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HomeMy WebLinkAbout10/21/1997, 4 - EI NINO PREPARATIONS council o , j acenaa aepout CITY O F SAN LUIS O B I S P O FROM: Michael D.McCluskey,Public Works Director ' t Prepared By: Lawrence S. Tolson,Park Maintenance Supervisor SUBJECT: El NINO PREPARATIONS CAO RECOMMENDATION Approve the El Nino storm preparation program as described and Appropriate$115,100 from the unappropriated balance of the General fund; $28,600 from the Sewer Fund and $15,600 from the Water Fund. REPORT-IN-BRIEF The upcoming winter season has become known as El Nino. Due to its notoriety the City needs to be totally prepared to respond to emergencies,to inform its citizens what they can do to protect themselves and to inform them what the City has been and will be doing for this year's storm season. The City is taking an aggressive stance toward its physical preparations as well as the information campaign needed for its citizens. At the Council meeting of October 7�, the Council discussed the need to prepare for protecting the Water Reclamation Facility. Staff has followed Council direction and has contracted for preparation of plans and specifications for a possible sheet piling project and ordered rock rip rap for erosion protection,as well as continued to pursue the issuance of an "emergency"Army Corps of Engineers permit. DISCUSSION The City of San Luis Obispo routinely prepares for each and every winter season to provide its citizens the highest level of flood protection possible. This upcoming storm season of 1997-98 is predicted to have heavier than average rainfall and has become identified with a weather pattern known as El Nino. To meet the increased public awareness and concern for the predicted El Nino effect this winter season, staff felt it necessary to evaluate all aspects of our preparedness and determine what measures need to be accomplished prior to the upcoming winter season. At the City Council meeting of October 7 , the Council gave direction that staff implement flood protection measures for various areas around town as needed; retain a consultant to prepare plans . and specifications for a potential sheet piling project at the City's Water Reclamation Facility and be prepared to report at tonight's Council meeting on any progress with federal permitting agencies for flood protection projects the City is currently pursuing. Winter Preparations- What are we doing to prepare for this special upcoming winter season? On Tuesday, September 23', staff from various departments met with the CAO to discuss preparations for the upcoming winter season. The group focused on two major issues: 1. A more extensive operational preparedness program. 2. The need for a public information campaign to inform our citizens what we are doing Council Agenda Report-EI Nino Preparations Page 2 and what they can do to better prepare themselves for the winter season. Operational Preparations: What do we do routinely? For each upcoming winter season, the Public Works Department begins preparations starting in July of each year with a walking inspection of the major creeks. The creeks are then cleared of vegetation and debris at the low-flow line. Environmental restrictions are placed by Fish& Game and the Army Corps of Engineers on when,where,how much and what can be removed. Major creeks are cleaned first,then tributaries and channels by a combination of city staff, seasonal workers,California Conservation Corps,California Department of Forestry,and California Mens Colony workers,as available. Beginning in 1996 the Public Works Department began providing fill material for sand bags, free of charge to the public, at four locations in the City: the Corporation Yard, Santa Rosa Park, Sinsheimer Park and Laguna Lake Golf Course parking lots. The material is available at the Corporation Yard beginning September 15" and at all remaining sites on October 1'. For normal winter seasons an inventory of about 16,000 sand bags is kept on hand and is made available to the public during heavy storms at no charge. The City currently has in stock over 9,500 full size burlap sandbags. Information about sand bags and availability is provided by Public Works staff via phone when contacted by the public. The months of September and October see the City tree crew annually pruning the City trees in the downtown area in preparation of the windy and rainy season. An inspection of trees needing removal and/or pruning in City creeks is also performed and that work is accomplished as needed if the trees are the responsibility of the City for maintenance. If the trees are the responsibility of private property owners along any creeks they are given notification of the need