED, by the Council of the City of San Luis Obispo as follows: SECTION 1 That the City Council hereby adopts the Addendum attached hereto as Exhibit A and finds that it has been completed in compliance with CEQA and the State Guidelines. R 10700 Resolution No. 10700 (2016 Series) Page 2 SECTION 2 That pursuant to Public Resources Code section 21152 and CEQA Guidelines section 15094, the City Clerk shall cause a Notice of Determination to be filed with the San Luis Obispo Clerk Recorder and the State Office of Planning and Research. SECTION 3 That the City Council hereby authorizes the Mayor to execute Amendment No. 3 to the Nacimiento Project Water Delivery Entitlement Contract reflecting an additional allocation to the City estimated at 2,102 acre feet per year substantially in true form attached hereto as Exhibit B. Upon motion of Council Member Christianson, seconded by Council Member Ashbaugh, and on the following roll call vote: AYES: Council Members Ashbaugh, Christianson and Rivoire, Vice Mayor Carpenter and Mayor Marx NOES: None ABSENT: None The foregoing resolution was adopted this 15th day of March 2016. Ma*aMarnx ATTEST: Lee Price, MC Interim City Clerk R 10700 Resolution No. 10700 (2016 Series) Page 3 APPROVED AS TO FORM: J. 9firistine Dietrick ty Attorney IN WITNESS WHEREOF, I have here nto set my h d and affixed the official seal of the City of San Luis Obispo, California, this day of Lee Pn , MMC Interim City Clerk R 10700 Resolution No. 10700 (2016 Series) EXHIBIT A, Page 4 mrs California Environmental Quality Act (CEQA) Prepared for. City of San Luis Obispo Utilities Department 879 Morro Street San Luis Obispo, California 93401-2710 Prepared by: Marine Research Specialists 3140 Telegraph Road, Suite A Ventura, California 93003 February 2016 )roject act Resolution No. 10700 (2016 Series) EXHIBIT A, Page 5 Table of Contents Table of Contents Tableof Contents........................................................................................................................... i 1.0 Introduction and Background.........................................................................................1 2.0 Project Location and Regional Setting........................................................................... 2 3.0 Description of the Approved Nacimiento Water Project .............................................. 5 4.0 Description of Proposed Changes to the Project............................................................ 7 5.0 Evaluation of Environmental Effects.............................................................................. 9 6.0 Environmental Impact Analysis...................................................................................... 9 6.1 Hydrology and Water Quality........................................................................................... 10 6.1.1 Analysis of the Revised Project.............................................................................. 10 6.1.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ...................... 11 6.1.3 Conclusion.............................................................................................................. 11 6.2 Geology, Seismicity, and Soils......................................................................................... 11 6.2.1 Analysis of the Revised Project.............................................................................. 11 6.2.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ...................... 12 6.2.3 Conclusion..............................................................................................................12 6.3 Drainage, Erosion and Sedimentation............................................................................... 12 6.3.1 Analysis of the Revised Project.............................................................................. 12 6.3.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ......................13 6.3.3 Conclusion..............................................................................................................13 6.4 Air Quality........................................................................................................................ 13 6.4.1 Analysis of the Revised Project.............................................................................. 13 6.4.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ...................... 14 6.4.3 Conclusion..............................................................................................................24 6.5 Noise................................................................................................................................. 24 6.5.1 Analysis of the Revised Project.............................................................................. 24 6.5.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ...................... 24 6.5.3 Conclusion..............................................................................................................25 6.6 Hazards and Hazardous Materials.................................................................................... 25 6.6.1 Analysis of the Revised Project.............................................................................. 25 6.6.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ...................... 26 6.6.3 Conclusion..............................................................................................................26 6.7 Biological Resources........................................................................................................ 26 February 2016 i Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 6 Table of Contents 6.7.1 Analysis of the Revised Project.............................................................................. 26 6.7.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ...................... 27 6.7.3 Conclusion.............................................................................................................. 27 6.8 Cultural and Paleontological Resources........................................................................... 27 6.8.1 Analysis of the Revised Project.............................................................................. 27 6.8.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ...................... 28 6.8.3 Conclusion..............................................................................................................28 6.9 Land Use........................................................................................................................ 6.9.1 Analysis of the Revised Project........................................................................... 6.9.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ................... 6.9.3 Conclusion........................................................................................................... 6.10 Utilities and Public Services.......................................................................................... 6.10.1 Analysis of the Revised Project........................................................................... 6.10.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ................... 6.10.3 Conclusion........................................................................................................... 6.11 Transportation/Circulation................................................................................... 6.11.1 Analysis of the Revised Project................................................................. 6.11.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ......... 6.11.3 Conclusion................................................................................................. .. 28 .. 28 .. 29 -29 .. 29 .. 29 .. 30 .. 30 .. 30 .. 30 ............. 31 ............. 31 6.12 AestheticsNisual Resources............................................................................................. 31 6.12.1 Analysis of the Revised Project.............................................................................. 32 6.12.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ...................... 32 6.12.3 Conclusion ....................... ....................................................................................... 33 6.13 Agricultural Resources...................................................................................................... 33 6.13.1 Analysis of the Revised Project.............................................................................. 33 6.13.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ...................... 33 6.13.3 Conclusion..............................................................................................................34 6.14 Recreational Resources..................................................................................................... 34 6.14.1 Analysis of the Revised Project.............................................................................. 34 6.14.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ...................... 35 6.14.3 Conclusion.............................................................................................................. 35 6.15 Socioeconomic Resources................................................................................................ 35 6.15.1 Analysis of the Revised Project.............................................................................. 35 6.15.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ...................... 36 February 2016 ii Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 7 Table of Contents 6.15.3 Conclusion..............................................................................................................36 6.16 Environmental Justice....................................................................................................... 36 6.16.1 Analysis of the Revised Project.............................................................................. 36 6.16.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance ...................... 37 6.16.3 Conclusion..............................................................................................................37 7.0 Cumulative Impacts........................................................................................................ 37 7.1 Interlake Tunnel Project.................................................................................................... 37 7.2 Cumulative Effects............................................................................................................ 38 8.0 Growth Inducement........................................................................................................ 38 9.0 Conclusion....................................................................................................................... 39 10.0 References........................................................................................................................39 List of Figures Figure 1 Schematic of Treated Water Option......................................................................... 3 Figure 2 Schematic of Raw Water Option.............................................................................. 4 Figure3. NWP Water Allocation............................................................................................. 7 List of Tables Table 1 Table 2 Tentative Nacimiento Water Project Allocations..................................................... 6 Operational GHG Emissions, metric tonnes........................................................... 23 February 2016 iii Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A. Page 8 EIR Addendum 1.0 Introduction and Background The Nacimiento Water Project (NWP) Final Environmental Impact Report (EIR), adopted in 2004, contains a comprehensive disclosure and analysis of potential environmental effects associated with the construction and operation of water delivery pipelines. The purpose of this Addendum is to provide clarification of the changes to the Project water allocations and to provide explanation supported by substantial evidence as to why these proposed changes will not result in any new impacts or any increase in the severity of impacts addressed in the EIR. California Code of Regulations title 14 ("State CEQA Guidelines"), sections 15162 through 15164 discuss a lead or responsible agency's responsibilities in handling new information that was not included in a project's final environmental impact report. Section 15162 of the State CEQA Guidelines provides: (a) When an EIR has been certified... for a project, no subsequent EIR shall be prepared for that project unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more of the following: 1. Substantial changes are proposed in the project which will require major revisions of the previous EIR... due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; 2. Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or 3. New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete... shows any of the following: (A)The project will have one or more significant effects not discussed in the previous EIR; (B) Significant effects previously examined will be substantially more severe than shown in the previous EIR; (C) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or (D) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative. In the alternative, where some changes or additions are necessary to the previously approved Final EIR, but none of the changes or additions meet the standards as provided for a subsequent EIR pursuant to State CEQA Guidelines, section 15162, then the lead agency February 2016 1 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A. Paee 9 EIR Addendum or responsible agency is directed to prepare an Addendum to the Final EIR. (State CEQA Guidelines, section 15164). Further, the Addendum should include a "brief explanation of the decision not to prepare a subsequent EIR pursuant to Section 15162," and that "explanation must be supported by substantial evidence." (State CEQA Guidelines, section 15164, subd. (e).) The addendum need not be circulated for public review, but may simply be attached to the Final EIR (Ibid.; State CEQA Guideline, section 15164, subd. (c)). 