S TAT E OF C A L I F 0 R N I A

Governor's Offic e of Planning and Research

State Clearinghouse a nd Planning Unit Edmund G. Brown Jr.

Governor

Notice of Preparation

November 22, 2013

To: Reviewing Agencies

Re : Pradio Basin Sediment Management Demonstration Project SCH# 2013111071

Attached for your review and comment is the Notice of Preparation (NOP)for the Pradio Basin Sediment Management Demonstration Project draft Environmental Impact Report (EIR).

Responsible agencies must transmit their conunents on the scope and content of the NOP, focusing on specific inforn1ation related to their own statutory responsibility, within 30 days of receipt of the NOP from the Lead Agency. This is a courtesy notice provided by the State Clearinghouse with a reminder for you to conm1ent in a timely manner. We encourage other agencies to also respond to this notice and express their concerns early in the environn1ental review process .

Please direct your comments to:

Daniel Bott Orange County Water District 18700 Ward Street Fountain Valley, CA 92708

with a copy to the State Clearinghouse in the Office of Planning and Research. Please refer to the SCH number noted above in all correspondence concerning this project.

If you have any questions about the environmental document review process, please call the State Clearinghouse at (9 16) 445-0613.

Sincerely,

~"~ Sco~:· ·~ Director, State Clearinghouse

Attachments cc: Lead Agency

HOO TE.:\TH STREET P 0 BOX 304,1 SA. C!'L\MENTO. CA..LIFORNIA 95Sl2-3044 TEL (916) -145-0613 FA.c\: (916) 323-3018 www.opr.ca.gov

SCH# Project Title

Lead Agency

2013111071

Document Details Report State Clearinghouse Data Base

Pradio Basin Sediment Management Demonstration Project Orange County Water District

Type NOP Notice of Preparation

Description Proposed project is to explore practical and beneficial methods to remove approximately 250,000 to

500,000 cubic yards of sediment from Prado Basin and re-entrain the sediment into the lower Santa

Ana River.

Lead Agency Contact Daniel Bott Name

Agency Phone

Orange County Water District 714 378 3256

email Address 18700 Ward Street

City Fountain Valley

Project Location County Riverside

City Corona Region

SR-91 at SR-71 33° 53' 12" N I 11r 38' 13" W

Cross Streets Lat!Long Parcel No.

Township 3S

Proximity to: Highways SR-91, 71

Airports Corona Railways

Waterways Schools

Land Use

Santa Ana River

Open Space

Range 7W

Fax

State CA Zip 92708

Section 8 Base

Project Issues AestheticNisual; Air Quality; Biological Resources; Drainage/Absorption; Geologic/Seismic; Noise;

Traffic/Circulation; Vegetation; Water Quality; Water Supply; Wetland/Riparian; Landuse

Reviewing Agencies

Resources Agency; Department of Parks and Recreation; Department of Water Resources;

Department of Fish and Wildlife, Region 6; Native American Heritage Commission; Caltrans, Division

of Aeronautics; California Highway Patrol; Caltrans, District 8; Air Resources Board; Regional Water

Quality Control Board, Region 8

Date Received 11/21/2013 Start of Review 11/22/2013 End of Review 12/23/2013

NOP Distribution List -------- -~

:esources Agency

I Resources Agency Nadell Gayou

0 Dept. of Boating & Waterways

Nicole Wong

0 California Coastal Commission

Elizabeth A. Fucl1s

0 Colorado River Board Tamya Trujillo

0 Dept. of Conservation Elizabeth Carpenter

0 California Energy Commission

Eric Knight

0 Cal Fire Dan Foster

0 Central Valley Flood Protection Board

James Herota

0 Office of Historic Preservation

Ron Parsons

Dept of Parks & Recreation Environmental Stewardship Section

0 California Department of Resources, Recycling & Recovery Sue O'Leary

0 S.F. Bay Conservation & Dev't. Comm.

Steve McAdam

Ill Dept. of Water Resources Resources Agency

Nadell Gayou

;hand Game

0 Depart_ of Fish & Wildlife Scott Flint Environmental Services Division

0 Fish & Wildlife Region 1 Donald Koch

0 Fish & Wildlife Region 1 E Laurie Harnsberger

0 Fish & Wildlife Region 2 Jeff Drongesen

0 Fish & Wildlife Region 3 Charles Anmor

0 Fish & Wildlife Region 4 Julie Vance

0 Fish & Wildlife Region 5 Leslie Newton-Reed Habitat Conservation Program

II Fish & Wildlife Region 6 Gabrina Gatchel Habitat Conservation Program

0 Fish & Wildlife Region 6 liM Heidi Sickler lnyo/Mono, Habitat Conservation Program

0 Dept. of Fish & Wildlife M George Isaac Marine Region

Other Departments

0 Food & Agriculture Sandra Schubert Dept. of Food and Agriculture

0 Depart. of General Services

Public School Construction

0 Dept. of General Services Anna Garbeff Environmental Services Section

0 Dept. of Public Health Jeffery Worth Dept. of Health/Drinking Water

0 Delta Stewardship Council Kevan Samsam

Independent Commissions. Boards

0 Delta Protection Commission

Michael Machado

0 Cal EMA (Emergency Management Agency)

Dennis Castrillo

County: \2 vJ 'Z; ~ \\:fr,

• Native American Heritage Comm.