for such work. The month of October is dedicated to a comprehensive program of street catch basin cleaning. A specialized vehicle, the Vactor truck, is used, which basically vacuum cleans the basin, and the lines which drain to and from these basins,of debris.built up over the last 11 months. The program begins in the downtown area and works its way out to all of the major identified basins needing cleaning. Also inspected, cleared and cleaned as needed during this period are all rock guards, storm drains,grates and drop inlets. Although not annual maintenance,the City Council has authorized in the budget for the last two- year financial period,a catch basin replacement program which is also funded for the next two-year period. Thus far, there has been over $100,000 budgeted and spent for this ongoing program to correct problem or"hot spot" catch basins which in the past have been problem areas during storm events. What'sdierentfor this upcoming season? Prior to the September 23'meeting,a number of ideas to enhance Public Works preparations for the winter season were identified. After that meeting, more ideas were added and the CAO authorized actions to begin immediately. Some items have already seen action and/or are on order while others are awaiting the outcome of tonight's action. El Nino winter preparation items for implementation and their cost and status are described below: 1. An additional 100,000 half-size polyethylene sandbags with ties were ordered and have been delivered at a cost of$20,000. These bags are smaller;will be easier for the public to fill during emergencies; will last more than one season and are just as effective as burlap sand bags in holding back water. The extra bags will guarantee an adequate supply for dispersion to the public if required and will be available in following seasons if not used this year. Council Agenda Report-El Nino Preparations Page 3 2. A new Emergency Generator will be ordered for the Corporation Yard at a cost of$30,000.The current unit is a dual purpose generator in that it can be removed from the Yard for emergency power outages by the Utilities Water Distribution and Wastewater Collection Divisions. When this happens the Corporation Yard,which functions as the Emergency Operations Center during all storms, is left without emergency back-up power electric power in case of power failure. The Utilities Department has long needed another back-up generator(one already exists but two are needed)and this purchase would provide a permanent fixed back-up power supply for the Corporation Yard. Utilities would assume ownership of the existing mobile unit. In essence the Sewer and Water Fund would be buying the mobile unit from the General Fund and the new unit would be purchased by the General Fund. 3. The City crane broke and was not replaced after the 1995 storms. The decision at the time was that it would be far more cost effective to rent a crane when necessary. Therefore staff will contract for an available standby crane, with a potential cost of $25,000. This will be emergency account to draw upon only if needed. The crane's typical use is for the emergency removal of downed trees and debris that usually end up blocking any of the many the waterways that flow through town. 4. Six additional sump/trash pumps at a cost of$4,200 will be ordered and will be made available at the Corporation Yard for the public's use to protect their property from the effects of flooding such as the need to pump out flooded basements or pump flows away from property into creeks or drainage systems. In addition to these six pumps,the Fire Department has additional pumps on hand for this purpose. However,it feels that the existing number is not sufficient to meet the public's need if a major storm with flooding does occur. 5. To create a stock pile of rock rip rap material for use in emergencies in general and also specifically along the Water Reclamation Facility,staff has ordered 900 tons of this material at a cost of$21,000. Approximately 280 tons of rock will be piled along the banks of San Luis Creek at the Water Reclamation Facility to prevent erosion that could damage the facility, causing discharge of pollutants into the creek, if the City should be unsuccessful in obtaining emergency Army Corp of Engineer permits to use that rock as part of an approved permit. Remaining material will be used for the RRM site and at other locations as needed. 6. Per the Public Works storm response program, all patrol vehicles responding to emergencies should be equipped with chainsaws. Of the eight vehicles,three are in need of these pieces of equipment. The three additional chainsaws will be ordered at a cost of $1,400. 