2.0 Project Location and Regional Setting The NWP included two equal water delivery options that were evaluated and compared equally throughout the EIR: a Treated Water Option and a Raw Water Option. The proposed project location is shown in Figures 1 and 2 for the two co -equal alternatives that were considered in EIR. The proposed local water distribution pipelines and facilities are located throughout a wide area of San Luis Obispo County between Lake Nacimiento and the City of San Luis Obispo. San Luis Obispo County is bordered by Monterey County to the north, Kern and King Counties to the east, and Santa Barbara County to the south. Lake Nacimiento is located 16 miles west of the City of El Paso de Robles (Paso Robles), near the northern border of San Luis Obispo County. Elevations in the project area range from sea level, near Cayucos along the coastal plain, to 1,577 feet above mean sea level (msl), north of the Cuesta Grade. The project area transects three broad physiographic regions: coastal mountains and valleys, interior mountains and valleys, and a coastal plain. Lake Nacimiento is located in the Santa Lucia coastal mountain range. The Santa Lucia, Temblor, Caliente, and La Panza ranges form a part of the Coast Range Mountains which extend across the County in a northwest to southeast orientation. The highest peaks, many over 3,000 feet msl, are located in the Santa Lucia and Caliente ranges. Although none of the mountain ranges in the proposed project area are particularly high, the terrain is quite rugged. The cities of Paso Robles and Atascadero, and the communities of Templeton and Santa Margarita, are located in the interior valley within the La Panza Range. Major water courses in the interior valley north of the Cuesta Grade are the Nacimiento and Salinas rivers and Santa Margarita Creek. Major streams include Paso Robles, Santa Rita, Graves, Atascadero, San Marcos Creek and Yerba Buena creeks. South of the Cuesta Grade, major water courses in the project area include Stenner and San Luis Obispo creeks, Laguna Lake, and the Morro Bay Estuary. Major drainage basins include the Lake Nacimiento Watershed and the Salinas River. Several westwardly trending lesser drainages in the Morro Bay and Cayucos areas occur along the coast. The Salinas River system drains a large basin in the northern interior of San Luis Obispo County. This river is the largest single watershed in the Central Coast area and flows northward into Monterey County and eventually discharges into Monterey Bay. February 2016 2 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 10 Figure 1 Schematic of Treated Water Option 111 r Lake Nacimiento Intake PIS Heritage Ranch Camp Roberts EIR Addendum LEGEND Recommended Pipeline Pump Station PIS Reservoirs -♦ Water Treatment WTPlntiP San Res • j x Miguel Connection to — X Cake WTP1 Turnout Existing System Na�m16wo 4a Salinas River G14 Crossing 'p, a 46, Paso Robles am Templeton Whale Rock ReservoirlDam or 4+ \Cayucos CSA -10 Morro Rock MWC Lewis Pollard Trust Cuesta Tunnel Ras. Rock Pipeline Cilli Existing rp ,.g xIa/Ie CtI,rlCCvesta rrt] y San Luis .�ne�f IAlTP Tunnel CUS0 Source: San Luis Obispo County, 2003. Atascadero Rocky Canyon Road Reservoir and Road Salinas River Crossing x Scan LUIS O1 Camp San pbtsp© Los Osos Luis Obispo MPTP Santa 1 Margarita San Luis Obispo 227 AirportFiero Ln Wtr Co Area x CSA2N Edna Valley MWC February 2016 3 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 11 Figure 2 Schematic of Raw Water Option EIR Addendum Nacamte�itvRi.'cr - LEGEND Reservoir/Dam Lake Nacimiento Intake PIS Recommended Salinas River Cayucos Pipeline Atascadero to Crossing CSA -10 Morro Rock MWC 0 my, Pump Station PIS Heritaa 'N River Discharge Ranch'A Camp Roberts Reservoirs Cuesta WTP WTP tot Connection to —x Res_. PIS San Existing System take Miguel TrcP_a tment n r_ Treatment vete%, WfP Nac;miento Ci1SD —� ` _ . -. Tunnel I s Salinas River x 0111 Crossing Camp San Obispo 'p, Luis Obispo MP Paso Robles Templeton W Rock Rocky Canyon Road Reservoir and PIS Reservoir/Dam orWhale Salinas River Cayucos Atascadero to Crossing CSA -10 Morro Rock MWC Santa Margarita Pipeline. 'N Lewis Pollard Trust Cuesta Whale Exislingl Tunnel Res. Rock k Pipeline New CSanta Pipeline ` �pk' ;y' a CMC Margarita iro San Luis Y vete%, WfP Existing Cuest Ci1SD —� ` _ . -. Tunnel I s 0l x San Luis Camp San Obispo Los Osos Luis Obispo MP San Luis Obispo 22' Airport — Fiero Ln Wlr Co Area x CSA22 V Edna Source: San Luis Obispo County, 2003. February 2016 4 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 12 EIR Addendum 3.0 Description of the Approved Nacimiento Water Project The proposed project was in response to San Luis Obispo County's need for future water supplies and to supplement existing groundwater sources. The NWP would potentially supply up to 16,2001 acre feet per year (afy) of water to augment the existing water supplies in various communities within San Luis Obispo County. The main objective of the NWP was to provide a reliable supplemental water source for a variety of uses within San Luis Obispo County by supplementing the local ground and surface water supplies with a new surface water source. The objective was also to increase reliability of water deliveries, to improve water quality and to lessen the extent of future ground water pumping to existing residents and provide sufficient supplies to support planning objectives in various communities of San Luis Obispo County. The objective of the project was, therefore, to ensure better management of water resources throughout the County. The San Luis Obispo County Flood Control and Water Conservation District has a 17,500 afy entitlement from Lake Nacimiento per agreement executed in 1959 with Monterey County. Of this 17,500 afy, 16,200 afy was slated for this project and the remaining 1,300 afy was reserved for local lakeside use. Fifteen (15) purveyors submitted their requests for Lake Nacimiento water. Of the 16,200 afy available for the project, 13,575 afy was being requested; the remaining 2,625 afy was considered a County -owned contingency capacity. Table 1 shows each purveyor allocation request and requested peaking factor (percent of extra project capacity requested by the purveyor) that was evaluated in the EIR. After the Nacimiento Water Project was approved, only four purveyors decided to join the County and participate in moving forward with the project: Paso Robles, Templeton, Atascadero and the City of San Luis Obispo. The NWP included two co -equal water delivery options that were evaluated and compared throughout the EIR: Treated Water Option and Raw Water Option. Both options include construction of the water intake at Lake Nacimiento, water storage tanks, pump stations and a 64 -mile water transmission pipeline. The differences between the options are that the Raw Water Option includes construction and operation of three water discharge facilities. Construction and operation of these water discharge facilities would be the responsibility of the purveyors benefiting from the water (Paso Robles, Templeton, and Atascadero). The Treated Water Option also includes construction and operation of a central Water Treatment Plant near Lake Nacimiento on Camp Roberts' property. Numerous potentially significant impacts were identified for the proposed project, most of which could be mitigated to a level considered less than significant (Class II). Two significant (Class I) impacts were identified for the proposed project, both the Treated and Raw Water Options, and are summarized below. Significant (Class I) impacts are associated, in general, with two aspects of the proposed project: the significant air pollutant emissions in the region that would occur during construction and growth induced by availability of additional water in the region, which are summarized as follows: 1 One acre foot equals 325,853 gallons. February 2016 5 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 13 Table 1 Nacimiento Water Project Allocations Evaluated in the EIR EIR Addendum Water Purveyor' Allocation of Peaking Factor % . Flow Rate__ m d cfs San Miguel CSD 610 10 0.60 0.93 Paso Robles City 4,000 30 4.64 7.18 Templeton CSD 250 30 0.29 0.45 Atascadero MWC 3,000 30 3.48 5.38 Santa Margarita Ranch 200 10 0.20 0.30 CSA 23 -Santa Margarita 100 30 0.12 0.19 San Luis Obispo City 3,380 10 3.32 5.14 Camp San Luis Obispo 200 10 0.20 0.30 San Luis CUSD-Morro Bay 55 10 0.05 0.08 CSA 10A Ca cos 80 10 0.08 0.12 Lewis Pollard Trust-Cayucos 50 10 0.05 0.08 Morro Rock MWC-Ca cos 30 10 0.03 0.05 CSA 22 -Airport Area 890 10 0.87 1.35 Fiero Lane WC -Airport Area 30 10 0.03 0.05 Edna Valle MWC-Airport Area 700 10 0.69 1.06 Subtotal 13,575 15.25 23.59 San Luis Obispo County (Contingency) _ 2,625 10 2.57 3.98 Pipeline Total 16,200 17.82 1 27.57 Reserved or Lakeside use 1,300 NA NA NA Total Allocation 17,500 Note: * Peaking factor is the percent of extra capacity requested by the purveyors to allow short term flows higher than the average of their yearly allocation. For the purveyors that requested no peaking, 10% has been added to allow for system downtime. afy =acre feet per year; mgd=million gallons per day; cfs=cubic feet per second; MWC=Mutual Water Company; CSD=Community Services District; CSA=County Service Area; WC=Water Company; NA=Not Applicable 1. Participating purveyors include Paso Robles, Templeton CSD, Atascadero, the City of San Luis Obispo and CSA l0A Cayucos and are collectively referred to as the Nacimiento Project Partners. • Air Quality AQ.1 Construction activities would generate air emissions that would impact air quality in the area. Air pollutant emissions during pipeline and facility construction would exceed the San Luis Obispo County Air Pollution Control District's significance thresholds, even after implementation of all feasible mitigations. This impact would only last during the construction of the project, with air quality impacts during project operations being less than significant. • Growth G.1 Countywide, the growth inducing impacts of accepting supplemental water supplies from the NWP could be considered significant, adverse and unavoidable. However, local impacts could vary depending on how project supplies are used by each project participant. February 2016 6 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A. Page 14 EIR Addendum Several less -than -significant impacts were also identified for the Raw and Treated Water Options of the Project. Again, most of these impacts were identical for both options. While these impacts are considered less than significant, they represent the only differences between the two options that can be used to evaluate advantages or disadvantages of each option. 4.0 Description of Proposed Changes to the Project Current Nacimiento Project Partners have subscribed to 11,405 acre-feet of the 17,500 acre-feet available. 6,095 acre-feet remain unallocated or in "reserve." Reserve water is the water available above what is currently allocated among the project participants (see Figure 3). Figure 3. NWP Water Allocation The Nacimiento Partners anticipated that once the NWP was built, other entities would come forward to purchase a permanent allocation from the available reserve water. Since no entities had requested to permanently purchase water since deliveries began in 2010, even in the extraordinary drought conditions in effect in 2015, the Nacimiento Project Partners conducted an analysis which concluded that the full allocation of the 6,095 acre-feet of reserve water to the current participants as the best opportunity to manage the project's assets (infrastructure and water) to maximum benefit. February 2016 7 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 15 EIR Addendum Article 29 of the Nacimiento Agreement contract provides a method for the participants to obtain the additional water. This Article requires a 60 -day notice to existing participants of the request for additional entitlement. The City of San Luis Obispo would increase their allocation of 3,380 acre-feet by 2,139 acre- feet, for a total allocation of 5,519 acre-feet, should no other entities come forward to purchase reserve water during the 60 -day period stipulated in the contract. If other entities were to come forward, the project partners would support the allocation to come from the 6,095 acre-feet in reserve, with the remainder allocated proportionately to the project partners. This revised allocation would not require any new construction. With uncertainty of future climatic conditions, regulation and aging infrastructure, adding more Nacimiento water to the City's portfolio will reduce pressure on use of water supplies in the Whale Rock and Salinas reservoirs. It would serve to extend these stored supplies during future critical water shortage periods. Full allocation of the Nacimiento Project would potentially be of regional benefit in northern San Luis Obispo County. The Nacimiento Agreement allows for temporary water sales of `surplus' water. This surplus water, created only when the reserve water has been fully allocated, may be sold at market pricing on a temporary basis under certain circumstances. Fully allocating the reserve water results in the quickest and most economical path forward to put the entire yearly allocation of Nacimiento Project water to beneficial use. The County Flood Control District was the Lead Agency in the Nacimiento Project's final environmental impact report (2003). This EIR contemplated full allocation of the project's 17,500 acre-feet of water. As evaluated in the EIR, the City of San Luis Obispo requested an allocation of 3,380 afy to meet future demand and provide more reliable in City water supplies. The requested entitlement would meet the projected water needs of the City of San Luis Obispo through build -out of the General Plan. The requested entitlement also included 2,000 afy of water that would establish a Reliability Reserve. The Reliability Reserve is water that would help meet community water demand during a drought cycle, but would not be available to support growth or land development. On May 14, 2002, the City Council eliminated the policy that would require the establishment of a Reliability Reserve. However, in order to maintain the highest degree of flexibility and keep every option open, the City Council decided to maintain the current allocation request of 3,380 afy of water from the Nacimiento Water Project. The City of San Luis Obispo's Water Conservation Program is considered to be very successful and has been in place since around 1985. The City's requested entitlement of water from the NWP took into account the City's ongoing water conservation efforts. A section of the 2004 EIR focused on reviewing the environmental impacts of providing the City of San Luis Obispo with 3,380 acre-feet of water annually. Due to the original intent of including future partners, the 2004 EIR did not consider the currently proposed additional delivery of approximately 2,139 acre-feet of water being delivered to San Luis Obispo. This volume is estimated due to the possible purchase of reserve water during the 60 -day period following the signing of the above mentioned letter. This additional amount is intended to be used to maintain the City's existing water supplies and delivery capabilities. The NWP was designed to provide participants with the flexibility to balance their water demand requirements, recognizing that NWP water would supplement other sources of water that may not always be available in February 2016 8 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 16 EIR Addendum sufficient quantities to meet local demand. As is the case with the current drought, participants have seen decreases in the availability of water from other sources, and the proposed increase in the NWP allocation would be used to offset the loss of water from other sources. Uses that were not initially studied during the project's 2004 EIR would require environmental review. A statement of overriding consideration related to significant and unavoidable impacts related to growth inducement and air quality was adopted by the San Luis Obispo County Board of Supervisors (as the District's Board) when it adopted the EIR. The City, as a Responsible Agency, also adopted a follow-up resolution including a statement of overriding consideration to support the District's findings. The City of San Luis Obispo has an adopted General Plan that includes land use and growth management policies that specify how and how much the City will grow. An additional layer of water resource protection is found in the City's Charter requirement to provide a water reliability reserve. The City's General Plan Water and Wastewater Management Element, updated in 2010, includes policies related to primary, reliability reserve, and secondary water supplies to provide adequate water resources to the community. 