0

0

0

Debbie Treadway

0 Public Utilities Commission

Leo Wong

Santa Monica Bay Restoration Guangyu Wang

State Lands Commission Jennifer Deleong

Tahoe Regional Planning Agency (TRPA) Cherry Jacques

Business. Trans & Housing

• Caltrans - Division of Aeronautics

Philip Crimmins

0 Caltrans - Planning Terri Pencovic

• California Highway Patrol Suzann lkeuchi Office of Special Projects

0 Housing & Community Development

CEQA Coordinator Housing Policy Division

Dept. of Transportation

0 Caltrans, District 1 Rex Jackman

0 Caltrans, District 2 Marcelino Gonzalez

0 Caltrans, District 3 Gary Arnold

0 Caltrans, District 4 Erik Aim

0 Caltrans, District 5 David Murray

0 Caltrans, District 6 Michael Navarro

0 Caltrans, District 7 Dianna Watson

2 0 1 3 11 1 u /-1 SCH# --~~~-__ _

• Caltrans, District 8 Dan Kopulsky

0 Caltrans, District 9 Gayle Rosander

0 Caltrans, District 10 Torn Dumas

0 Caltrans, District 11 Jacob Armstrong

0 Caltrans, District 12 Maureen El Harake

Cal EPA

Air Resources Board

• All Projects CEQA Coordinator

0 Transportation Projects Jon Taylor

0 Industrial Projects Mike Tollstrup

0 State Water Resources Control Board

Regional Programs Unit Division of Financial Assistance

0 State Water Resources Control Board

Student Intern, 401 Water Quality Certification Unit Division of Water Quality

0 State Water Resouces Control Board

Phil Crader Division of Water Rights

0 Dept. of Toxic Substances Control

CEQA Tracking Center

0 Department of Pesticide Regulation

CEQA Coordinator

Regional Water Quality Control Board (RWQCBl

0 RWQCB 1 Cathleen Hudson North Coast Region (1)

0 RWQCB2 Environmental Document Coordinator San Francisco Bay Region (2)

0 RWQCB3 Central Coast Region (3)

0 RWQCB4 Teresa Rodgers Los Angeles Region (4)

0 RWQCB 5S Central Valley Region (5)

0 RWQCB 5F Central Valley Region (5) Fresno Branch Office

0 RWQCB 5R Central Valley Region (5) Redding Branch Office

0 RWQCB6 Lal10ntan Region (6)

0 RWQCB6V Lahontan Region (6) Victorville Branch Office

0 RWQCB7 Colorado River Basin Region (7)

II RWQCB 8 Santa Ana Region (8)

0 RWQCB9 San Diego Region (9)

0 Other ______ _

0 ___ _ Conservancy

LCJsl lJnrl81P.rl q /?4/?nP.

Notice of Completion & Environmental Document Transmittal Mail to: State Clearinghouse, P.O. Box 3044, Sacramento, CA 95812-3044 (916) 445-0613 For Hand Delivery/Street Address: 1400 Tenth Street, Sacramento, CA 95814

Print Form Appendix C

Project Title: Prado Basin Sediment Management Demonstration Project

Lead Agency: Orange County Water District Contact Person: Daniel Bott --~~---------------

Mailing Address: 18700 Ward Street City: Fountain Valley, CA

Phone: 714 378-3256

Zip: 92708 County: Orange --~~-------------------------

Project Location: County: Riverside City/Nearest Community: Corona -------------------------- -------------------------------Cross Streets: SR-91 at SR-71 Zip Code: ------­Longitude/Latitude (degrees, minutes and seconds): !..!Z_o ~· .1l___" N I ~o ~· g_" W Total Acres: 85 acres

--~-------Assessor's Parcel No.: Section: 8 Twp.: 38 Range: 7W Base: N. Corona Within 2 Miles: State Hwy #: SR-91, SR-71 Waterways: Santa Ana River ----------------------------------------

Airports: Corona Railways: Schools: ------------------------- ---- ------- ----- -----Document Type:

CEQA: ~ NOP 0 Early Cons 0 Neg Dec 0 MitNegDec

Local Action Type:

0 General Plan Update 0 General Plan Amendment 0 General Plan Element 0 Community Plan

Development Type:

0 DraftEIR RECEI\/JiO 0 NOI Other: 0 Supplement/Subsequent EIR 0 EA (Prior SCH No.)

NuV 2 1 2013 0 Draft EIS

Other: 0 FONSI

0 -s - .fi-~11 ATE CL-Et~~~HR,QUSE- - -- - - - -

pec1 1c'P an 0 ezone 0 Master Plan 0 Prezone 0 Planned Unit Development 0 Use Permit 0 Site Plan 0 Land Division (Subdivision, etc.)

0 Residential: Units _____ Acres ___ __

------0 Joint Document 0 Final Document 0 Other:

0 Annexation 0 Redevelopment 0 Coastal Permit ~ Other: project Approval

0 Office: Sq.ft. Acres __ _ 0 Commercial:Sq.ft. Acres __ _

Employees __ _ 0 Transportation: Type ---------------------------0 Mining: Mineral Employees __ _ 0 Industrial: Sq.ft. Acres __ _ 0 Educational:

Employees __ _ ----------~~-----------0 Power: Type--------- MW ________ _ 0 Waste Treatment: Type MGD ________ _

0 RecreationaL·-----------------------------------

0 Water Facilities:Type -----------0 Hazardous Waste:Type ~ Other: Sediment Ma nag_e_m_e_n-:-t -;:::D:-e_m_o_n_s~tr-at"'"io_n_P;:::-ro-=-je-c-:-t-----MGD ____ _

Project Issues Discussed in Document:

~ AestheticNisual 0 Fiscal 0 Recreation/Parks 0 Agricultural Land 0 Flood Plain/Flooding 0 Schools/Universities ~ Air Quality 0 Forest Land/Fire Hazard 0 Septic Systems 0 Archeological/Historical ~ Geologic/Seismic 0 Sewer Capacity ~ Biological Resources 0 Minerals 0 Soil Erosion/Compaction/Grading 0 Coastal Zone ~Noise 0 Solid Waste ~ Drainage/Absorption 0 Population/Housing Balance 0 Toxic/Hazardous 0 Economic/Jobs 0 Public Services/Facilities [g) Traffic/Circulation

Present Land Use/Zoning/General Plan Designation: Open Space/Open Space

~ Vegetation [g) Water Quality [g) Water Supply/Groundwater ~Wetland/Riparian 0 Growth Inducement [g) Land Use 0 Cumulative Effects 0 Other: -------------

---------------------------------------------Project Description: (please use a separate page if necessary) Proposed project is to explore practical and beneficial methods to remove approximately 250,000 to 500,000 cubic yards of sediment from Prado Basin and re-entrain the sediment into the lower Santa Ana River.

