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HomeMy WebLinkAbout55A - SAN LORENZO SEWER LIFT STATIONREQUEST FOR COUNCIL ACTION CITY COUNCIL MEETING DATE: FEBRUARY 21, 2012 TITLE: RESOLUTION CERTIFYING EIR FOR SAN LORENZO SEWER LIFT STATION AND CONCEPTUAL APPROVAL OF SAN LORENZO SEWER LIFT STATION PROJECT CITY MANAGER RECOMMENDED ACTION 1. Adopt a resolution: CLERK OF COUNCIL USE ONLY: APPROVED ❑ As Recommended ❑ As Amended ❑ Ordinance on 15' Reading ❑ Ordinance on 2 n Reading ❑ Implementing Resolution ❑ Set Public Hearing For_ CONTINUED TO FILE NUMBER (a) Certifying that the Final Environmental Impact Report (EIR) NO 2012 -001 for the San Lorenzo Sewer Lift Station (Exhibit 1) (a) has been completed in compliance with the California Environmental Quality Act (CEQA) (Public Resources Code § 21000 of seq.); (b) was presented to the City Council of the City of Santa Ana, which reviewed and considered the information contained in the Final EIR prior to approving the project; and (c) reflects the City of Santa Ana's independent judgment and analysis. (b) Adopting the Findings of Fact and Statement of Overriding Considerations, attached to the Resolution as "Exhibit A." (c) Adopting the Mitigation Monitoring and Reporting Program, attached to the Resolution as "Exhibit B." 2. Conceptually approve the proposed San Lorenzo Sewer Lift Station as described in the Final EIR. DISCUSSION The City has prepared an Environmental Impact Report (EIR) to evaluate the potential environmental impacts associated with construction and operation of a new sewer lift station at the end of San Lorenzo Avenue, just east of Bristol Street (Exhibit 2). The new sewer lift station would replace an out -of -date facility located beneath Bristol Street approximately 700 feet to the west of the proposed site. The new station will include mechanical and electrical equipment, an updated operating system, and additional pumps, which will greatly reduce the possibility of a major sewage spill. In December 2008, the City prepared a CEQA Initial Study and Mitigated Negative Declaration (MND) for the proposed project. The MND was approved by the City Council on February 2, 2009. 55A -1 Resolution Certifying EIR for San Lorenzo Sewer Lift Station and Approval of Sewer Lift Station Project February 21, 2012 Page 2 Subsequently, the MND was challenged in California Superior Court by an adjacent property owner: Santa Ana California Lodge, LLC. As a result, the court instructed the City to vacate its approval of the MND and prepare a project EIR. The Draft EIR was developed and circulated for public review and comment from July 14, 2010 through September 10, 2010 (58 days). Based on a review of comments provided on this Draft EIR and a prior version of the Final EIR, which was never certified, the City opted to expand the EIR's analysis of alternative locations for the proposed project and incorporate other minor revisions into the Draft EIR. The City also decided to recirculate the Draft EIR. Accordingly, in compliance with CEQA Guidelines, the City prepared a recirculated Draft EIR (RDEIR), which was made available for public review for a 47- day period from September 14 through October 31, 2011. The City has prepared a Final EIR which includes all comments and recommendations received on the RDEIR, and written responses to those comments. Staff recommends that the City Council adopt the resolution certifying the Final Environmental Impact Report for the San Lorenzo Sewer Lift Station, and approve the project as described in the Final EIR. In order to construct the new lift station as described in the Final EIR, the City will need to acquire approximately 292 square feet of unused land owned by the Santa Ana California Lodge, LLC. In addition, a temporary construction easement of 465 square feet would also be required. Assuming the Council approves this resolution certifying the EIR, the City will then make a good faith offer to acquire the needed property for its project. In the event a voluntary acquisition is not possible, staff will bring forth a Resolution of Necessity for the Council's consideration. Attached as Exhibit 3 is the executive summary of the EIR, which explains the revisions made between the originally circulated Draft EIR and the RDEIR. Copies of the Final EIR are available for public review at the City Clerk's office and at the Public Works counter on the first floor of the Ross Annex. This item was originally scheduled for the January 17, 2012 council meeting, On the morning of January 17, the City received a letter from the Silverstein Law Firm citing additional objections to the EIR. Attached as Exhibit 4 is the City's response to the Silverstein letter. ENVIRONMENTAL IMPACT The Final Environmental Impact Report has been prepared in accordance with CEQA. Virtually all of the significant environmental impacts associated with this project are temporary impacts that occur due to construction activities and can be mitigated to below the level of significance. The one significant long -term impact identified was the possibility of odors emanating from the lift station and impacting sensitive receptors. However, this potential impact is reduced to "less than significant" by incorporating an odor - control system into the lift station design. The EIR identified only one significant impact that could not be mitigated below the level of significance: traffic disruption due to lane closures on Segerstrom Avenue and Bristol Street. This impact is a near -term impact and would occur only during five weeks of the construction schedule 55A -2 Resolution Certifying EIR For San Lorenzo Sewer Lift Station and Approval of Sewer Lift Station Project February 21, 2012 Page 3 The EIR evaluated 21 alternatives to the proposed project, including 19 alternative site locations. As set forth in detail in the EIR, none of these alternatives or alternative sites are environmentally superior to the proposed project, and many would increase total environmental impacts as compared to the proposed project. As required by CEQA, the City has prepared specific findings on each significant impact of the proposed project, the mitigation measures for those impacts, and each alternative considered in the Final EIR, and a statement of overriding considerations explaining the specific reasons that the project's economic, legal, social, technological, or other benefits outweigh its adverse environmental impact (Exhibit A to Exhibit 1). The City has also prepared a mitigation monitoring and reporting Program to ensure implementation of all mitigation measures identified in the EIR (Exhibit B to Exhibit 1). FISCAL IMPACT There is no fiscal impact associated with this action. Raul Godinez IV Executive Director Public Works Agency RG /SW Exhibits: 1. Resolution Exhibit A — Findings of Fact and Statement of Overriding Considerations Exhibit B — Mitigation Monitoring and Reporting Program 2. Location Map 3. EIR Executive Summary 4. Response to letter from Silverstein Law Group, dated January 13, 2012. 55A -3 55A -4 RESOLUTION NO. 2012 -001 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA ANA CERTIFYING THE ENVIRONMENTAL IMPACT REPORT FOR THE SAN LORENZO SEWER LIFT STATION PROJECT, ADOPTING CERTAIN FACTS, FINDINGS AND A STATEMENT OF OVERRIDING CONSIDERATIONS, AND ADOPTING A MITIGATION MONITORING AND REPORTING PROGRAM BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF SANTA ANA AS FOLLOWS: Section 1. The City Council of the City of Santa Ana hereby finds, determines, and declares as follows: A. In compliance with the California Environmental Quality Act (CEQA) (Public Resources Code § 21000 et seq.) and Title XIV, California Code of Regulations, Section 15000 et. seq. (CEQA Guidelines), the City of Santa Ana has prepared an Environmental Impact Report (EIR) to analyze the environmental impacts of the San Lorenzo Sewer Lift Station Project (Project No. 06- 3510), which would upgrade and replace an existing sewer lift station located generally near the intersection of South Bristol Street and West Segerstrom Avenue. B. In compliance with CEQA and CEQA Guidelines Sections 15063 and 15082, the City prepared an Initial Study and Notice of Preparation (NOP) of a Draft Environmental Impact Report (EIR), which was distributed to the Office of Planning and Research, all responsible and trustee agencies and other interested parties on April 12, 2010. C. In compliance with CEQA and CEQA Guidelines Sections 15087, the City provided public notice of the availability of the Draft EIR and sent a notice of completion to the Office of Planning and Research on July 14, 2010, which began a 44 -day review period, ending on August 27, 2010. On August 30, 2010, the City extended the review period for an additional 14 days, until September 10, 2010, for a total review period of 58 days. D. In compliance with CEQA and CEQA Guidelines Section 15088.5, following the City's review of public comment letters received on the Draft EIR and previously prepared (but never certified) Final EIR, the City determined a need to incorporate substantive revisions to the Draft EIR, thereby necessitating a re- circulation of the Draft EIR for public review. Accordingly, the City prepared a Recirculated Draft EIR ( RDEIR) and sent a notice of completion to the Office of Planning and Research on September 14, 2011 and provided notice of the availability of the RDEIR as required by CEQA Guidelines Section 15087, which began a 47 -day public review period for the RDEIR that concluded on October 31, 2011. 55A -5 E. The City prepared a Final EIR, which includes all comments and recommendations received on the RDEIR, a list of persons, organizations, and public agencies commenting on the RDEIR, the City's written responses to significant environmental points raised in the review and consultation process, and the RDEIR and associated technical appendices. F. The City provided written responses to all agencies and members of the public commenting on the Draft EIR at least ten (10) days prior to certification of the EIR. G. The City Council of the City of Santa Ana fully considered this matter, and all public testimony, written and oral, at its regularly scheduled meeting of February 21, 2012 H. The City has prepared Findings of Fact in compliance with Public Resources Code Sections 21081 and 21081.5 and CEQA Guidelines Section 15091 for every significant impact of the San Lorenzo Sewer Lift Station Project, including an explanation of the rationale for each finding. I. The San Lorenzo Sewer Lift Station Project will have one significant transportation/traffic impact that cannot be mitigated to below the level of significance. J. The City has prepared a Statement of Overriding Considerations in compliance with Public Resources Code Sections 21081 and CEQA Guidelines Section 15093, which finds that specific economic, legal, social, technological or other benefits of the San Lorenzo Sewer Lift Station Project outweigh the significant and unavoidable impact identified in the EIR. K. The City has prepared a Mitigation, Monitoring and Reporting Program (MMRP) in compliance with Public Resources Code Sections 21081.6 and CEQA Guidelines Section 15087 to ensure compliance with the mitigation measures identified in the EIR during project construction, implementation and operation. L. All attached documents, including the Final EIR, the MMRP, the findings and statement of overriding considerations, the Request for Council Action dated February 21, 2012, and the record of proceedings are incorporated herein by this reference as though fully set forth. Section 2. The City Council of the City of Santa Ana further finds, determines, and declares as follows: A. The City Council certifies that: 1) The Final EIR has been completed in compliance with CEQA. 2) The Final EIR was presented to the City Council of the City of Santa Ana, which reviewed and considered the information contained in the Final EIR prior to approving the project. 3) The Final EIR reflects the City of Santa Ana's independent judgment and analysis. B. The City Council adopts the Findings of Fact and Statement of Overriding Considerations, attached to this Resolution as "Exhibit A." C. The City Council adopts the Mitigation Monitoring and Reporting Program, attached to this Resolution as "Exhibit B." D. All attached documents, including the Mitigation Monitoring and Reporting Program, the CEQA Findings of Fact and the Statement of Overriding Considerations, are hereby incorporated by reference as though set forth in full. Section 3. Pursuant to Title XIV, California Code of Regulations ( "CCR ") §735.5(c)(1), the City Council has determined that, after considering the record as a whole, there is no evidence that the San Lorenzo Sewer Lift Station Project will have the potential for any adverse effect on wildlife resources or the ecological habitat upon which wildlife resources depend. The proposed project exists in an urban environment characterized by paved concrete, roadways, surrounding buildings and human activity. Therefore, pursuant to Fish and Game Code §711.4(c)(2) and Title XIV, CCR §753.5, the payment of Fish and Game Department filing fees is not required in conjunction with this 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 21_day of February, 2012. 55A -7 Miguel A. Pulido Mayor APPROVED AS TO FORM: City Attorney i AYES: Councilmembers NOES: Councilmembers ABSTAIN: Councilmembers NOT PRESENT: Councilmembers CERTIFICATE OF ATTESTATION AND ORIGINALITY I, MARIA D. HUIZAR, Clerk of the Council, do hereby attest to and certify the attached Resolution No. 2012 -001 to be the original resolution adopted by the City Council of the City of Santa Ana on February 21, 2012. Date: Clerk of the Council City of Santa Ana e61 ATTACHMENT "A" SAN LORENZO LIFT STATION PROJECT (SCH No. 2010041028) CE6?A Findings of Fact/ Statement of Overriding Considerations Prepared for: The City of Santa Ana Public Works Agency Water Resources Division 200 S. Daisy Avenue Corporate Yard, MS 85 Santa Ana, CA 92703 Prepared by. T &B Planning, Inc. 17542 East 17th Street, Suite 100 Tustin, CA 92780 February 21, 2012 Contents Attachment "A" Contents Section Egge, Chapter 1 - Introduction .......................................................... ............................... 1 -1 Chapter 2 - CEQA Findings ....................................................... ............................... 2 -1 2.1 Introduction ................................................................ ............................... 2 -1 2.2 Findings Regarding Environmental Impacts .................. ............................2 -2 Chapter 3 - Findings Regarding Project Alternatives ................ ............................... 3 -1 3.1 Introduction ................................................................ ............................... 3 -1 3.2 Project Objectives ...................................................... ............................... 3 -1 3.3 Selection of Alternatives ................................................ ............................3 -1 3.4 Project Alternative Findings ........................................ ............................... 3 -3 3.4.1 No Project Alternative ...................................... ............................... 3 -3 3.4.2 Modified Construction Configuration C.2 Alternative ..................... 3 -5 3.4.3 Alternative Site Location No. 1 (Alternative Site No. 1) .................... 3 -6 3.4.4 Alternative Site Location No. 2 (Alternative Site No. 2) .................... 3 -8 3.4.5 Alternative Site Location No. 3 (Alternative Site No. 3) .................. 3 -10 3.4.6 Alternative Site Location No. 4 (Alternative Site No. 4) .................. 3 -12 3.4.7 Alternative Site Location No. 5 (Alternative Site No. 5) .................. 3 -13 3.4.8 Alternative Site Location No. 6 (Alternative Site No. 6) .................. 3 -15 3.4.9 Alternative Site Location No. 7 (Alternative Site No. 7) .................. 3 -16 3.4.10 Alternative Site Location No. 8 (Alternative Site No. 8) .................. 3 -18 3.4.1 1 Alternative Site Location No. 9 (Alternative Site No. 9) .................. 3 -20 3.4.12 Alternative Site Location No. 10 (Alternative Site No. 10) .............. 3 -22 3.4.13 Alternative Site Location No. 11 (Alternative Site No. 1 1) .............. 3 -24 3.4.14 Alternative Site Location No. 12 (Alternative Site No. 12) .............. 3 -27 3.4.15 Alternative Site Location No. 13 (Alternative Site No. 13) .............. 3 -29 3.4.16 Alternative Site Location No. 14 (Alternative Site No. 14) .............. 3 -31 San Lorenzo Lift Station EIR (Project No. 06 -3510) i CEQA Findings of Fact/Statement of Overriding Considerations 55A -10 Contents Attachment "A" 3.4.17 Alternative Site Location No. 15 (Alternative Site No. 15) .............. 3 -33 3.4.18 Alternative Site Location No. 16 (Alternative Site No. 16) .............. 3 -35 3.4.19 Alternative Site Location No. 17 (Alternative Site No. 17) .............. 3 -36 3.4.20 Alternative Site Location No. 18 (Alternative Site No. 18) .............. 3 -39 3.4.21 Alternative Site Location No. 19 (Alternative Site No. 19) .............. 3 -41 3.4.22 Findings on Alternatives that were Considered but Eliminated from Detailed Analysis in the Draft EIR ........... ............................... 3 -43 3.4.23 Additional Findings ............................................ ...........................3 -45 Chapter 4 - Statement of Overriding Considerations ............. ............................... 4 -47 4.1 Introduction .............................................................. ............................... 4 -47 4.2 Unavoidable Significant Adverse Impacts .................... ...........................4 -47 4.3 Overriding Considerations ............................................ ...........................4 -48 4.3.1 Project Benefits .............................................. ............................... 4 -48 San Lorenzo Lift Station EIR (Project No. 06 -3510) CEQA Findings of Fact/Statement of Overriding Considerations 55A -11 Chapter 1 Introductlon Attachment "A" Chapter 1 - Introduction The City of Santa Ana (City) adopts the following Findings of Fact in connection with the San Lorenzo Lift Station Project (Project). Such Findings must be adopted by the City pursuant to the requirements of Section 21081 of the California Environmental Quality Act (CEQA) (Public Resources Code §21000 et seq.) and Section 15091 of the State CEQA Guidelines (CEQA Guidelines) (14 Cal. Code Regs. §15000 et seq.) prior to approval of a project for which an Environmental Impact Report (EIR) has been certified which identifies one or more significant environmental effects. The City also adopts the Statement of Overriding presented in Chapter 4 of this document, which provides the specific reasons that the Project's economic, legal, social, technological, or other benefits outweigh its adverse environmental impacts. This document is organized as follows: Chapter 1 Introduction to CEQA Findings of Fact and Statement of Overriding Considerations. Chapter 2 CEQA Findings of Fact regarding the significant environmental impacts of the Project and the mitigation measures for those impacts identified in the Environmental Impact Report (EIR) prepared for the Project and adopted as conditions of approval. Chapter 3 Findings regarding the alternatives to the Proposed Project evaluated in the EIR and the reasons that such alternatives were rejected or accepted. Chapter 4 Statement of Overriding Considerations explaining the specific reasons that the Project's economic, legal, social, technological, or other benefits outweigh its adverse environmental impact. Brief Project Description The Project area is located at the western terminus of San Lorenzo Avenue, immediately north of West Segerstrom Avenue and south of an existing alley. The Project would replace the existing Segerstrom Lift Station, which is located beneath South Bristol Street approximately 700 feet to the west of the new lift station site. The Project will consist of a newly constructed lift station that will be housed within an approximately 8 -foot by 30 -foot block structure, measuring approximately 17 feet in height. The following facilities will be installed within or beneath the block structure: electrical panels and control center; a below - ground wet well of sufficient size and depth to prevent back up and surcharging of the upstream sewer mains; a below - ground dry well to house the pumps, motors, associated equipment and appurtenances; a gravity odor control system; and a stairway access into the dry well. Landscaping and hardscape improvements are included as part of the new lift station. The Project includes the repaving of a portion of the western end of San Lorenzo Avenue, portions of an existing San Lorenzo Lift Station EIR (Project No. 06 -3510) 1 -1 CEQA Findings of Fact/Statement of Overriding Considerations 55A -12 Chapter 1 Introduction Attachment "A" alley, and a portion of West Segerstrom Avenue, along with the installation of new sidewalks in areas where existing sidewalks have fallen into a state of disrepair and /or will be demolished during lift station construction. Some existing landscaping along West Segerstrom Avenue will remain. The Project also includes the installation and operation of approximately 1,300 linear feet of new underground sewer infrastructure, including approximately 560 linear feet of 15 -inch gravity sewer pipe; approximately 190 linear feet of 12 -inch gravity sewer pipe; approximately 545 linear feet of 10 -inch force main; and sewer manholes and appurtenances. Construction of these new facilities will occur beneath the paved rights -of -ways of South Bristol Street and West Segerstrom Avenue. The new infrastructure will be needed to connect several existing sewer mains to the Project. After construction of the Project is complete and the new subsurface sewer pipes and manholes are installed, the new lift station will move effluent through the station and into gravity sewer lines, which will convey the sewerage to the Orange County Sanitation District's (OCSD) Reclamation Plant No. 1, located in the City of Fountain Valley adjacent to the Santa Ana River. Effluent will continuously flow through the Project and will not be stagnant. The Project will replace the Segerstrom Lift Station and will not increase the capacity of the City's existing sewer system. The Project will be constructed with odor control devices and the City will regularly monitor the facility to ensure it is functioning properly. After the Project has been constructed and is in operation, demolition of the existing Segerstrom Lift Station will occur. Demolition activities will involve abandonment in place of the existing lift station, including the removal and disposal of all lift station equipment and filling of the existing wet well manhole with sand. An existing generator, located southerly of the existing lift station, will remain in place and will serve as a back -up power source for the proposed Project. Some removal and replacement of existing sidewalk and roadway pavement will occur in association with proposed demolition activities. Demolition of the existing Segerstrom Lift Station will occur in conformance with all applicable federal, state, and local regulations and standards. All roadway segments disturbed by Project construction will be resurfaced. CEQA Compliance As described in Section 1.3.1 of the EIR, the City originally prepared and processed a Mitigated Negative Declaration (MND) for the proposed Project in December 2008. The MND was adopted by the City Council on February 2, 2009. However, the MND was challenged in California Superior Court by an adjacent property owner, and the Court ordered the lead agency to vacate its approval of the MND and required preparation of a project EIR. The City published a Draft EIR for the Project and circulated it for public review between July 14, 2010 and September 10, 2010. Following the City's review of comment letters received in response to the Draft EIR and a previously prepared (but never certified) Final EIR, the City determined a need to incorporate substantive revisions to the Draft EIR, thereby necessitating a re- circulation of the Draft EIR for an additional public review period. Accordingly, the City prepared a Recirculated Draft EIR (RDEIR) and sent a notice of completion to the Office of Planning and Research on September 14, 2011 and provided notice of the availability of the RDEIR as required by CEQA Guidelines Section 15087, which began a 47 -day public review period for the RDEIR that concluded on October 31, 2011. The key procedural actions related to the proposed Project and CEQA to date include: San Lorenzo Lift Station FIR (Project No. 06 -3510) 1 -2 CEQA Findings of Fact /Statement of Overriding Considerations 55A -13 Chapter 1 Introduction Attachment 'A' • Circulate Initial Study/Notice of Preparation of a Draft EIR: April 12, 2010 through May 12, 2010 (30 days); • Provide Notice of Availability of the Draft EIR, file Notice of Completion (NOC) with the Office of Planning and Research and circulate Draft EIR for Public Review: July 14, 2010 through September 10, 2010 (58 days); • Provide Notice of Availability of the RDEIR, file NOC with the Office of Planning and Research and re- circulate the RDEIR for Public Review: September 14, 2011 through October 31, 2011 (47 days); and • Prepare Final EIR, including all comments and recommendations received on the RDEIR, a list of persons, organizations, and public agencies commenting on the RDEIR, the City's written responses to significant environmental points raised in the review and consultation process, and the RDEIR. San Lorenzo Lift Station EIR (Project No. 06 -3510) 1 -3 CEQA Findings of Fact /Statement of Overriding Considerations 55A -14 Chapter 2 CEQA Findings Attachment 'A" Chapter 2 - CEQA Findings 2.1 Introduction This chapter presents the impacts that were identified in the EIR and the findings that are required in accordance with Section 15091 of the CEQA Guidelines. The possible findings for each significant adverse impact are as follows: 1. Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the EIR ( "Finding 1 ") 2. Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency ( "Finding 2 "). 3. Specific economic, social, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives in the EIR ( "Finding 3 "). CEQA requires that the Lead Agency adopt mitigation measures or alternatives, where feasible, to avoid or substantially reduce significant environmental impacts that would otherwise occur as a result of a project. Project modifications or alternatives are not required, however, where they are infeasible or where the responsibility for modifying the project lies with some other agency (State CEQA Guidelines §15091(a)[21,[3]). Public Resources Code Section 21061.1 defines "feasible" to mean "capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors." State CEQA Guidelines Section 15364 adds another factor: "legal" considerations. (See also Citizens of Goleta Valley v. Board of Supervisors [Goleta II] [1990] 52 Cal.3d 553,565 [276 Cal. Rptr. 410].) When an agency approves a project with significant environmental effects that will not be avoided or substantially lessened, it must adopt a statement that, because of the project's overriding benefits, it is approving the project despite its environmental harm. (CEQA Guidelines §15043). This written statement is known as the Statement of Overriding Considerations. The Statement of Overriding Considerations demonstrates that the decision making body of the Lead Agency has weighed the benefits of the project against its unavoidable adverse effects in determining whether to approve the project. If the specific economic, legal, social, technological or other benefits of the project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered "acceptable." (CEQA Guidelines § 15093.) The California Supreme Court has stated that, "the wisdom of approving any development project, a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of the local officials and their constituents who are responsible for such decisions. The law as we interpret and apply it simply requires that those decisions be informed, and therefore balanced" (Goleta H, 52 Cal.3d 553, 576 [276 Cal. Rptr. 401]). San Lorenzo Lift Station EIR (Project No. 06 -3510) 2-1 Findings of Fact /Statement of Overriding Considerations 55A -15 Chapter 2 CEQA Findings Attachment "A" 2.2 Findings Regarding Environmental Impacts Table 2 -1, CEQA Findings, summarizes the environmental impacts of the Project which either have no impact or are less than significant, the significant impacts of the Project that will be reduced to less - than - significant levels with mitigation, and the significant and unavoidable impact. The City hereby finds that Project impacts associated with the issue areas of Hazards/Hazardous Materials, Utilities /Service Systems, and Water Quality /Hydrology either have no impact or are less than significant. This finding is based on the explanation and analysis included in RDEIR Chapters 3.2, 3.5 and 3.6, respectively, which the City ratifies, adopts and incorporates in these findings. The City hereby finds that mitigation measures have been identified in the RDEIR that will avoid or substantially lessen Project impacts associated with the issue areas of Air Quality, Noise, and Transportation and Traffic to a less than significant level. This finding is based on the explanation and analysis included in RDEIR Chapters 3.1, 3.3 and 3.4, respectively, which the City ratifies, adopts and incorporates in these findings. The City hereby finds that mitigation measures have been identified in the RDEIR that will lessen Project impacts associated with the issue areas of Transportation and Traffic, specifically the impact to intersection operations during implementation of Construction Configuration C.2 under Transportation /Traffic Threshold 1, but not to a less than significant level. This finding is based on the explanation and analysis included in RDEIR Chapter 3.4, which the City ratifies, adopts and incorporates in these findings. In addition, the City hereby finds that impacts to the following issue areas would not occur as a result of the Proposed Project: Aesthetics; Agricultural Resources; Biological Resources; Cultural Resources; Geology /Soils; Land Use /Planning; Mineral Resources; Population /Housing; Public Services; Recreation; and Utilities /Service Systems (except for wastewater). This finding is based on the explanation and analysis included in Initial Study prepared for the Project, which the City ratifies, adopts and incorporates in these findings. Additional facts that support the findings are set forth in the Final EIR, the staff report to the City Council, and the record of proceedings for the Project. Key discussions that support the Findings from the Final EIR are summarized in the "Evidence /Rationale Supporting Finding" column of Table 2 -1. However, other evidence may be contained in the overall record of the project to further support the finding. In making these findings, the City ratifies, adopts and incorporates the analysis and explanation in the Final EIR, and ratifies, adopts and incorporates in these findings the determinations and conclusions of the Final EIR relating to the environmental impacts and mitigation measures, except to the extent any such determinations or conclusions are specifically and expressly modified by these findings. The documents and other materials that constitute the record of proceedings on which the Project findings are based are located at the City of Santa Ana Public Works Agency, 200 South Daisy Avenue, Corporate Yard, MS 85, Santa Ana, California, 92703. The custodian for these documents is Steve Worrall, Senior Civil Engineer. This information is provided in compliance with Public Resources Code §21081.6(a)(2) and CEQA Guidelines §15091(e). San Lorenzo Lift Station EIR (Project No. 06 -3510) 2 -2 Findings of Fact /Statement of Overriding Considerations 55A -16 e Q m t Q U N 55A -17 O In M O z U a� 'o a W 0 .y N c O 0 3•. U 'O O U an c 'O 0 0 c N U w 0 on c 'D fi. Q a W U N o O U •Z7 N cC 'O ti b ro .�-. F c3 F U O U -O 'O ro gl +4 E cC F �.. F U N is � U �'' a' vUi b Y .a o o U 'm E E s' aCi O E 'a 'o � N � U on U • a� on ^ � � . 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LM,Mfqe� Itt N N 0 'C O O U O j zo U 4•+ ��I G ca W� y O U ca o N � c S `o w �l d cn U Q U Q a U N �1�JMl"J kn N N 0 M O O z U N O a` W 0 N O td Cd U ° U cd ca R. y (n L •—� y GJ Y CY Q, y N ice. •� N N V CT •- to° N Y w � C� d❑ Y 1 q C"i s 10 U8 'n � � > -o c -o Y 'o Y = > -o = 'b Y 'd y � > -o c '•o .w ,� G '> .o = w •a -C o '> -o = � .o -o c > -o = � .D .?o F- � ° � � � a� ."� F- � U � � h 0 .°p F- �a a� �c � � U •— ccz C C) s. N L 0.0 r-+ r-+ O GA bfJ 'C b ti cp CQ U = U L L CC CQ 6' d 1 U y U Y N LL C 4 G' bA m ca s C, a a s I Ca a o a o 0 0 0 N a� O bq W U O bA a a� O= O .'O.. � o Ca� W w� � °oN °Yoca w °a _° °p���> 0. °30 '�� Y�U. H ,O N a ' 3 '� = F N 'v c° U Z iC yU„ °c a ca x a E °' ." x Fes- c i Fes- �1�JMl"J kn N N 0 M O O z U N O a` W 0 N O Chapter 3 Findings Regarding Project Alternathas Attachment "A" Chapter 3 - Findings Regarding Project Alternatives 3.1 Introduction The RDEIR prepared for the Project considered numerous alternatives to the Project and ultimately analyzed twenty -one (21) of these alternatives in detail. This chapter describes the Project's objectives and design criteria used to develop and evaluate the project alternatives presented in the RDEIR. A description of the alternatives compared to the Project and the findings regarding the feasibility of adopting the described alternatives are presented below. 3.2 Project Objectives The project objectives of the proposed San Lorenzo Sewer Lift Station Project are as follows: • To construct a new sewage lift station (the San Lorenzo Lift Station) near the intersection of South Bristol Street and West Segerstrom Avenue to replace an existing lift station that has exceeded its design life (the Segerstrom Lift Station). • To install modern lift station equipment and associated wastewater conveyance infrastructure to reduce the potential of a sewer spill or equipment failure. • To provide a lift station facility in which electrical components of the facility are housed above ground so as to preclude the potential for electrical failure during peak storm events (due to flooding). • To construct a lift station facility that provides sufficient access space for maintenance of the lift station facility. • To avoid detrimental effects to existing businesses during construction and long -term operation of the lift station facility to the extent feasible. • To improve safety for both motorists and City workers by providing for an above - ground lift station facility located outside of existing roadway rights -of -way. • To minimize odor - related nuisances to land uses in close proximity to the new sewage lift station through the installation of a gravity odor control system. • To install landscape and hardscape improvements in areas that will be disturbed by lift station construction. • To safely demolish and abandon the existing Segerstrom Lift Station in accordance with applicable federal, state, and local regulations and standards. 3.3 Selection of Alternatives The RDEIR evaluated twenty -one (21) alternatives, including the No Project Alternative, in Chapter 5.0. This evaluation compared the environmental advantages and disadvantages of each alternative to the Proposed Project. The No Project Alternative, as required by CEQA, considers a scenario in San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -1 CEQA Findings of Fact/Statement of Overriding Considerations 1 Chapter 3 findings Regarding ProjectAltemathas Attachment "A" which no new lift station facility would be constructed and the existing lift station north of the South Bristol Street/West Segerstrom Avenue intersection would continue operating as it does under existing conditions. The Modified Construction Configuration C.2 Alternative addressed an alternative to the Proposed Project that would reduce or eliminate the Project's significant and unavoidable impact to the intersection of South Bristol Street /West Segerstrom Avenue by modifying the construction schedule for portions of construction Phases 11, 14 and 16. In addition, the RDEIR evaluated a total of nineteen (19) alternative site locations, as follows (refer also to Figure 5 -1 of the Final EIR): • Alternative Site No. 1 would be sited at the western end of San Lorenzo Avenue, but would occur fully within existing public rights -of -way (including temporary construction and staging areas). • Alternative Site No. 2 would be sited within an existing City park located at the northeast corner of the West Segerstrom /South Shelton Street intersection. • Alternative Site No. 3 would be sited in the parking lot of an existing medical office and retail center (2835 South Bristol Street). • Alternative Site No. 4 would be sited within an undeveloped parcel located behind 2402 South Bristol Street. • Alternative Site No. 5 would be sited in the parking lot of an existing commercial complex (approximately 3001 -3005 South Bristol Street). • Alternative Site No. 6 would be sited in the parking lot of an existing commercial center (approximately 2840 South Bristol Street). • Alternative Site No. 7 would be sited would be sited in the parking lot of an existing commercial center (approximately 2840 South Bristol Street). • Alternative Site No. 8 would be sited in the parking lot behind an existing medical office building (2810 South Bristol Street). • Alternative Site No. 9 would be sited in the parking lot behind an existing medical complex (2720 -2740 South Bristol Street). • Alternative Site No. 10 would be sited in the parking lot behind an existing medical building (2700 South Bristol Street). • Alternative Site No. 11 would be sited in the parking lot behind an existing medical building (2650 South Bristol Street). • Alternative Site No. 12 would be sited in the parking lot of an existing hospital (2701 South Bristol Avenue). • Alternative Site No. 13 would be located in the parking lot in front of an existing commercial building (2449 South Bristol Street). • Alternative Site No. 14 would be located in the parking lot of an existing commercial complex (located at the southeast corner of the intersection of South Bristol Street and West Warner Avenue). San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -2 CEQA Findings of Fact /Statement of Overriding Considerations 55A -41 Chapter 3 Findings Regarding Project Altemativw Attachment "A" • Alternative Site No. 15 would be located in the parking lot of an existing commercial complex (located at the southeast corner of the intersection of South Bristol Street and West Warner Avenue). • Alternative Site No. 16 would be located within Carl Thornton Park (1801 West Segerstrom Avenue). • Alternative Site No. 17 would be located in the parking lot of an existing commercial complex (approximately 3200 South Bristol Street). • Alternative Site No. 18 would be located in the parking lot of an existing commercial center (approximately 3300 South Bristol Street). • Alternative No. 19 would be located in the parking lot of an existing commercial center (approximately 3301 -3365 South Bristol Street. These alternatives were selected to foster meaningful public participation and informed decision - making. Among the factors that were taken into account when considering the potential feasibility of alternatives (as described in CEQA Guidelines Section 15126.6[f][l]) were site suitability, environmental impacts, economic viability, availability of infrastructure, regulatory limitations, jurisdictional boundaries, and attainment of the Project's objectives. As stated in Section 15126.6(1)(3) of the CEQA Guidelines, an EIR need not consider an alternative whose effects could not be reasonably ascertained or whose implementation is remote and speculative. Additionally, an EIR need not consider an alternative that would not achieve most of the basic project objectives or that is infeasible. (CEQA Guidelines Section 15126.6[a].) An EIR also need not consider every conceivable alternative to a project; the range of alternatives is governed by the rule of reason. (Id.) The analysis in the EIR includes sufficient information about each alternative to provide meaningful evaluation, analysis, and comparison with the Proposed Project. 3.4 Project Alternative Findings The Lead Agency's findings on each alternative and the rationale behind each finding are set forth below. 3.4.1 No Project Alternative 3.4.1.1 Summary of the No Proiect Alternative The No Project Alternative is included in the EIR Alternatives analysis (Section 5.4.1) as required pursuant to CEQA Guidelines Section 15126.6(e). The CEQA Guidelines require evaluation of an alternative that considers what would reasonably be expected to occur on the property in the foreseeable fixture if the Project were not approved, based on current plans and consistent with available infrastructure and community services. The No Project Alternative therefore assumes that the Proposed Project is not approved and the existing Segerstrom Lift Station facility located beneath South Bristol Street would continue operating into the foreseeable future. Construction of a new lift station facility, new underground sewer infrastructure, and sewer manholes and appurtenances associated with a new lift station would not occur under this alternative. The existing lift station facility beneath South Bristol Street would not be demolished under this alternative and would continue operating. No landscape or hardscape improvements would occur under this alternative. San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -3 CEQA Findings of Fact/Statement of Overriding Considerations 55A -42 Chapter 3 Findings Regarding Project Altemathres Attachment "A" 3.4.1.2 Comparison of Environmental Effects The impacts of this alternative were evaluated and compared to those of the Project. As concluded in the Final EIR, implementation of the No Project Alternative would eliminate all of the Project's near - term construction - related impacts. However, several long -term impacts would increase with implementation of this alternative, including increased impacts to air quality, hazards/hazardous materials, transportation /traffic, and water quality/hydrology. Long -term impacts from noise would be slightly reduced under this alternative due to the increased distance between the existing lift station facility and nearby sensitive receptors. 3.4.1.3 Finding and Rationale for the No Project Alternative The City hereby finds that specific economic, legal, social, technological, or other considerations make the No Project Alternative infeasible. Although the No Project Alternative would avoid all of the Project's near -term construction - related environmental effects, including the Project's significant an unavoidable impact to the intersection of South Bristol Street/West Segerstrom during the implementation of Construction Configuration C.2, this alternative would not meet any of the Project's basic objectives. Specifically: • The No Project Alternative would not result in the construction of a replacement lift station to replace the existing lift station that has exceeded its design life. • The No Project Alternative would not allow for the installation of modern lift station equipment and associated wastewater conveyance infrastructure that would reduce the potential for sewer spills or equipment failure. • The No Project Alternative would not provide for a replacement lift station facility in which electrical components are housed above ground to preclude the potential for electrical failure during peak storm events, as the existing lift station facility houses all of its electrical equipment underground and is subject to flooding. • The No Project Alternative would not provide for a facility that accommodates sufficient access space for maintenance workers, as the existing facility is located beneath the crown of South Bristol Street and affords very little space for maintenance workers. • The No Project Alternative would not avoid detrimental effects to existing businesses, as the existing lift station would continue to require frequent maintenance to clear blockages due to debris collected in the system and the risk from a sewage spill under the No Project Alternative would be increased in comparison to the proposed Project. • The No Project Alternative would not improve safety for motorists and City workers, as the existing lift station is located within the right -of -way of South Bristol Street, a major City thoroughfare. • The No Project Alternative would not reduce the potential for odor - related nuisances to land uses in close proximity to the facility, as no new odor - control systems would be installed. • The No Project Alternative would not provide for hardscape and landscape improvements and would not result in the demolition of the existing outdated facility. The No Project Alternative would not meet the basic Project objectives and therefore would not provide the numerous benefits of the Project, as set forth in the Statement of Overriding Considerations, including the installation of a replacement lift station facility that reduces the San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -4 CEQA Findings of Fact/Statement of Overriding Considerations 55A -43 Chapter 3 Findings Regarding Project Altematti(es Attachment "A" potential for sewer spills and nuisance odors; enhanced City worker and vehicular safety; improved appearance of the immediate area (i.e., hardscape /landscape improvements); and the provision of a generally more reliable and efficient lift station facility as compared to the existing facility. The No Project Alternative would increase impacts to the environment under long -term conditions as compared to the Project. The existing Segerstrom Lift Station facility was originally constructed in the 1960s and has exceeded its design life. The existing lift station facility has become inadequate to handle existing sewerage flows and is obsolete in comparison to modern lift station designs. The existing lift station is prone to frequent maintenance (two to three times per week) in order to clear blockages due to debris collected in the system. In addition, due to the age of the equipment, the existing pumps are subject to frequent mechanical failure (requiring maintenance) and it is difficult to obtain necessary replacement parts for the existing facility. These conditions result in an increased potential for sewer spills as compared to the Project. With the increased potential for sewer spills under long -term conditions, impacts to air quality (odors), hazards/hazardous materials, and water quality/hydrology would increase under the No Project Alternative. Since the existing lift station is located within the northbound travel lanes of South Bristol Street, long -term maintenance of the existing facility would result in periodic lane closures along South Bristol Street, which would result in increased impacts to traffic and air quality. The City finds that the No Project Alternative would fail to meet the Project's basic objectives and would result in an increase in long -term impacts to the environment, and therefore rejects the No Project Alternative as infeasible. 3.4.2 Modified Construction Configuration C.2 Alternative 3.4.2.1 Summary of the Modified Construction Configuration C.2 Alternative The Modified Construction Configuration C.2 Alternative (analyzed in RDEIR Section 5.4.2) would incorporate a modified construction schedule for the five (5) weeks in which Construction Configuration C.2 would need to be in place. Specifically, traffic control measures associated with Construction Configuration C.2 would be restricted to between the hours of 6:45 p.m. and 7:00 a.m. instead of allowing for 24 -hour lane closures as proposed by the Project. All other aspects of construction activities would be identical to the Project, and there would be no change to the long- term operational characteristics of the facility under this alternative. 