5.0 Evaluation of Environmental Effects The following environmental analysis provided in Section 6.0 supports a determination that approval and implementation of the changes to the Nacimiento Water Project identified in Section 4.0, would not result in any previously -undisclosed significant environmental impacts or a substantial increase in the severity of previously disclosed impacts or additional significant environmental impacts beyond those previously covered under the Final EIR for the Project. Documents containing the environmental analysis supporting the County Board of Supervisor's action in approving the Project include the Final EIR, Mitigation Monitoring and Reporting Program, CEQA Findings, and additional responses provided for comments submitted after publication of the Final EIR. Section 6.0 analyzes eleven areas of environmental concern, and discusses whether the proposed Project modifications described in Section 4.0 trigger CEQA Guidelines Section 15162 in each of these areas. For each impact area, a reference to the Final EIR discussion is provided, followed by an analysis of the revised Project as it relates to each of these sections. Finally, an analysis is presented to determine whether there are any changed circumstances or new information relative to the revised Project. 6.0 Environmental Impact Analysis The City developed the following impact analysis based on the information provided in Sections 1 through 5 above. All impacts in this document have been classified according to the following criteria: • Class I — Signif cant adverse impacts that cannot be mitigated to insignificance: Significant impacts that cannot be effectively mitigated. No measures could be taken to avoid or reduce these adverse effects to insignificant or negligible levels. February 2016 9 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 17 EIR Addendum ■ Class lI — Significant impacts that can be mitigated to insignificance: These impacts are potentially similar in significance to those of Class I, but can be reduced or avoided by the implementation of mitigation measures. • Class III — Adverse but insignificant impacts: Generally, no mitigation measures are required for this Class of impacts. • Class IV — Beneficial impacts: Effects that are beneficial to the environment. • No Impact. Generally, the proposed changes to the Nacimiento Water Project would not result in any new impacts due to the proposed changes in water allocations. The term "significance" is used throughout the 2004 EIR and this Addendum to characterize the magnitude of the projected impact. For the purpose of this Addendum, a significance impact is a substantial or potentially substantial change to resources in the local proposed project area or the area adjacent to the proposed project. In the discussions of each issue area, criteria used to distinguish between significant and insignificant impacts were provided in the Final EIR. To the extent feasible, distinctions are also made between local and regional significance and short- versus long-term duration. As noted previously, the 2004 EIR evaluated two co -equal projects: a Treated Water Option and Raw Water Option. Since the Raw Water Option was selected and constructed, the evaluation of potential environmental impacts associated with the proposed changes will be compared to the raw water project as evaluated in the EIR. 6.1 Hydrology and Water Quality Analysis of Hydrology and Water Quality impacts and EIR-identified mitigation measures of the approved NWP Project are contained in the Final EIR, Section 5.1, and Section 11.0 Responses to Comments. 6.1.1 Analysis of the Revised Project The following impacts were identified in the 2004 NWP EIR: Impact Impact Description Residual Impact Construction WQ.1 Potentially significant impact of degradation of surface water quality and Class II groundwater quality due to contamination by fuel or other materials related to construction activities. WQ.2 Increased turbidity impacts from construction work within the water bodies. Class III Operations WQ.3 Potentially significant impact from reduction of water deliveries during drought Class II and resulting water shortages to the participants. WQA Potential impact of prolonged (over one week) shutdown of releases from Lake Class 11 Nacimiento during minimum pool conditions, resulting in water shortages at Water World Resorts and Heritage Ranch. WQ.5 Impacts to groundwater from sea water intrusion in Salinas Basin. Class III WQ.6 Potential degradation of groundwater quality resulting from aquifer discharge Class II using Lake Nacimiento water containing elevated metals concentrations. February 2016 10 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A. Page 18 EIR Addendum Impact Impact Description Residual Impact WQ.7 Potential nuisances caused by the presence of vegetation in the ponds and/or Class II eutrophication. WQ.8 Impacts from lack of sufficient capacity of the Paso Robles Discharge Area to Class II take full NWP deliveries; and WQ 9 Impacts from lack of sufficient capacity of the City of Paso Robles' Thunderbird Class II well field to extract the total combined water right to Salinas River underflow after adding the NWP water right. Construction impacts WQ.1 and WQ.2 would not change since the revised water allocations would not require any new construction. Impacts WQ.6 through WQ.9 are not applicable to the City of San Luis Obispo since the city receives raw water directly from the NWP pipeline and does not use discharge basins and groundwater recovery. Impacts WQ.3 through WQ.5 were evaluated in the 2004 EIR based on the San Luis Obispo County Flood Control and Water Conservation District 17,500 afy entitlement from Lake Nacimiento per agreement executed in 1959 with Monterey County. The proposed increase in participant allocations would not exceed the 17,500 afy entitlement that was evaluated in the NWP EIR. Therefore, there would be no additional impact associated with participant allocation increases. 6.1.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance The circumstances under which the NWP was undertaken remain essentially unchanged. The NWP was designed to provide participants with the flexibility to balance their water demand requirements, recognizing that NWP water would supplement other sources of water that may not always be available in sufficient quantities to meet local demand. As is the case with the 2015 drought, participants have seen decreases in the availability of water from other sources, and the proposed increase in the NWP allocation would be used to offset the loss of water from other sources. 6.1.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to water quality as evaluated in the NWP EIR. Therefore, potential impacts would be considered less than significant. 6.2 Geology, Seismicity, and Soils Analysis of Geology, Seismicity, and Soils impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.2, and Section 11.0 Responses to Comments. 6.2.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: February 2016 11 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 19 EIR Addendum Impact Impact Description Residual Impact Operations GS.1 Ground rupture along the Rinconada fault could damage project facilities. Class II GS.2 Locating the Rocky Canyon Water Storage Tank and Happy Valley Pump Station near the Rinconada fault zone may result in poor foundation conditions. Class II GS.3 Excavation in rock or soils containing asbestos may cause risk to human health. Class II Impacts GS.2 and GS.3 are related to the construction of the pipeline and pump station facilities, and would not be affected by the proposed allocation increases. Likewise, Impact GS.1 evaluated potential impacts to project facilities that are independent of water allocations. 6.2.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance There is no potential for significant changes in geological, seismic or soils resource conditions within the area of potential effect of the Project since the time of certification of the Final EIR, because such resources are relatively static. Additionally, no new information regarding unknown hazards, conditions or resources has become available. Therefore, no changes in circumstances and no new information of substantial importance relative to geological, seismic or soils resource have been identified. 6.2.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to Geology, Seismicity, and Soils as evaluated in the NWP EIR. Therefore, there would be no impact associated with the proposed water allocation increase. 6.3 Drainage, Erosion and Sedimentation Analysis of Drainage, Erosion and Sedimentation impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.3, and Section 11.0 Responses to Comments. 6.3.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: Impact Impact Description Residual Impact Construction DE.1 Potentially significant impact of changes to surface water flow patterns during Class II construction. DE.2 Potentially significant impact of damage to construction sites if flood flows occur Class II while a pipeline is being installed in a streambed. DE.3 Potentially significant impacts to surface waters of increased turbidity and Class II sedimentation, and to groundwater recharge in streams crossed and paralleled due to clearing, grading, trenching, and backfilling activities. Operations February 2016 12 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 20 EIR Addendum Impact Impact Description Residual Impact DEA Potentially significant impact of erosion and downstream sedimentation from a Class II pipeline rupture. DE.5 Potentially significant impact of scouring occurring in stream channels that expose Class II buried pipeline or undermine suspended pipe crossing abutments or cable caissons. DE.6 Potentially significant impact of increased or concentrated storm runoff flowing Class II onto erodible soils from impervious surfaces. DE.7 Potentially significant impact of high river flow or bank erosion resulting in Class II damage to branch pipelines or discharge piping in the three discharge areas. Construction impacts DE.1 through DE.3 would not change since the revised water allocations would not require any new construction. Impact DE.7 is not applicable to the City of San Luis Obispo since the City receives raw water directly from the NWP pipeline and does not use discharge basins and groundwater recovery. Impacts DEA through DE.6 evaluated potential impacts to project facilities that are independent of water allocations. The proposed increase in participant allocations would not exceed the 17,500 afy entitlement that was evaluated in the NWP EIR. Therefore, there would be no additional impact associated with participant allocation increases. 6.3.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance There is no potential for significant changes in Drainage, Erosion and Sedimentation conditions within the area of potential effect of the Project since the time of certification of the Final EIR, because such resources are relatively static. Additionally, no new information regarding unknown hazards, conditions or resources has become available. Therefore, no changes in circumstances and no new information of substantial importance relative to Drainage, Erosion and Sedimentation have been identified. 6.3.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to Drainage, Erosion and Sedimentation as evaluated in the NWP EIR. Therefore, there would be no impact associated with the proposed water allocation increase. 6.4 Air Quality Analysis of Air Quality impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.4, and Section 11.0 Responses to Comments. 6.4.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: Impact Impact Description Residual Impact Construction February 2016 13 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 21 EIR Addendum AQ.1 Construction activities would generate air emissions that would impact air quality in the area. Class I Operations AQ.2 Operation of the project facilities would generate air emissions that could impact air quality in the area. Class II AQ.3 Increased emissions of toxic compounds due to the project could result in increased health risks. Class III AQ.4 Project Conformity with the Clean Air Act. Class III AQ.5 Project Consistency with the County Clean Air Plan. Class III Construction impact AQ.1 would not change since the revised water allocations would not require any new construction. Impacts AQ.2 through AQ.4 evaluated potential impacts to project facilities that are independent of water allocations. The proposed increase in participant allocations would not exceed the 17,500 afy entitlement that was evaluated in the NWP EIR. Therefore, there would be no additional impact associated with participant allocation increases. Given recent changes in legislation regarding climate and greenhouse gas (GHG) emissions, Impact AQ.5 has been reevaluated in the following section to determine if project operations pose a potentially significant source of GHG emissions. 6.4.