Note: The State Clearinghouse will assign identification numbers for all new projects. If a SCH number already existsfor a project I e.g. Notice of Preparation or previous draft document) please fill in.

1

ENDANGERED HABITATS LEAGUE DE DICATED TO ECOSYS TE M P RO TE CT I ON A N D SUS TA I NABLE L A N D U SE

VIA ELECTRONIC MAIL

Daniel Bott, Principal Planner Orange County Water District 18700 Ward St Fountain Valley, CA 92708 dbott@ocwd.com

December 16, 2013

RE: Prado Basin Sediment Management Demonstration Project

Dear Mr. Bott:

The Endangered Habitats League (EHL) appreciates the opportunity to review the Notice of Preparation. EHL strongly supports this demonstration project for transport of sediment that has collected behind Prado Dam to the downstream reaches of the river and beaches where it belongs. The goal of the demonstration is to provide data, conclusions, and recommendations for a long-term program. This is a visionary effort that can be a model for similar endeavors in many other watersheds that are starved for sediment.

The potential benefits down the line are great and multiple, and clearly justify the cost involved for the demonstration project. Most directly, removing sediment will increase the capacity of Prado Dam, increase its lifespan, and potentially obviate more costly capacity-increasing measures. Sediment transport can also reduce scouring and erosion downstream and help restore damaged fluvial and ecosystem processes. It can replenish beaches and protect coastal structures from the forces of the ocean, again potentially obviating the need for costly structural measures like seawalls that create even more problems.

On a technical level, the proper issues for analysis in the EIR are well thought through and clearly laid out in the Initial Study. Attention is being paid to the biological impacts of creating the infrastructure for the project, such as channels and storage areas. We do recommend that options for re-entrainment of sediment be evaluated for those methods and locations that would generate most ecological benefit. We look forward to reviewing the DEIR and its proposed mitigation.

We commend the District for undertaking this project, which can both advance the District' s water conservation mission and help restore some of the damage that Prado Dam and the massive human settlement it supports have done to the original ecosystem. Please maintain EHL on all notification and distribution lists, including CEQA documents and public hearings.

8424 SAN TA MONICA B LvD Su1n A 592 Los AN GE LE S CA 90069-4267 + www.EHLEAGUE. ORG + PH O N E 213.804.2750

Sincerely,

Dan Silver, MD Executive Director

(951 ) 736-2262

(951) 279-3550 FAX

December 19, 2013

Mr. Daniel Bott Principal Planner

Community Development Department "Promoting and Sustaining Quality Developmenf'

400 S. Vicentia Avenue, Corona, California 92882 www. discovercorona. com

Orange County Water District 18700 Ward Street Fountain Valley, CA 92708

RE: Notice of Preparation (NOP) of Environmental Impact Report Orange County Water District Prado Basin Sediment Management Demonstration Project

Dear Mr. Bott:

Thank you for the opportunity to comment on the above-referenced NOP. The city staff has reviewed the Initial Study and finds that the document properly scopes the topics of concern to the City of Corona including potential impacts from light and glare, noise, and truck/equipment routes.

We look forward to the opportunity to review the Environmental Impact Report when it is circulated, and invite you to contact us if you need any information that the City of Corona can provide.

Sincerely,

Terri Manue , AICP Planning Manager

C. Maria Sambito, Principal Civil Engineer, City of Corona

DEPARTMENT OF PUBLIC WORKS FLOOD CONTROL • LAND DEVELOPMENT & CONSTRUCTION • OPERATIONS SOLID WASTE MANAGEMENT • SURVEYOR • TRANSPORTATION

825 East Third Street • San Bernardino, CA 92415·0835 • (909) 387-8104 Fax (909) 387-8130

December 19, 2013

Daniel Bott, Principal Planner Orange County Water District 18700 Ward Street Fountain Valley, CA. 92708

COUNTY OF SAN BERNARDINO

GERRY NEWCOMBE Director of Public Works

File: 1 O(ENV)-4.01

RE: CEQA - NOTICE OF PREPARATION OF A DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE PRADO BASIN SEDIMENT MANAGEMENT DEMONSTRATION PROJECT FOR THE ORANGE COUNTY WATER DISTRICT

Mr. Bott:

Thank you for giving the San Bernardino County Department of Public Works the opportunity to comment on the above-referenced project. We received this request on November 26, 2013, and pursuant to our review, we have no comments.

Sincerely,

ANNESLEY IG ~TIUS, P.E. Deputy Director - Environmental & Construction

ARI: p E: n h/ CEQA Comments_NOP-Orange County Watyer District_Prado Basin Sediment Mgmt_12-19-13

bca~c ol Suoerv.s.•.::rs Tf'irC Di::tr:,::

~e:t :r : :: [>:t::c!

South Coast Air Quality Management District 21865 Copley Drive, Diamond Bar, CA 91765-4178

(909) 396-2000 • www.aqmd.gov

Daniel Bott, Principal Planner Orange County Water District 18700 Ward Street Fountain Valley, CA 92708

Notice of Preparation of a CEQA Document for the Prado Basin Sediment Management Project

January 3, 2014

The South Coast Air Quality Management District (SCAQMD) staff appreciates the opportunity to comment on the above-mentioned document. The SCAQMD staffs comments are recommendations regarding the analysis of potential air quality impacts from the proposed project that should be included in the draft CEQA document. Please send the SCAQMD a copy of the Draft EIR upon its completion. Note that copies of the Draft EIR that are submitted to the State Clearinghouse are not forwarded to the SCAQMD. Please forward a copy of the Draft EIR directly to SCAQMD at the address in our letterhead. In addition, please send with the draft EIR all appendices or technical documents related to the air quality and greenhouse gas analyses and electronic versions of all air quality modeling and health risk assessment files. These include original emission calculation spreadsheets and modeling files (not Adobe PDF files). Without all files and supporting air quality documentation, the SCAQMD will be unable to complete its review of the air quality analysis in a timely manner. Any delays in providing all supporting air quality documentation will require additional time for review beyond the end of the comment period.

