HomeMy WebLinkAbout04-27-16 PC Item 1 - OTHER-2318-2015Meeting Date: April 27, 2016
Item Number: 1
2
PLANNING COMMISSION AGENDA REPORT
SUBJECT: Review of the Draft Environmental Impact Report (DEIR) for the City of San Luis Obispo
Water Resource Recovery (WRRF) Project.
PROJECT ADDRESS: 35 Prado Road BY: Jennifer Haddow, Rincon Consultants
Brian Leveille, Senior Planner
Phone Number: 781-7166
e-mail: bleveille@slocity.org
FILE NUMBER: OTHR-2318-2015 FROM: David Hix, Deputy Director, Utilities
RECOMMENDATION: Receive a presentation and public testimony, and provide feedback on the
Water Resource Reclamation Facility (WRRF) project DEIR
SITE DATA
Applicant City of San Luis Obispo, Utilities
Department
Representative David Hix, Deputy Director -
Wastewater
Zoning Public Facility (PF and PF-S) and
Conservation and Open Space
(C/OS-20)
General Plan Public and Open Space
Site Area Approximately 66 acres
Environmental
Status
Draft Environmental Impact
Report was released for public
review on April 18, 2016
SUMMARY
The City is proposing the WRRF Project, which entails upgrading the City’s wastewater treatment
facility to comply with updated discharge requirements outlined in the National Pollutant Discharge
Elimination System (NPDES) permit adopted by the Regional Water Quality Control Board (RWQCB)
and State Water Resources Control Board (SWRCB) in September 2014. The NPDES permit went into
effect December 1, 2014, and compliance is required by November 30, 2019. At the same time, the
WRRF would be upgraded to provide a nominal increase in average dry weather flow (ADWF)
capacity to serve the needs of the City, as projected in the updated San Luis Obispo 2035 General Plan
Land Use Element.
A Draft Environmental Impact Report (DEIR) has been prepared that evaluates the proposed WRRF
project’s potential to significantly impact the environment, while also identifying ways to reduce or
avoid environmental impacts through mitigation measures and alternatives to the project. The DEIR
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has been prepared in accordance with California Environmental Quality Act (CEQA) statutes and
guidelines. The City is the lead agency for the CEQA process.
1.0 COMMISSION’S PURVIEW
Review the DEIR, receive public comment, and provide feedback on any needed refinements or issue
areas which should be addressed in the Final Environmental Impact Report (FEIR).
2.0 BACKGROUND
The City WRRF Facilities Plan (San Luis Obispo, June 2015) contains an extensive discussion of the
background for the project, technical evaluations of various treatment options, and detailed
descriptions and graphics for the various improvements proposed. A brief summary of that information
is presented here, with an emphasis on the items that relate to environmental issues and the assessment
of impacts and mitigation within the DEIR.
The primary document or permit that governs the WRRF is the approval from the Regional Water
Quality Control Board (RWQCB) and State Water Resources Control Board (SWRCB). This approval
is in the form of Order No. R3-2014-0033, establishing the Waste Discharge Requirements for the
facility. Under authority from the U.S. Environmental Protection Agency (USEPA), the SWRCB
approval also serves as the federal permit under the National Pollutant Discharge Elimination System
(NPDES) requirements, and the approval is NPDES No. CA0049224.
The Waste Discharge Requirements Order establishes prohibitions on certain types of discharges, and
limitations and specifications for the permitted discharges. This Order was adopted in September,
2014, and it establishes discharge requirements that are more stringent than before, and which the
current treatment plant equipment cannot meet. The Waste Discharge Requirements also has an
accompanying Time Schedule Order (TSO No. R3-2014-0036) that establishes the compliance
schedule for the project.
The WRRF Facilities Plan (San Luis Obispo City June 2015: Section 1) explains this situation:
A key driver of the WRRF Project is the new NPDES permit adopted in September 2014
(effective December 1, 2014). The new permit includes discharge limitations that will
require significant process upgrades. Specifically, the new permit includes strict
disinfection byproduct limits which will require a new disinfection technology, as well as
nitrate limits which will require a significant upgrade of the secondary treatment
processes. A new Time Schedule Order (TSO) was also adopted in September 2014 which
requires the City to achieve the disinfection byproduct limits and nitrate limits by
November 30, 2019.
The existing facility is currently rated for 5.1 million gallons per day (mgd) for ADWF conditions. The
WRRF Facilities Plan states that the plant currently treats an average of approximately 3.5 mgd under
ADWF (without Cal Poly the ADWF is 3.1 mgd) and 3.9 mgd under average annual flow (AAF)
conditions (San Luis Obispo June 2015: Section 1.1 and Table 5-1). The EIR that was prepared for the
City’s recent update of the Land Use and Circulation Elements estimates the AAF at 4.39 mgd based
on records from 2000 through 2012 (San Luis Obispo December 2014: page 4-359). The difference
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between the two AAF condition estimates may reflect the influence of more recent drought conditions,
including conservation measures implemented in response.
The City General Plan Land Use Element projects a future 2035 City population of 56,686 (City of San
Luis Obispo December 2014: Table 3), with a slightly higher population of 57,200 if the City’s Urban
Reserve Capacity is used. For planning purposes, a per capita wastewater generation rate of 87.5
gallons per capita per day (gpcd) for ADWF conditions was used to determine the required capacity,
which is consistent with what the City has used in past studies and evaluations (City of San Luis
Obispo 2015: page 5-2). A population projection of 57,200, which is in line with the City’s Urban
Reserve Capacity as well as projected contributions from Cal Poly, was used to determine an estimated
ADWF of 5.4 mgd.
During wet weather, additional water enters the collection system through inflow and infiltration even
though the system is not designed to collect stormwater flows. The peak flows during wet weather
amount to an equivalent of 33.5 mgd (San Luis Obispo City June 2015: Table 1-2), but the current
plant has a peak wet weather flow capacity of 22 mgd (City of San Luis Obispo September 2014: page
4-359). Currently, wet weather flows are handled through a combination of temporary storage in ponds
and the practice of blending treated and less treated flows prior to discharge; however, the latter
practice is no longer permitted under the new NPDES permit.
In summary, the WRRF is being upgraded to meet a number of objectives, including providing the
nominal increase in ADWF capacity to serve the needs of the City as anticipated in the updated
General Plan Land Use Element to upgrade/replace aging infrastructure. Primarily, though, the WRRF
upgrade is necessary to meet the more stringent discharge requirements established by the RWQCB
and SWRCB in late 2014. Finally, the proposed upgrades would increase the production of recycled
water, provide a number of public amenities, and position the City for potential future potable reuse, as
described below. A more complete description of the individual project components and their
respective impacts follows.
The City is acting as the Lead Agency in accordance with the California Environmental Quality Act
(CEQA) in processing the EIR. In conjunction with the EIR certification, the City will have the
opportunity to act on project approvals related to ministerial permits (i.e., building permits, grading
and drainage permits, encroachment permits, etc.) and if applicable, discretionary permits (i.e.,
architectural review permit and land use permit). Staff will return to the Planning Commission for
review of the Final EIR and if applicable, land use entitlements. Once the City has certified the Final
EIR, other agencies will be able to utilize the EIR to process regulatory permit requests including the
California Department of Fish and Wildlife (CDFW) and RWQCB. The SWRCB will also use the
Final EIR in evaluating the project’s compliance with requirements und er the State Revolving Fund
(SRF) Loan Project
The purpose of this hearing is to highlight the findings of the DEIR, while receiving public and
Commissioner testimony on the DEIR during the public comment period. The public comment period
for the DEIR ends on Thursday, June 2nd, 2016. Comments on the DEIR will be utilized to prepare the
Final EIR which is anticipated to be released in July of this year.
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3.0 PROJECT INFORMATION
3.1 Site Information/Setting
The City of San Luis Obispo WRRF is located at 35 Prado Road, San Luis Obispo, CA 93401 (see
DEIR Figure 2-2. The facility occupies approximately 66 acres (along with other uses described
below) between U.S. Highway 101 (U.S. 101) on the west and San Luis Obispo Creek on the east.
Most of the components of the WRRF are located within Assessor Parcel Number 053-051-045
(54.7 acres), which fronts Prado Road. The project site also includes the mostly undeveloped area
to the southwest of the main facility site as well as the area containing the decommissioned
chlorine contact channels and related equipment, approximately 0.5 mile south of the main facility.
The decommissioned chlorine contact channels and equipment are located adjacent to existing
holding ponds near the present effluent outfall, or discharge point, for the WRRF. In addition, San
Luis Obispo Creek runs adjacent to the eastern boundary of the site. Further site specific details are
noted below.
3.2 Project Description
The WRRF Facilities Plan provides details regarding the components of the project and their
construction. These are summarized as follows:
1. Demolition of Existing Structures. During the WRRF upgrade certain structures would be
demolished to make room for new and enlarged equipment. The Prado Day Center building
would be removed, along with the small bore gun range, some sludge drying beds and other
facilities. DEIR Figure 2-3 shows a draft demolition plan, indicating the structures that are
proposed to be demolished. Since the WRRF must continue operating during the upgrades,
not all of the indicated demolition would occur concurrently.