7. The railing to the Marsh St.bridge will be modified at a cost of $5,500. Major flooding occurs at this location due to debris caught on the railing. Water is then diverted down Higuera Street. In order to pre-empt this,modifications to the bridge include the removal of the 6 inch curb on the down stream side,rail modifications to both sides to allow for quick removal and relocation as needed. Flood flows will then flow over the top of the bridge from one side to the other and fall back into the creek rather than flowing down Higuera Street. 8. To aid in communication during major emergencies staff has identified the need for four additional cell phones at a cost of $1,300. Typically, crews are near a vehicle and can be reached by radio however, in certain instances crews must hike into certain areas and are thus out of communication except via the use of cell phones. �3 Council Agenda Report-El Nino Preparations Page 4 9. In order to aid the public in the filing of sand bags,staff has ordered and received six additional sandbag filling stands at a cost of$600. These stands will be placed so as to provide each satellite sandbag filling location with 2 stands for a safer, easier and faster method of filling sandbags by the public. 10. Magnetic"Storm Patrol" Signs for City trucks have been ordered at a cost of$400 as a means to increase visibility of storm patrol vehicles,reassure the public of our presence during storms and allow the public to contact us more easily in the field with questions or emergencies. 11.During the 1995 storm,the Corporation Yard became isolated by flood waters and needed street barricades could not be delivered to flooded areas in the Laguna Lake area. In order to prevent this reoccurrence staff will rent a storage container at.a cost of$500. It will be rented for six months and be located at the Laguna Lake Golf Course. Besides barricades, additional sandbags will be stored and other pieces of hand equipment will be housed in the container. 12.The existing Utilities back up generator needed a new fuel pump installed prior to the upcoming winter season. This was accomplished for a cost of$1,200. 13.During the 1995 storm all city backhoes were in use. In the 1999-2000(pg. 101,Appendix B) budget is a minor equipment purchase which would create another backhoe simply by the purchase of an backhoe attachment at a cost of $15,000. Staff is proposing to move that purchase date forward immediately. 14. Staff has contracted with the California Conservation Corps for extra labor to help in various areas in preparation for the upcoming season at a cost of$4,000. They will be used in the clearing of vegetation at the Perfumo Creek arm near L.O.V.R., the down stream side of the Laguna Lake outlet at Madonna Rd. Staff is still obtaining cost estimates for the removal of rock and debris from an extremely large culvert under Broad Street near Murray Street. This work will be done and reported to the CAO as soon as possible. Public Information Program: 1. Due to the attention the upcoming winter season is receiving,City Hall,Public Works and the . Fire Department are receiving literally dozens of calls per day requesting sand bag information, asking other questions or informing staff of areas of debris and possible future storm drain blockages. In order to provide our citizens with assurances that the City is prepared and inform them of what they can do themselves to prepare, the CAO authorized a public information campaign specifically to deal with these issues. Included in that campaign will be the following: a) The City will contract with Barnett& Cox to coordinate a balanced media information program at a cost of$15,000. That firm will use information and materials developed by staff, as well as implement those ideas that,from their experience,would also be beneficial. b) Staff will contract to upgrade the Public Works Web Site at a cost of $700. Information on self-preparedness,the City's policies and storm actions,as well as general storm emergency information,flood zone maps and flood information with links to National Weather Service etc. will be provided. Council Agenda Report-El Nino Preparations Page 5 2. A new"Storm"module will be created for the City's Customer Service Request program at a cost of$2,500. This will not only allow us to inform the public of actions taken on their requests but also provide the information needed by agencies such as FEMA when exact costs of storm response will be needed. 3. Staff has ordered NCR caller information forms at a cost of$500. These two part forms will be used for receiving caller information during an EOC storm emergency. 4. A storm season fact sheet will be mailed to all residents in their water bill mailing. The cost of this insert is$1000. 