3.4.2.2 Comparison of Environmental Effects Implementation of this alternative would reduce the Project's near -term significant and unavoidable construction - related impact at the intersection of South Bristol Street /West Segerstrom Avenue, which would occur between the hours of 7:15 a.m. and 8:00 a.m. and between the hours of 2:30 p.m. and 6:45 p.m. (Monday through Friday) by approximately two weeks. However, because construction activities associated with Construction Configuration C.2 would be modified to occur in the nighttime, between the hours of 6:45 p.m. and 7:00 a.m., a significant and unavoidable noise impact would result due to the exposure of nearby sensitive receptors to noise levels in excess of the City's Noise Ordinance standards. Impacts related to air quality /greenhouse gas emissions, hazards /hazardous materials, utilities /service systems, and water quality /hydrology would be similar to the proposed Project's impacts during construction. During long -term operation of the proposed facility, all impacts would be the same under both the Modified Construction Configuration C.2 Alternative and the proposed Project. San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -5 CEQA Findings of Fact /Statement of Overriding Considerations 55A -44 Chapter 3 Findings Regarding ProjectAiternathies Attachment "A" 3.4.2.3 Finding and Rationale for the Modified Construction Configuration C.2 Alternative The City hereby finds that specific economic, legal, social, technological, or other considerations make the Modified Construction Configuration C.2 Alternative infeasible. Although the Modified Construction Configuration C.2 Alternative would reduce the Project's significant and unavoidable construction - related impact at the intersection of South Bristol Street/West Segerstrom Avenue by a period of two (2) weeks, this alternative would result in new significant and unavoidable noise impacts for a period of two (2) weeks because construction activities would be required to occur during nighttime hours to allow sufficient time to set up and remove traffic control measures. Such nighttime construction activities would invariably result in significant noise levels that would impact nearby sensitive receptors, including residents of the nearby apartments and the Studio Inn Hotel. Such noise levels would exceed the City's Noise Ordinance requirements for nighttime noise levels, and would result in a significant and unavoidable impact to noise. In addition, and as discussed in EIR Section 3.4.7, modifying the timing restrictions for Construction Configuration C.2 so as to allow construction during the daytime while completely avoiding significant traffic impacts during the five (5) weeks in which Construction Configuration C.2 would be in place is not feasible. Specifically, during the three (3) weeks during the construction of a new manhole within the South Bristol Street /West Segerstrom intersection, Construction Configuration C.2 would need to be in place 24 hours per day. Accordingly, this alternative would reduce (by a period of 2 weeks), but would not avoid, the Project's significant and unavoidable impact to transportation /traffic. On balance, the City finds that the reduction in duration of significant unavoidable impacts to transportation /traffic that would occur under this alternative does not justify the significant and unavoidable impacts to noise that would result from the nighttime construction activities required for this alternative. Therefore, the City finds that the Modified Construction Configuration C.2 Alternative is not feasible. 3.4.3 Alternative Site Location No. 1 (Alternative Site No. 1) 3.4.3.1 Summary of Alternative Site No. 1 Under this alternative a lift station would be constructed at the western terminus of San Lorenzo Avenue (Alternative Site No. 1) in lieu of the proposed Project site. The location of Alternative Site No. 1 is depicted on Final EIR Figure 5 -1. Alternative Site No. I is almost identical to the proposed Project but would be constructed wholly within the existing public right -of -way of San Lorenzo Avenue and an unnamed public alley. This alternative would not require the acquisition of private property. Although the acquisition of private property that would occur as part of the proposed Project would not result in a significant environmental effect, construction of a lift station at Alternative Site No. 1 was selected in order to evaluate construction of a lift station on an alternative site that would not require the City of Santa Ana to acquire any private property. 3.4.3.2 Summary Comparison of Environmental Effects As detailed in RDEIR Section 5.4.3, relocating the proposed lift station to Alternative Site No. 1 would neither avoid nor reduce the Project's near -term significant and unavoidable construction- San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -6 CEQA Findings of Fact/Statement of Overriding Considerations 55A -45 Chapter 3 Findings Regarding Project Allernathees Attachment "A" related impact at the intersection of South Bristol Street and West Segerstrom Avenue, which would occur between the hours of 7:15 a.m. and 8:00 a.m. and between the hours of 2:30 p.m. and 6:45 p.m. (Monday through Friday). Alternative Site No. 1 also would create a new, significant long -term impact to public services by adversely affecting the provision of police protection services. This alternative also would result in a significant impact to emergency access under long -term conditions, which could only be mitigated with the acquisition of private property, thus, negating the purpose of analyzing this alternative, i.e., to examine whether it would be possible to design the project to avoid the need to condemn private property. Impacts related to air quality /greenhouse gas emissions, noise, utilities and service systems, and water quality and hydrology would be similar to the proposed Project's impacts during construction and long -term operation. Additionally, both the City's Police Department and Fire Department object to this alternative for the reasons explained above. 3.4.3.3 Finding and Rationale for Alternative Site No. 1 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. I infeasible. Alternative Site No. 1 would not avoid or substantially lessen the Project's near -term significant and unavoidable construction - related impact at the intersection of South Bristol Street and West Segerstrom Avenue, which would occur between the hours of 7:15 a.m. and 8:00 a.m. and between the hours of 2:30 p.m. and 6:45 p.m. (Monday through Friday). This alternative also would introduce new impacts to public services (long -term) and emergency access (long -term) that would not occur in association with the proposed Project. None of the other impacts associated with the proposed Project would be avoided or substantially lessened with implementation of this alternative. Additionally, the Santa Ana Police Department reviewed the proposal to construct a lift station at Alternative Site No. 1, and determined that this alternative has the potential to adversely affect public safety. In a letter dated March 15, 2010, the Police Department indicated that locating a lift station at Alternative Site No. 1 would obstruct the line of sight for patrol and passerby, thereby inhibiting the ability of police (and the public) to monitor activities within the alley located north of this alternative site location. In addition, the Police Department noted that a lift station at Alternative Site No. 1 would leave a significant amount of dead space behind the building which could "provide concealment for transients and other undesirable activities" and "create an attractive nuisance" for graffiti (see RDEIR Appendix H for the complete letter from the Santa Ana Police Department). The only available mitigation for this impact would be to re- locate the proposed lift station to the west, which would be the same design as proposed by the Project. Further, the City Fire Department reviewed the proposal to construct a lift station at Alternative Site No. I and determined this alternative would interfere with the ability of emergency vehicles to navigate the turn between the west end of San Lorenzo Avenue and the north -south oriented alley. (See letter from Fire Chief Dave Thomas to Raul Godinez, dated March 17, 2011, RDEIR Appendix H.) Specifically, the Fire Department determined at Alternative Site No. 1 would not meet the Fire Department's minimum turn radius requirement (minimum 20 -foot interior and 40 -foot exterior turn radius), as required by Santa Ana Municipal Code (SAMC) Sec. 14 -25. In addition, the City has an Automatic Mutual Aide agreement provided by the Costa Mesa Fire Department (CMFD), and such aid may be provided by larger CMFD vehicles that require a minimum 28 -foot interior and 46 -foot ' The letter from the Santa Ana Police Department included in Appendix H of the RDEIR is erroneously dated March 15, 2010; this letter was actually provided to the Public Works Department in March 2011. San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -7 CEQA Findings of Fact/Statement of Overriding Considerations i � le� Chapter 3 Findings Regarding Project AtternatAss Attachment "A" exterior turn radius. Construction of a replacement lift station at Alternative Site Location No. I would interfere with the ability of fire trucks to make such turns. This alternative would, therefore, adversely affect the Fire Department's ability to respond to emergencies in the Project vicinity. The City has determined that these concerns about the impacts of Alternative Site No. 1 on public safety render it infeasible, particularly in light of the fact that Alternative Site No. I would not avoid or substantially lessen any significant effects of the project. (See CEQA Guidelines Section 15126.6(b).) 3.4.4 Alternative Site Location No. 2 (Alternative Site No. 2) 3.4.4.1 Summary of Alternative Site No. 2 Alternative Site Location Number 2 (Alternative Site No. 2) would involve the construction of a new replacement lift station within an existing City park located at the northeast corner of the West Segerstrom Avenue /South Shelton Street intersection instead of the proposed Project site. Alternative Site No. 2 is located approximately 0.15 -mile northeast of the proposed Project site. The location of Alternative Site No. 2 is depicted on Final EIR Figure 5 -1. Development of a lift station at Alternative Site No. 2 would occur wholly within an existing City-owned park; therefore, this alternative would not require the acquisition of private property. The lift station that would be constructed at Alternative Site No. 2 would consist of a similar above - ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 2 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the construction of approximately 115 percent increase in the length of underground sewer conveyance infrastructure as compared to the proposed Project (i.e., 2,800 linear feet, as compared to 1,300 feet for the proposed Project). The duration of the construction phase would be increased as compared to the Project to accommodate the construction of additional underground sewer conveyance infrastructure. 3.4.4.2 Summary Comparison of Environmental Effects As detailed in RDEIR Section 5.4.4, relocating the proposed lift station to Alternative Site No. 2 would neither avoid nor reduce the proposed Project's near -term significant and unavoidable construction - related impact at the intersection of South Bristol Street and West Segerstrom Avenue, which would occur between the hours of 7:15 a.m. and 8:00 a.m. and between the hours of 2:30 p.m. and 6:45 p.m. (Monday through Friday). In addition, development of a lift station at Alternative Site No. 2 would result in a new significant and unavoidable impact to recreation, as this alternative would reduce park land in the City and would exacerbate an existing deficiency of park and recreation facilities in the City. Specifically, the City has a standard of providing two (2) acres of park land per 1,000 residents (SAMC, Sec. 35 -108); however, the City currently does not meet this standard and is providing less than one (1) acre of park land per 1,000 residents. Development of a lift station at Alternative Site No. 2 would reduce the amount of available park land in the City (by approximately 0. 15 acre during the 12 months of construction, and by approximately 0.03 acre under long -term operating conditions). This temporary and permanent loss of parkland would exacerbate the existing deficiency of parkland in the City. This alternative also would result in an increased, but mitigable, long -term air quality impact due to the potential to expose nearby odor - sensitive uses to substantial offensive odor levels during worst -case accident conditions. Impacts related to construction - related air quality/greenhouse gas emissions and noise would be increased under this alternative, but would not result in any new significant impacts as compared to the proposed Project. San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -8 CEQA Findings of Fact /Statement of Overriding Considerations 55A -47 Chapter 3 Findings Regarding ProjectAiternathres Attachment "A" Impacts related to air quality /greenhouse gas emissions (long - term), noise (long - term), utilities and service systems, and water quality and hydrology would be similar to the proposed Project. 3.4.4.3 Finding and Rationale for Alternative Site No. 2 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 2 infeasible. Alternative Site No. 2 would not avoid or substantially lessen the Project's near -term significant and unavoidable construction - related impact at the intersection of South Bristol Street and West Segerstrom Avenue, which would occur between the hours of 7:15 a.m. and 8:00 a.m. and between the hours of 2:30 p.m. and 6:45 p.m. (Monday through Friday). This alternative also would introduce new impacts to recreation (near- and long -term) that would not occur in association with the proposed Project, and would increase potential long -term odor impacts affecting nearby sensitive receptors, in addition to increasing impacts to construction - related air quality /greenhouse gas emissions and noise. None of the impacts associated with the proposed Project would be avoided or substantially lessened with implementation of this alternative. Furthermore, the City Parks, Recreation and Community Services Agency (PRCSA) submitted a $2.4 million grant application to the state's Urban Greening Grant Program on June 16, 2011 to develop the existing park as an "Eco- Park," which may feature amenities such as a community amphitheater, rock climbing area, picnic area, interpretive center, demonstration gardens, jogging trails and sidewalks, and open turf areas. (See Memorandum from Ron Ono, Administrative Service Manager of the City of Santa Ana PRCSA, to Steve Worrall, dated November 23, 2011.) The City hopes to use the park site as a showcase to educate residents on the value of water and energy conservation and provide landscape examples of drought tolerant plants, water harvesting techniques, solar panel installation, amphitheater for education classes, and natural type play equipment for adjacent residents. (See letter from the Gerardo Mouet, Executive Director, PRCSA, to R. Godinez, included in RDEIR Appendix H.) The site is also located a block west of Flower Street Bike Trail and the Golden Loop Bike Trail, which will make the site accessible to all residents in Santa Ana and adjacent cites. (Id.) A conceptual plan for this facility is presented on RDEIR Figure 5 -2, Conceptual West Segerstrom Avenue Eco -Park. The development of a lift station at Alternative Site No. 2 will interfere with any future development of this park for the community. Awards are anticipated to be announced early 2012. Regardless of whether the City receives a grant in this round of the Urban Greening Grant Program, it plans to improve the recreational opportunities at this park site and any construction of a Sewer Lift Station at the site would conflict with these community - serving objectives. The City has determined that these concerns about the impacts of Alternative Site No. 2 on recreational opportunities in the City render it infeasible, particularly in light of the fact that Alternative Site No. 2 would not avoid or substantially lessen any significant effects of the project. (See CEQA Guidelines Section 15126.6(b).) Z http : / /resources.ca.gov /bondsprop84 urbangreenine.html (last accessed December 6, 2011). San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -9 CEQA Findings of Fact /Statement of Overriding Considerations A •1 •� Chapter 3 Findings Regarding Project ANernathres Attachment "A" 3.4.5 Alternative Site Location No. 3 (Alternative Site No. 3) 3.4.5.1 Summary of Alternative Site No. 3 Alternative Site Location Number 3 (Alternative Site No. 3) would involve the construction of a new replacement lift station in the parking lot of an existing medical office and retail center located at 2835 South Bristol Street in lieu of the proposed Project site. Alternative Site No. 3 is located approximately 0.05 -mile north of the proposed Project site. The location of Alternative Site No. 3 is depicted on Final EIR Figure 5 -1. The lift station that would be constructed at Alternative Site No. 3 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 3 would feature similar equipment and appurtenances as the proposed Project. This alternative would construct 23 percent less underground sewer conveyance infrastructure than the proposed Project, and it is anticipated that the duration of the Construction Phase 11 would be decreased by six (6) work days (approximately one week) as compared to the Project. The construction schedule for this alternative would otherwise be similar to the Project. This alternative would not require construction activities within the South Bristol Street/West Segerstrom Avenue intersection or beneath the existing paved right -of -way of West Segerstrom Avenue (east of South Bristol Street). Therefore, this alternative would not require the implementation of Construction Configuration C.2. In addition, this alternative would not require implementation of Construction Configurations B.1, B.2, and C.I I. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the proposed Project (i.e., to the north of the existing Segerstrom Lift Station). Specifically, this segment of South Bristol Street contains a 20 -inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16 -inch water main, and a SCE /MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 feet. Construction along this segment of South Bristol Street likely would require supporting the utilities from the top of the trench. Due to these existing utility constraints beneath South Bristol Street, portions of this roadway would need to be closed to accommodate construction associated with this alternative. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. Development of a lift station at Alternative Site No. 3 also would require the City to acquire private property to implement a temporary construction easement, accommodate the proposed lift station, and provide easements for proposed sewer lines, since the proposed lift station would be constructed within the parking lot of an existing medical office and retail center located at 2835 South Bristol Street. 3.4.5.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 3 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.5. This alternative would avoid the Project's significant and unavoidable impact associated with Construction Configuration C.2; however, this alternative would create a significant and unmitigable near -term traffic impact to a portion of the South Bristol Street road segment that would not occur as part of the proposed Project. This alternative's significant and unmitigable impact to South Bristol Street would occur for approximately 14 days during construction, approximately eleven (11) days shorter than the proposed Project's significant and unmitigable San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -10 CEQA Findings of Fact /Statement of Overriding Considerations Chapter 3 Findings Regarding Project Allernatives Attachment 'A" impact associated with Construction Configuration C.2. In addition, construction of a lift station at Alternative Site No. 3 would exacerbate an existing parking deficiency at this location by eliminating approximately 20 parking spaces during near -term construction, and five parking spaces under long- term operating conditions. Near- and long -term impacts to parking at Alternative Site No. 3 would represent a significant and unmitigable impact. As such, impacts to transportation /traffic would be greater at Alternative Site No. 3 as compared to the proposed Project site. This alternative also would result in a slight increase in the severity of impacts to air quality as compared to the proposed Project, because relocating the proposed lift station to Alternative Site No. 3 would have a greater potential to expose nearby odor - sensitive uses to substantial offensive odor levels during worst -case accident conditions; however, odor effects would be mitigable to a level below significant. Total construction air quality /greenhouse gas emissions would be modestly reduced under this alternative due to a slightly shorter construction period, although average daily construction emissions would be similar to the proposed Project. Impacts related to near -term water quality and hydrology would be slightly increased under this alternative, while impacts to noise, utilities and service systems, and water quality and hydrology (long -term) would be similar to the proposed Project. 3.4.5.3 Finding and Rationale for Alternative Site No. 3 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 3 infeasible. Although this alternative would avoid the proposed Project's significant and unavoidable impact to the South Bristol Street/West Segerstrom Avenue intersection, this alternative would introduce a new significant unavoidable impact along South Bristol Street, which would occur for approximately 14 days (11 days shorter than the proposed Project's significant unavoidable impact). When considered in conjunction with this alternative's near- and long -term significant and unavoidable impacts to parking, the City finds that this alternative would, on the whole, result in increased impacts to transportation /traffic as compared to the proposed Project. Accordingly, the City rejects Alternative Site No. 3 as infeasible because it would result in an overall increase in environmental impacts as compared to the proposed Project and would not avoid or substantially lessen any significant effects of the Project (CEQA Guidelines Section 15126.6(b).) Additionally, as indicated in Section 5.4.5.4, this alternative would exacerbate an existing parking deficiency by eliminating approximately 20 parking spaces during near -term construction, and five parking spaces under long -term operating conditions. Under this alternative, a 6,420 square -foot portion of the parking lot would be closed and unavailable to site patrons during the entire construction phase (i.e., approximately 12 months) to accommodate construction and staging activities. Based on an analysis of this site, it is estimated that up to 20 parking spaces would be impacted and unavailable for the duration of construction activities, resulting in a deficit of approximately 61 parking spaces during the construction phase. Furthermore, construction of a connection between the proposed lift station and new east -west trending sewer facilities would require trenching activities within the parking lot that would impact additional parking spaces and internal drive aisles for a period of several weeks during construction, which would result in adverse effects to site access and internal circulation. Alternative Site No. 3 includes doctor's offices, a Physical Therapy Center, Orthopedic Clinic, Prenatal Care Facility and "Orange County Health Care Agency" offices. Ingress and egress to this parking lot is tight and many of the patrons are handicapped or physically impaired drivers, pregnant women, or elderly. Construction of the Lift San Lorenzo Lift Station EIR (Project No. 06 -3510) CEQA Findings of Fact /Statement of Overriding Considerations 55A -50 3 -11 Chapter 3 Findings Regarding ProjectAiternathres Attachment "A° Station and associated pipelines through the parking would create significant confusion and safety issues for the public. Therefore, this alternative is rejected as infeasible because it would substantially interfere with and disrupt the medical and retail uses at this location. Further, unlike the proposed Project site where the City has an existing sewer easement, construction at this location would require the City to acquire private property to provide easements for proposed sewer lines. Finally, construction of the lift station at this location would replace currently developed, useable land, in contrast to the proposed Project site, which is vacant and undeveloped. 3.4.6 Alternative Site Location No. 4 (Alternative Site No. 4) 3.4.6.1 Summary of Alternative Site No. 4 Alternative Site Location Number 4 (Alternative Site No. 4) would involve the construction of a replacement lift station in an undeveloped field located behind 2402 South Bristol Street instead of at the proposed Project site. Alternative Site No. 4 is located approximately 0.45 -mile northwest of the proposed Project site. The location of Alternative Site No. 4 is depicted on Final EIR Figure 5 -1. The lift station that would be constructed at Alternative Site No. 4 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 4 would feature similar equipment and appurtenances as the proposed Project. This alternative would construct 108 percent more underground sewer conveyance infrastructure than the proposed Project, and it is anticipated that Construction Phase 11 would be increased by an additional 61 work days (approximately 12 weeks) as compared to the proposed Project. The construction schedule for this alternative would otherwise be similar to the proposed Project. This alternative would not require construction activities within the South Bristol Street/West Segerstrom Avenue intersection or beneath the existing paved right -of -way of West Segerstrom Avenue (east of South Bristol Street). Therefore, this alternative would not require the implementation of Construction Configurations B.1, B.2, C.1, or C.2. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the Project (i.e., to the north of the existing Segerstrom Lift Station). Due to existing utility constraints beneath South Bristol Street, portions of this roadway would need to be closed to accommodate construction associated with this alternative. Specifically, this segment of South Bristol Street contains a 20 -inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16 -inch water main, and a SCE/MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 feet. Construction along this segment of South Bristol Street likely would require supporting the utilities using trench boxes or shields, which in turn would require a larger area of closure along South Bristol Street during construction. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. Development of a lift station at Alternative Site No. 4 also would require the City to acquire private property to implement a temporary construction easement, accommodate the proposed lift station, and provide easements for proposed sewer lines, as the proposed lift station would be constructed in an undeveloped field located behind 2402 South Bristol Street. 3.4.6.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 4 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in San Lorenzo Lift Station EIR (Project No. 06 -3510) CEQA Findings of Fact /Statement of Overriding Considerations 55A -51 3 -12 Chapter 3 Findings Regarding Project AlternatAms Attachment "A" RDEIR Section 5.4.6. This alternative would avoid the proposed Project's significant and unavoidable impact associated with Construction Configuration C.2; however, this alternative would result in a significant and unmitigable near -term impact to a portion of the South Bristol Street road segment that would not occur as part of the proposed Project. This alternative's significant and unmitigable impact to South Bristol Street would occur for approximately 16 weeks (approximately 11 weeks longer than the Project's significant and unmitigable impact associated with Construction Configuration C.2). Unavoidable impacts to transportation /traffic would also occur when construction activities disrupt left -turn movements, thereby diverting traffic to adjacent intersections or encouraging cut - through traffic in local neighborhoods; such impacts would not occur in association with the proposed Project. Near -term significant and unmitigable impacts would occur over a longer duration under this alternative; therefore, impacts to traffic and circulation are considered to be greater at Alternative Site No. 4 as compared to the proposed Project site. Total construction air quality /greenhouse gas emissions would be increased under this alternative due to a longer construction period, although average daily construction emissions would be less than significant and similar to the proposed Project. Impacts to near -term water quality and hydrology also would be increased under this alternative due to a larger area of impact, although such effects would be reduced to a level below significant with mitigation. Impacts to noise, utilities and service systems, and water quality and hydrology (long -term) would be similar to the proposed Project. 3.4.6.3 Finding and Rationale for Alternative Site No. 4 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 4 infeasible. Although this alternative would avoid the proposed Project's significant and unavoidable impact to the South Bristol Street /West Segerstrom Avenue intersection, it would introduce a new significant unavoidable impact along South Bristol Street, which would occur for approximately 11 weeks longer than the Project's significant and unmitigable impact associated with Construction Configuration C.2. Therefore, the City finds that implementation of this alternative would result in increased impacts to transportation /traffic as compared to the proposed Project. Accordingly, the City rejects Alternative Site No. 4 as infeasible because it would result in an overall increase in environmental impacts as compared to the proposed Project and would not avoid or substantially lessen any significant effects of the Project. (CEQA Guidelines Section 15126.6(b).) This alternative also is rejected as infeasible because it would fail to meet, or would not be as effective in achieving, the Project's objective to minimize disruptions to existing businesses, since construction of this alternative would require near -term closures of the center median that allows left - turn access into the parking lots of existing businesses. 3.4.7 Alternative Site Location No. 5 (Alternative Site No. 5) 3.4.7.1 Summary of Alternative Site No. 5 Alternative Site Location Number 5 (Alternative Site No. 5) would involve the construction of a replacement lift station in the parking lot of an existing commercial complex located at 3001 -3005 South Bristol Street in lieu of the proposed Project site. Alternative Site No. 5 is located approximately 0.04 -mile southwest of the proposed Project site. The location of Alternative Site No. 5 is depicted on Final EIR Figure 5 -1. The lift station that would be constructed at Alternative Site No. 5 would include an above - ground block structure similar to the proposed Project and would also San Lorenzo Lift Station EIR (Project No. 06 -3510) CEQA Findings of Fact/Statement of Overriding Considerations 55A -52 3 -13 Chapter 3 Findings Regarding Pr %ctAftrnatives Attachment 'A" feature similar equipment and appurtenances as the proposed Project. In addition, the construction of a lift station at Alternative Site No. 5 would require similar construction activities as the proposed Project (including the need to construct a manhole within the South Bristol Street /West Segerstrom Avenue intersection), and would follow a similar construction schedule. Development of a lift station at Alternative Site No. 5 also would require the City to acquire private property to implement a temporary construction easement, accommodate the proposed lift station, and provide easements for proposed sewer lines (as discussed in Section 5.2.3), as the proposed lift station would be constructed within the parking lot of an existing commercial retail center located at 3001 -3005 South Bristol Street. 3.4.7.2 Summary Comparison of Environmental Effects As summarized in Final EIR Table 5 -1 and described in detail in RDE1R Section 5.4.7, relocating the proposed lift station to Alternative Site No. 5 would neither avoid nor reduce the proposed Project's near -term significant and unavoidable construction - related impact at the intersection of South Bristol Street and West Segerstrom Avenue, which would occur between the hours of 7:15 a.m. and 8:00 a.m. and between the hours of 2:30 p.m. and 6:45 p.m. (Monday through Friday); in fact, under this alternative the duration of Construction Configuration C.2 (and the significant unavoidable impact) would increase due to the need to completely cross the West Segerstrom Avenue right -of -way. In addition, development of a lift station at Alternative Site No. 5 would create new, significant near - term impacts transportation /traffic due to inadequate parking capacity. Impacts related to air quality /greenhouse gas emissions, noise, utilities and service systems, and water quality and hydrology would be similar to the proposed Project. 3.4.7.3 Finding and Rationale for Alternative Site No. 5 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 5 infeasible. Alternative Site No. 5 would not avoid or substantially lessen the Project's near -term significant and unavoidable construction- related impact at the intersection of South Bristol Street and West Segerstrom Avenue, or any other impacts associated with the proposed Project. Furthermore, this alternative would result in the elimination of approximately 27 parking spaces during near -term construction resulting in a temporary deficiency of six (6) parking spaces for a period of up to twelve (12) months. Because this alternative would result in inadequate parking capacity at an existing commercial retail center during construction, it would substantially interfere with and disrupt the existing commercial retail center that utilizes the parking lot, as well as fail to meet the Project's objective of avoiding detrimental effects to existing businesses. Further, unlike the proposed Project site where the City has an existing sewer easement, construction at this location would require the City to acquire private property to provide easements for proposed sewer lines. Finally, construction of the lift station at this location would replace currently developed, useable land, in contrast to the proposed Project site, which is vacant and undeveloped. Based on these considerations, the City rejects Alternative Site No. 5 as infeasible and finds that it would not avoid or substantially lessen any significant effects of the Project. (CEQA Guidelines Section 15126.6(b).) San Lorenzo Lift Station EIR (Project No. 06 -3510) CEQA Findings of Fact /Statement of Overriding Considerations 55A -53 3 -14 Chapter 3 Findings Regarding Project Altemathres Attachment "A' 3.4.8 Alternative Site Location No. 6 (Alternative Site No. 6) 3.4.8.1 Summary of Alternative Site No. 6 Alternative Site Location Number 6 (Alternative Site No. 6) would involve the construction of a replacement lift station in the southern portion of a parking lot of an existing commercial center located at 2840 South Bristol Street instead of the proposed Project site. Alternative Site No. 6 is located approximately 0.15 -mile west of the proposed Project site, northwesterly of the South Bristol Street /West Segerstrom Avenue intersection. The location of Alternative Site No. 6 is depicted on Final EIR Figure 5 -1. The lift station that would be constructed at Alternative Site No. 6 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 6 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the construction of 46 percent less underground sewer conveyance infrastructure than the proposed Project. As a result, it is anticipated that the duration of Construction Phase 11 would be decreased as compared to the Project. The new sewer lines required in support of this alternative would be constructed within the alignments of West Segerstrom Avenue (westerly of South Bristol Street), and within South Bristol Street (northerly of West Segerstrom Avenue), and would require the construction of a manhole within the intersection of these two roadways (thereby necessitating implementation of traffic control in a manner similar to Construction Configuration C.2). Development of a lift station at Alternative Site No. 6 also would require the City to acquire private property to implement a temporary construction easement, accommodate the proposed lift station, and provide easements for proposed sewer lines. 3.4.8.2 Summary Comparison of Environmental Effects As summarized in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.8, relocating the proposed lift station to Alternative Site No. 6 would slightly increase the duration of the Project's near -term significant and unavoidable construction - related impact at the intersection of South Bristol Street and West Segerstrom Avenue, which would occur between the hours of 7:15 a.m. and 8:00 a.m. and between the hours of 2:30 p.m. and 6:45 p.m. (Monday through Friday). In addition, development of a lift station at Alternative Site No. 6 would create new, significant near- and long- term impacts to transportation /traffic due to inadequate parking capacity. Near -term air quality impacts would be slightly reduced under this alternative due to a shorter duration of construction, and long -term odor impacts would be slightly reduced due to a slight increase in the distance to the nearest sensitive receptor. Near -term hydrology and water quality impacts also would be slightly reduced due to a smaller area of disturbance. Non -odor related impacts related to air quality /greenhouse gas emissions (long - term), impacts to noise, and impacts to utilities and service systems would be similar to the proposed Project. 3.4.8.3 Finding and Rationale for Alternative Site No. 6 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 6 infeasible. Specifically, Alternative Site No. 6 would not avoid or substantially lessen the Project's near -term significant and unavoidable construction - related impact at the intersection of South Bristol Street and West Segerstrom Avenue, which would occur between the hours of 7:15 a.m. and 8:00 a.m. and San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -15 CEQA Findings of Fact /Statement of Overriding Considerations 55A -54 Chapter 3 Findings Regarding Project AiternatAres Attachment "A" between the hours of 2:30 p.m. and 6:45 p.m. (Monday through Friday); in fact, impacts to this intersection would slightly increase under this alternative. Further, implementation of the proposed lift station at Alternative Site No. 6 would result in the elimination of approximately 14 parking spaces during near -term construction, and six parking spaces under long -term operating conditions, which would result in deficiency in parking by 13 spaces and five spaces under near- and long -term conditions, respectively. Because this alternative would result in inadequate parking capacity at an existing commercial center during construction, it would substantially interfere with and disrupt the existing commercial center that utilizes the parking lot, as well as fail to meet the Project's objective of avoiding detrimental effects to existing businesses. Further, unlike the proposed Project site where the City has an existing sewer easement, construction at this location would require the City to acquire private property to provide easements for proposed sewer lines. Finally, construction of the lift station at this location would replace currently developed, useable land, in contrast to the proposed Project site, which is vacant and undeveloped. Based on these considerations, the City rejects Alternative Site No. 5 as infeasible and finds that it would not avoid or substantially lessen any significant effects of the Project. (CEQA Guidelines Section 15126.6(b).) 3.4.9 Alternative Site Location No. 7 (Alternative Site No. 7) 3.4.9.1 Summary of Alternative Site No. 7 Alternative Site Location Number 7 (Alternative Site No. 7) would involve the construction of a replacement lift station in the northeast portion of a parking lot of an existing commercial center located at 2840 South Bristol Street in lieu of the proposed Project site. It should be noted that Alternative Site No. 7 would occur in the same parking lot described above for Alternative Site No. 6. Alternative Site No. 7 is located approximately 0.10 -mile northwest of the proposed Project site. The location of Alternative Site No. 7 is depicted on Final EIR Figure 5 -1. The lift station that would be constructed at Alternative Site No. 7 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 7 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the installation and operation of approximately 77 percent less underground sewer conveyance infrastructure than the proposed Project and it is anticipated that the duration of Construction Phase 11 would be decreased by eight (8) work days (approximately 1.5 weeks) as compared to the proposed Project. The construction schedule for this alternative would otherwise be similar to the proposed Project. This alternative would not require construction activities within the South Bristol Street/West Segerstrom Avenue intersection or beneath the existing paved right -of -way of West Segerstrom Avenue (east of South Bristol Street). Therefore, this alternative would not require the implementation of Construction Configuration C.2. In addition, this alternative would not require implementation of Construction Configurations B.1, B.2, and C.I. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the Project (i.e., to the north of the existing Segerstrom Lift Station). Specifically, this segment of South Bristol Street contains a 20 -inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16 -inch water main, and a SCE/MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 feet. Construction along this segment of South San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -16 CEQA Findings of Fact/Statement of Overriding Considerations 55A -55 Chapter 3 Findings Regarding Project Alternathres Affachment "A" Bristol Street likely would require supporting the utilities from the top of the trench. Due to these existing utility constraints beneath South Bristol Street, portions of this roadway would need to be closed to accommodate construction associated with this alternative. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. Development of a lift station at Alternative Site No. 7 also would require the City to acquire private property to implement a temporary construction easement, accommodate the proposed lift station, and provide easements for proposed sewer lines. 3.4.9.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 7 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.9. This alternative would avoid the proposed Project's significant and unavoidable impact associated with Construction Configuration C.2; however, this alternative would create a significant and unmitigable near -term impact to transportation /traffic due to a LOS deficiency that would occur for approximately twelve (12) days during construction, which is a reduction in comparison to the proposed Project, which would result in a deficient LOS for up to twenty -five (25) days during construction. However, construction of a lift station at Alternative Site No. 7 would result in inadequate parking at an existing commercial retail center both during construction and long -term operation. Near- and long -term impacts to parking at Alternative Site No. 7 would be a significant and unmitigable impact. Therefore, because Alternative Site No. 7 would still result in a significant and unavoidable near -term traffic impact, and would result in significant near -term (12 months) and long -term impacts to parking capacity, impacts to transportation /traffic would be increased with implementation of Alternative Site No. 7 as compared to the proposed Project. Total construction air quality /greenhouse gas emissions would be decreased under this alternative due to a shorter construction period, although average daily construction emissions would be less than significant and similar to the proposed Project. Impacts related to near -term water quality and hydrology also would be decreased under this alternative due to a smaller area of impact. Impacts associated with long -term odors would slightly increase under this alternative, although with mitigation this impact would be reduced to less than significant levels. Impacts to non -odor related air quality /greenhouse gas emissions (long - term), noise, utilities and service systems, and water quality and hydrology (long -term) would be similar to the proposed Project. 3.4.9.3 Finding and Rationale for Alternative Site No. 7 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 7 infeasible. Alternative Site No. 7 would, on balance, result in an overall increase in impacts to transportation /traffic as compared to the proposed Project. Although this alternative would avoid the proposed Project's significant and unavoidable impact to the south Bristol Street/West Segerstrom Avenue during the five weeks in which Construction Configuration C.2 would be in place, this alternative would result in a LOS deficiency that would occur for approximately twelve (12) days during construction, and also would result in a new significant and unavoidable impact to parking (near- and long -term) that would not occur in association with the proposed Project. In light of these considerations, the City finds that Alternative Site No. 7 would result in an overall increase in near- San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -17 CEQA Findings of Fact/Statement of Overriding Considerations 55A -56 Chapter 3 Findings Regarding ProjectAllernathres Attachment "A" term impacts to transportation /traffic, and rejects this alternative as infeasible because it would not avoid or substantially lessen the significant environmental effects of the Project. (CEQA Guidelines Section 15126.6(b).) This alternative also is rejected as infeasible because it would result in inadequate parking at an existing commercial retail center, and would, therefore, fail to meet the proposed Project's objective of avoiding detrimental effects to existing businesses. Detrimental effects to the business would be further exacerbated by ongoing construction in close proximity to the existing commercial retail center. Further, unlike the proposed Project site where the City has an existing sewer easement, construction at this location would require the City to acquire private property to provide easements for proposed sewer lines. Finally, construction of the lift station at this location would replace currently developed, useable land, in contrast to the proposed Project site, which is vacant and undeveloped. 3.4.10 Alternative Site Location No. 8 (Alternative Site No. 8) 3.4.10.1 Summary of Alternative Site No. 8 Alternative Site Location Number 8 (Alternative Site No. 8) would involve the construction of a replacement lift station in the parking lot of an existing medical office building located at 2810 South Bristol Street in lieu of the proposed Project site. Alternative Site No. 8 is located approximately 0.15 -mile north of the proposed Project site. The location of Alternative Site No. 8 is depicted on Final EIR Figure 5 -1. Alternative Site No. 8 includes only the eastern portion of the parking lot, as the westernmost portion of the parking lot is part of the adjacent parcel to the north (which is discussed below as part of Alternative Site No. 9). The lift station that would be constructed at Alternative Site No. 8 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 8 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the installation and operation of approximately 27 percent less underground sewer conveyance infrastructure than the proposed Project and it is anticipated that the duration of Construction Phase 11 would be decreased by four (4) work days (approximately 1 week) as compared to the proposed Project. The construction schedule for this alternative would otherwise be similar to the proposed Project. This alternative would not require construction activities within the South Bristol Street/West Segerstrom Avenue intersection or beneath the existing paved right -of -way of West Segerstrom Avenue (east of South Bristol Street). Therefore, this alternative would not require the implementation of Construction Configurations B.1, B.2, C.1, or C.2. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the proposed Project (i.e., to the north of the existing Segerstrom Lift Station). Specifically, this segment of South Bristol Street contains a 20- inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16 -inch water main, and a SCE /MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 feet. Construction along this segment of South Bristol Street likely would require supporting the utilities from the top of the trench or the use of trench boxes /shields. Due to these existing utility constraints beneath South Bristol Street, portions of this roadway would need to be closed to accommodate construction associated with this alternative, which has the potential to result in adverse effects to vehicular San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -18 CEQA Findings of Fact /Statement of Overriding Considerations 55A -57 Chapter 3 Findings Regarding ProjectAilernatives Attachment "A" circulation. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. Development of a lift station at Alternative Site No. 8 also would require the City to acquire private property to implement a temporary construction easement, accommodate the proposed lift station, and provide easements for proposed sewer lines (as discussed in Section 5.2.3). 3.4.10.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 8 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.10. This alternative would avoid the proposed Project's significant and unavoidable impact associated with Construction Configuration C.2; however, this alternative would create a significant and unmitigable near -term impact to transportation /traffic due to a LOS deficiency that would occur for approximately sixteen (16) days during construction, which is a slight reduction in comparison to the proposed Project, which would result in a deficient LOS for up to twenty-five (25) days during construction. However, construction of a lift station at Alternative Site No. 8 would also result in inadequate parking capacity at an existing medical office building both during construction and long -term operation. Near- and long -term impacts to parking at Alternative Site No. 8 would be a significant and immitigable impact. As such, impacts to transportation /traffic would be greater at Alternative Site No. 8 as compared to the proposed Project. Total construction - related air quality /greenhouse gas emissions would be reduced under this alternative due to a slightly shorter construction period, although average daily construction emissions would be similar to the proposed Project. Long -term odor - related impacts would be slightly reduced under this alternative, though as with the proposed Project mitigation still would be required to minimize to the extent feasible the proposed Project's potential to generate substantial odor impacts. In addition, construction noise levels would be slightly reduced under this alternative due to a slight increase in the distance to sensitive receptors; however, construction noise impacts would be less than significant under both this alternative and the proposed Project. Impacts related near -term water quality and hydrology would be slightly decreased under this alternative, while impacts to noise (long- term), utilities and service systems, and water quality and hydrology (long- term) would be similar to the proposed Project. 3.4.10.3 Finding and Rationale for Alternative Site No. 8 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 8 infeasible. Alternative Site No. 8 would, on balance, result in an overall increase in impacts to transportation /traffic as compared to the proposed Project. Although this alternative would avoid the proposed Project's significant and unavoidable impact to the south Bristol Street/West Segerstrom Avenue during the five weeks in which Construction Configuration C.2 would be in place, this alternative would result in a LOS deficiency that would occur for approximately sixteen (16) days during construction, and also would result in a new significant and unavoidable impact to parking (near- and long -term) that would not occur in association with the proposed Project. In light of these considerations, the City finds that Alternative Site No. 8 would result in an overall increase in near - term impacts to transportation /traffic, and rejects this alternative as infeasible because it would not avoid or substantially lessen the Project's significant effects. (CEQA Guidelines Section 15126.6(b).) San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -19 CEQA Findings of Fact /Statement of Overriding Considerations �1� Chapter 3 Findings Regarding Project Alternatives Attachment "A" This alternative also is rejected as infeasible because it would fail to meet, or would not be as effective in achieving, the proposed Project's objectives. Specifically, Alternative Site No. 8 would result in inadequate parking at an existing medical office building, and would, therefore, fail to meet the proposed Project's objective of avoiding detrimental effects to existing businesses. Detrimental effects to the business would be further exacerbated by ongoing construction in close proximity to the medical office building. Further, unlike the proposed Project site where the City has an existing sewer easement, construction at this location would require the City to acquire private property to provide easements for proposed sewer lines. Finally, construction of the lift station at this location would replace currently developed, useable land, in contrast to the proposed Project site, which is vacant and undeveloped. 3.4.11 Alternative Site Location No. 9 (Alternative Site No. 9) 3.4.11.1 Summary of Alternative Site No. 9 Alternative Site Location Number 9 (Alternative Site No. 9) would involve the construction of a replacement lift station in the parking lot of an existing medical complex located at 2720 -2740 South Bristol Street in lieu of the proposed Project site. Alternative Site No. 9 is located approximately 0.20 -mile north of the proposed Project site. The location of Alternative Site No. 9 is depicted on Final EIR Figure 5 -1. Due to the existing configuration of this site and in order to minimize disruptions to the existing use during construction and long -term operation, it is assumed that a replacement lift station at this location would need to be located along or near the western property line. The lift station that would be constructed at Alternative Site No. 9 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 9 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the installation and operation of approximately 12 percent more underground sewer conveyance infrastructure than the proposed Project and it is anticipated that the duration of Construction Phase 11 would be increased by nine (9) work days (approximately two weeks) as compared to the proposed Project. The construction schedule for this alternative would otherwise be similar to the proposed Project. This alternative would not require construction activities within the South Bristol Street/West Segerstrom Avenue intersection or beneath the existing paved right -of -way of West Segerstrom Avenue (east of South Bristol Street). Therefore, this alternative would not require the implementation of Construction Configurations B.1, B.2, C.1, or C.2. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the proposed Project (i.e., to the north of the existing Segerstrom Lift Station). Specifically, this segment of South Bristol Street contains a 20- inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16 -inch water main, and a SCE /MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 feet. Construction along this segment of South Bristol Street likely would require supporting the utilities from the top of the trench or the use of trench boxes /shields. Due to these existing utility constraints beneath South Bristol Street, portions of this roadway would need to be closed to accommodate construction associated with this alternative, which has the potential to result in adverse effects to vehicular San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -20 CEQA Findings of Fact/Statement of Overriding Considerations 55A -59 Chapter 3 Findings Regarding ProjectAiternatlhaes Attachment "A" circulation. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. Development of a lift station at Alternative Site No. 9 also would require the City to acquire private property to implement a temporary construction easement, accommodate the proposed lift station, and provide easements for proposed sewer lines. 3.4.11.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 9 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.11. This alternative would avoid the proposed Project's significant and unavoidable impact associated with Construction Configuration C.2; however, this alternative would create a significant and immitigable near -term impact to transportation /traffic due to a LOS deficiency that would occur for approximately 29 days during construction, which is a slight increase in duration as compared to the twenty -five (25) days of construction during which the proposed Project would create a significant unavoidable impact to transportation /traffic at the South Bristol Street /West Segerstrom Avenue intersection. Impacts to transportation /traffic would also occur when construction activities disrupt left -turn movements, thereby diverting traffic to adjacent intersections or encouraging cut - through traffic in local neighborhoods; such impacts would not occur in association with the proposed Project. Furthermore, construction of a lift station at Alternative Site No. 9 would exacerbate an existing parking deficiency at the existing medical complex both during construction and long -term operation. Near- and long -term impacts to parking at Alternative Site No. 9 would be a significant and unmitigable impact. As such, impacts to transportation /traffic would be greater at Alternative Site No. 9 as compared to the proposed Project site. This alternative also would result in an increase in the severity of the Project's significant long -term air quality impact as compared to the proposed Project, because Alternative Site No. 9 is closer to nearby sensitive receptors than the proposed Project and would thereby have an increased potential to expose nearby odor - sensitive uses to substantial offensive odor levels during worst -case accident conditions. However, with mitigation (i.e., Mitigation Measure MM 3.1 -1), long -term odor related impacts would be reduced to less than significant levels. Total construction air quality /greenhouse gas emissions would be increased under this alternative in comparison to the proposed Project due to a longer construction period, although average daily construction emissions would be similar to the proposed Project and would not be significant. In addition, construction noise levels would be greater under this alternative due to the closer proximity of residential land uses; however, construction noise impacts would be regarded as less than significant following mitigation, as with the proposed Project. Less than significant impacts related near -term water quality and hydrology would be slightly increased under this alternative, while impacts to noise (long - term), utilities and service systems, and water quality and hydrology (long -term) would be similar to the proposed Project and would be less than significant. 3.4.11.3 Finding and Rationale for Alternative Site No. 9 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 9 infeasible. San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -21 CEQA Findings of Fact /Statement of Overriding Considerations AWQ%� Chapter 3 Findings Regarding Project Alternathes Attachment °A" Alternative Site No. 9 would result in an overall increase in impacts to transportation /traffic as compared to the proposed Project. Although this alternative would avoid the proposed Project's significant and unavoidable impact to the south Bristol Street /West Segerstrom Avenue during the five weeks in which Construction Configuration C.2 would be in place, this alternative would result in a LOS deficiency that would occur for approximately 29 days during construction, would result in new significant unavoidable impacts due to the disruption of left -turn movements along South Bristol Street, and also would result in a new significant and unavoidable impact to parking (near- and long- term) that would not occur in association with the proposed Project. In light of these considerations, the City finds that Alternative Site No. 9 would result in an overall increase in near -term impacts to transportation /traffic, and rejects this alternative as infeasible because it would not avoid or substantially lessen the Project's effects. (CEQA Guidelines Section 15126.6(b).), This alternative also is rejected as infeasible because it would fail to meet, or would not be as effective in achieving, the proposed Project's objectives. This alternative would be less effective than the proposed Project in minimizing odor - related nuisances to land uses in close proximity. In addition, this alternative would exacerbate an existing parking deficiency at an existing medical complex, and would therefore fail to meet the Project's objective of avoiding detrimental effects to existing businesses. Detrimental effects to business would be further exacerbated by ongoing construction in close proximity to the existing medical complex. Further, unlike the proposed Project site where the City has an existing sewer easement, construction at this location would require the City to acquire private property to provide easements for proposed sewer lines. Finally, construction of the lift station at this location would replace currently developed, useable land, in contrast to the proposed Project site, which is vacant and undeveloped. 3.4.12 Alternative Site Location No. 10 (Alternative Site No. 10) 3.4.12.1 Summary of Alternative Site No. 10 Alternative Site Location Number 10 (Alternative Site No. 10) would involve the construction of a replacement lift station in the parking lot of an existing medical building located at 2700 South Bristol Street in lieu of the proposed Project site. Alternative Site No. 10 is located approximately 0.25 -mile north of the proposed Project site. The location of Alternative Site No. 10 is depicted on Final EIR Figure 5 -1. Due to the existing configuration of this site and in order to minimize disruptions to the existing use during construction and long -term operation, it is assumed that a replacement lift station at this location would need to be located along or near the western property line. The lift station that would be constructed at Alternative Site No. 10 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 10 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the installation and operation of approximately 23 percent more underground sewer conveyance infrastructure than the proposed Project and it is anticipated that the duration of Construction Phase 1 I would be increased by 13 work days (approximately 2.5 weeks) as compared to the proposed Project. The construction schedule for this alternative would otherwise be similar to the proposed Project. This alternative would not require construction activities within the South Bristol Street/West Segerstrom Avenue intersection or beneath the existing paved right -of -way of West Segerstrom Avenue (east of South Bristol Street). Therefore, this alternative would not require the San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -22 CEQA Findings of Fact/Statement of Overriding Considerations 55A -61 Chapter 3 Findings Regarding Project Affernattites Attachment "A" implementation of Construction Configurations B.1, B.2, CA, and C.2. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the Project (i.e., to the north of the existing Segerstrom Lift Station). Due to existing utility constraints beneath South Bristol Street, portions of this roadway would need to be closed to accommodate construction associated with this alternative, which has the potential to result in adverse effects to vehicular circulation. Specifically, this segment of South Bristol Street contains a 20 -inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16 -inch water main, and a SCE/MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 feet, and this depth would increase with distance from the existing facility. Construction along this segment of South Bristol Street likely would require supporting the utilities from the top of the trench or the use of trench boxes /shields. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. Development of a lift station at Alternative Site No. 10 also would require the City to acquire private property to implement a temporary construction easement, accommodate the proposed lift station, and provide easements for proposed sewer lines. 3.4.12.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 10 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.12. This alternative would avoid the proposed Project's significant and unavoidable impact associated with Construction Configuration C.2; however, this alternative would create a significant and unmitigable near -term impact to transportation /traffic due to a LOS deficiency that would occur for approximately 33 days during construction, which is an increase in duration as compared to the twenty -five (25) days of construction during which the proposed Project would create a significant unavoidable impact to transportation /traffic at the South Bristol Street /West Segerstrom Avenue intersection. Significant and unavoidable impacts to transportation /traffic would also occur when construction activities disrupt left -turn movements, thereby diverting traffic to adjacent intersections or encouraging cut - through traffic in local neighborhoods; such impacts would not occur in association with the proposed Project. Mitigation for left -turn movement disruptions is not available since the existing parcels along South Bristol Street have limited access points that cannot be replaced. Furthermore, construction of a lift station at Alternative Site No. 10 would also result in inadequate parking capacity at an existing medical office building both during construction and long -term operation. Near- and long -term impacts to parking at Alternative Site No. 10 would be a significant and unmitigable impact. As such, impacts to transportation /traffic would be greater at Alternative Site No. 10 as compared to the proposed Project site. All other direct and cumulative near -term impacts to transportation /traffic would be less than significant and similar to the proposed Project. This alternative also would result in an increase in the severity of the Project's significant long -term air quality impact because Alternative Site No. 10 is closer to nearby sensitive receptors than the proposed Project and would thereby have an increased potential to expose nearby odor - sensitive uses to substantial offensive odor levels during worst -case accident conditions. However, long -term odor impacts would be reduced to less than significant levels with incorporation of Mitigation Measure MM 3.1 -1. Although total construction air quality /greenhouse gas emissions would be increased under this alternative due to a slightly elongated construction period, impacts would be less than significant since average daily construction emissions would be below SCAQMD thresholds, as with San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -23 CEQA Findings of Fact /Statement of Overriding Considerations M, * Chapter 3 Findings Regarding Project Alternathres Attachment 'A" the proposed Project. In addition, construction noise levels would be greater under this alternative due to the closer proximity of residential land uses; however, construction noise impacts would be regarded as less than significant as with the proposed Project. Impacts related near -term water quality and hydrology would be slightly increased under this alternative (though such impacts would not be significant), while impacts to noise (long - term), utilities and service systems, and water quality and hydrology (long -term) would be similar to the proposed Project. 3.4.12.3 Finding and Rationale for Alternative Site No. 10 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 10 infeasible. Alternative Site No. 10 would result in an overall increase in impacts to transportation /traffic as compared to the proposed Project. Although this alternative would avoid the proposed Project's significant and unavoidable impact to the south Bristol Street /West Segerstrom Avenue during the five weeks in which Construction Configuration C.2 would be in place, this alternative would result in a LOS deficiency that would occur for approximately 33 days during construction, would result in new significant unavoidable impacts due to the disruption of left -turn movements along South Bristol Street, and also would result in a new significant and unavoidable impact to parking (near- and long- term) that would not occur in association with the proposed Project. In light of these considerations, the City finds that Alternative Site No. 10 would result in an overall increase in near -term impacts to transportation /traffic, and rejects this alternative as infeasible because it would not avoid or substantially lessen any significant effects of the Project. (CEQA Guidelines Section 15126.6(b).) This alternative also is rejected as infeasible because it would fail to meet, or would not be as effective in achieving, the proposed Project's objectives. This alternative would not be as effective in achieving the Project's objective to minimize odor - related nuisances to land uses in close proximity. In addition, this alternative would result in inadequate parking at an existing medical office building, and would, therefore, fail to meet the proposed Project's objective of avoiding detrimental effects to existing businesses. Detrimental effects to business would be further exacerbated by ongoing construction in close proximity to the existing medical office building. Further, unlike the proposed Project site where the City has an existing sewer easement, construction at this location would require the City to acquire private property to provide easements for proposed sewer lines. Finally, construction of the lift station at this location would replace currently developed, useable land, in contrast to the proposed Project site, which is vacant and undeveloped. 3.4.13 Alternative Site Location No. 11 (Alternative Site No. 11) 3.4.13.1 Summary of Alternative Site No. 11 Alternative Site Location Number 11 (Alternative Site No. 11) would involve the construction of a replacement lift station in the parking lot of an existing medical building located at 2650 South Bristol Street in lieu of the proposed Project site. Alternative Site No. 11 is located approximately 0.27 -mile north of the proposed Project site. The location of Alternative Site No. 11 is depicted on Final EIR Figure 5 -1. Due to the existing configuration of this site and in order to minimize disruptions to the existing use during construction and long -term operation, it is assumed that a replacement lift station at this location would need to be located along or near the western property line. San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -24 CEQA Findings of Fact /Statement of Overriding Considerations 'ti Chapter 3 Findings Regarding Project Aitemathes Attachment `A° The lift station that would be constructed at Alternative Site No. 11 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 11 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the installation and operation of approximately 32 percent more underground sewer conveyance infrastructure than the proposed Project and it is anticipated that the duration of Construction Phase 11 would be increased by 16 work days (approximately three weeks) as compared to the Project. The construction schedule for this alternative would otherwise be similar to the Project. This alternative would not require construction activities within the South Bristol Street/West Segerstrom Avenue intersection or beneath the existing paved right -of -way of West Segerstrom Avenue (east of South Bristol Street). Therefore, this alternative would not require the implementation of Construction Configurations B.1, B.2, C.1, or C.2. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the Project (i.e., to the north of the existing Segerstrom Lift Station). Due to existing utility constraints beneath South Bristol Street, portions of this roadway would need to be closed to accommodate construction associated with this alternative, which has the potential to result in adverse effects to vehicular circulation. Specifically, the segment of South Bristol Street between this site and the existing lift station facility contains a 20 -inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16 -inch water main, and a SCE /MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 feet, and this depth would increase with distance from the existing facility. Construction along this segment of South Bristol Street likely would require supporting the utilities from the top of the trench and/or the use of trench boxes /shields. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. Development of a lift station at Alternative Site No. I 1 also would require the City to acquire private property to implement a temporary construction easement, accommodate the proposed lift station, and provide easements for proposed sewer lines. 3.4.13.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 11 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.13. This alternative would avoid the proposed Project's significant and unavoidable impact associated with Construction Configuration C.2; however, this alternative would create a significant and immitigable near -term impact to transportation /traffic due to a LOS deficiency that would occur for approximately 36 days during construction, which is an increase in duration as compared to the twenty -five (25) days of construction during which the proposed Project would create a significant unavoidable impact to transportation /traffic at the South Bristol Street /West Segerstrom Avenue intersection. Significant and unavoidable impacts to transportation /traffic would also occur when construction activities disrupt left -turn movements, thereby diverting traffic to adjacent intersections or encouraging cut - through traffic in local neighborhoods; such impacts would not occur in association with the proposed Project. Furthermore, construction of a lift station at Alternative Site No. 11 would also result in inadequate parking capacity at an existing medical office building both during construction and long -term operation. Near- and long -term impacts to parking at Alternative Site No. 11 would be a significant and San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -25 CEQA Findings of Fact/Statement of Overriding Considerations 55A -64 Chapter 3 Findings Regarding ProjectAlternathres Attachment "A" unmitigable impact. As such, impacts to transportation /traffic would be greater at Alternative Site No. 11 as compared to the proposed Project site. This alternative also would result in an increase in the severity of the Project's significant (but mitigable) long -term air quality impact because relocating the proposed lift station to Alternative Site No. 11 is closer to nearby sensitive receptors than the proposed Project and would thereby have an increased potential to expose nearby odor - sensitive uses to substantial offensive odor levels during both normal operation and worst -case accident conditions. Odor impacts associated with this alternative would, however, be reduced to less than significant levels with mitigation (i.e., Mitigation Measure MM 3.1 -1). Total aggregate construction air quality/greenhouse gas emissions would be increased under this alternative due to a slightly elongated construction period, although average daily construction emissions would be less than significant and similar to the proposed Project. In addition, construction noise levels would be greater under this alternative due to the close proximity of residential land uses; however, construction noise impacts would be regarded as less than significant as with the proposed Project. Impacts related near -term water quality and hydrology would be slightly increased under this alternative but would remain below a level of significance, while impacts to noise (long - term), utilities and service systems, and water quality and hydrology (long -term) would be similar to the proposed Project and would be less than significant. 3.4.13.3 Finding and Rationale for Alternative Site No. 1 1 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 10 infeasible. Alternative Site No. 11 would result in an overall increase in impacts to transportation /traffic as compared to the proposed Project. Although this alternative would avoid the proposed Project's significant and unavoidable impact to the south Bristol Street /West Segerstrom Avenue during the five weeks in which Construction Configuration C.2 would be in place, this alternative would result in a LOS deficiency that would occur for approximately 36 days during construction, would result in new significant unavoidable impacts due to the disruption of left -turn movements along South Bristol Street, and also would result in a new significant and unavoidable impact to parking (near- and long- term) that would not occur in association with the proposed Project. In light of these considerations, the City finds that Alternative Site No. 10 would result in an overall increase in near -term impacts to transportation /traffic, and rejects this alternative as infeasible because it would not avoid or substantially lessen any of the significant effects of the Project. (CEQA Guidelines Section 15126.6(b).) This alternative also is rejected as infeasible because it would fail to meet, or would not be as effective in achieving, the proposed Project's objectives. This alternative would not be as effective in achieving the proposed Project's objective to minimize odor - related nuisances to land uses in close proximity. In addition, this alternative would result in inadequate parking at an existing medical office building, and would therefore fail to meet the proposed Project's objective of avoiding detrimental effects to existing businesses. Detrimental effects to business would be further exacerbated by ongoing construction in close proximity to the existing medical office building. Further, unlike the proposed Project site where the City has an existing sewer easement, construction at this location would require the City to acquire private property to provide easements for proposed sewer lines. Finally, construction of the lift station at this location would replace currently developed, useable land, in contrast to the proposed Project site, which is vacant and undeveloped. San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -26 CEQA Findings of Fact /Statement of Overriding Considerations 55A -65 Chapter 3 Findings Regarding Project Alternatives Attachment 'A" 3.4.14 Alternative Site Location No. 12 (Alternative Site No. 12) 3.4.14.1 Summary of Alternative Site No. 12 Alternative Site Location Number 12 (Alternative Site No. 12) would involve the construction of a replacement lift station within the parking lot of an existing medical complex located at approximately 2701 South Bristol Street instead of at the proposed Project site. It should be noted that although construction of a replacement lift station at Alternative Site No. 12 could occur anywhere within the block bounded by South Bristol Street, Hemlock Way, Central Avenue, and Baker Street, with exception of the existing AutoZone use at the northwestern corner of the site and the existing residential uses abutting Baker Street, for purposes of analysis it is assumed that the replacement lift station would be constructed in the southwestern portion of the block (i.e., near the intersection of Hemlock and South Bristol). Alternative Site No. 12 is located approximately 0.15 - mile north of the proposed Project site. The location of Alternative Site No. 12 is depicted on Final EIR Figure 5 -1. The lift station that would be constructed at Alternative Site No. 12 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 12 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the installation and operation of approximately 42 percent less underground sewer conveyance infrastructure than the proposed Project; however, the segment of South Bristol Street between this site and the existing lift station facility contains a 20 -inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16 -inch water main, and a SCE/MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 feet, and this depth would increase with distance from the existing facility. Construction along this segment of South Bristol Street likely would require supporting the utilities from the top of the trench and /or the use of trench boxes /shields, which would elongate the construction schedule. Due to these constraints, it is anticipated that the duration of Construction Phase 11 would be increased by two (2) work days (approximately 0.5 week) as compared to the proposed Project. However, this alternative would not require the construction of a sewer bypass during Phase 2 of construction, thereby shortening that phase of construction by up to two (2) weeks. The construction schedule for this alternative would otherwise be similar to the proposed Project. This alternative would not require construction activities within the South Bristol Street/West Segerstrom Avenue intersection or beneath the existing paved right -of -way of West Segerstrom Avenue (east of South Bristol Street). Therefore, this alternative would not require the implementation of Construction Configurations B.1, B.2, C.1, or C.2. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the Project (i.e., to the north of the existing Segerstrom Lift Station). Due to the existing utility constraints beneath South Bristol Street (described above), portions of this roadway would need to be closed to accommodate construction associated with this alternative, which has the potential to result in adverse effects to vehicular circulation. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. Development of a lift station at Alternative Site No. 12 also would require the City to acquire private property to implement a temporary construction easement, accommodate the proposed lift station, and provide easements for proposed sewer lines. San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -27 CEQA Findings of Fact/Statement of Overriding Considerations A ' ' :Te Chapter 3 Findings Regarding Project Alternathes Attachment "A° 3.4.14.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 12 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.14. Alternative Site No. 12 would avoid the proposed Project's significant and unavoidable impact associated with Construction Configuration C.2; however, this alternative would create a significant and immitigable near -term impact to transportation /traffic due to a LOS deficiency that would occur for approximately twenty-two (22) days during construction, which is a slight decrease in duration as compared to the twenty-five (25) days of construction during which the proposed Project would create a significant unavoidable impact to transportation /traffic at the South Bristol Street /West Segerstrom Avenue intersection. Impacts to transportation /traffic would also occur when construction activities disrupt left -turn movements, thereby diverting traffic to adjacent intersections or encouraging cut - through traffic in local neighborhoods; such impacts would not occur in association with the proposed Project and would represent a new significant and unavoidable impact to traffic /transportation. Furthermore, construction of a lift station at Alternative Site No. 12 would exacerbate an existing parking deficiency at an existing medical complex both during construction and long -term operation. Near- and long -term impacts to parking at Alternative Site No. 12 would be a significant and unmitigable impact. Since this alternative would significantly impact traffic along South Bristol Street and would significantly impact parking, impacts to transportation /traffic would be greater at Alternative Site No. 12 as compared to the proposed Project site. Total construction air quality/greenhouse gas emissions would be slightly reduced under this alternative due to a slightly reduced construction period, although average daily construction emissions would be similar to the proposed Project and would not be significant. Near -term nighttime construction noise and long -term odor impacts are assumed to be slightly reduced under this alternative, but as with the proposed Project these effects would be reduced to less than significant levels with incorporation of mitigation. Impacts related to near -term water quality and hydrology also would be slightly decreased under this alternative due to a smaller area of impact, although as with the proposed Project such impacts would be less than significant. Impacts related to operational noise, utilities and service systems, and water quality and hydrology (long -term) would be similar to the proposed Project and would be less than significant. 3.4.14.3 Finding and Rationale for Alternative Site No. 12 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 12 infeasible. Alternative Site No. 12 would result in an overall increase in impacts to transportation /traffic as compared to the proposed Project. Although this alternative would avoid the proposed Project's significant and unavoidable impact to the south Bristol Street/West Segerstrom Avenue during the five weeks in which Construction Configuration C.2 would be in place, this alternative would result in a LOS deficiency that would occur for approximately 22 days during construction, would result in new significant unavoidable impacts due to the disruption of left -turn movements along South Bristol Street, and also would result in a new significant and unavoidable impact to parking (near- and long- term). Impacts to parking and turn movements would not occur in association with the proposed Project. In light of these considerations, the City finds that Alternative Site No. 12 would result in an overall increase in near -term impacts to transportation /traffic, and rejects this alternative as infeasible San Lorenzo Lift Station FIR (Project No. 06 -3510) 3 -28 CEQA Findings of Fact /Statement of Overriding Considerations 55A -67 Chapter 3 Findings Regarding Project Allernathres Attachment 'A" because it would not substantially lessen any significant effects of the Project. (CEQA Guidelines Section 15126.6(b).) This alternative also is rejected as infeasible because it would fail to meet, or would not be as effective in achieving, the proposed Project's objectives. This alternative would exacerbate an existing parking deficiency at an existing medical complex and would interfere with access to this site during construction, and would therefore fail to meet the Project's objective of avoiding detrimental effects to existing businesses. Detrimental effects to business would be further exacerbated by ongoing construction in close proximity to the existing medical complex. Further, unlike the proposed Project site where the City has an existing sewer easement, construction at this location would require the City to acquire private property to provide easements for proposed sewer lines. Finally, construction of the lift station at this location would replace currently developed, useable land, in contrast to the proposed Project site, which is vacant and undeveloped. 3.4.15 Alternative Site Location No. 13 (Alternative Site No. 13) 3.4.15.1 Summary of Alternative Site No. 13 Alternative Site Location Number 13 (Alternative Site No. 13) would involve the construction of a replacement lift station in the parking lot of an existing commercial building located at approximately 2449 South Bristol Street in lieu of the proposed Project site. Alternative Site No. 13 is located in the same general shopping center as Alternative Site Nos. 14 and 15, which is generally bounded by Central Avenue on the South, Bristol Street on the West, and Warner Avenue on the north. Alternative Site No. 13 would be located in the south - central portion of this shopping center, just northerly of El Polio Loco (2501 South Bristol Street). Alternative Site No. 13 is located approximately 0.40 -mile north of the proposed Project site. The location of Alternative Site No. 13 is depicted on Final EIR Figure 5 -1. The lift station that would be constructed at Alternative Site No. 13 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 13 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the installation and operation of approximately 65 percent more underground sewer conveyance infrastructure than the proposed Project and it is anticipated that the duration of Construction Phase 11 would be increased by 34 work days (approximately seven weeks) as compared to the proposed Project. The construction schedule for this alternative would otherwise be similar to the proposed Project. This alternative would not require construction activities within the South Bristol Street/West Segerstrom Avenue intersection or beneath the existing paved right -of -way of West Segerstrom Avenue (east of South Bristol Street). Therefore, this alternative would not require the implementation of Construction Configurations B.1, B.2, C.1, or C.2. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the Project (i.e., to the north of the existing Segerstrom Lift Station). The segment of South Bristol Street between this site and the existing lift station facility contains a 20 -inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16 -inch water main, and a SCE/MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 feet, and this depth would increase with distance from the existing facility. Construction along this segment of South Bristol Street would require supporting the utilities from the top of the trench San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -29 CEQA Findings of Fact/Statement of Overriding Considerations *�_Q:Ofel Chapter 3 Findings Regarding Project Alternatives Attachment "A" and /or the use of trench boxes /shields, which would elongate the construction schedule. Due to these existing utility constraints beneath South Bristol Street, portions of this roadway would need to be closed to accommodate construction associated with this alternative, which has the potential to result in adverse effects to vehicular circulation. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. Development of a lift station at Alternative Site No. 13 also would require the City to acquire private property to implement a temporary construction easement, accommodate the proposed lift station, and provide easements for proposed sewer lines. 3.4.15.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 13 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.15. This alternative would avoid the Project's significant and unavoidable impact associated with Construction Configuration C.2; however, this alternative would create a significant and immitigable near -term impact to transportation /traffic due to a LOS deficiency that would occur for approximately 65 days during construction, which is an increase in duration as compared to the twenty-five (25) days of construction during which the proposed Project would create a significant unavoidable impact to transportation /traffic at the South Bristol Street /West Segerstrom Avenue intersection. Impacts to transportation /traffic would also occur when construction activities disrupt left -turn movements, thereby diverting traffic to adjacent intersections or encouraging cut - through traffic in local neighborhoods; such impacts would not occur in association with the proposed Project and would represent a new significant and unavoidable impact to traffic /transportation. As such, impacts to traffic and circulation would be greater at Alternative Site No. 13 as compared to the proposed Project site. Mitigation would not be available to reduce these effects to less than significant levels, as it is not possible to construct this alternative without affecting the travel lanes within South Bristol Street, and the ability to make left turns along South Bristol Street during construction. Total construction air quality/greenhouse gas emissions would be increased under this alternative due to a longer construction period, although average daily construction emissions would be similar to the proposed Project and would be less than significant. In addition, construction - related impacts to water quality and hydrology would be increased under this alternative due to a larger area of impact, although such effects would be less than significant with mandatory regulatory compliance. Long- term odor impacts associated with accident conditions and near -term noise impacts associated with nighttime dewatering activities would be slightly decreased under this alternative, due to the increased distance to nearby sensitive receptors, although as with the proposed Project such effects would be less than significant (with implementation of Mitigation Measures MMs 3.1 -1, 3.3 -1, and 3.3 -2). Impacts related to noise, utilities and service systems, and water quality and hydrology (long- term) would be similar to the proposed Project and would be less than significant. 3.4.15.3 Finding and Rationale for Alternative Site No. 13 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 13 infeasible. Alternative Site No. 13 would result in an overall increase in impacts to transportation /traffic as compared to the proposed Project. Although this alternative would avoid the proposed Project's San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -30 CEQA Findings of Fact/Statement of Overriding Considerations A �Y" U, Chapter 3 Findings Regarding Project Affernathes Attachment "A" significant and unavoidable impact to the south Bristol Street/West Segerstrom Avenue during the five weeks in which Construction Configuration C.2 would be in place, this alternative would result in a LOS deficiency that would occur for approximately 65 days during construction, and would result in new significant unavoidable impacts due to the disruption of left -turn movements along South Bristol Street. Impacts to turn movements would not occur in association with the proposed Project. In light of these considerations, the City finds that Alternative Site No. 13 would result in an overall increase in near -term impacts to transportation /traffic, and rejects this alternative as infeasible because it would not substantially lessen any significant effects of the Project. (CEQA Guidelines Section 15126.6(b).) This alternative also is rejected as infeasible because it would fail to meet, or would not be as effective in achieving the proposed Project's objectives. This alternative would cause serious disruptions to existing business along South Bristol Street due to the need to construct sewer lines near the median, and would further disrupt the businesses within the shopping complex where this alternative site is located. This alternative would therefore fail to meet the proposed Project's objective of avoiding detrimental effects to existing businesses. 3.4.16 Alternative Site Location No. 14 (Alternative Site No. 14) 3.4.16.1 Summary of Alternative Site No. 14 Alternative Site Location Number 14 (Alternative Site No. 14) would involve the construction of a replacement lift station in the parking lot of an existing commercial complex located at southeast corner of the intersection of South Bristol Street and West Warner Avenue in lieu of the proposed Project site. Alternative No. 14 is located in the same general shopping center as Alternative Site Nos. 13 and 15, and would be constructed just northerly of the Chase Bank (2407 South Bristol Street). Alternative Site No. 14 is located approximately 0.50 -mile north of the proposed Project site. The location of Alternative Site No. 14 is depicted on Final EIR Figure 5 -1. The lift station that would be constructed at Alternative Site No. 14 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 14 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the installation and operation of approximately 112 percent more underground sewer conveyance infrastructure than the proposed Project and it is anticipated that the duration of Construction Phase 11 would be increased by 64 work days (approximately 13 weeks) as compared to the proposed Project. The construction schedule for this alternative would otherwise be similar to the proposed Project. This alternative would not require construction activities within the South Bristol Street/West Segerstrom Avenue intersection or beneath the existing paved right -of -way of West Segerstrom Avenue (east of South Bristol Street). Therefore, this alternative would not require the implementation of Construction Configurations B.1, B.2, C.1, or C.2. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the proposed Project (i.e., to the north of the existing Segerstrom Lift Station). The segment of South Bristol Street between this site and the existing lift station facility contains a 20 -inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16- inch water main, and a SCE /MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 feet, and this depth would increase with distance from the existing facility. San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -31 CEQA Findings of Fact/Statement of Overriding Considerations 55A -70 Chapter 3 Findings Regarding ProjectAitemathres Attachment W Construction along this segment of South Bristol Street would require supporting the utilities from the top of the trench and /or the use of trench boxes /shields, which would elongate the construction schedule. Due to these existing utility constraints beneath South Bristol Street, portions of this roadway would need to be closed to accommodate construction associated with this alternative, which has the potential to result in adverse effects to vehicular circulation. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. Development of a lift station at Alternative Site No. 14 also would require the City to acquire private property to implement a temporary construction easement, accommodate the proposed lift station, and provide easements for proposed sewer lines. 3.4.16.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 14 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.16. This alternative would avoid the Project's significant and unavoidable impact associated with Construction Configuration C.2; however, this alternative would create a significant and unavoidable near -term impact to transportation /traffic due to a LOS deficiency that would occur for approximately 84 days during construction, which is an increase in duration as compared to the twenty-five (25) days of construction during which the proposed Project would create a significant unavoidable impact to transportation /traffic at the South Bristol Street/West Segerstrom Avenue intersection. Impacts to transportation /traffic would also occur when construction activities disrupt left -turn movements, thereby diverting traffic to adjacent intersections or encouraging cut - through traffic in local neighborhoods; such impacts would not occur in association with the proposed Project. As such, impacts to transportation /traffic would be greater at Alternative Site No. 14 as compared to the proposed Project site, and mitigation would not be available to reduce these effects to less than significant levels, as there is no way to construct this alternative without affecting the travel lanes within South Bristol Street, and because there is no way to avoid affecting left turns along South Bristol Street during construction. Total construction air quality/greenhouse gas emissions would be increased under this alternative due to a longer construction period, although average daily construction emissions would be similar to the proposed Project and impacts would be less than significant. In addition, construction - related impacts to water quality and hydrology would be increased under this alternative due to a larger area of impact, but would remain below a level of significance. Long -term odor impacts associated with accident conditions and near -term noise impacts associated with nighttime dewatering activities would be slightly decreased under this alternative, due to the increased distance to nearby sensitive receptors, although as with the proposed Project impacts would be reduced to less than significant levels with implementation of Mitigation Measures MM 3.3 -1 and 3.3 -2. Impacts related to noise, utilities and service systems, and water quality and hydrology (long -term) would be similar to the proposed Project and would be less than significant. 3.4.16.3 Finding and Rationale for Alternative Site No. 14 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 14 infeasible. Alternative Site No. 14 would result in an overall increase in impacts to transportation /traffic as compared to the proposed Project. Although this alternative would avoid the proposed Project's San Lorenzo Lift Station EIR (Project No. 06 -3510) CEQA Findings of Fact /Statement of Overriding Considerations 55A -71 3 -32 Chapter 3 Findings Regarding Protect Altematives Attachment "A" significant and unavoidable impact to the south Bristol Street/West Segerstrom Avenue during the five weeks in which Construction Configuration C.2 would be in place, this alternative would result in a LOS deficiency that would occur for approximately 84 days during construction, and would result in new significant unavoidable impacts due to the disruption of left -turn movements along South Bristol Street. Impacts to turn movements would not occur in association with the proposed Project. In light of these considerations, the City finds that Alternative Site No. 14 would result in an overall increase in near -term impacts to transportation /traffic, and rejects this alternative as infeasible because it would not avoid or substantially lessen any significant effects of the Project. (CEQA Guidelines Section 15126.6(b).) This alternative also is rejected as infeasible because it would fail to meet, or would not be as effective in achieving, the proposed Project's objectives. This alternative would cause serious disruptions to existing business along South Bristol Street due to the need to construct sewer lines near the median, and would further disrupt the businesses within the shopping complex where this alternative site is located, and would therefore fail to meet the proposed Project's objective of avoiding detrimental effects to existing businesses. 3.4.17 Alternative Site Location No. 15 (Alternative Site No. 15) 3.4.17.1 Summary of Alternative Site No. 15 Alternative Site Location Number 15 (Alternative Site No. 15) would involve the construction of a replacement lift station in the parking lot of an existing commercial complex located at southeast corner of the intersection of South Bristol Street and West Warner Avenue in lieu of the proposed Project site. Alternative No. 15 is located in the same general shopping center as Alternative Site Nos. 13 and 14, and would be constructed near the existing Starbucks, located at the corner of South Bristol Street /West Warner Avenue. Alternative Site No. 15 is located approximately 0.50 -mile north of the proposed Project site. The location of Alternative Site No. 15 is depicted on Final EIR Figure 5 -1. The lift station that would be constructed at Alternative Site No. 15 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 15 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the installation and operation of 123 percent more underground sewer conveyance infrastructure than the proposed Project and it is anticipated that the duration of Construction Phase 11 would be increased by 70 work days (approximately 14 weeks) as compared to the proposed Project. The construction schedule for this alternative would otherwise be similar to the proposed Project. This alternative would not require construction activities within the South Bristol Street/West Segerstrom Avenue intersection or beneath the existing paved right -of -way of West Segerstrom Avenue (east of South Bristol Street). Therefore, this alternative would not require the implementation of Construction Configurations B.1, B.2, C.1, or C.2. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the Project (i.e., to the north of the existing Segerstrom Lift Station). The segment of South Bristol Street between this site and the existing lift station facility contains a 20 -inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16 -inch water main, and a SCE/MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -33 CEQA Findings of Fact /Statement of Overriding Considerations 55A -72 Chapter 3 Findings Regarding ProjectAffernatlhres Attachment "A" feet, and this depth would increase with distance from the existing facility. Construction along this segment of South Bristol Street would require supporting the utilities from the top of the trench and /or the use of trench boxes /shields, which would elongate the construction schedule. Due to these existing utility constraints beneath South Bristol Street, portions of this roadway would need to be closed to accommodate construction associated with this alternative, which has the potential to result in adverse effects to vehicular circulation. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. Development of a lift station at Alternative Site No. 15 also would require the City to acquire private property to implement a temporary construction easement, accommodate the proposed lift station, and provide easements for proposed sewer lines. 3.4.17.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 15 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.17. This alternative would avoid the Project's significant and unavoidable impact associated with Construction Configuration C.2; however, this alternative would create a significant and immitigable near -term impact to transportation /traffic due to a LOS deficiency that would occur for approximately 90 days during construction, which is an increase in duration as compared to the twenty -five (25) days of construction during which the proposed Project would create a significant unavoidable impact to transportation /traffic at the South Bristol Street/West Segerstrom Avenue intersection. Impacts to transportation /traffic would also occur when construction activities disrupt left -turn movements, thereby diverting traffic to adjacent intersections or encouraging cut - through traffic in local neighborhoods; such impacts would not occur in association with the proposed Project. As such, impacts to transportation /traffic would be greater at Alternative Site No. 14 as compared to the proposed Project site, and mitigation would not be available to reduce these effects to less than significant levels, as there is no way to construct this alternative without affecting the travel lanes within South Bristol Street, and because there is no way to avoid affecting left turns along South Bristol Street during construction. Total construction air quality /greenhouse gas emissions would be increased under this alternative due to a longer construction period, although average daily construction emissions would be similar to the proposed Project and would be less than significant. In addition, construction - related impacts to water quality and hydrology would be increased under this alternative due to an increased area of impact, although such impacts would be less than significant. Long -term odor impacts associated with accident conditions and near -term noise impacts associated with nighttime dewatering activities would be slightly decreased under this alternative, due to the increased distance to nearby sensitive receptors, although as with the proposed Project such impacts would be less than significant due to implementation of Mitigation Measures MM 3.3 -1 and 3.3 -2. Impacts related to noise, utilities and service systems, and water quality and hydrology (long -term) would be similar to the proposed Project and would be less than significant. 3.4.17.3 Finding and Rationale for Alternative Site No. 15 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 15 infeasible. San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -34 CEQA Findings of Fact/Statement of Overriding Considerations 55A -73 Chapter 3 Findings Regarding ProlectAilernathres Attachment "A" Alternative Site No. 15 would result in an overall increase in impacts to transportation /traffic as compared to the proposed Project. Although this alternative would avoid the proposed Project's significant and unavoidable impact to the south Bristol Street/West Segerstrom Avenue during the five weeks in which Construction Configuration C.2 would be in place, this alternative would result in a LOS deficiency that would occur for approximately 90 days during construction, and would result in new significant unavoidable impacts due to the disruption of left -turn movements along South Bristol Street. Impacts to turn movements would not occur in association with the proposed Project. In light of these considerations, the City finds that Alternative Site No. 15 would result in an overall increase in near -term impacts to transportation /traffic, and rejects this alternative as infeasible because it would not avoid or substantially lessen any of the significant effects of the Project. (CEQA Guidelines Section 15126.6(b).) This alternative also is rejected as infeasible because it would fail to meet or would not be as effective in achieving the proposed Project's objectives. This alternative would cause serious disruptions to existing business along South Bristol Street due to the need to construct sewer lines near the median, and would further disrupt the businesses within the shopping complex where this alternative site is located. This alternative would therefore fail to meet the Project's objective of avoiding detrimental effects to existing businesses. 3.4.18 Alternative Site Location No. 16 (Alternative Site No. 16) 3.4.18.1 Summary of Alternative Site No. 16 Alternative Site Location Number 16 (Alternative Site No. 16) would involve the construction of a new replacement lift station within an existing City park (Carl Thornton Park) located at 1801 West Segerstrom Avenue in lieu of the proposed Project site. Alternative Site No. 16 is located approximately 0.4 -mile west of the proposed Project site. The location of Alternative Site No. 16 is depicted on Final EIR Figure 5 -1. Development of a lift station at Alternative Site No. 16 would occur wholly within an existing City - owned park; therefore, this alternative would not require the acquisition of private property. The lift station that would be constructed at Alternative Site No. 16 would include an above - ground block structure similar to the proposed Project. In addition, the lift station at Alternative Site No. 16 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the installation and operation of approximately 208 percent more underground sewer conveyance infrastructure than the proposed Project. The duration of Construction Phase 11 would be increased as compared to the Project, to accommodate the construction of additional underground sewer conveyance infrastructure. Although the acquisition of private property that would occur as part of the proposed Project would not result in a significant environmental effect, relocation of the proposed lift station to Alternative Site No. 16 was selected for consideration to allow decision - makers to compare the impact of the proposed Project against the impact of an alternative that would not require the acquisition of private property. 3.4.18.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 16 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.18. Relocating the proposed lift station to Alternative Site No. 16 would slightly San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -35 CEQA Findings of Fact /Statement of Overriding Considerations 55A -74 Chapter 3 Findings Regarding Project Aitemathres Attachment "A" increase the duration of the proposed Project's near -term significant and unavoidable construction - related impact at the intersection of South Bristol Street and West Segerstrom Avenue, which would occur between the hours of 7:15 a.m. and 8:00 a.m. and between the hours of 2:30 p.m. and 6:45 p.m. (Monday through Friday). In addition, development of a lift station at Alternative Site No. 16 would result in a new, significant impact to recreation, as this alternative would reduce park land in the City and would exacerbate an existing deficiency of park and recreation facilities in the City. Construction - related impacts related to air quality/greenhouse gas emissions and hydrology and water quality would be increased under this alternative as compared to the proposed Project, but would be less than significant. Impacts related to air quality/greenhouse gas emissions (long - term), noise, and utilities and service systems would be similar to the proposed Project and would be less than significant, although long -term impacts associated with odors under accident conditions would be slightly reduced under this alternative and would be less than significant with the incorporation of Mitigation Measure MM 3.1 -1 (similar to the proposed Project). 3.4.18.3 Finding and Rationale for Alternative Site No. 16 The City hereby finds that specific economic, legal, social, technological, or other considerations make the Alternative Site No. 16 infeasible. Alternative Site No. 16 would slightly increase by a period of one to two days the Project's near -term significant and unavoidable construction - related impact at the intersection of South Bristol Street and West Segerstrom Avenue, which would occur between the hours of 7:15 a.m. and 8:00 a.m. and between the hours of 2:30 p.m. and 6:45 p.m. (Monday through Friday). This alternative also would introduce new significant and unavoidable impacts to recreation (near- and long -term) that would not occur in association with the proposed Project, and would increase construction- related air quality /greenhouse gas emissions and water quality/hydrology impacts. None of the significant impacts associated with the proposed Project would be avoided or substantially lessened with implementation of this alternative. In light of these considerations, the City rejects Alternative Site No. 16 as infeasible because it would avoid or substantially lessen any of the significant effects of the Project. (CEQA Guidelines Section 15126.6(b).) 3.4.19 Alternative Site Location No. 17 (Alternative Site No. 17) 3.4.19.1 Summary of Alternative Site No. 17 Alternative Site Location Number 17 (Alternative Site No. 17) would involve the construction of a new replacement lift station in the parking lot of an existing commercial office (AT &T) located at 3200 South Bristol Street in lieu of the proposed Project site. Alternative Site No. 17 is located approximately 0.25 -mile southwest of the proposed Project site. The location of Alternative Site No. 17 is depicted on Final EIR Figure 5 -1. In order to minimize disruptions to the existing AT &T building, the replacement lift station would be constructed in the western portion of the parking lot at this site. The lift station that would be constructed at Alternative Site No. 17 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 17 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the installation and operation of approximately 54 percent more underground sewer conveyance infrastructure than the proposed Project and it is anticipated that the duration of Construction Phase I 1 would be increased by 30 work days (approximately four weeks) as compared San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -36 CEQA Findings of Fact/Statement of Overriding Considerations 55A -75 Chapter 3 Findings Regarding Project Aitemath es Attachment "A" to the Project. The construction schedule for this alternative would otherwise be similar to the Project. This alternative would require construction activities within and adjacent to the South Bristol Street /West Segerstrom Avenue intersection; however, the duration of construction activities within the intersection would be reduced to one (1) week under this alternative. Traffic control associated with demolition of the existing lift station facility still would require up to two weeks; accordingly, traffic control within the intersection of South Bristol Street /West Segerstrom Avenue would occur for a total duration of three weeks, rather than the five weeks associated with the proposed Project. In addition, this alternative would not require implementation of Construction Configurations B.1, B.2, or C.1. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the Project (i.e., to the south of the South Bristol Street/West Segerstrom Avenue intersection). The segment of South Bristol Street between this site and the existing lift station facility contains a 20 -inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16 -inch water main, and a SCE /MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 feet, and this depth would increase with distance from the existing facility. Construction along this segment of South Bristol Street would require supporting the utilities from the top of the trench and /or the use of trench boxes /shields, which would elongate the construction schedule. Due to these existing utility constraints beneath South Bristol Street, portions of this roadway would need to be closed to accommodate construction associated with this alternative, which has the potential to result in adverse effects to vehicular circulation. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. Development of a lift station at Alternative Site No. 17 would require the City to acquire private property to accommodate the proposed lift station. In addition, this alternative would require the City to acquire a temporary construction easement to facilitate construction of the proposed lift station. 3.4.19.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 17 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.19. This alternative would reduce the Project's significant and unavoidable impact associated with Construction Configuration C.2 by two weeks; however, this alternative would create a significant and unmitigable near -term impact to the capacity of South Bristol Street for a period of approximately 46 days, which is an increase in duration as compared to the twenty - five (25) days of construction during which the proposed Project would create a significant unavoidable impact to transportation/traffic at the South Bristol Street/West Segerstrom Avenue intersection. As such, impacts to transportation /traffic would be greater at Alternative Site No. 17 as compared to the proposed Project site, and mitigation would not be available to reduce these effects to less than significant levels because there is no way to construct this alternative without impacting travel lanes on South Bristol Street. Furthermore, construction of a lift station at Alternative Site No. 17 would exacerbate an existing parking deficiency at this site both during construction and long- term operation. Near- and long -term impacts to parking at Alternative Site No. 17 would be a significant and immitigable impact. Construction activities at Alternative Site No. 17 also would San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -37 CEQA Findings of Fact/Statement of Overriding Considerations 55A -76 Chapter 3 Findings Regarding Project Altemathtes Attachment 'A' result in a significant and immitigable near -term impact to traffic and circulation due to inadequate emergency access (i.e., Garry Street). As such, impacts to traffic and circulation would be greater at Alternative Site No. 17 as compared to the proposed Project site, and would be significant and unavoidable. This alternative also would result in an increase in the severity of long -term odor impacts as compared to the proposed Project, because Alternative Site No. 17 is located in closer proximity to existing sensitive receptors that could be exposed to odors under accident conditions; however, as with the proposed Project, mitigation would reduce this impact to less than significant levels. In addition, construction noise levels would be greater under this alternative due to the closer proximity of residential land uses; however, construction noise impacts would be mitigated to less than significant levels, as with the proposed Project. Total construction air quality /greenhouse gas emissions would be increased under this alternative due to a longer construction period, although average daily construction emissions would be similar to the proposed Project and would be less than significant. In addition, construction - related impacts to water quality and hydrology would be increased under this alternative due to a larger area of impact, but would remain below a level of significance. Impacts related to noise (long - term), utilities and service systems, and water quality and hydrology (long -term) would be similar to the proposed Project and would be less than significant. 3.4.19.3 Findina and Rationale for Alternative Site No. 17 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 17 infeasible. Alternative Site No. 17 would result in an overall increase in impacts to transportation /traffic as compared to the proposed Project. Although this alternative would reduce by a period of three weeks the proposed Project's significant unavoidable impact to the South Bristol Street/West Segerstrom Avenue intersection, this alternative would create a significant and immitigable near -term impact to the capacity of South Bristol Street for a period of approximately 46 days, or 21 days longer than the proposed Project's significant unavoidable impact to the South Bristol Street/West Segerstrom Avenue intersection. Furthermore, construction of a lift station at Alternative Site No. 17 would exacerbate an existing parking deficiency at this site both during construction and long -term operation. Near- and long -term impacts to parking at Alternative Site No. 17 would be a significant and immitigable impact. Construction activities at Alternative Site No. 17 also would result in a significant and immitigable near -term impact to traffic and circulation due to inadequate emergency access (i.e., Garry Street). In light of these considerations, the City finds that Alternative Site No. 17 would result in an overall increase in near -term impacts to transportation /traffic, and rejects this alternative as infeasible because it would not avoid or substantially lessen any of the significant effects of the Project. (CEQA Guidelines Section 15126.6(b).) This alternative also is rejected as infeasible because it would fail to meet, or would not be as effective in achieving, the proposed Project's objectives. This alternative would not be as effective as the proposed Project in meeting the Project's objective to minimize odor - related nuisances to land uses in close proximity. In addition, this alternative would exacerbate an existing parking deficiency at an existing commercial office building, and would, therefore, fail to meet the Project's objective of avoiding detrimental effects to existing businesses. Detrimental effects to business would be further exacerbated by ongoing construction in close proximity to the existing commercial office building. Further, unlike the proposed Project site where the City has an existing sewer easement, construction San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -38 CEQA Findings of Fact/Statement of Overriding Considerations 55A -77 Chapter 3 Findings Regarding Project Alternathies Attachment "A" at this location would require the City to acquire private property to provide easements for proposed sewer lines. Finally, construction of the lift station at this location would replace currently developed, useable land, in contrast to the proposed Project site, which is vacant and undeveloped. 3.4.20 Alternative Site Location No. 18 (Alternative Site No. 18) 3.4.20.1 Summary of Alternative Site No. 18 Alternative Site Location Number 18 (Alternative Site No. 18) would involve the construction of a new replacement lift station in the parking lot of an existing commercial retail center located at 3300 South Bristol Street (i.e., Target shopping center) in lieu of the proposed Project site. Alternative Site No. 18 is located approximately 0.35 -mile southwest of the proposed Project site. The location of Alternative Site No. 18 is depicted on Final EIR Figure 5 -1. The lift station that would be constructed at Alternative Site No. 18 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 18 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the installation and operation of approximately 62 percent more underground sewer conveyance infrastructure than the proposed Project and it is anticipated that the duration of Construction Phase 11 would be increased by approximately 90 work days (approximately eighteen weeks) as compared to the proposed Project. The substantial increase in construction duration is due in part to the need to cross the existing railroad tracks near the intersection of Alton Road/South Bristol Street, which would require approximately six weeks (30 working days) to complete. The construction schedule for this alternative would otherwise be similar to the Project. This alternative would require construction activities within and adjacent to the South Bristol Street /West Segerstrom Avenue intersection; however, the duration of construction activities within the intersection would be reduced to one (1) week under this alternative and traffic control associated with demolition of the existing lift station facility still would require up to two weeks; accordingly, under this alternative, traffic control affecting the intersection of South Bristol Street /West Segerstrom Avenue would occur for a total duration of three weeks, rather than the five weeks associated with the proposed Project. In addition, this alternative would not require implementation of Construction Configurations B.1, B.2, and C.1. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the Project (i.e., to the south of the South Bristol Street /West Segerstrom Avenue intersection). The segment of South Bristol Street between this site and the existing lift station facility contains a 20 -inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16 -inch water main, and a SCE /MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 feet, and this depth would increase with distance from the existing facility. Construction along this segment of South Bristol Street would require supporting the utilities from the top of the trench and /or the use of trench boxes /shields, which would elongate the construction schedule. Due to these existing utility constraints, portions of this roadway would need to be closed to accommodate construction associated with this alternative. Moreover, the duration of construction for this alternative site location would greatly increase due to the need to cross the railroad tracks running parallel and north of Alton Avenue. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -39 CEQA Findings of Fact/Statement of Overriding Considerations ����_wll� Chapter 3 Findings Regarding Pr%ct Alternatives Attachment "A" Development of a lift station at Alternative Site No. 18 would require the City to acquire private property to accommodate the proposed lift station. In addition, this alternative would require the City to acquire a temporary construction easement to facilitate construction of the proposed lift station. 3.4.20.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 18 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.20. This alternative would reduce the Project's significant and unavoidable impact associated with Construction Configuration C.2 by two (2) weeks; however, this alternative would result in a significant unavoidable impact to the capacity of the South Bristol Street roadway for a total of 94 days (or 69 days longer than the proposed Project's significant unavoidable impact). In addition, this alternative would result in significant unavoidable impacts to the intersection of South Bristol Street /Alton Avenue for the five (5) days in which construction activities would occur within the intersection, which represents a more severe impact to transportation /traffic than would occur under the proposed Project. Furthermore, construction of a lift station at Alternative Site No. 18 would exacerbate an existing parking deficiency at this existing commercial retail building both during construction and long -term operation, which would result in a total parking deficiency of 69 spaces and 58 spaces under near- and long -term conditions, respectively. Near- and long -term impacts to parking at Alternative Site No. 18 would be a significant and immitigable impact. As such, impacts to transportation /traffic would be greater at Alternative Site No. 18 as compared to the proposed Project site. Total construction air quality /greenhouse gas emissions would be increased under this alternative due to a longer construction period, although average daily construction emissions would be similar to the proposed Project and would be less than significant. In addition, construction - related impacts to water quality and hydrology would be increased under this alternative due to a larger area of impact, but would remain below a level of significance. Impacts due to nighttime dewatering during construction would be slightly decreased under this alternative and, as with the proposed Project, would be reduced to less than significant levels with incorporation of Mitigation Measure 3.3 -2. All other impacts associated with noise would be similar to the proposed Project and would be less than significant. Impacts related to utilities and service systems and water quality and hydrology (long- term) would be similar to the proposed Project and would be less than significant. Impacts associated with operational odors under accident conditions also would be slightly reduced under this alternative; however, with implementation of Mitigation Measure MM 3.1 -1, odor impacts would be less than significant for this alternative and the proposed Project. All other long -term impacts to air quality /greenhouse gas emissions would be similar to the proposed Project and would be less than significant. 3.4.20.3 Finding and Rationale for Alternative Site No. 18 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 18 infeasible. Alternative Site No. 18 would result in an overall increase in impacts to transportation /traffic as compared to the proposed Project. Although this alternative would reduce the Project's significant and unavoidable impact associated with Construction Configuration C.2 by two (2) weeks, this alternative would result in a significant unavoidable impact to the capacity of the South Bristol Street San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -40 CEQA Findings of Fact /Statement of Overriding Considerations 55A -79 Chapter 3 Findings Regarding ProjectAlternatives Attachment "A" roadway for a total of 94 days (or 69 days longer than the proposed Project's significant unavoidable impact). In addition, this alternative would result in significant unavoidable impacts to the intersection of South Bristol Street/Alton Avenue for the five (5) days in which construction activities would occur within the intersection. This also represents a more severe impact to transportation /traffic than would occur under the proposed Project. Furthermore, construction of a lift station at Alternative Site No. 18 would exacerbate an existing parking deficiency at this existing commercial retail building both during construction and long -term operation. Significant impacts to parking would not occur under the proposed Project. In light of these considerations, the City finds that Alternative Site No. 18 would result in an overall increase in near -term impacts to transportation /traffic, and rejects this alternative as infeasible because it would not avoid or substantially lessen any significant impacts of the Project. (CEQA Guidelines Section 15126.6(b).) This alternative also is rejected as infeasible because it would fail to meet, or would not be as effective in achieving, the proposed Project's objectives. This alternative would exacerbate an existing parking deficiency at an existing commercial retail building, and would, therefore, fail to meet the Project's objective of avoiding detrimental effects to existing businesses. Detrimental effects to business would be further exacerbated by ongoing construction in close proximity to the existing commercial retail building. Further, unlike the proposed Project site where the City has an existing sewer easement, construction at this location would require the City to acquire private property to provide easements for proposed sewer lines. Finally, construction of the lift station at this location would replace currently developed, useable land, in contrast to the proposed Project site, which is vacant and undeveloped. 3.4.21 Alternative Site Location No. 19 (Alternative Site No. 19) 3.4.21.1 Summary of Alternative Site No. 19 Alternative Site Location Number 19 (Alternative Site No. 19) would involve the construction of a new replacement lift station in the parking lot of an existing commercial retail center located at 3301- 3365 South Bristol Street in lieu of the proposed Project site. Alternative Site No. 19 is located approximately 0.40 -mile south of the proposed Project site. The location of Alternative Site No. 19 is depicted on Final EIR Figure 5 -1. The lift station that would be constructed at Alternative Site No. 19 would include a similar above- ground block structure as the proposed Project. In addition, the lift station at Alternative Site No. 19 would feature similar equipment and appurtenances as the proposed Project. This alternative would require the installation and operation of approximately 83 percent more underground sewer conveyance infrastructure than the proposed Project and it is anticipated that the duration of Construction Phase 11 would be increased by 89 work days (approximately 18 weeks) as compared to the Project. The substantial increase in construction duration is due in part to the need to cross the existing railroad tracks near the intersection of Alton Road /South Bristol Street, which would require approximately six weeks (30 working days) to complete. The construction schedule for this alternative would otherwise be similar to the Project. This alternative would require construction activities within and adjacent to the South Bristol Street /West Segerstrom Avenue intersection; however, the duration of construction activities would be reduced to one (1) week under this alternative. Traffic control associated with demolition of the existing lift station facility still would require up to two weeks; accordingly, under this alternative, traffic control affecting the intersection of South Bristol Street /West Segerstrom Avenue would occur San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -41 CEQA Findings of Fact /Statement of Overriding Considerations Chapter 3 Findings Regarding Project Altemattim Attachment "A" for a total duration of three weeks, rather than the five weeks associated with the proposed Project. In addition, this alternative would not require implementation of Construction Configurations B.1, B.2, or C.1. However, this alternative would require the installation of new sewer facilities beneath the existing paved right -of -way of South Bristol Street that are not proposed as part of the proposed Project (i.e., to the south of the South Bristol Street/West Segerstrom Avenue intersection). The segment of South Bristol Street between this site and the existing lift station facility contains a 20- inch OCSD trunk sewer, a 36 -inch MWD pipeline, a 16 -inch water main, and a SCE /MCI Duct Bank. These utilities would require special support during construction of the new 18 -inch sewer, as the new sewer line would need to be installed at a depth of approximately 16 feet, and this depth would increase with distance from the existing facility. Construction along this segment of South Bristol Street would require supporting the utilities from the top of the trench and /or the use of trench boxes /shields, which would elongate the construction schedule. Due to these existing utility constraints beneath South Bristol Street, portions of this roadway would need to be closed to accommodate construction associated with this alternative, which has the potential to result in adverse effects to vehicular circulation. Moreover, the duration of construction for this alternative site location would greatly increase due to the need to cross the railroad tracks running parallel and north of Alton Avenue. Implementation of this alternative would otherwise be similar to the proposed Project during construction conditions. Development of a lift station at Alternative Site No. 19 would require the City to acquire private property to accommodate the proposed lift station. In addition, this alternative would require the City to acquire a temporary construction easement to facilitate construction of the proposed lift station. 3.4.21.2 Summary Comparison of Environmental Effects The environmental effects of constructing the proposed lift station at Alternative Site No. 19 in comparison to the proposed Project site are shown in Final EIR Table 5 -1 and described in detail in RDEIR Section 5.4.21. This alternative would reduce the proposed Project's significant and unavoidable impact associated with Construction Configuration C.2 by two (2) weeks; however, this alternative would result in a significant unavoidable impact to the capacity of the South Bristol Street roadway for a total of 109 days (or 89 days longer than the proposed Project's significant unavoidable impact). Furthermore, construction of a lift station at Alternative Site No. 19 would exacerbate an existing parking deficiency at this existing commercial retail building both during construction and long -term operation. Near- and long -term impacts to parking at Alternative Site No. 19 would be a significant and unmitigable impact. As such, impacts to traffic and circulation would be greater at Alternative Site No. 19 as compared to the proposed Project site. Total construction air quality /greenhouse gas emissions would be increased under this alternative due to a longer construction period, although average daily construction emissions would be similar to the proposed Project and would be less than significant. In addition, construction - related impacts to water quality and hydrology would be increased under this alternative due to a larger area of impact, although such impacts would be less than significant. As with the proposed Project, impacts associated with nighttime dewatering activities during construction would be reduced to less than significant levels with compliance with Mitigation Measure MM 3.3 -2. Long -term odor impacts associated with accident conditions would be slightly decreased under this alternative in comparison to the proposed Project and would be less than significant similar to the proposed Project. Impacts related to long -term noise, utilities and service systems, and water quality and hydrology (long -term) would be similar to the proposed Project and would be less than significant. San Lorenzo Lift Station FIR (Project No. 06 -3510) 3 -42 CEQA Findings of Fact /Statement of Overriding Considerations 55A -81 Chapter 3 Findings Regarding Project Alternatives Attachment "A" 3.4.21.3 Finding and Rationale for Alternative Site No. 19 The City hereby finds that specific economic, legal, social, technological, or other considerations make Alternative Site No. 19 infeasible. Alternative Site No. 19 would result in an overall increase in impacts to transportation /traffic as compared to the proposed Project. Although this alternative would reduce the Project's significant and unavoidable impact associated with Construction Configuration C.2 by two (2) weeks, this alternative would result in a significant unavoidable impact to the capacity of the South Bristol Street roadway for a total of 109 days (or 89 days longer than the proposed Project's significant unavoidable impact). Furthermore, construction of a lift station at Alternative Site No. 18 would exacerbate an existing parking deficiency at this existing commercial retail building both during construction and long -term operation. Significant impacts to parking would not occur under the proposed Project. In light of these considerations, the City finds that Alternative Site No. 19 would result in an overall increase in near -term impacts to transportation /traffic, and rejects this alternative as infeasible because it would not avoid or substantially lessen any of the significant effects of the Project. (CEQA Guidelines Section 15126.6(b).) This alternative also is rejected as infeasible because it would fail to meet, or would not be as effective in achieving, the proposed Project's objectives. This alternative would exacerbate an existing parking deficiency at an existing commercial shopping center, and would, therefore, fail to meet the Project's objective of avoiding detrimental effects to existing businesses. Detrimental effects to business would be further exacerbated by ongoing construction in close proximity to the existing commercial shopping center. Further, unlike the proposed Project site where the City has an existing sewer easement, construction at this location would require the City to acquire private property to provide easements for proposed sewer lines. Finally, construction of the lift station at this location would replace currently developed, useable land, in contrast to the proposed Project site, which is vacant and undeveloped. 3.4.22 Findings on Alternatives that were Considered but Eliminated from Detailed Analysis in the Draft EIR In addition to the 21 alternatives evaluated in the RDEIR, the Lead Agency considered two additional alternatives. Both of these alternatives were eliminated from detailed analysis in the EIR either because they did not meet the Project's basic objectives, would fail to reduce or avoid the significant impacts of the Project as proposed, and /or were determined at the outset to be infeasible. These alternatives are discussed below. 3.4.22.1 Saddleback High School Alternative This alternative would involve the construction of a lift station at Saddleback High School, either on a portion of the athletic field or parking lot adjacent to West Segerstrom Avenue. Such an alternative would not require the acquisition of privately owned property. The City hereby finds that specific economic, legal, social, technological, or other considerations make the adoption of this alternative infeasible. The Saddleback High School property is owned by a public entity, the Santa Ana Unified School District ( SAUSD). City staff inquired with the SAUSD about use of the school's property for construction the lift station facility. In a letter dated April 11, 2011, the SAUSD rejected the concept because: 1) the District is currently in the design phase of San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -43 CEQA Findings of Fact/Statement of Overriding Considerations A; LY96L Chapter 3 Findings Regarding Project Alternatives Attachment 'A" expanding the Saddleback High School and construction of the lift station would conflict with the District's on -going plans to provide additional student facilities; 2) construction in the parking lot adjacent to West Segerstrom would exacerbate already insufficient parking on -site for school events and activities; and 3) construction that would result in the loss of a portion of the school's athletic fields is prohibited under Title IX (1972 Education Amendments to the Civil Rights Act). SAUSD is unwilling to offer use of the school property for construction of the lift station, and has provided several reasons why construction of the lift station is inconsistent with ongoing SAUSD uses at the school site. Because the property in question is currently owned and used by the SAUSD, it is likely protected from the City's powers of eminent domain under the doctrine of prior public use. In order to challenge the school's ownership of the property, the City would be required to file suit to appropriate the site for a more necessary public use under Code of Civil Procedure §1240.610. Given the proposed use as a lift station facility, compared to the current use as an educational institution, such a suit would be unlikely to succeed. In any event, it is not City policy to exercise its eminent domain powers on school property for public works projects. For these reasons, construction of the lift station on the Saddleback High School campus is not feasible. Additionally, construction of a lift station on the campus of Saddleback High School would not reduce the significant and unavoidable short -term traffic impact associated with the proposed Project. Construction of a lift station facility at the Saddleback High School would require the construction of a manhole in the intersection of South Bristol Street/West Segerstrom Avenue, thereby resulting in a need to implement Construction Configuration C.2 for up to five (5) weeks during construction on a 24 -hour basis. As with the proposed Project, 24 -hour lane closures associated with Construction Configuration C.2 would result in a significant and unavoidable impact of the proposed Project. As implementation of Construction Configuration C.2 is the only impact of the proposed Project that cannot be reduced to less than significant levels with the incorporation of mitigation measures, this alternative site location would fail to meet CEQA's stated purpose of considering and discussing alternatives in an EIR. CEQA Guidelines §15126.6(b) requires that "...the 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..." CEQA Guidelines § 15126.6(f)(2) further requires that, in making the decision to include or exclude analysis of an alternative site, the "...key question and first step in analysis is whether any of the significant effects of the project would be avoided or substantially lessened by putting the project in another location. Only locations that would avoid or substantially lessen any of the significant effects of the project need to be considered for inclusion in the EIR." Since construction of the proposed Project at the Saddleback High School would fail to avoid or substantially lessen the Project's sole unavoidable impact to transportation /traffic, such an alternative is rejected as infeasible because it would fail to meet the standards for project alternatives as set forth in CEQA Guidelines § 15126.6(b) or § 15126.6(f)(2). 