2. Treatment Upgrades. Section 7 in the WRRF Facilities Plan provides a detailed
description of the proposed upgrades within the WRRF. The details of the equipment and
processes identified for the WRRF upgrade are described below and are based on meeting
various performance standards, so that the facility will comply with the discharge
specifications set by the SWRCB. The proposed changes are shown in DEIR Figure 2-4
(Construction Sequencing) and DEIR Figure 2-5 (Proposed Site Plan), and summarized
briefly below. DEIR Figure 2-6 illustrates the proposed process flow diagram with the
upgraded equipment. DEIR Figure 2-7 provides photos characterizing existing conditions at
the site and locations of proposed upgrades.
Primary Treatment. Addition of a new flow monitoring system, along with other
mechanical and structural improvements to the existing headworks. Rehabilitation of
the primary clarifiers and upgrades to the supporting mechanical equipment.
Flow Equalization. Upgrades to the existing equalization pond (including an increase in
capacity) to enhance operations and maintenance and improve wet weather
performance.
Secondary Treatment. Upgrades and expansion of secondary treatment system to
remove nitrogen and organic components, necessary to meet the new Waste Discharge
Requirements specifications.
Tertiary Treatment. Expansion of the filter capacity to meet peak flow requirements and
construction of a new Ultraviolet (UV) disinfection unit to meet the new stringent
discharge limits for disinfection byproducts
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Solids and Liquids Handling Processes, including:
o Solids Thickening. Addition of new equipment to thicken the solids produced in the
treatment process. Upgrade would replace existing Dissolved Air Flotation
Thickener, with a less energy-intensive process.
o Anaerobic Digester. Construction of a new anaerobic digester.
o Biosolids Dewatering. Replacement of the old belt filter press with a new screw
press.
o Sidestream Treatment/Return Stream Management. Several upgrades would be
made in the handling and treatment of waste streams produced internally. These
include filter backwash, thickening return fluid (sidestream), digester return fluid
(sidestream), lagoon supernatant (from dewatering sidestream), sludge drying bed
return fluid, and plant drain.
3. Cooling. Upgrades to effluent cooling would be provided as part of the project, either
through the addition of cooling towers, wetland cooling or other methods. Additional
cooling could be provided through a combination of cooling towers and/or heat exchangers.
An alternate cooling method may include use of the undeveloped area immediately
southwest of the main facility for development of a wetland cooling system. The concept of
using wetlands for cooling and polishing effluent before discharge in lieu of using
mechanical chillers has been modeled and determined to be a viable option for cooling at
the site. The size of this area is sufficient to allow use of the wetland cooling option without
requiring removal of the portion of Bob Jones Bike Trail present in that area of the site,
though some realignment may be necessary.
4. Stormwater Management/Flood Protection Improvements. The project would also
include internal drainage improvements. As part of the proposed project, stormwater
discharges from the site would be managed using one of several options, including a)
continuing to direct all stormwater to the existing discharge points, b) directing part or all of
the onsite stormwater flow to the undeveloped area southwest of the main facility, if the
wetland cooling option is selected, c) directing part of the stormwater flow to a new
discharge point along San Luis Obispo Creek, possibly near the northeast corner of the
WRRF, or d) a combination of the three options above. Low impact development (LID),
may also be included as part of the internal stormwater management plan for the site.
Planned flood protection improvements include construction of enhanced protection for key
facilities, which includes raising concrete walls protecting some structures, and a new berm
around the flow equalization basin.
5. Public Amenities. Public amenities proposed at the site include construction of a new
Water Resource Center, and grading and restoration of land at the northeast corner of the
WRRF after removal of the existing supernatant lagoon, which may ultimately be used for
public park purposes under the direction of the City Parks and Recreation Department. The
purpose of the Water Resource Center is to serve staff needs while simultaneously engaging
and educating the community on the water cycle and recycled water treatment. Other
amenity improvements would include a Learning Center with a walking tour of the facility,
interpretive exhibits, picnic areas, a small amphitheater and demonstration gardens and
wetlands. The project would also include improvements to perimeter fencing and
landscaping, particularly at the Prado Road frontage of the property, as well improvements
for security, access control, and internal circulation.
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6. Research and Development. Cal Poly currently conducts water treatment research at the
WRRF facility. Cal Poly would continue to conduct these types of activities in the future at
various locations throughout the site, depending on the type of research being conducted. In
addition, the City intends to test pilot processes and treatment technologies in the future at
the WRRF facility. These tests would occur at various locations throughout the site,
depending on the type of research being conducted.
7. Other Proposed Improvements. The following is a list of other proposed
upgrades/improvements included as part of the WRRF Project.
Odor Control improvements
Internal Access Improvements
Additional Electrical and Control Upgrades
Renewable Energy Improvements
4.0 DRAFT EIR KEY FINDINGS
The following paragraphs briefly introduce each of the project impacts and the key findings of the
DEIR. The DEIR classifies potential environmental impacts into four categories:
Class I: Impacts which are significant and unavoidable even with mitigation
Class II: Impacts that can be mitigated to less than significant levels
Class III: Less than significant impacts that do not require mitigation
Class IV: Beneficial impacts
No Class I impacts were identified for the proposed project. Mitigations are proposed for all Class II
impacts. The Attached Executive Summary (Attachment 2) and the complete DEIR (enclosed CD or
weblink: http://www.slocity.org/Home/ShowDocument?id=10532) provide substantial additional
detail in addition to describing project impacts and proposed mitigation measures.
4.1 Class I Impacts (Significant and Unavoidable)
None identified.
4.2 Class II Impacts (Significant but Mitigable)
Air Quality. Construction of the proposed project would result in temporary generation of air
pollutants, which would affect local air quality. Short term emissions would exceed SLOAPCD
thresholds for ozone precursors.
Biological Resources. Construction of the project could have a substantial adverse effect on
candidate, sensitive, or special-status species.
Biological Resources. Construction of the project could have a substantial adverse effect on
sensitive habitats, including riparian areas.
Biological Resources. Construction of the project could have a substantial adverse effect on
Federally protected wetlands as defined by Section 404 of the Clean Water Act.
Cultural Resources. Construction of the proposed project would involve ground-disturbing
activities which have the potential to unearth or adversely impact archaeological resources.
Cultural Resources. Construction of the proposed project would involve ground-disturbing
activities which have the potential to unearth or adversely impact paleontological resources.
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Hazards and Hazardous Materials. Construction of the proposed project would temporarily
increase the routine transport and use of hazardous materials used in construction activities.
Operation of the expanded and upgraded WRRF would entail the routine transportation, use,
storage, and/or disposal of minor amounts of hazardous materials.
Hazards and Hazardous Materials. The proposed project has potential to create a hazard
through reasonably foreseeable upset and accident conditions involving the release of
hazardous materials into the environment during both construction and operation.
Hazards and Hazardous Materials. The proposed project could result in the disturbance of
contaminated soils on an active cleanup sites listed on the SWRCB GeoTracker database.
Hazards and Hazardous Materials. The proposed project could impair or physically interfere
with an adopted emergency evacuation and response during construction.
Hazards and Hazardous Materials. The proposed project would not increase the exposure of
people or structures to wildfire risks due to population growth, but construction activities could
create hazardous fire conditions.
Hydrology and Water Quality. During construction the proposed project could potentially
violate water quality standards or waste discharge requirements.
Hydrology and Water Quality. The proposed project could result in placement of stormwater
outfall infrastructure within a 100-year flood hazard area.
Recreation. Impacts associated with construction of the recreational components of the
proposed project are part of the wider project analyzed in the DEIR. Potential adverse impacts
have been identified in several environmental issue areas, related primarily to construction
activities associated with the proposed project.
4.3 Class III Impacts (Less than Significant)
Air Quality. The proposed project would not contribute to population growth, and would
therefore be consistent with the growth assumptions in the 2001 Clean Air Plan and the City of
San Luis Obispo Climate Action Plan.
Air Quality. Construction of the proposed project would result in temporary generation of air
pollutants, which would affect local air quality. Short term emissions would exceed SLOAPCD
thresholds for ozone precursors.
Air Quality. Standard operation of the proposed project would involve regular testing of two
new diesel generators, which would incrementally increase long-term emissions. Regular
testing of the generators would ensure they would not generate emissions greater than the daily
or annual thresholds set by SLOAPCD.
Air Quality. In the unlikely event of an emergency power outage, the two new generators
would temporarily generate worst-case scenario emissions over a short period of time.
Greenhouse Gas Emissions. The proposed project would generate greenhouse gas emissions
through construction, increased energy use, increased biogenic processes as a result of the
increased wastewater capacity, and testing of emergency diesel generators. The increased
emissions would be below the SLOAPCD threshold for annual greenhouse gas emissions.