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance The Final EIR for the NWP was certified prior to the passage of AB 32, the landmark legislation addressing global warming and greenhouse gas emissions. As such, potential impact associated with the NWP have not been evaluated to determine if the project would be considered a significant source of GHG emissions. The following sections contain background information on the changes that have taken place regarding GHG legislation and evaluation requirements, as well as an evaluation of potential project impacts. International Regulations Kyoto Protocol The Kyoto Protocol is a treaty made under the United Nations Framework Convention on Climate Change, which was signed on March 21, 1994. The Convention was the first international agreement to regulate GHG emissions. It has been estimated that if the commitments outlined in the Kyoto Protocol are met, global GHG emissions would be reduced by an estimated 5 percent from 1990 levels during the first commitment period from 2008 until 2012. However, while the US is a signatory to the Kyoto Protocol, Congress has not ratified it; therefore, the US is not bound by the Protocol's commitments. Climate Change Technology Program In lieu of the Kyoto Protocol's mandatory framework, the US has opted for a voluntary and incentive -based approach toward emissions reductions. This approach, the Climate Change Technology Program, is a multi -agency research and development coordination effort, led by the Secretaries of Energy and Commerce, who are charged with carrying out the President's National Climate Change Technology Initiative. February 2016 14 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A. Paee 22 EIR Addendum Federal Regulations Clean Air Act In the past, the US EPA has not regulated GHG under the Clean Air Act. However, the US Supreme Court held that the EPA can, and should, consider regulating motor -vehicle GHG emissions. In Massachusetts v. Environmental Protection Agency, 12 states and cities, including California, in conjunction with several environmental organizations sued to force the EPA to regulate GHG as a pollutant pursuant to the Clean Air Act (US Supreme Court No. 05-1120; 127 S.Ct. 1438 (2007)). The Court ruled that GHG fit within the Clean Air Act's definition of a pollutant and that the EPA's reason for not regulating GHG was insufficiently grounded. 40 CFR Section 98 specifies mandatory reporting requirements for a number of industries. The final 40 CFR part 98 applies to certain downstream facilities that emit GHG, and to certain upstream suppliers of fossil fuels and industrial GHG. For suppliers, the GHG emissions reported are the emissions that would result from combustion or use of the products supplied. The rule also includes provisions to ensure the accuracy of emissions data through monitoring, recordkeeping and verification requirements. The mandatory reporting requirements generally apply to facilities that produce more than 25,000 metric tonnes of CO2 equivalent per year. State Regulations and Programs Executive Order S-3-05 The 2005 California Executive Order 5-3-05 established the following GHG emission -reduction targets for California: • By 2010, reduce GHG emissions to 2000 levels; • By 2020, reduce GHG emissions to 1990 levels; and • By 2050, reduce GHG emissions to 80 percent below 1990 levels. The Secretary of the California Environmental Protection Agency (CaIEPA) is charged with coordinating oversight of efforts to meet these targets and formed the Climate Action Team to carry out the Order. Emission reduction strategies or programs developed by the Climate Action Team to meet the emission targets are outlined in a March 2006 report (CaIEPA 2006). The Climate Action Team also provided strategies and input to the CARB Scoping Plan. Assembly Bill 1493 In 2002, the legislature declared in AB 1493 (the Pavley regulations) that global warming was a matter of increasing concern for public health and the environment in the state. It cited several risks that California faces from climate change, including reduction in the state's water supply, increased air pollution due to higher temperatures, harm to agriculture, and increase in wildfires, damage to the coastline, and economic losses caused by higher food, water, energy, and insurance prices. Furthermore, the legislature stated that technological solutions for reducing GHG emissions would stimulate California's economy and provide jobs. Accordingly, AB 1493 required the CARB to develop and adopt the nation's first GHG emission standards for automobiles. The CARB responded by adopting CO2 -equivalent fleet average emission standards. The standards will be phased in from 2009 to 2016, reducing emissions by 22 percent in the "near term" (2009 to 2012) and 30 percent in the "mid-term" (2013 to 2016), as compared to 2002 fleets. February 2016 15 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Paee 23 EIR Addendum The legislature passed amendments to AB 1493 in September 2009. Implementation of AB 1493 requires a waiver from the EPA, which was granted in June 2009. Assembly Bill 32 AB 32 codifies California's GHG emissions target and requires the state to reduce global warming emissions to 1990 levels by 2020. It further directs the CARB to enforce the statewide cap that would begin phasing in by 2012. AB 32 was signed and passed into law by Governor Arnold Schwarzenegger on September 27, 2006. Key milestones of AB 32 include: June 20, 2007 - Identification of "discrete early action GHG emission -reduction measures." • January 1, 2008 - Identification of the 1990 baseline GHG emissions levels and approval of a statewide limit equivalent to that level. Adoption of reporting and verification requirements concerning GHG emissions. • January 1, 2009 - Adoption of a scoping plan for achieving GHG emission reductions. • January 1, 2010 - Adoption and enforcement of regulations to implement the actions. • January 1, 2011 - Regulatory adoption of GHG emission limits and reduction measures. ■ January 1, 2012 - GHG emission limits and reduction measures become enforceable. Since the passage of AB 32, the CARB published Proposed Early Actions to Mitigate Climate Change in California. This publication indicated that the issue of GHG emissions in CEQA and General Plans was being deferred for later action, so the publication did not discuss any early action measures generally related to CEQA or to land use decisions. California Senate Bill 1368 In 2006, the California legislature passed SB 1368, which requires the Public Utilities Commission (PUC) to develop and adopt a "greenhouse gases emission performance standard" by March 1, 2007, for private electric utilities under its regulation. The PUC adopted an interim standard on January 25, 2007, requiring that all new long-term commitments for base load generation involve power plants that have emissions no greater than a combined cycle gas turbine plant. That level is established at 1,100 lbs/MWh of CO2. The California Energy Commission has also adopted similar rules. Senate Bill 97— CEQA: Greenhouse Gas Emissions In August 2007, Governor Schwarzenegger signed into law SB 97 — CEQA: Greenhouse Gas Emissions stating, "This bill advances a coordinated policy for reducing greenhouse gas emissions by directing the Office of Planning and Research and the Resources Agency to develop CEQA guidelines on how state and local agencies should analyze, and when necessary, mitigate greenhouse gas emissions." Specifically, SB 97 requires the Office of Planning and Research (OPR), by July 1, 2009, to prepare, develop, and transmit to the Resources Agency guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions, as required by CEQA, including, but not limited to, effects associated with transportation or energy consumption. The Resources Agency would be required to certify and adopt those guidelines by January 1, 2010. OPR would be required to periodically update the guidelines to incorporate new information or criteria established by the CARB pursuant to the California Global Warming Solutions Act of 2006. SB 97 also identifies a limited number of types of projects that would be exempt under CEQA from analyzing GHG emissions. February 2016 16 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 24 EIR Addendum On January 7, 2009, OPR issued its draft CEQA guidelines revisions pursuant to SB 97. On March 16, 2010, the Office of Administrative Law approved the Amendments, and filed them with the Secretary of State for inclusion in the California Code of Regulations. The Amendments became effective on March 18, 2010. Office of Planning and Research Technical Advisory and Preliminary Draft CEQA Guidelines Amendments for Greenhouse Gas Emissions Consistent with SB 97, on March 18, 2010, the CEQA Guidelines were amended to include references to GHG emissions. The amendments offer guidance regarding the steps lead agencies should take to address climate change in their CEQA documents. According to OPR, lead agencies should determine whether GHG may be generated by a proposed project, and if so, quantify or estimate the GHG emissions by type and source. Second, the lead agency must assess whether those emissions are individually or cumulatively significant. When assessing whether a project's effects on climate change are cumulatively considerable, even though its GHG contribution may be individually limited, the lead agency must consider the impact of the Project when viewed in connection with the effects of past, current, and probable future projects. Finally, if the lead agency determines that the GHG emissions from the proposed project are potentially significant, it must investigate and implement ways to avoid, reduce, or otherwise mitigate the impacts of those emissions. The Amendments do not identify a threshold of significance for GHG emissions, nor do they prescribe assessment methodologies or specific mitigation measures. The Preliminary Amendments maintain CEQA discretion for lead agencies to establish thresholds of significance based on individual circumstances. The guidelines developed by OPR provide the lead agency with discretion in determining what methodology is used in assessing the impacts of greenhouse gas emissions in the context of a particular project. This guidance is provided because the methodology for assessing GHG emissions is expected to evolve over time. The OPR guidance also states that the lead agency can rely on qualitative or other performance based standards for estimating the significance of GHG emissions. On December 11, 2008, the CARB adopted the Scoping Plan as directed by AB 32 (CARB 2008). The Scoping Plan proposes a set of actions designed to reduce overall GHG emissions in California. The numerous measures in the Scoping Plan approved by the Board are being implemented in phases with Early Action Measures that have already been implemented. Measures include a cap -and -trade system, car standards, low carbon fuel standards, landfill gas control methods, energy efficiency, green buildings, renewable electricity standards, and refrigerant management programs. The Scoping Plan provides an approach to reduce emissions to achieve the 2020 target and to initiate the transformations required to achieve the 2050 target. The 2008 Scoping Plan indicated that a 29 percent reduction below the estimated "business as usual" levels would be necessary to return to 1990 levels by 2020. The 2011 supplement (Functional Equivalent Document) to the Scoping Plan emission inventory revisions indicated that a 16 percent reduction below the estimated "business as usual" levels would be necessary to return to 1990 levels by 2020. This revision was due to the slowing economy between 2008 and 2010 and to reduction measures that were already in place (CARB, 2011). An update of the Scoping Plan has occurred with a release February 2016 17 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A. Paae 25 EIR Addendum of a Draft Discussion Document in October, 2013 and a 2014 Update (see below). Another update is required in 2018. CARB underwent an extensive and rigorous process in developing and approving the Scoping Plan. For a detailed discussion of this process, see Association of Irritated Residents et. al. v. State Air Resources Board et. al., Court of Appeal of California, First Appellate District, Division Three (206 Cal. App. 4th 1487; 143 Cal Rptr. 3d 65; 2012 Cal. App. LEXIS 718; 42 ELR 20127, June 19, 2012, p. 5 — hereafter "AIR."). Among other things, CARB considered several alternatives to achieve the mandated maximum technologically feasible and cost- effective reductions in GHGs and submitted its analyses and recommendations for peer review and public comment on many occasions (AIR p. 5). In affirming CARB's adoption of the Scoping Plan, the Court of Appeal of California concluded as follows: "The Governor and the Legislature have set ambitious goals for reducing the level of greenhouse gas emissions in California and to do so by means that are feasible and most cost-effective. The challenges inherent in meeting these goals can hardly be overstated. [C]ARB has been assigned the responsibility of designing and overseeing the implementation of measures to achieve these challenging goals. The scoping plan is but an initial step in this effort, to be followed by the adoption of regulations, the first of which are already in effect, and plan updates no less than every five years. As the plan itself indicates, there is still much to be learned that is pertinent to minimizing greenhouse gas emissions. It is hardly surprising that the scoping plan leaves some questions unanswered and that opinions differ as to [the] many complex issues inherent in the task. After reviewing the record before us, we are satisfied that the Board has approached its difficult task in conformity with the directive from the Legislature, and that the measures that it has recommended reflect the exercise of sound judgment based upon substantial evidence. Further research and experience likely would suggest modifications to the blueprint drawn in the scoping plan, but the plan's adoption in 2009 was in no respect arbitrary or capricious." (AIR, p. 13.) Executive Order 5-03-05 sets a goal that California emit 80 percent less GHGs in 2050 than it emitted in 1990. CARB's Scoping Plan, including the October, 2013 Discussion Draft, provides additional direction and insight as to how it anticipates California would achieve the 2050 reduction goal in Governor Schwarzenegger's Executive Order 5-03-05: "Reducing our greenhouse gas emissions by 80 percent would require California to develop new technologies that dramatically reduce dependence on fossil fuels, and shift into a landscape of new ideas, clean energy, and green technology. The measures and approaches in this plan are designed to accelerate this necessary transition, promote the rapid development of a cleaner, low carbon economy, create vibrant livable communities, and improve the ways we travel and move goods throughout the state" (CARB 2008). "[T]he measures needed to meet the 2050 goal are too far in the future to define in detail ..." (Ibid.) The CEC and CARB also have published an alternative fuels plan that identifies challenging but plausible ways to meet 2050 transportation goals. The majority of the measures identified by the CEC/CARB (renewable power requirements, the low carbon fuel standard, and vehicle emissions standards) relate to technology improvements beyond both the control of the Applicant and the scope of the proposed Project. But, these technological improvements would reduce the demand for crude oil through a reduction in demand for gasoline and diesel fuels. February 2016 18 Nacimiento Water Project Resolution No. 10700 2016 Series) EXHIBIT A, Page 26 EIR Addendum Scoping Plan 2011 Re Approved Document In August 2011, the initial Scoping Plan was re -approved by the ARB, and includes the Final Supplement