Air Quality Analysis The SCAQMD adopted its California Environmental Quality Act (CEQA) Air Quality Handbook in 1993 to assist other public agencies with the preparation of air quality analyses. The SCAQMD recommends that the Lead Agency use this Handbook as guidance when preparing its air quality analysis. Copies of the Handbook are available from the SCAQMD's Subscription Services Department by calling (909) 396-3720. More recent guidance developed since this Handbook was published is also available on SCAQMD's website here: www.aqmd.gov/ceqa/hdbk.html. SCAQMD staff also recommends that the lead agency use the CaiEEMod land use emissions software. This software has recently been updated to incorporate up-to-date state and locally approved emission factors and methodologies for estimating pollutant emissions from typical land use development. CalEEMod is the only software model maintained by the California Air Pollution Control Officers Association (CAPCOA) and replaces the now outdated URBEMIS. This model is available free of charge at: www.caleemod.com.

The Lead Agency should identify any potential adverse air quality impacts that could occur from all phases of the project and all air pollutant sources related to the project. Air quality impacts from both construction (including demolition, if any) and operations should be calculated. Construction-related air quality impacts typically include, but are not limited to, emissions from the use of heavy-duty equipment from grading, earth-loading/unloading, paving, architectural coatings, off-road mobile sources (e.g., heavy-duty construction equipment) and on-road mobile sources (e.g., construction worker vehicle trips, material transport trips). Operation-related air quality impacts may include, but are not limited to, emissions from stationary sources (e.g., boilers), area sources (e.g., solvents and coatings), and vehicular trips (e.g., on- and off-road tailpipe emissions and entrained dust). Air quality impacts from indirect sources, that is, sources that generate or attract vehicular trips should be included in the analysis.

The SCAQMD has also developed both regional and localized significance thresholds. The SCAQMD staff requests that the lead agency quantifY criteria pollutant emissions and compare the results to the recommended regional significance thresholds found here: http://www.aqmd.gov/ceqa/handbooklsignthres.pdf. In addition to analyzing regional air quality impacts, the SCAQMD staff recommends calculating localized air quality impacts and comparing the results to localized significance thresholds (LSTs). LST's can be used in addition to the recommended regional significance thresholds as a second indication of air quality impacts when preparing a CEQA document. Therefore,

Daniel Bott -2- January 3, 2014

when preparing the air quality analysis for the proposed project, it is recommended that the lead agency perform a localized analysis by either using the LSTs developed by the SCAQMD or performing dispersion modeling as necessary. Guidance for performing a localized air quality analysis can be found at: http://www.aqmd.gov/ceqalhandbook!LST/LST.html.

In the event that the proposed project generates or attracts vehicular trips, especially heavy-duty diesel-fueled vehicles, it is recommended that the lead agency perform a mobile source health risk assessment. Guidance for performing a mobile source health risk assessment ("Health Risk Assessment Guidance for Analyzing Cancer Risk from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis") can be found at: http://www.aqmd.gov/ceqalhandbook!mobile toxic/mobile toxic.html. An analysis of all toxic air contaminant impacts due to the use of equipment potentially generating such air pollutants should also be included.

In addition, guidance on siting incompatible land uses (such as placing homes near freeways) can be found in the California Air Resources Board's Air Quality and Land Use Handbook: A Community Perspective, which can be found at the following internet address: http://www.arb.ca.gov/ch/handbook.pdf. CARB's Land Use Handbook is a general reference guide for evaluating and reducing air pollution impacts associated with new projects that go through the land use decision-making process.

Mitigation Measures In the event that the project generates significant adverse air quality impacts, CEQA requires that all feasible mitigation measures that go beyond what is required by law be utilized during project construction and operation to minimize or eliminate these impacts. Pursuant to state CEQA Guidelines § 15126.4 ( a)(l )(D), any impacts resulting from mitigation measures must also be discussed. Several resources are available to assist the Lead Agency with identifying possible mitigation measures for the project, including:

• Chapter 11 ofthe SCAQMD CEQA Air Quality Handbook • SCAQMD's CEQA web pages at: www.aqmd.gov/ceqalhandbook!mitigation!MM intro.html • CAPCOA's Quantifying Greenhouse Gas Mitigation Measures available here:

http:/ /www.capcoa.org/wp-content/uploads/20 1 0/11 /CAPCOA-Quantification-Report-9-14-Final.pdf. • SCAQMD's Rule 403- Fugitive Dust, and the Implementation Handbook for controlling construction-related

emissions • Other measures to reduce air quality impacts from land use projects can be found in the SCAQMD's Guidance

Document for Addressing Air Quality Issues in General Plans and Local Planning. This document can be found at the following internet address: http://www.aqmd.gov/prdas/aqguide/aqguide.html.

Data Sources SCAQMD rules and relevant air quality reports and data are available by calling the SCAQMD's Public Information Center at (909) 396-2039. Much of the information available through the Public Information Center is also available via the SCAQMD's webpage (http://www.aqmd.gov).

The SCAQMD staff is available to work with the Lead Agency to ensure that project emissions are accurately evaluated and mitigated where feasible. If you have any questions regarding this letter, please contact me at imacmillan@aqmd.gov or call me at (909) 396-3244.