3.4.22.2 Retrofitted Segerstrom Lift Station Alternative Under this alternative, the City would retrofit and upgrade the existing Segerstrom Lift Station facility rather than constructing a replacement facility in another location. The City hereby finds that specific economic, legal, social, technological, or other considerations make the adoption of this alternative infeasible. This alternative would fail to meet several of the Project's basic objectives. Specifically, retrofitting of the existing Segerstrom Lift Station would not allow the City to house electrical equipment above - ground. In addition, retrofitting the existing lift station would require upgrades to existing electrical equipment and installation of additional equipment; the addition of new equipment would further restrict workable space within the facility, San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -44 CEQA Findings of Fact /Statement of Overriding Considerations A�:R] Chapter 3 Findings Regarding ProjectAitematIves Attachment "A" and therefore would not meet the Project's objective to "Provide a lift station facility that provides sufficient access space for maintenance of the lift station facility." Moreover, such an alternative would fail to meet the Project's objective to construct a replacement lift station facility located outside of the public rights -of -way so as to minimize potential safety conflicts between motorists and maintenance personnel. Finally, such an alternative would not achieve the Project's objective to construct a new lift station facility, as this alternative would not involve the construction of a new lift station but rather would involve upgrades to the existing facility. 3.4.23 Additional Findings 3.4.23.1 Findings Related to Recirculation of the RDEIR CEQA Guidelines Section 15088.5 describes the conditions under which a Draft EIR that was circulated for public review is required to be re- circulated for additional public review and comment. CEQA Guidelines Section 15088.5 states that new information added to a Draft EIR is not significant unless the Draft EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project's proponents have declined to implement. "Significant new information" requiring recirculation includes, for example, a disclosure showing that: • A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented. • A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance. • A feasible project alternative or mitigation measure considerably different from the others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project's proponents decline to adopt it. • The RDEIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. As described in Section F.2 of the Final EIR, No Revisions to the Proposed Project, following receipt of comments from the public in response to the 47 -day public review period for the RDEIR, the City evaluated the comments received and responded to all substantive comments (refer to Section F.3 of the Final EIR). As indicated in the responses to public comment letters provided in Section F.3 of the Final EIR, Responses to Comments, no comments were received on the RDEIR that warrant revision to the analysis of the Project's impacts to the environment. Additionally, the Final EIR does not identify any new significant environmental impacts that were not already identified by the RDEIR, and no new mitigation measures were imposed on the proposed Project that could result in a new significant environmental impact. The Final EIR also does not identify any increases in the severity of any environmental impacts that were disclosed in the RDEIR, and new mitigation measures are not required in order to reduce the severity of such environmental impacts to a level below significant. In addition, public comment letters on the RDEIR did not identify any new mitigation measures or alternatives to the proposed Project that are considerably different from those already evaluated by San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -45 CEQA Findings of Fact/Statement of Overriding Considerations A; LYeey Chapter 3 Findings Regarding ProjectMernattves Attachment "A" the RDEIR; accordingly, no feasible alternatives or mitigation measures were identified by the public that would clearly lessen the significant environmental impacts of the proposed Project. Finally, the City of Santa Ana finds that the RDEIR was comprehensive and thorough, and was sufficient to provide the public with meaningful opportunities to comment. Based on the foregoing, the City of Santa Ana has determined that recirculation of the RDEIR is not warranted pursuant to Section 15088.5 of the State CEQA Guidelines. 3.4.23.2 Finding Related to the Analysis of Alternatives The City Council finds that the RDEIR's analysis of alternatives complies with CEQA Guidelines Section 15126.6 by providing sufficient information about each alternative to allow meaningful evaluation, analysis and comparison with the proposed Project. Specifically, the detailed analysis in RDEIR Section 5.0 and the summary provided in the RDEIR Table 5 -1 give the City Council sufficient information about each alternative, both before and after mitigation, to permit a reasoned choice. The City Council further finds that while the EIR's assessment of potential feasibility of alternatives is informative, only City Council has the authority to make the findings required by CEQA. (CEQA Guidelines §15025(b)(2) [reviewing body may not delegate the making of findings required by CEQA Guidelines sections 15091 and 15093].) The findings presented herein reflect City Council's consideration of all comments received in the RDEIR and Final EIR, and reflect the City Council's final determination regarding feasibility, regardless of any statements of feasibility in the EIR. Finally, the City Council finds that using a submersible pump at the existing lift station as an alternative to the proposed project, as has been suggested by a commenter, is not feasible for all of the reasons set forth above in Section 3.4.22.2 of these Findings, explaining why the City would not retrofit and upgrade the existing Segerstrom Lift Station facility rather than constructing a replacement facility in another location. San Lorenzo Lift Station EIR (Project No. 06 -3510) 3 -46 CEQA Findings of Fact/Statement of Overriding Considerations 55A -85 Chapter 3 Findings Regarding Project Alfemattim Attachment "A" Chapter 4 - Statement of Overriding Considerations 4.1 Introduction Section 15093 of the CEQA guidelines states: (a) CEQA requires the decision - making agency to balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered "acceptable." (b) When the lead agency approves a project which will result in the occurrence of significant effects which are identified in the final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reason to support its actions based on the final EIR and /or other information in the record. The statement of overriding considerations shall be supported by substantial evidence in the record. (c) If an agency makes a statement of overriding considerations, the statement should be included in the record of the project approval and should be mentioned in the notice of determination. This statement does not substitute for, and shall be in addition to, findings required pursuant to Section 15091. This Statement of Overriding Considerations describes the anticipated economic, social, and other benefits or other considerations of the Project to support the decision to proceed with the Project even though not all of the identified impacts are mitigated to a less - than - significant level. 4.2 Unavoidable Significant Adverse Impacts Even with mitigation measures identified in the Final EIR for the Project, the following significant impact is unavoidable because no feasible mitigation is available to further reduce the impact to a less- than - significant level. Refer to Chapter 2, CEQA Findings, for further clarification regarding the impact listed below. Transportation/Traffie Impacts to Intersection Operations During Implementation of Construction Configuration C.2 under Transportation /Traffic Threshold 1: Implementation of Construction Configuration C.2, which would occur on a 24 -hour basis for up to a total of five weeks, would result in deficient levels of service at the intersection of South Bristol Street /West Segerstrom Avenue between the hours of 7:15 a.m. to 8:00 a.m. and between the hours of 2:30 p.m. and 6:45 p.m. (Monday through Friday). This impact is considered a near -term impact, and would only occur during the five weeks of construction during which Construction Configuration C.2 would be in place. Mitigation Measures MM 3.4 -3 and MM 3.4 -5 have been imposed on the Project and will reduce, to the maximum feasible extent, the San Lorenzo Lift Station EIR (Project No. 06 -3510) 4 -47 CEQA Findings of Fact/Statement of Overriding Considerations • Chapter 3 Findings Regarding Project Atternathres Attachment "A' Project's impacts to this intersection. However, the only way to completely avoid this impact would be to prohibit traffic control measures during peak hours. Prohibiting traffic control measures is not technically feasible due to the extent of required improvements and associated traffic control measures. Furthermore, construction of a manhole within the intersection of South Bristol Street /West Segerstrom Avenue would require the excavation of a large hole that would preclude the City's ability to safely remove traffic control measures. Accordingly, the City finds that this impact is significant and unavoidable. 4.3 Overriding Considerations The City hereby finds that economic, legal, social, technological or other benefits of the Proposed Project outweigh the significant and unavoidable impacts identified in the EIR. In making this finding, the City has balanced the benefits of the Project against its unavoidable significant impact and has indicated its willingness to accept that adverse impact. The Santa Ana City Council finds that the following benefits of the Proposed Project warrant approval of the Proposed Project notwithstanding its significant, unavoidable environmental impact. Having (i) adopted all feasible mitigation measures, (ii) rejected as infeasible alternatives to the Project discussed above, (iii) recognized all significant, unavoidable impacts, and (iv) balanced the benefits of the proposed Project against the its significant and unavoidable impact, the City hereby finds that its benefits outweigh and override its significant unavoidable impact for the reasons stated below. Each benefit set forth below constitutes an overriding consideration warranting approval of the Project, independent of the other benefits, despite the Project's unavoidable impact. 4.3.1 Project Benefits 1. The construction and operation of a lift station facility facilitates a public need for the conveyance and treatment of wastewater generated in this portion of the City, and the Project is necessary to ensure the City's continued ability to provide for this essential public service. 2. The Project will provide for a new replacement lift station incorporating modern equipment that will reduce the potential for sewer spills and equipment failure in the local area as compared to existing conditions. 3. The Project will provide for a new lift station facility that houses electrical equipment above ground, thereby reducing the potential for power failures during peak storm events as compared to the existing condition. 4. The Project will enhance the safety of City maintenance personnel by providing for a replacement lift station that is located outside of the rights -of -way of major thoroughfares and that provides ample working space to conduct maintenance activities. 5. The Project will reduce long -term impacts to transportation /traffic and will improve vehicular safety by eliminating the need for lane closures during routine maintenance of the lift station facility, which is required under existing conditions. 6. The Project will incorporate modern odor control equipment that will reduce the potential for exposing nearby sensitive receptors to objectionable odors as compared to existing conditions. 7. The Project will provide for landscape and hardscape improvements that will enhance the appearance of the Project area. San Lorenzo Lift Station EIR (Project No. 06 -3510) 4 -48 CEQA Findings of Fact/Statement of Overriding Considerations 55A -87 Chapter 3 Findings Regarding Protect Alternatives Attachment "A" 8. The Project will provide all of the benefits listed above at a small, vacant, undeveloped property through which the City has an existing sewer easement, and in close proximity to the existing Lift Station, which minimizes the length of new sewer main required. San Lorenzo Lift Station EIR (Project No. 06 -3510) 4 -49 CEQA Findings of Fact /Statement of Overriding Considerations ATTACHMENT "B" SAN LORENZO LIFT STATION PROJECT MITIGATION MONITORING AND REPORTING PROGRAM Prepared for: The City of Santa Ana Public Works Agency Water Resources Division 200 S. Daisy Avenue Corporate Yard, MS 85 Santa Ana, CA 92703 Prepared by. T &B Planning, Inc. 17542 East 17'h Street, Suite 100 Tustin, CA 92780 February 2012 � ;L"m96 % ATTACHMENT "B" Mitigation Monitoring and Reporting Program 1.1 Introduction This document reflects the Mitigation Monitoring and Reporting Program (MMRP) requirements of Public Resources Cod (PRC) Section 21081.6. The California Environmental Quality Act (CEQA) Guidelines Section 15097 states: ...In order to ensure that the mitigation measures and project revisions identified in the EIR or negative declaration are implemented, the public agency shall adopt a program for monitoring or reporting on the revisions which it has required in the project and the measures it has imposed to mitigate or avoid significant environmental effects. A public agency may delegate reporting or monitoring responsibilities to another public agency or to a private entity which accepts the delegation; however, until mitigation measures have been completed the lead agency remains responsible for ensuring that implementation of the mitigation measures occurs in accordance with the program. 1.2 Enforcement In accordance with CEQA, the primary responsibility for making determinations with respect to potential environmental effects rests with the lead agency rather than the monitor or preparer. As such, the City of Santa Ana is identified as the enforcement agency for this MMRP. 1.3 Program Modification After review and approval by the lead agency, minor changes to the MMRP are permitted but can only be made by the City of Santa Ana. No deviations from this MMRP shall be permitted unless it continues to satisfy the requirements of PRC Section 21081.6, as determined by the lead agency. 1.4 Mitigation Monitoring and Reporting Program The organization of this MMRP follows the subsection formatting style as presented within the San Lorenzo Sewer Lift Station Final Environmental Impact Report (FEIR). Only those subsections of the environmental issues presented in the EIR that have mitigation measures are provided below in Table 1, Mitigation Monitoring and Reporting Program Matrix. All other subsections in the EIR do not contain mitigation measures. 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O � °' � v ti c ay�i G � G cn ca c❑ a a� c O U `"^ �a a a� o ¢' •� c a' 4 N bp o U U F" 'c > .O a, Q v, O c ° N °J °' ° a.) y 0 0 3 a �q a o c y 'S 0 (ID c o v Q o c bA bo -o b o •b4 ._ c U ; C] w o 0 U a. .- -, O Y s.. .� a y r� L •71 N by •iC .L O C c .c .� O U Y ai �l C .� c y oo <'" O V] s, p �? •� O tb -C bq bA U h U° N Y U •`� .�O. bq W .G ca G ° 2 2 3 W ro U ° �' w o H'� u o a°'i o >, E a S b o Y o °z J O Z a a'� o a> U o c❑ to o o "' a °c o O Q W caUQ ca ca M rM 0 M z° a O � W � •�; by � c � o N � o G ����_d_[�I�� Exhibit 3 0 SAN LORENZO SEWER LIFT STATION ME] ENVIRONMENTAL IMPACT REPORT S.0 ExECUTIVE SUMMARY S.0 EXECUTIVE SUMMARY S.1 INTRODUCTION The California Environmental Quality Act (CEQA), Public Resources Code Section 21000, et seq. requires that before a public agency makes a decision to approve a project that could have one or more adverse effects on the physical environment, the agency must inform itself about the project's potential environmental impacts, give the public an opportunity to comment on the environmental issues, and take feasible measures to avoid or reduce potential harm to the physical environment. This Environmental Impact Report (EIR), having California State Clearinghouse No. 2010041028, has been prepared in accordance with CEQA Guidelines Article 9, Sections 15120 to 15132, to evaluate the potential environmental impacts associated with planning, constructing, and operating the proposed San Lorenzo Sewer Lift Station Project (herein, the Project). This EIR does not recommend either approval or denial of the proposed Project; rather, it is a source of impartial information regarding potential impacts that the Project may cause to the physical environment. The Draft EIRwill bewas initially made available for public review for a period of 45-58 days (from July 14 through September 10, 2010). In response to the public review period for the Draft EIR the City of Santa Ana received seven (7) comment letters. The City also received a public comment letter just prior to final consideration of the FEIR, which contained new information that the City decided to evaluate further. Based on a review of the comments provided, the City opted to eland the EIR's analysis of alternative locations for the proposed project and incorporate other minor revisions into the Draft EIR The City also decided to recirculate the EIR pursuant to CEQA Guidelines § 15088.5(a). Accordingly, the Recirculated Draft EIR (RDEIR) will be made available for an additional 45 -day public review period. After consideration of public comments received in response to the RDEIR, the City of Santa Ana will consider certifying the Final EIR and adopting required findings in conjunction with Project approval. In the case that there are any adverse environmental impacts that cannot be fully mitigated, the City of Santa Ana must adopt a Statement of Overriding Considerations prior to Project approval, stating why the Project is being approved despite its unavoidable impacts. This Executive Summary has been prepared in accordance with CEQA Guidelines Section 15123. This EIR includes a description of the proposed Project and evaluates the physical environmental impacts that could result from planning, constructing, and operating the Project. The scope of this EIR has been narrowed to six subject areas through the completion of an Initial Study prepared by the City of Santa Ana pursuant to CEQA Guidelines Section 15063, and in consideration of public comment received by the City in response to this EIR's Notice of Preparation (NOP). The Initial Study, NOP, and written comments received by the City in response to the NOP, are attached to this EIR as Appendix A. As determined by the Initial Study and in consideration of public comment on the NOP, the six environmental subject areas that could be reasonably and significantly affected by the Project are analyzed herein, including: 1. Air Quality 4. Transportation and Traffic 2. Hazards and Hazardous Materials 5. Utilities and Service Systems (Wastewater) 3. Noise 6. Water Quality and Hydrology Refer to Section 3.0, Environmental Analysis, for a full account and analysis of the subject matters listed above. As mentioned, the scope of this EIR has been narrowed to these six subject areas through the completion of an Initial Study pursuant to CEQA Guidelines Section 15063, and in consideration of public comment to this EIR's NOR Subject areas for which the Initial Study concluded that impacts would be PAGE S -1 55A -101 ■ ■ SAN LORENZO SEWER LIFT STATION On ENVIRONMENTAL IMPACT REPORT Exhibit 3 S.0 ExECUiNE SUMMARY clearly less than significant and that do not warrant further analysis in this EIR are addressed in Section 4.4, Effects Found Not to Be Significant. For each of the six subject areas analyzed in Section 3.0, this EIR describes: 1) the physical conditions that existed at the approximate time this EIR's NOP was filed with the California State Clearinghouse (April 12, 2010); 2) discloses the type and magnitude of potential environmental impacts resulting from Project planning, construction, and operation; and 3) if warranted, recommends feasible mitigation measures that would reduce or avoid any significant adverse environmental impacts that the Project may cause. A summary of the Project's significant environmental impacts and the mitigation measures imposed by the City of Santa Ana to lessen or avoid those impacts is included in this Executive Summary as Table S.1, Mitigation, Monitoring, and Reporting Program. This EIR also discusses alternatives to the proposed Project. Alternatives are studied that would attain most of the Project objectives while avoiding or substantially lessening the proposed Project's significant environmental effects. A full discussion of Project alternatives is found in EIR Section 5.0, Alternatives. S.2 PROJECT OVERVIEW S.2.1 LOCATION AND REGIONAL SETTING The proposed Project site is located in the southern portion of the City of Santa Ana, in the vicinity of South Bristol Street and West Segerstrom Avenue. It includes all ground area that would be physically altered by the Project's construction and operation. The Project site includes the location of the existing Segerstrom Lift Station, which is proposed to be abandoned and demolished as part of the Project. The existing Segerstrom Lift Station is located along the eastern side of South Bristol Street, approximately 258-275 feet north of the intersection of South Bristol Street and West Segerstrom Avenue. The proposed Project site also is composed of an approximately 900 square -foot area north and adjacent to West Segerstrom Avenue, at the western terminus of San Lorenzo Avenue, which would be the site of the new proposed San Lorenzo Lift Station. Additionally, the Project site also includes the area of ground disturbance needed to install proposed subsurface sewer lines in South Bristol Street and West Segerstrom Avenue between the existing and proposed lift station facilities, and associated areas of roadway resurfacing. Refer to Figure 2 -2, Aerial Photograph, in Section 2.0. S.2.2 PROJECT OBJECTIVES, PURPOSE AND NEED The primary objective of the proposed Project is to provide a new sewer lift station to replace the existing Segerstrom Lift Station, which was originally constructed in the 1960s, most recently upgraded in 1989, and has since exceeded its design life. it has beeetme inadequate to handle existing Pews and-4*S obsolete in eempaFiSOH modem lift station designs. Under existing conditions, the Segerstrom Lift Station is prone to frequent maintenance (two to three times per week) in order to clear blockages due to debris collected in the system. In addition due to the age of the equipment the existing pumps and other equipment are subject to frequent mechanical failure (requiring maintenance) and it is difficult to obtain necessary replacement parts for the existing facility. The new pump station provides standby pumps in the event a pump is lost and includes grinders and a larger wet well to address debris within the collection system. Needed r-edundaneies asseeia4ed with the e?iisting lift station are inadequate in that twe pumps are f equently operated near- °paeity without ° third standby pump. The provision of a new sewage lift station and associated infrastructure would ensure that sewage flows are adequately conveyed to downstream wastewater treatment facilities while minimizing the risk of potential sewer spills. The following is a list of objectives sought by the City of Santa Ana in pursuing the proposed Project. PAGE S -2 55A -102 Exhibit 3 ■ ■ SAN LORENZO SEWER LIFT STATION 0 E ENVIRONMENTAL IMPACT REPORT S.0 ExEcum SUMMARY • To construct a new sewer lift station (the San Lorenzo Lift Station) near the intersection of South Bristol Street and West Segerstrom Avenue to replace an existing lift station that has exceeded its design life (the Segerstrom Lift Station). • To install modern lift station equipment and associated wastewater conveyance infrastructure to *de system r-edoodaneies in order- to reduce the potential of a sewer spill or equipment failure. • To provide a lift station facility in which electrical components of the facility are housed above ground so as to preclude the potential for electrical failure during peak storm events (due to flooding). • To construct a lift station facility that provides sufficient access space for maintenance of the lift station facility. • To avoid detrimental effects to existing businesses during construction and long -term operation of the lift station facility to the extent feasible. • To improve safety for both motorists and City workers by providing for an above - ground lift station facility located outside of existing roadway rights -of -way. • To minimize odor - related nuisances to land uses in close proximity to the new sewer lift station through the installation of a gravity odor control system. • To install landscape and hardscape improvements in areas that will be disturbed by lift station and associated subsurface infrastructure construction. • To safely demolish and abandon the existing Segerstrom Lift Station in accordance with applicable federal, state, and local regulations and standards. S.2.3 PROJECT DESCRIPTION SUMMARY The City of Santa Ana is proposing to construct and operate a new sewer lift station (the San Lorenzo Lift Station) to be located at the end of the western terminus of San Lorenzo Avenue, immediately north of West Segerstrom Avenue and south of an existing alley. The proposed sewer lift station would replace the existing Segerstrom Lift Station, which is located beneath South Bristol Street approximately 790 -420 linear feet to the west of the proposed new lift station site. The existing Segerstrom Lift Station has exceeded its design life and would be demolished and abandoned once the proposed San Lorenzo Lift Station is operational. The proposed lift station would be housed within an approximate 8 -foot by 30 -foot block structure, measuring approximately 17 feet in height. The structure's exterior walls would be tan in color and the roof material would be composed of brown metal roofing with a simulated Spanish tile pattern. Access into the interior of the structure would be provided via two doors on the southern face of the structure and two doors on the eastern face of the structure. Exterior lighting would be limited to security lighting above the entrance doors. The following facilities would be installed within or beneath the block structure: electrical panels and control center; a below - ground wet well of sufficient size and depth to prevent back up and surcharging of the upstream sewer mains; a below - ground dry well to house the pumps, motors, associated equipment and appurtenances; a gravity odor control system; and a stairway access into the dry well. In order to construct the San Lorenzo Lift station in its proposed location, a temporary construction easement would be placed over an approximately 499465 square-foot _L_ .) area west of the western terminus of San Lorenzo Avenue and immediately re4w of West Seger- str -o., kyen . °to the west and north of the lift station facility. It should be noted that the 465 s.f. temporary construction easement would be in addition to PAGE S -3 55A -103 Exhibit 3 ■ ■ SAN LORENZO SEWER LIFT STATION ■� ENVIRONMENTAL IMPACT REPORT S.O Encu yE SUMMARY the existing 20 -foot sewer easement and the permanent condemnation of approximately 292 s.f. of private property. The temporary construction easement would encompass an area consisting of the first five (5) feet westerly of the existing wall and the first ten (10) feet northerly of the existing wall (refer to Section 2.4.3 for a detailed description of the temporary construction easement). Additionally, the City of Santa Ana would need to acquire permanent title to approximately 292 square feet of private property, which is owned by Santa Ana California Lodge, LLC (Studio Inn, APN 410 - 411 -19). This property would be acquired by the City in any manner authorized by law, which in proper circumstances could potentially include adoption of a resolution of necessity by the Santa Ana City Council. Around the new lieft station, landscaping and hardscape improvements are proposed. The Project includes the repaving of a portion of the western end of San Lorenzo Avenue, portions of an existing alley, and a portion of West Segerstrom Avenue, along with the installation of new sidewalks in areas where existing sidewalks have fallen into a state of disrepair and /or would be demolished during lift station construction. An existing wall separating the proposed lift station site from an existing, adjacent motel (Studio Inn) would be removed and replaced with a new, six -foot tall, tan - colored block wall. Some existing landscaping along West Segerstrom Avenue would remain. New landscaping would be installed in a triangular area located between the proposed lift station building and the sidewalk along West Segerstrom Avenue, and would include the planting of one 24 -inch box tree (Brisbane Box), along with shrubs and groundcover (Silverberry and Autumn Sage). Hardscape improvements adjacent to the new lift station would include the installation of new sidewalk, curb, and gutter. The Project also proposes the installation and operation of approximately 1,300 linear feet of new underground sewer infrastructure, including approximately 560 linear feet of 15 -inch gravity sewer pipe; approximately 190 linear feet of 12 -inch gravity sewer pipe; approximately 545 linear feet of 10 -inch force main; and sewer manholes and appurtenances. Construction of these new facilities would occur beneath the paved rights -of -ways of South Bristol Street and West Segerstrom Avenue. The new infrastructure would be needed to connect several existing sewer mains to the new proposed San Lorenzo Lift Station. After construction of the San Lorenzo Lift Station is complete and the new subsurface sewer pipes and manholes are installed, the new lift station would move effluent through the station and into gravity sewer lines, which would convey the sewerage to an existing Orange County Sanitation District (OCSD) treatment facility. Effluent would continuously flow through the San Lorenzo Lift Station and would not be stagnant. The new lift station would replace the Segerstrom Lift Station and would not increase the capacity of the City's existing sewer system. The new lift station facility would be constructed with odor control devices and the City would regularly monitor the facility to ensure it is functioning properly. After the new San Lorenzo Lift Station has been constructed and is in operation, demolition of the existing Segerstrom Lift Station would occur. Demolition activities would involve abandonment in place of the existing lift station, including the removal and disposal of all lift station equipment and filling of the existing wet well manhole with sand. An existing generator, located southerly of the existing lift station, would remain in place and would serve as a back -up power source for the proposed new San Lorenzo Lift Station. Finally, some removal and replacement of existing sidewalk and roadway pavement would occur in association with proposed demolition activities, including the removal /replacement of an existing 80 -foot long by 12 -foot wide bus pad located immediately south of the existing Segerstrom Lift Station facility. Demolition of the existing Segerstrom Lift Station would occur in conformance with all applicable federal, state, and local regulations and standards. Lastly, resurfacing of roadway segments disturbed by Project construction would occur. PAGE S -4 55A -104 Exhibit 3 ■■ SAN LORENZO SEWER LIFT STATION M0 ENVIRONMENTAL IMPACT REPORT S.O EXECUTIVE SUMMARY A complete description of the Project is contained in Section 2.0, Project Description, of this EIR. Please refer to Section 2.0 for additional information, including a detailed description of the construction process and schedule. S.3 EIR PROCESS In December 2008, the City of Santa Ana prepared a CEQA Initial Study and Mitigated Negative Declaration (MND) for the proposed Project. The MND disclosed adverse environmental impacts in the areas of air quality (odor) and short-term construction - related traffic. Mitigation measures were presented in the MND to reduce those impacts to below levels of significance. The MND was circulated for public review, and then approved by the City of Santa Ana on February 2, 2009. Subsequently, the MND was challenged in California Superior Court by an adjacent property owner, Santa Ana California Lodge, LLC. As a result, the Court ordered that the City vacate its approval of the MND, and further required preparation of a project EIR. As a first step in complying with the procedural requirements of CEQA for an EIR, an Initial Study (refer to EIR Appendix A) was prepared by the City of Santa Ana to determine whether any aspect of the proposed Project, either individually or cumulatively, may cause a significant adverse effect on the physical environment. For this Project, the Initial Study indicated that this EIR should focus on five (5) of the six (6) environmental subject areas listed above in Subsection S.1. After completion of the Initial Study, the City filed a NOP with the California Office of Planning and Research (State Clearinghouse) to indicate that an EIR would be prepared. In turn, the Initial Study and NOP were distributed for a 30 -day public review period, which began on April 12, 2010 and ended on May 12, 2010. Written comments on the scope of the EIR were received during those 30 days, and were considered by the City during the preparation of this EIR. After considering public comments on the NOP, the City decided that a sixth subject area (Water Quality and Hydrology), which was not identified in the Initial Study as warranting further analysis, should be added as a subject area to be further analyzed in this EIR. According to CEQA Guidelines Section 15082(c)(1), an advertised public meeting (called a scoping session) was not required because the Project is not of statewide, regional, or area -wide significance as defined by CEQA Guidelines Section 15206. This EIR i �was being- circulated for review and comment by the public and other interested parties, agencies, and organizations for a 4558 -day review period, which extended from July 14 through September 10, 2010. In response to the public review period for the Draft EIR, the City of Santa Ana received seven (7) comment letters. The City also received a public comment letter just prior to final consideration of the FEIR, which contained new information that the City decided to evaluate further. Based on a review of the comments provided, the City of Santa Ana opted to expand the EIR's analysis of alternative locations for the proposed project and to incorporate other minor revisions into the Draft EIR. The City also decided to recirculate the EIR pursuant to CEQA Guidelines Section 15088.5. During the 45 -day public review period for the RDEIR, public notices announcing availability of the EIR will be mailed to interested parties, advertisements will be posted in the local newspaper, and copies of the Draft El RDEIR and its Technical Appendices will be available for review at the following locations: City of Santa Ana Public Works Agency, Water Resources Division, 200 S. Daisy Avenue, Santa Ana, CA 92703; and City of Santa Ana Public Works Agency, First Floor, 20 Civic Center Plaza, Santa Ana, CA 92701. After the close of the 45 -day E4RRDEIR public comment period, responses to written comments on the environmental effects of the proposed Project will be prepared and published. The Final EIR will then be PAGE S -rJ 55A -105 Exhibit 3 ■ ■ SAN LORENZO SEWER LIFT STATION ■FI ENVIRONMENTAL IMPACT REPORT S.O ExFCunyE SUMMARY considered for certification by the City of Santa Ana City Council in a public hearing(s). The City Council will review and consider the Final EIR prior to deciding to approve, approve with revision, or reject the proposed Project. Approval of the proposed Project would be accompanied by the adoption of written findings and a statement of overriding considerations for any significant unavoidable environmental impacts identified in the Final EIR. In addition, the City must adopt a Mitigation, Monitoring, and Reporting Program (MMRP), which describes the process to ensure implementation of the mitigation measures identified in the Final EIR to reduce or avoid significant impacts on the physical environment. The MMRP, which is included as Table S -1 in this EIR, will ensure CEQA compliance during Project construction and operation. S.4 AREAS OF CONTROVERSY AND ISSUES TO BE RESOLVED CEQA Guidelines Section 15123(b)(2) requires that areas of controversy known to the Lead Agency (City of Santa Ana Public Works Agency, Water Resources Division) be identified in the Executive Summary. The Lead Agency is aware of one issue of controversy: • Opposition of Santa Ana California Lodge, LLC (Studio Inn, APN 410- 411 -19), to City acquisition of a temporary construction easement affecting their heir property (comprising approximately 465 s.f. in area), and opposition to Ci1y acquisition of permanent title to approximately 292 square feet of their private property in order to construct the proposed San Lorenzo Lift Station. Regarding issues to be resolved, this EIR addresses the environmental issues that are known by the City and that are identified in the Initial Study prepared for the Project (refer to Appendix A of this EIR). Four (4) written comment letters were received by the City on this EIR's NOP, copies of which are also included in Appendix A. Environmental topics raised in written comment to the NOP are primarily related to the issue areas of air quality (including odor), noise, traffic, water quality /drainage, and hazardous materials. Refer to Table 1 -2, Summary of NOP Comments, in Section 1.0 of this EIR. S.5 ALTERNATIVES TO THE PROPOSED PROJECT In compliance with CEQA Guidelines Section 15126.6, an EIR must describe a range of reasonable alternatives to the Project or to the location of the Project. Each alternative must be able to feasibly attain most of the Project's objectives and avoid or substantially lessen the Project's significant effects on the environment. A detailed description of each alternative evaluated in this EIR, as well as an analysis of the potential environmental impacts associated with each alternative, is provided in Section 5.0, Alternatives. Also described in Section 5.0 is a list of alternatives that were considered, but rejected from further analysis. The alternatives considered by this EIR include those listed below. S.5.1 NO PROJECT ALTERNATIVE The No Project Alternative is included in the Alternatives analysis as required pursuant to CEQA Guidelines Section 15126.6(e), which requires evaluation of an alternative that considers what would reasonably be expected to occur on the property in the foreseeable future if the Project were not approved, based on current plans and consistent with available infrastructure and community services. For purposes of analysis in this EIR, the No Project Alternative assumes that the proposed Project would not be approved; meaning that the existing Segerstrom Lift Station facility located beneath South Bristol Street would not be demolished and would continue operating in its existing condition into the foreseeable future. Construction of a new lift PAGE S -6 Exhibit 3 NO SAN LORENZO SEWER LIFT STATION ■o ENVIRONMENTAL IMPACT REPORT S.0 EXECUTIVE SUMMARY station facility, new underground sewer infrastructure, and sewer manholes and appurtenances as a replacement for the Segerstrom Lift Station would not occur. S.5.2 MODIFIED CONSTRUCTION CONFIGURATION C.Z ALTERNATIVE As described in EIR Section 3.4, implementation of the proposed Project would result in a significant unavoidable impact at the intersection of South Bristol Street at West Segerstrom Avenue for up to five weeks during construction activities within the intersection and /or when construction activities require access to two (2) northbound lanes within South Bristol Street northerly of the intersection. In order to avoid this significant unavoidable impact, Construction Configuration C.2 would need to be altered to include timing restrictions so as to avoid traffic control measures between the hours of 7:15 a.m. to 8:00 a.m. and between the hours of 2:30 p.m. and 6:45 p.m. According to the Project's engineer, such time restrictions would limit construction activities to about 1 -2 hours per day before construction activities would need to cease in order to ensure that traffic control is removed by 2:30 p.m. Such time restrictions are considered infeasible from a practical perspective because they would dramatically elongate the construction schedule for construction activities within the intersection from up to 158 days (3-2 weeks Monday - Friday) to approximately 6040- 12050 days (based on an assumption of one to two working hours per day with traffic control, and approximately 12058 working hours needed to complete construction within the intersection). The time restrictions also would elongate the construction schedule for work within South Bristol Street, which would increase from approximately 10-5 days (23 weeks Monday – Friday) to 4060-804-2-0 days (based on an assumption of one to two working hours per day with traffic control, and approximately 800 working hours needed to complete the portion of construction within South Bristol Street requiring access to two northbound travel lanes). With an elongated construction schedule of up to 200 days (403-5 weeks, or nearly 1013 months), construction costs would be increased and construction equipment and associated activities would be a nuisance to adjacent land uses for a longer period of time. However, as shown on EIR Figure 3.4 -8, acceptable levels of service at the intersection of South Bristol Street/West Segerstrom Avenue could be maintained between the hours of 6:45 p.m. and 7:00 a.m. without elongating the construction schedule. Assuming that traffic control measures would require approximately four hours (i.e., two hours to set up and two hours for removal), this would allow for approximately 8.25 working hours per day for improvements within the intersection of South Bristol Street /West Segerstrom Avenue. Therefore, this nighttime construction alternative, identified herein as the "Modified Construction Configuration C.2 Alternative," considers modifying the construction schedule for the ..el4iells of construction Phases 44—,14; and 16 involving ^anntransitioning the existing sewer within Bristol to the new lift station within the int eetion and viedc v,,ithi . South B -istal Street so as to limit the hours of traffic control and construction activities to between the hours of 6:45 p.m. and 7:00 a.m. (nighttime). Impacts to the intersection of South Bristol Street /West Segerstrom Avenue still would occur under this alternative during Construction Phase 11, as Construction Phase 11 would require implementation of Construction Configuration C.2 for a period of up to three weeks on a 24 -hour basis. Implementation of the Modified Construction Configuration C.2 Alternative would otherwise be identical to the proposed Project. The Modified Construction Configuration C.2 Alternative was selected for consideration in order to a reduce by two weeks the duration of the Project's significant and unavoidable short-term traffic impacts to the intersection of South Bristol Street/ West Segerstrom Avenue. S.5.3 ALTERNATIVE SITES This EIR evaluates a total of 19 alternative site locations for the proposed San Lorenzo Lift Station facility. The alternative site locations selected for consideration in this EIR include a reasonable range of potential PAGE S -7 55A -107 Exhibit 3 ■■ SAN LORENZO SEWER LIFT STATION ■� ENVIRONMENTAL IMPACT REPORT S.O EXECUTIVE SUMMARY development sites that would not require demolition of existing uses and are located in the vicinity of the existing Segerstrom Lift Station For purposes of evaluation herein each of the 19 alternative sites is anticipated to be developed with an approximate 8 -foot 8 -inch by 36 -foot 8 -inch block above - ground structure with an approximate height of 17 feet. The lift station equipment and appurtenances housed within and below the block structure would be similar to the proposed Project. Development of a lift station at each of the 19 alternatives sites would require a final site area of approximately 1,290 square feet, including the block structure a 5 -foot buffer area around the structure, and a clearance zone for hatches /manholes providing_ access to the below ground facilities. An area comprising approximately 6,420 square feet would temporarily be required for construction and staging at each of the alternative sites. Like the proposed Project development of a lift station at any of the alternative sites would require the demolition of the existing Segerstrom Lift Station. The location of the alternative sites under consideration are depicted on Figure 5 -1, Alternative Site Locations, and summarized below. • Alternative Site No. 1 would be sited at the western end of San Lorenzo Avenue, but would occur fully within existing public rights-of-way (including the temporary construction and staging areas). • Alternative Site No 2 would be sited within an existing City park located at the northeast corner of the West Segerstrom /South Shelton Street intersection. • Alternative Site No 3 would be sited in the parking lot of an existing medical office and retail center (2835 South Bristol Street). • Alternative Site No. 4 would be sited within an undeveloped parcel located behind 2402 South Bristol Street. • Alternative Site No. 5 would be sited in the parking lot of an existing commercial complex (approximately 3001 -3005 South Bristol Street). • Alternative Site No. 6 would be sited in the parking lot of an existing commercial center (approximately 2840 South Bristol Street). • Alternative Site No. 7 would be sited would be sited in the parking lot of an existing commercial center (approximately 2840 South Bristol Street). • Alternative Site No. 8 would be sited in the parking lot behind an existing medical office building (2810 South Bristol Street). • Alternative Site No. 9 would be sited in the parking lot behind an existing medical complex (2720- 2740 South Bristol Street). • Alternative Site No. 10 would be sited in the parking lot behind an existing medical building (2700 South Bristol Street). • Alternative Site No. 11 would be sited in the parking lot behind an existing medical building (2650 South Bristol Street). • Alternative Site No. 12 would be sited in the parking lot of an existing hospital (2701 South Bristol Avenue). • Alternative Site No. 13 would be located in the parking lot in front of an existing commercial building (2449 South Bristol Street). PAGE S -8 Exhibit 3 ■■ SAN LORENZO SEWER LIFT STATION ■� ENVIRONMENTAL IMPACT REPORT S.O ExECUTIVE SUMMARY • Alternative Site No 14 would be located in the parking lot of an existing commercial complex (located at the southeast corner of the intersection of South Bristol Street and West Warner Avenue). • Alternative Site No 15 would be located in the parking lot of an existing commercial complex (located at the southeast corner of the intersection of South Bristol Street and West Warner Avenue). • Alternative Site No 16 would be located within Carl Thornton Park (1801 West Segerstrom Avenue). • Alternative Site No 17 would be located in the parking lot of an existing commercial complex (approximately 3200 South Bristol Street). • Alternative Site No 18 would be located in the parking lot of an existing commercial center (approximately 3300 South Bristol Street). • Alternative No 19 would be located in the parking lot of an existing commercial center (approximately 3301 -3365 South Bristol Street). S.6 SUMMARY OF IMPACTS PROJECT REQUIREMENTS, MITIGATION MEASURES, AND CONCLUSIONS S.6.1 EFFECTS FOUND NOT TO BE SIGNIFICANT The scope of this EIR has been narrowed to six (6) subject areas through the completion of an Initial Study prepared by the City of Santa Ana pursuant to CEQA Guidelines Section 15063 and CEQA Statute Section 21002.1(e), as well as consideration of public comment received by the City on this EIR's NOP. The Initial Study, NOP, and public comments received in response to the NOP, are attached to this EIR as Appendix A. Subject areas for which the Initial Study concluded that impacts would be clearly less than significant and that do not warrant further analysis in this EIR include: Aesthetics, Agricultural Resources, Biological Resources, Cultural Resources, Geology and Soils, Land Use and Planning, Mineral Resources, Population and Housing, Public Services, Recreation, and Utilities and Service Systems (except wastewater). 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O W7 bq vl U O Y U N y H G G o th c 0 w �° 3 o UH c3 0 0 U o 0 0 n lu o❑ U a o G o 0 U U O O O U ca ..O ca z cC � r � M V M Y � O 7 o 0 3 0�A U O O vi O G � U U bGA U N � O � N � O O p C1. ° a � 55A -117 Lu Q CV) � 2 � 2 � 2 § LU LU 0 ui z _ o 92 L& I.