to the Scoping Plan Functional Equivalent Document. In the 2011 re -approved Scoping Plan, ARB updated the projected business as usual (BAU) emissions based on current economic forecasts (i.e., as influenced by the economic downturn) and GHG-reduction measures already in place. The BAU projection for 2020 GHG emissions in California was originally, in the 2008 Scoping Plan, estimated to be 596 MMTCO2e. ARB subsequently derived an updated estimate of emissions in a 2013 Draft Discussion Document by considering the influence of the recent recession and reduction measures that are already in place. The revision estimates the year 2020 emissions at 507 MMTCO2e (as the BAU estimate). The 2011 Re -Approved Scoping Plan concluded that achieving the 1990 levels by 2020 meant cutting approximately 16 percent, compared to the original 2008 Scoping Plan that estimated a 29 percent reduction (CARE 2011). The 2011 Scoping Plan sets forth the expected GHG emission reductions from a variety of measures, including the Pavley I automobile standards and the Renewables Portfolio Standard, neither of which were assumed in the 2008 Scoping Plan. Scoping Plan 2014 First Update CARB approved the first update to the Scoping Plan on May 22, 2014 with recommendations for a mid-term target (between 2020 and 2050) and sector -specific actions. The First Update addresses issues such as a revision to the GWP for gasses (to a 20 year instead of the 100 year timeframe), the establishment of a mid-term 2030 goal (of between 33-40 percent reduction over 1990 levels), and the development of post -2020 emissions caps related to Cap -and -Trade to reflect the establishment of a 2030 midterm target. This first revision also provides an update on climate science and a report on progress toward the 2020 target, including achievements of the 2008 and 2011 Scoping Plans, an update on the inventory of GHG emissions, and an update of the economy and its potential affect on future emissions' forecasting. It also addresses post -2020 goals, including Executive Order 5-3-05. California Air Resource Board Cap -and -Trade Regulation The California Air Resource Board has implemented a cap -and -trade type program, as per the AB -32 directed Scoping Plan, applicable to specific industries that emit more than 25,000 MTCO2e annually. The AB 32 Scoping Plan identifies a Cap -and -Trade program as one of the strategies California would employ to reduce GHG emissions that cause climate change. Under cap -and -trade, an overall limit on GHG emissions from capped sectors would be established by the Cap -and -Trade program, and facilities subject to the cap would be able to trade permits (allowances) to emit GHGs. The program started on January 1, 2012, with an enforceable compliance obligation beginning with the 2013 GHG emissions for GHG emissions from stationary sources. The petroleum and natural gas systems sector is covered starting in 2013 for stationary and related combustion, process vents and flare emissions if the total emissions from these sources exceed 25,000 MTCO2e per year. Suppliers of Natural Gas and transportation fuels are covered beginning in 2015 for combustion emissions from the total volume of natural gas delivered to a non -covered entity or for transportation fuels. CARB's rationale for adopting Cap -and -Trade was prominently noted by the Court of Appeals' opinion upholding the ARB Scoping Plan as follows: The final scoping plan explains the Board's rationale for recommending a cap -and -trade program in combination with the so-called "complementary measures" by citing the rationale outlined by February 2016 19 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A. Paae 27 EIR Addendum the market Advisory committee and quoting from the report of the economic and technology advancement advisory committee, in part, as follows: " A declining cap can send the right price signals to shape the behavior of consumers when purchasing products and services. It would also shape business decisions on what products to manufacture and how to manufacture them. Establishing a price for carbon and other GHG emissions can efficiently tilt decision-making toward cleaner alternatives. This cap and trade approach (complemented by technology -forcing performance standards) avoids the danger of having government or other centralized decision - makers choose specific technologies, thereby limiting the flexibility to allow other options to emerge on a level playing field. Complementary policies would be needed to spur innovation, overcome traditional market barriers ... and address distributional impacts from 9ossible higher prices for goods and services in a carbon -constrained world. "(AIR 206 Cal.App.4 at p. 1499.) Cap -and -Trade is designed to reduce the emissions from a substantial percentage of GHG sources (approximately 80 percent of GHG emissions would come under the program) within California through a market trading system. The system would reduce GHG emissions by reducing the available GHG "allowances" over time up until the year 2020. The program beyond the year 2020 has not been designed yet, but the program is intended to extend beyond that timeframe. Facilities are required to obtain an "allowance", either through purchasing on auction or through freely allocated "industry assistance" allowances from CARB, for each MTCO2e of GHG they emit. CARB issues the "industry assistance" allocations for free for a number of industries. These are based, in part, on a pre -defined "benchmark" of GHG emissions per unit of production. For the thermally enhanced oil recovery (TEOR) production sector, allowances are provided as a function of the amount of crude oil produced, thereby establishing, in effect, a level of efficiency in regards to GHG emissions for that sector. Other sectors are also allocated allowances based on their own respective activities. If an operation within the TEOR sector operates less efficiently than the specified "benchmark", thereby receiving an insufficient number of "free" allowances to cover their emissions, implementation of efficiency improvements or the purchase of additional allowances from the CARB auction would be required. Some availability of "offsets" is also included in the program, which can be obtained from specific, allowable offset programs, such as GHG reduction projects related to forestry, livestock and ozone depleting chemicals. Offsets outside of these three options are not allowed at this time. The first group of sectors began trading in allowances in 2012. That group includes the oil and gas sector as well as most stationary sources. A second group is planned to begin the program in 2015, which would include the transportation fuels sector. CARB auctioned about 23 million allowances in November 2012 to be used for the 2013 year. For subsequent periods after the initial 2013 period, allowances are planned to be distributed freely through the "industry assistance" program or auctioned off. Industry assistance allowances would decrease each year as per a "cap adjustment factor". The cap adjustment factor would be approximately two to three percent annually through 2020. The total allowances allowed to be allocated each year (either freely allocated or auctioned) are limited by the defined February 2016 20 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 28 EIR Addendum allowance budget, which decreases each year through 2020 and is currently set at approximately 159 million MTCO2e for the year 2014. An operator is required to participate in the Cap -and -Trade program if its facility emits more than 25,000 MTCO2e annually. Annual reporting of GHG emissions is required under the CARB Mandatory Reporting Rule. As only a limited number of allowances are issued, based on the original emissions estimates prepared by the CARE, and these allowances are reduced each year by a given percentage to achieve the year 2020 goals, any operator who commences operations after the Cap -and -Trade program is in effect would be required to obtain allowances from the given limited pool. Any increase in GHG emissions at a facility would therefore be allowed through a reduction in GHG emissions at some other location with the net GHG emissions statewide not increasing. This mechanism would serve to ensure that the goals of AB 32 are achieved; that emissions statewide are reduced, even if local GHG emissions increase; and that, ultimately, emissions of GHG and atmospheric CO2 concentrations are stabilized, thereby reducing impacts. This produces, in effect, mitigation for this cumulative impact. Note that GHG emissions produce no immediate, local health effects (such as criteria pollutants or ozone), and therefore GHG emissions reduced in another County, for example, could be used to offset the GHG emissions occurring at a project site. The evolution of the Cap -and -Trade program past 2020 may render certain industries with higher GHG emissions economically infeasible. Many oil and gas projects may no longer exist by 2050 as the remaining unextracted resources may no longer be economically recoverable due to the cost of obtaining allowances. In addition, the goals of the State programs are to move the demand-side away from fossil fuels. As per the Scoping Plan, "Reducing our greenhouse gas emissions by 80 percent [by 2050] will require California to develop new technologies that dramatically reduce dependence on fossil fuels, and shift into a landscape of new ideas, clean energy, and green technology. The measures and approaches in this plan are designed to accelerate this necessary transition, promote the rapid development of a cleaner, low carbon economy..." SB 375 Sustainable Communities and Climate Protection Act of 2008 SB 375 supports the State's climate action goals to reduce greenhouse gas (GHG) emissions through coordinated transportation and land use planning with the goal of more sustainable communities. Under the Sustainable Communities Act, ARB sets regional targets for GHG emissions reductions from passenger vehicle use. In 2010, ARB established these targets for 2020 and 2035 for each region covered by one of the State's metropolitan planning organizations (MPO). ARB will periodically review and update the targets, as needed. Each of California's MPOs must prepare a "sustainable communities strategy" (SCS) as a part of its regional transportation plan (RTP). The SCS contains land use, housing, and transportation strategies that, if implemented, would allow the region to meet its GHG emission reduction targets. The Sustainable Communities Act also establishes incentives to encourage local governments and developers to implement the SCS or the APS. Developers can get relief from certain environmental review requirements under the California Environmental Quality Act February 2016 21 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 29 EIR Addendum (CEQA) if their new residential and mixed-use projects are consistent with a region's SCS (or APS) that meets the targets (see Cal. Public Resources Code §§ 21155, 21155.1, 21155.2, 21159.28.). The San Luis Obispo Council of Governments (SLOCOG) released their Draft Regional Transportation Plan (RTP) in December 2014. The plan would reduce vehicle miles traveled per capita from 30.2 in 2005 to 28.2 in 2035, an 8.5 percent reduction. The RTP would also reduce per capita CO2 emissions by 10.9 percent, exceeding the region's target of 8 percent. The plan was adoption in April 2015. California Climate Action Registry General Reporting Protocol The California Climate Action Registry is a program of the Climate Action Reserve and serves as a voluntary GHG registry. The California Climate Action Registry was formed in 2001 when a group of chief executive officers, who were investing in energy efficiency projects that reduced their organizations' GHG emissions, asked the State to create a place to accurately report their emissions history. The California Climate Action Registry publishes a General Reporting Protocol, which provides the principles, approach, methodology, and procedures to estimate such emissions. California Air Resource Board Proposed Mandatory Reporting Regulation The Air Resources Board approved a mandatory reporting regulation in December 2007, which became effective January 2009 (which appears at sections 95100-95133 of Title 17, California Code of Regulations), which requires the mandatory reporting of GHG emissions for specific industries emitting more than 10,000 - 25,000 MTCO2e depending on the process source type. Status of California GHG Reduction Efforts The State is required to monitor the effectiveness of the state programs on an annual basis. According to the State report card for 2013, the Pavley Standard achieved a 2.2 million MTCO2e (MMT) of reductions in 2011 (the last year of available data in the 2013 report) with a goal of 29.9 MMT by 2020; the Low Carbon Fuel Standard program achieved a 0.7 MMT reduction in 2011 with a goal of 15 MMT by 2020; and the Renewable Portfolio Standard program for power generation achieved a reduction of 3.5 MMT in 2011 with a goal of 19.3 MMT. The Cap -and - Trade program was started in 2013 and has reported few problems, but specific reductions have not been quantified yet. Its goal is a reduction of 18 MMT by 2020. Total reductions in all state programs total 9.1 MMT in 2011 (6.3 percent of the goal), with a goal of 146 MMT reductions by 2020. Local Regulations and Programs County Climate Action Plan The City adopted a Climate Action Plan on July 17, 2012, and summarizes strategies for reducing greenhouse gas emissions. Community strategies for climate change adaptation and reduction of GHG emissions are divided into six chapters: Buildings, Renewable Energy, Transportation & Land Use, Water, Solid Waste, and Parks & Open Space. Strategies that will help reduce GHG emissions associated with City Government Operations were also included in a separate chapter. County Climate Action Plan The County adopted a Climate Action Plan (EnergyWise Plan) on November 22, 2011, as a blueprint for reducing greenhouse gas emissions. Additionally, a Green Building Ordinance to February 2016 22 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A. Paae 30 EIR Addendum improve energy efficiency in new and existing development effective January 1, 2013. The CAP focuses on local actions to reduce GHG emissions through energy efficiencies, including: retrofitting existing buildings; reversing rural sprawl; and increasing use of non-fossil fuels such as solar and wind energy (SLOC 2011). County General Plan, Conservation, and Open Space Element The County Board of Supervisors in 2010 adopted a comprehensive Conservation and Open Space Element with a focus on reducing GHG emissions, increasing energy efficiency, and using local renewable energy. The County's EnergyWise Plan (adopted in 2011) included an inventory of GHG. The EnergyWise Plan is required by the Conservation and Open Space Element of the General Plan. The Inventory found that the unincorporated San Luis Obispo community emitted 917,710 metric tons of carbon dioxide equivalent (MTCO2e) in 2006. SLOCAPCD The SLOCAPCD adopted GHG thresholds on March 28, 2012 and updated their CEQA Handbook in April, 2012, to incorporate the new thresholds (SLOCAPCD 2012). Significance Thresholds For stationary -source projects, the threshold is 10,000 metric tons per year (MT/yr) of COZe. Stationary -source projects include land uses that would accommodate processes and equipment that emit GHG emissions and would require an SLOCAPCD permit to operate. This threshold is applied to emissions within San Luis Obispo County. For construction, the GHG emissions from construction are amortized over the life of the project (50 years for residential projects and 25 years for commercial and industrial projects) and added to the operation GHG emissions. Impact Analysis Impact # Impact Description Phase Impact Classification Pump Station 2,275 Operational activities associated with the Proposed Project 0.0 2,284 AQ.6 could generate GHG emissions that exceed SLOCAPCD Operations Class III Total Emissions 7,332 thresholds. 