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HomeMy WebLinkAbout2019-055 - Approving the Water Supply Assessmentjmf 6/10/19 RESOLUTION NO. 2019-055 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA ANA APPROVING THE WATER SUPPLY ASSESSMENT FOR THE PROPOSED ELAN MIXED -USE PROJECT LOCATED AT 1660 EAST FIRST STREET WHEREAS, in accordance with California Water Code Sections 10912(a)(1) and 10912(a)(6), any development that is proposing a mixed -use project that includes a proposed residential development of more than 500 dwelling units requires the preparation and approval of a water supply assessment; and WHEREAS, the proposed Elan Mixed -Use Project located at 1660 East First Street is proposing development of a mixed -use project including 603 residential dwelling units; and WHEREAS, the proposed Elan Mixed -Use Project therefore requires the preparation and approval of a water supply assessment pursuant to California Water Code Sections 10910 and 10912; and WHEREAS, the City of Santa Ana is the public water system that currently supplies and will supply water to the proposed Elan Mixed -Use Project; and WHEREAS, the projected water demand associated with the proposed Elan Mixed -Use Project was accounted for in the City of Santa Ana 2015 Urban Water Management Plan; and WHEREAS, the Water Supply Assessment for the Elan Mixed -Use Project has been prepared; and WHEREAS, the findings from the Water Supply Assessment prepared for the Elan Mixed -Use Project show that there is sufficient water supply available for the proposed Elan Mixed -Used Project during normal, single -dry, and multiple dry years within a 20- year projection to meet the projected water demand of the Project in addition to the demand of existing and other planned future uses, including, but not limited to, agricultural and manufacturing uses. NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Santa Ana as follows: Section 1. The Water Supply Assessment for the Elan Mixed -Use Project is hereby approved, a copy of which is attached as Exhibit A and will be on file at the offices of the Public Works Agency of the City for public inspection. Resolution No. 2019-055 Page 1 of 4 Section 2. Approval of the Water Supply Assessment by the City does not constitute a "will -serve" or in any way entitles the Elan Mixed -Use Project to water service or to any right, priority or allocation in any supply, capacity or facility. Section 3. Approval of the Water Supply Assessment shall not affect the City of Santa Ana's obligation to provide service to its existing customers or any potential future customers, including this Elan Mixed -Use Project. Section 4. This Resolution shall take effect immediately upon its adoption by the City Council, and the Clerk of the Council shall attest to and certify the vote adopting this Resolution. ADOPTED this 2nd day of July, 2019. APPROVED AS TO FORM: Sonia R. Carvalho, City Attorney By:•1~42— J n M. Funk Assistant City Attorney AYES: Councilmembers NOES: Councilmembers ABSTAIN: Councilmembers NOT PRESENT: Councilmembers Ward 4 representative vacant. Resolution No. 2019-055 Page 2 of 4 ,_W_ .V .. Mayor Iglesias Penaloza Pulido Sarmiento, Solorio, Villegas (6) None (0) None (0) None (0) CERTIFICATION OF ATTESTATION AND ORIGINALITY I, NORMA MITRE, Acting Clerk of the Council, do hereby attest to and certify the attached Resolution No. 2019-055 to be the original resolution adopted by the City Council of the City of Santa Ana on July 2, 2019. Date: g oly Norma Mitre Acting Clerk of the Council City of Santa Ana Resolution No. 2019-055 Page 3 of 4 Refer to Laserfiche for Exhibit A: Water Supply Assessment for the Elan Mixed -Use Project Resolution No. 2019-055 Page 4 of 4 *20M`ING ENGINEERING WATER SUPPLY ASSESSMENT City of Santa Ana County of Orange, California Prepared For Santa Anna First Street, LLC 5120 Shoreham Place, #150 San Diego, CA 92122 858.535.1475 Prepared By Fuscoe Engineering, Inc. 16795 Von Korman, Suite 100 Irvine, California 92606 949.474.1960 www.fuscoe.com Project Manager: Josh Ruiz Date Prepared: November 2, 2017 CITY OF SANTA ANA Elan P WATER PPLY ASSESSMENT ORANGE COUNTY, CALIFORNIA PREPARED FOR: SANTA ANNA FIRST STREET, LLC 5120 Shoreham Place, #150 San Diego, CA 92122 858.535.1475 PREPARED BY: FUSCOE ENGINEERING, INC. 16795 Von Korman, Suite 100 Irvine, CA 92606 949.474.1960 www.fuscoe.com DATE PREPARED: NOVEMBER 2, 2017 ELAN PROJECT WATER SUPPLY ASSESSMENT TABLE OF CONTENTS NOVEMBER 2, 2017 1. WSA PURPOSE AND BACKGROUND ............................................ 4 2. INTRODUCTION 6 ..................................................................... 2.1 Project Description.............................................................................................6 2.1 .1 Existing Water Use......................................................................................8 2.1 .2 Proposed Water Use.................................................................................10 3. REGIONAL WATER SUPPLIES AND DEMANDS .............................. 12 3.1 City Water Supplies.........................................................................................12 3.2 City Water Demands.......................................................................................18 4. REGIONAL WATER SUPPLY RELIABILITY ...................................... 20 4.1 Metropolitan Water District regional water supply reliability.................................20 4.2 OCWD and City of Santa Ana Local Water supply reliability................................21 5. CONCLUSION 27 ..................................................................... 6. REFERENCES........................................................................28 7. TECHNICAL APPENDICES........................................................ 29 LIST OF FIGURES Figure1 Vicinity Map.......................................................................................................7 Figure 2 Existing Land Use Aerial......................................................................................9 Figure 3 Proposed Elan Site Plan....................................................................................I I FUSCOE ENGINEERING, INC. I ELAN PROJECT WATER SUPPLY ASSESSMENT LIST OF TABLES NOVEMBER 2. 2017 Table 1 Project Home Type Details...................................................................................6 Table 2 Existing Water Demands......................................................................................8 Table 3 Proposed Water Demands.................................................................................1 C Table 4 City of Santa Ana Connections to Metropolitan Facilities.......................................12 Table 5 2015 Projected and Actual Water Supply and Demand (Acre-feet).........................13 Table 6 City of Santa Ana Groundwater Production Data 2015-16...................................15 Table 7 City of Santa Ana Projected Total Water Demands...............................................19 Table 8 Metropolitan Multiple Climate Scenario Water Supply Capability and Projected Demands Comparison from 2020-2040 (AF)..................................................................21 Table 9 City of Santa Ana Multiple Climate Scenario Water Supply and Demand Comparison from2020-2040(AF)....................................................................................................23 Table 10 City of Santa Ana Ability to Supply the Elan Project.............................................25 LIST OF APPENDICES Appendix A — Proposed Project Water Demand Calculations Appendix B — City of Santa Ana Landscape Guidelines Appendix C — SGRMA Basin 8-1 Alternative Plan FUSCOE ENGINEERING, INC. ELAN PROJECT WATER SUPPLY Ass ESSMENT ACRONYMS & ABBREVIATIONS AF Acre -Feet AFY Acre -Feet per Year BEA Basin Equity Assessment BPP Basin Production Percentage CDR Center for Demographic Research CEQA California Environmental Quality Act cfs cubic feet per second CRA Colorado River Aqueduct DU Dwelling Unit DWR Department of Water Resources GPCD Gallons per Capita per Day gpd gallons per day GWRS Groundwater Replenishment System LTFP Long Term Facilities Plan M&I Municipal and Industrial MG Million Gallons OCWD Orange County Water District QSA Quantification Settlement Agreement RA Replenishment Assessment SANDAG San Diego Association of Governments SAR Santa Ana River SB Senate Bill SCAG Southern California Association of Governments SF Square Feet SWP State Water Project UWMP Urban Water Management Plan WSA Water Supply Assessment FUSCOE ENGINEERING, INC. NOVEMBER 2, 201 ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2, 2017 1 . WSA PURPOSE AND BACKGROUND This Water Supply Assess ment (WSA) was prepared for Santa Anna First Street, LLC as the project sponsor/applicant, and the City of Santa Ana ("City' or "Santa Ana") as the lead agency under the California Environmental Quality Act (CEQA), by Fuscoe Engineering, Inc. (Fuscoe), as the consultant, regarding the Elan Project ("Elan" or "Project"). This study is a requirement of California law, specifically Senate Bill 610 (referred to as SB 610). SB 610 is an act that amended Section 21 151 .9 of the Public Resources Code, and Sections 10631, 10656, 10910, 10911, 10912, and 10915 of the Water Code. SB 610 repealed Section 10913, and added and repealed Section 10657 of the Water Code. SB 610 was approved by the Governor and filed with the Secretary of State on October 9, 2001, and became effective January 1, 2002. Under SB 610, WSAs must be furnished to local governments for inclusion in environmental documentation for certain projects (as defined in Water Code 10912 [a]) subject to CEQA. Due to increased population, land use changes and water demands, this water bill seeks to improve the link between information on water availability and certain land use decisions made by cities and counties. SB 610 takes a significant step toward managing the demand of California's water supply as it provides regulations and incentives to preserve and protect future water needs. The intent of this bill is to coordinate local water supply and land use decisions to help provide California's cities, farms, and industrial developments with adequate water supplies. With the introduction of SB 610, any project under CEQA shall provide a WSA if the project meets the definition of the Water Code Section 10912. "Project" means any of the following: • A proposed residential development of more than 500 dwelling units. • A proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space. • A proposed commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space. • A proposed hotel or motel, or both, having more than 500 rooms. • A proposed industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 square feet of floor area. • A mixed -use project that includes one or more of the projects specified in this subdivision. • A project that would demand an amount of water equivalent to, or greater than, the amount of water required by a 500 dwelling unit project. • If a public water system has fewer than 5,000 service connections, then "project" means any proposed residential, business, commercial, hotel or motel, or industrial development that would account for an increase of 10 percent or more in the number of the public water system's existing service connections, or a mixed -use project that would demand an amount of water equivalent to, or greater than, the amount of water required by residential development that would represent an increase of 10 percent or more in the number of the public water system's existing service connections. After review of Water Code Section 10912, the Elan Project is deemed a "Project" because it proposes a residential development of more than 500 dwelling units. In addition, it is also necessary to include the recent passing (September 24, 2016) of Senate Bill 1262 (Chapter 594) which acts to amend Section 66473.7 of the Government Code, and FUSCOE tNGINEERING, INC. ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2, 2017 to amend Section 10910 of the Water Code, relating to land use' and the Sustainable Groundwater Management Act (SGMA) that was passed by California's Governor on September 16, 2014. Pursuant to SB 1262, as of January 1, 2017, WSAs are now required to include certain SGMA-related information if water supply for a proposed project includes groundwater. Specifically, if a water supply for a proposed project includes groundwater, the following additional information shall be included in the water supply assessment: • A description of any groundwater basin or basins from which the proposed project will be supplied. • For those basins for which a court or the board has adjudicated the rights to pump groundwater, a copy of the order or decree adopted by the courtor the board and a description of the amount of groundwater the public water system, or the city or county if either is required to comply with this part pursuant to subdivision (b), has the legal right to pump under the order or decree. • For a basin that has not been adjudicated that is a basin designated as high- or medium - priority pursuant to Section 10722.4, information regarding the following: o Whether the department has identified the basin as being subject to critical conditions of overdraft pursuant to Section 12924. o If a groundwater sustainability agency has adopted a groundwater sustainability plan or has an approved alternative, a copy of that alternative or plan. • For a basin that has not been adjudicated that is a basin designated as low- or very low priority pursuant to Section 10722.4, information as to whether the department has identified the basin or basins as overdrafted or has projected that the basin will become overdrafted if present management conditions continue, in the most current bulletin of the department that characterizes the condition of the groundwater basin, and a detailed description by the public water system, or the city or county if either is required to comply with this part pursuant to subdivision (b), of the efforts being undertaken in the basin or basins to eliminate the long-term overdraft condition. As described in more detail throughout this WSA, the proposed Project will utilize water from the Orange County Groundwater Basin that is designated as a medium priority basin. Therefore, additional information regarding groundwater supply and management will be included in this WSA to satisfy the requirements of SB 1262. ' Senate Bill No. 1262, CHAPTER 594, found here: hHp:Hleginfo.legislature.co.gov/faces/billTextClient.xhtml?bill id=201520160SB1262 FUSCOE ENGINEERING, INC. ELAN PROJECT WATER SUPPLY ASSESSMENT 2. INTRODUCTION 2.1 PROJECT DESCRIPTION NOVEMBER 2, 2017 The Elan Project is a 6.4-acre residential and commercial project located in the City of Santa Ana. The Project address is 1660 E. First Street, Santa Ana which is located north of E. Chestnut Avenue, south of E. First St, east of S. Lyon St and west of Elk Ln next to the Santo Ana Zoo. See Figure 1 for a vicinity map of the proposed Project. The proposed Project will replace an existing hotel (Elks Lodge) and associated surface parking lot. The northern portion of the Project is currently vacant. The Project includes the development of two buildings with 601 residential units comprised of 21 studios, 280 one -bedroom apartments, 256 two -bedroom apartments and 43 three - bedroom apartments. In addition, 9,519 sf of commercial space will be included that will provide a live/work opportunity for some of the one -bedroom apartments. The majority of the parking for the Project will be located within two (2) levels of subterranean parking structures located below the two residential structures. Amenities of the Project include fitness/yoga areas, an artist's gallery, a pet spa, courtyards and other lounging areas. Approximately 56,730 SF of publicly accessible open space is provided through common areas and courtyards. See Table 1 below for additional specifications related to the proposed Project. Table 1 Project Home Type Details Home Type YP Unit" Count Average Square Footage S Percentage of Total Unit Count parldng Studios 21 576 4% Parking Garage One -bedrooms 280 776 47% Parking Garage Two -bedrooms 256 1,078 43% Parking Garage Three -bedrooms 43 1,303 7% Parking Garage Total 601 935 100% Parking Garage Notes: As mentioned, the purpose of this WSA is to provide information to confirm that the City of Santa Ana has sufficient water supply to provide for the proposed Project in addition to other service area demands now and into the future. This WSA compares the existing water demand of the Project site to the proposed water demand of the Project and to the City of Santa Ana regional water supplies and demands through 2040. FuSCOE ENGINEERING, INC. •: � FBI �e 1.�IL y7� T'�1 J@ • Its • / I �..�� ••of Nf `� i 111111 • .' � R x• e � stir 5.�.. ■„ - - p rN VOL al '.t N 1 a I � Ttal! I p 1 Y �' i ! H 'W.t•' „per • �' t�i i -... i ai. _ _ S i• �a _a� �Jy �-�-.f gas "17 z � s ELAN PROJECT WATER SUPPLY ASSESSMENT 2.1.1 Existing Water Use NOVEMBER 2, 2017 As mentioned, the existing land use of the Project is vacant at the northern portion of the Project with an existing hotel and parking at the middle and southern portions. The Elks Lodge area in the center of the site covers a footprint of approximately 86,000 sf. The Elks Lodge structures cover approximately 50,000 SF and has approximately 20,000 SF of existing landscaping. See Figure 2 for an aerial image of the existing land uses at the proposed Project site. The water demand factors from the City of Santa Ana Design Guidelines for Water and Sewer Facilities (March 2017)2 were utilized to establish an estimate of existing water demands at the Project site. A commercial water demand factor of 2,500 gallons per day (gpd) per acre was employed to account for Elks Lodge at the existing Project site. In addition, a landscape water demand factor of 3,000 gpd/acre was employed for the scattered landscaping at the Project site. See Table 2 below for estimated existing water demands and the Project site. Table 2 Existing Water Demands 6dsNng Land Land Use Square band Use Water Demand Fodor ELdsting Water E)dsflng Water Use Footage Acreage (gpd acre) " Demand (gpd) Demand (AFY) Elks Lodge 50,000 1.15 2,500 2,875 3.22 Landscaped Area 20,000 0.46 3,000 635 0.71 Total 70,000 1.61 3,510 3.93 Notes: d gallons per day AFY acre-feet per year As shown above, the estimated existing water use at the Project site is approximately 3,510 gallons per day (gpd) or 3.9 acre-feet per year (AFY). An estimated annual difference between existing water demands and proposed water demands resulting from the proposed Project are calculated and shown in Section 2.1.2 below. 2 City of Santa Ana Design Guidelines for Water and Sewer Facilities (March 2017). Found here: htip://www.santo-ano.org/pwa/documents/DesignGuidelines.pdf FUSCOE ENGINEERING, INC. mw. !m4 r F. s P �'t A "_t���: �. I r I AClli iPK..�•:. .y r131 e A la a v ZE NO, ELAN PROJECT WATER SUPPLY ASSESSMENT 2.1.2 Proposed Water Use NOVEMBER 2, 2017 As mentioned, the proposed Project includes a total of 601 residential units comprised of 22 studios, 280 one -bedroom apartments, 256 two -bedroom apartments and 43 three -bedroom apartments. Amenities include fitness/yoga areas, an artist's gallery, a pet spa, courtyards and other lounging areas. In addition, 9,519 sf of commercial space will be included that will provide a live/work opportunity for some of the one -bedroom apartments. Approximately 56,730 SF of open space is provided through common areas and the court yards. See Figure 3 below for the proposed site plan for the Project. Total Project residential water demands include estimates of both indoor and outdoor water demands. Indoor water demands include toilet -flushing, showers, baths, dishwashers, washing machines, faucets, and leakage. Outdoor water demands include landscape irrigation estimates. The estimates for residential water demands were developed by following the City of Santa Ana Design Guidelines for Water and Sewer Facilities (March 2017). Table 3 Proposed Water Demands Land Use Unit Water Persons per DU Project DU Daily Water Usage Annual Type Demand' Assumption or acreage (gad) Water Usage Studios 120 gpd/capita 22 DU 3,353 3.8 One- bedrooms 120 ca gpd/capita 1 72 280 DU 57,792 64.7 Two- bedrooms 120 ca gpd/capita 2.89 256 DU 88,781 99.5 Three- bedrooms 120 gpd/capita 3.80 43 DU 19,608 21.0 Commercial 2,500 gpd/acre 9,519 sf (0.22 acres) 546 0.6 Landscaped 3,000 56,730 sf Areas gpd/acre (1.30 ac) 3,900 4.4 TOTAL PROJECT WATER DEMAND 601 RESIDENTIAL UNITS 173,984 glad 194.9 AFY Notes City of Santa Ana Design Guidelines for Water and Sewer Facilities (March 2017). 