55A - SAN LORENZO SEWER LIFT STATION

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EXHIBIT "A" In response to the comment on air quality, the increased "laydown space" associated with this alternative would not reduce the overall air quality emissions. An overlap of construction phases would actually increase daily emissions due to the intensification of construction activities; the SCAQMD measures air quality impacts based on daily emissions, therefore an overlap of construction phases would increase air quality impacts in relation to the proposed project. Additionally, the need to construct an additional 1,500 additional linear feet of sewer conveyance infrastructure would result in additional ground disturbance and require more construction equipment operation, thereby increasing air quality impacts in relation to the proposed project. Finally, with the exception of the five weeks during which Construction Configuration C.2 would be in place both for this alternative and the proposed project, the Draft FEIR does not identify any significant unavoidable impacts to transportation/traffic associated with the required traffic control. The purpose of identifying alternatives under CEQA is to "avoid or substantially lessen any of the significant effects of the project." This alternative site location does not serve that purpose. Section V.C.2 (Alternative Site 3) Responses to The Silverstein Law Firm's October 31, 2011 comments on Alternative Site No. 3's impacts to transportation/traffic and odors are included in the Draft FEIR (refer to Responses J -18 through J -23 of Section F.3.3, which are herein incorporated by reference). No revisions to these responses appear warranted based on the comments provided in the January 13, 2012 comment letter or the attachment from Mr. Dickson. Alternative Site No. 3 is not a feasible location for the new lift station. Aside from CEQA issues, there are social, economic, and safety issues associated with this site. The current land use includes doctor's offices, a Physical Therapy Center, an Orthopedic Clinic, a Prenatal Care Facility and "Orange County Health Care Agency" offices. Ingress and egress to this parking lot is already tight and many of the patients and patrons are handicapped or physically impaired drivers, pregnant women, or elderly. Construction of the Lift Station and associated pipelines through the parking lot would create significant confusion and safety issues for the public. Section V.C.3 (Alternative Site 5) Even if Table 5 -1 were revised to show a reduction in air quality and hydrology /water quality impacts in relation to the proposed project, Table 5 -1 would result in a score of "0" for Alternative 5, indicating that this alternative is environmentally equal, not superior, to the proposed project. However, it should be noted that according to the Project's engineering consultant (TetraTech), the reduction in construction schedule during Phase 2 would comprise only a maximum of two weeks. Furthermore, there may not be a reduction in time at all depending on the site specific issues that may be encountered at Alternative Site No. 5. The Draft FEIR has been revised to indicate a slight reduction in impacts to hydrology /water quality and air quality associated with this alternative, and Table 5 -1 has been revised to show that this alternative would have a score of "0." 55A -126