5. The pamphlet "When water is your enemy"will be revised and reproduced at a cost of$1,000. It will be made available to the public at various City office locations and mailed upon request. 6. As part of the City's flood insurance program, a mailer was sent to all homes in flood areas last year. This year, with the heightened flood awareness, the mailer will be sent to every parcel in the city at a cost of$2,000. 7. For quick and ready reference, staff has contracted for production of refrigerator magnets with important telephone numbers that citizens can call at a cost of$500. 8. Staff will pursue radio, television, and T-T spots, in conjunction with the consultant. Anticipated actions could include: KVEC Good Morning Show, KSBY Newsmaker spot with Public Works Director, a Viewpoint article in T-T by Public Works Director, etc. The Mayor and the Public Works Director have already made one appearance on radio and the Public Works Manager was interviewed on television regarding the City's sand bag program. 9. Staff will set up a Farmers Market information booth with storm related information. 10. The Parks and Recreation winter brochure will include storm information fact sheet. Wastewater Reclamation Facility Protection: After discussion at its meeting of October 7', the City Council directed that Staff retain an engineer to prepare plans and specifications for a sheet-piling project to protect the WRF if needed. Staff has initiated contract negotiations with an identified consultant that specializes in this field with an estimated cost of$6,000. As mentioned above, rock rip-rap has been ordered in case an emergency permit is obtained and, if not obtained, would be used at the top of creek bank to provide erosion protection as best possible, should erosion occur and the rock fall to the base of the cliff. Staff is likewise pursuing obtaining of the"emergency permit" from the Army Corps of Engineers which, if granted, would allow the City to construct and install interim protection devices at two locations within the City(RRM and WRF)if conditions of the emergency can be met. An additional permit to allow removal of rock and gravel at the Marsh Street Bridge is also being pursued in conjunction with the other two projects. y-s Council Agenda Report-El Nino Preparations Page 6 FISCAL MPACT Total appropriations will come from unappropriated fund balances as follows: Sewer Fund: $28,600 Water Fund: $15,600 General Fund:$115,100 The audit is not yet completed for 1996-97; however, based on our interim financial results, it appears that we will end last fiscal year in a stronger position than projected in the 1997-99 Financial Plan. Accordingly,the proposed expenditures can be made without taking fund balance below policy levels in any of the three funds. lxadel nino agn rpt y� ;';ILL-IING AGENDA SACRAMENTO OFFICE DATE i0_Z; ITEM # SLN STATE CAPITOL.ROOM 5035 e T SACRAMENTO.CA 95814 0 191614455405SAN LUIS OBISPO OFFICE ,(T �` m �% 1260 CHORRO STREET.SUITE A L n` N L SAN LUIS OBISPO.CA 93401 Ory 18051 547-1600 a. SANTA BARBARA OFFICE SENATOR 226 WEST RI SUITE JACK O'CONNELL CHAIR SANTA BARBARA. C CA 93101 BUDGET&FISCAL REVIEW ,805,966.2296 EIGHTEENTH SENATORIAL DISTRICT COASTAL CAUCUS VENTURA OFFICE MAJORITY CAUCUS MCMDER B9 S CALIFORNIA STREET.SUITE E VENTURA.CA 93001 BUDGET AND FISCAL REVIEW ,805,641.1500 BUSINESS AND PROFESSIONS CONSTITUTIONAL AMENDMENTS EDUCATION ENVIRONMENTAL DUALITY �AUNCIL r CDD DIR JUDICIARY r 0 , NATURAL RESOURCES October 9, 1997no r ERKIORIG ❑ f OLICE COIF MMT ❑ REC DIR m Qi ❑ UTIL DIR ❑ [3 PERS DIR The Honorable Allen Settle, Mayor City of San Luis Obispo 990 Pal Street San Luis Obispo, CA 93401 Dear Allen: Thank you for forwarding me a copy of your September 11 letter to Congressman Capps regarding cleanup from the 1995 and 1996 storms. I apologize for the delay in responding to your letter. As you may be aware, Governor Wilson announced this week that he is contacting the Clinton Administration to request expedited cleanup in light of the forthcoming predictions of this year's EI Nino. I have been informed that there will be regional meetings throughout the state to discuss the efforts that will be necessary from state and local governments. A meeting for the Santa Barbara region has been set for November 19 and a location will be announced. Thank you again for providing me with a copy of your correspondence. As more information comes to me regarding the preparations for EI Nino, please be assured I will keep you informed. Sincerely, eCKCONNELL JO:tav CR RECEIVED 0 C T 2 0 1996 SLO CITY COUNCIL PRINTED ON RECYCLED PAPER ' PatETINGGx_97 AGENDA 021 DATE ITEM # COUNCIL MEMORANDUM .77 October 20, 1997 �� TO: City Council "ca oN ie PAO cAO ❑ WOF voe VIA: John Dunn, City Administrative Offic� FCLEO KIORRNEY [I Poue eA �CLERKIORIG ❑P0110ECx�• ❑!