2 Modified US Census Assumptions — Utilized from Herita e Mixed Use Project in Santa Ana (July 2015 As shown, the proposed Project will have an annual water demand of approximately 195 AFY. This is an increase of approximately 191 AFY as compared to the existing water demands at the Project site. The following sections evaluates the ability for the City to meet the proposed increase in water demands. FUSCOE ENGINEERING, INC. 10 i� t I Iq 1 l- W Z 133HIS 1SHI3 I I 2 n e I � e e I 8 t I � 0 m I I C 3 0 0 • I h 9 ELAN PROJECT WATER SUPPLY A55ESSMENT NOVEMBER 2, 2017 3. REGIONAL WATER SUPPLIES AND DEMANDS 3.1 CITY WATER SUPPLIES The City's water supply comes from a combination of imported water, local groundwater and recycled water to satisfy water demands. The City purchases these water supplies from Metropolitan Water District of Southern California (Metropolitan) and the Orange County Water District (OCWD). The City is a member agency of Metropolitan and receives imported water from the State Water Project and the Colorado River under agreements with Metropolitan. OCWD manages the Orange County Groundwater Basin ("OC Basin" or "Basin") and provides groundwater resources to the City. The City maintains 444 miles of transmission and distribution mains, nine reservoirs with a storage capacity of 49.3 million gallons, seven pumping stations, 20 wells, and seven imported water connections. The seven imported water connections to the Metropolitan System are described in Table 4 below. Table 4 City of Santa Ana Connections to Metropolitan Facilities MWD Connection Name of Connection Normal Operating Ca ci MGD Design Capacity MGD SA-1 Bristol 5.17 6.46 SA-2 First 5.17 9.69 SA-3 McFadden 5.17 6.46 SA-4 Warner 4.85 6.46 SA-5 Alton 4.85 12.93 SA-6 Santa Clara 7.76 12.93 SA-7 Red Hill 4.85 32.31 From 2005-2015, Metropolitan delivered between 3,000 AF or 2.6 MGD (2015, lowest delivery) to 13,000 AF or 11.6 MGD (2005, highest delivery) to the City.' The design capacity of the Metropolitan connections is more than adequate to deliver imported to the City as shown in the table above. The City's Water Utility provides water service within a 27-square mile service area. The service area includes the City of Santa Ana and a small neighborhood in the City of Orange, near Tustin Avenue and Fairhaven by the northeast corner of Santa Ana. See Table 5 which shows the City's recent water supply to satisfy demands from 2015. 3 2015 Metropolitan UWMP. FUSCOE ENGINEERING, INC. 12 ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2, 201 Table 5 2015 Projected and Actual Water Supply and Demand (Acre-feet) Land Use Type YP 2010 UWMP Projected 2015 Demand Actual 2015 Demand Single Family 18,368 14,084 Multi -Family 13,563 10,399 Other (CII) 15,684 12,025 Landscape 185 147 Total 47,800 36,656 Notes: Source: 2010 and 2015 City of Santa Ana UWMPs As shown in Table 5 above, there was a decrease in water supplied to the City in 2015 as to what was predicted to be delivered in the 2010 UWMP (47,800 AF) by approximately 23%. This is likely due to Senate Bill (SB) x7.7 which requires the State of California to reduce urban water use by 20% by the year 2020 as described in more detail below. Similarly, the Executive Order mandated by California Governor Edmund Brown in April 2015 in response to the recent drought further required a collective reduction in statewide urban water use of 25%which would also reduce Citywide demands. In addition, UWMPs are typically developed in a conservative manner and tend to overestimate future water demands. Currently, 71% of the City's water supply is from OC Basin groundwater, 28% is from Metropolitan imported water and 1 % is from recycled water. The City's water supply portfolio is expected to change slightly to 70% from OC Basin groundwater, 29% from Metropolitan imported water, and 0.7% recycled water by the year 2040 as discussed in more detail throughout this WSA. Additional details on the strategic management of these resources is explained below. OCWD Groundwater The primary source of water for the City is the Orange County Groundwater Basin ("OC Basin") which is managed by the Orange County Water District (OCWD). The OC Basin underlies the north half of Orange County beneath broad lowlands. The OC Basin covers an area of approximately 350 square miles, bordered by the Coyote and Chino Hills to the north, the Santa Ana Mountains to the northeast, the Pacific Ocean to the southwest, and terminates at the Orange County line to the northwest, where its aquifer systems continue into the Central Basin of Los Angeles County. The OC Basin storage capacity is estimated to be 66 million AF^, of which only a fraction is available for use to prevent against physical damage to the Basin such as seawater intrusion or land subsidence. To ensure the Basin is not overdrawn, OCWD recharges the Basin with local and imported water. The Basin is recharged primarily by four sources including local rainfall, storm and base flows from the Santa Ana River ISAR), purchased Metropolitan imported water; and highly treated recycled wastewater. Basin recharge occurs largely in the following recharge basins that are located in or adjacent to the City of Anaheim: Warner Basin: A 50-foot-deep recharge basin located next to the SAR at the intersection of the 55 and 91 freeways; 4 OCWD Groundwater Management Plan 2015 Update. June 17, 2015. FUSCOE ENGINEERING, INC. 13 ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2, 2017 Burris Basin: Located between Lincoln Avenue and Ball Road in the City of Anaheim; Kraemer Basin: Located adjacent to Burris Pit; Santiago Creek: Located in the City of Orange between Villa Park Road and E. Bond Avenue. As mentioned above, SB 1262 amended Section 10910 of the Water Code and requires the inclusion of SGMA-related information in WSAs. Specifically, following the SGMA basin prioritization and designations', for a non -adjudicated basin that is designated as high- or medium -priority pursuant to Section 10722.4, information regarding the following must be included: • Whether the department has identified the basin as being subject to critical conditions of overdraft pursuant to Section 12924. • If a groundwater sustainability agency has adopted a groundwater sustainability plan or has an approved alternative, a copy of that alternative or plan. The OC Basin (also referred to as Basin 8-1) has been designated as a medium -priority basin which requires this WSA to address or include information regarding the bullets above. As mentioned, SGMA provides authority for agencies like OCWD to develop and implement Groundwater Sustainability Plans or alternative plans ("Alternatives') that demonstrate the basin has operated within its sustainable yield over a period of at least 10 years. OCWD decided to submit an Alternative for evaluation by the California Department of Water Resources (DWR). An Alternative is required to be submitted to DWR for review no later than January 1, 2017, and every 5 years thereafter. In general, Alternatives must be consistentwith one of the following (Water Code §10733.6(b)): A plan developed pursuant to Part 2.75 (commencing with Section 10750) or other law authorizing groundwater management. Management pursuant to an adjudication action. An analysis of basin conditions that derronstrates that the basin has operated within its sustainable yield over, a period of at least 10 years. The submission of an alternative described by this paragraph shall include a report prepared by a registered professional engineer or geologist who is licensed by the state and submitted under that engineer's or geologist's seal. OCWD prepared an Alternative that satisfies the third bullet point above to prove the OC Basin has operated within its sustainable yield over a period of at least 10 years. The Basin 8-1 Alternative is included in Appendix C of this WSA. The Alternative states that Basin 8-1 has operated within its sustainable yield for more than 10 years without experiencing significant and unreasonable (1) lowering of groundwater levels, (2) reduction in storage, (3) water quality degradation, (4) seawater intrusion, (5) inelastic land subsidence, or (6) depletions of interconnected surface water that have significant and unreasonable adverse impacts on beneficial uses of the surface water. In addition, Basin 8-1 has not been in conditions of critical overdraft. DWR has one year to evaluate the Basin 8-1 Alterative. The paragraphs below will s SGMA Groundwater Information Center Interactive Map Application, found here: hffps:Hgis.water.ca.gov/app/gicima/ h USCOE ENGINEERING, INC. 14 ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2. 2017 further explain how OCWD successfully manages the OC Basin to meet these new groundwater monitoring and management requirements. OCWD manages the Basin through the Basin Production Percentage (BPP) which is determined each water year. The BPP is set based on groundwater conditions, availability of imported water supplies, water year precipitation, SAR runoff, and basin management objectives. The BPP represents an established percentage identifying the amount of groundwater all pumpers in the Basin can pump without paying a "pumping tax' or Basin Equity Assessment (BEA) to OCWD. For example, if the BPP is set to 75%, all pumpers within the Basin, including the City, can supply 75% of their water needs from groundwater supplies at a cost significantly less than the cost of imported water. If groundwater production is equal to or less than the BPP (i.e. less than 75% in the example above), all producers within the Basin pay a replenishment assessment (RA) fee which is used to fund groundwater replenishment and recharge programs aimed at ensuring the long-term viability and stability of the Basin. If groundwater production is greater than the established BPP for that water year (i.e. greater than 75% in the example above), the BEA is determined for the producer of that amount of groundwater provided in excess of the BPP. The BEA is an additional fee paid on each AF of water pumped above the BPP, making the total cost of that additional water equal to the higher cost of imported water from Metropolitan. According to OCWD's Engineer's Report for fiscal year 2015/16, the actual BPP was 75% as shown in Table 6 below. Total water demands within OCWD were 367,402 AF for the water year (July 1, 2015 to June 30, 2016). This is tie lowest figure for total water demands since 1982 which was caused by the State of California's emergency drought regulations. Groundwater production for the water