ORC131122-03 Control Number

Sincerely,

/._ 1/ ?.L ?ld Ian MacMillan Program Supervisor, CEQA Inter-Governmental Review Planning, Rule Development & Area Sources

Public Works Integrity, Accountability, Service, Trust

December 31, 2013

Mr. Daniel Bott, Principal Planner Orange County Water District 18700 Ward Street Fountain Valley, California 92708

Shane L Silsby, P.E., Director 300 N. Flower Street

Santa Ana, CA 92703

P.O. Box 4048 Santa Ana, CA 92702-4048

Telephone: (714) 667-8800 Fax: (714) 967-0896

NCL-13-057

SUBJECT: Notice of Preparation of Environmental Impact Report, Orange County Water District Prado Basin Sediment Management Demonstration Project.

Dear Mr. Bott:

The County of Orange has reviewed the Notice of Preparation of Draft Environmental Impact Report Orange County Water District Prado Basin Sediment Management Demonstration Project and offers the following comments:

Environmental Resources: 1. Potential water quality impacts of the project should be evaluated with, at minimum, the

following information provided:

• Description of project characteristics with respect to water quality issues, such as project site location in a given watershed, site acreage, known ground contamination, known groundwater contamination, and anticipated change in percent impervious surface area.

• Identification of receiving waters. The EIR should identify all downstream receiving waters that may receive contributory runoff from the project site.

• Description of the sensitivity of the receiving waters. In particular the EIR should identify Areas of special Biological Significance, water bodies with Total Maximum Daily Loads (TMDL), and Clean Water Act Sec. 303(d) listed impaired water bodies.

• Characterization of the potential water quality impacts from the proposed project and identification of the anticipated pollutants to be generated by the project.

• Identification of downstream hydrologic conditions of concern that may be affected by project-related changes in runoff volume and velocity; sediment load, makeup or characteristics; reduced infiltration; and /or increased flow, frequency, duration, and peak(s) of storm runoff.

• Evaluation of thresholds of significance.

Daniel Bott Notice of Preparation Page 2

• Assessment of project impact significance to water quality.

• If a proposed project has the potential to create a major new stormwater discharge to a water body with an established TMDl, the EIR should consider quantitative analysis of the anticipated pollutant loads in the stormwater discharges to the receiving waters.

• A reasonable analysis of the cumulative impacts of the proposed project together with past, present and reasonably anticipated future projects (related projects) that could produce cumulative impacts together with the proposed project.

2. The EIR should address the project's compliance with the California Surface Mining and Reclamation Act.

3. Please ensure that Orange County Public Works Flood Control Program and Santa Ana River Project section assesses the issues relating to the placement/storage of dredged material after dewatering below Prado Dam.

4. We would defer to the Santa Ana Regional Water Quality Control Board to determine what type of NPDES permits will be required for the discharges of sediment back into the Santa Ana River, and for the discharge of dewatering back into Prado Basin.

5. Please contact the Archaeologist of the U.S. Army Corps of Engineers, los Angeles District, to locate the pioneer cemeteries that were never relocated after Prado Dam was constructed, notably with regard to the project sediment dewatering and green waste areas.

Flood Program/SAR: 1. Although the work associated with the project will be primarily located within the Prado Basin,

the EIR should place equal emphasis on the project's impact to the lower Santa Ana River downstream of Prado Dam due to sediment re-entrainment.

2. The downstream limits of the study area should be explicitly defined and extend from Prado Dam to the Pacific Ocean.

If you have any questions or need clarification please do not hesitate to call me at (714) 667-3211.

Sincerely,

Polin Modanlou, Manager Strategic land Planning Division OC Public Works/OC Planning Services 300 North Flower Street Santa Ana, California 92702-4048 Polin.Modanlou@ocpw.ocgov.com

cc: Chris Crompton, Manager, OC Public Works/Environmental Resources lance Natsuhara, Manager, OC Public Works/Flood Programs/SAR

0 R A N G E C 0 U N T Y

December 31, 2013

Sent via U.S. Postal Servia:

Daniel Bott Principal Planner Orange County Water District 18700 Ward Street Fountain Valley, CA 92708 Phone: (714) 378-3256 Email: dbott@ocwd.com

COASTKEEPER ®

3151 Airway A venue, Suite F -110 Costa Mesa, CA 92626 Phone 714-850-1965 Fax 714-850-1592 www.Coastkeeper.org

RE: Notice of Preparation of Environmental Impact Report- Prado Basin Sediment Management Demonstration Project

Dear Mr. Daniel Bott,

Orange County Coastkeeper ("Coastkeeper") is an environmental organization with the mission to preserve, protect and restore the watersheds and coastal environments of Orange County. We write on behalf of our collective membership to express our support, as well as some of our concerns, with the Notice of Preparation of Environmental Impact Report for the Orange County Water District ("OCWD") Prado Basin Sediment Management Demonstration Project (the "Project"), released on November 13,2013 by OCWD. Fully aware of the benefits that will come from data obtained as a result of this demonstration project, Coastkeeper supports the responsible undertaking of this demonstration Project. While Coastkeeper believes this demonstration project will provide data that will benefit water management practices for the Santa Ana River, we have outlined some comments addressing what should be addressed by the Environmental Impact Report ("EIR") in order to ensure that the sediment removal project goes forward in a manner that is both economically viable and environmentally responsible.

The EIR Must Contain Analysis Sufficient to Reach its Conclusions The California Environmental Quality Act ("CEQA") 1 does not encourage mere conclusions to be made as statements of fact. In Concerned Citizens of Costa Mesa, Inc. v. 32nd Dist. Agricultural Assn., the California Supreme Court held that, "[t]o facilitate CEQ A's informational role, the EIR must contain facts and analysis, not just the agency's bare conclusions or opinions."2 In Laurel Hei,_f!,hts Improvement Asso?iation of San Francisco, Jm: v. The Regents of the Universi!J ~lCal~jomia, the court said, "[w]e do not impugn the integrity of the Regents, but neither can we countenance a result that would require blind trust by the public, especially in light of CEQA's fundamental goal that the public be fully informed .... "3 Conclusions made in the EIR should be supported by a reasonable level of analysis throughout.