0.1 7,361 The NWP does not directly utilize fossil fuels or emit greenhouse gases. However, the project requires electrical power generated offsite to power the pipeline pump stations and end receiver water treatment plants. Table 2 shows the GHG emissions associated with the NWP Project. As shown in Table 2, project -related GHG emissions at full capacity would be less than the SLOAPCD significance threshold of 10,000 metric tonnes per year. Therefore, potential project impacts would be considered adverse but insignificant (Class III). Table 2 Operational GHG Emissions, metric tonnes Source CO2 CH4 N20 MTCO2E Pump Station 2,275 0.1 0.0 2,284 Water Treatment 5,056 0.2 0.0 5,077 Total Emissions 7,332 0.3 0.1 7,361 February 2016 23 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 31 EIR Addendum SLOAPCD Threshold 10,000 Note: MTCO2E-metric tons CO2 equivalent. 6.4.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to air quality or greenhouse gas emissions as evaluated in the NWP EIR and the GHG analysis above. Therefore, there would be no impact associated with the proposed water allocation increase. 6.5 Noise Analysis of Noise impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.5, and Section 11.0 Responses to Comments. 6.5.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: Impact IImpact Description Residual Impact Construction N*I Construction noise would temporarily increase ambient daytime noise levels along Class II the pipeline route and near the pump station and WTP sites. Operations N.2 Operations noise from pumps would increase long-term ambient noise levels. Class III N.3 Periodic testing and emergency use of generators would increase short-term ambient noise levels near the pump stations. Class II Construction impact N.1 would not change since the revised water allocations would not require any new construction. Impacts N.3 and N.3 were evaluated potential impacts to project facilities that are independent of water allocations. The proposed increase in participant allocations would not exceed the 17,500 afy entitlement that was evaluated in the NWP EIR. Therefore, there would be no additional impact associated with participant allocation increases. 6.5.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance There is no potential for significant changes in noise conditions within the area of potential effect of the NWP since the time of certification of the Final EIR, because such resources are relatively static. Additionally no new information regarding unknown conditions or resources has become available. Therefore, no changes in circumstances and no new information of substantial importance relative to noise have been identified. February 2016 24 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 32 EIR Addendum 6.5.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to noise impacts as evaluated in the NWP EIR. Therefore, there would be no impact associated with the proposed water allocation increase. 6.6 Hazards and Hazardous Materials Analysis of Hazards and Hazardous Materials impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.6, and Section 11.0 Responses to Comments. 6.6.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: Impact I Impact Description Residual Impact Construction HM.1 During construction of the proposed pipeline on the Camp Roberts property, Class III unexploded military ordnance could be encountered, which could expose construction workers to explosion hazards. HM.2 Earth -moving operations during construction could uncover contaminated soils Class II and other hazardous materials, including naturally occurring asbestos, creating health risks to construction workers and public. HM.3 During construction, hazardous utilities could be damaged by construction Class II equipment. This could expose construction workers and public to hazardous materials transported by the damaged pipelines. HMA Releases of hazardous or flammable materials during construction could pose Class III risks of fire or contamination. HM.5 Contaminated materials in the soil could enter into the pipeline expose water users Class III to contamination and pose health risks. Operations HM.6 During operation of the WTP, the employees and public could be exposed to the Class II hazardous chemicals transported to, used, and stored at the plant. HM.7 Accidental release of large quantities of treated water into a fresh water body Class III could be harmful to the organisms in the water body. Construction impacts HM.1 through HM.5 would not change since the revised water allocations would not require any new construction. Impact HM.6 is not applicable to the City of San Luis Obispo since the City receives raw water directly from the NWP pipeline and the water treatment plant that was evaluated in the NWP EIR was never constructed. Chemicals are used to treat raw water deliveries, which would slightly increase with the proposed allocation increase of NWP water, as well as differences in pH levels of the water from Lake Nacimiento. However, since the water from the increased NWP allocation would be used to displace other sources of water, overall chemicals to treat raw water use within the City would not change appreciably with potential impacts considered less than significant (Class III). February 2016 25 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 33 EIR Addendum Impact HM.7 evaluated potential impacts of treated water spills that are independent of water allocations, but are instead related to the demand for treated water delivery to customers. There would be no project -related changes to the City's water distribution network that would change the probability or magnitude of a treated water spill. Therefore, there would be no additional impact associated with participant allocation increases. 6.6.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to hazards or hazardous materials impacts as evaluated in the NWP EIR. Therefore, there would be no impact associated with the proposed water allocation increase. 6.6.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in the use of hazardous materials or potential impacts to public safety as evaluated in the NWP EIR. Therefore, there would be no impact associated with the proposed water allocation increase. 6.7 Biological Resources Analysis of Biological Resources impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.7, and Section 11.0 Responses to Comments. 6.7.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: Impact Impact Description Residual Impact Construction 13R.1 Potentially significant impacts to terrestrial biological resources from heavy construction machinery and various construction activities. Class II 13R.2 Impacts to riparian, water, and wetlands habitats and their biological resources from construction activities. Class II 13R.3 Impacts to wildlife from noise due to the project construction and operation phases. Class II BRA Impacts to wildlife in drainages due to erosion, sedimentation and dewatering. Class II BR.S Impacts to plants from dust emission due to the project construction phase. Class II 13R.9 Impacts to riparian habitat due to construction of the water discharge areas in the vicinity of Salinas River. Class II Operations 13R.6 Impacts to aquatic life from treated water spills in case the treated water pipeline ruptures during operational phase of the project. Class III 13R.7 Impacts to fish in Lake Nacimiento due to pumping through the water intake during operational phase of the project. Class III BR.8 Impacts to fisheries during operational phase of the proposed project. Class III Class II February 2016 26 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Paae 34 EIR Addendum Construction impacts BR.1 through BR.5 and BR.9 would not change since the revised water allocations would not require any new construction. Impact BR.6 evaluated potential impacts of treated water spills that are independent of water allocations, but are instead related to the demand for treated water delivery to customers. There would be no project -related changes to the City's water distribution network that would change the probability or magnitude of a treated water spill. Therefore, there would be no additional impact associated with participant allocation increases. Impacts BR.7 and BR.8 were evaluated in the EIR based on the San Luis Obispo County Flood Control and Water Conservation District 17,500 afy entitlement from Lake Nacimiento per agreement executed in 1959 with Monterey County. The proposed increase in participant allocations would not exceed the 17,500 afy entitlement that was evaluated in the NWP EIR. Therefore, there would be no additional impact associated with participant allocation increases. 6.7.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to biological resource impacts as evaluated in the NWP EIR. Therefore, there would be no impact associated with the proposed water allocation increase. 6.7.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to biological resources as evaluated in the NWP EIR, which mainly focused on potential impacts to biological resources during project construction. Therefore, there would be no impact associated with the proposed water allocation increase. 6.8 Cultural and Paleontological Resources Analysis of Cultural and Paleontological Resources impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.8, and Section 11.0 Responses to Comments. 6.8.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: Impact Impact Description Residual Impact Construction CR.I Soil moving construction activities (e.g., trenching, excavating) could impact significant and important paleontology resources. Class II CR.2 Soil moving construction activities (e.g., trenching, excavating) could impact significant and important geology resources. Class III CR.3 Soil moving construction activities (e.g., trenching, excavating) could impact significant and important geomorphology resources. Class II February 2016 27 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 35 EIR Addendum Impact Impact Description Residual Impact CRA Soil moving construction activities (e.g., trenching, excavating) could impact Class II significant and important prehistoric cultural resources. CR.5 Soil moving construction activities (e.g., trenching, excavating) could impact Class III significant and important historical cultural resources. CR.6 Construction of the proposed project adjacent to or in the vicinity of Class II archaeological or historical sites may result in the looting, vandalism or destruction of cultural resources by construction employees or persons visiting the construction site. Operations None I I Class II All of the potential impacts to Cultural and Paleontological Resources that were evaluated in the NWP Final EIR involved construction activities and the potential disturbance of sensitive resources. Construction impacts CR.1 through CR.6 would not change since the revised water allocations would not require any new construction. Therefore, there would be no new impacts. 6.8.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to cultural or paleontological resource impacts as evaluated in the NWP EIR. Therefore, there would be no impact associated with the proposed water allocation increase. 6.8.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to cultural or paleontological resources as evaluated in the NWP EIR, which mainly focused on potential impacts to cultural or paleontological resources during project construction. Therefore, there would be no impact associated with the proposed water allocation increase. 6.9 Land Use Analysis of Land Use impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.9, and Section 11.0 Responses to Comments. 6.9.1 Analysis of the Revised Project The NWP Final EIR found that there would be no significant impacts to land use resulting from the proposed project as the proposed project is compatible with the underlying land use designations outlined in San Luis Obispo County's General Plan, and with those of affected Federal, State, and local government entities. February 2016 28 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 36 EIR Addendum 6.9.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to land use impacts as evaluated in the NWP EIR. Therefore, there would be no impact associated with the proposed water allocation increase. 6.9.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to land use as evaluated in the NWP EIR. Please see Section 8.0 for a discussion of potential project -related growth inducement impacts. 6.10 Utilities and Public Services Analysis of Utilities and Public Services impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5. 10, and Section 11.0 Responses to Comments. 6.10.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: Impact Impact Description Residual Impact Construction UP.1 Impacts to Water Services during construction. Class III UPA Impacts to Fire Protection and Emergency Response Services. Class II UP.5 Impacts to Law Enforcement. Class III UP.6 Impacts to Waste Disposal Services. Class III UP.8 Impacts to roads and road maintenance. Class III Operations UP.2 I Impacts to Water Services during operation. Class IV Construction and Operations UP.3 Impacts to Energy Resources. Class III UP.7 I Impacts to school facilities. Class III Construction impacts UP.1, UPA, UP.5, UP.6 and UP.8 would not change since the revised water allocations would not require any new construction. Operational Impact UP.2 was considered a beneficial impact for water services since it provided project participants with more flexibility and capacity to provide service to their customers. As is the case with the 2015 drought, participants have seen decreases in the availability of water from other sources, and the proposed increase in the NWP allocation can be used to offset the loss of water from those other sources, which is considered a beneficial impact of the project. Impact UP.3 noted the less than significant impact associated with fossil fuel use during project construction, and electricity use during normal project operations associated with the pump stations and water treatment at full capacity. The impact analysis was evaluated in the EIR based February 2016 29 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 37 EIR Addendum on the San Luis Obispo County Flood Control and Water Conservation District 17,500 afy entitlement from Lake Nacimiento per agreement executed in 1959 with Monterey County. The proposed increase in participant allocations would not exceed the 17,500 afy entitlement that was evaluated in the NWP EIR. Therefore, there would be no additional impact associated with participant allocation increases. Impact UP.7 identified a less than significant adverse impact associated with growth and potential increases in school enrollment. The proposed water allotment increase would only support growth consistent with the City's approved General Plan. Therefore, the potential impact to schools would remain adverse but less than significant. 