year totaled 277,090 AF including any available In -Lieu Program water and excluding Metropolitan Groundwater Storage Program extractions. A total of 47,524 AF of supplemental water was used for the purpose of groundwater replenishment and barrier maintenance. For the water year, the "annual overdraft" (annual basin storage decrease without supplemental replenishment water) was 141,000 AF. The accumulated overdraft decreased from 381,000 AF on June 30, 2015 to 379,000 AF on June 30, 2016. Precipitation within the Basin was 62% of normal rainfall during the water year, totaling 8.40 inches .6 The table below shows the water production data from 2015/16 for the City of Santa Ana. Table 6 City of Santa Ana Groundwater Produdion Data 2015-76 Groundwater Supplemental Water(AF) (AF) Actual Groundwater BPP Producer Non- Metropolitan Irrigation Total Conservation Delivery Total Grand Non - Irrigation CUP Pumping Credit Total Only City of Santa Ana 29,629 4,524 24,745 8,183 83 8,266 33,012 75.0% Source: OCWD 2015-16 Engineer's Report Over the recent past, production capability of the Basin has increased as a result of increased wastewater reclamation at the Groundwater Replenishment System (GWRS) located in Fountain Valley. The GWRS, which is designed to turn wastewater into drinking water, is one of the most n OCWD. Engineer's Report, 2015/16, February 2017. FUSCOE ENGINEERING, INC. 15 ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2, 2017 technologically advanced wastewater treatment plants in the world. Atreatment plant expansion of 30 million gallons per day was recently put on line by OCWD increasing the recharge capacity of the GWRS to 100 million gallons per day. This equates to the recycling of over 1 10,000 AFY of wastewater back into the Basin for future extraction and potable use. A final expansion of the treatment system is being designed to have a capacity of 130 million gallons per day. Expansion projects to the GWRS increase local water supply reliability and ensure low- cost water supplies throughout northern Orange County, including the City of Santa Ana. Metropolitan Imported Water The City of Santa Ana is one of only three retail member agencies of Metropolitan in Orange County. As a member agency, pursuant to the Metropolitan Act, the City has preferential rights to a certain percentage of water delivered to Metropolitan each year primarily from the State Water Project and/or the Colorado River Aqueduct as well as other Metropolitan storage programs. Being a member agency of Metropolitan puts the City in a better position relative to receiving water directly from Metropolitan, as opposed to other agencies in Orange County which obtain their imported Metropolitan water through Municipal Water District of Orange County (MWDOC). The main sources of water Metropolitan provides to the City include water from northern California delivered via the State Water Project (SWP) and water from the Colorado River Basin delivered via the Colorado River Aqueduct. More details on these sources of imported water are explained below. Colorado River The Colorado River was Metropolitan's original source of water after Metropolitan's establishment in 1928. Lake Mead and Lake Powell, the two largest reservoirs in the United States, can store 4 times the annual flow of the Colorado River. River flows are primarily generated from snowpack in the Rocky Mountains. Colorado River water is allocated and delivered to seven states in the US including Colorado, Utah, Wyoming, New Mexico, Arizona, Nevada and California. Mexico also has an allocation of 1.5 million acre-feet (MAF) along the Colorado River each year. California's urban water allocation is managed by Metropolitan and imported from the Colorado River via the Colorado River Aqueduct (CRA) which is stored at Diamond Valley Lake and Lake Mathews in Riverside County. The CRA includes supplies from the implementation of the Quantification Settlement Agreement (QSA) and related agreements to transfer water from agricultural agencies in Imperial County to urban uses throughout Southern California including Los Angeles, Orange County and San Diego. The 2003 QSA enabled California to implement major Colorado River water conservation and transfer programs, stabilizing water supplies for 75 years and reducing the state's demand on the river to its 4.4 MAF entitlement. Colorado River transactions are potentially available to supply additional water up to the CRA capacity of 1.25 MAF on an as -needed basis. California is apportioned the largest allocation on the River of 4.4 MAF of water from the Colorado River each year plus one-half of any surplus that may be available for use collectively in Arizona, California, and Nevada. In addition, California has historically been allowed to use Colorado River water apportioned to but not used by Arizona or Nevada. Metropolitan has a basic entitlement of 550,000 AFY of Colorado River water, plus surplus water up to an additional 662,000 AFY if certain conditions exist. The remainder of California's allocation FUSCOE ENGINEERING, INC. 16 ELAN PROJECT WATER SUPPLY AsSESSMENT NOVEMBER 2, 2017 goes to Imperial County, primarily to the Imperial Irrigation District, and is used mainly for agriculture production. Over the past 16 years (2000-2015), there have only been three years when the Colorado River flow has been above average.' The long-term imbalance in future supply and demand is projected to be approximately 3.2 MAF by the year 2060. Actions are currently being taken and planned in the future to resolve the imbalance between water supply and demand in areas that use Colorado River water. Such actions include the resolution of uncertainties related to water conservation, reuse, water banking, and weather modification concepts.' State Water Proiect The State Water Project (SWP) collects water from rivers in Northern California and redistributes it to the water -scarce but populous central and southern portions of California through a network of aqueducts, pumping stations and power plants. Approximately 70% of the water provided by the SWP is used for urban areas and industry in Southern California and the San Francisco Bay Area, and 30% is used for irrigation in the Central Valley. The availability of water supplies from the SWP can be highly variable. A wet water year may be followed by a dry water year which restricts the amount of water that can be delivered throughout California. Metropolitan's SWP imported water is stored at Castaic Lake on the western side of Metropolitan's service area and at Silverwood Lake near San Bernardino, as well as in Diamond Valley Lake. The Sacramento -San Joaquin River Delta (Delta) is key to the SWP's ability to deliver water to its agricultural and urban contractors. The Delta faces many challenges concerning its long- term sustainability such as climate change posing a threat of increased variability in floods and droughts. Sea level rise complicates efforts in managing salinity levels and preserving water quality in the Delta to ensure a suitable water supply for urban and agricultural use. Furthermore, other challenges include continued subsidence of Delta islands, many of which are below sea level, and the related threat of a catastrophic levee failure as the water pressure increases, or as a result of a major seismic event. Metropolitan's Board approved a Delta Action Plan in June 2007 that provides a framework for staff to pursue actions with other agencies and stakeholders to build a sustainable Delta and reduce conflicts between water supply conveyance and the environment. The Delta action plan aims to prioritize immediate short-term actions to stabilize the Delta while an ultimate solution is selected, and mid-term steps to maintain the Delta while a long-term solution is implemented. Currently, Metropolitan is working towards addressing three basic elements: Delta ecosystem restoration, water supply conveyance, and flood control protection and storage development. In April 2015, the Brown Administration announced California WaterFix, as well as a separate ecosystem restoration effort called California EcoRestore. Together, the California WaterFix and California EcoRestore will make significant contributions toward achieving the coequal goals of providing a more reliable water supply for California and protecting, restoring, and enhancing the Delta ecosystem. The WaterFix is aimed at making physical and operational improvements to the SWP system in the Delta necessary to restore and protect ecosystem health, 2015 Metropolitan UWMP. s 2012 USBR Colorado River Basin Water Supply and Demand Study. FUSCOE ENGINEERING, INC. 17 ELAN PROJECT WATER SUPPLY AsSESSMENT NOVEMBER 2, 2017 south -of -Delta SWP water supplies, and water quality. The WaterFix includes the construction of two tunnels up to 150 feet below ground and three new intakes, each with 3,000 cubic -feet per second (cfs) capacity and an average annual yield of 4.9 million acre-feet designed to protect California's water supplies. These proposed upgrades would provide protection against water supply disruption from failure of aging levees due to sea -level rise, earthquakes and flood events. Recycled Water The City depends on OCWD for its recycled water supply for non -potable uses such as irrigation. OCWD provided 352 AF of recycled water to the City of Santa Ana in 2015 as part of the Green Acres Project (GAP). OCWD owns and operates the GAP, a water recycling system that provides up to 8,400 AFY of recycled water as an alternate source of water that is mainly delivered to parks, golf courses, greenbelts, cemeteries, and nurseries in the cities of Costa Mesa, Fountain Valley, Newport Beach, in addition to Santa Ana. The City maintains an agreement with OCWD to supply GAP water to customers where available. It is anticipated that recycled water supplied to the City will maintain around 300 AFY through 2040. 