�G TEAM ❑REC DI:1 VIA: Mike McCluskey,Director of Public Works p� ❑UTIL DIR ❑ ❑PERS DIR FROM: Wayne Peterson, City Engineer SUBJECT: El Nino Meeting with Congressman Capps 10/17/97 On Friday I traveled to Santa Barbara with the County Engineer to attend a meeting involving Congressman Capps and other public agency representatives. Prior to the meeting, the counties and I met with the Corps and discussed concerns. The Corps feels boxed in between what we are asking for and the other Federal agencies who have different agendas and the public, some of whom are interested in environmental issues and others in property rights and flood protection issues. The Corps was able to give Santa Barbara County some fairly good news prior to the meeting with Capps regarding the status of their applications. When the actual meeting convened those in attendance at the main conference table were representatives of the Corps of Engineers, Federal Fish and Wildlife Service, the Congressman and several of his staff., County of Santa Barbara Engineering and Flood Control, County of San Luis Obispo Engineer and Flood Control and the City of San Luis Obispo. EPA was represented via conference call. Around the sides of the room, and listening to those speak at the conference table, were representatives of Lompoc, various environmental groups, private citizens and Vandenberg Air Force base. The meeting was facilitated by Congressman Capps. He led off with a speech indicating his concern and desire to find solutions to the problems. The Congressman asked the two County Engineers to speak and list out their needs. The Federal regulators then explained how they could or could not help the Counties accomplish their goals for preparation for the winter rains. The Federal agencies provided some obvious new information, that caught County representatives by surprise, that seemed to allow the Counties some opportunity to proceed with their applications. The agencies agreed to expedite the winter preparation projects on a 15 or 30 day turnaround. However, the Federal Fish and Wildlife representative made clear that just because, in certain circumstances, cities and counties do not need an Corps permit they probably still need a Fish and Wildlife permit prior to doing work. This was something new to all the local agencies in the room. The Congressman offered me a chance to speak towards the end of the meeting. I expressed my concern about the difficulty we were having dealing with the various Federal agencies and the 1 amount of time that was involved in the process. I encouraged him to proceed with the process of looking at the program .and finding ways to make the process more understandable and easier to negotiate. After the meeting I spent some time talking to the Congressman and his aid from San Luis Obispo. The impression they gave me is that he intends to pursue the issue and create some reform of the process. I believe we should continue to press the need for reform. I was advised on Thursday at 5pm that our emergency project should receive a permit from the Corps by Thursday this week. I have authorized Jeff Peters of Questa Engineering to prepare the bid plans for the project. If granted, the work would have to be completed prior to November 150', the deadline established by the State Fish and Game. The City Council will be asked to grant approval for bidding at its October 215L meeting in anticipation of receipt of a Corps permit. 2 , rPCr ua:C.:L ❑CD c:a Rppp ❑FIRE CHIEF :EYING AGENDA RNEY tFPw DIR - = DATE ITEM # ` KIOAI4 ❑POLICE CHF i pIm T7F� ❑AEC DIR ENVIRONMENTAL OUTILDIR DEFENSE `CENTER ?rte 09 Anthony Spina National Marine Fisheries Service 501 W. Ocean Blvd., Suite 4200 "- Long Beach, CA 908024213 RE: CITY OF SAN LUIS OBISPO; PROPOSED BANK STABILIZATION AND DESILTING AT THREE LOCATIONS IN SAN LUIS OBISPO CREEK -Dear Anthony: As a follow up to our conversations regarding the City of San Luis Obispo's proposed emergency.bank stabilization and desilting project at three locations in the San Luis Obispo Creek, we are writing to express the Environmental Defense Center's concerns about the proposal. Additionally, we will offer meaningful mitigation measures that could serve to lessen impacts to steelhead in the creek. After our discussion, I contacted Phil Ashley, a fisheries biologist in San Luis Obispo. Phil visited the site and determined that there is water present at the Marsh Street Bridge site, as you had mentioned, but he also confirmed that there is water present in the pool at the base of the steep bank at the RRM site. This pool, according to your measurements, is