Greenhouse Gas Emissions. The proposed project would not conflict with State GHG
reduction goals, or any applicable plan, policy, or regulation adopted for the purpose of
reducing GHG emissions.
Hydrology and Water Quality. The proposed project would not result in flooding, erosion or
siltation on- or off-site.
Noise. Construction activities associated with the proposed project would expose nearby
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sensitive receptors to temporary increases in noise, however, these would not exceed City noise
thresholds.
Noise. Project construction would expose nearby sensitive receptors to a temporary increase in
vibration levels. However, vibration levels during construction would not expose nearby
structures to vibration damage or excessive vibration noise.
Noise. Noise associated with operation of the proposed project would not exceed City
thresholds.
Public Services and Utilities. The proposed project would not directly or indirectly induce
population growth and require the need for new or addition fire protection or police services
that would result in the need for expanded facilities.
Public Services and Utilities. Stormwater drainage improvements are included as part of the
proposed project, therefore the project would not result in the need for additional expansion.
Public Services and Utilities. The proposed project would be served by a landfill with
sufficient capacity to accommodate solid waste that would be generated.
Public Services and Utilities. The proposed project would comply with all federal, state, and
local statutes and regulations related to solid waste.
4.4 Class IV Impacts (Beneficial)
Air Quality. The proposed project would have the potential to emit odors as a result of several
processes on site. However, the project would include a variety of odor control technologies,
ultimately reducing odor from the site, and would be 300 feet away from the nearest sensitive
receptor.
Hydrology and Water Quality. The proposed project would result in an improvement in the
quality of discharges from the WRRF to San Luis Obispo Creek.
Recreation. The proposed project would potentially affect operation of existing and planned
park and recreation facilities, as it would enhance recreational amenities at the site.
Public Services and Utilities. The proposed project would include improvements to the
WRRF, which would improve treated wastewater quality.
5.0 DRAFT EIR ALTERNATIVES
Alternatives to the project have been developed in accordance with CEQA. Two alternatives to the
proposed project were chosen for analysis as follows: Alternative 1: No Project and Alternative 2:
Alternate Process Options.
5.1 No Project Alternative (Required by CEQA)
The No Project Alternative assumes that the proposed project site and existing treatment methods at
the WRRF would remain as currently described in the existing setting under each issue area discussed
in Chapter 3, Environmental Setting, Impacts and Mitigation Measures, of the DEIR. It should be
noted that implementation of the No Project Alternative would not be feasible because implementation
of improvements at the project site are required to meet the more stringent discharge limits in the new
NPDES permit for the facility as well as the accompanying TSO. If the No Project Alternative is
selected the City would not be able to achieve compliance with the NPDES permit requirements in the
required timeframe.
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The No Project Alternative would be the Environmentally Superior Alternative when compared to the
proposed project in that it would avoid all of the potentially significant impacts associated with
construction of the proposed project. However, it would not meet any of the objectives of the proposed
project, including complying with the stringent discharge requirements included in the facility’s
September 2014 NPDES permit and the accompanying TSO that establishes the compliance schedule
for the project. In addition, none of the beneficial impacts of the project with regards to water quality
and odor reduction would be realized under this alternative.
5.2 Alternative 2 (Alternate Process Options)
Alternative 2 (Alternate Process Options) considers alternate technologies that would enable the
WRRF to meet the new NPDES permit requirements. These process alternatives are available for
renewable energy, flow equalization, disinfection, cooling, secondary treatment and filtration. Details
of these various alternatives are discussed in the WRRF Facilities Plan. While these alternate process
options were not included in the proposed project, they would be feasible for use at the WRRF site,
though not preferred. For a list of the current technology at the site, the technology that was selected
for each process for inclusion in the proposed project, and a list of the alternate technologies
considered as part of this alternative, refer to Table 5-1 of the DEIR. The alternate technologies
considered comprise Alternative 2.
Alternative 2 (Alternate Process Options) would result in a similar level of impact as the proposed
project, though in some issue areas, such as air quality, noise and greenhouse gases, potential impacts
could be better or worse depending on which combination of process options is selected. This
alternative would avoid the potential need to realign the segment of the Bob Jones Bike Trail that
passes through the southern portion of the site as it would not include the wetlands cooling option. The
impact to the trail resulting from the proposed project would be less than significant as it would not
necessitate removal of the trail from within the site and would maintain continuity with the portions of
the trail north and south of the facility.
6.0 DRAFT EIR PROCESS
Following completion of the Draft EIR comment period, the City and the EIR consultant will respond
to any comments received and make necessary amendments to the EIR. Table 1 illustrates the
estimated timing.
Table 1: Anticipated EIR/Process Timing
Activity Timing
Release of Draft EIR April 18th
End of public Comment Period June 2nd
Estimated Release of Final EIR July 5th
Planning Commission Hearing (FEIR, entitlements) October 23
City Council Hearing (FEIR, entitlements) November 19
7.0 NEXT STEPS
Following the end of the public comment period, the Final EIR will be prepared and provided to the
Planning Commission for review and recommendation to the City Council. If applicable, any land use
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entitlements associated with the proposed project will also be reviewed by the Planning Commission at
that time. Following City certification of the FEIR, the City will be able to utilize the EIR to process
City permits, pursue State and Federal Agency regulatory permits and as a component of the City’s
application to the SWRCB SRF Loan Program.
8.0 ATTACHMENTS
1. Vicinity Map
2. Executive Summary
Enclosed: CD copy of DEIR
The DEIR is also available online at: http://www.slocity.org/Home/ShowDocument?id=10532
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Attachment 1
Water Resource Recovery Facility Project Draft EIR
Executive Summary
City of San Luis Obispo
1
EXECUTIVE SUMMARY
This draft environmental impact report (Draft EIR) evaluates the environmental impacts of the
proposed City of San Luis Obispo Water Resource Recovery Facility (WRRF) Project. This
document has been prepared in accordance with California Environmental Quality Act (CEQA)
statutes and guidelines, and includes additional analysis for the “CEQA-Plus” documentation
that is required for the City of San Luis Obispo (City) to apply for State Revolving Fund (SRF)
funding.1
The City is the lead agency for the CEQA process. Inquiries regarding this document and
project should be directed to:
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA
Attn: David Hix
Phone: 805-781-7039
PROJECT OVERVIEW
The City proposes the WRRF Project, which entails upgrading the City’s wastewater treatment
facility to comply with updated discharge requirements outlined in the National Pollutant
Discharge Elimination System (NPDES) permit adopted by the Regional Water Quality Control
Board (RWQCB) and State Water Resources Control Board (SWRCB) in September 2014. The
NPDES permit went into effect December 1, 2014, and compliance is required by November 30,
2019. At the same time, the WRRF would be upgraded to provide a nominal increase in average
dry weather flow (ADWF) capacity to serve the needs of the City, as projected in the updated
San Luis Obispo 2035 General Plan Land Use Element.
Need and Objectives
The WRRF Project is necessary in order to meet new wastewater discharge requirements and
accommodate forecasted future growth in the City. The objectives of the WRRF Project include:
1. Meeting the standards outlined in the NPDES permit adopted by the RWQCB and
SWRCB in September 2014 (effective December 1, 2014)
2. Providing a nominal increase in ADWF capacity to serve the needs of the City, as
anticipated in the updated General Plan Land Use Element
3. Increasing the production of recycled water, positioning the City for potential future
potable reuse
4. Incorporating interpretive features and public amenities
5. Replacing aging infrastructure and equipment
1 SWRCB is the responsible agency that would review and consider the information in the environmental document
prior to approving the project.
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Attachment 2
Water Resource Recovery Facility Project Draft EIR
Executive Summary
City of San Luis Obispo
2
The new NPDES permit contains stricter discharge limitations that require significant process
upgrades to the WRRF facility, specifically, disinfection byproduct limits that will require new
disinfection technology and nitrate limits that will require a significant upgrade of the
secondary treatment processes. A new Time Schedule Order (TSO) was also adopted in
September 2014, which requires the City to achieve the disinfection byproduct limits and nitrate
limits by November 30, 2019.
The City General Plan Land Use Element projects a future 2035 City population of 57,200 (City
of San Luis Obispo December 2014: Table 3). The ADWF capacity required to accommodate this
increase in population is 5.4 million gallons per day (mgd), while the current capacity of the
WRRF is 5.1 mgd.2 Therefore, a nominal increase in ADWF capacity is needed to serve the
needs of the City’s anticipated growth.
For “a statement of objectives sought by the proposed project,” which includes the City’s vision,
mission, and objectives for the proposed project, please refer to Section 2.5, Project Objectives.
Project Location
The City of San Luis Obispo Water Resource Recovery Facility (WRRF) is located at 35 Prado
Road, San Luis Obispo, CA 93401. The facility occupies approximately 55 acres (along with
other uses described below) between U.S. Highway 101 (U.S. 101) on the west and San Luis
Obispo Creek on the east. Figure 2-1 shows the project location within the City limits and in the
region. Figure 2-2 shows the project site and vicinity.