3.2 CITY WATER DEMANDS The City's Water Utility provides water service within a 27-square mile service area to a population of approximately 335,299 as of 201 V . The City is almost completely built -out and its population is projected to increase only 0.9% by 2040. Approximately 67% of the City's water demand is residential including single family and multi -family residential units. Commercial land uses, including dedicated landscape, accounts for the remaining 33% of the total demand. The 2015 UWMP highlighted that water demands throughout the City were 36,656 AF from July 2014 to June 2015. The 2010 UWMP anticipated water demands in 2015 to be much larger at 47,800 AF. As mentioned, the difference -is likely because of the mandatory water restrictions from the Governor's Executive Order and the fact that UWMPs are typically developed in a conservative manner and tend to overestimate future water demands. In April 2015 Governor Brown issued an Executive Order as a result of one of the most severe droughts in California's history, requiring a collective reduction in statewide urban water use of 25% by February 2016, with each agency in the state given a specific reduction target by DWR. In response to the Governor's mandate, the City began to track its water wasting prohibition enforcement activities. On June 2, 2015, the City declared a Phase 2 water supply shortage in Resolution No. 2015-025 by formally requiring all water consumers to reduce use by 12% relative to their 2013 consumption. Additionally, on August 4, 2015, a water wasting penalty rate was established by Resolution No. 2015-047. This new penalty rate permits City staff to penalize those users not meeting their water use reduction targets of 12%. The City of Santa Ana as a whole met its State mandated target; as a result the City did not have to impose any monetary penalties on any of its users. As of April 7, 2017, Governor Brown ended the drought State of Emergency in most of California, while maintaining water reporting requirements and prohibitions on wasteful 9 Center of Demographics Research (CDR) at California State University, Fullerton FUSCOE ENGINEERING, INC. 18 ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2, 2017 practices such as watering during or right after rainfall.70 The City continues to promote water use efficiency and currently has a goal to continue to reduce water demands by 3% compared to 2013 consumption. In addition, the City only allows outdoor watering to every other day or Monday, Thursday, and Saturday and only between the hours of 6 PM and 6 AM." Such restrictions have significantly reduced water demands throughout California. In addition to these mandated restrictions, cities must follow the Water Conservation Act of 2009, also known as Senate Bill (SB) x7-7. This law required the State of California to reduce urban water use by 20% by the year 2020. The City must determine baseline water use during their baseline period and water use targets for the years 2015 and 2020 to meet the state's water reduction goal. The City's 2015 target was 123 gallons per capita per day (GPCD) and the 2020 target is 116 GPCD. The 2015 UWMP reported that the City has already met both the 2015 and 2020 water use targets with an actual use in 2015 of 83 GPCD. This is likely due to increased conservation as required by the Governor's Executive Order during severe drought conditions throughout California. The City's water demand has been decreasing in recent years due to the combination of the Governor's Executive Order and SBx7-7 goals. The City's water demands are then expected to increase by approximately 8%from 2015 to 2040 as shown in the table below. Table 7 City of Santa Ana Projected Total Water Demands `lJnd TVs Demand 2015 2020 2025 2030 2035 2040 Potable and Raw Water 36,656 36,678 39,397 39,669 39,658 39,716 Recycled Water 352 320 320 320 320 320 Total Water Demand 37,008 36,998 39,717 39,989 39,978 40,036 Source: 2015 City of Santa Ana UWMP As shown above, it is projected that water demands will increase from 37,008 AF in 2015 to 40,036 AF in year 2040. These estimates are approximately 10,000 AF less than what was predicted in the 2010 UWMP further highlighting the conservative nature of UWMP preparation. The 2015 Metropolitan UWMP stated that Metropolitan would be able to meet the demands of its member agencies, including the City of Santa Ana, through 2040. Therefore, imported water demands for the City are projected to be met through the 20-year requirements of SB 610 and beyond. The City of Santa Ana 2015 UWMP also confirmed the ability of the local supplies and the OC Basin to meet the growing demands of the City. The ability for the City to meet these growing demands in multiple climate scenarios is explained in the sections below. 10 SWRCB Water Conservation Portal — Emergency Conservation Regulation, accessed on 09/06/2017. Found here: http://www.waterboards.Co.gov/wafer_issues/procrams/conservation_portal/emergency_regulation.shtml City of Santa Ana — Water Conservation Website, accessed 09/06/2017. Found here: http://www.cl.santa- ano.ca.us/waterconsoNation/ FUSCOE ENGINEERING, INC. 19 ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2, 2017 4. REGIONAL WATER SUPPLY RELIABILITY The City of Santa Ana currently depends on Metropolitan and OCWD to provide the majority of its water supply. This section provides a description of the ability of Metropolitan, OCWD and the City to ensure that adequate water supplies will be available to satisfy the City's growing water demands including the proposed Project through 2040 during normal, single dry year and multiply dry year scenarios. 4.1 METROPOLITAN WATER DISTRICT REGIONAL WATER SUPPLY RELIABILITY Metropolitan's 2015 Urban Water Management Plan (UWMP) was finalized in June 2016 and has been prepared in compliance with Water Code Sections 10608.36 of SB X7-7 and Sections 10610 through 10656 of the Urban Water Management Planning Act (Act). The information included in the 2015 UWMP represents the most current and available planning projections of supply capability and demand developed through a collaborative process with the member agencies, including the City of Sana Ana. The Act requires reporting agencies to describe their water reliability under a single dry -year, multiple dry -year, and average year conditions, with projected information in five-year increments for 20 years. Metropolitan updates its retail municipal and industrial (M&I) projection periodically based on the release of official regional demographic and economic projections. The projections of retail M&I water demands used in the 2015 UWMP are based on data from the Southern California Association of Governments (SCAG) 2012 Regional Transportation Plan/Sustainable Community Strategy (April 2012) and the San Diego Association of Governments (SANDAG) Series 13: 2050 Regional Growth Forecast (October 2013). The projected regional water demand is adjusted to account for water conserved by Best Management Practices from active, code -based, and price -effect conservation. Supply analysis includes Colorado River supplies, SWP supplies and existing and proposed storage programs through Metropolitan's service area. Colorado River Aqueduct (CRA) supplies include supplies that would result from existing and committed programs and from implementation of the Quantification Settlement Agreement (QSA) and related agreements. State Water Project (SWP) supplies are estimated using the 2015 SWP Delivery Capability Report distributed by DWR in July 2015. In regards to storage, Metropolitan assumed 2015 storage levels at the start of simulation and used the median storage levels going into each of the five- year increments based on the balances of supplies and demands. See Table 8 below showing Metropolitan's ability to meet growing demands in normal, single -dry and multiple -dry year climate scenarios. FUSCOE ENGINEERING, INC. 20 ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2, 2017 Table 8 Metropolitan Multiple Climate Scenario Water Supply Capability and Projected Demands Comparison from 2020-2040 (AF) Forecast Year 2020 2035 2Q30 2035 2040 Normal Year Capability of Current Supply 3,448,000 3,550,000 3,658,000 3,788,000 3,824,000 Total Demands 1,860,000 1,918,000 1,959,000 2,008,000 2,047,000 Supply Programs Under Development 63,000 100,000 386,000 428,000 468,000 Total Potential Surplus 1,651,000 1,732,000 2,085,000 2,208,000 2,245,000 Single -:Dry Year Capability of Current Supply 2,584,000 2,6 66,000 2,775,000 2,905,000 2,941,000 Total Demands 2,005,000 2,066,000 2,108,000 2,160,000 2,201,000 Supply Programs Under Development 63,000 100,000 316,000 358,000 398,000 Total Potential Surplus 642,000 720,000 983,000 1,703,000 1,138,000 Multiple -Dry Year Capability of Current Supply 2,103,000 2,154,000 2,190,000 2,242,000 2,260,000 Total Demands 2,001,000 2,118,000 2,171,000 2,216,000 2,258,000 Supply Programs Under Development 43,000 80,000 204,000 245,000 286,000 Total Potential Surplus 145,000 116,000 223,000 271,000 288,000 Source: 2015 Metropolitan UWMP The findings of the 2015 Metropolitan UWMP highlight that Metropolitan has supply capabilities that would be sufficient to meet expected demands from 2020 through 2040 under the normal, single dry -year and multiple dry -year conditions. Metropolitan also has proposed programs in place to ensure against water shortages in the future. These programs include projects along the California Aqueduct and the Colorado River Aqueduct in addition to demand reduction projects. In all climate scenarios, Metropolitan estimates potential surpluses in water supply through 2040. The Metropolitan 2015 UWMP was made public in early 2016 and shared with Metropolitan's member agencies. Once these findings were finalized, the Metropolitan member agencies could conclude their own 2015 UWMP findings. The City of Santa Ana published their 2015 UWMP in April 2016 after determining Metropolitan would be able to meet the City's imported water demands through 2040. The City of Santa Ana and OCWD local water supply reliability is summarized below. 4.2 OCWD AND CITY OF SANTA ANA LOCAL WATER SUPPLY RELIABILITY Like Metropolitan, the City of Santa Ana is also required to assess the reliability of their water service to its customers under normal, single -dry and multiple -dry water years. As mentioned the City depends on a combination of imported water from Metropolitan and local groundwater supplies from OCWD to meet its water demands. The City has taken numerous steps to ensure it has adequate supplies to provide for growing demands. FUSCOE ENGINEERING, INC. 21 ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2, 2017 The City has several water demand reduction requirements and resources on their website that informs its customers on how to save water. Some of the main requirements are summarized below: Residential o Mandatory 3% reduction in water use compared to usage during the some billing period in 2013. o Outdoor watering is restricted to no more than every other day or Mondays, Thursdays and Saturdays, and only between the hours of 6 p.m. and 6 a.m.