6.10.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance The NWP Final EIR evaluated a wide variety of climatic conditions and historical water levels to determine potential impacts on water services during both wet and extended dry climatic periods. As such, the Final EIR impact analysis anticipated potential impacts to water resources and socioeconomic impacts associated with participant water withdrawals during drought conditions. In response to mandatory water use reductions, the City's 2015(Water Year 2015 covers October 2014 through September 2015) per capita water use was 97.3 gallons per capita per day (gpcd). Based on WWME policies, the City uses the ten-year gpcd average to project water required to serve build -out population. The ten-year average water use is 114.4 gpcd. Therefore, the current drought does not pose a situation that was not anticipated in the EIR analysis and does not change the relative significance of potential impacts that were identified in the Final EIR. 6.10.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to public services and utilities as evaluated in the NWP EIR. The NWP was designed to provide participants with the flexibility to balance their water demand requirements, recognizing that NWP water would supplement other sources of water that may not always be available in sufficient quantities to meet local demand. As is the case with the 2015 current drought, participants have seen decreases in the availability of water from other sources, and the proposed increase in the NWP allocation would be used to offset the loss of water from other sources. Please see Section 8.0 for a discussion of potential project -related growth inducement impacts. 6.11 Transportation/Circulation Analysis of Transportation/Circulation impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.11, and Section 11.0 Responses to Comments. 6.11.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: February 2016 30 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 38 EIR Addendum Impact Impact Description Residual Impact Construction T.1 Construction associated with the project would temporarily add to local road traffic. Class II T.2 Pipeline construction would require partial road closures and reduce the number of travel lanes during peak traffic periods for roadways with an LOS of D or worse, resulting in a disruption of traffic flow and/or traffic congestion. Class II T.3 Partial street closures would temporarily restrict access to and from private property and adjacent land uses. Class 11 TA Construction activities could interfere with emergency response by ambulance, fire, paramedic, and police vehicles. Class II T.5 Pedestrian circulation would be affected by project activities if pedestrians are unable to pass through a construction zone. Class III T.6 Construction activities could result in physical damage to road surfaces. Class 11 Operations T.7 Operation of WTP, pump stations and pipeline would add truck traffic on local roads. Class III T.8 A pipeline failure could disrupt traffic during repairs. Class II Construction impacts T.1 through T.6 would not change since the revised water allocations would not require any new construction. Impact T.7 is not applicable to the proposed project since the County selected the Raw Water Option and never constructed the water treatment plant at Camp Roberts. Impact T.8 is a baseline condition within the City of San Luis Obispo since the existing water distribution would be utilized and no new construction has been proposed as part of the increased allocation. 6.11.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to transportation impacts as evaluated in the NWP EIR. Therefore, there would be no impact associated with the proposed water allocation increase. 6.11.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to transportation and circulation as evaluated in the NWP EIR, which mainly focused on potential impacts during project construction. Therefore, there would be no impact associated with the proposed water allocation increase. 6.12 Aesthetics/Visual Resources Analysis of AestheticsNisual Resources impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.12, and Section 11.0 Responses to Comments. February 2016 31 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A. Paae 39 EIR Addendum 6.12.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: Impact Impact Description Residual Impact Operations VR.1 Visual impacts due to long-term presence of water intake structures at Nacimiento Dam. Class II VR.2 Visual impacts due to long-term presence of WTP, WTP storage tanks, and the pump station Class III VR.3 Visual impacts due to long-term presence of Salinas River suspended pipe crossing. Class III VRA Visual impacts due to long-term presence of surge tank in the vicinity of Templeton treated water pipeline turnout site. Class II VR.5 Visual impacts due to long-term presence of Rocky Canyon Road storage tank and Happy Valley pump station. Class II VR.6 Visual impacts due to long-term presence of Cuesta Tunnel Storage Tank Class III VR.7 Visual impacts due to long-term presence of turnouts and air release valves. Class III VR.8 Visual impacts due to change in the Lake Nacimiento water levels resulting from the release of additional water. Class III VR.9 Visual impacts due to long-term presence of river discharge facilities. Class III Construction impacts VR.1 through VR.7 and VR.9 would not change since the revised water allocations would not require any new construction. Impact VR.2 is not applicable to the proposed project since the County selected the Raw Water Option and never constructed the water treatment plant at Camp Roberts and the existing pump stations would not change as a result of the project. The impact analysis was evaluated in the EIR based on the San Luis Obispo County Flood Control and Water Conservation District 17,500 afy entitlement from Lake Nacimiento per agreement executed in 1959 with Monterey County. The proposed increase in participant allocations would not exceed the 17,500 afy entitlement that was evaluated in the NWP EIR. Therefore, the NWP Final EIR adequately evaluated the visual impact of low lake levels and there would be no additional impact associated with participant allocation increases. 6.12.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance The circumstances under which the NWP was undertaken remain essentially unchanged. The NWP was designed to provide participants with the flexibility to balance their water demand requirements, recognizing that NWP water would supplement other sources of water that may not always be available in sufficient quantities to meet local demand. As is the case with the current 2015 drought, participants have seen decreases in the availability of water from other sources, and the proposed increase in the NWP allocation would be used to offset the loss of water from other sources. Even under the current drought conditions, the Lake Nacimiento lake level of approximately 719 feet (as of 12/3/15) remains above the minimum and dead pool levels of 688 and 670 feet, respectively. The County's 17,500 afy entitlement represents less than 10 February 2016 32 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A. Paae 40 EIR Addendum percent of the overall annual release volume of 200,000 afy and has only a minor impact on lake level variations. 6.12.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to visual resources as evaluated in the NWP EIR. Therefore, potential impacts would be considered less than significant. 6.13 Agricultural Resources Analysis of Agricultural Resources impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.13, and Section 11.0 Responses to Comments. 6.13.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: Impact Impact Description Residual Impact Construction AG.1 Water pipeline construction within the roads ROW has the potential to adversely impact access to and maintenance of agricultural operations. Class I1 AG.2 Water pipeline construction (including fence removal and trenching) along property boundaries has the potential to impact ranching and livestock operations. Class 11 AG.3 Water pipeline construction and placement of staging areas on agricultural lands have the potential to permanently impact soils on grazing and croplands due to improper soil replacement and/or reseeding efforts. Class 11 AGA Water pipeline construction activities have the potential to adversely impact agricultural lands through the spread of noxious weeds or wind-borne dust. Class 11 Operations None Class 11 All of the potential impacts to agricultural resources that were evaluated in the NWP Final EIR involved construction activities and the potential disturbance of sensitive resources. Construction impacts AGA through AGA would not change since the revised water allocations would not require any new construction. Therefore, there would be no new impacts. 6.13.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to agricultural resource impacts as evaluated in the NWP EIR. Therefore, there would be no impact associated with the proposed water allocation increase. February 2016 33 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A. Paae 41 EIR Addendum 6.13.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to agricultural resources as evaluated in the NWP EIR, which mainly focused on potential impacts to agricultural resources during project construction. Therefore, there would be no impact associated with the proposed water allocation increase. 6.14 Recreational Resources Analysis of recreational resources impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.14, and Section 11.0 Responses to Comments. 6.14.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: Impact Impact Description Residual Impact Construction REC.3 Open trench construction along the following reaches would result in short-term Class II impacts to bicyclists: Rocky Canyon Road to Santa Margarita, Santa Margarita to the Cuesta Tunnel, Cuesta Tunnel to San Luis Obispo WTP, San Luis Obispo WTP to Highway 227/Santa Fe Road, and Highway 227. RECA Partial loss of access to recreational opportunities at Laguna Lake Park due to Class II water pipeline installation activities along Reach No. 10 (Sta. 2520+00-2935+00) near Dalidio Drive in San Luis Obispo. REC.5 Portions of the adopted Salinas River Trail System may need to be re-routed due Class II to the construction of water discharge facilities. Operations REC.1 The partial relocation of a log boom 500 feet from the intake location would Class III prohibit all recreational activity on approximately 2 additional acres of lake surface area. REC.2 Implementation of the proposed project could result in adverse impacts to Class III recreational resources at Lake Nacimiento, as compared to historic conditions, due to the additional lowering of water levels to elevations below 748 feet during periods of drought. Construction impacts REC.3 through REC.5 would not change since the revised water allocations would not require any new construction. Impact REC.1 would remain the same since the proposed allocation increases would not alter the location of the log boom near the dam. The impact analysis was evaluated in the EIR based on the San Luis Obispo County Flood Control and Water Conservation District 17,500 afy entitlement from Lake Nacimiento per agreement executed in 1959 with Monterey County. The proposed increase in participant allocations would not exceed the 17,500 afy entitlement that was evaluated in the NWP EIR. Therefore, the NWP Final EIR adequately evaluated the visual impact of low lake levels and there would be no additional impact associated with participant allocation increases. February 2016 34 Nacimiento Water Project Resolution No. 10700 2016 Series EXHIBIT A, Pa e 42 EIR Addendum 6.14.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance The circumstances under which the NWP was undertaken remain essentially unchanged. The NWP was designed to provide participants with the flexibility to balance their water demand requirements, recognizing that NWP water would supplement other sources of water that may not always be available in sufficient quantities to meet local demand. As is the case with the 2015 drought, participants have seen decreases in the availability of water from other sources, and the proposed increase in the NWP allocation would be used to offset the loss of water from those other sources. Even under the current drought conditions, the Lake Nacimiento lake level of approximately 719 feet (as of 12/3/15) remains above the minimum and dead pool levels of 688 and 670 feet, respectively. The County's 17,500 afy entitlement represents less than 5 percent of the overall storage capacity of 377,900 afy and has only a minor impact on lake level variations. 6.14.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to recreational resources as evaluated in the NWP EIR. Therefore, potential impacts would be considered less than significant. 6.15 Socioeconomic Resources Analysis of Socioeconomic Resources impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.15, and Section 11.0 Responses to Comments. 6.15.