Project Description
The WRFF Project includes equipment and process upgrades that are based on meeting various
performance standards so that the facility will comply with updated discharge specifications set
by the RWQCB and SWRCB. Implementation of the proposed project would include the
following elements:
1.Demolishing existing structures to make room for new and enlarged equipment
2.Modernizing equipment and operations processes to improve primary, secondary, and
tertiary wastewater treatment systems, as well as solids and liquids handling processes
3.Upgrading effluent cooling system through the addition of cooling towers, wetland
cooling, and/or other methods
4.Improving internal site drainage for stormwater management and flood control, with
the possibility of designing these improvements to support the effluent cooling system
5.Incorporating public amenities at the site, including within the newly constructed Water
Resource Center, the proposed Learning Center, and grading and restoring land at the
northeast corner of the WRRF site after removal of the existing supernatant lagoon; this
restored area may ultimately be used for public park purposes under the direction of the
City Parks and Recreation Department
6.Promoting continued research and development activities by Cal Poly and future testing
of as yet unidentified pilot process and treatment technologies at the WRRF facility
2 These estimates were calculated based on the three driest months of the year.
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Attachment 2
Water Resource Recovery Facility Project Draft EIR
Executive Summary
City of San Luis Obispo
3
These project elements are further described in Section 2.4.2, Project Characteristics, and the
proposed changes are shown in Figure 2-4 (Construction Sequencing) and 2-5 (Proposed Site
Plan). Additionally, detailed descriptions of the proposed upgrades are provided in Section 7 of
the WRRF Facilities Plan, while control upgrades and other proposed amenities are further
described in other sections of the WRRF Facilities Plan. The WRRF Facilities Plan is available at
the following link: http://www.slocity.org/government/department-directory/utilities-
department/wastewater/wastewater-treatment/wrrf-upgrade-project. (San Luis Obispo City
June 2015)
Because the WRRF must continue operating during upgrades, not all of the demolition and
upgrades would occur concurrently. The proposed construction sequencing is shown in Figure
2-4 (Construction Sequencing) and described in the WRRF Facilities Plan (San Luis Obispo City
June 2015: Figure 13-2). This sequencing, however, may be refined as the design process
continues.
Construction activities are expected to start in late 2017. The deadline for most of the proposed
upgrades that are required to meet the TSO issued by the SWRCB is November 30, 2019. Other
upgrades that will address capacity, condition and other facility needs are planned to be
completed as part of this project, at a later date. As the City continues to move forward with
design procurement discussions with the RWQCB, the City will evaluate if the compliance
schedule for nitrate permit limit can be extended.
PROJECT ALTERNATIVES
Two alternatives to the proposed project were chosen for analysis as follows:
•Alternative 1: No Project
•Alternative 2: Alternate Process Options
The No Project Alternative assumes that the proposed project site and existing treatment
methods at the WRRF would remain as currently described in the existing setting under each
issue area discussed in Chapter 3, Environmental Setting, Impacts and Mitigation Measures. It
should be noted that implementation of the No Project Alternative would not be feasible
because implementation of improvements at the project site are required to meet the more
stringent discharge limits in the new NPDES permit for the facility as well as the accompanying
TSO. The TSO establishes the compliance schedule for the permit and requires the City achieve
the required disinfection byproduct limits and nitrate limits by November 30, 2019. If the No
Project Alternative is selected the City would not be able to achieve compliance with the NPDES
permit requirements in the required timeframe.
Alternative 2 (Alternate Process Options) considers alternate technologies that would enable the
WRRF to meet the new NPDES permit requirements. These process alternatives are available
for renewable energy, flow equalization, disinfection, cooling, secondary treatment and
filtration. Details of these various alternatives are discussed in the WRRF Facilities Plan. While
these alternate process options were not included in the proposed project, they would be
feasible for use at the WRRF site, though not preferred. For a list of the current technology at the
site, the technology that was selected for each process for inclusion in the proposed project, and
a list of the alternate technologies considered as part of this alternative, refer to Table 5-1. The
alternate technologies considered comprise Alternative 2.
PC 1- 14
Attachment 2
Water Resource Recovery Facility Project Draft EIR
Executive Summary
City of San Luis Obispo
4
TYPE OF DOCUMENT
This document has been prepared in accordance with CEQA statutes and guidelines, and
includes additional analysis required for the “CEQA-Plus” documentation that is required for
the City to apply for SRF funding.3 CEQA-Plus documentation includes evaluation of
compliance with the Federal Endangered Species Act, National Historic Preservation Act, and
the General Conformity Rule for the Federal Clean Air Act. In addition, it requires evaluation of
compliance with the federal regulatory framework. Relevant to this project are the Migratory
Bird Treaty Act, policies for protection of wetlands, and flood plain management.
In compliance with CEQA, this Draft EIR contains a description of the project and existing
environmental setting, identification of project impacts, mitigation measures for impacts found
to be significant, and an analysis of project alternatives. The analysis in this document is
expanded beyond the typical content requirements of an EIR to include additional CEQA‐Plus
information pertaining to federally designated endangered species, cultural resource protection,
conformity with applicable air management plans, and other federal executive orders and
federal regulations.
This EIR focuses on those issues of primary concern identified through an initial scoping
process, which included discussions among the public, consulting staff, and the City during the
30-day public comment period for the Notice of Preparation (NOP). During this process, nine
issue areas were identified for evaluation in this Draft EIR. These topics are discussed in
Chapter 3, Environmental Setting, Impacts and Mitigation Measures, and include:
•Air Quality
•Biological Resources
•Cultural Resources
•Greenhouse Gas Emissions
•Noise
•Recreation
•Hydrology and Water Quality
•Hazards and Hazardous Materials
•Public Services and Utilities
The remaining environmental topics are addressed in Section 3.10, Effects Found Not to be
Significant.
AREAS OF CONTROVERSY
No comments or concerns were raised by agencies or the public during the scoping comment
period.
ISSUES TO BE RESOLVED
There are no issues to be resolved prior to implementation of the proposed project.
3 SWRCB is the responsible agency that would review and consider the information in the environmental document
prior to approving the project.
PC 1- 15
Attachment 2
Water Resource Recovery Facility Project Draft EIR
Executive Summary
City of San Luis Obispo
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SUMMARY OF IMPACTS AND MITIGATION MEASURES
Table ES-1 provides a summary of potential impacts by issue area, as analyzed in Chapter 3,
Environmental Setting, Impacts and Mitigation Measures. Only the impacts in Chapter 3 have been
assigned a numbering system. All identified environmental impacts associated with the
proposed project can be mitigated to less than significant levels, either with the implementation
of standard project best management practices (BMPs) included as part of the proposed project
and/or with mitigation measures identified in the analysis. No significant unavoidable impacts
would occur from proposed project implementation.
Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
AIR QUALITY
Impact AQ-1 The proposed
project would not contribute to
population growth, and would
therefore be consistent with the
growth assumptions in the 2001
Clean Air Plan and the City of
San Luis Obispo Climate Action
Plan. This impact would be Class
III, less than significant.
None required. Less than
significant.
Impact AQ-2 Construction of the
proposed project would result in
temporary generation of air
pollutants, which would affect
local air quality. Short term
emissions would exceed
SLOAPCD thresholds for ozone
precursors. Impacts would be
Class II, potentially significant
unless mitigation is incorporated.
AQ-2(a) Standard Mitigation Measures. The project shall
comply with the following, outlined in Section 2.3.1 of the
SLOAPCD CEQA Handbook:
•Maintain all construction equipment in proper tune
according to manufacturer’s specifications;
•Fuel all off-road and portable diesel powered equipment
with CARB certified fuel (non-taxed version suitable for
use off-road);
•Use diesel construction equipment meeting CARB’s Tier
2 certified engines or cleaner off-road heavy-duty diesel
engines, and comply with the State off-Road Regulation;
•Use on-road heavy-duty trucks that meet the CARB’s
2007 or cleaner certification standard for on-road heavy-
duty diesel engines, and comply with the State On-Road
Regulation;
•Construction or trucking companies with fleets that do
not have engines in their fleet that meet the engine
standards identified in the above two measures (e.g.
captive or NOX exempt area fleets) may be eligible by
proving alternative compliance;
•All on and off-road diesel equipment shall not idle for
more than 5 minutes, with the exception of concrete
delivery vehicles. Signs shall be posted in the
designated queuing areas and or job sites to remind
drivers and operators of the 5 minute idling limit;
•Diesel idling within 1,000 feet of sensitive receptors is
not permitted;
•Staging and queuing areas shall not be located within
1,000 feet of sensitive receptors;
•Equipment shall be electrified when feasible;
•Diesel powered equipment shall be substituted with
gasoline powered equipment when feasible;
•Alternatively fueled construction equipment shall be used
onsite when feasible, such as compressed natural gas
Less than
significant.