* o Leaks must be repaired within 48 hours of notification by the City. o No washing down sidewalks or driveways. o No excessive water flow or runoff that causes water to flow onto an adjoining sidewalk, driveway, street, alley, gutter or ditch. o No washing vehicles with a hose, unless the hose is fitted with a shut-off nozzle. o No operating a fountain or decorative water feature, unless the water is part of a recirculating system. o No outdoor watering during and 48 hours following measurable rainfall. • Businesses o Restaurants, cafes and bars can only serve water to customers on request. o Hotels and motels must prominently display a notice providing guests with the option of choosing not to have towels and linens laundered daily. In addition, landscape policies have also been modified to allow drought tolerate landscape throughout the City (see Appendix B). These programs have been successful in reducing water demands throughout the City's service area. OCWD is also taking strides to ensure local water supplies will meet growing demands now and into the future. As mentioned, OCWD manages the City's groundwater supply and the entire OC Basin utilizing the BPP approach. In 2013, OCWD's Board of Directors adopted a policy to establish a stable BPP with the intention to work toward achieving and maintaining a 75 percent BPP by FY 2015-16. Although BPP is set at 75 percent, based on discussions with OCWD a conservative BPP of 70 percent is assumed through 2040 for supply projection analysis in the City's 2015 UWMP. Principles of this policy include: OCWD's goal is to achieve a stable 75 percent BPP, while maintaining the some process of setting the BPP on an annual basis (BPP will be set in April of each year after a public hearing has been held and based upon the public hearing testimony, presented data, and reports provided at that time). OCWD's transition to the 75 percent BPP was due to construction of the GWRS Initial Expansion Project, which was completed in 2015. This expansion provided an additional 31,000 AFY of water for recharging the groundwater basin. OCWD must manage the OC Basin in a sustainable manner for future generations. The BPP will be reduced if future conditions warrant the change. FUSCOE ENGINEERING, INC. 22 ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2, 2017 • Each project and program to achieve the 75 percent BPP goal will be reviewed individually and assessed for their economic viability. The BPP goals mentioned above coincide with other management strategies as shown in OCWD's Long Term Facilities Plan (LTFP), the 2015 Groundwater Management Plan and the 2020 Water Master Plan Report. These documents highlight OCWD's plans to ensure groundwater supply will be available into the future to support growing demands of its service area. As shown in Table 9 below, the City's available supply, including OCWD groundwater and Metropolitan imported water, will meet projected demand during normal, single dry and multiple dry years. For the City's 2015 UWMP, the normal dry year was selected as the City's 2015 demand. A single -dry year is defined as a single year of no to minimal rainfall within a period that average precipitation is expected to occur. The City has documented that it is 100% reliable for single dry year demands from 2020 through 2040 with a demand increase of 6% using FY 2013-14 as the single dry -year. Multiple -dry years are defined as three or more years with minimal rainfall within a period of average precipitation. The City is capable of meeting all customers' demands with significant reserves held by Metropolitan, local groundwater supplies, and conservation in multiple dry years from 2020 through 2040 with a demand increase of 6% using FY 201 1-12 through FY 2013-14 as the driest years. Table 9 City of Santa Ana Multiple Climate Scenario Water Supply and Demand Comparison from 2020-2040 (AF) Forecast Year 12020 2 225 12030 12035 12040 Normal Year Supply totals 36,998 39,717 39,989 39,978 40,036 Demand totals 36,998 39,717 39,989 39,978 40,036 Single -Dry Year Supply totals 39,278 42,100 42,388 42,377 42,438 Demand totals 39,218 142,100 42,388 42,377 42,438 Multiple -Dry Year First year Supply totals 39,218 42,100 42,388 42,377 42,438 Demand totals 39,218 42,100 42,388 42,377 42,438 Second year Supply totals 39,218 42,100 42,388 42,377 42,438 Demand totals 39,218 42,100 42,388 42,377 42,438 Third year Supply totals 39,218 42,100 42,388 42,377 42,438 Demand totals 39,218 42,100 42,388 42,377 42,438 Source: 2015 City of Santa Ana UWMP FUSCOE ENGINEERING, INC. 23 ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2, 201 As shown in Table 9 above, in all climate scenarios analyzed in the 2015 UWMP, available water supplies are projected to meet demands. Reliability of local water supplies will be ensured through continued implementation of the OCWD Groundwater Management Plan, OCWD's LTFP, and the combined efforts and programs among member agencies of Metropolitan. The City closely monitors development throughout the City to ensure water supplies will meet growing demand. The City has a log of all developments that have required a WSA and track the increases in water demands from these projects. As shown in Table 10 below, the City is able to provide water supply to satisfy growing City demands including the Elan Project. FUSCOE ENGINEERING, INC. 24 $ / L ±» k \\\�cl § \ d \\\§} d / d (lc� ® ! } # / � I ƒ I CO C_ 0 % 9 } <` i \ !��}}\�\\\}}\\\ƒ \/() 0a°� %§7E�@■-j\ ,}}/ $�/E0 \\)))e:-2J? { ;»{0w ~-t; §!§§(■��)E�`cc 22\\\\/ $3)20 )))))�3\)> ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2, 2017 As shown above, a small deficit of 329 AF (less than 1 % of total demands) is projected for the year 2020. These demand/supply numbers come from projections calculated within the City's UWMP. As mentioned throughout this WSA, UWMPs are conservative in nature and tend to overpredict demand. For example, there was a 23% decrease in water use in the City in 2015 as to what was predicted to be used in the 2010 UWMP for the year 2015. Therefore, the deficits shown in Table 10 above during the year 2020 will likely not occur due to the significant decreases in demand as seen over the past several years. From 2025-2040, surplus supply of approximately 2,000 AF is anticipated as well. As confirmed by the City's Water Utility department, the deficit is not anticipated to be an issue for the Project or the City.72 The findings of the Metropolitan 2015 UWMP and the City of Santa Ana 2015 UWMP confirm that the City of Santa Ana will be able to supply water to growing demands within its service area including the proposed Project through 2040 which satisfies the requirements of SB 610. 12 Personal communication with City's Water Utility department on 10/02/201 7. FUSCOE ENGINEERING, INC. 26 ELAN PROJECT WATER SUPPLY ASSESSMENT 5. CONCLUSION NOVEMBER 2, 2017 The City of Santa Ana depends on local and regional water supplies from OCWD and Metropolitan to satisfy growing demands. OCWD has managed the OC Basin for over 75 years and has plans to sustainably manage the groundwater system through 2040 under the new California SGMA policies and guidelines. Metropolitan has stated in its 2015 UWMP that its water supply portfolio will be able to satisfy regional growth and water demands through 2040. The same findings were concluded in the City of Santa Ana 2015 UWMP as both Metropolitan and OCWD supplies are projected to meet future water demands. The 2015 City UWMP projected that water demands would grow from 37,008 AF in 2015 to 40,036 AF in 2040. Over the past several years, actual demands decreased substantially to due to local conservation and regional drought management regulations. Therefore, like most UWMPs, the 2015 City UWMP is conservative with projections of water supplies needed to satisfy demands through 2040. The 2015 UWMP incorporates regional growth projections from CDR in order to determine future water demands. Projects like Elan are included in these regional projections of future population growth and are tracked by the City. The proposed Project will demand approximately 195 AF per year (an increase of approximately 191 AF per year as compared to existing water demands) which is well within the planned water supplies needed in the future in the City of Santa Ana. Therefore, this WSA is able to conclude adequate supplies are available to provide for the demands of the proposed Project as well as other service area demands within the City of Santa Ana. FUSCOE ENGINEERING, INC. 27 ELAN PROJECT WATER SUPPLY ASSESSMENT NOVEMBER 2, 2017 G. REFERENCES 2012 USBR Colorado River Basin Water Supply and Demand Study 2015 Metropolitan of Southern California Urban Water Management Plan Center of Demographics Research (CDR) at California State University, Fullerton City of Santa Ana — Water Conservation Website, accessed 09/06/2017. Found here: httr)://www.ci.santo-ana.ca.us/waterconservation/ City of Santa Ana Design Guidelines for Water and Sewer Facilities (March 2017). Found here: http://www.sonto-ana.org/pwa/documents/DesignGuidelines.pdf OCWD Groundwater Management Plan 2015 Update. June 17, 2015 OCWD. Engineers Report, 2015/16, February 2017 Senate Bill No. 1262, CHAPTER594, found here: http://Iegi nfo.legislature.co.gov/faces/billTextClient.xhtml? bill_id'-201520160SB 126 SGMA Groundwater Information Center Interactive Map Application, found here: hffps:Hgis.water.ca.gov/app/gicima/ SWRCB Water Conservation Portal — Emergency Conservation Regulation, accessed on 09/06/2017. Found here: http://www.waterboa rds.ca.gov/water_issues/programs/conservation_portal/em ergen cy_regulation.shtml FUSCOE ENGINEERING, INC. 28 ELAN PROJECT WATER SUPPLY ASSESSMENT 7. TECHNICAL APPENDICES Appendix A— Proposed Project Water Demand Calculations Appendix B — Landscape Water Efficiency Ordinance No. 6355 Appendix C — SGMA Basin 8-1 Alternative Plan NOVEMBER 2, 2017 PUSCOE ENGINEERING, INC. 29 ELAN PROJECT WATER SUPPLY ASSESSMENT APPENDIX A NOVEMBER 2, 201 PROPOSED PROJECT WATER DEMAND CALCULATIONS EUSCOE ENGINEERING, INC. 30 ƒ 2< \ k 2 \ \ N % J \ \« 00 ol CO \ \ co \ / \ ) \ ,£ ° E \ \ § \ a g 10 co co v ^ ° ° \ ){ §� \ ) ° 14) E § 00 {7 } - � \ }\ \ R ° \ \ 3 ^ r !, ) ) { a. ƒ) CL ». § ; E ƒ - < » ; } ƒ r § ) \\ \ \ } \ \ \\\ I ELAN PROJECT WATER SUPPLY ASSESSMENT APPENDIX B CITY OF SANTA ANA LANDSCAPE GUIDELINES NOVEMBER 2, 2017 EUSCOE ENGINEERING, INC. 31 Planning and Building Agency Planning Division 20 Civic Center Plaza Santa Ana, x 1988 2702 CALIFORNIA FRIENDLY Santa Ana, CA 92702 (714)647-5804 LANDSCAPE GUIDELINES www.santa-ana.org In response to the extreme drought conditions throughout California, and the drought State of Emergency declared by the Governor in 2014, landscape policies have been modified to allow drought tolerant landscape throughout the city. The following are the Planning Division policy guidelines for required landscape planting and "ground cover" on private property: 1. 