1 Cal. Pub. Resources Code§ 21000 et seq. 2 Concerned Citizeru of Costa Mesa, Im: v. 32nd DiJ·t. A,gricu/tural Ann., (1986) 42 Cal.3d 929, 935. 3 Laurel Heights Improt;ement AJSn. v. Regents ofUnivmity o(Calijornia, (1988) 47 Cal.3d 376, 404.

Page 1

EIR's Project Description A stable, complete, and accurate project description is the most basic and important factor in preparing an EIR. It is critical that the project description be clear and complete so that fully informed decisions may be made regarding the proposed project. A vague or ambiguous project description will render all further analyses and determinations ineffectual. "An accurate project description is necessary for an intelligent evaluation of potential environmental effects of a proposed activity."4

Environmental Setting The EIR should exactly define the existing environmental setting. Establishment of an appropriate environmental baseline is a key factor in assessing the environmental impact of the project. Importantly, Section 15125 (a) of the Guidelines for Implementation of the California Environmental Quality Act ("CEQA") provides the following:

(a) An EIR must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced, from both a local and regional perspective. This environmental setting will normally constitute the baseline physical conditions by which a lead agency determines whether an impact is significant .... 5

As stated in Counry if Amador v. ElDorado Counry Water Agenry, "[b]efore the impact of a project can be assessed and mitigation measures considered, an [ ]EIR must describe the existing environment. It is only against this baseline that any significant environmental effects can be determined."6

Aesthetics The EIR needs to discuss the Projects effect on the aesthetics of the Prado Dam flood basin area. A sufficient analysis should include, but not limited to, the following:

1. Would the project have a substantial adverse effect on a scenic vista?

2. Would the project substantially damage scenic resources, including, but not limited to, trees and rock outcroppings?

3. Would the project substantially degrade the existing visual character or quality of the site and its surroundings?

Biological Resources The EIR must discuss the Project's potential impacts on Biological resources, specifically, whether the project will have a substantial adverse effect, either directly, or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service. Given that the Project is in the area of a large riparian habitat and wetlands, any substantial adverse effects that the Project will have on these surrounding habitats or any other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or US Fish and Wildlife Service needs to be analyzed in depth. The EIR should also discuss any potential interference with with the

4 MtQueen v. Board ofDiredors ofthe Mid-Peninsula ~11,iona/ Open Space DiJ'trt•'f, (1998) 202 Cal.App.3d 1136, 1143. s 14 Cal. Code of Regs.§ 15125. 6 County ojAmador 11. E! Dorado County Water Acgen~y, (1999) 76 Cal.App.4th 931, 952.

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movement of any native resident or migratory fish or wildlife species, or established native resident or migratory wildlife corridors, or the use of native wildlife nursery sites.

Geology I Soils A primary aspect of the proposed Project is the construction large sediment removal channel measuring 6,000 feet in length and 200 feet wide. The creation of this channel in the Dam's flood basin will clearly have significant effects on the soil in the Project area and the EIR needs to analyze these effects and their proposed mitigation measures in depth. Therefore, the EIR should include an analysis on Geology and Soils that includes, but is not limited to, the following:

1. Would the project result in substantial soil erosion or the loss of topsoil?

2. Will the displacement of soil from the project area pose a substantial risk of significant environmental harm?

3. Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?

4. Have potential removal and recompaction of soils been taken into account in the examination of construction impacts, specifically noise, air quality and vehicle traffic?

5. Would the project expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving:

a) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault?7

b) Strong seismic ground shaking?

c) Seismic-related ground failure, including liquefaction?

Hydrology I Water Quality The Projects impacts on Hydrology and Water Quality must be discussed because of the project's proposed reintroduction of sediment downstream of the Dam in addition to the construction of the large sediment removal channel. Specifically, whether the project would violate any water quality standards or waste discharge requirements, or substantially alter the existing drainage pattern of the site or area, including, through the alteration of the course of a stream or river in a manner which would result in substantial erosion, siltation, or flooding on- or off-site should be analyzed.

The issue of whether the project could create or contribute runoff water which would then exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff or otherwise substantially degrade water quality also needs to be examined in the EIR as well. The mitigation or structural Site Design Best Management Practices (BMPs) must be prioritized (from highest to lowest priority):

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a) Infiltration BMPs (examples include permeable pavement with infiltration beds, dry wells, infiltration trenches, surface and sub-surface infiltration basins);

b) BMPs that harvest and use (e.g., cisterns and rain barrels); and

c) Vegetated BMPs that promote infiltration and evapotranspiration including bioretention, biofiltration and bio-treatment.

Recreation The EIR must contain a detailed analysis of whether the Project's potential to adversely impact recreation in the area of Prado Dam or any other area. This analysis must include, but is not limited to, impacts due to:

a) Visual blight.

b) Noise.

c) Impacts to plants and wildlife which lead to reduced enjoyment by the public.

Sediment loading could affect the public's enjoyment of activities such as boating, fishing, equestrian activities, picnicking and camping in the Santa Ana River. The potential impacts of the Project to the Santa Ana River downstream of the Dam need to be considered because the sediment loading described in the Initial Study could impair recreational use of the river for boating activities if utilized improperly. Furthermore, any of the Project's effects on the public's enjoyment of activities such as wildlife viewing or hiking in the flood basin itself need to be analyzed and mitigated as well.

Transportation I Traffic As the Project will require the use of trucks for monitoring, site preparation, infrastructure construction and sediment removal and re-entrainment, a sufficient traffic analysis for the EIR should include, but not be limited to, the following:

1. Would the project cause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)?

2. Would the project exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways?

3. Would the project result in inadequate emergency access?

4. Would the project conflict with adopted policies, plans, or programs supporting alternative transportation?

Noise The EIR must discuss the potential noise impacts on the surrounding area that are a result of the Project. The EIR's noise analysis should discuss the following:

1. Would the construction or day-to-day operation of the project result in adverse impacts on wildlife or recreation?

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2. Would the project result in exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?