PC 1- 16
Attachment 2
Water Resource Recovery Facility Project Draft EIR
Executive Summary
City of San Luis Obispo
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
(CNG), liquefied natural gas (LNG), propane, or
biodiesel.
AQ-2(b) Best Available Control Technology (BACT) for
Construction Equipment. The following BACTs, outlined in
the SLOAPCD CEQA Handbook, shall be incorporated into
construction of the proposed project:
•Tier 3 or Tier 4 off-road and 2010 on-road compliant
engines shall be used;
•Equipment shall be repowered with the cleanest engine
available;
•California Verified Diesel Emission Control Strategies
shall be installed.
Impact AQ-3 Standard
operation of the proposed project
would involve regular testing of
two new diesel generators, which
would incrementally increase
long-term emissions. Regular
testing of the generators would
ensure they would not generate
emissions greater than the daily
or annual thresholds set by
SLOAPCD. Impacts would be
Class III, less than significant.
None required. Less than
significant.
Impact AQ-4 In the unlikely
event of an emergency power
outage, the two new generators
would temporarily generate
worst-case scenario emissions
over a short period of time.
Impacts would be Class III, less
than significant.
None required. Less than
significant.
Impact AQ-5 The proposed
project would have the potential
to emit odors as a result of
several processes on site.
However, the project would
include a variety of odor control
technologies and would be 300
feet away from the nearest
sensitive receptor. Therefore,
impacts would be Class IV,
beneficial.
None required. Beneficial.
BIOLOGICAL RESOURCES
Impact BIO-1 Construction of
the project could have a
substantial adverse effect on
candidate, sensitive, or special-
status species. Impacts would be
Class II, potentially significant
unless mitigation is incorporated.
BIO-1(a) Special Status Plant Species Surveys. Prior to
the start of on-site construction activities and when the plants
are in a phenological stage conducive to positive identification
(i.e., usually during the blooming period for the species), the
applicant shall ensure an approved biologist will conduct
surveys for special status plant species throughout suitable
habitat within the project site.
BIO-1(b) Special Status Plant Species Avoidance. If
special status plant species are discovered within the study
area, the applicant shall ensure an approved biologist will flag
and fence these locations before construction activities start
Less than
significant.
PC 1- 17
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Executive Summary
City of San Luis Obispo
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
to avoid impacts.
BIO-1(c) Restoration Plan. If avoidance is not feasible; the
applicant shall ensure all impacts be mitigated at a minimum
ratio of 2:1 (number of acres/individuals restored to number of
acres/individuals impacted) for each species as a component
of habitat restoration. The applicant shall prepare and submit
a restoration plan to the City for approval. The restoration
plan shall include, at a minimum, the following components:
•Description of the project/impact site (i.e., location,
responsible parties, areas to be impacted by habitat
type);
•Goal(s) of the compensatory mitigation project [type(s)
and area(s) of habitat to be established, restored,
enhanced, and/or preserved; specific functions and
values of habitat type(s) to be established, restored,
enhanced, and/or preserved];
•Description of the proposed compensatory mitigation site
(location and size, ownership status, existing functions
and values);
•Implementation plan for the compensatory mitigation site
(rationale for expecting implementation success,
responsible parties, schedule, site preparation, planting
plan [including species to be used, container sizes,
seeding rates, etc.]);
•Maintenance activities during the monitoring period,
including weed removal and irrigation as appropriate
(activities, responsible parties, schedule);
•Monitoring plan for the compensatory mitigation site,
including no less than quarterly monitoring for the first
year, along with performance standards, target functions
and values, target acreages to be established, restored,
enhanced, and/or preserved, and annual monitoring
reports to be submitted to the City for a maximum of five
years;
•Success criteria based on the goals and measurable
objectives; said criteria to be, at a minimum, at least 80
percent survival of container plants and 30 percent
relative cover by vegetation type;
•An adaptive management program and remedial
measures to address any shortcomings in meeting
success criteria;
•Notification of completion of compensatory mitigation
and agency confirmation; and
•Contingency measures (initiating procedures, alternative
locations for contingency compensatory mitigation,
funding mechanism).
BIO-1(d) Best Management Practices. The applicant shall
ensure the following general wildlife Best Management
Practices (BMPs) are required:
•No pets or firearms shall be allowed at the project site
during construction activities.
•All trash that may attract predators must be properly
contained and removed from the work site. All such
debris and waste shall be picked up daily and properly
disposed of at an appropriate site.
PC 1- 18
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Executive Summary
City of San Luis Obispo
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
•All refueling, maintenance, and staging of equipment
and vehicles shall occur at least 100 feet from San Luis
Obispo Creek and the southern holding ponds and in a
location where a spill would not drain toward aquatic
habitat. A plan must be in place for prompt and effective
response to any accidental spills prior to the onset of
work activities. All workers shall be informed of the
appropriate measures to take should an accidental spill
occur.
•To control sedimentation during and after project
implementation, appropriate erosion control BMPs (i.e.,
use of coir rolls, jute netting, etc.) shall be implemented
to minimize adverse effects on adjacent San Luis Obispo
Creek. No plastic monofilament netting shall be utilized
on-site.
•All vehicles and equipment shall be in good working
condition and free of leaks.
•Environmentally Sensitive Areas shall be delineated to
confine access routes and construction areas.
•Work shall be restricted to daylight hours.
BIO-1(e) WEAP Training. Prior to the initiation of
construction activities (including staging and mobilization), the
applicant shall ensure all personnel associated with project
construction shall attend a Worker Environmental Awareness
Program (WEAP) training.
•The training shall be conducted by a qualified biologist,
to aid workers in recognizing special status resources
that may occur in the project area. The specifics of this
program shall include identification of the sensitive
species and habitats, a description of the regulatory
status and general ecological characteristics of sensitive
resources, and review of the limits of construction and
avoidance measures required to reduce impacts to
biological resources within the work area. A fact sheet
conveying this information shall also be prepared for
distribution to all contractors, their employers, and other
personnel involved with construction of the project. All
employees shall sign a form provided by the trainer
documenting they have attended the WEAP and
understand the information presented to them.
BIO-1(f) Blainville’s Horned Lizard (Phrynosoma
blainvilli). The applicant shall ensure the following measures
are implemented to avoid and minimize potential impacts to
Blainville’s horned lizard.
•A qualified biologist shall be present on-site during initial
ground disturbance in areas determined to have suitable
habitat for this species. Any Blainville’s horned lizards
that are observed during initial ground disturbance shall
be relocated the shortest distance possible to a location
that contains suitable habitat not likely to be affected by
activities associated with the proposed project.
BIO-1(g) Western Pond Turtle (Actinemys [=Emys]
marmorata). The applicant shall ensure the following
measures are implemented to avoid and minimize potential
impacts to southern western pond turtle:
PC 1- 19
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Executive Summary
City of San Luis Obispo
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
•A qualified biologist(s) shall conduct a pre-construction
survey within 24 hours prior to the onset of work
activities within and around areas considered potential
western pond turtle habitat. If this species is found and
the individuals are likely to be injured or killed by work
activities, the approved biologist shall be allowed
sufficient time to move them from the project site before
work activities begin. The biologist(s) must relocate the
any western pond turtle the shortest distance possible to
a location that contains suitable habitat that is not likely
to be affected by activities associated with the proposed
project.
•Access routes, staging, and construction areas shall be
limited to the minimum area necessary to achieve the
project goal and minimize potential impacts to southern
western pond turtle habitat including locating access
routes and construction staging areas outside of
wetlands and riparian areas to the maximum extent
practicable.
BIO-1(h) California Red-Legged Frog (Rana draytonii).
The applicant shall ensure the following measures are
implemented to ensure that impacts to CRLF from the
proposed project are reduced to a less than significant level.
•Only USFWS-approved biologists shall participate in
activities associated with the capture, handling, and
monitoring of CRLF.
•Ground disturbance shall not begin until written approval
is received from the USFWS that the biologist is qualified
to conduct the work. If the USFWS does not authorize
the relocation of CRLF occurring within the project site,
CRLF found within the project site shall be avoided with
a 100-foot buffer and no activities shall occur within that
buffer until the CRLF has left the project site on its own.
•The project site shall be surrounded by a solid temporary
exclusion fence (such as silt fencing) that shall extend at
least three feet above the ground and be buried into the
ground at least 6 inches to exclude CRLF from the
project site. Plastic monofilament netting or other similar
material will not be used. The location of the fencing
shall be determined by a qualified biologist. The fence
shall remain in place throughout construction activities.
Installation of the exclusion fencing shall be monitored
by a qualified biologist to ensure that it is installed
correctly.
•All vehicles and equipment shall be in good working
condition and free of leaks.
•Environmentally Sensitive Areas shall be delineated to
confine access routes and construction areas.
•Work shall be restricted to daylight hours.
•To ensure that diseases are not conveyed between work
sites by the approved biologist, the fieldwork code of
practice developed by the Declining Amphibian
Populations Task Force shall be followed at all times.