100% of the required landscape for private property MUST be covered with materials such as plants, compost and mulch, and permeable "hardscape" — with the exception of approved driveways and walkways. Refer to property zoning district for minimum of trees and shrubs. http://www.ci. santa-ana.ca. us/pba/planninq/Zoning Documents.asp 2. Plant material must cover at least 65% of the required landscape area. a. The Landscape Plan MUST be designed such that it can reasonably be assumed that at least 65% of the site will be covered with Ip ant material by the time the plants are mature, or within two years, whichever is sooner. This determination will be made at the sole discretion of Planning and Building Agency staff. Synthetic turf may be installed, provided it does not exceed 50% of the area designated as plant material for the yard. For more details on synthetic turf landscape plan requirement see http://www.santa-ana.orq/pba/planning/documents/Synthetic turf standards.Ddf b. Plant material is to be dispersed throughout the landscape area. 3. Permeable hardscape may cover no more than 35% of the required landscape area. a. Permeable hardscape may include pavers and brick set on a bed of sand, where no mortar or grout has been used. b. If not covered by permeable hardscape or plant material, landscape must be completely covered by at least a two-inch layer of mulch. Acceptable mulch includes compost, bark and other organic material. There can be no bare soil or installation of non -permeable (material water cannot easily penetrate) hardscape such as a concrete patio or walkway. c. Permeable hardscape adjacent to approve driveways shall not be used for parking of vehicles. Permeable hardscape is to no greater than two percent slope to allow for draining of water into the soil. 4. All plant materials selected from these two websites (LA Coastal Gardens and www.bewaterwise.com) are acceptable drought tolerant plants. 5. Irrigation systems should also be adjusted to be water efficient through best practices (drip irrigation, bubblers, etc.) Additional information and a variety of resources for creating and maintaining a California Friendly garden are available at http://www.santa-ana.orq/SAwatersmart/. For more information about landscaping your parkway, is please see the "Quick Links" for the Parkway Improvement Guidelines. NLIandscaperCA Friendly Lm6capc Guideline %1ay272015R1.Vslac Sample of landscape planting and permeable hardscape F�nsT'o d e rat kJkb 20 Feet oe? r f CO) T , 0 Landscape Plants (65%minimum) 0 Permeable Hardscape (35% maximum) Single Family Residences (R1 zoning district) requires: 20 feet landscape setback for front yard; to include one 24-inch box canopy tree, six 5-gallon shrubs, ten 1-gallon shrubs (SAMC 41-240) and "ground cover' (per 2014 City California Friendly Landscape Guideline). A five feet landscape setback is also required for side yards, with the exception of approved walkway or driveway. Mid.andstapelCA I nendLy Ian&eape Guideline May272015RIA-Am ELAN PROJECT WATER SUPPLY ASSESSMENT APPENDIX C SIGMA BASIN 8-1 ALTERNATIVE PLAN NOVEMBER 2, 2017 FUSCOE ENGINEERING, INC. 32 VT � YV CITY OF LA HABRA i Irvine Ranch WATER DISTRICT Basin 8-1 Alternative "Reduced Version. Full document found here: https://www.ocwd.com/media/4918/basin-8-l-alternative-final-report-1 .pdf Submitted by: Orange County Water District City of La Habra Irvine Ranch Water District Submitted to: California Department of Water Resources January 1, 2017 Table of Contents Overview 11. Hydrogeology of Basin 8-1 111. La Habra -Brea Management Area IV. OCWD Management Area V. South East Management Area VI. Santa Ana Canyon Management Area Attachment One: Documentation of Public Participation and Agency Approvals 2017 BASIN 8-1 ALTERNATIVE Table of Contents i Basin 8-1 Overview BASIN 8-1 ALTERNATIVE OVERVIEW The Sustainable Groundwater Management Act (SGMA) requires all high- and medium -priority basins, as designated by the Department of Water Resources (DWR), be sustainably managed. DWR designated the Coastal Plain of Orange County Groundwater Basin ("Basin 8-1" or "Basin") as a medium -priority basin, primarily due to heavy reliance on the Basin's groundwater as a source of water supply. Compliance with SGMA can be achieved in one of two ways: 1) A Groundwater Sustainability Agency (GSA) is formed and a Groundwater Sustainability Plan (GSP) is adopted, or 2) Special Act Districts created by statute, such as OCWD, and other agencies may prepare and submit an Alternative to a GSP. The agencies within Basin 8-1 have agreed to collaborate together in order to submit an Alternative to a GSP. Within this document, this Alternative to a GSP will be referred to herein as the "Basin 8-1 Alternative" or "Alternative". In accordance with Water Code §10733.6(b)(3), this Alternative presents an analysis of basin conditions that demonstrates that the Basin has operated within its sustainable yield over a period of at least 10 years. In addition, the Alternative establishes objectives and criteria for management that would be addressed in a GSP and is designed to be "functionally equivalent" to a GSP. As will be shown in the Basin 8-1 Alternative, Basin 8-1 has been operated within its sustainable yield for more than 10 years without experiencing significant and unreasonable (1) lowering of groundwater levels, (2) reduction in storage, (3) water quality degradation, (4) seawater intrusion, (5) inelastic land subsidence, or (6) depletions of interconnected surface water that have significant and unreasonable adverse impacts on beneficial uses of the surface water. Please note that the boundaries of Basin 8-1 described in this document are based on the scientific boundary modifications as accepted by DWR in 2016 as part of the Basin Boundary Modification Process. The Basin 8-1 Alternative has been jointly prepared by the Orange County Water District (OCWD), Irvine Ranch Water District (IRWD); and the City of La Habra (collectively the "Submitting Agencies"); pursuant to this Alternative, the Submitting Agencies will ensure the entire Basin 8-1 continues to be sustainably managed and data reported as required by SGMA. Other agencies within Basin 8-1 and at least partially outside of OCWD's boundaries support submission of the Basin 8-1 Alternative and either have participated in preparing the Alternative and/or reviewed the Alternative. These agencies include the cities of Brea, Corona, and Chino Hills; the Counties of Orange, Riverside, and San Bernardino; Yorba Linda Water District; and El Toro Water District. Pursuant to Water Code §10733.6(b)(3), the Basin 8-1 Alternative has been prepared by or under the direction of a professional geologist or professional engineer. 2017 BASIN 8-1 ALTERNATIVE Overview 1 Basin 8-1 Overview For the purpose of compliance with the SGMA requirement that the entire basin be covered by this Basin 8-1 Alternative, Submitting Agencies have divided Basin 8-1 into four management areas: La Habra -Brea, OCWD, South East, and Santa Ana Canyon Management Areas, shown in Figure 1-1. Historically, the majority of Basin 8-1 (90% of the land area) has been managed by OCWD, which includes the land area within the OCWD Management Area and a small portion of the land area within the Santa Ana Canyon Management Area. The percentage of the land area within Basin 8-1 in each of the management areas is shown in Figure 1-2. Although the land areas outside of OCWD's jurisdiction in the Santa Ana Canyon and South East Management Areas have not been formally "managed" by OCWD, the hydrogeological conditions in these areas are essentially an extension of the managed basin. OCWD has incorporated data, when available, from these areas into the OCWD data base. For example, precipitation runoff from the mountains along the eastern border (in the South East Management Area) is estimated and incorporated into OCWD's basin water budget. The Santa Ana Canyon Management Area, created in this report in order to include land within and outside of OCWD's service area, is upstream of OCWD recharge operations. While OCWD does not have jurisdiction over all the land in this area, OCWD does have the rights to all the water in the Santa Ana River released from Prado Dam. In this respect, OCWD is actively engaged in managing the flow of surface water within the Santa Ana Canyon irrespective of land ownership. While the four management areas are described separately in this report, it is important to understand that actual "management" is not as distinct, and existing collaborative efforts between agencies in managing groundwater resources will continue. In the case of the La Habra -Brea Management Area, the City of La Habra has already been deemed the exclusive GSA for the La Habra/Brea area and intends to prepare a Groundwater Sustainability Plan (GSP). When La Habra submits a GSP, this Basin 8-1 Alternative will no longer include the La Habra/Brea area within the area designated by the GSP. As authorized by 23 CCR § 354.20, this Basin 8-1 Alternative describes four management areas as shown in Figure 1. The rationale for designating these management areas within Basin 8-1 is explained as follows: • La Habra -Brea Management Area includes the northern portion of Basin 8-1 that is located outside of the OCWD service area and is within the cities of La Habra and Brea. The City of La Habra currently manages this portion of Basin 8-1. Although this management area is hydrologically distinct from the OCWD Management Area there is an estimated 1,000 afy of subsurface groundwater flow from the La Habra -Brea Management Area to the OCWD Management Area. Surface water that recharges the OCWD portion of Basin 8-1 does not replenish the La Habra -Brea Management Area. The OCWD Management Area includes approximately 89 percent