- CL 2 � § z LU 2 0 0 32 � k 2 \ / 5 \\ ]~ 7\ / ) &\a \�\ \ < ®\g\\r ±ee� auem gEow) >2 E s I bl) z & ca, -0 $= § 2 , { ®§ ƒ2U ca - p z »t.2 3 br-11 ) \ k / \ \ \\ 3w §erg ±a. /yam \ : cIn. \\ \ \ ƒ�)[k \2 55A-1 1 8 � k � MEMORANDUM Paul Walters To: Interim City Manager Date: February 13, 2012 Raul Godinez II, P.E. From: Executive Director, Public Works EXHIBIT 4 Subject: Response to Letter from Silvestein Law Group, dated January 13, 2012 BACKGROUND The City has prepared an Environmental Impact Report (EIR), which analyzes the proposed construction of a new sewer lift station at the end of San Lorenzo Avenue. This facility would replace the existing lift station located beneath Bristol Street approximately 700 feet west of the proposed site. The existing sewer lift station is ridden with problems, all of which exemplify the need for a new facility, including: • Location is difficult to access beneath Bristol Street • Routine maintenance requires the closure of a travel lane and disruption of traffic on Bristol Street • Mechanical and electrical equipment are old and difficult to maintain in proper operating condition. • Station access is a manhole that floods during rainy conditions. • To perform maintenance crews must enter through the manhole and descend a 15 foot ladder carrying tools and equipment. • Working area in mechanical room (dry pit) is tight and cramped. • Existing computer software is old and obsolete compared to existing technology and support is not readily available. • Electrical panels are outdoors — set on back of sidewalk, and exposed to the elements. The EIR for the San Lorenzo Sewer Lift Station was scheduled for Council consideration on January 17, 2012. On the morning of January 17th the City received a letter from the Silverstein Law Firm citing objections to the EIR. SUMMARY RESPONSE Mr. Silverstein claims the project description is inaccurate, accuses the City of deliberately providing misleading information, questions the need for the project, and states that the project does not meet the stated project objectives. Mr. Silverstein also maintains the alternative sites analysis included in the EIR is inadequate and incomplete. 55A -119 Memo to Councilmembers February 2, 2012 Page 2 EXHIBIT 4 The need for the project is self evident due to the problems associated with maintaining the existing facility, some of which are listed above. The project objective is to alleviate these problems and provide a more reliable, safer, easier to maintain facility, with improved working conditions away from the traffic congestion on Bristol Street. The proposed site location is the best and most effective location for these improvements. It is a small, vacant, undeveloped piece of land at the end of San Lorenzo Avenue through which the City has an existing sewer easement. It is also in close proximity to the existing Lift Station which minimizes the length of new sewer main required. In regards to the alternative site analysis, the EIR evaluated a total of 19 alternative sites, most of which were identified by Mr. Silverstein himself. The majority of these alternative sites are fully developed parcels used by businesses, restaurants, retail establishments and medical facilities, or would involve construction within a park, e.g., the Segerstrom Triangle Park or the Carl Thornton Park. In his letter, Mr. Silverstein also suggests the alternative of revamping the existing lift station using the existing 8 foot diameter wet well and installing submersible pumps. Mr. Silverstein's engineer estimated the cost of this alternative at $748,000, which may or may not be accurate, but is certainly less than the $3.5 million cost estimate for the new station. However, this scenario is flawed and does not meet a number of the project objectives, as it would leave the facility within the Bristol Street right -of -way, and would not alleviate any of the associated problems noted above. A detailed response to each of the objections noted in Mr. Silverstein's letter is attached to this memorandum as Exhibit A. A technical response from TetraTech is attached as Exhibit B. Exhibit A: Responses to The Silverstein Law Group's letter Exhibit B: Response from TetraTech Exhibit C: Silverstein Law Group Letter, dated January 13, 2012 c: Mayor and City Council Joe Straka, Interim City Attorney Jose Sandoval, Chief Assistant City Attorney Ray Burk, Water Resources Manager Steve Worrall, Senior Civil Engineer N.H. Gordon, The Sohagi Law Group 55A -120 EXHIBIT "A" To: Raul Godinez II, P.E., Executive Director, Public Works Agency From: Steve Worrall, Senior Civil Engineer, Public Works Agency/Water Resources Division RE: Response to January 13, 2012 Comment Letter from Silverstein Law Firm On January 17, 2012, an Environmental Impact Report (EIR) for the San Lorenzo Lift Station Project (Project No. 06 -3510; "proposed project ") was scheduled for consideration by the Santa Ana City Council. On the morning of January 17, our office received a 15 -page letter (plus seven attachments) from The Silverstein Law Firm addressing the content of the FIR and the merits of the proposed project. In order to allow adequate time to respond to the comments that were provided, City Council continued the matter. The purpose of this memo is to address and respond to the comments that were provided in the letter and associated attachments. In summary, the comments do not require any substantive changes to the proposed project or the EIR. A discussion and rationale for this conclusion is provided below. These responses correspond to the organization of the January 13, 2012 letter. Section II. The attached memorandum from Tom Epperson, P.E. of TetraTech, the City's expert engineer, explains the City's need for the upgrades. The commenter's suggestion that clarifications in the Recirculated FIR somehow undermine the stability of the Project Description is baseless. An accurate, stable and finite project description is indeed the "sine qua non" of an adequate EIR (County of Inyo v. City ofLos Angeles (1977) 71 Ca1.App.3d 185, 192 -193), and that is precisely what has been provided in this FIR. Prior to recirculation, the prior draft FIR mistakenly contained some ambiguous information on the capacity issues referenced in the comment letter. Specifically, it accurately stated that the new lift station "would not increase capacity" but also indicated that "needed redundancies associated with the existing lift station are inadequate in that two pumps are frequently operated near capacity without a third standby pump." In its February 7, 2011 letter to Council, The Silverstein Law Group identified this issue. While the prior draft FIR was correct in characterizing the existing lift station as being prone to frequent failure, the discussion, as drafted, could have been interpreted to mean that the frequent failures at the existing facility are attributed to the failure of stand -by pumps or lack of capacity. For clarification, the statement was intended to refer to the fact that if a pump were to fail during dry weather conditions at the existing Segerstrom Lift Station facility, then the second pump would 55A -121 EXHIBIT "A" become operational and there would be no standby pump; thus, if two pumps were to fail at the existing lift station facility, there would not be a third standby pump to convey sewage, thereby increasing the potential for a sewer spill. By contrast, the proposed San Lorenzo Lift Station would have a total of three pumps, only one of which would be in operation during dry weather conditions. If two pumps were to simultaneously fail at the proposed lift station facility under dry weather conditions, then a third pump would be available to continue conveying wastewater. Thus, the replacement lift station would offer additional redundancies that do not exist at the existing Segerstrom Lift Station facility, but only under dry weather conditions. For clarification purposes, this information was corrected in the RDEIR. As indicated on RDEIR Page 2 -6, "The existing lift station is prone to frequent maintenance (two to three times per week) in order to clear blockages due to debris collected in the system. In addition, due to the age of the equipment, the existing pumps and other equipment are subject to frequent mechanical failure (requiring maintenance) and it is difficult to obtain necessary replacement parts for the existing facility." One of the key purposes of CEQA is to provide an opportunity for public comment on a proposed Project and for a Lead Agency to respond to that public comment. In responding to this issue and subsequently recirculating the EIR, the City has done exactly what CEQA envisions. The commenter's insinuation that the proposed improvements are not needed defy logic and run contrary to fact. TetraTech's attached memorandum explains the status of the mechanical equipment at the existing lift station. We acknowledge the evaluation provided by Mr. Bonneau Dickson and attached to the commenter's letter. However, the City's engineers and Department of Public Works' staff have a singular familiarity with the issues prevalent at the existing lift station. Beginning in approximately September 2010 crews noticed a dramatic change in the flow conditions going through the lift station. The pumps were clogging regularly due to rags, clothes, debris and other items. The City attempted to investigate upstream conditions but was unable to identify the specific source of the problem. This resulted in the dramatic increase in maintenance logs the commenter highlights. Department of Public Works staff mounted an extensive public outreach/educational campaign to alleviate these issues, including handing out brochures, magnets, and pan scrapers to facilitate proper disposal of oils and greases. All of this was done in response to a clear and present need, not as part some attempt to "manufacture" or "falsify" the City's records, as the commenter seems to imagine. Section III. The commenter is incorrect in stating that the proposed project does not provide a lift station in which electrical components are housed above ground so as to preclude the potential for electrical failure during peak storm events due to flooding. The proposed dry pit (which contains the mechanical piping /valves /pumps /motors) is protected by curbs and elevation to minimize any potential flooding, as compared to the existing dry pit, which is subject to flooding due to its location within the often flooded Bristol Street. Under the proposed design, any flood at the end of San Lorenzo will be relieved to Segerstrom prior to reaching the elevation of the top of the dry well. Similarly, the proposed electrical facilities will be located within a building whereas the existing electrical panels are located outside and exposed to elements. 55A -122 EXHIBIT "A" Section IV. The Draft Final Environmental Impact Report (FEIR) clearly acknowledges that odor impacts associated with the proposed project are potentially significant, and imposes mitigation to reduce this impact to a level below significance (refer to discussion on Pages 3.1 -36 and -37 of the Draft FEIR, and Measure MM 3.1 -1 on Pages 3.1 -45 and -46 of the Draft FEIR).1 Section V.A The commenter's complaint that the Draft FEIR's discussion and analysis of the 19 alternative site locations comprise "straw men alternatives" is difficult to comprehend. All of the alternative sites discussed and evaluated in Draft FEIR Section 5.0 are those suggested by The Silverstein Law Firm in their February 7, 2011 comment letter and associated attachments. With respect to the comments on Alternative Site Nos. 2 and 3, in both instances the Draft FEIR assumes that the replacement lift station would be placed in a manner that minimizes impacts to parking and disruptions to existing businesses. As a result, these alternatives were assumed to occur in locations that would be in closer proximity to nearby sensitive receptors than the proposed San Lorenzo Lift Station facility. Had the alternative locations been proposed in locations with lesser impacts to air quality and odor at the expense of greater impacts to parking and disruptions to existing businesses, one wonders if the commenter would have taken similar issue with those locations. In any event, all odor impacts associated with these alternatives would be less than significant with incorporation of mitigation, similar to the mitigation required for the San Lorenzo Lift Station facility. With respect to footnote number 3 in the commenter's letter, the FIR does not utilize differing criteria. The distances disclosed in the EIR are measured from the lift station exhaust vent to usable outdoor space. In the case of the apartments near the proposed Project site and all single- family residences located near the various alternative site locations, this distance is measured from the nearest back yard or patio. For the high school located near Alternative Site No. 2, distance to the property line is appropriate since there are several tennis courts located immediately south of the Segerstrom Triangle, which would represent usable outdoor space. The "discussion of alternatives [in an EIR] need not be exhaustive," and the requirement to discuss alternatives is "subject to a construction of reasonableness." (Residents Ad Hoc Stadium Committee v. Board of Trustees (1979) 89 Cal.App.3d 274, 286.) In considering i It is also difficult to understand the commenter's critique of the 75 foot zone of potential odor identified in the EIR, particularly in light of the fact that the commenter's own expert, Hans Giroux, has assumed 75 feet as the "zone of clearly offensive odor" for worst -case odor conditions in analysis of other projects, e.g., the Air Quality Impact Analysis prepared by Giroux & Associates in 2001 for the Audie Murphy Ranch Development in Riverside County, which states that "During upset conditions with stagnant sewage in the system, the zone of clearly offensive odor would be around 75 feet from the source." The San Lorenzo EIR makes the exact same, reasonable assumption. (See EIR, p. 3.1 -37.) 55A -123 EXHIBIT "A" alternatives, a lead agency need only make an objective, good faith effort to provide information permitting a reasonable choice of alternatives that would feasibly attain most of the basic objectives of the project, while avoiding or substantially lessening the project's significant adverse environmental impacts. (California Oak Foundation v. Regents of University of California (2010) 188 Cal.App. 4th 227, 275 -276.) "An EIR need not consider every conceivable alternative to a project" or multiple variations on the alternatives analyzed. (CEQA Guidelines § 15126.6(a).) "What is required is the production of information sufficient to permit a reasonable choice of alternatives so far as environmental aspects are concerned." (Village Laguna of Laguna Beach, Inc. v.21 Board of Supervisors of Orange County (1982) 134 Cal.App.3d 1022.) If the relative advantages and disadvantages of other potential alternatives can be ascertained from a review of the alternatives presented in an EIR, the EIR is not defective for not discussing variations on each theme. (1d; Mira Mar Mobile Cmty. v. City of Oceanside (2004) 119 Cal.App.4th 477; Residents Ad Hoc Stadium Comm., 89 Cal.App.3d at 287). The EIR's discussion and analysis of 19 different alternative site locations allows assessment of the relative advantages and disadvantages of other potential alternatives and complies with CEQA. Section V.B In claiming that parking capacity should not have been studied in the EIR, the commenter essentially argues that a lead agency may not analyze any impact or resource not expressly identified in Appendix G of the CEQA Guidelines. This is simply not the law's intent. CEQA gives the lead agency discretion to determine appropriate significance criteria. "The determination of whether a project may have a significant effect on the environment calls for careful judgment on the part of the public agency involved, based to the extent possible on scientific and factual data. An iron clad definition of significant effect is not always possible because the significance of an activity may vary with the setting." (CEQA Guidelines § 15064(b).) Therefore, "a lead agency has the discretion to determine whether to classify an impact described in an EIR as `significant,' depending on the nature of the area affected." (Mira Mar Mobile Community v. City of Oceanside (2004) 119 Cal.App.4th 477, 493.) CEQA Lead Agencies have discretion to identify thresholds of significance in an EIR above and beyond those set forth in Appendix G. (CEQA Guidelines §15064.7.) The checklist in Appendix G is "only a suggested form" with a list of "sample" questions to help a lead agency determine whether an EIR should be prepared for a particular project; it is not a mandatory set of thresholds. (See CEQA Guidelines, Appendix G.) The CEQA Guidelines explain that "[ s]ample forms for an applicant's project description and review form for use by the lead agency are contained in Appendices G and H ... These forms are only suggested, and public agencies are free to devise their own format for an initial study." (CEQA Guidelines § 15063(f)). Moreover, case law makes clear that a lead agency should not rely exclusively on Appendix G. (See Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal.App.4th 1099, 1109- 1112.) Accordingly, the significance criteria used in an EIR is not limited to the questions provided in Appendix G. 55A -124 EXHIBIT "A" The case cited in the comment letter — San Franciscans Upholding the Downtown Plan v. City and County of San Francisco (2002) 102 Cal.AppAth 656 — held that failure to include a parking analysis in an FIR is not a CEQA violation. This is not the same, nor can it be construed to mean, that an FIR that does consider impacts to parking is invalid. Similarly, the fact that the Natural Resources Agency removed the parking adequacy question from Appendix G in 2010 does not mean the FIR erred for analyzing it anyway. The City has discretion to analyze those impacts it chooses in its FIR. In short, there is no need to remove this impact from the analysis. Section V.C.1 (Alternative Site 2) Alternative Site No. 2 was studied in the FIR at the request of the commenter, even though it does not meet CEQA's stated purpose for consideration of alternative site locations. As specified in CEQA Guidelines Section 15126.6(f)(2), the "key question and first step in the [alternatives] analysis is whether any of the significant effects of the project would be avoided or substantially lessened by putting the project in another location. Only locations that would avoid or substantially lessen any of the significant effects of the project need to be considered for inclusion in the EIR." As indicated in Final DEIR Section 5.4.4.5, implementation of Alternative Site No. 2 "would not eliminate the Project's near -term unavoidable impact at the intersection of South Bristol Street /West Segerstrom Avenue during construction." Nevertheless, the FIR analyzed Alternative Site No. 2 and determined that it would result in the construction of approximately 1,500 additional linear feet of sewer conveyance infrastructure, thereby necessitating a greater area of ground disturbance than the proposed project. As a result, Draft Final FIR Section 5.4.4 properly concludes that impacts to hydrology /water quality would be increased in relation to the proposed project, although such impacts would not represent a significant environmental effect. With respect to reduction in parkland, the Draft FEIR adequately explains that a reduction in 0.03 acres of parkland would exacerbate the City's existing deficiency in parkland (refer to Section 5.4.4.4). The commenter's claims that his client has been "misled" regarding the City's application for a Urban Greening grant to develop an Eco -Park, and that the City violated the Public Records Act (PRA) are incorrect. The commenter filed a PRA request on October 20, 2011 requesting information on the Eco -Park grant application. The City responded to this request on October 31, 2011, providing the grant application and other relevant documents. The Parks Department received verbal notice from the State earlier this year (2012) that they were unsuccessful in obtaining Grant funding at this time. However the future plans for this park remain in place. Further, the conflict with the City's grant application was not characterized as a significant environmental effect in the analysis. A discussion of the City's future plans for the Segerstrom Triangle site was provided merely to foster informed decision - making. 55A -125 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 EXHIBIT "A" However, and as with Alternative Site No. 2, Alternative Site No. 5 would not substantially avoid or lessen the proposed project's significant unavoidable impact to the South Bristol Street /West Segerstrom Avenue intersection (as indicated in Section 5.4.7.4 of the Draft FEIR). As such, Alternative Site No. 5 does not meet CEQA's stated purpose for consideration of alternative site locations and would not meet the project objective to "avoid detrimental impacts to existing businesses." With respect to comments pertaining to parking, please refer to the response provided above in Section V.B. No change is required to the analysis of parking. However, to reflect the fact that feasibility of alternatives is ultimately up to the City Council, the FEIR has been revised to delete the conclusion that Alternative Site No. 5 (and Alternative Site Nos. 3, 6, 7, 8, 9, 10, 11, 12, 17, 18, and 19) would be "legally infeasible." Finally, the conclusion about emergency access in Draft EIR Section 5.4.7 was included in error and has been deleted from the FEIR. Table 5 -1 does not identify any significant impacts to emergency access associated with this alternative and, therefore, there is no change required in Table 5 -1. Section V.C.4 (Alternative Site 7) Page 5 -44 of the Draft FEIR clearly indicates that "for purposes of analysis, it is assumed that this alternative would be constructed in the northwestern portion of the parking lot" in order to reduce the amount of parking that would be lost and the degree of disruption to the existing business. Therefore, the characterization in Draft FEIR Section 5.4.9.1 is correct in concluding that odor impacts would be increased, but would be reduced to a level below significance with mitigation. With respect to comments pertaining to parking, please refer to the response provided above in Sections V.B and V.C.3. Even if the Draft FEIR were to identify reduced impacts to transportation/traffic due to the elimination of some of the proposed project's less than significant impacts caused by traffic control, Table 5 -1 still would identify Alternative Site No. 7 as having more severe impacts to transportation/traffic as compared to the proposed project. This is because this alternative would result in the introduction of a new significant unavoidable impact to parking, and because this alternative would fail to completely eliminate significant unavoidable impacts due to other forms of required traffic control. Therefore, there are no changes required in Table 5 -1. Section V.C.5 (Alternative Site 8) Please refer to the response provided above in Sections V.B and V.C.3 for responses to the comments on parking impacts. Furthermore, and as with Alternative Site No. 7, even if the Draft FEIR were to identify reduced impacts to transportation/traffic due to the elimination of some of the proposed project's less than significant impacts caused by 55A -127 EXHIBIT "A" traffic control, Table 5 -1 still would identify Alternative Site No. 8 as having more severe impacts to transportation/traffic as compared to the proposed project. This is because this alternative would result in the introduction of a new significant unavoidable impact to parking, and because this alternative would fail to completely eliminate significant unavoidable impacts due to other forms of required traffic control. Therefore, there are no changes required in Table 5 -1. Section V.C.6 (Alternative Site 12) Although the precise duration of construction activities cannot be determined without final engineering details that go beyond CEQA's requirement for alternatives analyses, the Draft FEIR has nonetheless been revised to indicate a slight reduction in impacts to air quality /greenhouse gas emissions due to a slight reduction in the construction schedule since this alternative would not require the construction of a sewer bypass. Table 5 -1 also has been updated to show reduced impacts to both air quality /greenhouse gas emissions and hydrology /water quality. As a result, the Draft FEIR now concludes that this alternative would be environmentally equal to the proposed Project. Note that the overlap of construction phases that these comments suggest would be possible, would actually increase daily emissions due to the intensification of construction activities since the SCAQMD measures air quality impacts based on daily emissions. The EIR conservatively assumes that such overlap of construction activities would not occur so as to minimize air quality impacts associated with this alternative. Please refer to the response provided above in Sections V.13 and V.C.3 for responses to the comments on parking impacts. Furthermore, and as with Alternative Site No. 7, even if the Draft FEIR were to identify reduced impacts to transportation/traffic due to the elimination of some of the proposed project's less than significant impacts caused by traffic control, Table 5 -1 still would identify Alternative Site No. 12 as having more severe impacts to transportation/traffic as compared to the proposed project. This is because this alternative would result in the introduction of a new significant unavoidable impact to parking, and because this alternative would fail to completely eliminate significant unavoidable impacts due to other forms of required traffic control. Therefore, there are no changes required in Table 5 -1. In fact, this alternative's reduction in the duration of significant unavoidable impacts due to traffic control would only comprise three (3) days (Draft FEIR Page 5 -75). This level of reduction does not comprise a "substantial lessening" of the proposed project's significant unavoidable impact to traffic. This alternative would therefore fail to meet CEQA's stated purpose for consideration of alternative site locations [CEQA Guidelines Section 15126.6(f)(2)]. The commenter is correct that Table 5 -1 erroneously indicates that impacts to hydrology /water quality would increase under this alternative. With the revision for both air quality /greenhouse gases and hydrology /water quality, the corrected score in Table 5- 55A -128 EXHIBIT "A" 1 still would be "0," indicating that this alternative is environmentally equal to the proposed project. EIR Table 5 -1 has been corrected to reflect these revisions. Section VI As was noted in Response J -29 in Section F.3.3 of the Draft EIR, there is no rule in CEQA or elsewhere that the environmental effects of alternatives must be compared in an EIR prior to consideration of mitigation. In Laurel Heights Improvement Assn. of San Francisco, Inc. v. Regents of University of California (1988) 47 Cal.3d 376, 399 -403, cited by the commenter, the CEQA lead agency failed to consider any alternatives to the proposed project after concluding that all significant environmental impacts would be mitigated to a level of insignificance. By contrast, the EIR here examined 21 alternatives to the proposed Project, including 19 alternative site locations. The Supreme Court in Laurel Heights specifically distinguished the situation at issue there, in which an EIR failed to consider any alternatives, from one in which the EIR discussed both alternatives and mitigation measures. (Id. at 402.) The Supreme Court established that the correct analysis in an EIR must include both mitigation measures and alternatives, which, the court noted, "have the same function — diminishing or avoiding adverse environmental effects... alternatives are a type of mitigation." (Id. at 403.) There is nothing about this case that questions an EIR analysis that identifies both mitigation for the significant impacts of the proposed project and also discusses a reasonable number of alternatives. In fact, this approach ensures that decision - makers consider all possible ways to lessen or avoid the impacts of a project as proposed. Section VII The commenter suggests using a submersible pump at the existing lift station as an alternative to the proposed project. The EIR considered retrofitting the existing Segerstrom Lift Station facility. (See Section 5.3.2.) This alternative was rejected from consideration because it would not meet several of the Project's basic objectives. Specifically, it would not allow the City to house electrical equipment above - ground, which means it would not eliminate the issues of the existing lift station being located in Bristol Street. In addition, retrofitting the existing lift station would require upgrades to existing electrical equipment and installation of additional equipment. This would not meet the Project's objective to "Provide a lift station facility that provides sufficient access space for maintenance of the lift station facility." Moreover, such an alternative would fail to meet the Project's objective to construct a replacement lift station facility located outside of the public rights -of -way so as to minimize potential safety conflicts between motorists and maintenance personnel. Finally, such an alternative would not achieve the Project's objective to construct a new lift station facility, as this alternative would not involve the construction of a new lift station but rather would involve upgrades to the existing facility. For these reasons, using a submersible pump at the existing lift station is not a feasible alternative to the proposed project. 55A -129 EXHIBIT "A" Conclusion Based on the foregoing discussion and analysis, the EIR is legally adequate, and is in full compliance with the Court's prior Judgment and Writ and all CEQA requirements. 55A -130 EXHIBIT "B" TETRA TECH MEMORANDUM TO: Steve Worrall, City of Santa Ana FROM: Tom Epperson, Tetra Tech JOB TITLE: San Lorenzo Sewer Lift Station PROJECT NO: City No. 06 -3510 / EIR No. ER- 2011 -04 SUBJECT: Response to January 13, 2012 Comment Letter from Silverstein Law Firm DATE: February 2, 2012 The following are our responses to several of the items which hopefully will assist the City in preparing the final response to the City Council. Section II Purpose of Project is stated in EIR S.2.2. The key objectives are listed in S.2.2 and further highlighted below: • Existing lift station was last upgraded in 1989; pumps rebuilt in 2007; other mechanical equipment and associated piping were not. Mechanical and electrical equipment are old and difficult to maintain in proper operating condition. • Existing lift station (dry pit containing mechanical equipment) is located in Bristol Street within manhole. Requires closure of a travel lane and disruption of traffic on Bristol to perform routine maintenance. To perform maintenance, crews must perform confine space requirements and descend 15 foot ladder carrying tools and equipment. All mechanical equipment is located within a below -grade 12 -foot diameter manhole, so work area is tight and cramped. • Proposed lift station is located outside of roadway right -of -way; located within a building; stairway is provided to dry pit; dry pit has sufficient space for maintenance (room is five times bigger). • Existing lift station has only two pumps while proposed lift station has three pumps which improves reliability. The proposed lift station wet well has three times more capacity than the existing lift station wet well. The response time to an emergency is much quicker with the new lift station due to ease of access (no traffic control set- up /confine space issues /etc) and the mechanical equipment being located within a building. Due to the faster response time, additional pump, and larger capacity wet well, the new lift station reduces the potential of a sewer spill. • Existing lift station electrical panels are located within Bristol parkway (back of sidewalk and exposed to elements). Being located within public right -of -way of an arterial, they are susceptible to catastrophic damage by an out -of- control car and public vandalism. Proposed lift station electrical panels will be located within a building (safe and secure). • Existing lift station is located within a roadway which has tendency to flood. Proposed lift station is designed to protect the electrical facilities and dry pit from flooding (located at an elevation that is higher than relief elevation to street). C:\Documents and Settings\nmitre \Local Settings \Temporary Internet Fil es \Content.Outlook \VDSN8UCB \santa ana memo on silverstream letter - TetraTech (FINAL 2012- 02- 02).DOC 55A -131 February 2, 2012 Page 2 EXHIBIT "B" Existing computer software is old and obsolete compared to existing technology and support is not readily available. Existing lift station does not have any odor control system. The proposed lift station will have an odor control system. A. Age and Replacement Parts Original mechanical equipment was all replaced in 1989 (at age of 29 years). Pumps were rebuilt in 2007 (at age of 18 years). By time proposed lift station is constructed and placed in service, existing mechanical equipment will be about 26 years old and will need to be replaced again. Rebuilt pumps will also have been in service for about 7 years at that same time and would be requiring additional maintenance work. The environment (below -grade manhole with high humidity) reduces the design life of the equipment. Replacement parts for the pumps are not readily available (within day or two of request). For the last pump replacement work, it took about four weeks to get the replacement parts. (The City contacted Mr. Chris Brown of Orange County Pump who confirmed that the minimum lead time for the pump rotating assemblies was 3 to 4 weeks as they are not readily available but need to be assembled from off the shelf parts and shipped). With only two pumps in the existing lift station, this delay in getting replacement parts places the City at a very large risk of a potential spill. To reduce this potential, the City has been storing used spare parts at their yard in case replacement parts are necessary. As the existing lift station equipment gets older, the need for maintenance and repair work increases. Section III The existing dry pit (contains the mechanical piping /valves /pumps /motors) is subject to flooding due to its location within the often flooded Bristol Street. The proposed dry pit is protected by curbs and elevation to minimize any potential flooding. Any flood at the end of San Lorenzo will be relieved to Segestrom prior reaching the elevation of the top of the dry well. The existing electrical panels are located outside and exposed to elements. The proposed electrical facilities will be located within a building. Section VII Retrofitting the existing lift station by installing a submersible pump will not eliminate the issues of the existing lift station being located in Bristol Street. The majority of the project's objectives will not be met by retrofitting the existing lift station. C: \Documents and Settings\nmitre \Local Settings \Temporary Internet Files \Content.Outlook \VDSN8UCB \santa ana memo on silverstream letter - TetraTech (FINAL 2012- 02- 02).DOC 55A -132 Exhibit C Silverstein Law Group Letter January 13, 2012 55A -133 THE SILVERSTEIN LAW FIRM A Professional Corporation January 13, 2012 VIA FACSIMILE (714) 647 -3345 AND OVERNIGHT EXPRESS Mr. Steve Worrall, Senior Civil Engineer City of Santa Ana Public Works Agency Water Resources Division Corporate Yard, M -85 220 S. Daisy Avenue Santa Ana, CA 92702 • 215 NORTH MARENoo AVENUE, 3RD FLOOR PASADENA, CALIFORNTA 91101 -1504 PHONE: (626) 4494200 FAX: (626) 4494205 ROBERT@ ROBERTSILVERMINIAW.COM www.RoSERTSiLvERMINLAW.COM Re: Supplemental Objections to Recirculated Draft and Final Environmental Impact Report for the San Lorenzo Sewer Lift Station Project, SCH No. 2010041028 Dear Mr. Worrall: I. INTRODUCTION. This firm represents Santa Ana California Lodges, LLC, owner of the improved property located at 2909 S. Bristol Street, Santa Ana, California. This correspondence constitutes our supplemental written comments on and objections to the Recirculated Final EIR ( "RFEIR ") for the San Lorenzo Sewer Lift Station Project ( "Project "). These comments are based, in part, on responses to comments on the Recirculated Draft EIR ( "RDEIR "), along with California Public Record Act requests precipitated by release of both the RDEIR and RFEIR. Please ensure that all communications from the City of Santa Ana ( "City ") to our client regarding the Project are also promptly copied to our office. All objections, including those regarding proper notice and due process, are expressly reserved, and all prior objections are incorporated herein by reference. Please also ensure that notice of all hearings, actions, events and decisions related to the Project are timely provided to this office. II. THE PROJECT DESCRIPTION IS INACCURATE AND MISLEADING. For nearly three years — through a Mitigated Negative Declaration, litigation, and a prior EIR so faulty that the City admitted recirculation was necessary — the public and the 55A -134 0 0 Mr. Steve Worrall January 13, 2012 Page 2 decision makers have been led to believe that the existing lift station had inadequate capacity and that Project objectives were tied to those capacity issues. However, when we noted in comments on the prior EIR that the Project would not provide any additional capacity, the language and objective related to capacity mysteriously disappeared from the RDEIR. (See comment J -6.) When we asked why, the City's response in the RFEIR was essentially "oops. We goofed up. Capacity really isn't inadequate after alI." Now, we and the public are presented with a new Project description and new objectives that are equally suspect and cannot withstand scrutiny. According to the RFEIR's rejiggered Project Description: "The primary objective of the Proposed Project is to provide a new sewage lift station to replace the existing Segerstrom Lift Station, which was originally constructed in the 1960s, most recently upgraded in 1989, and has since exceeded its design life. The exiting lift station is prone to frequent maintenance (two to three times per week) in order to clear blockages due to debris collected in the system. In addition, due to the age of the equipment, the existing pumps are subject to frequent mechanical failures (requiring maintenance), and it is difficult to obtain necessary replacement parts for the facility" (P. 2- 6) The new Project objectives are tied to this description of the existing lift station. A review of relevant records, however, shows this description to be both misleading and inaccurate.1 ` We also note that although this is a "new" EIR, it is still tied to the prior EIR and administrative process because the Project is the same and the proposed execution of the Project is identical to what was described before. Therefore, the City's shifting of the Project description (in an attempt to bypass valid objections) for the same Project is a separate violation of CEQA that provides independent grounds to invalidate this RFEIR. An incomplete or misleading project description improperly curtails environmental review and the consideration of mitigation measures and project alternatives. "Only through an accurate view of the project may affected outsiders and public decision - makers balance the proposal's benefit against its environmental cost, consider mitigation measures, assess the advantage of terminating the proposal (i.e., the `no project' alternative) and weigh other alternatives in the balance. An accurate, stable, and finite 55A -135 • Mr. Steve Worrall January 13, 2012 Page 3 A. Age and Replacement Parts. • According to the attached supplement report from Mr. Bonneau Dickson, P.E. (Exhibit 1), a consulting sanitary engineer with over 30 years experience, the only part of the lift station constructed in the 1960s that is still in service is the wet well — essentially a large manhole. Mr. Dickson's review indicates that not a single piece of mechanical or electrical equipment from the 1960s, is still in use. The 1989 upgrade included all new mechanical and electrical equipment. (Dickson Report, Exhibits A & B.) Moreover, the RDEIR fails to disclose that the two pumps were entirely rebuilt in 2007. (Dickson Report at p. 2, Exhibit C.) This renders the RDEIR assertion with respect to design life and difficulty in securing replacement parts even more false and misleading. According to Mr. Dickson, the rebuilding of the pumps in 2007 should extend their effective life to 2025. Moreover, the wet well should have an effective life of at least 100 years. With respect to the cost and availability of replacement parts, Mr. Dickson contacted a representative of Gorman Rupp, the manufacturer of the pumps. According to an email from the representative to Mr. Dickson, attached to his report as Exhibit D: "The T10A3 -B pump that is in use at the existing pump station is still manufactured. Parts for it are readily available. A new pump would cost around $11,000. A new rotating assembly for the pump would cost around $5,000. The pump is extremely rugged and many units are still in service after 30 years." This leaves the claims of an end of the lift station's useful life and difficulty in obtaining replacement place false at best, outright fallacious at worst, and eliminates the stated justification for the Project. B. Maintenance Issues. The RDEIR asserts that the exiting lift station is prone to frequent maintenance in order to clear blockage. Mr. Dickson's review of maintenance logs, however, shows the following maintenance calls by year: project description is the sine qua non of an informative and legally sufficient EIR." County of Inyo v. City of Los Angeles (1977) 71 Cal.App.3d 185, 192 -193. 55A -136 0 Mr. Steve Worrall January 13, 2012 Page 4 2004-4 2005-5 2006-5 2007-7 2008-2 2009-10 2010-30 2011-104 The logs are attached as Exhibit 2. For 2010, there are only five entries prior to September 13, none of which mention rags or debris. If there was some event that precipitated the need for bi- weekly rag and debris removal, that event should have been disclosed in the RDEIR. This failure to disclose provides inadequate information for informed decision making. Given that this apparent change came at approximately the time of our September 10, 2010 objection letter pointing out that the Project did not meet then - stated Project objectives with respect to an alleged need for increased hydraulic capacity, this also suggests merely a change (or falsification) in reporting practices starting in mid- September 2010 in order to manufacture a new justification for the Project. Additionally, the maintenance logs do not show a significant number of mechanical failures, further weakening the claimed justification for a new station. III. THE PROJECT DOES NOT MEET PROJECT OBJECTIVES. ?e t 6,e5 One of the Project Objectives is "to provide a lift station facility in which PC electrical components of the facility are housed above ground so as to preclude the potential for electrical failure during peak storm events (due to flooding)." As Mr. Dickson points out, the design of the proposed Project does not meet this objective. Drawings for the Project show the motors below ground level in the dry pit, with the potential for flooding and electrical failure. IV. THE PROJECT HAS A SIGNIFICANT AIR QUALITY IMPACT. -- oa62�'- The RFEIR asserts that the zone of a potentially significant odor impact is "around 75 feet." ( RFEIR, p. 3.1 -37.) This means that the border of the zone encompasses a range both less than and greater than 75 feet. The RFEIR places the nearest sensitive receptor at approximately 75 feet 6 inches away from the Project's exhaust fan. This a 0 55A -137 0 0 Mr. Steve Worrall January 13, 2012 Page 5 makes it reasonably foreseeable that the nearest sensitive receptor is within the zone, even though the RFEIR indicates that the impact to that receptor is less than significant. The City then tries to have it both ways, saying the impact is both less than significant and significant. The City cannot have it both ways. Either the impact is significant or it is not. V. THE ALTERNATIVES ANALYSIS IS LEGALLY INADEQUATE. A. The City Has Deliberately Designed Straw Men Alternatives. What the RFEIR suggests is an "exhaustive analysis" of alternative sites is nothing more than an exercise in the creation of straw men alternatives deliberately designed to create greater environmental impacts, thus dooming them to failure. See Sierra Club v. Contra Costa County (1992) 10 Ca1.App.4th 1212, 1217 -1218, 1222. This results in an improper and inadequate alternatives analysis. The most glaring example of this straw man approach to creating alternatives is with respect to air quality and odor. Most of the alternative sites are large areas. In the case of Alternative Site 2, Segerstrom Triangle, the size is over 1.7 acres. Other sites are large parking lots. Within many of these sites, though, the City has deliberately placed the lift station within 75 feet of a sensitive receptor to place the receptor within a potentially significant odor zone of "around 75 feet." ( RFEIR, p. 3.1 -37.) Similarly, the RFEIR does this for Alternative Sites 3. This is a classic example of creating straw men. G (ii In the case of Segerstrom Triangle, the City compounds the inadequacy by O C= creating straw men to knock down in support of its straw man, telling us why other Cam /� x ` Moreover, what substantial evidence does exists shows the nearest sensitive receptor to be within the zone. Figure 3.1 -2 of the prior FIR showed the nearest motel room at approximately 57 feet away from the Project, even though it was not then referred to as a sensitive receptor. We asked in a California Public Records Act request on October 7, 2011 for documents showing how the City arrived at the 75.5 -foot distance used in the RDEIR. The City, in its response, said it did not have any responsive documents showing how it arrived at that figure (Exhibit 3), leaving the only evidence as Figure 3.1 -2 from the prior EIR. (See also Exhibit 4 [Giroux correspondence].) f;� 0 0 Mr. Steve Worrall January 13, 2012 Page 6 portions of the site are unacceptable.' The fact remains, though, that simply moving the structure as little as five feet or putting the exhaust fan on the other side of the structure means there is no impact. B. Parking Capacitv Below Code Standards Is Not An Environmental Impact. In its response to comments on numerous alternative sites, the City continues to assert that reducing parking capacity below code requirements, even by a minor amount, is a significant environmental impact. A claim of inadequate parking in and of itself, however, is not necessarily a significant environmental impact to which CEQA applies. As the Court of Appeal has noted: "[T]here is no statutory or case authority requiring an EIR to identify specific measures to provide additional parking spaces in order to meet an anticipated shortfall in parking availability. The social inconvenience of having to hunt for scarce parking spaces is not an environmental impact; the secondary effect of scarce parking on traffic and air quality is. Under CEQA, a project's social impacts need not be treated as significant impacts on the environment. An EIR need only address the secondary physical impacts that could be triggered by a social impact." San Franciscans Upholding the Downtown Plan v. City and County of San Francisco (2002) 102 Cal.App.4th 656, 698 (emphasis in original). Indeed, parking no longer appears in the CEQA Appendix G checklist. The California Resources Agency removed parking from the Appendix G Checklist in part based on San Franciscans Upholding the Downtown Plan. As the Agency explained in its December 2009 Final Statement Of Reasons For Regulatory Action: "The Natural Resources Agency is aware of no authority requiring an analysis of parking adequacy as part of a project's environmental review. Rather, the Agency concurs With respect to a rejection of locating the facility along Segerstrom, there also appears to be use of a different criterion for sensitive receptors, using the property line in measuring distance from the school, but using residential structures as the measurement criteria for the Project. Application of criteria must be consistent. 55A -139 r- 0 0 Mr. Steve Worrall January 13, 2012 Page 7 with the court in the San Franciscans case that inadequate parking is a social impact that may, depending on the project and its setting, result in secondary effects. Consistent with existing CEQA Guidelines section 15131(a), deletion of the parking adequacy question from Appendix G checklist will ensure that the focus of the analysis shall be on the physical changes. Specifically, the Appendix G checklist contains questions asking about possible project impacts to air quality and traffic." (Exhibit 5 [Exccrpt from the Final Statement].) The RFEIR does not show any evidence of the potential loss of a few parking spaces on air quality or traffic. Thus, the alternatives matrix in Table 5 -1 must be adjusted accordingly and will show that on this basis alone Alternative Sites 3, 5, 6 and 8 are environmentally superior to the Project and Alternative Sites 15, 18 and 19 are the environmental equivalent of the Project. C. The Analysis Of Individual Alternative Sites Is Lezally Inadequate. 