•No pets or firearms shall be permitted on-site.
BIO-1(i) Steelhead Trout (Oncorhynchus mykiss irideus).
The applicant shall ensure the following mitigation measures
PC 1- 20
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Executive Summary
City of San Luis Obispo
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
are undertaken to ensure that impacts to steelhead from the
proposed project are reduced to a less than significant level.
These measures are included in or are subsequent to the
measures stipulated in the facility’s existing National Marine
Fisheries Service Biological Opinion.
•Before any activities begin on the project, a qualified
biologist will conduct a training session for all
construction personnel. At a minimum, the training will
include a description of the steelhead and its habitat, the
specific measures that are being implemented to
conserve this species for the current project, and the
boundaries within which the project may be
accomplished. Brochures, books, and briefings may be
used in the training session, provided that a qualified
person is on hand to answer any questions.
•During the duration of project activities, all trash that may
attract predators will be properly contained and secured,
promptly removed from the work site, and disposed of
regularly. Following construction, all trash and
construction debris will be removed from the work areas.
•All refueling, maintenance, and staging of equipment
and vehicles will occur at least 100 feet from riparian
habitat or bodies of water and in a location where a
potential spill would not drain directly toward aquatic
habitat (e.g., on a slope that drains away from the water
source). The monitor shall ensure that contamination of
suitable habitat does not occur during such operations.
Prior to the onset of work activities, a plan must be in
place for prompt and effective response to any
accidental spills. All workers shall be informed of the
importance of preventing spills and of the appropriate
measures to take should an accidental spill occur.
•The number of access routes, size of staging areas, and
the total area used for construction activities shall be
limited to the minimum area necessary to achieve the
project goals.
•The City will attempt to schedule work within the
immediate vicinity of San Luis Obispo Creek for times of
the year when potential impacts to steelhead would be
minimal. To the maximum extent feasible, work should
be restricted during the wet season (October 15 through
April 30) and should ideally occur during the late summer
and early fall.
•To control sedimentation during and after project
implementation, the City shall implement the following
BMPs. If the BMPs are somehow ineffective, the City, in
consultation with the appropriate resource agency(ies),
will attempt to remedy the situation immediately.
•It shall be the owner’s/contractor’s responsibility to
maintain control of the entire construction operations and
to keep the entire site in compliance.
•The owner/contractor shall be responsible for monitoring
erosion and sediment control measures (including but
not limited to fiber rolls, inlet protections, silt fences, and
gravel bags) prior, during and after storm events,
monitoring includes maintaining a file documenting
onsite inspections, problems encountered, corrective
actions, and notes and a map of remedial
PC 1- 21
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City of San Luis Obispo
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
implementation measures.
•All earth stockpiles over 2.0 cubic yards shall be covered
with a tarp and ringed with straw bales or silt fencing.
The site shall be maintained so as to minimize sediment-
laden runoff to any storm drainage system including
existing drainage swales and/or sand watercourses.
o Construction operations shall be carried out in
such a manner that erosion and water pollution
will be minimized.
o State and local laws concerning pollution
abatement shall be complied with.
o If grading operations are expected to denude
slopes, the slopes shall be protected with
erosion control measures immediately following
grading on the slopes.
•Specifically, in order to prevent sedimentation and debris
from entering San Luis Obispo Creek during
construction, silt fencing shall be installed along the top
of the banks on the west side of the channel prior to the
onset of construction activities.
•The project biologist will monitor construction activities,
in stream habitat, and overall performance of BMPs and
sediment controls for the purpose of identifying and
reconciling any condition that could adversely affect
steelhead or their habitat.
•Equipment will be checked daily for leaks prior to the
initiation of construction activities. A spill kit will be placed
near the creek and will remain readily available during
construction in the event that any contaminant is
accidentally released.
•In addition to these avoidance and minimization
measures, mitigation measure BIO-2 would also ensure
that potential indirect impacts to steelhead from this
project are reduced to the extent practicable.
BIO-1(j) Nesting Birds. The applicant shall ensure the
following mitigation measures are undertaken to reduce any
potential impacts to nesting birds to a less than significant
level.
•For construction activities occurring during the nesting
season (generally February 1 to September 15), surveys
for nesting birds covered by the California Fish and
Game Code and the Migratory Bird Treaty Act shall be
conducted by a qualified biologist no more than 14 days
prior to vegetation removal. The surveys shall include
the disturbance area plus a 500-foot buffer around the
site. If active nests are located, all construction work
shall be conducted outside a buffer zone from the nest to
be determined by the qualified biologist. The buffer shall
be a minimum of 50 feet for non-raptor bird species and
at least 300 feet for raptor species. Larger buffers may
be required depending upon the status of the nest and
the construction activities occurring in the vicinity of the
nest. The buffer area(s) shall be closed to all
construction personnel and equipment until the adults
and young are no longer reliant on the nest site. A
qualified biologist shall confirm that breeding/nesting is
completed and young have fledged the nest prior to
PC 1- 22
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
removal of the buffer.
•If feasible, removal of vegetation within suitable nesting
bird habitats will be scheduled to occur in the fall and
winter (between September 1 and February 14), after
fledging and before the initiation of the nesting season.
Impact BIO-2 Construction of
the project could have a
substantial adverse effect on
sensitive habitats, including
riparian areas. Impacts would be
Class II, potentially significant
unless mitigation is incorporated.
BIO-2 Riparian Habitat. A Habitat Mitigation and Monitoring
Plan (HMMP) shall be prepared which will provide a minimum
a 1:1 ratio for temporary and permanent impacts to riparian
habitat. The HMMP will identify the specific mitigation sites
and it will be implemented immediately following project
completion. The HMMP shall include, at a minimum, the
following components:
•Description of the project/impact site (i.e. location,
responsible parties, areas to be impacted by habitat
type);
•Goal(s) of the compensatory mitigation project [type(s)
and area(s) of habitat to be established, restored,
enhanced, and/or preserved; specific functions and
values of habitat type(s) to be established, restored,
enhanced, and/or preserved];
•Description of the proposed compensatory mitigation-
site (location and size, ownership status, existing
functions and values of the compensatory mitigation-
site);
•Implementation plan for the compensatory mitigation-site
(rationale for expecting implementation success,
responsible parties, schedule, site preparation, planting
plan [including plant species to be used, container sizes,
seeding rates, etc.]);
•Maintenance activities during the monitoring period,
including weed removal and irrigation as appropriate
(activities, responsible parties, schedule);
•Monitoring plan for the compensatory mitigation site,
including no less than quarterly monitoring for the first
year (performance standards, target functions and
values, target acreages to be established, restored,
enhanced, and/or preserved, annual monitoring reports);
•Success criteria based on the goals and measurable
objectives; said criteria to be, at a minimum, at least 80
percent survival of container plants and 80 percent
relative cover by vegetation type;
•An adaptive management program and remedial
measures to address negative impacts to restoration
efforts;
•Notification of completion of compensatory mitigation
and agency confirmation; and
•Contingency measures (initiating procedures, alternative
locations for contingency compensatory mitigation,
funding mechanism).
BIO-3 Jurisdictional Water and Wetlands Best
Management Practices (discussed below)
Less than
significant.
Impact BIO-3 Construction of
the project could have a
substantial adverse effect on
Federally protected wetlands as
defined by Section 404 of the
BIO-1(d) Best Management Practices (discussed above)
BIO-3 Jurisdictional Water and Wetlands BMPs. The
following BMPs shall be implemented:
1.To control sedimentation during and after project
Less than
significant.
PC 1- 23
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
Clean Water Act. Impacts would
be Class II, potentially significant
unless mitigation is incorporated.
implementation, appropriate erosion control best
management practices (i.e., installation of straw wattle,
jute netting, etc.) shall be implemented to minimize
adverse effects on jurisdictional areas in the vicinity of
the project. Plastic monofilament erosion control matting
will not be implemented onsite.
2.Project activities within the jurisdictional areas shall
occur during the dry season (typically between June 1
and November 1) in any given year, or as otherwise
directed by the regulatory agencies. Deviations from this
work window can be made with permission from the
relevant regulatory agencies.
3.During construction, no litter or construction debris shall
be placed within jurisdictional areas. All such debris and
waste shall be picked up daily and properly disposed of
at an appropriate site. In addition, all project-generated
debris, building materials, and rubbish shall be removed
from jurisdictional areas and from areas where such
materials could be washed into them.
4.Any substances which could be hazardous to aquatic
species resulting from project-related activities shall be
prevented from contaminating the soil and/or entering
jurisdictional areas.
5.All refueling, maintenance, and staging of equipment
and vehicles shall occur at least 100 feet from bodies of
water and in a location where a potential spill would not
drain directly toward aquatic habitat (e.g., on a slope that
drains away from the water source). Prior to the onset of
work activities, a plan must be in place for prompt and
effective response to any accidental spills. All workers
shall be informed of the importance of preventing spills
and of the appropriate measures to take should an
accidental spill occur.