of the land area of Basin 8-1. Ninety-eight percent of all groundwater production within 8-1 occurs in this management area. This area includes the portion of Basin 8-1 that is within OCWD's service area, except for an approximately 7-square mile portion of OCWD's service area 2017 BASIN 8-1 ALTERNATIVE Overview 2 Basin 8-1 Overview that is in the Santa Ana Canyon Management Area. OCWD has been managing the majority of Basin 8-1 since its formation in 1933. • The South East Management Area includes the southern and southeastern portion of Basin 8-1 that is hydrogeologically connected to the OCWD Management Area but is outside of OCWD's service area. This area consists of several, disconnected, small fringe areas that are within the DWR designated boundary of Basin 8-1. This management area includes areas under the jurisdiction of the IRWD, the El Toro Water District and the City of Orange. The groundwater basin in this area is thin and contains more clay and silt deposits than aquifers in the OCWD Management Area. Groundwater historically has flowed out of this area into the OCWD Management Area. Production has been minimal in this area due to hydrogeological conditions with little potential for significant future increases. • The Santa Ana Canyon Management Area includes the easternmost section of Basin 8- 1. This area includes land under the jurisdiction of several cities, two counties, and two water districts, including a portion that is within the OCWD service area. Groundwater production is relatively minor compared to groundwater production in the OCWD Management Area. The western boundary of this management area is located at Imperial Highway in the city of Anaheim where the basin thickness begins to increase. Imperial Highway crosses the Santa Ana River where OCWD begins to divert river water into the recharge facilities for percolation into the groundwater basin. The Basin 8-1 Alternative is organized as follows: • Overview: Provides a map and description of Basin 8-1 and a brief description of the basin management areas. • Hydrogeology of Basin 8-1: Provides a description of the hydrogeology of Basin 8-1 including a description of the basin, the aquifer systems, fault zones, total basin volume, basin cross -sections, basin characteristics, and general groundwater quality. • La Habra -Brea Management Area: Provides a description of sustainable management of the La Habra -Brea Management Area • OCWD Management Area: Provides a description of sustainable management of the OCWD Management Area • South East Management Area: Provides a description of sustainable management of the South East Management Area • Santa Ana Canyon Management Area: Provides a description of sustainable management of the Santa Ana Canyon Management Area 2017 BASIN 8-1 ALTERNATIVE Overview 3 Basin 8-1 Overview �' saa o�Rrvnemno LOSANGELES � = COUNTY �A m0 CYPPESG ORANGE ., r., ... COUNTY •L<Idi09 P C n y.v 49 c/, cO cF O DWR Basin 8-1 County Boundary Mesas a 120 24000 Fee: BEACX 3 Figure 1-1: Basin 8-1 Management Area Boundaries RNERSIDE COUNTY 2017 BASIN 8-1 ALTERNATIVE Overview 4 Basin 8-1 Overview I South East f 1 La Habra SAR Canyon OCWD 4% 4% f. .I 3% i 89% Figure 1-2: Percentage of Land Area in Basin 8-1 within Management Areas 1. LA HABRA-BREA MANAGEMENT AREA The La Habra -Brea Management area covers the northern portion of Basin 8-1. The City of La Habra has been deemed the exclusive GSA under SGMA for this management area. This management area is part of Basin 8-1, but is hydrogeologically distinct from the OCWD Management Area and is not under the jurisdiction of OCWD. The City adopted a resolution to establish the La Habra Basin as a separate basin from Basin 8-1. OCWD adopted a resolution to support the City's request to DWR for an internal jurisdictional boundary modification in the OC Basin that follows the city limits of La Habra and Brea as is outside of the Orange County Water District's jurisdictional boundary. The La Habra -Brea Management Area is included with this Alternative to facilitate collaboration among groundwater agencies within Basin 8-1 as required by SGMA. The City of La Habra and portions of the City of Brea comprise the La Habra -Brea Management Area. This area overlies the extents of the proposed La Habra Groundwater Basin, referenced herein. The La Habra -Brea Management Area is currently monitored for groundwater elevations and for groundwater quality through productions wells and historical data from monitoring wells within the La Habra -Brea Management Area and surrounding area. 2017 BASIN 8-1 ALTERNATIVE Overview 5 Basin 8-1 Overview As the City of La Habra currently depends on local groundwater to meet approximately 40 percent of its water consumption; preserving the sustainability of the La Habra -Brea Management Area is essential. Currently (and historically), the City of La Habra manages (and has managed) the La Habra -Brea Management Area through management plans and programs for groundwater levels, basin storage, and water quality. By January 2020, the City will manage the La Habra -Brea Management Area through a Groundwater Sustainability Plan under SGMA, which will describe the monitoring program and ensure that no undesirable results occur in the future. 2. OCWD MANAGEMENT AREA The OCWD Management Area covers an area of approximately 260 square miles within Basin 8-1, which represents approximately 89 percent of the land area of Basin 8-1. Ninety-eight percent of the groundwater production within Basin 8-1 occurs in the OCWD Management Area. Groundwater produced within the OCWD Management Area provides approximately 70 percent of the total water supply for a population of around 2.4 million residents. Since its formation by the California Legislature in 1933, OCWD has been the managing agency for the majority of Basin 8-1, also referred to as the Coastal Plain of Orange County Groundwater Basin. As a special act district listed in Water Code § 1072(c)(1), OCWD is the exclusive local agency within its jurisdictional boundaries with powers to comply with SGMA. Water demands within the OCWD Management Area have grown from approximately 150,000 acre-feet per year (afy) in the mid-1950s to a high of approximately 366,000 afy in water year 2007-08. OCWD operates an extensive network of recharge basins to increase recharge of surface water into the groundwater basin to support groundwater production. OCWD monitors the basin by collecting groundwater elevation and quality data from nearly 700 wells, including over 400 OCWD-owned monitoring wells, manages an electronic database that stores water elevation, water quality, production, recharge and other data on over 2,000 wells and facilities within and outside OCWD boundaries. An OCWD-operated water recycling plant provides up to 100 million gallons per day of advanced tertiary -treated wastewater that supplies recharge operations and a seawater intrusion barrier operated to protect the basin's water quality. OCWD manages groundwater storage and water levels within an established operating range which has resulted in sustainable conditions with no unreasonable and significant undesirable results. The Sustainability Goal for the OCWD Management Area is to continue to sustainably manage the groundwater basin to prevent conditions that would lead to significant and unreasonable (1) lowering of groundwater levels, (2) reduction in storage, (3) water quality degradation, (4) seawater intrusion, (5) inelastic land subsidence and (6) adverse impacts on hydrologically connected surface water. 2017 BASIN 8-1 ALTERNATIVE Overview 6 Basin 8-1 Overview 3. SOUTH EAST MANAGEMENT AREA The South East Management Area contains portions of Irvine Ranch Water District (IRWD), El Toro Water District (ETWD), and the City of Orange. The area covered this management area is essentially an extension of the main basin and was formed to comply with the requirement that the entirety of Basin 8-1 be covered by a responsible agency. There is relatively little existing, or potential, groundwater development within the South East Management Area. What pumping does occur is less than 200 acre -feet -per -year (afy), which is much less than the total recharge to the area. Water levels and storage levels are steady. The Sustainability Goal for the South East Management Area is to recognize it is a small part of the larger groundwater basin that is managed by OCWD. Nevertheless, groundwater levels and water quality will be monitored to assure that conditions do not lead to significant and unreasonable (1) lowering of groundwater levels, (2) reduction in storage, (3) water quality degradation, (4) inelastic land subsidence, (6) unreasonable adverse effect on surface water resources, and (6) adverse impacts on hydrologically connected surface water. 4. SANTA ANA CANYON MANAGEMENT AREA The Santa Ana Canyon Management Area covers the easternmost extent of Basin 8-1. The water resources in the Santa Ana Canyon Management Area include the Santa Ana River and groundwater. Groundwater is primarily located in a thin alluvial aquifer that is 90 to 100 feet thick and is a combination of infiltrated surface water and groundwater inflow from the adjacent foothills. Groundwater pumping in this management area is primarily used for irrigation with a minimal amount used for potable purposes. The amount of groundwater pumping is small relative to the large volumes of flow in the canyon provided by the Santa Ana River and monitoring indicates there are no depletions of interconnected surface water that have significant and unreasonable adverse impacts on beneficial uses of the surface water. There are no groundwater withdrawals within the areas covered by the Cities of Anaheim, Chino Hills, and Yorba Linda; Riverside County; and Yorba Linda Water District. OCWD has water rights to all Santa Ana River flows released through Prado Dam. For the area within its boundary, OCWD has the legal authority through the OCWD Act to require reporting of groundwater production and to charge groundwater pumping assessments for groundwater production. OCWD also monitors surface water flow and quality as well as groundwater levels and quality throughout the Santa Ana Canyon Management Area. The Sustainability Goal for the Santa Ana Canyon Management Area is to continue monitoring sustainable conditions and monitor to ensure that no significant and unreasonable results occur in the future. 2017 BASIN 8-1 ALTERNATIVE Overview 7