3. Would the project result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project?

4. Would the project result in exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels?

5. Would the project result in a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project?

6. The analysis must consider noise in terms of Ldn (day-night) levels or CNELs (Community Noise Equivalent Levels) which weigh noise according to time of day in recognition of the greater annoyance factor for night time noise.

7. Inasmuch as just noticeable difference (JND) is inversely proportional to the square root of loudness, what would be the JND of noise differences at the prevailing noise levels experienced in the project area?

8. The EIR must present combined noise levels generated by all equipment likely to be in use at peak times.

9. The EIR must identify present and future CNELs ofLdns.

10. The EIR must examine noise created by truck traffic, both during construction and in the operational phase. Calculations must take into account whether trucks arc fully loaded or not.

11. How would continual vibration due to construction and day-to-day operations affect structures near the project area?

12. How will the Project's noise be monitored?

Consideration of Alternatives According to Section 15126.6(a) of the Guidelines for Implementation of CEQA, the EIR must consider a "reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation." 8 "Feasible," as defined by Section 15364 of the Guidelines, means "capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors."9

As stated in Section 15126.6(b) of the Guidelines:

[T]he discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or

8 14 Cal. Code of Regs.§ 15126.6(a). '! 14 Cal. Code of Regs.§ 15364.

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would be more cosdy. w_

In particular, we feel it is important to analyze and explain any alternatives to the construction of a large sediment removal channel. If no feasible alternatives to the Project's channel exist, the EIR should analyze why the construction of the channel is an indispensable aspect of the project. In accordance with Section 15126.6(e)(1) the "no project" alternative must be addressed and if"no project" is the environmentally superior alternative, then the EIR must identify another environmentally superior alternative among

. . l . 1112 rema111111g a ternatlves.

Mitigation Measures The EIR must address all impacts associated with proposed mitigation measures, including, but not limited to, impacts on noise, air quality, water quality and traffic. According to CEQA Guidelines Section 15126.4 (a)(1)(D):

If a mitigation measure would cause one or more significant effects in addition to those that would be caused by the project as proposed, the effects of the mitigation measure shall be discussed but in less detail than the significant effects of the project as proposed.13

In 1988, the California Legislature passed AB 3180, effective January 1, 1989, which required that mitigation monitoring programs be prepared under CEQA.14 This was in response to a number of studies which indicated that, in fact, many public agencies did not verify implementation of mitigation measures. The use of "design features" could be- and is- utilized as a means of doing an end run around the requirements of AB 3180. It is thus essential and required to formally include as mitigation measures all measures identified as reducing the potential negative effects of a project, including "design features."

Although Section 15126 of the CEQA Guidelines states that mitigation measures proposed by an applicant must be distinguished from other measures, 15 they are all still mitigation measures that need to be discussed and considered contemporaneously in the EIR to be meaningful and lawful. If a proposed action is adopted as a mitigation measure, it will have to be included in the monitoring program with specific agency responsibility assigned to see that the measure is implemented. This is designed to increase the likelihood that the mitigation will actually occur.

10 14 Cal. Code of Regs.§ 15126.6(b). 11 14 Cal. Code of Regs.§ 15126.6(e)(1). 12 14 Cal. Code of Regs.§ 15126.6(e)(2). 13 14 Cal. Code of Regs.§ 15126.4(a)(1)(D). 14 Cal. Pub. Resources Code§ 21081.6. 15 14 Cal. Code of Regs.§ 15126.

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; . ~

Conclusion As an organization with members from many different walks of life, Coastkeeper encourages environmentally responsible development which could benefit the community. Coastkeeper recognizes the significance of the technical data that the Project will provide to OCWD, and Southern California, concerning the issues of sediment build-up behind Dams and water management as a whole. We have submitted these comments with the intention to ensure that the OCWD goes forward with the Project in the most sustainable manner possible for the benefit of all who live, work, or recreate in Orange County.

Sincerely,

Colin Kelly Staff Attorney Orange County Coastkeeper

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§JAJE OF CAllf:ORNIA

NATIVE AMERICAN HERITAGE COMMISSION 1550 Harbor Boulevard, Suite 100 West Sacramento, CA 95691 (916) 373-3715 I= ax (916) 373-5471

~:-~~~~~tie,~ne1~_9_()'1 e-mail: ds_nahc@pacbell.net

Mr. Daniel Bott, P.E.

December 2, 2013

Orange County Water District 18700 Ward Street Fountain Valley, CA 92708

RE: SCH#2013111 071 CEQA Notice of Preparation (NOP); draft Environmental Impact Reprot (DEIR) for the "Prado Basin Sediment Management Project (Move up to one-half million cubic yards of sediment and retrain it into the lower Santa Ana River);" located north of Corona in Riverside County, California

Dear Mr. Bott:

The Native American Heritage Commission (NAHC) has reviewed the above-referenced environmental document.

The California Environmental Quality Act (CEQA) states that any project which includes archeological resources, is a significant effect requiring the preparation of an EIR (CEQA guidelines 15064.5(b). To adequately comply with this provision and mitigate project-related impacts on archaeological resources, the Commission recommends the following actions be required:

Contact the appropriate Information Center for a record search to determine :If a part or all of the area of project effect (APE) has been previously surveyed for cultural places(s), The NAHC recommends that known traditional cultural resources recorded on or adjacent to the APE be listed in the draft Environmental Impact Report (DEIR).

If an additional archaeological inventory survey is required, the final stage is the preparation of a professional report detailing the findings and recommendations of the records search and field survey. We suggest that this be coordinated with the NAHC, if possible. The final report containing site forms, site significance, and mitigation measurers should be submitted immediately to the planning department. All information regarding site locations, Native American human remains, and associated funerary objects should be in a separate confidential addendum, and not be made available for pubic disclosure pursuant to California Government Code Section 6254.10.