CULTURAL RESOURCES
Impact CR-1 Construction of the
proposed project would involve
ground-disturbing activities which
have the potential to unearth or
adversely impact archaeological
resources. Impacts would be
Class II, potentially significant
unless mitigation is incorporated.
CR-1(a) WEAP Training. Prior to project construction, the
applicant shall retain a qualified archaeologist meeting the
Secretary of the Interior’s Standards for historic archaeology
to conduct a Worker’s Environmental Awareness Program
(WEAP) for all construction personnel working on the project.
The training shall include an overview of potential cultural
resources that could be encountered during ground disturbing
activities to facilitate worker recognition, avoidance, and
notification to a qualified archaeologist in the event of
unanticipated discoveries. The Native American monitor shall
also be present at the WEAP training to provide the Native
American perspective on cultural resources and potential
project-related impacts, and to receive information regarding
the project schedule, roles and responsibilities, and mitigation
measures
CR-1(b) Archaeological and Native American Monitoring.
Prior to project construction the applicant shall retain a
qualified archaeologist and Native American representative to
conduct archaeological monitoring of all project related
ground disturbing activities within 200 feet of the creek bed.
Archaeological monitoring should be performed under the
direction of an archaeologist meeting the Secretary of the
Interior’s Professional Qualification Standards for
Less than
significant.
PC 1- 24
Attachment 2
Water Resource Recovery Facility Project Draft EIR
Executive Summary
City of San Luis Obispo
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
archaeology (NPS 1983). The duration and timing of
monitoring shall be determined by the qualified archaeologist
in consultation with the City and based on the grading plans
and level of previous disturbance within work areas. If
archaeological resources are encountered during ground-
disturbing activities, work in the immediate area must halt and
the find be evaluated for significance under Section 106 of
the NHPA and CEQA.
CR-1(c) Discovery of Archaeological Resources. In the
event that archaeological resources are unearthed during
project construction, all earth disturbing work within the
vicinity of the find shall be temporarily suspended or
redirected until an archaeologist has evaluated the nature
and significance of the find. Evaluation of significance for the
find may include the determination of whether or not the find
qualifies as an archaeological site. Isolated finds do not
qualify as historical resources under CEQA or historic
properties under the NHPA and require no management
consideration under either regulation. Should any resource(s)
be identified, an evaluation of eligibility for the CRHR and
NRHP may be required through the development of a
treatment plan including a research design and subsurface
testing through the excavation of test units and shovel test
pits. After effects to the find have been appropriately
mitigated, work in the area may resume. Mitigation of
significant impacts or adverse effects to the find may include
a damage assessment of the find, archival research, and/or
data recovery to remove any identified archaeological
deposits, as determined by a qualified archaeologist.
CR-1(d) Discovery of Human Remains. If human remains
are found, the State of California Health and Safety Code
Section 7050.5 states that no further disturbance shall occur
until the county coroner has made a determination of origin
and disposition pursuant to Public Resources Code Section
5097.98. In the event of an unanticipated discovery of human
remains, the San Luis Obispo County coroner must be
notified immediately. If the human remains are determined to
be prehistoric, the coroner will notify the Native American
Heritage Commission (NAHC), which will determine and
notify a most likely descendant (MLD). The MLD shall
complete the inspection of the site within 48 hours of
notification and may recommend scientific removal and
nondestructive analysis of human remains and items
associated with Native American burials.
Impact CR-2 Construction of the
proposed project would involve
ground-disturbing activities which
have the potential to unearth or
adversely impact paleontological
resources. Impacts would be
Class II, potentially significant
unless mitigation is incorporated.
CR-2(a) Paleontological Mitigation and Monitoring
Program. Prior to construction activity a qualified
paleontologist should prepare a Paleontological Mitigation
and Monitoring Program to be implemented during project
ground disturbance activity. This program should be based
on the final project plans to identify specific areas where
ground disturbing activity has the potential to impact
scientifically significant paleontological resources and include
the following details:
1)Outline the procedures for construction staff Worker
Environmental Awareness Program (WEAP) training;
2)Specify the extent, location and duration of
Less than
significant.
PC 1- 25
Attachment 2
Water Resource Recovery Facility Project Draft EIR
Executive Summary
City of San Luis Obispo
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
paleontological monitoring based on proposed construction
activity;
3)Specify the procedures for salvage and preparation of
fossils;
4)Require a final mitigation and monitoring report; and
5)Specify the qualifications of a qualified paleontologist and
paleontological monitors.
CR-2(b) Paleontological WEAP. Prior to the start of
construction, construction personnel should be informed on
the appearance of fossils and the procedures for notifying
paleontological staff should fossils be discovered by
construction staff.
CR-2(c) Paleontological Monitoring. Any excavations
exceeding five feet in depth, including those in the young
alluvium, should be monitored according to the specifications
outlined in the PMMP. At a minimum, paleontological
monitoring should be sufficient to evaluate the potential of
newly exposed geologic units to contain fossils. If the
qualified paleontologist determines that geologic units are
unlikely to yield significant paleontological resources,
monitoring may be discontinued. If ground disturbance
activity is initiated in a new area or to a deeper depth than
previous excavations, paleontological monitoring should be
re-initiated. Monitoring should be conducted by a qualified
paleontological monitor as specified in the PMMP. Ground
disturbing activity that does not exceed five feet in depth in
young alluvium would not require paleontological monitoring.
CR-2(d) Salvage of Fossils. If fossils are discovered, the
qualified paleontologist (or paleontological monitor) should
recover them. Typically fossils can be safely salvaged quickly
by a single paleontologist and not disrupt construction
activity. In some cases larger fossils (such as complete
skeletons or large mammal fossils) require more extensive
excavation and longer salvage periods. In this case the
paleontologist should have the authority to temporarily direct,
divert or halt construction activity to ensure that the fossil(s)
can be removed in a safe and timely manner.
CR-2(e) Preparation and Curation of Recovered Fossils.
Once salvaged, fossils should be identified to the lowest
possible taxonomic level, prepared to a curation-ready
condition and curated in a scientific institution with a
permanent paleontological collection (such as the University
of California Museum of Paleontology or the Los Angeles
County Museum of Natural History), along with all pertinent
field notes, photos, data, and maps.
CR-2(f) Final Paleontological Mitigation and Monitoring
Report. Upon completion of ground disturbing activity (and
curation of fossils if necessary) the qualified paleontologist
should prepare a final mitigation and monitoring report
outlining the results of the mitigation and monitoring program.
The report should include discussion of the location, duration
and methods of the monitoring, stratigraphic sections, any
recovered fossils, and the scientific significance of those
PC 1- 26
Attachment 2
Water Resource Recovery Facility Project Draft EIR
Executive Summary
City of San Luis Obispo
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
fossils, and where fossils were curated.
GREENHOUSE GAS EMISSIONS
Impact GHG-1 The proposed
project would generate
greenhouse gas emissions
through construction, increased
energy use, increased biogenic
processes as a result of the
increased wastewater capacity,
and testing of emergency diesel
generators. The increased
emissions would be below the
SLOAPCD threshold for annual
greenhouse gas emissions,
therefore impacts would be
Class III, less than significant.
None required. Less than
significant.
Impact GHG-2 The proposed
project would not conflict with
State GHG reduction goals, or
any applicable plan, policy, or
regulation adopted for the
purpose of reducing GHG
emissions. Impacts would be
Class III, less than significant.
None required. Less than
significant.
NOISE
Impact N-1 Construction
activities associated with the
proposed project would expose
nearby sensitive receptors to
temporary increases in noise,
however, these would not
exceed City noise thresholds.
Impacts would be Class III, less
than significant.
None required. Less than
significant.
Impact N-2 Project construction
would expose nearby sensitive
receptors to a temporary
increase in vibration levels.
However, vibration levels during
construction would not expose
nearby structures to vibration
damage or excessive vibration
noise. Impacts would be Class
III, less than significant.
None required. Less than
significant.
Impact N-3 Noise associated
with operation of the proposed
project would not exceed City
thresholds. Therefore, impacts
would be Class III, less than
significant.
None required. Less than
significant.
RECREATION
Impact REC-1 The proposed
project would potentially affect
operation of existing and
planned park and recreation
facilities, as it would enhance
recreational amenities at the
None required. Less than
significant.
PC 1- 27
Attachment 2
Water Resource Recovery Facility Project Draft EIR
Executive Summary
City of San Luis Obispo
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
site. This is a Class IV, beneficial
impact.
Impact REC-2 Impacts
associated with construction of
the recreational components of
the proposed project are part of
the wider project analyzed in this
EIR. Potential adverse impacts
have been identified in several
environmental issue areas,
related primarily to construction
activities associated with the
proposed project. Impacts would
be Class II, potentially significant
unless mitigation is incorporated.