1. Alternative Site 2. In our prior objection letter of October 31, 2011, we provided substantial evidence to show a correct analysis of Alternative Site 2, the Segerstrom Triangle, which actually shows less traffic impacts, less water quality/hydrology impacts, and a likely shorter construction period. The RDEIR also overstates odor and recreational impacts. Further analysis by Mr. Dickson confirms each of these conclusions. In particular, his report notes a likely shorter construction schedule, which will result in a corresponding reduction in air quality emissions. He also quantifies the reduction in traffic impacts. With respect to recreation, in claiming the loss of 0.03 acres of passive recreational space in the Segerstrom Triangle will cause a significant and unavoidable City -wide impact to recreation, the RFEIR asserts that park users will be effectively concentrated in a smaller area, leading to an accelerated physical deterioration of existing park facilities. The response, though, fails to disclose the required analytic route traveled to reach that conclusion. See Laurel Hei htg s Improvement Assn. v. Regents of the Univ. of California (1988) 47 CaI.3d 376. 55A -140 Mr. Steve Worrall January 13, 2012 Page 8 • Moreover, to rely on a "grant application" as further evidence of a significant impact is to rely on false information. There is no grant application pending of which we are aware, and despite requests, this firm was never provided with such an application — not on October 31, 2011 or at any other time. What the City submitted to the California Resources Agency, and what was provided to this firm, was a concept proposal in response to a mass solicitation for such proposals. (Exhibit 6.) According to the FAQ for the process, which we submitted with our October 31, 2011 correspondence as Exhibit 4, the proposal process is itself competitive and "invitations to submit full applications are anticipated to be issued two or three months after the concept proposals are received, with applications due in the fall of 2011." The RFEIR cites the FAQ ( RFEIR, p. 64), but fails to include this language. The response is written as though the City has a competitive grant application pending, for which awards will be announced in early 2012. If the City was invited to submit a grant application based on the concept proposal, it has misled us and our client, and violated the California Public Records Act by failing to disclose the application in response to a request made under the Act. If the City was not invited to submit a grant application, then the response itself is false and a deliberate attempt to mislead the public. With respect to traffic, Response to Comment 13 claims it is "unclear" how more laydown space potentially results in a shorter construction duration and a reduction in associated traffic impacts. Mr. Dickson's February 7, 2011 Report (Exhibit 7 to our correspondence of October 31, 2011) could not be more explicit: "A larger laydown area should allow equipment from one phase to be moved to the site before the prior phase has concluded, allowing for an overlap of phases that compresses the construction schedule." As he further explains in Exhibit 1 to this correspondence: "The fact that the contractor would have access to all four sides of the project at Site No. 2 would provide more alternatives for the contractor to shorten the duration of construction than would be available at the proposed project site, where the contractor has full access only from one side, and only partial access from Segerstrom Avenue." Indeed, despite the Response's claimed lack of clarity, it nevertheless appears to accept Mr. Dickson's conclusion by noting that "it is reasonable to conclude that additional laydown space could reduce total construction time for the alternative..." 55A -141 • Mr. Steve Worrall January 13, 2012 Page 9 • (RFEIR, p. 70. See also RFEIR p. 72 [ "...while Alternative Site No. 2 could be constructed more quickly than indicated in the RDEIR... "].) Reduced construction time results in reduced impacts. With respect to water quality and hydrology, the FRIER asserts with no substantial evidence that the 16 -foot deep, 50 -foot long sewer by -pass required for the Project somehow has less impact than the additional sewer pipe required for Alternative No. 2. 2. Alternative Site 3. In our prior objection letter of October 31, 2011, we provided substantial evidence to show that Alternative Site 3, 2835 S. Bristol Street, results in less construction - related traffic impacts and that the impacts from odors are, to put it blund , fabricated. This is confirmed in Mr. Dickson's attached report. e z 1v i e- 51 � 3. Alternative Site 5. Mr. Dickson's prior alternatives analysis provided to the City on August 27, 2010 indicated that use of this site would require approximately 100 feet less force main and gravity sewer than the San Lorenzo site. His report attached hereto also indicates that use of this site will not require construction of a temporary by -pass. This will result in less land disturbance, which the City identifies elsewhere in the RDEIR as resulting in a lesser impact to water quality and hydrology. Table 5 -1 should be revised accordingly. Use of Alternative Site 5 will also shorten Phase 2 by at least four week. A shorter construction time leads to reduced air quality impacts than the San Lorenzo site. Again, Table 5 -1 should be revised accordingly The purported parking impact is not as severe as suggested. The operational deficiency, according to the Santa Ana Municipal Code, will only be six spaces — approximately 4% — and only temporarily. Section 41 -638.1 of the Code recognizes that less than Code required parking will not always create a potentially significant impact by providing for minor exceptions to off - street parking requirements. This is equally applicable to any alternative for which a potentially significant parking impact is claimed. The analysis also asserts that the alternative would be "legally infeasible" because it would result in a violation of the City's Municipal Code requirements for off - street parking. This is incorrect. The Municipal Code provides for exceptions to off -street parking requirements and there is nothing to preclude the City from taking an action that 55A -142 Mr. Steve Worrall January 13, 2012 Page 10 would result in the remainder of the property being non - conforming with respect to parking. To the contrary, the City's power of eminent domain, as well as access to City - owned land, suggests that alternative sites "may be more feasible, more often," when the developer is the City rather than a private party. Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 574. This analysis is equally applicable to each alternative for which a significant parking impact is claimed. Mr. Dickson's report also notes that access from West Segerstrom and the north/south alley will be maintained, meaning sufficient emergency access will also, in fact, be maintained. Finally, as noted in Section V.B., parking below code requirements is not per se an environmental impact. Accordingly, Table 5 -1 must be revised to show that Alternative 5 is environmentally superior to the Project. 4. Alternative Site 7. The RDIER asserts that Alternative Site 7 would have a greater operational odor impact and a greater construction noise impact than the San Lorenzo site. However, no distance to sensitive receptors has been identified, and no specific area within the site has been proposed. There is thus no substantial evidence in the record to support these conclusions. The purported parking impact is not as severe as suggested. The operational deficiency, according to the Santa Ana Municipal Code, will only be 13 spaces during construction and 5 spaces during operation, based on a requirement of 401 spaces. This is a minor amount and Section 41 -638.1 of the Code recognizes that less than Code required parking will not always create a potentially significant impact by providing for minor exceptions to off - street parking requirements. This is equally applicable to any alternative for which a potentially significant parking impact is claimed. The analysis also asserts that the alternative would be "legally infeasible" because it would result in a violation of the City's Municipal Code requirements for off - street parking. This is incorrect. The Municipal Code provides for exceptions to off -street parking requirements and there is nothing to preclude the City from taking an action that would result in the remainder of the property being non- conforming with respect to parking. To the contrary, the City's power of eminent domain, as well as access to City - owned land, suggests that alternative sites may be "more feasible, more often," when the developer is the City rather than a private parry. Citizens of Goleta Valley v. Board of 55A -143 Mr. Steve Worrall January 13, 2012 Page 11 Supervisors (1990) 52 Cal.3d 553, 574. This analysis is equally applicable to each alternative for which a significant parking impact is claimed. Moreover, Table 5 -1 fails to account for reductions to other significant traffic impacts, even though reductions in those impacts are noted in the RDEIR. (P. 5 -44, 45.) In particular, as identified by Mr. Dickson, reducing West Segerstrom Avenue to a single eastbound lane for 25 weeks will not be required and construction in the intersection of West Segerstrom Avenue and South Bristol Street will be avoided. At the very least, these reductions in impacts must be considered as offsets in Table 5 -1. Mr. Dickson's report also explains how the RDEIR grossly overstates any construction challenges at this site relative to the San Lorenzo site. Additionally, as noted in Section V.B., parking below code requirements is not per se an environmental impact. Accordingly, Table 5 -1 must be revised to show that Alternative 7 is environmentally superior to the Project. 5. Alternative Site 8. The purported parking impact is not as severe as suggested. Section 41 -638.1 of the Code recognizes that Iess than Code required parking will not always create a potentially significant impact by providing for minor exceptions to off - street parking requirements. This is equally applicable to any alternative for which a potentially significant parking impact is claimed. The analysis also asserts that the alternative would be "legally infeasible" because it would result in a violation of the City's Municipal Code requirements for off - street parking. This is incorrect. The Municipal Code provides for exceptions to off - street parking requirements and there is nothing to preclude the City from taking an action that would result in the remainder of the property being non - conforming with respect to parking. To the contrary, the City's power of eminent domain, as well as access to City - owned land, suggests that alternative sites may be "more feasible, more often," when the developer is the City rather than a private party. Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 574. This analysis is equally applicable to each alternative for which a significant parking impact is claimed. Table 5 -1 also fails to account for reductions to other significant traffic impacts, even though reductions in those impacts are noted in the RDEIR. (P. 5 -50, 51.) At the very least, these reductions in impacts must be considered as offsets in Table 5 -1. 55A -144 0 0 Mr. Steve Worrall January 13, 2012 Page 12 Finally, as noted in Section V.B., parking below code requirements is not per se an environmental impact. Accordingly, Table 5 -1 must be revised to show that Alternative 8 is environmentally superior to the Project. b. Alternative Site 12. The RDEIR claims that Alternative Site 12 would require a slightly elongated construction schedule, even though there is 42% less conveyance, because of additional supporting and the need to dig to a slightly deeper depth. However, as Mr. Dickson points out, this fails to account for a reduction in other phases of construction. Neither construction of a by -pass nor relocation of the SCE pole will be necessary, allowing for a reduction in that phase of construction. Unlike the San Lorenzo site, construction on the pipeline infrastructure and lift station can also occur simultaneously, further reducing the construction schedule and related emissions. Mr. Dickson's report also notes that the construction challenges at this site relative to the Project as proposed are greatly overstated. Table 5 -1 must be adjusted accordingly. The purported parking impact is not as severe as suggested. Section 41 -638.1 of the Code recognizes that less than Code required parking will not always create a potentially significant impact by providing for minor exceptions to off - street parking requirements. This is equally applicable to any alternative for which a potentially significant parking impact is claimed. The analysis also asserts that the alternative would be "legally infeasible" because it would result in a violation of the City's Municipal Code requirements for off - street parking. This is incorrect. The Municipal Code provides for exceptions to off - street parking requirements and there is nothing to preclude the City from taking an action that would result in the remainder of the property being non- conforming with respect to parking. To the contrary, the City's power of eminent domain, as well as access to City - owned land, suggests that alternative sites may be "more feasible, more often," when the developer is the City rather than a private party. Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 574. This analysis is equally applicable to each alternative for which a significant parking impact is claimed. Moreover, Table 5 -1 fails to account for reductions to other significant traffic impacts, even though reductions in those impacts are noted in the RDEIR. (P. 5 -73, 74.) At the very least, these reductions in impacts must be considered as offsets in Table 5 -1. 55A -145 • Mr. Steve Worrall January 13, 2012 Page 13 Additionally, as noted in Section V.B., parking below code requirements is not per se an environmental impact. Accordingly, Table 5 -1 must be revised to so reflect. The RDEIR indicates that there will be less area of ground disturbance resulting from this alternative because less underground sewer infrastructure will be necessary. (P. 5 -75.) Yet, Table 5 -1 mistakenly indicates that water quality impacts of the alternative are greater. This correct analysis, based on substantial evidence in the record, shows Alternative Site 12 to be environmentally superior to the Project. The table must be revised accordingly. VI. THE PROJECT ALTERNATIVES ARE NOT COMPARED TO THE PROJECT. The City continues to improperly compare the mitigated Project to alternatives without mitigation for purposes of determining environmental superiority. The City's response to comments that the concept is a "novel" one that is not supported by the CEQA Guidelines or applicable case" (RFEIR, p. 79) is curious since this "novel" concept has been provided for in CEQA for nearly 25 years. "[A]gcncies are required to certify the completion of an EIR `on any project they propose to carry out or approve.' (§ 21100.) As a matter of logic, the EIR must be prepared before the decision to approve the project. Not until project approval does the agency determine whether to impose any mitigation measures on the project. (§ 21002. 1, subd. (b).) One cannot be certain until then what the exact mitigation measures will be, much less whether and to what degree they will minimize environmental effects. According to the Regents, the decision to require mitigation measures on project approval removes the need to consider project alternatives in the EIR. The decision imposing mitigation measures, however, is not made, and cannot be made under CEQA, until after the EIR has been completed. To adopt the Regents' view, would be to say that alternatives need not be discussed if there is a possibility that the agency might adopt mitigation measures. Such result would invert the chronology of the CEQA process. Laurel Heights _ _Improvement Assn. v. 55A -146 0 0 Mr. Steve Worrall January 13, 2012 Page 14 Regents of University of California (1988) 47 Ca1.3d 376, 401 -402. So it is here. If the existence of mitigation for a project cannot be used to dismiss alternatives analysis altogether, it also cannot be used when comparing a project to an alternative once that alternative is selected. To do so, as the City does here, would lead to the very conclusion rejected by the California Supreme Court in Laurel Heights. VII. A SUBSTANTIALLY LESS EXPENSIVE AND SUPERIOR PROJECT CAN BE CONSTRUCTED AT THE EXISTING SEGERSTROM SITE. The City's response to a California Public Records Act request in 2010 indicated that the estimated Project cost was a minimum of $3,500,000 to $4,000,000. Mindful of the City's current and near term fiscal problems,4 it would make sense to further investigate other feasible and less expensive alternatives. One such alternative would be a submersible pump station at the existing Segerstrom site, using the existing 8 -feet diameter wet well. This alternative project is detailed in Mr. Dickson's report. This alternative would have the benefit of providing the City with a new pump station that reduced substantially the impacts of the Project, including those to traffic, air quality, hazards and hazardous materials, noise and water quality. The construction time of a submersible pump station is significantly less than that estimated for the Project. The cost of a submersible pump station is also significantly less than that of the Project. Mr. Dickson estimates the cost at $748,000 — less than one- fourth the cost of the Project. The pumps can be fitted with grit -flush valves that could also reduce maintenance costs associated with pumping grit from the bottom of the wet well. Such an alternative would address most of the legitimate needs of the City. Failure to analyze such an alternative results in a failure of the RFEIR to analyze a reasonable range of potentially feasible alternatives. 4 Recent news reports indicate that the City's General Fund balance dipped to as low as $161,000 this past summer, and faces a potential $30 million budget deficit for fiscal year 2012 -13. (Exhibit 5.) 55A -147 0 0 Mr. Steve Worrall January 13, 2412 Page 15 VIII. CONCLUSION. The RFEIR is fatally flawed. It violates the Court's prior Judgment and Writ, and violates CEQA innumerous respects. The Project, as proposed, and the RFEIR must be rejected. Please promptly advise this office of any actions or hearings in this matter. Very tru o OBERT P. SILVERSTEIN FOR THE SILVERSTEIN LAW FIRM RPS:jmr Attachments cc: Mayor Miguel Pulido Mayor Pro Tem Claudia Alvarez Councilmember Carlos Bustamante Councilmember David Benavides Councilmember Sal Tinajero Councilmember Vincent Sarmiento Paul M. Walters, Interim City Manager Josd Sandoval, Chief Assistant City Attorney All for distribution via Maria D. Huizar, Clerk of the Council, via Overnite Express •� le EXHIBIT 1 55A -149 0 0 2428 McGee Avenue Berkeley, CA 94703 (510) 845 -8625 (510) 845 -4606 FAX dickson.bonneau @gmail.com Bonneau Dickson, P.E. Consulting Sanitary Engineer January 12, 2012 Mr. Robert Silverstein, Esq. The Silverstein Law Firm 216 North Marengo Avenue, 3rd Floor Pasadena, CA 91101 -1504 Dear Mr. Silverstein: At your request, I have reviewed the September 15, 2011 Recirculated Draft Environmental Impact Report (RDEIR) documentation for the San Lorenzo Sewer Lift Station Project in the City of Santa Ana, California and the City's Final Environmental Impact Report (FEIR) recently issued. My review and analysis focused on: • The alleged age of the existing Segerstrom Lift Station. • Maintenance issues with the existing Segerstrom Lift Station. • A review of the RDEIR's analyses of some of the alternative sites. • Creation of an environmentally and economically superior alternative that would involve converting the existing Segerstrom Lift Station into a submersible lift station. • The City's FEIR comments on your letter of October 31, 2011. (Starting on Page FEIR -54). AGE OF THE EXISTING PUMP STATION The age of the existing pump station is relevant to the project objectives, which are discussed starting on Page 2-6 of the RDEIR. According to the RDEIR, the primary objective of the proposed project is said to be the replacement of the existing pump station "that has exceeded its design life." The RDEIR notes that the pump station was built in the 1960s. It also mentions that the station was rebuilt in 1989. 55A -150 Mr. Robert Silverstein, Esq. 0 Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 2 of 18 What the RDEIR does not say is that the 1989 project included totally new mechanical and electrical equipment. There is not a single piece of mechanical or electrical equipment from the 1960s pump station that is still in use. The 1989 plans for the rehabilitation of the Bristol Pump Station (as it was then called) and the Maxine Pump Station were prepared by the engineering firm CWC -HDR, Inc. Drawing 6 of 10 shows that the original 1960s pump station had its pumps in the 8 -foot diameter concrete structure and that all of the mechanical and electrical equipment from the 1960s project was removed in the 1989 project. See Exhibits A and B. The 8 -foot diameter pump station structure became the wet well for the 1989 project and is the only part of the 1960s facility that is still in use. None of the maintenance reports that I have been provided mention any problems with this structure. The wet well structure is essentially a large manhole. Usually manholes have an effective life of one hundred years or more. The FOR refers again in comment J -6 on Page FEIR -60 to the "age of the equipment" implying that the equipment is very old. This is factually incorrect, The real truth is that the existing pump station is a 1989 pump station, not a 1960s pump station. Furthermore, the two pumps were completely rebuilt in 2007. See the attached invoice from the Orange County Pump Company. (Exhibit C.) The invoice reads, "Disassemble and assess all pump and motor components. Remove and replace the following parts ". The listed parts include the seals and bearings, i.e. the parts that are likely to wear out. There is a handwritten note on the invoice saying, "Work Completed 2- 1 -07 ", The pumps that were installed in 1989 were rebuilt in 2007, 18 years later. The complete re -build of the pumps should have brought them back to near new condition, thus they should last for at least approximately another 18 years, i.e. until the year 2025. The RDEIR asserts in Paragraph 2,2 on Page 2-6 and elsewhere that, "...it is difficult to obtain necessary replacement parts for the existing equipment," and uses this as another justification for the Project. This assertion is repeated in comment J-6 on Page FEIR -60. 55A -151 Mr. Robert Silverstein, Esq. 0 is Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 3 of 18 I contacted Thomas and Associates, a representative of Gorman Rupp, the company that manufactured the existing pumps. According to the attached email (Exhibit D) from Thomas and Associates: The T10A3 -B pump that is in use at the existing pump station is still manufactured. Parts for it are readily available. A new pump would cost around $11,000. A new rotating assembly for the pump would cost around $5,000. The pump is extremely rugged and many units are still in service after 30 years. The RDEIR and FOR assertion that replacement parts are difficult to obtain is pure fabrication. A simple telephone call or email to the pump manufacturer would have revealed that replacement parts are readily available. Obviously no attempt has been made to determine if replacement parts are available. MAINTENANCE ISSUES The RDEIR and FEIR also identified frequency of maintenance as a justification for the proposed Project. A review of maintenance logs, though, only results in more questions. Copies of the maintenance log book from 1/28/04 through 6130110 were previously produced by the City. More recently, the City produced copies of the maintenance log book through 10111111. The entries in the log book show the unscheduled maintenance (emergency callouts) at the existing pump station. The number of unscheduled maintenance entries per year in the maintenance log book are noted in the table below. 55A -152 Mr. Robert Silverstein, Esq. 0 0 Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 4 of 18 MAINTENANCE LOG BOOK UNSCHEDULED MAINTENANCE ENTRIES Year No. of Entries Remarks 2004 4 Nearly all of the year. First entry is 1128104. 2005 5 2006 5 2007 7 2008 2 2009 10 2010 30 Five entries prior to 9113110, none of which mention rags or debris in the pumps. Twenty -five entries from 9113110 through the end of 2010, many of which mention rags, debris, clothes and trash. 2011 1 104 [Through 10111111. There are entries for 9113/10 and 9120110, which do not mention rags, debris or clothes, then the entries begin to be much more frequent and they begin to regularly mention rags, debris, clothes and trash. The entry after the 9/20110 is for 9114/10, out of order. The 9/14/10 entry and the following three are identical. The number of unscheduled maintenance entries from 2004 through September 13, 2010 vary from two to ten and average only five per year. Then suddenly in September, 2010, the number of entries shoots way up. There are 25 entries from mid - September through the end of 2010 and 104 entries in 2011. The wording of many of the entries is very similar. It is patently obvious that the City began padding the number of maintenance callouts starting in mid - September, 2010 merely to support the findings of its defective EIR. 55A -153 Mr. Robert Silverstein, Esq. • 0 Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 5 of 18 ALTERNATIVES ANALYSIS The Alternatives Analysis in the Recirculated DEIR is incomplete, inaccurate and incorrect in numerous places. 5.4.4 ALTERNATIVE SITE No. 2 In this alternative, the pump station would be placed on City -owned property, a short distance east of the proposed site. Since the City already owns this property, this site should receive a very high consideration. Duration Of Construction The RDEIR and comments J -13 through J -17 of the FOR note that the length of sewer and force main would be approximately doubled in this alternative and then claim that the duration of construction would be increased. No explicit information is provided to support this assertion and, in fact, it is incorrect. Phase 2 of the construction schedule includes eight (8) weeks for "Clearing /Grubbing /SCE Pole Relocation ". See Exhibit K. This phase includes construction of the temporary sewer bypass. The major part of the time is required for construction of the temporary sewer bypass. If Alternative Site No. 2 is used, there will be no need for the temporary bypass and the SCE pole will not have to be relocated. Thus the time for Phase 2 could be reduced by at least four weeks and possibly by as many as seven weeks. Construction of the force main and sewer is in Phase 11 of the construction schedule. See Exhibit K. Four (4) weeks is allowed for Phase 11. Since the length of the force main and sewer for Alternative Site No. 2 is about double the length in the proposed project, the duration of construction might also be about double, i.e. four weeks more. As noted above, though, this amount of time would be easily offset by the reduction in the duration of Phase 2. It should also be noted in Exhibit K that Phase 11, the construction of the force main and sewer is scheduled to take place after the construction of the pump station (Phases 4 through 10). This was necessary because the pump station site is so congested and access is so limited that it is not feasible to work on both the sewer and the pump station at the same time. At most of the other alternative sites, there is more space and better access, thus construction of the sewer could proceed simultaneously with construction of the pump station, further reducing overall construction duration. 55A -154 Mr. Robert Silverstein, Esq. 0 . Review Of The Recirculated DEIR And FOR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 6 of 18 Comment J -13 starting on Page 69 of the FEIR attempts to dismiss the fact that the additional laydown space that is available at Site No. 2 would likely result in a shorter duration of construction. (It might also reduce the bid price). The FEIR comments that the duration of construction will depend upon the contractor's means and methods. This is true but irrelevant. The fact that the contractor would have access to all four sides of the project at Site No. 2 would provide more alternatives for the contractor to shorten the duration of construction than would be available at the proposed project site, where the contractor has full access only from one side, and only partial access from Segerstrom Avenue. In comment J -16 on Page 72 of the FOR the greater depth of the pump station at Site No. 2 is mentioned. The use of the park site would require about 700 -feet of additional 15 -inch gravity sewer. The 15 -inch gravity sewer between the intersection of Bristol Street and Segerstrom Avenue is shown on Drawing C -3 (Sheet 6) to be 0.0020. The additional depth of the pump station at Proposed Site No. 2 thus would be: 700 Feet * 0.0020 Slope = 1.4 Feet. This additional depth of the pump station is trivial compared to the overall depth of about 30 -feet. In comment J -17 on Page 73 of the FOR there is a discussion that the impact on the intersection of South Bristol Street and Segerstrom Avenue is the same for both the proposed Project and for Site No. 2, as if this somehow detracts from the attractiveness of Site No. 2. The statement in comment J -17 is true, but irrelevant. The relevant point is that Site No. 2 does not cause any additional impact on the intersection. Odors The RDEIR and comment J -10 starting on Page 65 of the FOR assert that odor sensitive uses (residences) will be within 75 -feet of Alternative Site No. 2. The RDEIR does not identify which residences it is referring to, provides no documentation for this assertion, and clearly is inaccurate and incorrect. The claim that the point of odor release would be within 75 -feet of the residences is patently meant to be deceptive since the pump station could easily be located further back in the City owned property'. 55A -155 Mr. Robert Silverstein, Esq. 0 • Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 7 of 18 South Shelton Street is approximately 40 -feet wide from back of sidewalk to back of sidewalk. The residences on the west side of South Shelton Street are set back at least five feet from the back of sidewalk. A setback of at least this amount would be provided on the east side of South Shelton Street, creating a distance of at least 50 -feet from the superstructure of the proposed pump station to the nearest residence. The superstructure of the proposed pump station is 30 -feet long. Simply putting the vent at the other end of the structure would place it 80 -feet from the residences, even if a minimum setback of only 5 -feet is provided at South Shelton Street. As noted above, the pump station could easily be moved further back in the City owned property. The facts above equally apply to many of the other alternative sites. Recreation The RDEIR and comment J -7 of the FEIR claim that a pump station at Alternative Site No. 2 would reduce the size of the park by 0.03 acres, which is 1,307 square feet. In fact, the superstructure of the proposed pump station is only about 8' x 30', or 240 square feet. The rest of the structure is underground and would not interfere with using the area above for park purposes. Pump stations are often placed in parks. One of the best known examples is the Oceanside wastewater treatment plant and pump stations which are located next to and partially under the San Francisco Zoo. The New Brighton Wastewater Pump Station in Santa Cruz County is located in New Brighton State Beach. The pump station portion of the structure is underground. The superstructure contains toilets and showers for use by those who are visiting the beach. Most of the visitors do not even know that there is a pump station below the toilet facility, and the use of the recreational lands above are not affected. A wastewater pump station has just been completed in the grounds of the new UCSF Mission Bay Campus. Transportation And Traffic The RDEIR and comment J -12 on Page 68 of the FEIR assert that the impacts to transportation and traffic would be similar under both the proposed project and a project at Alternative Site No. 2. The construction schedule for the project clearly shows that this is not true. See Exhibit K. 55A -156 Mr. Robert Silverstein, Esq. 0 0 Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 8 of 18 In the construction schedule, traffic control plans B.1 and B.2 call for Segerstrom Avenue to be reduced to a single lane during construction of a pump station at the proposed site. These traffic control plans will be in effect from Phase 4 until Phase 10 of the project, which is from week 13 to week 37, a total of 25 weeks. Traffic control plans C.1 and C.2 cover the construction of the force main and sewer and have a duration of only four weeks. Since the length of the force main and sewer is approximately double for Alternative Site 2, the RDEIR suggests there might be traffic impacts for approximately an extra four weeks. In reality, the traffic impacts could be even less since much of the extra force main and sewer could be located in San Lorenzo Avenue, which is not a through street. In summary, Alternative Site No. 2 would result in impacts on Segerstrom Avenue for four to eight weeks while the proposed project will impact Segerstrom Avenue for 25 weeks, three to six times longer. 5.4.5 ALTERNATIVE SITE No. In this alternative, the pump station would be placed in the parking lot behind the commercial buildings at 2835 South Bristol Street. Duration Of Construction The RDEIR concedes that this site would require 23 percent less force main and that the shorter sewer would reduce the duration of construction by six days. As discussed for Site No. 2, Phase 2 (Clearing, Grubbing, Relocating The SCE Pole, And Construction Of A Temporary Bypass Sewer) would be shortened by at least four weeks. The duration of construction would further be reduced because construction of the pump station and the sewer and force main could proceed simultaneously since they do not interfere with each other at this site. Construction Of A Sewer In South Bristol Street At the top of Page 5 -27, the RDEIR notes the depth of the sewer and the number of utilities in the street and describes the trench work as being extremely difficult and requiring closure of part of the street. The length of new sewer in South Bristol Street scales as approximately 190 -feet. 55A -157 Mr. Robert Silverstein, Esq. is 0 Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Litt Station Project January 12, 2012 Page 9 of 18 The RDEIR fails to note that the proposed project also includes a deep sewer in South Bristol Street. Coincidentally, this part of the sewer in South Bristol Street also is 190 -feet long. Construction of the sewer for Site No. 3 would not be significantly different than construction of the sewer for the proposed project. Odors As in the analysis of Site No. 2, the RDEIR claims that there will be residences located less than 75 -feet from the pump station vent but it does not identify which residences it is referring to. In Figure 2 -5 of the RDEIR it can be seen that the public alley is 20 -feet wide and that there is another approximately 4 -feet of paved area up to the chain link fence. In Figure 2 -2 it can be seen that there are garages behind the houses that face on South Baker Street. These garages and space between them and the houses are approximately 25 -feet long. Thus the distance from the houses that face South Baker Street and the fence at the rear of Site No. 3 is about 49 -feet. If the vent is put at the opposite end of the 30 -foot long pump station structure, it will be at least 79 -feet from the residences, and this is without any set back from the chain link fence. Since some setback will surely be required, the residences will be well over 75 -feet from the vent of the pump station. Transportation And Traffic If Site No. 3 is selected, there will be no construction at the intersection of South Bristol Street and Segerstrom Avenue. This alone would dramatically reduce the impact that the project would have on transportation and traffic. The traffic control plans B.1 and B.2 in the construction schedule for the proposed project call for Segerstrom Avenue to be reduced to a single lane from Phases 4 through 10, a total of 25 weeks. Compared to this, Site No. 3 would not require any closures of Segerstrom Avenue. Because the length of construction in South Bristol Street is the same for both Site No. 3 and the proposed project, there will be no significant differences in impact on transportation and traffic on South Bristol Street. Comment J -18 of the FEIR totally misrepresents the significantly reduced impact on transportation and traffic that Site No. 3 would afford. Comment J -18 tries to equate a minor decrease in parking to weeks of lane closures in Segerstrom Avenue and construction in the middle of the intersection of South Bristol Street and Segerstrom Avenue. This is grossly misleading. 55A -158 Mr. Robert Silverstein, Esq. 0 • Review Of The Recirculated DEIR And FOR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 10 of 18 5.4.7 ALTERNATIVE SITE No. 5 Alternative Site No. 5 is located in the parking lot of the commercial complex at 3001 -3005 South Bristol Street. This is directly across Segerstrom Avenue from the site of the proposed project. The RDEIR concludes on Page 5 -39 (last paragraph of this alternative) that Site No. 6 is equal to the proposed project, except that there would be a deficiency of six parking spaces during construction and that emergency access to the site would be inadequate. A deficiency of six parking spaces out of the 140 that are required for the site only during the period of construction represents a deficiency of only four percent and seems trivial. Adequate parking spaces would be available after the project is completed. The last paragraph asserts that the inadequate emergency access would be detrimental to existing businesses but does not explain why this would be so or quantify the impact. Moreover, at the top of Page 5 -38 the RDEIR states that the number of lost parking spaces would maintain access from West Segerstrom Avenue and would ensure access to the north -south alley. This means that access for emergency vehicles would in fact be available. The RDEIR fails to note that the use of Site No. 3 would obviate the need for the temporary sewer bypass and relocation of the SCE pole in Phase 2. As discussed above, this would shorten Phase 2 by at least four weeks. 5.4.8 ALTERNATIVE SITE No. 6 Alternative Site No. 6 is in the southern part of the parking lot at 2840 South Bristol Street, which is the Burlington Coat Factory. The RDEIR concedes that this alternative would require 46 percent less underground sewer conveyance infrastructure than the proposed project, that the overall duration of construction activities would be decreased, and that there would be a slight reduction in long -term odor - related impacts. The RDEIR does not quantify the reduction in the duration of construction activities and fails to note that the use of Site No. 3 would obviate the need for the temporary sewer bypass and relocation of the SCE pole in Phase 2. As discussed above, this would shorten Phase 2 by at least four weeks. 55A -159 Mr. Robert Silverstein, Esq. 0 0 Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 11 of 18 The RDEIR notes that construction of a pump station at this site would result in a deficit of five parking spaces after the project is completed. A deficit of five parking spaces out of the 401 required parking spaces is only slightly over one percent and seems trivial. 5.4.9 ALTERNATIVE E No. 7 Alternative Site No. 7 is in the northeast comer of the same parking lot at 2840 South Bristol Street as Alternative Site No. 6. The RDEIR assumes that the pump station will be located in the northwest portion of the parking lot, claiming that this would result in less impact on traffic and transportation. The basis of this claim is not stated. The RDEIR concedes that the use of Site No. 7 would reduce the length of the underground sewer conveyance infrastructure by 77 percent. The reduction would be even greater if the pump station is located closer to the northeast corner of the parking lot. Location of the pump station a short distance away from South Bristol Street would allow all of the pump station construction activities to be in the parking lot and thus would result in no impact on traffic and transportation from the construction of the pump station. By contrast, construction of the pump station in the proposed project would reduce West Segerstrom Avenue to a single eastbound lane for 25 weeks. Site No. 7 would also avoid any construction at all in the intersection of South Bristol Street and West Segerstrom Avenue. These two factors would result in an enormous decrease in the impact on traffic and transportation. The RDEIR includes a long description of how difficult it will be to construct a sewer and force main in South Bristol Street. This argument is specious. The sewer and force main could in fact cross perpendicular to South Bristol Street and thus not run parallel to South Bristol Street. The gravity sewer is much deeper than all of the other utilities and thus would not conflict with them. The force main is a pressure pipe and does not have to slope continuously downward like a gravity sewer. It therefore can easily be snaked through the existing utilities. Although the RDEIR waxes eloquent about the difficulty of constructing a longitudinal sewer and force main in South Bristol Street, it fails to note that the proposed project includes 190 -feet of longitudinal sewer in South Bristol Street, Alternative Site No. 7 could totally avoid what the RDEIR describes as great difficulties. A;L"W1OfJ Mr. Robert Silverstein, Esq. is 0 Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Lift Station project January 12, 2012 Page 12 of 18 It would also be technically feasible to install the sewer and force main across South Bristol Street by trenchless techniques such as jacking and boring or horizontal directional drilling. If a trenchless technology is used for placing the pipes, the only work that would have to be done in South Bristol Street would be the connections of the gravity sewer to the existing manhole and connection of the force main to the existing force main. These connections would require only a small pit that could be constructed in at most three or four days each. This work could occur on weekends or at night so that the impact on traffic would be minimal. The RDEIR gives Alternative Site No. 7 credit for a reduction in the duration of construction of eight days. As discussed elsewhere, using sites other than the proposed site would avoid having to construct the temporary sewer bypass and relocate the SCE power pole, which would shorten the duration of construction by at least four weeks. The greater amount of space and the better access to the pump station in Site No. 7 would result in even more reduction in the duration of construction. The RDEIR states that impacts due to odors would slightly increase due to the decreased distance to nearby sensitive receptors, i.e, residential. This statement is incorrect. There are no nearby residences. As for Site No. 6, the RDEIR notes that construction of a pump station at this site would result in a deficit of five parking spaces after the project is completed. A deficit of five parking spaces out of the 401 required parking spaces is only slightly over one percent and seems trivial. 5.4.70 ALTERNATIVE SITE No. 8 Alternative Site No. 8 is located in the rear parking lot of a medical building located at 2810 South Bristol Street. The RDEIR concedes that the use of Site No. 8 would reduce the length of the underground sewer conveyance infrastructure by 27 percent and that Site No. 8 would also avoid any construction at all in the intersection of South Bristol Street and West Segerstrom Avenue. The two factors would result in a significant decrease in the impact on traffic and transportation. The RDEIR again includes a long description of how difficult it will be to construct a sewer and force main along South Bristol Street but fails to note that the proposed project includes 190 -feet of longitudinal sewer in South Bristol Street. 55A -161 Mr_ Robert Silverstein, Esq_ 0 0 Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 13 of 18 The RDEIR gives Alternative Site No. 8 credit for a reduction in the duration of construction of four days. As discussed elsewhere, using sites other than the proposed site would avoid having to construct the temporary sewer bypass and relocate the SCE power pole, which would shorten the duration of construction by at least four weeks. The greater amount of space and the better access to the pump station in Site No. 8 would result in even more reduction in the duration of construction. The RDEIR also concedes that Alternative Site No. 8 would have a reduced potential to expose nearby odor - sensitive uses to substantial offensive odor levels. The RDEIR notes that construction of a pump station at this site would result in a deficit of only three parking spaces after the project is completed, which is a very minor impact. 5.4.10 ALTERNATIVE SITE No. 12 Alternative Site No. 12 is located in the parking lot of a medical building located at 2701 South Bristol Street. The RDEIR concedes that the use of Site No. 12 would reduce the length of the underground sewer conveyance infrastructure by 42 percent but asserts that it would result in an increase of two days in the duration of the construction. This assertion is based on the specious presentation about the difficulty of construction in South Bristol Street. The construction schedule for the project allows four weeks for the pipeline work, including the 190 -feet of gravity sewer in South Bristol Avenue. Any increased difficulty of working in South Bristol Street would very likely be offset by the 42 percent reduction in the length of the pipes. Even if the much shorter length of pipeline work took the same four weeks as the pipeline work in the proposed project, the traffic disruption of four weeks in South Bristol Street would be far shorter than the 25 week lane closures in West Segerstrom Avenue. As discussed elsewhere, using sites other than the proposed site would avoid having to construct the temporary sewer bypass and relocate the SCE power pole, which would shorten the duration of construction by at least four weeks. 55A -162 Mr. Robert Silverstein, Esq. 0 Review Of The Recirculated 9! And FEIR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 14 of 18 Moreover, because the sewer to Alternative Site No. 12 and many of the other sites would not significantly interfere with construction of the pump station itself, the construction of the pipeline infrastructure and the pump station could proceed simultaneously. This would reduce the duration of construction by another four weeks. The RDEIR also concedes that Site No. 12 would also avoid any construction at all in the intersection of South Bristol Street and West Segerstrom Avenue. This significantly decreases the impact on traffic and transportation. The RDEIR again includes a long description of how difficult it will be to construct a sewer and force main along South Bristol Street but fails to note that the proposed project includes 190 feet of longitudinal sewer in South Bristol Street. AN ENVIRONMENTALLY AND ECONOMICALLY SUPERIOR PROJECT At the top of Page 2 -8, the RDEIR states as a Project objective, "[tjo provide a lift station facility in which electrical components of the facility are housed above ground so as to preclude the potential for electrical failure during peak storm events (due to flooding)." This Project objective is not met by the new design. Drawing 14 of 49 for the proposed pump station shows that the motors of the new pumps are far below ground level in the dry pit. If there is a break or leak in the discharge piping during a power outage when the sump pump is not in operation or a break or leak of a magnitude that exceeds the capacity of the sump pump, the dry pit will flood and will ruin the motors. This means the proposed pump station is no better than the existing pump station at meeting this project objective. An environmentally superior project would be to construct a submersible pump station, using the existing 8 -foot diameter wet well. Attached are three pages from the Flygt Pump Company showing a typical submersible pump station and the dimensions of a submersible pump. See Exhibits E through G. Submersible pumps have the motors directly connected to the pumps. As the name implies, the pumps are submersible; that is, they are sealed and therefore can and usually do operate underwater. The submersible pumps slide down guide rails into the wet well and then connect to the discharge piping at a base fitting. The pumps can be hoisted out of the wet well for service. Since all of the work on the pumps can be done at ground level, there is no need to enter the wet well, thus confined space safety is not an issue. 