approximately 23 feet long by 15 feet wide. Mr. Ashley was unable to ascertain whether or not steelhead were present, and stated that it would take elctroshocking to determine the presence or absence of steelhead in the pool. He did confirm that a western pond turtle, a state species of special concern, was using the pool yesterday, and that steelhead had been seen in this pool during the spring. .The Environmental Defense Center opposes the temporary emergency placement of rock rip rap at the RRM and Wastewater Treatment Plant(WWTP) sites because it is a resource unfriendly short term measure that may result in significant impacts to steelhead. Rip rap at these locations would partially fill in the RRM pool and potentially a dry pool that is used seasonally by steelhead underneath and adjacent to a failing gabion at the WWTP site. If rip rap is placed at these locations, it should only be done after the absence of steelhead is confirmed and under the following conditions: 1) The rip rap will encroach no more than five feet into the pool; 2) the rip"rap will be removed within 1-year following permitting by the Corps of a long-term solution; 3) the rip rap will be installed/removed during dry or low flow conditions; 4) work must be done from the bank top, and 5) no native trees will be removed. In addition to completely or partially filling these pools, the placement of rip rap may prevent the natural reestablishment of these pools in subsequent years. As I stated, I have seen situations on San Jose Creek in Goleta where rip rap was placed in pools along eroding banks, and apparently as a result, natural pool formation has not occurred. Therefore monitoring should be required of the City so pool reformation, or lack thereof, will be documented. 906 GARDEN STREET, SUITE 2, SANTA BARBARA, CA 93101 (805)963.1622 FAX: (805)962-1152 INTERNET ADDRESS: edcarain.ors Anthony Spina October 15, 1997 Page 2 Furthermore, since the proposed action is temporary, the removal of the boulders may also result in impacts. Unless it is undertaken when the creek is dry,removal may result in sedimentation. However, these sites may not go dry during the time that the City would propose removal. Additionally, if pools form adjacent to the rip rap that would be placed at the sites, then incidental fallback of material during the removal may jeopardize steelhead. The WWTP site contains a pool that although now dry, does support steelhead seasonally. This pool must be avoided. One option for avoiding this pool is relocating the sludge line that the City is concerned about. If this line is relocated as part of a permanent solution,then that would negate the misperceived emergency situation and open up a number of other options, including bio-technical measures, for bank stabilization. One of our concerns with the process that drives our concern for the natural resources of San Luis Obispo Creek is the definition of an emergency. The City proposed work is not of an emergency nature. These sites are historical problem areas. The problems may have been exacerbated by the high flows in the past three years, however, if this is the case, then.the City has had ample time to plan and undertake an environmentally friendly approach to resolving the problems. An emergency is defined by the Corps of Engineers as an imminent threat to life or property. While an emergency may have existed during the flooding two years ago, it no longer does. Therefore any federal action approving these projects as emergency activities is flawed and subject to legal challenge. The proposed work could be carried out in a more sensitive way that would avoid or minimize impacts to steelhead. Pools at the RRM and the WWTP sites can be avoided. The active stream channel at the Marsh Street Bridge site can also be avoided. If the Corps and NMFS direct the City to limit its work to the gravel bar on the right side of the channel (when facing downstream) both immediately upstream and immediately downstream from the bridge, then flowing and pooled water could be avoided and the project could proceed with less concern about direct impacts to steelhead. We recommend that the Corps and NMFS require the work area to be flagged in such a way that restricts activities from aquatic resources, and require biological monitoring during the construction and desilting. Thank you for your attention to our comments. Sincerely, Brian Trautwein, Environmental Analyst Environmental Defense Center cc: Tiffany Welch, ACOE Aaron Setran, EPA Chuck Marshall, CDFG Geoff land, ECO SLO Neil Havlik, City of San Luis Obispo Printed on 100%Recycled Paper ENVIRONMENTAL October 13, 1997 DEFENSE "CENTER OCT f. Wt Tiffany Welch �'�` 'o U.S. Army Corps of