Mitigation measures identified in Section 3.1, Air Quality,
Section 3.2, Biological Resources, Section 3.3, Cultural
Resources, and Section 3.7, Hazards and Hazardous
Materials, would apply.
Less than
significant.
HYDROLOGY AND WATER QUALITY
Impact HYD-1 During
construction the proposed
project could potentially violate
water quality standards or waste
discharge requirements. Impacts
would be Class II, potentially
significant unless mitigation is
incorporated.
HYD-1 Prepare an Emergency Wastewater Treatment
Plan. Before construction is initiated, the City of San Luis
Obispo shall work with its design engineers and
construction contractor to develop an Emergency
Wastewater Treatment Plan which identifies procedures for
handling and treating wastewater flows during construction
of the Project. This Plan shall include procedures and
contingency measures for proper handling and treatment of
wastewater flows in the event that the treatment train goes
offline unexpectedly as a result of construction activities,
such as temporary storage wastewater flows. The Plan
shall consider storage options, varying levels of treatment
and/or blending, temporary treatment options, and
conveyance to alternative treatment facilities. An existing
emergency treatment plan could be used in place of this
Emergency Wastewater Treatment Plan so long as its
provisions could be successfully implemented during
project construction.
HAZ-1(a) Hazardous Materials Management and Spill
Control Plan (discussed below)
HAZ-1(b) Preparation of Hazardous Materials Business
Plan (discussed below)
Less than
significant.
Impact HYD-2 The proposed
project would not result in
flooding, erosion or siltation on-
or off-site. Impacts would be
Class III, less than significant.
None required. Less than
significant.
Impact HYD-3 The proposed
project would result in an
improvement in the quality of
discharges from the WRRF to
San Luis Obispo Creek. Impacts
would be Class IV, beneficial.
None required. Beneficial.
Impact HYD-4 The proposed
project would result in placement
of structures within a 100-year
flood hazard area. Impacts would
be Class II, potentially significant
unless mitigation is incorporated.
HYD-4 Design Stormwater Outfall with Energy
Dissipaters. The City of San Luis Obispo shall ensure that
the San Luis Obispo Creek stormwater outfall, if selected to
manage storm flows on the WRRF site, is designed with
energy dissipation features as needed to prevent flooding
and erosion at or downstream of the point of discharge.
Less than
significant.
PC 1- 28
Attachment 2
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Executive Summary
City of San Luis Obispo
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
The design and location of the stormwater outfall shall be
approved by USACE to ensure that it does not impede high
flow capacity.
HAZARDS AND HAZARDOUS MATERIALS
Impact HAZ-1 Construction of
the proposed project would
temporarily increase the routine
transport and use of hazardous
materials used in construction
activities. Operation of the
expanded and upgraded WRRF
would entail the routine
transportation, use, storage,
and/or disposal of minor
amounts of hazardous materials.
Impacts would be Class II,
potentially significant unless
mitigation is incorporated.
HAZ-1(a) Hazardous Materials Management and Spill
Control Plan. Before construction begins, all construction
contractors shall be required to develop and implement a
HMMSCP that includes project-specific contingency plan
for hazardous materials and waste operations. The
HMMSCP shall establish policies and procedures
consistent with applicable codes and regulations, including
but not limited to the California Building and Fire Codes,
and federal and California Occupational Safety and Health
Administration (OSHA). The HMMSCP shall articulate
hazardous materials handling practices to prevent their
release into San Luis Obispo Creek during construction of
the storm water outfall.
HAZ-1(b) Preparation of Hazardous Materials Business
Plan. Prior to operation of the new facilities, a HMBP shall
be prepared and implemented for the proposed project.
The HMBP shall include a hazardous materials inventory,
site plan, an emergency response plan, and requirements
for employee training. An existing HMBP can be updated
and resubmitted for the expanded facilities.
Less than
significant.
Impact HAZ-2 The proposed
project has potential to create a
hazard through reasonably
foreseeable upset and accident
conditions involving the release
of hazardous materials into the
environment during both
construction and operation.
Impacts would be Class II,
potentially significant unless
mitigation is incorporated.
HAZ-1(a) Hazardous Materials Management and Spill
Control Plan (discussed above)
HAZ-1(b) Preparation of Hazardous Materials Business
Plan (discussed above)
Less than
significant.
Impact HAZ-3 The proposed
project could result in the
disturbance of contaminated
soils on an active cleanup sites
listed on the SWRCB
GeoTracker database. Impacts
would be Class II, potentially
significant unless mitigation is
incorporated.
HAZ-3(a) Phase I Environmental Site Assessment.
Before construction begins, the City of San Luis Obispo
shall perform a Phase I Environmental Site Assessment
(ESA) to clarify the potential for soil contamination due to
the adjacent open cleanup site. The recommendations set
forth in the Phase I ESA shall be implemented before
construction begins. Follow-up sampling may be
conducted, if needed, to characterize soil and groundwater
quality. Prior to construction, contractors shall be informed
of the location of potential areas of hazardous materials
that may be encountered during construction, and shall
ensure that safety precautions are in place to avoid or
minimize exposure to potentially contaminated soils, and to
reduce the potential for accidental damage to underground
storage tanks that could cause accidental release of
hazardous materials into the environment.
HAZ-3(b) Contaminated Soil Contingency Plan. The
City of San Luis Obispo shall require its construction
contractors to develop and implement a Contaminated Soil
Contingency Plan to handle treatment and/or disposal of
contaminated soils. If contaminated soil is encountered
Less than
significant.
PC 1- 29
Attachment 2
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Executive Summary
City of San Luis Obispo
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Table ES-1
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Impact Mitigation Measures Significance After
Mitigation
during project construction, work shall halt and an
assessment made to determine the extent of
contamination. Treatment and/or disposal of contaminated
soils shall be conducted in accordance with the
Contingency Plan.
Impact HAZ-4 The proposed
project would not result in a
safety hazard for people residing
or working in the project area
due to location within an airport
land use plan. Impacts would be
Class III, less than significant.
None required. Less than
significant.
Impact HAZ-5 The proposed
project could impair or physically
interfere with an adopted
emergency evacuation and
response during construction.
Impacts would be Class II,
potentially significant unless
mitigation is incorporated.
HAZ-5 Traffic Management Plan. Prior to the start of
construction, the City shall develop a Traffic Management
Plan, in coordination with City Transit, Public Works, and
other appropriate departments or users of the site, that
would include industry, Caltrans, and City standards for
managing construction traffic to and from the site.
Measures to manage construction traffic could include
warning signs, flag men, and scheduling deliveries outside
the AM and PM peak hours. The Traffic Management Plan
shall include measures that address how to accommodate
emergency evacuation and response, if needed.
Less than
significant.
Impact HAZ-6 The proposed
project would not increase the
exposure of people or structures
to wildfire risks due to population
growth, but construction activities
could create hazardous fire
conditions. Impacts would be
Class II, potentially significant
unless mitigation is incorporated.
HAZ-6 Prevention of Fire Hazards. During construction of
the proposed project, staging areas, welding areas, or
areas slated for construction shall be cleared of dried
vegetation or other material that could ignite. Construction
equipment that includes a spark arrestor shall be equipped
in good working order. In addition, construction crews shall
have a spotter during welding activities to look out for
potentially dangerous situations, such as accidental sparks.
Other construction equipment, including those with hot
vehicle catalytic converters, shall be kept in good working
order and used only within cleared construction zones. The
creation and maintenance of approved fire access to work
areas shall be required in accordance with local Fire
regulations. During construction of the proposed project,
contractors shall require vehicles and crews working at the
project site to have access to functional fire extinguishers.
Less than
significant.
PUBLIC SERVICES AND UTILITIES
Impact UTL-1 The proposed
project would not directly or
indirectly induce population
growth and require the need for
new or addition fire protection or
police services that would result
in the need for expanded
facilities. Impacts would be Class
III, less than significant.
None required. Less than
significant.
Impact UTL-2 The proposed
project would include
improvements to the WRRF,
which would improve treated
wastewater quality. There would
be a beneficial impact on
wastewater effluent quality.
Impacts would be Class IV,
None required. Beneficial.
PC 1- 30
Attachment 2
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Executive Summary
City of San Luis Obispo
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Table ES-1
Summary of Impacts, Mitigation Measures, and Significance After Mitigation
Impact Mitigation Measures Significance After
Mitigation
beneficial.
Impact UTL-3 Stormwater
drainage improvements are
included as part of the proposed
project. Impacts would be Class
III, less than significant.
None required. Less than
significant.
Impact UTL-4 The proposed
project would not require
additional water supplies. No
impact would occur.
None required. No impact.
Impact UTL-5 The proposed
project would not be served by a
landfill with insufficient capacity
to accommodate solid waste that
would be generated. Impacts
would be Class III, less than
significant.
None required. Less than
significant.
Impact UTL-6 The proposed
project would comply with all
federal, state, and local statutes
and regulations related to solid
waste. Impacts would be Class
III, less than significant.
None required. Less than
significant.
PC 1- 31
Attachment 2