55A -163 Mr. Robert Silverstein, Esq. 0 0 Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 15 of 18 This arrangement provides ample access space for maintenance and thus meets (and exceeds compared with the proposed project) the second project objective listed on Page 2 -8 of the RDEIR. An additional advantage of a submersible pump station is that the pumps can be fitted with grit -flush valves. The grit -flush valve is mounted on the side of the pump and allows much of the flow from the pump to squirt into the bottom of the wet well for a few seconds each time the pump starts. This stirs up the grit in the bottom of the wet well, which allows the grit to be pumped away. The maintenance records that were provided show that from time to time the City hires a contractor to pump grit and debris out of the bottom of the wet well. The grit -flush valves would reduce or perhaps even totally avoid this recurring cost, thus benefiting the City and its residents as compared with the design of the proposed project. Another advantage of submersible pumps is that because they are submerged, they cannot be heard, There is no noise impact, thus benefiting the City and its residents as compared with the design of the proposed project. The electrical control panel for the submersible pump station would be above ground at the back of the sidewalk, exactly where it currently is for the existing pump station. The existing pump station has two pumps, each rated at 2,600 GPM at 29 -feet total dynamic head (TDH). A submersible pump station alternative would include three submersible pumps, each rated at 1,300 GPM at 29 -feet total dynamic head (TDH). Two of the pumps would handle the peak flow. The third pump provides redundancy. A performance curve for a Flygt NP3153.181, MT, Curve No. 63- 435 -00 -4530, 217 mm impeller pump is included as Exhibit H. This pump has a capacity of 1,310 GPM at 29.30 -feet TDH, i.e. each pump has half the capacity of one of the existing pumps but the new pumps can still produce the same discharge pressure. If it is decided that the proposed hydraulic capacity of 2,600 GPM is in fact inadequate, similar submersible pumps are available to provide a higher capacity. At the bottom of the Lift Station Dimensions page (Exhibit E), it can be seen that the centerline to centerline spacing between the selected Flygt pumps is 24- inches (twice the PL dimension of 12- inches), thus three of these pumps can fit in the existing 8 -foot diameter wet well. 55A -164 Mr. Robert Silverstein, Esq. 0 0 Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 16 of 18 Exhibit 1 is a photocopy of a part of Sheet 4 of 49 of the plans for the proposed pump station. (Figure 2 -11 of the RDEIR). it has been marked up to show what the superior submersible pump station alternative would look like. There would be three submersible pumps in the existing 8 -foot diameter wet well. The new facilities would include a valve vault in the sidewalk with a hatch cover. Work on the valves thus would not have to be done in the street. Both the 19605 and the 1989 pump stations had similar access hatches in the sidewalk. A submersible pump station is not only environmentally superior to the Project, it is economically superior. The estimated cost of a submersible pump station is presented in Exhibit J. The total estimated cost is $748,000. This is less than a quarter of the estimated cost of the proposed pump station. Construction has just ended on the Secline Pump Station for the North Tahoe Public Utility District. I was the lead design engineer on this project. In this project a new circular wet well was placed in an existing rectangular wet well, four submersible pumps were installed in the new wet well, a valve vault and piping were installed to connect the new pumps to the existing force main, and an underground pump station was abandoned. This is similar to a submersible pump station that could be placed in South Bristol Street. The cost of the Secline project was $750,000, which confirms that the cost estimate in Exhibit J is reasonable. Not only is the submersible pump station alternative about four times less costly than the proposed project, but it also can be done in only a fraction of the time. In the Secline project, the contractor was on site only five weeks. That, in turn, means that environmental impacts of the proposed project would be mitigated or avoided, including but not limited to traffic, pedestrian safety, and noise. The submersible pump station alternative is clearly a potentially feasible alternative. it should have been fully disclosed and analyzed, preferably as part of a recirculated RDEIR, so that the public, other public agencies, and decision makers have a full and fair opportunity to review and comment on it. 55A -165 Mr. Robert Silverstein, Esq. 0 0 Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page W of 18 Conclusion The descriptions of the existing facility in the RDEIR and the FEIR are flawed, creating justifications for the Project where none exist. Moreover, the alternatives analysis is equally flawed. CEQA Guidelines Section 15126.6(f)(2) says the "key question and first step in analysis is whether any of the significant effects of the project would be avoided or substantially lessened by putting the project in another location. " A site, such as Altemative Site 2, that avoids lane closures on Segerstrom Avenue for approximately six months, will significantly reduce the Project's traffic impacts, thus meeting the "key question and first step in analysis" under CEQA Guidelines Section 15126.6(f)(2). Many of the other alternative sites would also similarly reduce the impacts. Finally, the RDEIR and FOR are fatally flawed because they have not included the obvious alternative of rehabilitating the existing pump station as described above. Very truly yours, Bonneau Dickson, PE Mr. Robert Silverstein, Esq. ! • Review Of The Recirculated DEIR And FEIR For The San Lorenzo Sewer Lift Station Project January 12, 2012 Page 18 of 18 Exhibits: A. CWC -HDR Drawing 6 Of 10 For The 1989 Project, B. CWC -HDR Drawing 6 Of 10 For The 1989 Project. C. Invoice For Rehabilitating The Pumps In 2007. D. Email From Gorman Rupp Saying Parts Are Readily Available. E. Typical Lift Station Plan. F. Typical Lift Station Section. G. Submersible Pump Dimensions. H. Performance Curve For A Suitable Pump For The Existing Segerstrom Pump Station. 1. Submersible Pump Station Superior Project. J. Estimated Cost Of A Submersible Pump Station In South Bristol Street. K. Construction Schedule For The Proposed Project. 55A -167 i EXHIBIT A 0 A;Lllw• �w ow F w° w �-x I / I� w .d z w Q O V N z ° a az. Q - w �o w IM _ o o f 14, 0 , !� �- u, z o z Q � � � �w 4 i m F xl `i' Io 0. W = C Of u.11. Id h- cn ' b3.Lf w F-- M W W In }� rm0 /I 1:/ i I/ 4• �3 .W z a J A W z CL a U � _. UJ Q [L = t3 �w� U �.JJIU ms { I� I W { z z J J in z 55A -170 1 CJa «._1 0 U) x in V ul cc Co. CL T- Y 0 a LL 0 to C) ee� oG D Q d K w { F A f `d3S -- } f } ti d I x f z �,-•. E w z { o a � m -- � h � i � N � I ¢ I � U v7o +V'b.LS � I �w ow F w° w �-x I / I� w .d z w Q O V N z ° a az. Q - w �o w IM _ o o f 14, 0 , !� �- u, z o z Q � � � �w 4 i m F xl `i' Io 0. W = C Of u.11. Id h- cn ' b3.Lf w F-- M W W In }� rm0 /I 1:/ i I/ 4• �3 .W z a J A W z CL a U � _. UJ Q [L = t3 �w� U �.JJIU ms { I� I W { z z J J in z 55A -170 1 CJa «._1 0 U) x in V ul cc Co. CL T- Y 0 a LL 0 to C) ee� oG D Q d K w I* EXHIBIT B 55A -171 - ACCESS TUJ } Ask EXIST '7UMP STATION EX157 WET WELL MANHOL 8-FOOT DIAMETER ALL 1960s EQUIPMENT REMOVED PLAN N 7S. EXISTING BRISTOL PUMP STATION DEMOLITION DETAIL OF Cl EXHIBITS. CWC -HDR DRAWING 6 OF 10 FOR i'HE 1989 PROJECT. 55A -172 0 EXHIBIT C I* 55A -173 L_ L Y 0 LIPN46v� _GLU I,Y_FpL00 -` FAUt 01/d1 i W4 v► CRMMNAL' INVOICE "1t RAN GE -COUNTY, PUNP 0. ss`` car 0ft0b4'.... ,24th 2 {{�� 0 0; 1310 N, Harbor Stva, s Santa Ana, Califon fle 92703 1 .a 554 -1722. J800) 440- PUrnt= { .FAQ (714) 554-&02 2220 S. Da se AVeP Ra tft Ana., &ufa is $2703 �l5 If. 7H 3 ; .p T ,ty , ouAmrinr o� dR TNs • DRucE . . GO n Rupp blade; Ti OR3 -B is I D188aisenble a a sssg all p d motor RAC _ baQ •,ER9110 I�OWian •p �REEd".i tB4 ,, r aa' Leave ;Lh o . working i rdet. ids �tslt g $ ls1�I end r :�:,. •.:.ssztv'ic� , vase;rat a � tis�e � ; 2 4510 -A GtM{ seal -. sSOMblf 2 381684 -302 G'R .94al plate# assembly 2 6- 169 •ba bear' t 3 #2:9 685 2 Z4 ?.3 -43.3 I 4'. 159I7 -6i sew.R._ - -.__ 43.96 ... f► 1 r M AL _ WORK COMPLETEI 2 -1-07. 4 an eewtty , n dprr r lac p.► ".ft Yli " CM.tpa wx a* :ddt:d r ! 1A�N N10pl18' i.°!lr?tPl ff` ?F'pE71 "n rMAL 7MA6 TAkmt" 2 t:5 op- r4pair i b -pumv #3 ' ifr �,,,�f10. ?30..44. SAMS n0e X 3 4.0 RT4&0 ST install #1 & t T30 .00 3 325.00 $BG:Ot} '3850 -.:Ot1 3 3.S ► t t 1T' 2'•G.ring t � �s�efla :00 210. DO .770.00 �t nMr t 4.5.00 .t 2 3 Z.S.��ar 0 2 . }a -ins 0. -�D 32 .5. GG 880-00 INVOICE TOTAL 62{8.40 2 . 865 4.0 drd$T.recair .?, tea crec% .22jo -.a . i J ,.- TOTAL LABOR ieceived by. Tt1ank -You, .rt rwVt. and thorlego mwi as mom wVA% S dan anw 6466 at ypg* : Urwim short* on Post due oe"W00- -t7: 061 inedt w IM tVolditfp, demo * on py.. wo"a Me+etlotta4a, Me to DOO6t tlfM V6d In n1w W1w1 4"m V=hab rpm-y R poW M each, Otnd- to d~:01 jWn#N CI MqXMgy. MiN `" tsMOr�- duel. 4041_ M *►►tit Out_" eceeawd A"ifo .. tlM�wrq •tend M M1 n+* ww CRT -t* NNtp.1.-woesodnye: Dutena -. Q9 tp Pay wotoftt& alkltNy �N and Ge.wt colt. EXHIBIT C. INVOICE FOR REHABILITATING THE PUMPS IN 2007. 55A -174 11 le EXHIBIT D 55A -175 Gmaii - Gorman Rupp Model TO -B information 0 Page 1 of 9 Bonnesu. Dickson 4dickson.bo»ne =ujfttni1l corn Gorman Rupp Model T10A3 -13 Information 6 messages Suzzane Thomas <sthomasQthomaspumps.net> Mon, Oct 31, 2041 at 4:43 PM To_ dickson.bormeau@gmail.com Good Afternoon. We are the Northern California reps for the Gorman Rupp Company and have been asked to respond to your inquiry about your clients T10A3-B pump. This model is still in production and parts are readily available. A budgetary estimate for a new pump would be around $11,000 not including freight or tax. The replacement rotating assembly would be around $5,000. This is a very rugged pump and we have many units still in service after 30 years. The iaVartant thing is that the casing registered fits are still Intact. If the casing Is in good shape ar replacement rotating asst': would be all you Would need. t could arrange for my Southern Caftmia counterpart to go to your clients location and inspect the pump and make a recommendation if you would so desire. Please let me know how I can be of further help in this matter. Thank you for your Interest in Gorman Rupp Pumps Regards Suzy Thomas Thomas and Associates EXHIBIT D. EMAIL FROM GORMAN RUPP SAYING PARTS ARE READILY AVAILABLE. http:ll mail .google.comlmaiV ?ui= 2 &ik= 3048f3 lcl g &vier —pt &search- inbox &th =1335bb$... 1114/2011 55A -176 I* EXHIBIT E I* 55A -177 i ITT FP {N P -3153 ' Water &Wastewater ? Lilt Station Dimensions Iss;nued: zro9. Supl. odes. ZW p NOTES: 1. CONFIGURATION AND DIMS- WOWN ARE SUCGESTM REOUIREMENTS ONLY, ALL DETAILS. INCLUN14C 3. LOCATE ANE14OR I3OL:TS USING INSIDE EDGE OF CLEAR OPENING AND PUMP CENTERLINE AS SIZING OF PIT, TYPE. LOCATION AND ARRANGEMENT OF VALVES AND PIPING, ETC. ARE TO BE SPECIfiED REFERENCE POINT, BOLT LOCATIONS MUST BE HELD TO MAINTAIN CXACI POSITION OF PUMP TO CLEAR BY THE CONSULTING ENGINEER AND ARE SU64CT OPENING. TO THEIR APPROVAL- 2. 2. REFERENCE GENERIC DUPLEX LIFT STATION LAYOUT ITT FLYCT 181X -FU35H HALVE. FOR ELEVATION VIEW, --1 B i simplex C, PIT Duplex �Pf i TF r - T oU 0U c� IR`.i�l`:l� All RlljFNl IA MC iDt I&I 1k1f -LJVC I-! W 4� 1- -ilY 1 I TY f- MIN. `, _- t - I ! ANN, v. � MIN. V ��P MIN. Y Mlsl. 1 ZAE—W TOP VIEW A c>,aR a NlNG REF. POINT 3 � REF U. ANENpft� POINT Oi..T (4x.) /�r- C A "— r PIT BASE 9EGTK7N 1 �L.._ ? - 4- � 1 —5-PIT, PUMP & UPPER D CUIDE BAR --1 B i BRACKET PIT BASE SECTION IR`.i�l`:l� All RlljFNl IA MC iDt I&I 1k1f -LJVC A "— r PIT BASE 9EGTK7N EXHIBIT E. TYPICAL LIFT STATION PLAN. 55A -178 i° ANCHORS BOLT (8x) PL TYP_ Ii PIT j PUMP ANON UPPER WOE BAR BRACKET 7YP. Ea W� ►1� IR`.i�l`:l� � #�.1� ®��,i.L7 �� � ®{6:t 7!(2J ��P W�A W �) t'r i »ii��3� ®ii]E�1�1�7 ®�l�mQ#l�m ®€s E�i�3 t►T�i�it�R'i ®7t�i�me���mi ll[�1i �Li "li E_ 7 EXHIBIT E. TYPICAL LIFT STATION PLAN. 55A -178 i° ANCHORS BOLT (8x) PL TYP_ Ii PIT j PUMP ANON UPPER WOE BAR BRACKET 7YP. Ea 0 EXHIBIT F 0 '� 55A -179 0 0 Generic Duplex tuft Station Layout e- Catalog >r Lift Station Guide Lines Issued: Qft I Supersedes: W05 ITT FLYGT PUMP CONTROL PAMEL ITT FLyyYGO7 -UPPER �S$ACOVEP !~ BAR BRACKET SHUT OFF VALVE 1 IIr-CABLE HOLDER., .. . GROUT I VENT PIPE J f ITT FLYGT I ITT FLYGT y l SAFE HATCH GROUND EL. 1 5087 BALL 1 j ACCESS COVER],' I; FT__!N Z CHECK VA L VE _ GROUT =1 I I--7I 4 ill` �I �! LEVEL SENSQR �T ,I HIGH LEVEL a + r ALARM __F T_ .SIN INTERMEINATE GUIDE BAR BRK7, , (USED FOR GUIDE BARS OVER 20 FT. LONG) 41 ~ .LAG PUMP ON __177__10 :11\/ REINFORCED< T CONCRETE PIPS JV + �- LEAD PUMP ON�, fTJN DISCHARGE, CONNECTION I GUIDE BARS (NOM. SIZE) �I I �I d l e _PIPE _ FT_ ,IN 80'I& I PUMPS OFF •_•_FT__IN a a BASE ELEVATIOif — . __FT__IN Q NOTES: 1. COVER SHOWN IS A STf1NDARD DUTY SAFE 4, 60- RECOMMENDED. HATCH WITH ANGLE FRAME. FOR DIMENSIONS ON 5. OTHER MATERIALS AVAILABLE. CONSULT ITT FLYGT. ACCESS COVERS PATH SAFE HATCH OR WITHOUT g, ITT FLYGT LIQUID LEVEL CONTROL MON7?IORING SAFE HATCH A5 WELL AS HEAVY DUTY OR OTHER SYSTEM. TYPES, CONSULT ITT FLYGT. 7. GOOD DESIGN PRACTICE DICTATES THAT 2. INSTALL ACCESS COVERS PER MANUFACTURER'S INFLUENT PIPE ELEVATIONS HIGHER THAN LWL. INSTRUCTIONS. SHOULD BE AVOIDED DUE TO RISK OF AIR 3. MIN. LIQUID LEVEL MUST NOT FALL BELOW TOP OF ENTRAINMENT, UNLESS SPECIAL. ARRANGEMENTS VOLUTE. ARE MADE. EXHIBIT P. TYPICAL LIFT STATION SECTION. 55A -180 F' 0 EXHIBIT G I* 55A -181 • REF-LINE 292 • f r 31 171 REF.LINE, 2 4j —7- 2" GUIDE BARS �� ry v MIN LEVEL 41 REF'.LINE .� VIEW Q U YJ Ncn� ♦4I ' BOLT_ 0j (4x) O UI * DIMENSION TD ENDS OF GUIDE BARS I�no Dimensional dr-wg AUrOCAD f NP,FP 315.3 MIT DRAWNG 1*6 " ; UVEI ht'(lbs,' Pump D-sch' EXHIBIT G. SUBMERSIBLE PUMP DIMENSIONS. A I IS EXHIBIT H 0 A;t" OOK Pip) to 16 ui 14 ? i2 a 10 8 2 DM42O1NT F(Opp i16AO[lq pong pp) EFF.1%] NPS%vpq C JARAN EE Q I Isla 29.30 18.6 414.71 SBA (M3) ' 223 S.E.P. 961 4147 65.5 174.5) 22.9 NI "A NPSHre 111w p I THE PERFORMANCE CURVE NP3153.1 81 MT DATE PROJECT CURVE HO ISSUE 2011 -10-31 6343"0-4530 5 1h -LOAD 314-LM It2 -LOAD RATED err NPILLERDU11W@W POWER K4c7zR .0.77 0.85 Sl' WEA 15 hp 297 mm EFF"NCY LOI-182 5 % 89.596 984 �NEJ47 ... 114 A 6107ORN CTAYM R£Y MomR DICTA - — — CkMENT ... 19 A 21 -15-4M OMER 91 Cm%wAT4 14tETMTLET RATED IoT 1755 r PREL>L PifASEa YdLYAO PoLm 4 G inch c� 60 Hz 3 460 V` 4 rrr�r IMF. TnRoumiLer IN M -. 0.0.72 kgm2 agARYWE. RAT�p -- auoes 2 r Pip) to 16 ui 14 ? i2 a 10 8 2 DM42O1NT F(Opp i16AO[lq pong pp) EFF.1%] NPS%vpq C JARAN EE Q I Isla 29.30 18.6 414.71 SBA (M3) ' 223 S.E.P. 961 4147 65.5 174.5) 22.9 NI "A NPSHre 1 r EFF. N go 70 40 3 10 +° 0 400 Boo 1200 1600 2000 [l% pm] FLOW LL NPSWe a KPSH3% * Min. opecelfwal merWn GUARANTEE BETWEEN UOTS (a0) ACC. TO P6Aorrrw" VAM dear water and ambient temp40'C H i level A EXHIBIT H. PERFORMANCE CURVE FOR A SUITABLE PUMP FOR THE EXISTING SEGERSTROM PUMP STATION. 55A -184 err r� r r ���r�rrs�r rrr�r �rrr.�,��r�r►.�rrr . �rr■�rr���,rr�r■rrrrr , �rr�,.r �rr�■rr a�arrrrra��.�!r� ■r�r.r�rrrr�r►�� rr , 1 r EFF. N go 70 40 3 10 +° 0 400 Boo 1200 1600 2000 [l% pm] FLOW LL NPSWe a KPSH3% * Min. opecelfwal merWn GUARANTEE BETWEEN UOTS (a0) ACC. TO P6Aorrrw" VAM dear water and ambient temp40'C H i level A EXHIBIT H. PERFORMANCE CURVE FOR A SUITABLE PUMP FOR THE EXISTING SEGERSTROM PUMP STATION. 55A -184 18 EXHIBIT 55A -185 wW 0 W z 0 a a a J CG D M� lilt 4. a cc W m 1 z z 0z z X0 v cu x z z 0 _ 1 Z CL za) , Z i as z r, O V tL 55A -186 _ a in C- a LLJ J � 0 EL y W `.1 I y w O h. g �-Ilea Asa w+� 4 J v� 9z, O u r N LL Q a �i Z n N N z. 0 EXHIBIT J 0 55A -187 Te DLO �0 :0 CO g0L ¥NC ;0000 CO) CM W) » I- Cf) _ 3 L § ui � R d, 2' W k � k � , ! ' z m (0). z CL CL �j � • $ col. . m; '» $ ,2 K © L a ~ LL. $�t 0 : v O. 2 § .a C . § ti ■ . I k \�0 0 W � ■ - M i 222 ■ @. c La ■ m \ a, IE$£;��_ . E �R '� Q , 0 222 E § © CL > §§�. a a I : a ■��c�7�� $= o ■ 0 ' & ,ƒ § _ .> '0 E22mEa2� ®§ CD �� m:2 = c e ®■ .0 (1) o c o > <;MW @n :w @ Q . / �o q n It q o & : ; 0 ,ca Te DLO 4) EXHIBIT K 19 F- LL Z Q U 0 U L� 2m pa Na w y. m a=. a U. 00 2� �O �W z ff O LU 0m QQ O WW lam- 4 a.. �oY ula u >W w irau 1-W U) 06< 4 of .Z o -a1L ... i J s J ti ti E? 2.� lift 33 ; d t 3 q K sIIs JE Z 3oa fj _o �r W W� L: 0 0 W a Z Q. 0 t W ~. 0 zN O W W Q) Lu LU LU O U. 0 }rr iii k V f5o m Co. — O r � H CL WE iF-R �v az°0 ZI a� v°o Pq 3 a�ca 19ZW 0 yj �NW t�. tli W d LL. �Fym �4aW F CO N HUM carom V LU w 0. W 0 0 LU a OC 0 LU 1 ca a Q 0 1- m 11% * M EXHIBIT 2 40 55A -191 Ar-I .7N 'Im TI Vv%F �J L ---------------------- 55A -192 IL jAJ Aod. LVA J f J)t- i hx 4r- i ILI Ar-I .7N 'Im TI Vv%F �J L ---------------------- 55A -192 I I 0 1 I I I I I I 55A-1 ",qlat parts of"uipfwlv ovohlw., Ypm7aMo AT cn-, t e- K;r-e- Ax -5--e OK Lelwl, 4 7�A 55A-1 qe-- ?44 7,r /-c. ----------------- 55A-1 pal Z - ar,- So-6 c,&, Aim; r;fjop What Dart -f FP X C4 I c Alor 6c-pq rH t-Gar s- 'L-4 55A-11 IC VA c 14 fbS 55A -19 wn4t Dar— v eva LL -------- Q &sj t L7 irf T �J U 55A -19 i i J Js I { 1 Ii I - - 55A -196 i = Dptr+atc�r(s): What aal:W [2--C-091 L[.q,Pin. c (� & V-r `p i k' cNay - ,'d. -L- E--2 -T 0 a• �e i' LZ I i tj�D rltALL- SAC-72 Fio)ct— 04-, i IA, K 7 tor'�, Jigl UA MEM cNay - ,'d. -L- E--2 -T 0 i4L-cW /I4-.� I rltALL- SAC-72 Fio)ct— 04-, 9A4 tj If MEM OUIA- 1 zlzl 15 74-yt�,T F4 Al 12— Act 49 A6 �s Z9 in 09 If rm rm A A 0% 0% OUIA- 1 zlzl 1 ,VAR 9 r _ r" (v • �7c7 vu i . TIVV 9 r _ r" (v • �7c7 vu i . �IIlL�7 SL'' TIVV a. +5 i i 4/00 'tr e� a Or 2 �IIlL�7 SL'' io � nl 4 i r Ci►'� LM.� d . I2 - 2 - ! 0 i I� -�crc` Su•�1- ?' tw►.�+U C Q - zul r a d•{�- - Noi.7� L �l uDk— . ;o _ r+P CtG ,4„� I.kr /� ®;{t �ic6t7�S c-K J- ►�U�l� - &LUGA S LJ C— i ALL �tD 7F. t 12—' _ IV Acio l T S 2Lac �LLltt? r Ci►'� LM.� d . 4L- I I U- U-i- lAt - cS 19 t.-C, , r 1 13 13 t cm,. ak 1 Q o. Li Mlll -� 1 R lie e � � r r r 14 zllkol 610 Sic ref-n 4- �t-v, -x L (ark, (:aAeR lb 41 60.1 17 9A Cs 3�2 AL t u jo; 04 V.A 11twX) Ali Z, MA? gy eln131 15 0. , ? ( /)J, #,4f lwx amfon or 1 A fJ 6 fr � JCr� i a i ;'.- .;`•.. CD \ rJ. If I IM f A 1 -'2-4' .L /a -3 CI R 20 Ir /) 77,E 3 Pill IL/ LdC nV V y Iav �t h ru 1 hC 60"+- k 'oU Ole. CCA 01A07 &b'��'��l�ati. I 1� 17 ti 4a� b "7Y ■ tam CA( f t C L&A f- 5 -z9- 'Orr- () Qk c1 yw f t C L&A f- 5 -z9- 'Orr- F �F , �P.� ►,cce� av Alo rIA o,+7 I/ cv le" cleb {ct r 55A -210 LIM �,I MROL 1 �►L . r i v L• OM.1�/ r r r. f r' RMt MIT MORMW *► _ y . - ..r . 1 tj, '► r �I r _ j I I I 20 (L ),,.,EJA UUM-AL I AL - I "--v FrL- I!.' uin C, C, U u VU UUM-AL I AL - I .l_ tia IM I Ol.— A 'GA �lt.11j .-i 21 iALJ A '/ )=Y- Cl viol vi-, ol-A OT �C/,�!Aj L.AA-% h,- IA"-D. 22 e F1 z i r . w-7 Nor�ln C, F v 23 eal r �S its 1 .1 1 to a� I � � �S �l t�j t� . le 1w- 55A -216 10 EXHIBIT 3 40 55A -217 0 THE SILVERSTEIN LAW FIRM A Professional Corporation October 10, 2011 VIA FACSIMILE (858) 755 -7874 AND U.S. MAIL Dennis W. Daley, Esq. Daley & Heft, LLP 462 Stevens Avenue, Suite 201 Solana Beach, CA 92075 • 215 NORTH MARENGO AVENUE, 3RD FLOOR PASADENA, CALIFORNIA 91101•IS04 PHONES (626) 449.4200 FAXe (626) 4494205 ROBERT@RoBERTSn vER.,-,mlNlAw.coM wW WAOEERISILVERSTETNIAw. coM VIA FACSIMILE (714) 647 -6515 AND U.S. MAIL Jose Sandoval, Esq, Managing Senior Assistant City Attorney City of Santa Ana City Attorney's Office 20 Civic Center Plaza P.O. Box 1988 Santa Ana, CA 92702 Re: California Public Records Act Requests San Lorenzo Lift Station Project Dear Mr. Daley and Mr. Sandoval: This request is made under the California Public Records Act pursuant to Government Code Section 6250, et seq. Please provide copies of the following from the City (as "City" is defined below). For ease of reference in this document, please refer to the following defined terms: "City" shall refer to the City of Santa Ana, the City of Santa Ana City Council, and all City of Santa Ana commissions, boards, offices, departments (including the city attorney's office and outside special city attomeys), officials, employees, consultants, and agents. "Project" shall refer to the San Lorenzo Sewer Lift Station Project. (1) All maintenance logs, repair reports and other documents related to maintenance and repair of the Segerstrom Lift Station from January 1, 2010 through the date of your compliance with this request, including but not limited to correspondence, emails, attachments to emails, correspondence, administrative drafts, staff reports, studies, photographs, memoranda and internal memoranda, agenda items, agenda statements, notes, photos, diagrams, schematics, and plans. (2) All documents and communications related to the attached excerpt of the Recirculated Draft Environmental Impact Statement for the Project that "the nearest sensitive receptor (i.e., hotel unit to the west is located at a distance of 55A -218 Dennis Daley, . Es q Jose Sandoval, Esq. October 10, 2011 Page 2 approximately 75.5 from the location of the proposed exhaust fan for the lift station facility, while the nearest residential home is located approximately 110 feet northeast of the proposed exhaust fan." I draw the City's attention to Government Code § 6253.1, which requires a public agency to assist the public in making a focused and effective request by: (1) identifying records and information responsive to the request, (2) describing the information technology and physical location of the records, and (3) providing suggestions for overcoming any practical basis for denying access to the records or information sought. If the City determines that any information is exempt from disclosure, I ask that the City reconsider that determination in view of Proposition 59 which amended the State Constitution to require that all exemptions be "narrowly construed." Proposition 59 may modify or overturn authorities on which the City has relied in the past. If the City determines that any requested records are subject to a still -valid exemption, I request that the City exercise its discretion to disclose some or all of the records notwithstanding the exemption and with respect to records containing both exempt and non- exempt content, the City redact the exempt content and disclose the rest. Should the City deny any part of this request, the City is required to provide a written response describing the legal authority on which the City relies. Please be advised that Government Code Section 6253(c) states in pertinent part that the agency `shall promptly notify the person making the request of the determination and the reasons therefore." (Emphasis added.) Section 6253(d) further states that nothing in this chapter "shall be construed to permit an agency to delay or obstruct the inspection or copying of public records. The notification of denial of any request for records required by Section 6255 shall set forth the names and titles or positions of each person responsible for the denial." Additionally, Government Code Section 6255(a) states that the "agency shall justify withholding any record by demonstrating that the record in chuestion is exempt under expressed provisions of this chapter or that on the facts of the particular case the public i interest served by not disclosing the record clearly outweighs the public interest served by disclosure of the record." (Emphasis added.) This provision makes clear that the agency is required to justify withholding any record with particularity as to "the record in question." (Emphasis added.) Please clearly state in writing pursuant to Section 6255(b): (1) if the City is withholding any documents; (2) if the .City is redacting any documents; (3) what documents 55A -219 Dennis Daley, Esq. i ! Jose Sandoval, Esq. October 10, 2012 Page 3 the City is so withholding and/or redacting; and (4) the alleged legal bases for withholding and/or redacting as to the particular documents. It should also be noted that to the extent documents are being withheld, should those documents also contain material that is not subject to any applicable exemption to disclosure, then the disclosable portions of the documents must be segregated and produced. We request that you preserve intact all documents and computer communications and attachments thereto, including but not limited to all emails and computer files, wherever originated, received or copied, regarding the subject matter of the above - referenced requests, including archives thereof preserved on tape, hard drive, disc, or any other archival medium, and including also any printouts, blowbacks, or other reproduction of any such computer communications If the copy costs for these requests do not exceed $500, please make the copies and bill this office. If the copy costs exceed $500, please contact me in advance to arrange a time and place where I can inspect the records. As required by Government Code Section 6253, please respond to this request within ten days. Because I am faxing this request on October 10, 2011 please ensure that your response is provided to me by no later than October 20, 2011. Thank you. Very truly yours, BRADLY S. TOG , AICP FOR THE SILVERS LAW FIRM BST:jr r 55A -220 0 �� SAN i.oRENZO SEWER LIF1 ENViRONMENiA! IMPACT REPORT 3.1 AIR QUALITY i marginally detectable, ; -10 D/T is considered clearly detectable, but not yet highly offensive. When levels exceed 10 D,,7 and the odor is normally considered offensive, such as from sewage, a siMificant impact is presumed to exist, Odors may be released from the vents on a lift station and carried downwind. During the daytime, winds across the Project site are mainly from west to east and during nighttime, winds are east to west. Thus, any odor- sensitive development directly east or west of the lift station would be possibly affected by odors. The y distance extent of any odor "envelope" was estimated based upon normal and worst -case odor conditions. Tc estimate the odor level (in units of DPI') for a vent release of fresh versus stale sewage gas, an odor concentration of 30 DT was assumed for fresh sewage, and 2000 D/T for stagnant material. under normal operational conditions ( "fresh sewage "), the limit of marginal detectability (1 D /T) is 25 feet. The clearly offensive odor limit (10 D/T) is around 6 feet from the vent. No odor sensitive uses are located within 25 feet of the proposed San Lorenzo Lift Station; thus, impacts under normal operating conditions would be less than significant. During upset conditions with stagnant sewage in the system, the zone of clearly offensive odor would be around 75 feet from the source. Maintaining a distance buffer of at least 73 feet from the lift station to the nearest odor - sensitive property is anticipated to maimain potential worst -case odor conditions at less -than significant levels. The nearest sensitive receptor (i.e.. hotel unit to the west) is located at a distance of Mro7;imately 75.5 feet from the location of the nroposed exhaust fan for the lift station facility while the i nearest residential home is located approximately 1 0 feet northeast of the silepronosed exhaust fan. Additionally, effluent would be continuously moving through the wet well with a minimum retention tithe. As such, it is unlikely that any significant odors detectable above g ound will be generated. I However, due to the complexities in evaluating the sensitivity of nearby receptors to potential odor impacts associated with the proposed facility, and given the relative close proximity of the nearest sensitive receptor, i it is conservatively estimated that long -term operation of the proposed lift station may result in a significant odor impact for which mitigation would be required. i r Threshold 5.• Wouid the Project conflict with or obstruct implementation of applicable Air Quality Attainment Plan or Congestion Management Plan? Air Quolily Attainment Pion Consistency Analysis The Project site is located within the SCAB, which is characterized by relatively poor air duality. The SCAQMD has jurisdiction over an approximately 12,400 square -mile area consisting of the four -county Basin and the Los Angeles County and Riverside County portions of what use to be referred to as the Southeast Desert Air Basin. In these areas, the SCAQMD is principally responsible for air pollution control. and works directly with the Southern California Association of Governments (SCAG), county transportation commissions, local governments, as well as state and federal agencies to reduce emissions from stationary, mobile. and indirect sources to meet state and federal ambient air quality standards. Currently, state and federal air quality standards are exceeded in most parts of the Basin. In response, the SCAQMD has adopted a series of Air Quality Management Plans (_AQIVjPs) to meet the state and federal ambient air quality standards. AQMPs are updated regularly in order to more effectively reduce emissions, accotvmodate growth, and to minimize any negative fiscal impacts of air pollution control on the economy-. GAGS 55A -221 THE SILVERSTEINI&W FIRM 05 NORTH MARENGO AVENUE, 3RD FLOOR PASADENA, CALiFORNM 91101.1504 A Professional Corporation PHONE, (626)449.4MO FAX, (626) 4494205 FACSIMILE TRANSMITTAL SHEET DATE: October 10, 2011 FROM: Bradly S. Torgan, Esq. NUMBER OF PAGES: 5 Total CLIENT/MATTER S7015 -001 No.. NAME FAXN0, PHONE NO. Dennis W. Daley, Esq, (858) 755 -7870 (858) 755 -5666 Daley & Heft, LLP Jose Sandoval, Esq. Managing Senior Assistant City (714) 647-6515 (714) 647 -5201 Attorne MESSAGE: Please see attached. IMPORTANT: THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT 1S ADDRESSED, AND MAY CONTAIN INFORMATION THAT 1S PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, OR THE EMPLOYEE OR AGENT RESPONS78LE FOR DELIVERING IT TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT READING, DISSEMINATING, DISTRIBUTING OR COPYING THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE IMMEDIATELY NOTIFY THE SENDER BY TELEPHONE, WHO WILL ARRANGE TO RETRIEVE IT AT NO COST TO YOU. THANK YOU IF YOU DO NOT RECEIVE ALL PAGES OR TRANSMISSION IS NOT CLEAR, PLEASE CALL TELEPHONE NUMBER (626) 4494200 IMMEDIATELY. 55A -222 fFax header Information The Silverstein Law Firm 626 -449 -4205 Oct -10 -2011 02:42 PM .. �. Identification M • •• 3249 Oct -10 -2011 02:40 AM Send 17146476515 1:15 5 Success 55A -223 Fax Header Information The Silverstein _aw Firm 626 - 449 -4205 Oct -10 -2012 02:44 PM i Identification 3250 Oct -10 -2011 02:42 PM Send 18587557870 1:22 5 Success I 55A -224 MAYOR Miguel A. Pulldo Yt MAYOR PRO TEM Claudia Alvarez COUNCIL MEMBERS David Benevides Carlos Bustarnante Michele Martinez ierrto CITY OF SANTA ANA Sal Ti ajero Sal Tinajero OFFICE OF THE CITY ATTORNEY 20 CIVIC CENTER PLAZA W29 • P.O.9oX 1988 SANTA ANA, CALIFORNIA 92702 (714) 647 -5201 • Fax (714) 647 -6515 October 31, 2011 VIA U.S. MAIL Bradly S. Torgan THE SILVERSTEIN LAW FIRM 215 North Marengo Avenue, 3r° Floor Pasadena, CA 91101 INTERIM CITY MANAGER Paul M. Walters INTERIM CITY ATTORNEY Joseph A. Straka CLERK OF THE COUNCIL Marie D. Nuizar Re: Public Records Act Request Dated October 2012011 San Lorenzo Lift Station Proiect Dear Mr. Torgan: This letter is written in response to your request pursuant to the California Public Records Act. The City has now completed a thorough investigation for public records responsive to your request. In response to the request for information: (1) Enclosed is a grant application with attachments. (2) Enclosed is an email (with attachment) dated April 26, 2011. (3) There are no documents responsive to this request. This letter is intended to fully respond to your request dated October 20, 2011. Please do not hesitate to contact me should you have any questions or need more information concerning this matter. JSljmp Enclosures Very truly yours, JOSEPH W.FLETCHER CIT SE SANDOVAL Chief Assistant City Attorney 55A -225 55A -226 I* EXHIBIT 4 0 55A -227 Giroux & Assoses 1820 East Garry St.,62 Ph: 949.387.5477 Environmental Consultants Santa Ana, CA 92705 Fax: 949.387.5477 r 1AV January 12, 2012 Mr. Robert P. Silverstein Attorney at Law 215 N. Marengo Ave., 3rd Floor Pasadena, CA 91101 -1504 Subject: San Lorenzo Sewer Lift Station Dear Mr. Silverstein: At your request, we have reviewed the most recent air quality impact analysis for the above project. The previous analyses identified an odor impact distance of approximately 75 feet from the source to the receptor without substantiation as to the basis for the selection of such an impact distance. Our review concluded that if one accepts this impact distance, the nearest motel rooms at the California Lodge would be located within this impact distance. With apparent slight rearrangement of the site, the RDEIR now concludes that there is 75 feet and 6 inches of separation between the center of the exhaust fan and the nearest motel window. The conclusion is unsupportable or inaccurate for a number of reasons. There is no basis in the technical literature for lift station siting that supports 75 feet as an absolute zone of impact. Lift Station Design standards for public works agencies identify the importance of considering the relationship between a lift station and land use, but an extensive search of standards throughout the United States shows no recommendation of 75 feet as an absolute set -back distance. For example, a typical standard states as follows: Every effort shall be made in site selection to reduce potential for odor pollution. Wind direction, duration and intensity are all important considerations that must be evaluated. (City of Reno Wastewater Lift Station Design Standards, July, 2007) The RDEIR presents no supportable information that "wind direction, duration and intensity have been considered in the adoption of the 75 -foot "approximate" impact distance. To the contrary, authoritative literature contradicts the unsupported conclusion of odor impact distance in the RDEIR. Attached hereto is a scan of the cover sheet and page 1654 of an authoritative engineering manual, Wastewater Engineering, Treatment And Reuse, Metcalf & Eddy Inc., McGraw Hill, Fourth Edition, 2003. That treatise states that "Depending on the local meteorological conditions, it has been observed that odors may be measured at undiluted concentrations at great distances from the point of generation.... In some cases, odors have been detected at distances of up to 25 km from their source. This transport phenomenon has been termed the puff movement of odors (Tchobanoglous and Schroeder, 1985)." 55A -228 Gi roux & Assoses - Euvivronmental Consultants i A portion of the exhaust air will be directed toward the motel and a portion farther away. Some of the odor emissions within the exhaust stream will be much closer than 75 feet away from motel guests before they lose their momentum. Also, other motel areas, including a parking area immediately adjacent to the proposed Project where patrons and guests enter and exit their vehicles, are much closer to the exhaust fan and structure than 75 feet. Moreover, in sewage upset conditions likely to cause odor complaints, there is further a possibility that sewage overflow will generate odors over a wider area than the vent exhaust stack as it spills out of the station. We believe that there will be significant unmitigated air quality and odor impacts. However, the City's RDEIR and RDEIR have failed to adequately or accurately address odor impact conditions, potential mitigation measures, or alternatives to the Project. Hans D. Giroux Senior Analyst Giroux & Associates 55A -229 Fourth Edition g� y ew Metcalf & Eddy, Inc. m No. ism .; Revised by George Tchobo"oglous qp ` Pcofcssor Emeritus of Civil i}ni. Errvironmenwl Engineering CJltl �. University of CulifovthLi Davit: Franklin L. Burton 2421 Mwe &am LosA tax, Engineer �i � 94703 Los Altox, California , s H. David Stensel TEL (510) W. Professor of Civil and Environmental Engineering University Of Washington. Seattle r I I Boston Surf Ridge, IL Dubuque, IA Madison, Wl New York Sari Francisco St. Louis Bangkok Bogota Caracas Kuala Lumpur Lisbon London Madrid Mexioo City Milan Montreal New Delhi Santiago Seoul Singapore Sydney Taipei Toronto 55A -230 1654 1 .Chapter 15 Issuss itelajed a Treotment-plont Trinvthylamine (TNIA) is pre nt in the tud hale in man 9 � p y :utaert>bicaltj �- digested ilirdges. Trimethylarnine is ! um is in that it is salable below pli.9.bs 9i above•this pH level it is a gas rind can be: cowed into the air. Adding lime to di�Q sludge For odor control may, in fact, li rote Or 'by converting TMA to:a gas (NGa m 2001 `Murthy. 2001). SOMC pla may be u e to lamd apply dewatered sludge; becatnm of the, increased odor duction. Thus, itt ivaring processing and d)sp*,. options: the ramifications Of or gencyntion and con' t ave to be evaluated e�rafrily:< xs e Movement of Odors #seal S+ erslnowomr Treatment fay iffties u nit " Under quiescent meteorological eanditions, odorous gases that develop at fmatw000., o lnj factliticx tend to hO%'Cr over the point Of- generation (e.g:, sludge thickettin.g faciiiliES,; a sludge %torage lagnons), because the txkorous gases are roore dense than air. D:;a ' ` ;nt on the 1001 meteorolu ical conditions, it has been observed that otlerrs ma be mta ti cured at undiluted Loncentrations at .gtvat di%Wn es from the riot of genemion.. ti llowin9 events AMar to happen. (l) in the .evening or early morning hottts, ' quiescem-metencological condition,,. a cloud of odors will develop over the wart treatmem unit Ernie to the relea%e of odors; and,(2) the mmeantrated cloud Iof ods�ts. } then 'be .tr - srted 0.e., pushed ak;ng), without. GM,akin p g u , over great rs�tiRS ": . the weak mntn ctr roily rnorntng rrreaes, U Gy c ctp; .n some cases. WON _ been detected ur disttutccs of U m 5 V. fir cun rA�;r Iren„rua UMB cermea cne. P401, 'urerrl of odors (Tchbbanoglous and Schroed�r, The p*#'Inmvemenf. of on was first descciW by Wilson l The most Co method used to mitigate the effects of the odor pull' is to install baniers.:to indu bulenoe. thus break -ing vp and dispersing the cloud of concentrated radars, andjor wind generators to maintain a rni6isnum %'elocity across the source. 55A -231 55A -232 EXHIBIT 5 55A -233 • • CALIFORNIA NATURAL RESOURCES AGENCY C A l I F Q R M 1 A rVatr -w::k resources A G E N C Y FINAL STATEMENT OF REASONS FOR REGULATORY ACTION Amendments to the State CEQA Guidelines Addressing Analysis and Mitigation of Greenhouse Gas Emissions Pursuant to SB97 December 2009 55A -234 0 Parking L As explained in the Initial Statement of Reasons, the Natural Resources Agency concluded that the question related to parking adequacy should be deleted from the Appendix G checklist in part as a result of the decision in San Franciscans Upholding the Downtown Plan v. City and County of San Francisco (2002) 102 Cal.AppAth 656. The court in that case distinguished the social impact of inadequate parking from actual adverse environmental impacts. In particular, that court explained: [Tjhere is no statutory or case authority requiring an EIR to identify specific measures to provide additional parking spaces in order to meet an anticipated shortfall in parking availability. The social inconvenience of having to hunt for scarce parking spaces is not an environmental impact; the secondary effect of scarce parking on traffic and air quality is. Under CEQA, a project's social impacts need not be treated as significant impacts on the environment. An EIR need only address the secondary physical impacts that could be triggered by a social impact. (ld. at p. 698 (emphasis in original).) The Natural Resources Agency is aware of no authority requiring an analysis of parking adequacy as part of a project's environmental review. Rather, the Agency concurs with the court in the San Franciscans case that inadequate parking is a social impact that may, depending on the project and its setting, result in secondary effects. Consistent with exiting CEQA Guidelines section 15131(a), deletion of the parking adequacy question from Appendix G checklist will ensure that the "focus of the analysis shall be on the physical changes." Specifically, the Appendix G checklist contains questions asking about possible project impacts to air quality and traffic. Some comments pointed to examples of potential adverse impacts that could result from parking shortages, such as double- parking and slower circulation speeds, and referred specifically to a study of "cruising" behavior by Donald Shoup that noted that cruising could result in emissions of carbon dioxide. The relationship between parking adequacy and air quality is not as clear or direct as some comments imply. Mr. Shoup, for example, submitted comments to the Natural Resources Agency supporting the deletion of the parking question. (See, Letter from Donald Shoup, Professor of Urban Planning, University of California, Los Angeles, October 26, 2009.) In those comments, Mr. Shoup opines that cruising results not from the number of parking spaces associated with a project, but rather from the price associated with those parking spaces. (ibid.) The Natural Resources Agency also has evidence before it demonstrating that providing parking actually causes greater emissions due to induced demand. The California Air Pollution Control Officers Association CEQA White Paper, for example, suggests reducing available parking as a way to reduce greenhouse gas emissions. (Greg Tholen, et al. (January, 2008). CEQA & Climate Change: Evaluating and Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act. California Air Pollution Control Officers Association, at Appendix B, pp. 8 -9.) 96 55A -235 55A -236 0 EXHIBIT 6 0 55A -237 MAYOR Miguel A. Puhdo MAYOR PRO TEM Claudia C. Alvarez COUNCILMEMBERS David Senavides Carlos austamante Michele C. Martinez Vince Sarmie to Sal Tinajero June 16, 2011 0 0 CITY OF SANTA ANA 20 Civic Cemw Plaza • p.0. Sox 1988 Santa Ana, CaRomsa 92702 California Natural Resources Agency Bonds & Grants 1416 Ninth Street, Ste 1311 Sacramento, CA 95816 INTERIM CITY MANAGER Paul kVal M INTERIM! CITY ATTORNEY Joseph Straka CLERK OF THE CDUNCIL Maria D. Huizar Sub: Eco -Park Concept Proposal (Urban Greening for Sustainable Communities Grant) Dear Ms Escovedo, The City of Santa Ana would like to thank you for the opportunity to submit to your agency a Concept Proposal under the Urban Greening for Sustainable Communities Grant,' Attached is our concept proposal to develop an Eco -Park on a 1.25 acre triangular parcel located at Segerstrom Avenue, Shelton Street and Hemlock Way. The site is located in an urban area surrounded by residential, educational, commercial and industrial properties. A block east of the site is a Class 1 bike route that 1011 provide access to the site from residents citywide. The proposal is to develop an Eco -Park that will provide examples in ways to save energy, methods of water conservation, use of natural resources and to educate the public an the values of protecting the environment. Basic improvements will include drought tolerant planting plots of formal and informal planting, dry stream bed and water harvesting methods, solar panel installation, use of re -cycle and porous materials and education through interpretive signage and classes. We are excited and proud to submit this concept proposal and hope your agency feels the same as you review our preliminary application. Thank you for this opportunity and hope to hear from you soon. If you have any questions, please contact me at (714) 571- 4204 or Ron Ono, Administrative Services Manager at (714) 571 -4220. Sincerely, 0% Gei ardo Mouet Ex utive Director Parks, Recreation and Community Services Agency 1;� 0 EXHIBIT 7 0 55A -239 13anta Ana's General Fund Balance Dips to Just Over $300,000 - Voice of OC I Orange Co... Page 1 of 2 0 0 Santa Ana's General Fund Balance Dips to 3ust Over $300,000 ADAM ELMAHREK I Posted: Thursday, October 20,20119:22 pm Friday, Oct. 21, 20111 The city of Santa Ana is essentially living paycheck to paycheck, according to records released this week by the city's finance director, Francisco Gutierrez. Santa Ana's general fund balance at the end of September was $3I3,343.50, according to the records. This represents about one -tenth of 1 percent of its nearly $200 - million general fund budget. The balance has dropped precipitously since the end of July, when it stood at just under $3.4 million, records show. Then it dived to $161,035.46 by the end of August, according to the records. These numbers are the latest in a series of revelations in recent months showing Santa Ana to be teetering on the edge of insolvency. An August report by the city's budget consultants, Management Partners Inc., stated that the city has spent through its $41.4 - million unrestricted fund balance. The city announced in September that it is facing a potential $30- million budget deficit for fiscal year 2012 -13. "Simply put, the city must now take substantial action to reduce its spending," the consultants wrote in a cover letter to the report. Interim City Manager Paul Walters is supposed to release in January his first set of recommendations to close the deficit. Union leaders have indicated a willingness to reopen contracts. Yet it remains to be seen whether the city will act soon enough. The firefighters union hasn't proposed sufficient pay and benefits cuts, Councilman Sal Tinajero said, and the city has asked the Orange County Fire Authority for a proposal to outsource the fire department. City officials also acknowledged that they're leveraging internal service funds set up for special purposes, like payouts for legal settlements. The city transferred $5.2 million from those special funds to balance its books in September and is planning a $2.8- million transfer this month. That money will not be available again, according to the Management Partners report, and some of the special funds are already underfunded. Last week, Joaquin Avalos, president of the Santa Ana chapter of the Service Employees International Union, said the city was in danger of missing payroll perhaps as early as November. httP://www.voiceofoc.org/oc—central/,ulicle-9dgg)tic 160_8289- 001cc4c002e01t... 11 /3 /2011 Santa Ana's General Fund Balance Dips to Just Over $300,000 - Voice of OC I Orange Co... Page 2 of 2 Walters refuted that claim, saying in an email that the city expects to meet payroll obligations for the rest of the fiscal year. It is common for cities to run low on cash in the first part of a fiscal year as they await cash infusions in December, when the largest property and sales tax installments are paid to the city. Nonetheless the city's cash position has raised eyebrows among other government officials and is raising alarm bells among some members of the Santa Ana City Council. "I want answers if we only have $300,000 in the bank," Tinajero said. To put the Santa Ana situation in context, Costa Mesa Mayor Gary Monahan rang warning bells based on the fact that his city's general fund balance dropped to $5 million last November. Costa Mesa is one -third the size of Santa Ana. Orange County Supervisor John Moorlach, who is a former county treasurer -tax collector, said Santa Ana's situation is reminiscent of Vallejo's, the Bay Area city that filed for municipal bankruptcy in 2005. Vallejo had been leveraging all of its internal funds until there was nothing left, prompting the city to go bankrupt, Moorlach said. "It's when you're out of cash — and when your bank says, hey, we don't want to extend more credit — that's when you're really hitting the wall," Moorlach said. Tinajero and Councilmen Vincent Sarmiento and David Benavides said they would be making inquiries at City Hall. Councilwoman Michele Martinez said she asked Gutierrez about the city's cash flow after Voice of OC's post on the issue last week. She said she was told that the city is waiting for its large revenue disbursements at the end of the year and that the city would be able to pay all of its bills. But Gutierrez did not inform her of the city's low cash position, she said. "I believe we should have a reserve policy for times like these," Martinez said. Mayor Miguel Pulido and council members Carlos Bustamante and Claudia Alvarez did not return a reporter's calls. Correction: Due to an editing error, a pervious version of this story incorrected stated that the Costa Mesa's fund balance available was estimated to be $5 million by this November. In fact, the city's fund balance available was 35 million in .November 2010. We regret the error. Please contact Adam Elmahrek directly at aelmahrek @voiceofoc.org and follow him on Twitter: twitter.com /adamelmahrek. And add your voice with a letter to the editor. http : / /www.voiceofoc,org /oc_central /article 9UAa444e0- 8289- 001cc4c002e0.ht... 11/3/2011 55A -242