Engineers ? � I) 2151 Allesandro Drive, Suite 255 Ventura, CA 93001 RE: STREAM CORRIDOR MANAGEMENT PLAN FOR SAN LUIS OBISPO CREEK;RESPONSE TO 9-23-97 LETTER FROM QUESTA ENGINEERING CORPORATION Dear Tiffany: I have reviewed the September 23, 1997 letter from Questa to you in response to the Environmental Defense Center's comments regarding the Corps Public Notice for the San Luis Obispo Creek Flood Control Project(a.k.a. Stream Corridor Management Plan.) Questa strongly disagrees with our conclusions that alternatives need to be evaluated. This engineering firm states that"alternatives were thoroughly reviewed for each of the sites." However,the Environmental Defense Center knows of no such alternatives. Alternatives were not reviewed by the public nor by biologists interested in the avoidance and minimization of impacts to waters of the U.S.,wetlands, and aquatic resources including Threatened and Endangered species. The Questa letter states that"all identified impacts have been mitigated." This troubling statement warrants several comments. First, all impacts have not been identified in either Questa's review or in the City of San Luis Obispo's Negative Declaration. Second, no impacts of this project have been mitigated. Finally,the mitigation measures suggested by Questa and proposed by the City are, according to the City,largely experimental. For instance,the lunker structures and planted rip-rap,and gabions are new measures for the City. Their effectiveness at mitigating impacts is questionable. Santa Barbara County's Flood Control District has had little success at revegetating rip-rap with willow cuttings. There has been no analysis of the impacts of phase II, even though,phase I and H combined would channelize or otherwise alter approximately 1-mile of the creek. In this regard,'the City has improperly segmented its analysis of this project. The impacts of the City's proposed action and other contemplated or reasonably foreseeable actions have similarly not been analyzed. Thus, Questa's evaluation of alternatives and mitigation measures was . consideration for the cumulative impacts of other'nctivities. performed in a vacuum with no . and no consideration for avoidance of resources as a higher priority thaninifigating impacts. .. 906 GARDEN STREET, SUITE 2, SANTA BARBARA, CA 93.101 —_ - I80S)963=1622 FAX: (805)962-3152 INTERNET ADDRESS: edc®ra n.or 6 - Tiffany Welch October 13, 1997 - Page Questa suggests that the value of the pools currently inhabited by steelhead and other aquatic resources is low because"these.are not historic, long-term pools that have persisted in a stable stream channel.." .Questa's assertion is not true. These pools are of avery high value for ' spawning and rearing activities. The City's work should include avoidance of these resources rather than filling:of the.pools and relying on unproven mitigation techniques. The pool at the RRM site is located at the outside of a bend in the creek. It is a natural location for a pool-to develop. This pool had standing water on September 24, 1997, and . likely still does, or will again this fall as the days grow shorter and the production of riparian vegetation and evapo-transpiration slows down causing a rise in the groundwater elevation relative to the streambed. Placement of rip-rap at this location(filling the pool)may prevent the future formation of pools on the outside of the bend at this location,thus Iimiting available natural habitat. In closing, Questa's September 23: 1997 letter to you failed to address many of the significant issues raised in the Environmental Defense Center's September 10, 19971etter to the Corps. We remain concerned that significant,unmitigated.impacts to the aquatic resources of San Luis Obispo Creek will result from the proposed actions. Therefore, we urge the Corps to require an•EIS for the work proposed by the City. An EIS may be the only way in which significant issues and less damaging alternatives are adequately analyzed. The Environmental Defense Center maintains.its position in support of the Corps' proper enforcement of the Clean Water Act. We continue to be committed to offering our assistance in any way possible to ensure that the project ultimately implemented by the City conforms with the legal requirements to protect aquatic resources in San Luis Obispo Creek. Thank you for your consideration of these comments. Sincerely, /r3 Brian Trautwein,Environmental Analyst Environmental Defense Center cc: Neil Havlik, City of San Luis Obispo Chuck Marshall,Department of Fish and Game Anthony Spina,National Marine Fisheries Service David Castanon,U.S.-Army Corps of Engineers Kirk Wong, U.S. Fish and Wildlife Service Geoff Laud,ECOSLO Printed on 100%Recycled Paper_