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: Impact Impact Description Residual Impact Construction SE.1 Water pipeline construction activities located within the road ROWs near business Class III centers (Paso Robles, Santa Margarita, and San Luis Obispo) have the potential to cause adverse impacts to industries located within and adjacent to project areas by impeding standard business practices. The majority of businesses that would be affected for the short-term are those located within or adjacent to construction areas on North River Road, El Camino Real in Santa Margarita, at the intersection of Dalidio Drive and Madonna Road, along Dalidio Drive, Prado Road extension, and Highway 227. These businesses may experience short-term impedance to business caused by road closures in front of businesses, some difficulties accessing store fronts, and nuisance to patrons from construction activities. This impedance to business would average one to two days during construction (based on construction of 50 to 100 feet of pipeline per day). February 2016 35 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 43 EIR Addendum Impact Impact Description Residual Impact Operations SE.2 Implementation of the proposed project would result in insignificant adverse Class III impacts to businesses that rely on tourism/recreational activities at Lake Nacimiento, as compared to historic conditions, due to the additional lowering of water levels to elevations below 748 feet. SE.3 Implementation of the proposed project would result in insignificant adverse Class III impacts to property values surrounding Lake Nacimiento resulting from changes in lake levels. Construction impact SE.1 would not change since the revised water allocations would not require any new construction. Impacts SE.2 and SE.3 were evaluated in the EIR based on the San Luis Obispo County Flood Control and Water Conservation District 17,500 afy entitlement from Lake Nacimiento per agreement executed in 1959 with Monterey County. The proposed increase in participant allocations would not exceed the 17,500 afy entitlement that was evaluated in the NWP EIR. Therefore, there would be no additional impact associated with participant allocation increases. 6.15.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance The circumstances under which the NWP was undertaken remain essentially unchanged. 6.15.3 Conclusion The proposed increase in the City's water allocation would not result in any appreciable increase in impacts to socioeconomic resources as evaluated in the NWP EIR. Therefore, potential impacts would be considered less than significant. 6.16 Environmental Justice Analysis of Environmental Justice impacts and EIR-identified mitigation measures of the approved Project are contained in the Final EIR, Section 5.16, and Section 11.0 Responses to Comments. 6.16.1 Analysis of the Revised Project The following impacts were identified in the NWP EIR: Impact Impact Description Residual Impact Construction EJ.1 Construction and operational impacts would adversely impact disadvantaged Class III segments of the population in San Luis Obispo County. Construction impact EJ.1 would not change since the revised water allocations would not require any new construction. February 2016 36 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 44 EIR Addendum 6.16.2 Substantial Changes with Respect to the Circumstances under which the Project is Undertaken/New Information of Substantial Importance The circumstances associated with Impact EJ.1 or any other potential environmental justice impacts have not changed. 6.16.3 Conclusion The proposed changes in water allocations would not have any adverse impact on environmental justice issues. The increase allocation would enable the City to maintain water service at an overall cost that would be lower than other new sources of water that are currently available or possible in the future. Minimizing potential increases in water costs would be beneficial to disadvantaged populations where basic utilities represent a significant percentage of their disposable income. 7.0 Cumulative Impacts There is one current cumulative project that would directly affect potential impacts associated with the City's proposed NWP allocation increase. The Interlake Tunnel Project and associated impacts/benefits are described in the following sections. 7.1 Interlake Tunnel Project The Interlake Tunnel Project has been proposed by Monterey County to create a tunnel between Lake Nacimiento and Lake San Antonio. Lake Nacimiento and Lake San Antonio are manmade reservoirs within the Salinas River Basin that provide a number of vital functions to the area. These functions consist of flood control, water supply and recreation. Rain water and runoff from the surrounding watershed is typically stored during winter months and then released in a controlled fashion during the dry summer months. The water supply is used for ground water recharge in the Salinas Valley via releases from both lakes which combine in the upper Salinas River. Water from Lake Nacimiento is used for distribution via the San Luis Obispo County NWP Nacimiento Pipeline project. Flood control is achieved by retaining water and limiting flow in the Nacimiento and San Antonio rivers during winter storm events. The watershed feeding Lake Nacimiento is more productive, filling it in nearly three times faster than Lake San Antonio. At times water releases are made from Lake Nacimiento during the winter months because the lake is at capacity while Lake San Antonio has excess storage available. The goal of the Nacimiento—San Antonio Interlake Tunnel Project is to provide a pathway would be to redirect water that would be effectively washed out to sea and use it to fill the excess capacity typically available in Lake San Antonio. The Interlake Tunnel Project would consist of intake and exit structures connected by a 10,000 foot long tunnel or piping. The intake structures may have grating or other mechanism to restrict fish passage from one lake to the next. The tunnel, approximately 10 feet in diameter, would be small enough to easily maintain and accessed by standing workmen yet large enough to handle the expected high flow rates during storm events. Numerous smaller diameter pipes may be substituted based on efficiency or cost effectiveness in order to support power generation. An in -tunnel turbine or set of turbines may be developed in order to maximize the generation of hydro -electric power from the passing water. Since the maximum elevation of Lake San Antonio is 20 feet lower than that of Lake Nacimiento power generation turbines would be February 2016 37 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 45 EIR Addendum optimized for flow between the lakes. Additional turbines may be defined or developed to capture power generation from the exit into Nacimiento or San Antonio rivers. 7.2 Cumulative Effects As proposed, the Interlake Tunnel Project would allow Lakes San Antonio and Nacimiento to capture and store up to an average additional 60,000 acre feet per year. In addition, the Interlake Tunnel Project would have the potential to improve flood control capabilities for the two lake system, allow for greater aquifer recharge, augment supplies to the Salinas River Diversion Facility (SRDF), reduce lower Salinas River salt water intrusion, enhance aquatic environments in both lakes and along the Salinas River and provide surface water for future projects. There would not be any adverse cumulative impacts associated with the City's proposed NWP allocation increase. While the Interlake Tunnel Project has the potential to increase water storage up to 60,000 afy in Lake San Antonio, it is unclear if the diversion from Lake Nacimiento would result in any changes in water allocations within the County's 17,500 afy entitlement. 8.0 Growth Inducement The City of San Luis Obispo provides water service to residents, businesses, and institutions within city limits. The City's Municipal Code prohibits the provision of water service to anyone outside the city limits, with a few exceptions. These exceptions include the County Airport, since it is seen as an essential service benefiting the city. Another exception is a small number of residents and cattle troughs along the Highway 101 corridor just north of town. The City's requirement to serve water to these properties is in accordance with agreements that date back to the early 1900's. There is also an exception for temporary interim water service to the Fiero Lane Annexation area although that water use was contemplated under the General Plan. Other exceptions exist where individual properties were provided with service prior to adoption of the ordinance. The City originally requested 3,380 afy from NWP supplies as evaluated in the 2004 EIR. This amount was based on the City's adopted General Plan at the time the EIR was prepared. It included 880 afy for new development over the next 30 years, 500 afy to compensate for projected yield reductions at Santa Margarita Lake (Salinas Reservoir) and Whale Rock Reservoir due to siltation over that time. (The EIR reflected the City vote to eliminate the "reliability reserve" from its calculation of future water demand, thus reducing the city's requirement for additional supplies to serve its buildout population of 56,000. The City has since included a reliability reserve in the latest Water and Wastewater Management Element Update in 2010, San Luis Obispo obtains water from Santa Margarita Lake and Whale Rock Reservoir, which have a coordinated yield of 6,940 afy, from the NWP, which has a contract limit of 3,380 afy, 185 afy from recycled water, and a deficit of 500 afy to address siltation. The combined safe yield/available water for the city from these sources is 10,005 afy. Of the 10,005 afy available in the City's water supply portfolio, 7,330 afy is the City's primary2 water supply, 1,174 afy is 2 Primary water supply is the amount needed to meet the General Plan build -out of the City. The quantity of water needed for the City's primary water supply needs is calculated using a ten-year average of actual per -capita water use and the City's build -out population. February 2016 38 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 46 EIR Addendum allocated to the reliability reserve 3, and 1,501 afy is considered as a secondary water source. The increased NWP allocation would be allocated to the City's secondary water supply. Potential Impacts The City of San Luis Obispo's projected population in 2035 is 56,686 based on one percent annual growth. The projected population number does not include current or potential residents of the Cal Poly campus which is within the urban reserve line but outside the city limits, while water planning includes the urban reserve population of 57,200. The potential environmental impacts of full development under the City's General Plan were evaluated in the Environmental Impact Report for the 2014 Land Use and Circulation Elements Update (available for review at http://www.slocity.org/government/department- directory/community-development/planning-zoning/general-plan). When the City adopted the update and certified the EIR, it acknowledged that the planned growth would have significant, adverse impacts. These impacts would be: conversion of prime agricultural land to urban use; increased water usage; unacceptable levels of service for traffic on most arterial streets; change from rural to urban character; the number of workers increasing faster than the number of residents; and certain localized impacts due mostly to street widening or extension projects. Schools would also be further impacted. As noted in Section 3.0, potential growth -related impacts were considered a significant adverse impact that cannot be mitigated to insignificance. The additional NWP allocation would be allocated to the City's secondary water supply and would not be available to accommodate new projects or additional growth. An increase in City's allocation would only serve areas already evaluated and approved for future development potential consistent with existing specific plan areas and City policies and land use designations of the City's General Plan Land Use Element adopted in 2014. Therefore, the proposal to increase the NWP allocation would not result in any additional growth impacts over those identified in the NWP EIR. 9.0 Conclusion This document identified all Project changes, changed circumstances, and new information and memorializes in detail the City's reasoned conclusion that the revised Allocation Project as described in Section 4.0 does not create the conditions requiring the preparation of a Subsequent or Supplemental EIR pursuant to State CEQA Guidelines, sections 15162 and 15163. 10.0 References AEP 2007. Recommendations by the Association of Environmental Professionals (AEP) on How to Analyze Greenhouse Gas Emissions and Global Climate Change in CEQA Documents. Comment Draft. White Paper. March. AIHA 2014, Emergency Response Planning Guideline. 3 Reliability reserve provides a buffer for future unforeseen or unpredictable long-term impacts to the City's available water resources such as loss of yield from an existing water supply source and impacts due to climate change. 4 Secondary water supply is the amount needed to meet peak water demand periods or short-term loss of City water supply sources. The City's secondary water supply is identified as any water supply resources above those needed to meet the primary water supply and reliability reserve. February 2016 39 Nacimiento Water Project Resolution No. 10700 (2016 Series) EXHIBIT A, Page 47 EIR Addendum API 2004, Compendium of Greenhouse Gas Emissions Methodologies for the Oil And Gas Industry. CaIEPA 2006, California Environmental Protection Agency. Climate Action Team, Executive Summary. Climate Action Team Report to Governor Schwarzenegger and the California Legislature; March; Sacramento, CA. CARB 2006, California Air Resources Board AB 32 Text, September 27, 2006. CARB 2007, California Air Resources Board. Climate Change: Information Regarding ARB's Climate Change Program Pursuant to 2006 Assembly Bill 32. Available from www.arb.ca.gov/cc/cc.htm. CARB 2008. California Air Resources Board, Climate Change Scoping Plan, December 2008. CARB 2011, California Air Resources Board, Attachment D: Final Supplement to the AB 32 Scoping Plan Functional Equivalent Document, August 19, 2011. http://www.arb.ca.gov/cc/scopingplan/fed.htm. CARB 2012, Regulation For The Mandatory Reporting Of Greenhouse Gas Emissions, http://www.arb.ca.gov/cc/reporting/ghg-rep/ghg-rep.htm. CARB 2014, First Update to the Scoping Plan", May 2014. CARB 2014, GHG Inventory, http://www.arb.ca.gov/cc/inventory/inventory.htm. CSA 2014, California State Assembly, Sea -Level Rise: a Slow -Moving Emergency. IPCC 2007, Intergovernmental Panel on Climate Change (. Climate change 2007: The physical science basis, summary for policy makers. Working Group 1 Fourth Assessment Report; February. Available from http://www.ipcc.ch/SPM2febO7.pdf. IPCC 2014, Intergovernmental Panel on Climate Change (Climate change 2014: Synthesis Report). Available from http://www.ipcc.ch/. NOAA, 2013. National Oceanic and Atmospheric Administration (NOAA), 2013, website for global climate data, Earth System Research Lab. http://www.esrl.noaa.gov/gmd/ccgg/trends/global.html#global_growth. SLOC 2011, EnergyWise Plan, November 2011, http://www.slocounty.ca.gov/Assets/PL/CAP- LUCE/final/SLOCoCAP_Board_Approved-Complete+Doc.pdf. SLOCAPCD 2012, CEQA Handbook, April 2012. SLOCAPCD 2012, GHG Thresholds and Supporting Evidence, March 28, 2012. February 2016 40 Nacimiento Water Project Third Amendment (Full Allocation) to the Nacimiento Project Water Delivery Entitlement Contract between the District and the City of San Luis Obispo 1 of 5 2 of 5 3 of 5 4 of 5 5 of 5