A list of appropriate Native American Contacts for consultation concerning the project site has been provided and is attached to this letter to determine if the proposed active might impinge on any cultural resources. Lack of surface evidence of archeological resources does not preclude their subsurface existence.

Lead agencies should include in their mitigation plan provisions for the identification and evaluation of accidentally discovered archeological resources, pursuant to California Health & Safety Code Section 7050.5 and California Environmental Quality Act (CEQA) §15064.5(f). In areas of identified archaeological sensitivity, a certified archaeologist and a culturally affiliated Native American, with knowledge in cultural resources, should monitor all ground-disturbing activities. Also, California Public Resources Code Section 21083.2 require documentation and analysis of archaeological items that meet the standard in Section 15064.5 (a)(b)(f).

Lead agencies should consider first, avoidance for sacred and/or historical sites, pursuant to CEQA Guidelines 15370(a). Then if the project goes ahead then, lead agencies include in their mitigation plan provisions for the analysis and disposition of recovered artifacts, pursuant to California Public Resources Code Section 21083.2 in consultation with culturally affiliated Native Americans.

Lead agencies should include provisions for discovery of Native American human remains in their mitigation plan. Health and Safety Code §7050.5, CEQA §15064.5(e), and Public Resources Code §5097.98 mandates the process to be followed in the event of an accidental discovery of any human remains in a location other than a dedicated cemetery.

CC: State Clearinghouse

Attachment: Native American Contacts list

Pechanga Band of Mission Indians Paul Macarro, Cultural Resources Manager P.O. Box 1477 Luiseno Temecula , CA 92593 (951) 770-8100 pmacarro@ pechanga-nsn. gov (951) 506-9491 Fax

Ramona Band of Cahuilla Mission Indians Joseph Hamilton, Chairman P .0. Box 391670 Cahuilla Anza , CA 92539 ad min@? ramonatribe.com (951) 763-4105 (951) 763-4325 Fax

Juaneno Band of Mission Indians Acjachemen Nation

David Belardes, Chairperson 32161 Avenida Los Amigos Juaneno San Juan Capistranq CA 92675 chiefdavidbelardes@yahoo. (949) 493-4933 - home (949) 293-8522

Santa Rosa Band of Mission Indians John Marcus, Chairman P.O. Box 391820 Cahuilla Anza , CA 92539 (951 ) 659-2700 (951) 659-2228 Fax

This list Is cummt only as of the date of this document.

Native American Contacts Riverside County California

December 2, 2013

Morongo Band of Mission Indians William Madrigal, Jr.,Cultural Resources Manager 12700 Pumarra Road Cahuilla Banning , CA 92220 Serrano (951) 201-1866- cell wmadrigal@ morongo-nsn. gov (951) 572-6004 Fax

Pechanga Band of Mission Indians Mark Macarro, Chairperson P.O. Box 1477 Luiseno Temecula , CA 92593 (951) 770-6100 hlaibach@pechanga-nsn. gov (951) 695-1778 FAX

Cahuilla Band of Indians Luther Salgado, Chairperson PO Box 391760 Cahuilla Anza , CA 92539 Chairman @cahuilla. net 760-763-5549 760-763-2631 - Tribal EPA

Pechanga Cultural Resources Department Anna Hoover, Cultural Analyst P.O. Box 2183 Luiseno Temecula , CA 92593 ahoover@ pechanga-nsn.gov 951-770-8104 (951) 694-0446- FAX

Distribution of this list does not relieve any person of the statutory responsibility as defined In Section 7050.5 of the Health and Safety Code, Section 5097.94 of the Public Resources Code and Section 5097.98 of the Public Resources Code.

his list s only applicable for contacting local Native Americans with regard to cultural resources for the proposed SCH#2013111 071; CEQA Notice of Preparation (NOP); draft Environmental Impact Report (OEIR) for the Pado Basin Sediment Management Demonstration Project; located In the Prado Basin north of the City of Corona; Riverside County, Calllfornia.

SOBOBA BAND OF LUISENO INDIANS Joseph Ontiveros, Cultural Resource Department P.O. BOX 487 Luiseno San Jacinto , CA 92581 jontiveros@ soboba-nsn .gov (951) 663-5279 (951) 654-5544, ext 4137

This list Is current only as of the date of this document.

Native American Contacts Riverside County California

December 2, 2013

Distribution of this list does not relieve any person of the statutory responsibility as defined In Section 7050.5 of the Health and Safety Code, Section 5097.94 of the Public Resources Code and Section 5097.98 of the Public Resources Code.

his list s only applicable for contacting local Native Americans with regard to cultural resources tor the proposed SCH#2013111 071; CEQA Notice of Preparation (NOP); draft Environmental Impact Report (DEIR) tor the Pado Basin Sediment Management Demonstration Project; located In the Prado Basin north of the City of Corona; Riverside County, Calllfornla.

Yorba Linda Water District Reliable and Trusted Service tor More Than 100 Years

December 9, 2013

Orange County Water District 18700 Ward Street Fountain Valley, CA 92708 Attn.: Daniel Bott, Principal Planner

RE: Notice of Preparation of Environmental Impact Report - OCWD Prado Basin Sediment Management Demonstration Project

Mr. Bott:

Yorba Linda Water District (YLWD) staff reviewed the referenced Notice ofPreparation, and offers the following comments: Regarding sediment distribution into the Santa Ana River (SAR), in the EIR please elaborate on OCWD's criteria for defining "higher flow conditions" that will allow for sediment concentration levels less than or equal to 1 %. Please also confirm that the additional sediments discharged into the SAR will not significantly impact OCWD's operations.

YL WD has no additional comments.

Please call me at (714) 701-3106 if you have any questions or need additional information.

Sincerely,

~Jr\~ Anthony Manzano, P .E. Sr. Project Manager Yorba Linda Water District

cc: Steve Conklin

1717 E. Miraloma Avenue Placentia, CA 92870 714-701-3100 714-701-3108 Fax